Representation on behalf of Thomson Homes in respect of Sunnyside, Strathkinness (LDP- STK001) Do you agree with the preferred strategy for the St Andrews Area? This Representation is submitted on behalf of Thomson Homes in respect of the FIFEplan Preferred Development Strategy for the St Andrews Area. Thomson Homes does not agree with the preferred strategy for the St Andrews Area. The submission made to the Main Issues Report for the development at Sunnyside, Strathkinness is for a major tourism development to serve the St Andrews Area, with housing in an enabling role to raise part of the investment to deliver the tourism project. Thomson Homes is promoting 6.9 hectares of land at Sunnyside, Strathkinness, on the south eastern edge of Strathkinness for a bespoke leisure development comprising an antiques and collectables centre with an arts and craft village and a micro brewery. This leisure development will be supported by residential development in an enabling role. Approximately 80 new homes for sale are required to cross fund the completion of this leisure proposal. There is currently a deficit in tourism provision in this part of Fife outwith the visitor destination of St. Andrews. It is also understood that there are concerns with the availability of the employment land supply in the St Andrews area. The Fife MIR confirms support for the need to deliver sustainable economic growth, and further states (page 33): ...The planning system has a significant role in supporting sustainable economic growth in rural areas. It indicates that a positive approach to new development can assist in creating the right conditions for rural businesses and communities to flourish. FIFEplan’s aim will be to enable development in all rural areas which supports prosperous and sustainable communities whilst protecting and enhancing environmental quality. This Preferred Strategy needs to be compliant with the Council’s aim to support sustainable economic growth in rural areas. Need for further housing land releases To identify the Preferred Development Strategy, the Council has undertaken an assessment of the housing land shortfall set out in Table 2. The Council has indentifies a requirement for an additional 20% flexibility (or generosity) to be added to the housing land requirement for both the St Andrews and North East Fife Housing Market Area (HMA) and Cupar and West Fife HMA. This is in accord with the draft Scottish Planning Policy (SPP). For Fife (TAYplan) the annual housing land requirement would be 384 homes (132 homes for Cupar and West Fife HMA and 252 homes for St Andrews and North East Fife HMA) The Preferred Development Strategy states that the housing land requirement for the period 2012-2024 is 4,990 homes for the Fife TAYplan area, with 4,780 homes already allocated in both Local Plans. This figure includes an allowance for windfall sites, small sites and demolitions. The consultation document states that land for a further 325 homes must be identified in FIFEplan. TAYplan Policy 5A requires that Local Development Plan (LDP) ...allocate land which is effective or capable of becoming effective to meet the housing land requirement up to year 10 from the predicted date of adoption, ensuring a minimum of 5 years effective land supply at all times, and work towards the provision of a 7 years supply of effective housing land by 2015, to support economic growth. Further, TAYplan Policy 5A requires that ...land should be allocated within each Housing Market Area (Proposal 2) through Local Development Plans to provide an effective and generous supply of land to assist in the delivery of in the order of 26,000 units up to year 2024 across TAYplan. Average annual build rates are illustrated. Therefore, time period under consideration for FIFEplan LDP is 2012 to 2024 and not 2012 to 2025. On this basis, FIFEplan Preferred Development Strategy should identify housing land requirement of 4,608 homes from 2012 to 2024 (384 homes per annum x 12 years) and not 4,990 homes as stated. The approved Housing Land Audit (HLA) 2013 provides evidence to support the estimate of effective housing land supply to adopt. Geddes Consulting has analysed the effective supply to 2024 with completions continued from effective sites from 2020 to 2024 based on the final programming assumption in year 2019/20. It is noted that in the approved HLA 2011 and HLA 2012, an assumption of 30 homes per annum is adopted for windfall calculation purposes. For the purposes of the housing land supply, only windfall sites should be included. The assessment below identifies the housing land shortfall for Fife (TAYplan) and therefore the scale of housing land allocations which the Council should identify in the Proposed Plan. Fife (TAYplan) 2012-2024 Housing Land Requirement (TAYplan SDP) (+20%) 4,608 minus Effective Housing Land Supply (Housing Land Audit 2013) 3,034 minus Windfall Allowance (30 homes per annum from 2013) 330 equals Housing Land Shortfall 1,244 The housing shortfall for 2012 to 2024 for Fife (TAYplan) is therefore 1,244 homes. Accordingly, the allocation of land for only 325 homes as set out in the Preferred Development Strategy will not meet the housing land requirement. This does not accord with the requirements of TAYplan Policy 5A. The table below sets out the calculation of the housing land shortfall for St Andrews and North East Fife HMA. The Preferred Development Strategy housing land requirement is 3,276 homes for the period 2012 to 2025. In compliance with TAYplan Policy 5A, the housing land requirement is 3,024 homes from 2012 to 2024. Analysis of the approved HLA 2013 confirms that the effective supply over the period 2012-2024 is 2,012 homes. This includes 220 completions from St Andrews West. The windfall allowance to adopt is 20 homes per annum. Accordingly the housing land shortfall for the St Andrews and North East Fife HMA that must be addressed by allocations of effective housing land in the Proposed Plan is 792 homes and there is not a surplus of 13 homes as stated in Table 2. Cupar and Howe of Fife HMA 2012-2024 Housing Land Requirement (TAYplan SDP) (+20%) 3,024 minus Effective Housing Land Supply (Housing Land Audit 2013) 2,012 (Dependency on St Andrews West – 300 homes over LDP period) minus Windfall Allowance (20 homes per annum) 220 equals Housing Land Shortfall 792 FIFEplan’s Preferred Development Strategy indicates land will be allocated at Crail (capacity unknown), Strathkinness (40 homes), Balmullo (20 homes) and Leuchars (200 homes). Part of the site at Pinkerton, Crail (CRA004A) is already allocated in the St Andrews and East Fife Local Plan for 100 homes and employment land over 12.5 hectares. The remainder of the site (CRA004B) has an area of 3.8 hectares. The capacity of this site at 25 homes per hectare (assuming all 3.8 hectares are developable) is 95 homes. Therefore, FIFEplan’s Preferred Development Strategy seeks to allocate circa 355 additional homes. Clearly this is not sufficient to meet the requirement for 792 homes for the period to 2024. On this basis, the Preferred Development Strategy will not comply with TAYplan and matters need to be addressed to ensure that the housing land requirement is met in full. In compliance with TAYplan Policy 5A, an assessment has been carried out as to whether the Preferred Development Strategy will maintain a 5 year effective land supply at all times. The outcome of this development strategy is dependent on progress of St Andrews West SDA. Reporter’s findings on Issue 8 of St Andrews & East Fife Local Plan Examination concluded: 55. In summary, I conclude that the local plan has not met the structure plan requirements in full in the St Andrews HMA, as noted above. However, I do not consider this deficiency is serious, as it is relatively small, the structure plan period extends beyond the local plan period and the new strategic development plan, which will revisit strategic requirements, has now been submitted for examination. 56. Figure 4 of the council’s hearing statement shows that the 5 year rolling supply of housing land in the St Andrews HMA has a significant surplus in each of the 5 year periods from 2010-15 to 2017-22. Even when windfall and urban capacity allowances are excluded (which I have already concluded not to be justified) there are modest surpluses from 2013-18 to 2016-21. 57. I conclude that, even though there is a deficiency against the numerical requirements of the structure plan, as the 5 year rolling supply of housing land is in significant surplus in each of the years from 2010 to 2022, there is no need to make any additional allocations of housing land in the St Andrews and North East Fife Housing Market Area. In conclusion, the Reporter made no further housing land allocations at the St Andrews and East Fife Local Plan Examination on the basis that the 5 year rolling effective supply would have a surplus. This optimism expressed at the St Andrews and East Fife Local Plan Examination has not materialised and that the effective housing land supply for the St Andrews and East Fife HMA level is now critical. If St Andrews West SDA continues to be delayed then the effective housing land supply for the St Andrews and North East Fife HMA will not meet the housing land requirement. The Council expects that St Andrews West will deliver 40 completions per annum for most of the LDP period. For every year there is a further delay to the delivery of St Andrews West, a further release of 40 homes on other sites will be required to make up the housing land shortfall.