Mr R Watson: Land East of Newbigging Submissions on Proposed Angus Local Development Plan Emac Planning LLP, Ballinard House, 3 Davidson Street, Broughty Ferry, Dundee DD5 3AS Proposed Angus LDP R Watson: Newbigging East First name (Required): Emelda Surname (Required): Maclean Organisation (if relevant) (Required): Mr R Watson c/o Emac Planning LLP Address line 1 (Required): Ballinard House Address line 2 (Required): 3 Davidson Street Town / city (Required): Broughty Ferry Postcode (Required): DD5 3AS Email (Required): [email protected] Telephone (Required): 01382 738822 Emac Planning LLP April 2015 2 Proposed Angus LDP R Watson: Newbigging East Representations and Suggested Modification to the Proposed Angus Local Development Plan The following submissions are made on behalf of Mr R Watson in support of seeking an allocation in the LDP for the residential and recreational use of land to east of Pitlarlie Road, Newbigging. Mr Watson owns and controls the land concerned. The site extends to an area of approximately 8.3 hectares, including the existing recreation ground and is considered capable of delivering approximately 116 houses over the LDP period, that is 51 dwellings in the period 2016-2021 and 65 dwellings in the period 2021-2026, with an overall 40% contribution to affordable housing. The proposal also incorporates recreational provision. A context analysis of the site was provided with the MIR submissions and is attached in Appendix 1. The site assessment has been progressed since this submission and more detailed design proposals and a Masterplan for the future development of the site have been developed and incorporated in to the Design and Access Statement attached in Appendix 2. The Design and Access Statement (DAS) identifies that the aim of the proposal is to provide a catalyst for the revitalisation of the existing village community through the provision of varied, mixed-tenure housing, live-work and additional community infrastructure. The DAS describes the proposal as “An innovative model for an autarkic, zero-carbon, rural community energy generation scheme integrating combined heat and power with the biomass production potential of the neighbouring farm is also proposed.” The following submission is made in relation to specific policies of the ALDP, followed by site specific submissions on Newbigging. Subject: Strategy Part 1 – A Presumption in Favour of Sustainable Development Page / policy reference: 6 The approach of the ADLP to enshrine a presumption in favour of sustainable development reflects national planning policy and is supported, together with the commitment to support proposals which will improve the economic, social and environmental conditions in the area. Subject: Strategy Part 2 – Directing the Right Development to the Right Place Page / policy reference: 7 Emac Planning LLP April 2015 3 Proposed Angus LDP R Watson: Newbigging East The strategy for guiding the majority of development to the principal settlements identified including Arbroath, Forfar, Montrose, Brechin, Carnoustie and Kirriemuir is supported and is in accordance with Policy 1: Location Priorities of the TAYplan, approved 2012. The approach is also consistent with the emerging Proposed TAYplan, 2015. The strategy also seeks to “maintain and protect the diversity and quality of the rural area and encourage local development which supports the population and services of local communities; and provide opportunities for appropriate diversification of the rural economy.” This is supported, however it is considered that the Proposed ALDP fails to secure this in practice for a number of local communities and villages. The Proposed ALDP fails to facilitate even a modest scale of growth in a number of locations where such development would support local services and community life. Site-specific representations are made on the ADLP in this respect. Subject: Strategy Part 2 – Directing the Right Development to the Right Place (Rural Angus) Page / policy reference: 8 The strategy states that “Development in the rural area will be focused on supporting the RSCs of Edzell, Friockheim, Letham and Newtyle”. Prioritising these settlements for development is supported, but not at the cost of also allowing for some new growth elsewhere in the rural areas and within some of the other villages and settlements. In addition, there does not appear to be a planning justification for the scale of development proposed in the RSCs. It is considered that the Proposed ALDP should also allocate sites for residential development outwith the seven towns and four Rural Service Centres (RSCs). No justification is provided in the ALDP for failing to plan for the growth of the other villages and settlements over the 10-year period of the ALDP. It is considered that an embargo on growth outwith the seven towns and four RSCs fails to comply with bullets 2 and 3 of the ALDP’s stated development strategy (page 7). The above approach is considered to be contrary to national policy contained in SPP on ‘enabling delivery of new homes’ and the NPF3 context. SPP states in paragraph 109: “NPF3 aims to facilitate new housing development, particularly in areas within our cities network where there is continuing pressure for growth, and through innovative approaches to rural housing provision. House building makes an important contribution to the economy. Planning can help to address the challenges facing the housing sector by providing a positive and flexible approach to development. In particular, provision for new homes should be made in areas where economic investment is planned or there is a need for regeneration or to support population retention in rural and island areas”. Emac Planning LLP April 2015 4 Proposed Angus LDP R Watson: Newbigging East The lack of housing sites in rural areas will fail to provide for a range and choice of house of effective housing land as required by Scottish Government policy contained in paragraph 119 of SPP and also to support population retention. The ADLP does not provide for an innovation approach to the rural housing provision and to this extent fails to comply with national policy contained in SPP and with tthe key planning principal enshrined in the ALDP for a “presumption in favour of sustainable development”. The ADLP does not provide for a justification for limiting the scale of development to just 50 houses over 10 years in the RSCs and for failing to provide for planned growth outwith the seven towns and RSCs. It is considered that the ALDP should increase the housing provision in Rural Service Centres, for example at Friockheim, and provide for planned growth in some of the villages where this would sustain service provision, for example at Newbigging and Inveraldie. Suggested Change (‘Rural Angus’ page 9): Suggested change highlighted in bold or scored, as follows: To support and maintain population levels the ALDP makes provision for development of up to 50 houses new housing in each Rural Service Centre over the life of the plan. In pursuing a strategy promoting development in accessible locations in settlements with access to a range of services and facilities, the Local Development Plan does not allocates sites for residential development in some villages outwith the seven towns and four Rural Service Centres. In addition, below Rural Service Centre level appropriate infill or redevelopment proposals will be supported in those settlements and villages with development boundaries, and on appropriate sites in the open countryside. Subject: Strategy Part 3 – Creating High Quality Places Page / policy reference: Policy DS1 Development Boundaries and Priorities - page 10 Supported. Page / policy reference: Policy DS2 Accessible Development – page 11 Supported. Page / policy reference: Policy DS3 Design Quality and Placemaking – page 13 Supported. Page / policy reference: Policy DS4 Amenity – page 14 Emac Planning LLP April 2015 5 Proposed Angus LDP R Watson: Newbigging East Supported. Page / policy reference: Policy DS5 Developer Contributions – page 15 It is considered that Policy DS3 should make specific reference for the need for contributions to comply with advice contained in Circular 3/2012: Planning Obligations and Good Neighbour Agreements in order to provide further clarity on future requirements. This is without prejudice to commenting further on the referred to proposed statutory supplementary guidance on developer contributions, which should ideally be available for consultation alongside the consultation on the Proposed ALDP. Policy Framework Part 1 – Thriving and Connected Part 1 Subject: Policy TC1 Housing land Supply/Release Page / policy reference: 19 Housing Land Requirement: General In general the Policy is supported, together with maintaining a 7-year supply of effective housing land, however, it is considered that the Housing Land Requirement (HLR) should be increased and the following comments are made: The HLR should be increased by 10-20% to reflect Government Policy as contained in paragraph 116 of SPP, which states: “Within the overall housing supply target plans should indicate the number of new homes to be built over the plan period. This figure should be increased by a margin of 10 to 20% to establish the housing land requirement, in order to ensure that a generous supply of land for housing is provided. The exact extent of the margin will depend on local circumstances, but a robust explanation for it should be provided in the plan.” Table 1 of the Proposed ALDP identifies the