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MAIN ISSUES REPORT ADDENDUM RESPONSE FORM

As part of the development of the Proposed Local Development Plan a "Main Issues Report" was published in October 2013. This contained 19 questions, the responses to which we are using to inform the content of the new plan. Importantly the 2013 Main Issues Report was based on a draft Scottish Planning Policy document, which was published by Scottish Ministers in April2013.

The publication of the final Scottish Planning Policy in June 2014 raised a very small number of new issues on which we would welcome your views. Because of this we have chosen to publish an addendum to the Main Issues Report to highlight possible local interpretations of Scottish Planning Policy.

We are not reopening consultation on the range of other issues that were considered as part of the 2013 Main Issues Report. and ask that you only consider the limited number of additional issues set out in the Main Issues Report Addendum in any response you make.

Please note that further comments on any of the other issues that were included in the 2013 Main Issues Report will not be considered at this stage.

All comments received will be carefully assessed and will be used to inform the preparation of the Proposed Aberdeenshire Local Development Plan. There will be a further opportunity to comment on the specific proposals contained in this plan when it is published, in January 2015.

Please email to ldp@aberdeenshire.gov.uk or send this form to reach us by 19th September 2014.

Aberdeenshire COUNCIL

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Please use this form to make comments on the Aberdeenshire Local Development Plan Main Issues Report Addendum 2014. If you are making comments about more than one topic it would be very helpful if you could fill in a separate form for each comment.

Please email or send the form to reach us by . 19th September 2014 at the following. address: ·

P0St: Planning Policy Team Infrastructure Services Aberdeenshire Council Woodhill House Westburn Road A~ERDEEN

AB 165GB

Email: ldp@aberdeenshire.gov.uk

Are you happy to receive future correspondence only by email - Yes ~ No D

Are you responding on behalf of another person? Yes~ No D

If yes who are you representing

An acknowledgement will be sent to this address soon after the close of consultation.

. '

YOUR COMMENTS

Please provide us with your comments below ensuring you highlight the issue you are commenting on. Please feel free to add any extra pages you may require, ensuring you highlight the issue. We will summarise long comments and in our analysis will consider every point that is made. Once we have done this we will write back to you with Aberdeenshire Council's views on the submissions made. We will publish your name as the author of the comment. but will not make your address public.

Are you answering a question? Yes I No

Question Number being answer .I I ~ .1r

MIR ADDENDUM

RESPONSE BY BAN CON DEVELOPMENTS L TO.

Wind Energy

-We agree that it would be unreasonable to hold l!R the LOP Review process to undertake - ----~uc_h a necessarily extended review of the potential visual impact of wind farms around

\ settlements. Given the detailed wording in SPP relative to Table 1 : Spatial Frameworks-

2

! 'Group 2', it does n.Q!_seem unreasonable for the ~pplicant to have !2 demonstrate that his

i proposals 'may be appropriate' if he chooses to propose a site within 2km. of a defined

settlement.

Heat Networks

It is accepted that the LOP requires to comply with SPP, and that policies on heat mapping

and heat networks need to be brought forward. However, it is suggested that the 'preferred

option' perhaps goes too far on heat mapping. While it might be realistic to provide a map

for known sources of heat supply, developments with a high heat demand are not readily

identifiable. Most emerge over time as industrialists bring forward proposals. It might be

more realistic for a policy to suggest that such uses will generally be directed to the mapped

sources of heat supply so that the benefits of co-locating can be released.

It is suggested that the 'preferred option' is also too prescriptive as regards heat networks.

Requiring all'major' applications and some smaller ones to carry out a feasibility study on

the utility of incorporating a heat network seems onerous. A heat network would not be

appropriate for many types of 'major' application, far less smaller proposals. Particularly

' where the installation or connection is not to be mandatory, the suggested requirements for

expensive feasibility work seem highly unreasonable. It is suggested that this requirement

could more reasonably be applied to new master-planned areas.

The expectation of connectivity to a heat network, where it is shown to be viable, seems to 1 run contrary to the non-mandatory stipulation (page 4} in the 'preferred option'. Also the

requirement for all major developments to 'provide pipework for connection to heat I networks' is a significant imposition on development, which seems to go well beyond the

!safeguarding stance suggested in SPP. A more general requirement for the planning of I developments to safeguard against ruling out future connectivity would be more

appropriate. ~·

Land Supply and Distribution

In setting the scene for a response to question 3, it is useful to comment on the preceding

paragraphs.

---1 Although it is certainly not accepted that the housing allowances in the SOP are appropriate

I to meet the housing industry's requirements (in the short or long term) it is nevertheless

accepted that the SOP is now approved, and the Schedule to the SOP sets out the figures

which must be complied with .

Although the Action Programme has been updated (May 2014), it precedes SPP, and

therefore still refers to sites being 'capable of becoming effective'. Even then, it certainly

does not show satisfactory progress on 'the vast majority of the existing development

allocations'. There are still many allocated sites where no developer is involved, where the

Council have relied on landowners and agents to provide information, and where the critical

detailed servicing information required to give the greater certainty of delivery (which SPP

now requires) has not been provided.

3 The Action Programme still notes that at least 13 sites (marked 'red' ) are unlikely to be

delivered during the plan period. We have identified a further 24 sites in the AHMA alone,

where there is either no developer on board, or where there are known delivery problems­

yet the site is identified as 'green' in the Action Programme.

It is also accepted that the 2014 HLA represents a useful'snapshot in time'. However, it

must be recognised that it was carried out without the guidance which is now available in

SPP, and where the focus is much more on certainty of delivery. Although the HLA was

accepted (with only minimal disagreement), it will be recalled that HfS argued robustly that

very many sites in the HLA were dated, and were promoted only by landowners. With no

developer interest, it was argued that although they might technically be 'effective', they

were unlikely to come forward timeously.

Were we to be reconsidering the 2014 HLA today (armed with the expectations as to

timeous site delivery in SPP) whether a 5 year land supply could be demonstrated would

certainly be questionable.

The changed expectations (in SPP)- as to the deliverability of 'effective' sites- is particularly

relevant to the post 5 year land supply. It is suggested in Table 2 (in the Addendum) that a

(post 5 years) healthy (AHMA) supply of 20,283 units are immediately available for

development after 2018, and that accordingly the SPP requirements for land supply 'at all

times' (particularly towards the end of the second plan period) can be met. However, this is

not necessarily the case, the effectiveness of the sites require to be critically re-assessed

(having regard to the new guidance in SPP), and programmed to see whether (on the

developers programme) they are 'expected' to be built out during the second 5 years of the

LOP period.

-indeed right up to the last day of its life. These gaps must therefore be filled by new

deliverable allocations.

Appendix 8 (Bancon Developments Table 2) takes the same approach as Table 1, but looks

at the likely performance of the Shire allocations on a disaggregated basis -looking

particularly at the three AHMA SGAs, and comparing them with the SDP Allowances. It can

be seen that significant numbers of units in these SGAs are not expected to be delivered

until after 2026. There are 510 post 2026 units in the Ellon/Biackdog corridor, 620 in

lnverurie/Biackburn, and 1845 units in the Potlethen/Stonehaven corridor. These are

significant gaps.

Considering this analysis, it is clear that the land supply problem is not just confined to the

second phase ofthe new LDP, but right throughout the life ofthe emerging plan. It is

important to recall that the SDP requires the LDP to deliver not just a global land allocation

for the HMA as a whole, but also to deliver a timeous supply in each of the separate SGAs.

From this it is clear that new allocations are required to fill these gaps, particularly bearing

in mind the comments made above in relation to the effect of SPP on the reliability of the

HLA and current Action Programme.

It has been suggested that these gaps could potentially be filled by constrained sites

becoming effective. However, this has been considered along with other HfS housebuilders,

and reference is made to the submission by HfS in this regard.

The HfS analysis fully supports and reinforces the points made above. In particular HfS Table

1 shows that the when the allocations are programmed, and compared with the SDP

Requirement, they are less than 'generous', while there is confirmation that the RHMA will

significantly fail to perform, undermining the overall SDP Strategy for growth. HfS Table 2

reinforces our analysis of the problem in the AHMA with the 2022-26 Phase of the emerging

LDP, as well as the predicted total failure of the RHMA allocations, and their implications for

the overall SDP Growth Strategy. HfS Table 4 further reinforces these points on a

disaggregated basis, and confirms that the Shire allocations are less likely to be timeously

,delivered that those in the city.

/ It is clear from the HLA that the sites which are programmed to be delivered earliest, are the

' smaller sites of less than c.100 units, where no development framework or masterplan is

required, and where infrastructure constraints are more readily resolved. It is suggested

that these are the type of site which should now be considered as additional allocations to

fill these identified gaps in the delivery strategy.

It is clear from all the foregoing that we cannot agree with the Shire assessment of the

\_:_urrent and projected land supply position.

Additional Development Sites

· Paragraph 4.6 of the Addendum is perhaps the most significant of the changed

circumstances highlighted, and it is hugely disappointing that its full significance has not

been recognised. The change from the proposed allocations being 'capable of becoming

effective', to their being 'expected to beoome effective' has huge import.

We suggest that although the definition of 'effective' housing land has not been changed

per se (The Glossary of SPP 2010 also refers to the fact that the effective land is 'expected'

to be free of constraints during the plan period), the effect of the new guidance in SPP

means that further factors require to be oonsidered. In particular all the guidance set out in

paras 115- 125 (of SPP) needs to be brought to bear on the judgement of whether a site is

truly 'effective'. The references to the consideration of issues such as capacity, resources,

deliverability, and judgements as to 'effectiveness' needing to be supported by compelling,

realistic and clear evidence, are highly relevant, linked as they are in the SPP to the utility

and weight to be attached to the Action Programme and HLA.

In choosing to ignore the implications of the new re-focused definition of the 'effective' land

supply, for both the HLA and the Action P.lan, it might be suggested that the optimistic tone

of paras 4.7 and 4.8 are effectively misleading the public anent the true position regarding

future land supply.

Having said all that, to arrive at a judgement on Question 3, we have ignored the

deficiencies of both the HLA and the Action Programme, and looked at how the

development industry plans to deliver the allocations over the ten year period covered by

the LOP Review.

Appendix A (Bancon Developments Table 1) particularly looks at whether with the new

definition of 'expected to become effective' the LPA can truly claim all the post 5 years

effective sites as available to meet the allocations to 2026. As it is of most significance, the

analysis has focused on the AHMA. The Table analyses the delivery of those sites which are

programmed to continue after 2021, in accord with the 2014 HLA returns.

This Table clearly shows that some 2367 units in the Shire, and 6594 units in the City are

planned by the housebuilding industry for development after 2026. In total, 8961 units in

the AHMA are not 'expected' to contribute to fulfilling the requirements of the SOP Strategy

during the life of the LOP Review.

The Table also shows that by removing these sites from consideration (as required by SPP)

there will be a serious shortfall in the Shire delivery strategy after 2023, when compared

with the SOP Allowances. The Table also shows there will be a similar problem in the City

towards the end of the Plan period. Considering the whole AHMA, it is seen that the even

amalgamating the expectations as to delivery in the City and Shire, there remains a strategic

housing supply problem. This is clearly contrary to Para 119 of SPP, where it is re-confirmed

that the 5 year land supply has to be provided throughout the whole 10 year life of the plan

r-The addendum promotes three new sites in Portsoy, Old meld rum, and Tarves. Bancon have

_n_o com~nts __ on_!h~ Port~oy q_r Ol dllleldrY.m s!~HoweverGe are currently 7evelopi~g­immediately to the south of the proposed Tarves site, and other residential devel~pmen~

proposed adjoining our land. It is suggested that in addition to the 'careful screening'

::t-- suggested, an acceP.table development ofthe site should be compatible with the adjacent

~h~using and residential opportunitieiJ

Appendix A

Bancon Developments: Table 1

Site

Sites to become effective Exoected to become effective

Larger sites with housi 2021

Blac 20 28 so 75 75 75 75 75 75

nk, Ellon 25 40 so so so so 50 so so so 20 60 60 60 60 60 60 60 60 60 60

20 40 40 40 40 40

25 I 25 25 I 25 I 25

7S 125 200 I 200 I 200 I 200 I 200 I 200 200 I 200 I 200

Small sites with 2021

Meldrum House 2 2 2 2 2 2 2 2 1

10 15 1S 15 15 15 15

70 70 70 70 70 70 70 15

East Newmachar 12 36 36 36 36 36 36 36 36

Kintore East 75 100 100 100 100 100 25

Blairs Co 30 30 30 30 30 30 35 35 20

Lochside of 2 3 37 37 37

Shire AHMA totals 690 I 569 I 487 I 450

Shire AHMA SOP allowances 675 I 675 675 675 675 675 675 I 675 675

Sites with housing post 2021

1 Western Road

Keoolestone

41 Nelson St

Bradford Wo St 20 20 100 100 100 I 100 77

Powis Lane

1 and 2 nk Road

Bimini 69 Constitution St

26-38 Union St

Dutch Schoo Orr Avenue

Pittodrie

29 St Clement St

Greenferns

Greyhope Road

Craibstone South A so so so so so so so so 50 50

Craibstone South B

Davidson Paoer Mill 90 90 90 18 100 100 100 I 100 100 I 100 12

Rowett South 20 85 135 135 135 135 135 135 135

Greenferns Landward

Maidencra 50 I SO so I so I 75 I 75 75 I 75 I 75 I 75 I 75

Wellington Road 50 I so so I so I so I so 50 I 50 I 50 I 50 I 50

Loriston SO I 100 100 I 185 I 185 I 185 185 I 185 I 185 I 185 I 55

East Woodcraft North

Grand home 50 I 100 150 I 200 I 200 I 200 200 I 200 I 200 I 200 I 200

Balgownie Centre

279-281 N Deeside Rd

Co u ntesswells 150 I 200 I 250 I 250 I 250 I 250 I 250 I 250 I 250 I 250 I 250

Oldfold 25 I so I so I so I so I so I so I so I so I so I so Peterculter Burn

totals 1195 1172 1095 877

SOP allowances 800 800 800 800

AHMA totals 1885 1741 1582 1327

AHMA total SOP allowances 1475 1475 I 1475 I 1475 1475 1475 1475 1475 1475

AHMA total SOP 1502 1502 I 1502 I 1502 1502 1502 1502 1502 1502

SOPta comoletion rates 1875 I 1875 I 1875 I 1875 I 2250 I 2250 I 2250 I 2250 I 2250 I 2250

~

• Appendix B

Bancon Developments: Table 2

Site I Current LOP I

2015 12016 I I I I I Table includes all allocated new sites in the 2012 LDP. All

Sites expected to become effective

Ellon to Blackdog SGA

Blackdog 20 28 so 75 7S 7S 7S 7S 7S

Ell on 25 40 50 so so so 50 so so 50

Hillhead Drive, Ellon 5

South of Westfield, Foveran 10 10 10 10 I 10

S of Chapelwell Park, Balmedie 10 3o I 40 I 40 I 30

Balmedie South 2S 2S

Park Terrace, Belhelvie

Menie

Ellon to Blackdog totals 15 35 105 143 150 165 155 125 125 125 125

SOP Allowances 133 133 150 150 150 150 150 150 150 150 150

lnverurie -Blackburn SGA

I J 81 241 241 lnverurie Conglass M1 2

lnverurie Loco Works M2

lnverurie Harlaw Road/Harlaw Drive M2

lbnverurie Uryside M3 20 4o 1 40 I 4o 1 40 I 40

lnverurie Crichie H1 20 60 60 60 60 60 6o I 6o I 6o I 6o I 60

lnverurue Conglass H3 16 11

.)h 2 H4 I I I I I 25 I 25 1 2s I 2s I 25

lnverurie F

Blackburn M1 25 25

Kintore M1 75 100 100 100 100 100 2S

lnverurie to Blackburn totals 52 79 159 184 162 205 250 225 150 125 I 125

SOP Allowances 167 167 150 150 150 150 150 150 150 150 I 150

Portlethen - Stonehaven SGA

Chapelton of Elsick 75 12S 200 200 I 200 I 200 I 200 I 200 I 200 I 200 I 200

Newtonhill H1 20 20 20 10

Stonehaven Carron Den H1 25 2S 25 25 3S

Stonehaven Ury H2 25 30 30 30 3o I 3o I 30

Stonehaven Ury H3 10 15

Stonehaven Fet eresso H4 10 10 10 10 10

Portlethen t o Stonehaven totals 155 225 285 275 275 240 230 200 200 200 200

SOP Allowances 367 367 240 240 240 240 240 240 240 240 240