ANGUS MIR QUESTIONNAIRE. Contact Details: Emelda Maclean Emac Planning LLP Ballinard House 3 Davidson Street Broughty Ferry Dundee DD5 3AS Email: [email protected] Tel: 01382 738822 Representations on behalf of: Inveraldie Properties Ltd. Site Name: Land North and East of Inveraldie ___________________________________________________________________________________ SPATIAL STRATEGY: Introduction to Site Representation The following comments are made within the context of supporting an allocation in the forthcoming LDP of land to the north and west of Inveraldie for residential and mixed-use development on behalf of Inveraldie Properties Ltd. The site extends to an area of approximately 23 hectares and is considered capable of accommodating around 70-100 houses, rural employment land, community/village hub and new open space provision over the first period of the LDP, with further phases of residential development (approximately 250 houses) over the longer-term period of the LDP and beyond. Site Specific Representations are provided in Appendix 1 and the site plan is attached in Appendix 2. The initial Development Concept Framework (DCF) submitted to Angus Council at the Raising Awareness stage in the preparation of the LDP is attached in Appendix 3 and is relevant to the site-specific representations. Since the DCF was prepared, further liaison has been carried with Transport Scotland and Angus Council on the access to the site, resulting in new indicative access improvements to the A90. The plan illustrating the currently proposal improved access arrangements is attached in Appendix 4. Appendix 5 encloses an extract from the Dundee Evening Telegraph identifying ongoing discussions, as a strategic level, on a potential new relief road around Dundee, which is relevant to the long- term potential of this site. The response to the following MIR questions is provided within this context. Questions for the Angus LDP spatial strategy: Q1. Do you support the preferred options for the LDP spatial strategy and its implementation, as shown in Tables 1, 2 and 3? Please explain your answer and give details of any alternative option that you think is better. Response to Q1: The preference is that Inveraldie should be included in Table 1, as a settlement suitable for the allocation of small-scale development over the period of the LDP, with a commitment to the longer-term development of the site. The site is capable of delivering effective new housing, employment and community uses, whilst sustaining existing service provision. The DCF submitted with these representations confirms that the development of this site, would not impact on the stated SEA objectives for settlements included in Table 1. The ‘Reasonable Alternative’ is supported as the site can contribute to the future allocation for small-scale development sites (for housing, mixed use or employment) in the villages or the countryside. The MIR confirms that the Council intends to undertake a landscape capacity review of smaller settlement boundaries, prior to the preparation of the Proposed Plan, which will determine where there may be capacity to accommodate small-scale new development. The above approach is supported and it is considered that the settlement boundary of Inveraldie should be reviewed as part of this process and the site allocated for housing and mixed use development in the LDP. It is considered that the site is well located in relation to both the local and wider landscape setting and is appropriate for development. The moderate expansion of Inveraldie in the first period of the LDP would deliver the objectives set out in consideration (1), that is, new development would deliver social, economic and environmental benefits, by sustaining service provision in the village. The provision of new mixed-use development in this location is appropriate as the village is accessible, has a close association with the core settlement of Dundee and the site is capable of delivering effective housing land. A moderate scale of development in the first period of the LDP, would not compete with or undermine the objectives for directing the majority of development to the principal settlements. It is considered that the moderate expansion of some villages, in particular Inveraldie, would be complementary to this strategy and allow for choice and flexibility in the provision of housing land across the Housing Market Area (HMA). Having regard to the stated SEA implications, of both the ‘Preferred Alternative’ and ‘Reasonable Alternative’, it is considered that the DCF demonstrates that there are no potential negative impacts as a result of this proposal which would prohibit the allocation of this site in the LDP. Q2. Would you support the implementation of a “Development Charge” system in Angus, so that public sector finances would be used to front-fund the development of infrastructure that is required to service new development, with costs being recouped once new homes/business premises are sold? Please explain your answer. Response to Q2: No, not at this stage, until further research has been carried out on the issue and until there is more detail on what this would entail. The Consultation Findings on the Development Delivery Consultation in March 2012 did not identify overwhelming support for introducing development charges with 56% favouring development charges and 44% against. There were some concerns expressed that such charges might raise development costs and thus further depress development activity. It is considered that the existing system of achieving relevant contributions should continue through S75 Obligations, in accordance with the advice contained in Circular 3/2012: Planning Obligations and Good Neighbour Agreements. The requirement that planning obligations can only be sought where they meet the necessary policy tests ensures that there is less financial burden on those developments in locations where there are few or no infrastructure restrictions. Sites in such locations, including land at to the east of Inveraldie, are more likely to be effective and deliver the designated land use within the LDP plan period, having regard to the current framework provided in Circular 3/2010. Circular 3/2012: Planning Obligations and Good Neighbour Agreements confirms that the Development Plan should be the point at which consideration of the potential need for and use of planning agreements begins and that Planning Authorities should include policies on the use of planning agreements in their development plans. This allows for consultation on the requirements and for the proper engagement of all parties on the expected levels of contributions that might be sought from applicants. The Angus Local Development Plan should, instead of providing a policy on Development Charges, provide clear policy direction, based on the stated requirements of Circular 3/2012: Planning Obligations and Good Neighbour Agreements across a range of requirements, which would allow the discussion to take place on the effects of any such policy prior to the LDP being adopted. In terms of the ‘Reasonable Alternative’, whilst the existence of infrastructure is supported as a key guiding principle, it is considered that the wording ‘only’ should be removed from the stated Reasonable Alternative. SPP also requires the efficient use of ‘land’ and the creation and maintenance of high quality places to be considered together with the spatial implications of economic, social and environmental change. All these planning policy requirements should be integrated into the criteria for site selection. In conclusion, A policy on Planning Obligation requirements, which accords with Circular 3/2012, is supported. The ‘Reasonable Alternative’ has some support as it is recognised that Infrastructure is a key issue, but other planning considerations should also be taken into account in deciding upon land allocations. MAIN ISSUE 1: How should we provide a generous supply of housing land across Angus? Questions for MAIN ISSUE 1: Q3. Do you agree that new housing development on unallocated small and “windfall” sites should be considered as additional to new housing on allocated sites? Please explain your answer. Response to Q3: Yes. In order to achieve flexibility in the supply of housing both ‘small sites’ and ‘windfall sites’ should be considered as additional to new housing. As stated in paragraph 4.11 of Topic Paper 4: Housing this would also account for flexibility in the event of the failure of other sites. This approach is supported by Scottish Government advice. Paragraph 61 of Scottish Government advice contained in PAN 2/2010: Affordable Housing and Housing Land Audits on “Small Sites” confirms “It is for planning authorities to consider how to take account of the expected contribution of small sites (i.e. sites capable of accommodating up to 4 dwellings) towards meeting the housing land supply through their development plans. Completions on small sites make a significant contribution to the land supply in some local authority areas and may be regarded as providing flexibility in addition to the supply on sites of five or more dwellings expected to meet the housing land requirement.” Paragraph 62 on windfall sites confirms “These sites should count towards meeting the housing land requirement only once planning permission has been granted for residential development and it is considered to be effective or is being developed.” Q4. Do you agree that the Angus LDP should not allocate land just to compensate for the possible failure of some sites to deliver new homes on expected timescale? Please explain your answer. Response to Q4: No. In his letter of 29th October 2010, the then Director and Chief Planner, Jim McKinnon reminded the Heads of Planning that Scottish Planning Policy (SPP) states that a supply of effective land for at least 5 years should be maintained at all times to ensure a continuing generous supply of land for housing. Planning authorities should monitor land supply through the audit and Development Plans should identify the triggers for the release of future phases of effective sites where a 5-year effective supply is not being maintained.