East Lothian Local Development Plan Main Issues Report Proposed Residential Allocation Land at Glenkinchie On behalf of Aithrie Estates February 2015 PPCA Limited Job no: 916.11
East Lothian Local Development Plan Main Issues Report (2015) Response to Question 13 Proposed Residential Allocation Land at Glenkinchie Aithrie Estates 1.0 Introduction... 3 2.0 Main Issues Report... 4 3.0 Policy Context... 7 4.0 Site & Surrounding Area... 12 5.0 Proposed Development... 16 6.0 Site Effectiveness... 18 7.0 Conclusion... 21 2
1.0 Introduction 1.1 PPCA Ltd has been instructed by Aithrie Estates to make representation to the East Lothian Main Issues Report in support of site HSG 036 (PM/TT/HSG036), land at Glenkinchie. This submission makes representation to the Not Preferred Site status in the Main Issues Report for proposed residential development on the site. 1.2 This representation responds to the publication of the East Lothian Main Issues Report and the invitation to submit comments to the Council in advance of the publication of the Proposed Plan. Specifically this representation responds to Question 13 of the MIR which asks Do you support the preferred approach to new economic development and housing opportunities in the Tranent cluster? 1.3 Aithrie Estates does not agree with the preferred strategy for new economic development and housing opportunities in the Tranent cluster insofar as it relates to Glenkinchie and the nonallocation of land for residential development within the village. 1.4 On this basis, and in specific response to Questions 13 of the Main Issues Report, this representation expands upon submissions made at the earlier call for sites stage, and objects to the Council s Not Preferred status and the non-allocation of the site promoted by Aithrie Estates for residential development in the emerging Local Development Plan. 3
2.0 Main Issues Report 2.1 The site is identified in the MIR Interim Environmental Report as Site PM/TT/HSG036 Glenkinchie. The Council have chosen not to identify non-preferred sites within the Main Issues Report Area Maps; however these sites are identified in the Environmental Report Site and Strategic Environmental Assessment report. The Glenkinchie site is indentified in the plan below and in the Location Plan included as Appendix 1 of this submission. Glenkinchie Location Plan 2.2 It is proposed that the two sites at Glenkinchie could deliver a total of 12 units. A small allocation at Glenkinchie is deliverable in the short term and can contribute to East Lothian Council s aims and objectives for the Tranent Cluster. The MIR confirms that the Tranent Cluster is in high demand as a place to live, however there are no small scale allocations with the cluster such as what is proposed at Glenkinchie. Allocations such as these can deliver short term completions which make a small but effective contribution to the East Lothian housing land supply. 4
2.3 Development of the sites at Glenkinchie will enable East Lothian Council to comply with the policy requirements of SPP and the Government s specific objective to provide a generous supply of housing land. There is a need to maintain an effective 5 year housing land supply at all times, the site at Glenkinchie, while small scale, is an effective and deliverable site and can contribute 12 units in the short term to the housing land supply. 2.4 As part of the Local Development Plan Process, the sites at Glenkinchie have been assessed by East Lothian Council. The result of this assessment is published alongside the Main Issues Report in the Interim Environmental Report Site and Strategic Environmental Assessment. 2.5 The Council Site Assessment considers that the eastern part of the site is within the existing settlement boundary of Glenkinchie and the western part is outwith but well related to the settlement; the site is physically suitable for the proposed use with adjacent land uses being residential and agricultural; suitable access is achievable and there would be no major impacts on the road network; development on the site would be subject to infrastructure provision, including education capacity. 2.6 Additionally in relation to the potential impacts of development the Site Assessments concludes that the site is not within any areas designated for nature conservation interest; the site would provide housing, including an element of affordable housing to meet local need; there are no know constraints within the site; the site is not at risk of flooding 2.7 Issues relating to access to public transport have arisen through the Site Assessment, however, the site is within 400m of bus stops at Glenkinchie Distillery. Local bus services operate from this stop and to discount Glenkinchie as a development location based on the assumption that the limited service is unlikely to be viable for commuting is misleading and contrary to national policy. 2.8 In the case of Glenkinchie, where there is pressure for development but the village is located in an area of Intermediate Accessibility Paragraph 78 of SPP still supports additional housing in economic growth in such areas. It must be acknowledged that private car transport is a requirement in rural East Lothian. 2.9 The MIR Site Assessment also raises issue with the development of the site leading to the loss of agricultural land. It should be noted that Paragraph 80 of SPP allows for the loss of 5
agricultural land where it supports the strategy of the local development plan. The strategy of the East Lothian Local Development Plan is to deliver more housing; an allocation at Glenkinchie would therefore be consistent with that strategy. 2.10 The Site Assessment considers that an allocation at Glenkinchie would not fit with local/ strategic policy objectives and direction as the site is outwith the East Lothian SDA as identified within SESPlan and outwith a main settlement. 2.11 Policy 7 of SESPlan, in relation to the maintenance of a five year housing land supply, states that sites for greenfield housing development proposals either within or outwith the identified Strategic Development Areas may be allocated in Local Development Plans or granted planning permission to maintain a five years effective housing land supply. Sites such as that at Glenkinchie can make an effective contribution to the five year housing land supply in East Lothian as they are small, effective and deliverable within the short term. 2.12 The development sites are a logical infill extension to the village and would extend the existing settlement in a sustainable, viable and effective manner. 2.13 The sites can be developed without any apparent physical or environmental constraints. In particular, the proposed residential site could be contained comfortably into the landscape, permitting small but high quality development in terms of design, layout and landscaping. 2.14 New residential development at this location would not only provide a desirable location to live but would also represent a sustainable approach to development, which takes advantage of existing infrastructure capacity. 2.15 While there are limited services in the village, new housing would help sustain the local community by providing additional variety and choice of housing for potential house buyers in East Lothian; potentially increasing trade for local businesses; providing new pupils for the local school and helping to ensure its long term future. 6
3.0 Policy Context National Planning Framework 3 (NPF3) 3.1 The third National Planning Framework (NPF3) provides the statutory framework for Scotland s long-term spatial development. It sets out the Scottish Government s spatial development priorities for the next 20 to 30 years. Planning authorities are required to take the Framework into account when preparing development plans and it is a material consideration in the determination of planning applications. 3.2 NPF3 confirms that the Scottish Government s central purpose is to create a more successful country, with opportunities for all of Scotland to flourish, through increasing sustainable economic growth. To achieve this, the Government Economic Strategy aims to share the benefits of growth by encouraging economic activity and investment across all of Scotland s communities, whilst protecting our natural and cultural assets. 3.3 In terms of the vision for Scotland, NPF3 confirms that this includes a vision where Scotland is a successful, sustainable place with a growing economy which provides opportunities that are more fairly distributed between, and within, all communities. The objective is to provide high quality, vibrant and sustainable places with enough, good quality homes. Our living environments foster better health and we have reduced spatial inequalities in well-being. There is a fair distribution of opportunities in cities, towns and rural areas, reflecting the diversity and strengths of our unique people and places. 3.4 Section 2 of the NPF3 sets out the Government s strategy to achieve the vision of a successful, sustainable place. The strategy is to ensure that all parts of Scotland make best use of their assets to build a sustainable future, and to create high quality, diverse and sustainable places that promote well-being and attract investment. The new NPF notes that the financial climate has reduced the amount of new housing built in recent years, but the Scottish Government is committed to a significant increase in house building to ensure housing requirements are met across the country. 3.5 NPF3 encourages high quality, diverse and sustainable developments that promote wellbeing and attract investment. It confirms that there is a need for a significant increase in house building to ensure housing requirements are met across the country and more 7
ambitious and imaginative planning is needed to ensure a generous and effective supply of housing land. 3.6 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 and the allocation of the sites at Glenkinchie for residential development in the emerging Local Development Plan will meet the aims of NPF3 in the provision of housing for East Lothian as the site is effective and deliverable in the short term. Scottish Planning Policy 3.7 The updated Scottish Planning Policy (SPP) was published alongside the new NPF in June 2014 and sets out the policy that will help to deliver the objectives of NPF3. The SPP is a statement of Scottish Government policy on how nationally important land use planning matters should be addressed across the country. 3.8 It is a material consideration that carries significant weight in the preparation of development plans, the design of development; from initial concept through to delivery; and the determination of planning applications and appeals. 3.9 The new SPP confirms that the Scottish Government s central purpose is to focus on creating a more successful country, with opportunities for all of Scotland to flourish, through increasing sustainable economic growth. Sustainable economic growth is defined as: Building a dynamic and growing economy that will provide prosperity and opportunities for all, while ensuring that future generations can enjoy a better quality of life too. 3.10 SPP supports the aims of NPF3 to strengthen the role of our city regions and towns, create more vibrant rural places, and realise the opportunities for sustainable growth and innovation in our coastal and island areas. 3.11 Paragraph 15 explains that by locating the right development in the right place, planning can provide opportunities for people to make sustainable choices and improve their quality of life. Well-planned places promote well-being, a sense of identity and pride, and greater opportunities for social interaction. Delivering high-quality buildings, infrastructure and spaces 8
in the right locations helps provide choice over where to live and style of home, choice as to how to access amenities and services and choice to live more active, engaged, independent and healthy lifestyles. 3.12 The new SPP confirms the introduction of a presumption in favour of development that contributes to sustainable development. SPP explains that the planning system should support economically, environmentally and socially sustainable places by enabling development that balances the costs and benefits of a proposal over the longer term. 3.13 SPP explains that policies and decisions should be guided by a number of principles, including: giving due weight to net economic benefit; responding to economic issues, challenges and opportunities, as outlined in local economic strategies; supporting good design and the six qualities of successful places; making efficient use of existing capacities of land, buildings and infrastructure including supporting town centre and regeneration priorities; supporting delivery of accessible housing, business, retailing and leisure development; 3.14 In relation to housing development SPP sets out the Government s approach towards Enabling Delivery of New Homes and confirms the need to facilitate new housing development, particularly in areas within our cities network where there is continuing pressure for growth. SPP also confirms that house building makes an important contribution to the economy, and planning can help to address the challenges facing the housing sector by providing a positive and flexible approach to development. 3.15 SPP confirms that the planning system should: identify a generous supply of land; maintain at least a 5-year supply of effective housing land at all times; and enable provision of a range of attractive, well-designed, energy efficient, good quality housing, contributing to the creation of successful and sustainable places. In addition SPP confirms the local development plans should indicate the number of new homes to be built over the plan period, and this figure should be increased by a margin of 10 to 20% in order to ensure that a generous supply of land for housing is provided. Local development plans should provide for a minimum of 5 years effective land supply at all times. 9
3.16 SPP explains that planning authorities and developers should work together to ensure a continuing supply of effective land and to deliver housing, taking a flexible and realistic approach. Significantly, where a shortfall in the 5-year effective housing land supply emerges, development plan policies for the supply of housing land will not be considered up-to date, and paragraphs 32-35 of the new SPP will be relevant. 3.17 The proposals put forward for Glenkinchie will provide an element of residential development to meet East Lothian s housing requirement and can contribute to sustaining the rural East Lothian economy. The allocation of the site at Glenkinchie is consistent with the Scottish Government Guidance provided through NPF3 and SPP. SESPlan Strategic Development Plan 3.18 The South East Scotland Strategic Development Plan (SESPlan) was approved by Scottish Ministers in June 2013. The Strategic Development Plan states that South East Scotland is the main growth area and the key driver of the Scottish economy. 3.19 SESPlan has a clear aim of promoting sustainable development, whilst creating opportunities for satisfying the full range of housing needs. The Vision set out in SESPlan includes the aims to: Enable growth in the economy by developing key economic sectors, acting as the national hub for development and supporting local and rural development. Set out a strategy to enable delivery of housing requirements to support growth and meet housing need and demand in the most sustainable locations. Integrate land use and sustainable modes of transport, reduce the need to travel and cut carbon emissions by steering new development to the most sustainable locations. Conserve and enhance the natural and built environment 3.20 SESPlan confirms the need for a generous supply of housing land to be available at all times. The allocation of land for residential development at Glenkinchie contributes to the housing land supply in East Lothian. 10
3.21 In relation to 5 year housing land supply requirements, Scottish Planning Policy (June 2014) states, at paragraph 123, that Planning authorities should actively manage the housing land supply. They should work with housing and infrastructure providers to prepare an annual housing land audit as a tool to critically review and monitor the availability of effective housing land, the progress of sites through the planning process, and housing completions, to ensure a generous supply of land for house building is maintained and there is always enough effective land for at least five years. A site is only considered effective where it can be demonstrated that within five years it will be free of constraints and can be developed for housing. 3.22 Strategic Development Plan Policy 6 requires that Each planning authority in the SESPlan area shall maintain a five years effective housing land supply at all times. The scale of this supply shall derive from the housing requirements for each Local Development Plan area identified through the supplementary guidance provided for by Policy 5. For this purpose planning authorities may grant planning permission for the earlier development of sites which are allocated or phased for a later period in the Local Development Plan. 3.23 Policy 7 of the Strategic Development Plan, in relation to the maintenance of a five year housing land supply goes on to state that sites for greenfield housing development proposals either within or outwith the identified Strategic Development Areas may be allocated in Local Development Plans or granted planning permission to maintain a five years effective housing land supply, subject to satisfying certain criteria. 3.24 In relation to these criteria, the following can be confirmed in relation to the site at Glenkinchie. The development of twelve units will be in keeping with the character of the settlement and local area; the development will not undermine green belt objectives; and any additional infrastructure required as a result of the development is either committed or will be funded by the developer. 3.25 Sites such as that at Glenkinchie can make an effective contribution to the five year housing land supply in East Lothian. The nature of the site makes it deliverable within the short term. 11
4.0 Site & Surrounding Area 4.1 Glenkinchie is a small village in East Lothian set in the valley of the Kinchie Burn. It is located approximately 2.5 kilometres south of Pencaitland and has a population of approximately 100 persons. The village core is a designated Conservation Area and is dominated by the historic Glenkinchie Distillery complex of buildings. 4.2 The village is historic and picturesque. This is reflected in the number of local Listed Buildings and the designation of the Conservation Area. Any new development introduced into the village must preserve or enhance the characteristics of the Conservation Area and, as such, must be of high quality design and layout. The Conservation Area Character Statement in the adopted Local Plan notes that The setting of Glenkinchie is characterised by the large open arable fields that slope down on approach to the village and form the valley in which the settlement has developed. Glimpses of the distillery, its stack and other buildings can be obtained from distance views through the trees and other vegetation. These help integrate development into its sensitive broader landscape setting. The small woodland plantation to the north of the settlement is an important landscape feature. The electricity pylons passing through the valley are the only incongruous features in this otherwise rolling rural landscape. Glenkinchie itself has a unique settlement form reflecting its status as a distillery village. It is based tightly around a working distillery that has largely retained its traditional character and appearance. The distillery and its malt barns and stalk are category B Listed Buildings. Reflecting the bond between the housing and distillery common materials are used in both. The workers houses have distinctive steeply pitched overhanging slate roofs and red brick walls, unusual in East Lothian. Stone, slate and pantile have been used in the vernacular agricultural buildings to the south at Peaston Bank. Boundary treatment for plots is a mixture of traditional style stone walls and hedgerows. Most houses have short front gardens, which sets the buildings close to the road. Car parking is accommodated for on street. Many of the houses have lost original features such as their original window styles and there are some utilitarian alterations and extensions. Nonetheless, this does not detract in any significant way from the overall historic relationship between the distillery and the housing that is the essence of Glenkinchie s character. It is the overall function and form of the settlement, as well as its historical and aesthetic 12
relationship with its landscape setting, which represent a well-preserved example of industrial heritage. This gives the Conservation Area its special character. 4.3 There has been no major recent residential development in the context of the village. This is reflected in recent planning applications the majority of which are domestic scale development. It is considered inappropriate to promote major new residential development in the village given its scale and character. As such, the proposed development locations promoted by Aithrie Estates reflect this. Aerial Photograph of proposed development sites 4.4 The expansion of Glenkinchie is constrained to a great degree by field patterns and the lack of defensible boundaries on land surrounding the village. To the north there is a small plantation woodland that is a prominent feature on the approach to the village. This restricts expansion of the village to the north. 4.5 This does not mean that the village does not have the capacity to expand. It can accommodate further growth without adversely affecting the character of the village. 13
4.6 The village is served by a local Primary School and is part of a wider catchment for denominational Primary School and denominational and non-denominational Secondary School provision. Any school-based infrastructure improvements required as a direct result of the proposed development put forward through this Report would be dealt with by planning obligations at the appropriate time. 4.7 There are no brownfield development opportunities in the village known at this time. As such, new development would have to be located on appropriate greenfield land. 4.8 Development would be contained comfortably within the landscape, this is confirmed in the Council s Site Assessment which states that... development on the eastern side of the village would represent logical infill development in landscape terms, fairly well in keeping with the existing settlement pattern, while on the western side it would be a continuation of existing development.... Photograph of smaller site illustrating indicative development area Photograph of larger site illustrating indicative development area 14
4.9 The sites are fully effective and have a capacity of approximately 12 units. An allocation here would be in keeping with the village s scale and character. The site would add to the range and choice of housing available within the East Lothian rural area. 4.10 The site is suitable for housing and is well related to the village. The site benefits from strong defensible boundaries. The smaller site is already within the settlement boundary of the village and the inclusion of the larger site within the settlement would represent a logical boundary extension for the built up area. 15
5.0 Proposed Development 5.1 The development site as a whole can accommodate approximately 12 units. As the Local Development Plan emerges and a future planning application is progressed, a masterplan will be prepared for the site. It is anticipated that small scale residential development at Glenkinchie will be compatible with the immediately adjacent uses and will be of a scale, density and character in keeping with the local area. 5.2 A future masterplan will be prepared to reflect best practice in the planning and design of new housing development. This is a holistic approach that integrates urban design, land use, housing, transportation, ecology, landscape, conservation and energy efficiency. 5.3 Development at Glenkinchie, while small scale, will provide a high quality, sustainable development which is planned and developed in a coordinated and integrated manner. The future masterplan will demonstrate how the site will maximise opportunities to integrate the new development with the existing settlement and set out a landscape and framework which will enhance the setting of Glenkinchie at this location. 5.4 The site could be developed with no apparent physical or environmental constraints. It can also be effectively and readily serviced and there are no constraints to its immediate development. Owing to the nature of the site, it is considered that its development could be contained comfortably into the landscape, permitting a small but high quality development in terms of design, layout and landscaping. 5.5 The proposed development sites are identified on the enclosed location plan, it is envisaged that residential development could take place to the south of the village between Peastonbank Farm and the village. Land either side of the main road, as infill development, would provide a limited number of residential dwellings additional to existing houses and support local facilities. 5.6 The site to the east of the main road could accommodate 2 dwellings along the road frontage possibly in a bungalow style replicating that to the north and south and as previously stated, this site is already located within the settlement boundary. This site could be accessed directly from a frontage onto the main road. The site itself is well screened from the road by a mature hedgerow. 16
5.7 The site to the west could approximately 10 dwellings based on current nearby residential dwelling footprints along the road frontage. It is currently in agricultural use. This could be ether single storey or two storey development that replicates residential development to the north. The site could be accessed via direct frontage access on to the main road. A third option here would be to have residential parking located behind the dwelling houses accessed via a single main road frontage access of a scale to accommodate 10 houses and no more. Again, the site is screened via a mature hedgerow along the road frontage. The village boundary in this location could be extended to include the land shown on the accompanying map along the same lines as that for the smaller site above. 5.8 A well designed, laid out and landscaped development would round off the village form without adversely affecting either its character or setting or its Conservation Area characteristics. This could include an element of live-work housing subject to demand for such development and an appropriate land use planning means by which to control it. 5.9 The development of this site would not only provide a desirable location to live but would also represent a sustainable approach to development, which takes advantage of existing and proposed new infrastructure. New housing would also help sustain the local community of Glenkinchie and help extend services and facilities. 5.10 The location and nature of the site, including its ability to be accessed and its relationship with the existing residential development, confirm it as entirely suitable for private house building and its development would help provide for a variety and choice of locations for potential new house buyers in East Lothian. 5.11 The following section sets out the effectiveness of the site in relation to PAN 2/2010 and demonstrates that the site can be delivered within a short term timescale. 17
6.0 Site Effectiveness 6.1 The tests of effectiveness for housing allocations are set out in paragraph 55 of Planning Advice Note 2/2010 Affordable Housing and Housing Land Audits. These are as follows: ownership: the site is in the ownership or control of a party which can be expected to develop it or to release it for development. Where a site is in the ownership of a local authority or other public body, it should be included only where it is part of a programme of land disposal; physical: the site, or relevant part of it, is free from constraints related to slope, aspect, flood risk, ground stability or vehicular access which would preclude its development. Where there is a solid commitment to removing the constraints in time to allow development in the period under consideration, or the market is strong enough to fund the remedial work required, the site should be included in the effective land supply; contamination: previous use has not resulted in contamination of the site or, if it has, commitments have been made which would allow it to be developed to provide marketable housing; deficit funding: any public funding required to make residential development economically viable is committed by the public bodies concerned; marketability: the site, or a relevant part of it, can be developed in the period under consideration; infrastructure: the site is either free of infrastructure constraints, or any required infrastructure can be provided realistically by the developer or another party to allow development; and land use: housing is the sole preferred use of the land in planning terms, or if housing is one of a range of possible uses other factors such as ownership and marketability point to housing being a realistic option. 6.2 It is noted that paragraph 55 of the PAN specifically states that To assess a site or a portion of a site as being effective, it must be demonstrated that within the five-year period beyond 18
the date of the audit the site can be developed for housing (i.e. residential units can be completed and available for occupation), and will be free of constraints. 6.3 Addressing each of the above in turn, with regards to ownership it is confirmed that the site is in the ownership of a party that is willing, and intends, to release the land for residential development and associated uses during the period of the Local Development Plan 6.4 With regards to the PAN requirements on physical constraints it is confirmed that there are no physical constraints of the nature listed in the PAN affecting the site. 6.5 There are no known contamination issues within the site nor is there any history of such. The site is greenfield and farmed. 6.6 There are no deficit funding issues with regard to the site. It is wholly in private ownership. 6.7 The site is wholly marketable and the small scale development proposed would be a desirable addition to the village. Subject to a grant of planning permission, completions on the site would be delivered within the LDP period and the site is therefore considered effective in terms of Paragraph 55 of the PAN. 6.8 The landowner confirms that housing is the preferred land use of the land in planning terms. The site could accommodate approximately 12 dwellings. 6.9 With regard to wider known environmental or infrastructure constraints that may affect the suitability of the site for housing and the potential to deliver house completions over the plan period the following is provided. 6.10 There are no known environmental issues that would prevent the site from delivering development over the plan period. The site comprises agricultural fields and is not covered by any environmental designation. 6.11 There are no known physical infrastructure constraints that would affect the development of the site for residential use. There are no off site road capacity issues that would prevent site development. 19
6.12 In relation to education it is considered that the developments of the scale proposed at Glenkinchie will only generate a small number of pupils and it seems that there must be a prospect of there being sufficient education capacity to absorb them into the infrastructure available. Education provision should not therefore be regarded as an obstacle to the effectiveness of the site at Glenkinchie. 20
7.0 Conclusion 7.1 Representation is made to the on behalf of Aithrie Estates in relation to land at Glenkinchie. The sites identified at Glenkinchie should be allocated in the emerging Local Development Plan Proposed Plan for residential development. 7.2 The allocation of the sites is fully supported by the landowner, Aithrie Estates, and is considered to be effective and deliverable within the short term and will make an effective contribution to the East Lothian Housing Land supply. 7.3 It is therefore requested that East Lothian Council Extends the settlement boundary of Glenkinchie to include all the land identified on the enclosed location plan. Allocates the land shown on the location plan for residential development to accommodate, collectively, approximately 12 houses as a means of supporting rural development and local services. 21
February 2015 Aithrie Estates Legend: Site Boundary PPCA Ltd East Lothian Local Development Plan Land at Glenkinchie scale 1 : 5000 at A4 Reproduced from the 2012 Ordnance Survey 1 : 5000 scale with the permission of The Controller of Her Majesty's Stationary Office, c Crown Copyright. Licence No. AL100016663