MIR927 Doing things digitally is our preference. Tick the box if you are not happy to receive correspondence via email: Tick the box if you would like to subscribe to the Aberdeenshire LDP eNewsletter: Fair processing notice Please tick to confirm your agreement to the following statements: By submitting a response to the consultation, I agree that Aberdeenshire Council can use the information provided in this form, including my personal data, as part of the review of the Aberdeenshire Local Development Plan. This will include consultation on the Main Issues Report (including any subsequent Proposed Plan). I also agree that following the end of the consultation, i.e. after 8 April 2019, my name and respondent identification number (provided to you by Aberdeenshire Council on receipt of your submission) can be published alongside a copy of my completed response on the Main Issues Report website (contact details and information that is deemed commercially sensitive will not be made available to the public). The data controller for this information is Aberdeenshire Council. The data on the form will be used to inform a public debate of the issues and choices presented in the Main Issues Report of the Aberdeenshire Local Development Plan 2021. It will inform the content of the Proposed Aberdeenshire Local Development Plan. Aberdeenshire Council will only keep your personal data for as long as is needed. Aberdeenshire Council will retain your response and personal data for a retention period of 5 years from the date upon which it was collected. After 5 years Aberdeenshire Council will review whether it is necessary to continue to retain your information for a longer period. A redacted copy of your submission will be retained for 5 years beyond the life of the Local Development Plan 2021, possibly until 2037 Your Data, Your Rights You have got legal rights about the way Aberdeenshire Council handles and uses your data, which include the right to ask for a copy of it, and to ask us to stop doing something with your data. If you are unhappy with the way that Aberdeenshire Council or the Joint Data Controllers have processed your personal data then you do have the right to complain to the Information Commissioner’s Officer, but you should raise the issue with the Data Protection Officers first. The Data Protection Officers can be contacted by writing to: ▪ Mr Andrew Lawson, Data Protection Officer, Aberdeenshire Council, Business Services, Town House, 34 Low Street, Banff, AB45 1AY If you have difficulty understanding this document and require a translation, or you need help reading this document (for example if you need it in a different format or in another language), please phone us on 01467 536230. Which document(s) are you commetning on? Local Development Plan 2021: Main Issues Report (MIR) (including the Kincardine and Mearns Settlements Document). Your comments Chapter 3: Vision and Strategy Main Issue 1: The Vision of the Plan Gladman supports the preferred option to keep the existing vision statement unchanged. Gladman agrees that greater guidance on the value of the vision and how it relates to the policies should be provided. It is important that the Council continue to recognise the need to ensure the region is an ‘excellent place to live, visit and do business’ by increasing sustainable economic growth by enabling appropriate development throughout the region. Main Issue 2: The Settlement Strategy We support the preferred option to remove references within the spatial strategy to the six different administrative areas in Aberdeenshire, to give a wider context to the settlement strategy over the whole area. However, it is important that growth and development is encouraged across the entire region to ensure the Council deliver the Vision of the Plan, and do not over-rely on the delivery of the large scale, Strategic Growth Areas. Although such areas will be the primary focus for growth during the plan period, a range of sites and locations must be identified as suitable for development to ensure the entire region benefits from sustainable, economic growth. Chapter 5: Shaping Development in the Countryside We support the wider aim of the policies within this section of the emerging LDP to support a long-term sustainable pattern of development, which as recognised within the MIR and Scottish Planning Policy (SPP, para.40) is to promote growth within and adjacent to existing settlements. The MIR recognises 4 key issues for consideration during this consultation, however, it fails to take cognisance of that in the event there is a shortfall in the Council’s five-year effective housing land supply, appropriate locations, including outwith settlements, must be considered as potentially suitable for housing in line with SPP. The emerging LDP should allow for this eventuality to ensure that such locations will suitably be considered for housing development when the Council are failing to maintain a five-year effective housing land supply. Main Issue 8: Organic Growth We support the purpose of the organic growth policy to introduce an element of flexibility by permitted sites for development adjacent to settlements where a need has been established. However, we would note that the scale of development sites should not be restricted ensuring that all eventual needs can be accommodated for through appropriate growth in appropriate locations throughout the region. We support the Council’s preferred option on this issue. However, any identified housing need, and particularly a shortfall in the five-year effective housing land supply, must also be considered as a relevant need that must be recognised within this section of the emerging Plan. In terms of identifying areas permissible for such organic growth, as noted within the Council’s preferred option, there is currently a significant reliance on the delivery of the few Strategic Growth Areas throughout the region. There must be added weight in delivering appropriate growth within accessible small towns and rural areas, as defined by the Scottish Government Urban Rural Classification (6-fold) guidance noted within Main Issue 7, and recognise such areas as permissible for organic growth at a sufficient scale to address an identified housing need. Chapter 6: Shaping Homes and Housing Gladman supports the overall principles of this section ensuring that there is a generous supply of land for housing across all tenures identified by the Council, in line with SPP, and that there will be “a sharp focus on delivery”. In order to deliver this however, it will be imperative that the Council allocates a range of sites of varying sizes and throughout the Aberdeenshire-part of the Aberdeen HMA and the Rural HMA. The Housing Land Requirement (HLR) with the Strategic Development Plan includes a generous allowance (20%) for flexibility to ensure delivery of the Housing Supply Target (HST). It should be noted however that a significant proportion of units are expected to be delivered across a small number of sites as part of Strategic Growth Areas. In review of the 2018 Housing Land Audit, over 60% of the Council’s housing land supply (c. 8,000 units) within the Aberdeenshire-part of the Aberdeen HMA are expected to be delivered over the Plan period across only 7 sites, ranging in capacity from 465 units (Uryside Phase 2) to 4,405 units (Chapelton). These sites are noted within the table below. HLA Ref: Site Name Settlement Site Year Entered Effective Status Capacity Supply F/BA/H/030 Menie Estate Balmedie 500 2009 0 Outline PP F/BD/H/011 Blackdog M1 Blackdog 598 2014 233 Under Construction F/EL/H/042 Cromleybank Ellon 980 2013 170 Allocated G/IV/H/077 Crichie Inverurie 737 2012 125 Allocated G/IV/H/064 Uryside Ph 2 Inverurie 531 2006 280 Under Construction G/KT/H/028 Kintore East Kintore 600 2014 300 PPiP K/CH/H/001 Chapelton Chapelton 4,045 2011 370 Under Construction This places a significant reliance on a small number of sites to deliver as programmed and although the Council have identified a generous supply of housing land, the fact that the vast majority of units to be delivered are contained within only 7 sites, within this part of the HMA, does not provide suitable flexibility in the housing land supply to ensure the Housing Supply Target is met. To off-set this over-reliance on such large-scale sites, the Council should allocate additional sites at a smaller scale (i.e. sites up to 100 units) to ensure there is sufficient range and flexibility in the housing land supply. In addition to these concerns, from the 7 sites noted above, each of these sites have been included within the HLA for at least five years. This includes 4 sites that have been in the HLA and expected to deliver units for between 6-10 years, and 1 site that has been in the Audit since 2006. Moreover, only three of these sites are currently under construction and beginning to deliver houses. In review of the programming of the remaining sites through previous audits, these have formed part of the Council’s effective housing land supply since at least 2014 and continually pushed back. While these sites will still likely make a valuable contribution to the housing land supply over the plan period, the reliance on these sites to meet the Council’s Housing Supply Target, without delay, should not be ignored and additional smaller allocations be identified to ensure a generous and flexible housing land supply. Main Issue 10: Housing Numbers on Sites We agree with the Council’s approach in that housing allocations should provide an indicative capacity, rather than a maximum number, to ensure there is flexibility in bringing forward allocated sites during the period of the plan.