sd02 supporting statement

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CLACKMANNANSHIRE COUN

LOCAL DEVELOPMENT PLAN: -ISSUES REPORT

REPRESENTATIONS BY MUIR LIMITED

MARCH 2011

TMS PLANNING AND DEVELOPMENT SERVICES LI


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1.0 BACKGROUND

1.1 The following representation is made on behalf of Muira long established independent company active in commerciadevelopment throughout Scotland. Muir Homes Limited, theof the Muir Group, remains an active developer in todahousing markets with a variety of sites throughout the cnorthern Scotland. They have previously been, and remain, aClackmannanshire Council area.

2.0 GENERAL COMMENTS

2.1 The preferred strategy outlined within the Main Isrespect of the local development plan addressing requirements arising from the GROS 2008 population projsupported. It is clear that the plan needs to provide for the

plan area and its communities otherwise achieving the undeobjectives of prevailing national planning policy and of the locplan itself would be undermined. The critical test will bstrategy and related local development plan policies and sufficient to achieve the local development plan requirement retain our existing population and attract more people to coClackmannanshire, and in doing so boost economic vitalitopportunities locally, secure sustainable development and su

communities, and ultimately increase sustainable economicconstruction industry, including house building, is a key colocal economy and essential to the delivery of tClackmannanshire.

2.2 The extent of new development in Clackmannanshire wpast is noted as is the forward planning and relateunderpinning the delivery of new physical and social infrastruc

support further development within the County. Only wdevelopment plan facilitates the effective delivery of new deveground will the benefits of this investment be fully realised social) and the aspirational growth which the Council hasachieved.

2 3 It is agreed that the local development plan strategy n


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highly accessible sites in locations close to established facilities. These sites should be fully supported thro

development plan process and other sites/proposals which dobenefits, even where previously allocated, should be excluded

2.4 Based on the evolving requirements of the new planallocated for development, including (particularly) residential fully reassessed in order to ensure that they meet withstrategy and that these sites are best placed to deliverdevelopment required to meet community and wider Cla

needs. To simply transfer sites from the adopted local planFirst Alteration) into proposals within the local development wholly unsatisfactory approach and undermines the integrity confidence in the plan for all users of the planning system. commissioned site assessments have occurred (LUC) in thebut these need to be revisited in light of present and futurdevelopment objectives including the delivery agenda. Thepoint in allocating sites that will not be developed within the l

or making unrealistic assessments of likely contributions fromfailure to allocate sufficient deliverable residential sites thdevelopment plan process will fail to adequately address thaim of the local development plan related to meeting thehousing and supporting facilities by delivering an approphousing (including affordable housing) and services which sneeds and the population growth strategy. Insufficient dealso result in population stagnation/decline and related impac

2.5 There is a requirement, in accordance with the rScottish Planning Policy, to provide for a generous land supplyfull range of housing needs (from affordable to executive hthat land supply to be effective. Far too often a purely statisused to justify an inadequate land supply which ultimately faithe diverse range of needs within communities or to delivdevelopment required in order to meet the development plan

area. In this respect a robust assessment of individual resideis required in order to inform the Housing Land Audit (which is presently being prepared) and from there to determinadditional land allocations required. Each site requires to accordance with the guidance in Planning Advice Note 2/2Housing and Housing Land Audits (paragraph 55) in ordrespective contributions towards the 5 year effective lan


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required output during the 5 year period then additional allrequired. To this end, Muir Group are of the view that its

Farm, Alloa (refer attached plan) should be allocated development within the emerging local development plan, general compliance with the forward policy and delivery reqshould emerge through the local development plan. The rposition is set out below.

3.0 SPECIFIC ISSUES/COMMENTS

Population, Housing and Spatial Strategy

3.1 As indicated the approach to plan to meet the GROS 2forecast is considered appropriate as a fundamental underlyof the emerging local development plan. The issue thereaftrequired growth should occur and how much land should order to facilitate the delivery of this strategy. The Main

identifies the need for the local development plan to conappropriate areas where housing and associated developmabove that currently allocated, should be directed. fundamental issue. Why are all existing allocations not beitheir continued relevance to the emerging aims, orequirements of the local development plan? Only by uprocess and robustly assessing all potential sites against relevthere be confidence that the most appropriate sites are sele

contribute towards the delivery of the local development plan

3.2 The Main Issues Report correctly indicates that the moption for new residential development would be to direct the settlements which generally have the infrastructure aaccommodate them. The Main Issues Report further states thdevelopment should occur in accessible locations from whicwalk or cycle from home to work, school, shops and serv

provide more opportunities for healthy active travel, and uldependency on private cars. New residential development sthe opportunity to link the places where we live with the considering carefully the scope for improved outdoor accesscorridors and woodland planting around new developments. better integrated/linked residential development/environmentthe need to travel (primarily by car) and which are well lo


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the site (LUC 2008) is noted but the conclusions reached arby the assessment outlined and, as indicated, the importa

such as connectivity and sustainable development clearlypotentially negative matters (which were of limited signevent). The site at Lornshill Farm, Alloa should be includeddevelopment within the emerging local development plan foreasons, among others: -

The site lies within the main centre of population wheamenities are readily available;

The site lies adjacent to the local secondary schoowalking/cycling distance of commercial and recreatioeffect local services can be accessed without the use of

The site is highly accessible from the surrounding areabus and car. Indeed, there are linked Core Paths toeast site boundaries which facilitate segregated use The site also gives direct access to amenity woodlacountryside, and could be fully integrated wi

development. It is well connected to existing access rof open space; While the site lies within the designated Greenbelt it is

extent and function of the Greenbelt will be reviewed thdevelopment plan process in line with the requiremePlanning Policy. It is clear that the removal of this little material impact on the integrity of the Greenbeltor on the perceived separation between the settlemen

Tullibody. Indeed, there is logic to re-aligning the Gnorth-west site boundary of the Lornshill Farm site landscape containment and direct alignment with adjaschool;

The site is not subject to flooding and there environmental or physical restrictions affecting the site

The site comprises non-prime agricultural land; There would be no material impact on biodiversity; and

The site would be fully effective in terms Planning Adviin other words it would positively assist the delivedevelopment plan strategy (refer below).

3.4 Assessing the Lornshill Farm, Alloa site against the Planning Advice Note 2/2010 (paragraph 55) reveals that:


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contamination:there are no known contaminants on sits former or present use;

deficit funding: none required;

marketability: house completions within the site cawithin the 5 year horizon;

infrastructure: the site is free of infrastructure constrain

land use: housing is the sole preferred use of the laterms in respect of the surrounding area and the most of the site.

3.5 Each site proposed for residential development withilocal development plan should also be fully assessed in line requirements of Planning Advice Note 2/2010 and this assessmade public for the benefit of clarity and full disclosure as p

development plan process. The need for a more realisticallocations is strengthened by advice from the Scottish GovPlanner in a letter to Heads of Planning dated 29thOctober, the provision of an effective housing land supply. It is recogby making such effective provision will the related econobenefits of new housing provision be realised, including tadditional affordable housing (for which an identified need rem

Flood Management

3.5 In the Main Issues Report reference is made (papreferred option on flood management as a policy framewcontrol development on sites shown to be at risk of floodingmitigation where required. The preferred option, in line withshould be to prevent, not just control, development on flood pwhere there are no other alternatives that such develop

considered acceptable and only where sufficient mitigation can

Sustainable economic growth

3.6 It is noted that the local development plan wiemployment growth strategy which will also provide oconstruction and associated industries (page 23) Failure to a


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3.7 How to improve connectivity (page 39)? The Mainidentifies the need to reduce travel and to encourage more su

patterns. The Councils policies for reducing travel, promotisuch as cycling and walking, increasing accessibility and imtransport are promoted through the Local Transport SStrategic objectives include reducing the need to travel, convenient and integrated cycle, pedestrian, public transnetwork infrastructure and services, and promoting efinfrastructure and services, promoting new provision only wThe location of new development will be a key factor. F

already outlined in paragraphs 3.3 and 3.4 above, sites sLornshill Farm, Alloa satisfy the underlying sustainability arequirements set out within the Main Issues Report and this srepresents an appropriate response to the identified local dedelivery, locational and quality requirements.

The Natural Environment and Greenbelt

3.8 Key issues affecting the natural environment arelandscape protection, ensuring that the coverage of the Grepurpose, providing for local food production allotments angardens, and providing residents with good access to greencountryside. Biodiversity of landscape is also important (pageIssues Report accepts that national planning policy on evolved since the adoption of the Local Plan and there is a neeexisting designation and reconsider the most appropriate rol

in Clackmannanshire. The preferred option set out (page 49)function of Greenbelt against the purpose described in ScPolicy and to review its physical delineation based on the oassessment, altering coverage if appropriate and considerinextending existing and designating new areas of Greenbelt. an appropriate framework.

3.9 The Muir Group site at Lornshill Farm, Alloa presently

designated Greenbelt. This is seen as an obstacle to its develis considered that the exclusion of this site would not matedesignated area should it be concluded that the retention odesignation within the area between Alloa and Tillibody is policy response. It is true that removal of the site from the Gnarrow the designated area at this point but this would not bits function On the opposite side of the Tullibody Road the


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boundary with no material detriment to the area or its functiothe aforementioned benefits that would arise from the deve

site being realised.

3.10 Land to the west and south of the Lornshill Farm sGreenbelt) may also be utilised, in association with the devesubject site, in order to promote greater public access for reto the woodland and existing/new footpaths) and for local foothe form of allotments and a community garden which it is undemand locally. The residential development may then prov

infrastructure and access to the neighbouring land in ordallotment/community garden use on part of the site. Tincrease woodland cover (in support of the Scottishestablished policy) may also be explored within the residuuses would be appropriate rural uses within the retained Gdoing so deliver related community benefits including additionnatural environment. This would strengthen the role of the Grelated benefits to the area/local community.

4.0 CONCLUSIONS

4.1 The preferred approaches outlined with the Main Issgenerally supported subject to the comments made aboveremains of concern that parts of the housing land supply beindeliver the local development plan strategy are not pres

Large allocations, such as Sauchie West (800 units), and oinfrastructure and other constraints (including marketability) upon and where these fail to deliver the growth strategy isachieved to any material extent. It is therefore imperativerobust assessment of all proposed allocations occur prior to ththe Proposed Plan and that, where selected for developmDevelopment Plan clearly outlines development delivery times

4.2 The extent of the potential shortfall in the effectivsupply facing the Council may emerge after the productioHousing Land Audit, particularly where the Scottish GovePlanners requirements have been properly addressed. It hthat the site at Lornshill Farm, Alloa, which can be deshort/medium term and which fully meets the relevant site srelated to sustainability access integration etc can be de


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4.3 Muir Group are of the considered view that additional allocation(s) will be required within the local development

urge Clackmannanshire Council to include the identified sFarm, Alloa within the emerging plan for this specific purpowould be pleased to discuss any of the above with the Counccourse.

LORNSHILL FARM, ALLOA PROPOSED RESIDENTIAL ALLOCA


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