Representation to Fife Local Development Plan. Proposed Plan Stage. CALA Management Ltd & WB Bayne & Son

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1 Representation to Fife Local Development Plan Proposed Plan Stage CALA Management Ltd & WB Bayne & Son December High Street East Linton EH40 3 AB T M tony@apt-plandevelop.co.uk

2 Contents CALA Management Ltd & WB Bayne & Son 1.0 Introduction & Background 2.0 FIFEplan Spatial Strategy 3.0 FIFEplan Policies 4.0 Cupar North Strategic Development Area 5.0 Ferryfield, Brighton Road Cupar 6.0 Summary and Conclusions

3 1.0 Introduction and Background 1.1 apt planning & development ltd. is pleased to make this representation to the FIFEplan, Proposed Plan on behalf of CALA Management Ltd. (CALA) and WB Bayne & Son, the landowners at Ferryfield. Throughout this document both parties shall simply be referred to as CALA. This document has been prepared to best represent both parties. 1.2 This document supplements previous CALA submissions and especially the MIR submission earlier in 2014 and the previous Optimised Environments Ltd. (OPEN) document in August 2011 which addresses landscape fit and urban design matters. 1.3 Please note that where appropriate this document has been broken down to fit in with the online submission protocol. However in the interest of best promoting the site at Ferryfield, we feel that this comprehensive document and accompanying images should also be lodged to provide a more credible submission. 1.4 Clearly the FIFEplan Proposed Plan reflects the settled view of Fife Council. The process has been through the call-for-sites and MIR stage and consequently the Council is satisfied that the Proposed Plan represents their preferred option to meet the demands in the coming 10 years. 1.5 With regards to Cupar, the Council has maintained its relatively long held view that a strategic allocation of 1,400 homes and incorporating a northern relief road (and other facilities and uses) is the preferred strategy for Cupar and its hinterland. This allocation is made at the exception of all other development sites in the Cupar area. 1.6 The adopted TAYplan allocates Cupar North as a Strategic Development Area, making a major contribution to the area s housing need. However the Housing Policy (Policy 5) states that local development plans should allocate a generous supply of effective

4 housing sites, providing flexibility and choice, free of constraints and capable of contributing immediately to the rolling 5-year housing land supply for Fife and the TAYplan Area (which should become an 7 year effective supply by 2015) It is unusual for a Strategic document to be so prescriptive in its allocation for housing land. Surely it would be more appropriate to allocate an overall number of homes to be delivered in the Cupar Area as part of Fife Council s commitment to the housing land supply for TAYplan and SESplan. It would then be for Fife Council to decide how and where those 1400 units are to be delivered, and taking into consideration their effectiveness to deliver completed homes in the 5 year cycles. 1.8 The site at Ferryfield has been consistently promoted for residential development in recent years and was considered at the last Local Plan Examination for the St Andrews & East Fife Local Plan. 1.9 This plan was adopted in October 2012 with the Report of the Examination in February 2012 relying exclusively on the delivery of Cupar North to meet Local Plan housing delivery targets. Even at that stage there was concern over the timescale for delivering Cupar North. This concern remains and will be dealt with later in this submission but at this point we would like to make two initial comments: Throughout the FIFEplan Main Issues Report stage and in this submission, CALA does not advocate against the major allocation at Cupar North but seeks an acknowledgement of a credible period for delivery, lasting many years. Some forecasts predict a build out of up to 30 years to deliver the 1,400 homes and associated infrastructure. Cupar North will be a significant contributor to housing provision in North East Fife. Our contention is that there should be a far more realistic approach to the likely timescale for development and that must then be reflected in a number of further allocations to meet the short and medium term housing land demand, providing flexibility as promoted in national and regional policy (Policy 5 from TAYplan as above). Second, for far too many years, and far too many Local Plans, Local Authorities across Scotland have allocated land to meet their housing supply requirements. These sites have, for any number of reasons, not always been effective development sites and have subsequently not delivered the housing numbers expected and especially within the projected timescale. This non-delivery has serious implications in housing completions and creates a false comfort in the delivery of new homes. The non-performance of these sites leads to a paucity of supply that drives

5 unsustainable house price inflation as well as severely restricting choice in the market. The allocation of residential development sites should present credible and deliverable sites to the market and therefore be more than a paper allocation. These policies should represent deliverable roofs over heads allocations There are examples of major allocations across the country where this has happened including the Dundee Western Villages within the same TAYplan Housing Market Area. Well over ten years since it was first promoted, it still remains an aspirational allocation. Given the commitment to its success, it will, in time, be an important contributor to the supply of new homes in the area, yet it has consistently failed to deliver new homes, local plan after local plan This undermines the credibility of the process and fails to deliver urgently required new homes to the market, regardless of the paper figures adding up to the required number. This must not be allowed to happen in Fife, and especially as the recovery of the economy will, in part, be driven by the provision of new homes both to prevent house price inflation and in creating economic activity in the sector There has been little real progress at Cupar North since it was first promoted and supported (and especially since the St Andrews and North East Fife Local Plan was finalised and adopted in 2011/2012). Fife Council is in danger of hanging their housing land hopes on a site that cannot possibly deliver completed homes within the necessary timescales (and acknowledging that a proposal of application notice has been lodged).

6 2.0 FIFEplan Spatial Strategy 2.1 The Spatial Strategy is the overarching statement of how Fife should develop over the 10 years to 2026 and at Figure S3 it identifies Cupar as a Strategic Development Area (SDA) (as well as a focus for employment). 2.2 At Paragraph 10, the strategy records that despite early signs of recovery, housebuilding is still only at around 50% of the pre-recession peak and that the policy framework provided by the LDP will accelerate housebuilding and provide a continuous effective housing land supply. 2.3 Paragraph 31 seeks to ensure a more sustainable Fife encouraging high quality design and recognising the role that quality of life plays in a successful and sustainable community. Paragraph 32 then proceeds to look at the creation of places that meet the six criteria of successful places and we will return to this particular aspect and with specific regard to Ferryfield later. 2.4 Paragraphs 54 to 56 look specifically at Cupar and the Howe of Fife identifying Cupar North as the established strategic proposal with consistent local and strategic support. Reflecting this, New Development opportunities are not supported in close proximity to Cupar to avoid competing with the Strategic Development Area although it is acknowledged that small-scale development will be possible in the wider area and identifies a number of small settlements where this additional development is appropriate. 2.5 By its very nature, the Spatial Strategy must be a holistic framework catering for the many disparate interests and issues across Fife. We acknowledge the dearth of housebuilding in recent years and the urgent need to mobilise the housebuilding industry, providing a range and choice of opportunities to meet a growing and pent-up demand and welcome a local and strategic framework that encourages development (in appropriate locations) and acts as a catalyst for increased house completions. 2.6 Concurrently, we also acknowledge and support the Council s stated aim for a high quality and sustainable settlement pattern, promoting high quality design, reducing the need to travel and conserving resources where possible. 2.7 With specific regard to Cupar, the binary approach, entirely dependent on the delivery of a single allocation at Cupar North is both overly restrictive and lacks any credibility as a strategy to deliver 1,400 new homes to Cupar within the 10 year LDP cycle.

7 2.8 We support the concept of Cupar North as a long-term contributor to the North-East Fife housing market, straddling a number of consecutive LDP periods and being part of a pattern of development sites providing a range and choice of new homes to what is a very attractive part of Scotland. 2.9 Cupar has proven itself to be a hugely popular place to live including many who then commute outwith Fife to work. This is reflected in Cupar being recognised in TAYplan as part of its wider housing market area In truth however, Cupar also proves popular with Edinburgh commuters, especially when the train journey into the City Centre is only one hour. Indirect evidence is that morning trains to Edinburgh and the subsequent post-work return is hugely popular, not to mention those that choose to drive into Edinburgh and other work destinations in and around the Capital. Cupar clearly contributes to the SESPlan housing market area as well as the very obvious link to TAYplan Cupar benefits from the main-line train link and good links to the strategic road network. It is a sustainable location for future growth and residential development. Ferryfield is an attractive and wholly appropriate development site that can contribute to the demand for growth at Cupar in the immediate term The Spatial Strategy should therefore reflect a more realistic programme of delivery (at Cupar North) presenting a suite of sites in and around Cupar (that will then be detailed in the more comprehensive Policies section) to deliver the much needed homes up to 2024 and beyond. We contend that Ferryfield would be the best option for helping underpin the housing supply in Cupar in the first 5 year housing supply cycle.

8 3.0 FIFEplan Policies 3.1 As part of this LDP process, CALA is seeking that the land at Ferryfield should be allocated for residential development. The site has a capacity for approximately 100 homes of mixed size and tenure (the accompanying indicative layout shows 91 homes). 3.2 Consequently our assessment of the LDP Policies starts and finishes with a desire for the site to be allocated, and therefore included as one of the sites that will deliver the requisite number of new homes to Fife and specifically a Cupar SDA which could be renamed to include Ferryfield in addition to Cupar North. 3.3 CALA is an experienced and high quality housebuilder. Many of the policies refer to specific characteristics and expectations that each development should adhere to (starting at Part B of Policy 1). CALA supports these policies of the LDP. They represent a positive and proactive approach to ensuring the delivery of high quality, sustainable developments and CALA is well versed in these practices and committed to their appropriate implementation. 3.4 CALA also supports the principle of development being directed to allocated sites as outlined at Policy 1, Part A(1) whilst seeking to provide a degree of flexibility should there be a predicted/actual shortfall in the continuous 5 year provision of homes (Part A (2)). The principle of developing on allocated sites is repeated at Policy 2 and again a degree of flexibility is supported in order to maintain the continuous land supply. Furthermore CALA supports the provision of affordable housing in line with Figure Policy 2 also comments on the need to provide a generous supply of housing and that this must respond to a range of house types and tenures. 3.6 Policy 2 also refers to the sequential methodology for addressing potential housing land shortfall (Figure 2.1). CALA is promoting that Ferryfield should be allocated in the Cupar and Cupar Muir Settlement Plan. Figure 2.1 applies to sites that are not allocated and are being promoted to address a shortfall in housing numbers. Regardless, it is logical to assess Ferryfield against this sequential methodology to ensure it is an appropriate additional site for Cupar. Is there as housing shortfall in the relevant HMA? YES - Cupar is entirely reliant on Cupar North to deliver new homes to there will be a short and medium term shortfall in the housing land supply and this situation will be exacerbated if alternative sites are not allocated/granted permission in the immediate future.

9 Can the allocated site be used? NO - not within the 5 year housing land cycle and neither will it deliver in full during the 10 year life cycle of the emerging Local Development Plan. Is there a suitable unallocated site within a settlement? NO - though in promoting Ferryfield we would advocate that the settlement boundary be stretched to include the site. Is the proposal on an edge-of-settlement or countryside greenfield land release? YES - Ferryfield is adjacent to the south west settlement boundary of Cupar and therefore an edge-of-settlement site. Does the proposal conform to the LDP strategy and policies? YES - as we have stated in this representation, the Ferryfield site conforms with LDP strategy and policies. It s effectiveness is tested later in this document as well as the six qualities of a successful place. 3.7 Policy 4 deals with Planning Obligations. This is an evolving and maturing aspect of property development and again CALA is well versed in the general implementation of Planning Obligations policies. With regards to the Cupar North SDA, Figure 4.1 identifies the requirement for the Cupar Relief Road, a new Primary School and a further contribution to a secondary school. 3.8 Finally, Policy 14 seeks to ensure that new development adheres to the Six Qualities of Successful Places concept as introduced in the Scottish Planning Policy. We assess Ferryfield against these six qualities later in this document. 3.9 With the exception of the omission of Ferryfield from the allocated development sites, CALA is broadly supportive of the range of policies for Cupar contained in the Proposed Plan. Given the singular and overly restrictive approach to providing the required homes at Cupar, relying entirely on land at Cupar North, the overall strategy must be questioned with regards to the provision of a generous supply of land for housing and the promotion of a range and choice of house types and locations CALA therefore proposes that further sites be allocated for development in Cupar thus ensuring a generous supply in delivering a continuous 5-year supply, across a range of sites. As we go on to explain, this has the added advantage of allowing Cupar North to proceed at the correct pace enabling a number of complex and contentious issues to be dealt with in an appropriate timescale.

10 4.0 Cupar North Strategic Development Area 4.1 As we have stated all along, it is not CALA s intention to campaign against the inclusion of Cupar North in the LDP. It has been a contentious allocation from the outset but it is also an established allocation with strong political support and it will provide a significant level of new housing for Fife in future years as well as ensuring added benefits to Cupar, such as the provision of the northern-relief road. 4.2 CALA s contention and in supporting an additional allocation at Ferryfield, remains that there is no way that Cupar North will deliver 1,400 homes in the plan period to 2024 (SDP period) or 2026 (LDP Period). 4.3 A number of pertinent facts outline the basis of this argument. There is no planning permission in place for Cupar North and therefore no Section 75 Legal Agreement or other related consents and permissions the Section 75 itself could take many months to conclude; There is no planning application lodged for Cupar North and therefore no supporting technical information that will be required to credibly justify development across the site. It has been confirmed that an Environmental Impact Assessment will have to be completed as part of the application process. These supplementary reports will be plentiful and will take time to prepare, submit and consider/negotiate and respond to any further questions (it is almost inevitable that an addendum to the EIA will be required at some point). The Proposal of Application Notice has been lodged with Fife Council. It is accompanied by a Revised Timeline document. It predicts securing Planning Permission in Principle and the first tranche of MSC permissions by November The timetable illustrated is practically impossible to achieve. Even with the fairest of winds, it is highly unlikely that Cupar North could benefit from an implementable MSC planning permission before mid-late There will therefore be no new homes, completed and occupied before mid-late Cupar North is still in multiple ownerships and though cooperation agreement s exist they can be notoriously difficult to implement and deliver. Knowing what goes where and when, and implementing a mechanism for delivery are the key building blocks before Cupar North can become reality. There has been some debate over whether Fife Council is contemplating providing the relief road and primary school before seeking developer contributions to cover the costs, no mechanism is in place to enable this to happen, though we understand that the current situation is that key infrastructure must be delivered by the developers.

11 There is no contract in place to design and deliver the road and primary school (to name just two key elements of the SDA). These elements must be in place or guaranteed at the very outset. 4.4 Based on the above facts, and taking an optimistic view, it is likely that only a very small proportion of the Cupar North allocation can be delivered in either the initial LDP 5 year period (to 2019) or the allocation to 2024 (the 2 nd 5-year period) or even To achieve even a 50% delivery of the allocation (700 homes) by 2024 and commencing completions and sales in 2019 would require 140 completed homes per year, easily outstripping annual completions in any year including the very peak of Cupar has never delivered 140 new homes per year to the market. 4.5 Given the scale of development (and the inherent risks and costs involved), housebuilders will not be willing to continue to build if homes are not selling. Assuming that Cupar North can deliver homes for sale and occupation at the beginning of January 2019, the scenario of providing half of the allocated 1,400 homes requires 12 house sales per month, every month for 5 years. 4.6 Furthermore, any potential purchaser of an early-phase home will also realise that there is a significant level of development still to take place in the immediate vicinity and that their amenity and quality of life will be compromised for a period of time (though this will be offset by the opportunity to secure a good deal and with all other things remaining equal, namely the macro-economic conditions). This could have a damaging impact on the marketability of Cupar North as well as its overall attractiveness and viability (if prices need to be dropped to ensure early sales). 4.7 In essence, there is a major risk, and we would state an inevitability that Cupar North contributes far less than the LDP is anticipating in the plan period. It is fair to expect a development of this scale and complexity to take years to substantially complete and as stated earlier, potentially many more years than that. 4.8 Clearly if a 25%, or more realistically a 50%, reduction in housing provision was accepted at Cupar North (in terms of its allocation for this plan period) this would create a significant shortfall in housing land provision in the emerging plan period (350 or 700 homes respectively) and given what we stated earlier about planning policy delivering roofs-over-heads, sites would need to be found to provide completed homes in the immediate 5 year period as well as contributing to the 2 nd 5 year period. In reality the shortfall will be far more than 700 homes (and not accounting for an identified shortfall already). 4.9 It is impossible to give a clear indication of the likely programme for Cupar North (there are simply too many uncertainties and hurdles to overcome) but even assuming a very optimistic start date in 2016 and delivering homes in 2017 and an even more optimistic delivery of 100 completed and occupied homes a year, this would still leave a shortfall of 600 units in the plan period. Alternatives must be explored and Ferryfield is a credible, deliverable site.

12 FIFEplan - Housing Land Supply 4.10 CALA continues to believe that the issues with the Cupar North SDA can be dealt with, in part, in a local context. There are credible and deliverable sites, including Ferryfield, to provide a range of house types and tenures in the short-term to reduce the increasing pressure on housing land caused by the continuing delays in the delivery of Cupar North coupled with the Council s current position that Cupar North must continue to be the only allocation In the wider Fife context, CALA is aware that there is mounting concern that there is an emerging shortfall in housing land provision (running to several thousand homes even employing generous development and delivery assumptions) These concerns are not including any major failing at Cupar North which would exacerbate this shortfall and create a situation whereby the housing land allocations and calculations are not fit-for purpose, requiring a major review of the LDP and especially the housing policies creating more uncertainty, confusion and delay whilst alternatives are considered Similarly should Cupar North continue not to deliver homes to the market, there will be an unhelpful situation whereby other landowners promoting applications through the system, are refused on Policy grounds only to appeal based on the ineffectiveness of the housing policies in the new LDP. Again this will create uncertainly as well as wasting huge amounts of public and private sector time and resources The shortage of available new homes would again lead to house price inflation alongside the loss of home-buyers potentially to other local authority areas as they seek opportunities to purchase new homes elsewhere As the figures extracted from the 2013 Fife Housing Land Audit (below) demonstrate, Cupar North is due to begin providing house to the land supply in If this was to be achievable, they would require to have secured full planning permission in place and be constructing homes now. Even looking at the figures below, it anticipates 1,010 to be provided post This would equate to units per annum at Cupar North for it to fulfil its land supply commitments and aspirations (or 170 occupied homes per annum to 2026). Again this far outstrips any land supply in the Cupar area. It is simply unachievable. Whichever way you look at it, there is no credible assessment that concludes with Cupar North delivering its local plan allocation by 2024 or even Fife Housing Land Audit, 2013 Schedule 1a.

13 5.0 Ferryfield, Brighton Road Cupar 5.1 The site at Ferryfield on the south western edge of Cupar has been promoted for residential development for approximately 8 years. The key determining factor in it not being allocated for development in previous Local Plans and in the emerging Local Development Plan has been the continuing reliance on Cupar North as almost the only potential mechanism for delivering new homes to the Cupar area. 5.2 Version 3 of the FIFEplan Site Assessments Report (September 2014) looks at the Ferryfield site under its LDP reference LDP-CUP001. With the exception of the LDP strategy directing all development to Cupar North, there is nothing in the assessment to preclude development at Ferryfield. 5.3 In total, seven sites are assessed in Cupar, most of which are on the south-east side of the town with the overriding conclusion for all sites being that they are not Cupar North. 5.4 However it is CALA s stated position that a suite of allocations in appropriate locations will help Fife Council meet their short-medium term housing supply issues without damaging the long-term viability and deliverability of Cupar North. 5.5 CALA continues to support and promote the site at Ferryfield as a deliverable, marketable and attractive potential housing residential development. In an earlier MIR submission the effectiveness test from PAN 2/2010 was addressed and its relevance remains. Ownership: single private ownership and legally contracted to CALA. Available for immediate development on receipt of necessary consents. Physical: free from physical constraint and has been thoroughly investigated. The site forms a natural extension to the south-western edge of Cupar and can be fully integrated with adjoining uses. Contamination: no contamination - deficit funding not required. Marketability: this is a high quality housing market location. CALA has no concerns over the attractiveness of the site nor its ability to sell houses here. Infrastructure: there are no infrastructure constraints then impact significantly on the viability of this proposal - there are no prohibitive costs to development. Land-use: housing is a suitable and appropriate use of the site and the long-term urban edge of Cupar can be drawn at this locus by incorporating the site within the settlement envelope. The substantive tree belt along the south-western edge of the site will constitute a long term defensible edge to Cupar, and provides a physical and visual link with the adjacent woodland to the north.

14 5.6 CALA considers that this site is fully effective and would contribute to the short-term land supply helping to meet market area shortfalls without affecting the future delivery of the Cupar North SDA. Its real-time effectiveness would depend on the ability to secure the necessary permissions, but Ferryfield could contribute to the housing supply in 2016 if Fife Council is minded to support the site. 5.7 At Policy 14 in the emerging LDP, the Council seeks to ensure that future developments comply with the Six Qualities of a Successful Place. We have looked at each of these in turn and comment below. These comments are to be read alongside the indicative layout and phot-montage documents submitted as part of this representation: 1. Distinctive places Ferryfield will help to define the boundary between Cupar town and adjoining countryside in a less abrupt manner than the existing urban edge, building out to an existing tree belt and forming a robust and appropriate long term settlement boundary; Sensitively planned housing on the site will create an attractive new gateway into Cupar enhancing the existing transition from country to town and forming a logical defensible boundary in views across the town from the approach on the A916; The Ferryfield site reflects the established pattern of development in the western part of Cupar and will reflect this by maintaining the growth between Brighton Road and the railway, occupying a gently sloping, south facing site; Together with woodland belts around Ferrymuir House, the new tree belt along the edge of the site will create a distinctive and strong edge to Cupar, softening the interface between the town and country. 2. Safe and Pleasant The layout for Ferryfield will ensure that the housing areas are accessed by well signed and lit path connections, which are overlooked by houses to provide a high sense of natural surveillance;

15 Housing access roads will comprise shared surfaces or homezones making the streets and public areas accessible, safe and attractive to use; The roads will have a maximum design speed of 20mph (10mph on shared surface roads) which will be enforced through the design of the main spine road, which curves through the site. 3. Easy to move around and beyond The site layout will be simple and clear to create a highly legible streetscape, which generates a positive and welcoming character of space for visitors and occupiers; The layout allows clear opportunities for several connections to be formed either for foot and/or cycle path routes from the new development into adjoining areas, to maximise choice for those on foot/ bike; The site will enable direct pedestrian routes to new and/or existing bus stops on the existing road network; 4. Welcoming The Ferryfield site will be accessed from Brighton Road and Millfield making it accessible and approachable; Houses will face onto public open space, as shown in the indicative layout, to ensure a welcoming feeling and character to the public space; Public space will include integrated children s play areas, designed with natural surveillance; SUDS facilities can be integrated into public open space provide enhanced visual amenity for residents and visitors; 5. Adaptable The Ferryfield site will create a mix of house types and tenures, which can be flexible and adaptable; Affordable housing will be integrated with private tenure rather than separating the two; 6. Resource efficient The south facing aspect of the Ferryfield site will be particularly advantageous in terms of solar gain, introducing effective opportunities for passive warmth and active generation from solar panels; Houses can be orientated to maximise opportunities for energy efficient design in this way. 5.8 Previous work undertaken has confirmed that the site can be accommodated within its landscape setting (and without damaging the setting or character of Ferrymuir House to the north and west of the site).

16 5.9 The accompanying layout and photo montage demonstrates that the site would provide a modern, well integrated and attractive development site when viewed from the southern approach to Cupar (A914 South Road), appearing as a seamless extension of the town along a well-established development corridor on the south-facing slope of River Eden valley The delay and concern over the delivery of Cupar North also runs the real risk of not only blighting the development but also of blighting Cupar. If the town is seen as not being open for business it could have longer term impacts on the attractiveness and viability of Cupar North In allocating the land at Ferryfield, the Council will be able to facilitate development in Cupar in the short-term, contributing to the initial 5 year supply period Perhaps more importantly the development at Ferryfield would also generate credible market interest in Cupar and create a genuine momentum in the housing market. This would help Cupar North, especially during the early stages of development It is entirely reasonable to believe that development at Ferryfield could be on-site, completed and sold, including the delivery of approximately 20 affordable units, in advance of any homes being available at Cupar North In creating momentum, delivering homes in Cupar and contributing to the future development, economically, physically and socially, of Cupar, Ferryfield would have a positive impact on the future delivery of Cupar North and especially if the opportunity exists to secure planning permission and be on site in late 2015, and delivering completed homes in mid-2016.

17 6.0 Summary and Conclusions 6.1 CALA Management Ltd. and WB Bayne & Son are delighted to respond to this opportunity to input into the ongoing preparation of the Fife Local Development Plan. 6.2 CALA has been promoting the site at Ferryfield for a number of years. It is an appropriate site, capable of providing up to 100 units to the local Cupar and wider Fife housing market area in the immediate term. It is an effective site. 6.3 Local, regional and national policy promote a flexible approach in the allocation of a generous supply of land to provide a range and mix of hoes to the market. 6.4 The singular approach at Cupar promoting singular allocation of Cupar North will not deliver the requisite number of homes in the required timescales. The Cupar North allocation does not constitute a generous or flexible allocation and will struggle to provide a genuine mix of house types and tenures. It is an overly restrictive policy stance that will significantly damage Fife s ability to deliver the required number of new homes by To date Cupar North has not delivered a single house. 6.5 CALA does not advocate for the removal of Cupar North from the housing land supply. The site will form an important part of the delivery of homes to North East Fife for many years. 6.6 The LDP seeks to ensure that its policies act as a catalyst for future increases in housebuilding activity in order to meet the housing land supply targets. This is a laudable objective but must then be supported by credible and effective housing land allocations. 6.7 There can be no argument that Cupar North is wholly deliverable within the LDP timescale to 2019 (first 5 year land supply period) 2024 or Consequently, alternative and additional sites MUST be allocated to deliver homes in the short-medium term. 6.8 Cupar is a popular place to live and it should be acknowledged that it contributes to both the SESplan and TAYplan housing market areas. There is a significant shortfall in both housing market areas as a result of allocations that cannot deliver homes in the necessary timescale. 6.9 For Cupar and North East Fife to deliver the allocated number of units in the lifecycle of the LDP requires completed and occupied homes to be provided, consistency on an unprecedented scale over a 10 year timeframe. The site does not have a Planning Permission in Principle let alone any detailed permissions that would enable development The necessary permissions at Cupar North may not be in place until late It is entirely reasonable to assume that no completed homes will be provided before mid-late 2017 at the earliest. It is impossible for Cupar North to deliver its allocation within the required timeframe leaving a residual shortfall in housing number of many hundreds.

18 6.11 In fact, due to the level of uncertainty, it is impossible to provide any sort of credible time frame for the delivery of Cupar North. The lack of any development is also blighting Cupar as a credible location for future investment and development The Ferryfield site would be an eminently appropriate site to help meet short-term land supply shortfalls. This report has demonstrated that it is an effective development site and that the indicative layout and design approach will ensure that the site can meet the six qualities of a successful place In addition the development of the Ferryfield, a natural extension of Cupar to the south west, will create a degree of momentum for the Cupar Housing market and will provide impetus for Cupar North when it starts to deliver completed homes. Cupar North can feed off the positivity created by the development of up to 100 new homes at Ferryfield Ferryfield will sit comfortably within its landscape setting, appearing as an continuation of the settlement pattern, and neither interrupting the views to and from Ferrymuir House, nor breaking the horizon or distant views of Cupar from the South and South West Development at Ferryfield could be on site, constructed and delivered before a single house at Cupar North is sold. It is anticipated that Ferryfield will have a three year construction and sales life cycle The Proposed LDP allocates 1,400 units to Cupar North. These units will not be delivered in the LDP period. Fife Council must allocate alternative and additional sites to meet this shortfall in housing provision. Ferryfield is the most appropriate site in the Cupar area to help meet this shortfall. CALA contends that the site at Ferryfield should be allocated for residential development in the emerging Fife Local Development Plan.