Angus Local Development Plan Proposed Plan. Carnoustie settlement statement & proposals plan. On behalf of Angus Estates Ltd and Muir Homes

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1 Angus Local Development Plan Proposed Plan Carnoustie settlement statement & proposals plan On behalf of Angus Estates Ltd and Muir Homes 30 th April 2015 Representation 1.0 Ristol Consulting Ltd (RCL) are instructed by Angus Estates Ltd and Muir Homes to submit representations on the Local Development Plan (LDP) Proposed Plan 2015 in relation to the settlement of Carnoustie. 2.0 It is submitted that Angus Council modify the Proposed Plan through; 1. The deletion of allocations C1 (Pitskelly) for 250 residential units and C6 for employment land from the settlement statement and proposals map. 2. The reinstatement of allocation C1 (West of Carlogie) for 300 residential within the settlement statement and proposals plan to reflect the content of the draft Proposed Plan (December 2014) presented to Committee on the 11 th December 2014, as shown on the attached Figures 1 and To progress adoption of the LDP without these modifications will render the Plan unsound and the process unsafe, contrary to provision within the Planning etc (Scotland) Act 2006 and The Town and Country Planning (Development Planning) (Scotland) Regulations 2008 (the Regulations). 4.0 This centres on planning matters detailed below which demonstrate that the Proposed Plan does not promote a sustainable or deliverable spatial strategy for housing and employment land in Carnoustie. Furthermore, the allocation of land at Pitskelly for a free standing large scale housing and employment development runs counter to the TayPlan locational strategy and accompanying policy 4 which directs new growth to existing settlements (Appendix 1). Supporting development contiguous to settlement boundaries is evident in a recent Council committee report dated 21 st April 2015 for an application of 300 houses (13/01001/PPPM), were the Head of Planning advised in paragraphs 8.19 and 8.34 that policy supports development on a site outwith but adjacent to a development boundary and proposals contiguous with a development boundary (Appendix 2). Allocation C1 runs counter to this established approach to spatial planning. 5.0 As local landowners who have invested significant time and resources in the LDP process todate, Angus Estates Ltd and Muir Homes are key stakeholders in the plan preparation process. Were the Plan progressed without these modifications neither party would have confidence in the outcomes of the LDP and both would have serious concerns over the transparency of the process. This runs counter to the core values of the planning system as detailed in paragraph4 of the Scottish Planning Policy (Appendix 3). 6.0 Angus Council s minded to approve permission decision of the 18 th December 2014 for the development of land at Pitskelly (as covered by allocations C1 and C6 in the Proposed Plan) is subject to judicial review. The weight which can be given to this decision within the context of the LDP process is therefore limited. 1

2 Grounds for modifying the Proposed Plan area as follows; 7.0 Spatial planning constraints. 7.1 The allocation of land for residential and commercial development at Pitskelly runs counter to the conclusions reached in technical studies undertaken by Angus Council as part of the preparation of the Proposed Plan. Of note are assessments into landscape capacity, traffic impact and education provision. 7.2 These studies concluded: 1. Landscape the landscape assessment prepared by the Council to inform the plan preparation process post Main Issues Report (MIR) stage concluded in section that notwithstanding mitigation, development of land at Pitskelly would adversely affect this area of Carnoustie due to its high landscape sensitivity and value (Appendix 4). The Council s own assessment of sites, which included the Strategic Environmental Assessment and informed the draft Proposed Plan, concluded that in relation to Pitskelly The location conflicts with the Visual Envelope (as defined on Map D). There is a pronounced step in site landform around Ravensbury/Pitskelly which could contribute to current settlement setting. Significant landscape and visual impacts arising, which could be difficult to mitigate. (see Appendix 5) 2. Transportation in identifying land to the west of Carnoustie in the MIR as a development option, Angus Council concluded in paragraph 20 that by adjoining the town the opportunity existed to maximise the potential for creating footpath links to ensure future development would be integrated into local neighbourhoods (Appendix 6). However, by excluding land adjoining the town boundary within allocation C1 and C7, the Proposed Plan promotes a free standing settlement which runs counter to the aims of the MIR and place making policies of the Proposed Plan. The inherent failures of the site as a sustainable location for new development is reflected in the minded to approve decision of 18 th December 2014 which requires the subsidisation of a bus system to try and create non-vehicular links between the site and town centre amenities (1A (iii) Appendix 7). 3. Education of the three primary schools in Carnoustie, Burnside (catchment for Pitskelly) is constrained due to its location in the flood plain, Woodlands is almost at capacity but Carlogie Primary School has capacity. The Council confirmed in para 6.7 of the 18 th December 2014 committee report that any development in the Carnoustie area would therefore need to be accommodated at Carlogie PS (Appendix 8). This re-emphasises the locational failures of the Pitskelly allocations site in contrast to land at Carlogie. 8.0 Planning process 8.1 The allocation of land at Pitskelly for residential and employment development was carefully tested through the early stages of the plan preparation process. A large area of land to the north west of Carnoustie was considered for residential development as part of the MIR stage and was contiguous with the settlement edge, as shown in Appendix 6. Following the MIR stage further technical work and assessments of consultee responses were undertaken by Angus Council in accordance with the procedures detailed in the Regulations. The conclusion reached was that land to the north west of Carnoustie at Pitskelly was constrained in terms of 2

3 landscape, traffic and education capacity and consequently not taken forward for inclusion into the Proposed Plan. 8.2 This was in contrast to an alternative site at Carlogie which through considered technical evaluation was considered to be a preferable location for new development and formed part of the draft Proposed Plan presented to Committee on the 11 th December 2014 for approval under allocations C1 (housing) and C6 (Working) (Appendix 9). 8.3 Development at Carlogie follows an established direction of growth for the town. It is of relevance that the development of land at Pitskelly was rejected at the public local inquiry into the Angus Local Plan Review of 2009, with the Reporter concluding in paragraphs and that land at Pitskelly was open countryside, development could not be adequately screened, in strong contrast to land at Carlogie (Appendix 10). The Council accepted these conclusions when adopting the Angus Local Plan Review 2009 and the allocation of the Carlogie business park (C6). 8.4 Removal of the Carlogie housing site and its replacement with land at Pitskelly at the 11 th December 2014 committee meeting was not subject to technical scrutiny and runs counter to the conclusions reached by the Council in their site assessments leading up to the publication of the Proposed Plan. It also runs counter to the conclusions reached at the previous Local plan inquiry and renders the Committee decision unsafe. 9.0 The merits of land at Carlogie. 9.1 Land at Carlogie adjoins the settlement boundary. This is evident through the Council s technical assessments which demonstrate that the landscape can accommodate development in this location and through the road network and surrounding residential uses, the area has the infrastructure to enable development to be integrated into the town. Of note is the ability to facilitate pedestrian and cycle access to education facilities, town centre and railway station without the requirement for a dedicated, subsidies bus service. 9.2 The Environmental Report incorporating the Strategic Environmental Assessment accompanying the December 2014 draft Proposed Plan (Appendix 11), concludes that land at Carlogie has the capacity to provide a high quality residential environment and is accessible and can be further accessed by a variety of modes of transport, including walking, cycling and public transport. These modes of transport all provide potential to link to a range of facilities and services (including health, education, retail, recreational and employment opportunities). The development site provides further opportunities to enhance the existing urban edge of Carnoustie with additional structural planting and landscaping to enhance biodiversity. (page 115). 9.3 This is in sharp contrast to the spatial planning weaknesses of development on land at Pitskelly, as concluded by the Council in the preparation of the Plan and as detailed above. 9.3 The consented Carlogie business park with the proposed road improvements reflected in allocations C6 and C8 of the Proposed Plan further demonstrate the investment being made into the north and eastern part of the town. 9.4 Active marketing of the Carlogie business park is underway along with the discharge of planning conditions. The landowner and Angus Council s economic investment team are working jointly to promote the site with a focus on supporting the growth of local SME companies. Notwithstanding the technical weaknesses of allocation C7 at Pitskelly, research 3

4 establishes that the local commercial land and property market only requires one strategic site over the Plan period and as such, allocation C7 prejudices the delivery of the consented Carlogie business park. This is acknowledged by Angus Council in the committee paper of 18 th December 2014 dealing with the Pitskelly planning application where the Head of Planning advises elected officials in paragraph 6.15 The recent grant of planning permission for the development of employment land at Carlogie is (also) noted. While it is considered that both sites have relative merits, it is considered that there is only likely to be a need for one such site. (Appendix 12) 9.5 Land at Carlogie as shown on Figure 1 can be delivered to meet the requirements of a development brief as detailed in page 128 of the draft Proposed Plan of December 2014 (Appendix 9). The framework plan accompanying this representation (Appendix 13) outlines how the main spatial planning issues of landscape integration, connections with the town boundary and wider place making objectives of street frontage design, greenspace, structure planting and SuDS can be delivered. This is consistent with the placemaking principles underpinning the Proposed Plan and detailed in policies DS Land at Carlogie subject of this representation and shown in Figure 1 is effective, meeting the tests of market interest, technically unconstrained, financially viable and laid out in section 2 of PAN 2/ End - Figures 1 Carlogie Road, Carnoustie - Proposed Modifications 2 Carlogie Road, Carnoustie - Extract from the 11 th December 2014 Committee Paper Appendices 1 TayPlan Located Strategy June 2012, pg 8 (extract). 2 Angus Council Development Standards Committee, Agenda Item no. 6, Report No. 170/15 (extract). 3 Scottish Planning Policy June 2014 (extract). 4 Angus Main Carnoustie Landscape Capacity study, para (extract). 5 Angus Council Site Assessment including SEA. December 2014 Committee (extract). 6 Angus LDP Main Issues Report November 2012 (extract). 7 Angus Council Special Meeting, 12 th February 2015, Agenda Item No. 8, Report No. 65/15. Appendix 2 (extract). 8 Angus Council Special Meeting, 18 th December 2014, Agenda Item No. 8, Report No. 511/14. 9 Proposed Angus LDP, Committee Draft December 2014 (extract). 10 Angus Local Plan Review Reporter s Report (extract). 4

5 11 Angus Local Development Plan Environmental Report December 2014, pg 115 (extract). 12 Angus Council Special Meeting Agenda Item No. 8, Report No 511/14, para 6.15, pg 5 (extract). 13 Draft development framework April

6 From: Mark Richardson Sent: 12 July :23 To: WyllieWK Cc: CoweyKJ; McgregorKD; 182 Angus Estates Ltd; Bryony Wallace Subject: RE: Proposed Angus Local Development Plan Submission (Ref 00135) Dear Walter Thankyou for your of the 8 th July (below) and the opportunity to clarify the representation made on behalf of Angus Estates and the Muir Group on Carnoustie. I confirm that para 2 of the submission should have read; 2.0 It is submitted that Angus Council modify the Proposed Plan through; 1. The deletion of allocations C1 (Pitskelly) for 250 residential units and C7 for employment land from the settlement statement and proposals map. 2. The reinstatement of allocation C1 (West of Carlogie) for 300 residential within the settlement statement and proposals plan to reflect the content of the draft Proposed Plan (December 2014) presented to Committee on the 11 th December 2014 as shown on the attached Figure 1. Reference to C6 in point 1 above (which Angus Estates and Muir Group wish retained in the Proposed Plan as detailed on page 99 and the proposals map (page 103)), was a typographic error and should have read C7 (pg 100) as now shown above and highlighted in red, consistent with the Proposed Plan and grant of planning permission for Carlogie business park, as reflected in allocation C6. Thankyou for the opportunity to clarify this point and I hope this clarification can be carried through into the schedule 4 s. If you require the full representation to be revised accordingly, pleased do let me know and I will arrange. With regards Mark Mark Richardson Ristol Consulting Ltd 2 Kirk Street Dunblane FK15 0AN

7 VAT Registration: This may contain confidential information; if received in error please delete it without making or distributing copies. Opinions and information that do not relate to the official business of Ristol Consulting Ltd are not endorsed by the firm. Ristol Consulting Ltd may monitor outgoing and incoming s. By replying to this you give your consent to such monitoring Please consider the environment before printing this From: Mark Richardson Sent: 09 July :13 To: WyllieWK Cc: CoweyKJ; McgregorKD Subject: Re: Proposed Angus Local Development Plan Submission (Ref 00135) Dear Walter Many thanks for your and opportunity to clarify the representation. I am currently on holiday, but will check the representations submitted over the next few days and confirm by Monday. I hope this is in order. Yours Mark On 8 Jul 2015, at 16:23, WyllieWK <WyllieWK@angus.gov.uk> wrote: Good afternoon Mr Richardson, I am writing to you in relation to the representation (Our Ref: 00135) which Ristol Consulting Ltd submitted on behalf of Angus Estates Ltd and Muir Homes in relation to the Proposed Angus Local Development Plan. With reference to section 2.0 the representation which Ristol Consulting Ltd have submitted states the following:

8 2.0 It is submitted that Angus Council modify the Proposed Plan through; 1. The deletion of allocations C1 (Pitskelly) for 250 residential units and C6 for employment land from the settlement statement and proposals map. With reference to the Proposed Angus Local Development Plan (2014), I would like to confirm that C1 Housing Land at Pitskelly constitutes a 10 hectare allocation of housing land for around 250 dwellings (Page 97) to the north west of Carnoustie. Furthermore, C6 Working Land at Carlogie constitutes a 15 hectare allocation of land for employment use (Page 99) to the north east of Carnoustie. Can you please reply to this confirming whether or not section 2.0 within your representation is correct? Kind regards, Walter Wyllie Planning Officer (Environment and Development Plan Team) Planning and Place Communities Angus Council County Buildings Market Street Forfar DD8 3LG T: E: WyllieWK@angus.gov.uk This message is strictly confidential. If you have received this in error, please inform the sender and remove it from your system. If received in error you may not copy, print, forward or use it or any attachment in any way. This message is not capable of creating a legal contract or a binding representation and does not represent the views of Angus Council. s may be monitored for security and network management reasons. Messages containing inappropriate content may be intercepted. Angus Council does not accept any liability for any harm that may be caused to the recipient system or data on it by this message or any attachment.

9 Figure 1 - Carlogie Road, Carnoustie Angus Council Local Development Plan - Proposed Plan Representation made on behalf of Angus Estates Ltd Proposed Modi cations 30th April 2015 Scale 1:5000@A3 LDP Allocated Employment Site C6 and C7 Proposed 20 acres (8Ha) C1

10 Figure 2 - Carlogie Road, Carnoustie Angus Council Local Development Plan - Proposed Plan Representation made on behalf of Angus Estates Ltd Extract from the 11th December 2014 Committee Paper 30th April 2015 Plan not to scale LDP Allocated Employment Site C6 and C7 Proposed 20 acres (8Ha) C1

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29 ... The development proposals include: Site design layout which integrates with the rural landscape character and the layout and character of neighbouring building with frontages onto the Carlogie Road Structural planting, landscaping or networks of green corridors within and around the site to create an appropriate urban edge including enhancement of the Lochty Burn and its environment Provision for vehicular, cycle and pedestrian access arrangements to the satisfaction of the council Client: Angus Estates Ltd Drawing Title: Carlogie, Carnous e Development FrameworkIni al Considera ons G Date: 27th April 2015 F Key: I E D B A H A Residen al development 37 acres (15Ha) B Road access network C SUDs scheme D New roundabout E A930 new connec ng link road. F Allocated employment land C6/C7 Carlogie Business Park 37 acres (15Ha) G Example 0.5 acre (2000m2) business plot H Carlogie Road I Unnamed Road J A930 Pedestrian and cycle access paths Frontage Housing C Issue Status: DRAFT (for informa on purposes only) Revision: Scale : 1:5000@A3