sent via scottish government sea gateway – piers blaxter ... · dear mr blaxter . 00840...

Scottish Natural Heritage, Great Glen House, Leachkin Road, Inverness, IV3 8NW Tel: 01463 725000 Fax: 01463 725067 www.snh.gov.uk

Dualchas Nàdair na h-Alba, Taigh a’ Ghlinne Mhòir, Rathad na Leacainn, Inbhir Nis, IV3 8NW Fòn: 01463 725000 Facs: 01463 725067 www.snh.gov.uk/gaelic

Sent via Scottish Government SEA Gateway – [email protected] Piers Blaxter Planning Policy Team Leader Aberdeenshire Council Woodhill House Westburn Road Aberdeen AB16 5GB Our ref: 00840-SEA 6 May 2015 Dear Mr Blaxter 00840 Environmental Report Addendum – Aberdeenshire Local Development Plan 2016 Thank you for the opportunity to provide comments on this SEA Environmental Report, which accompanies the proposed Aberdeenshire Local Development Plan 2016. We consider that the key environmental issues have largely been correctly identified, and the assessment of likely significant effects on the environment has largely been carried out satisfactorily. The SEA correctly identifies a clear need for the plan to address possible adverse effects on the River Dee SAC. Our separate response to you on the HRA record (same date, our reference - CEA135958/CPP135985) contains more detail on our advice in relation to this issue. Rather than repeat that here I simply refer you to that response. To inform our HRA response, we went back to the Aberdeen City & Shire Strategic Development Plan (page 31) and would suggest that your Environmental Report could helpfully do the same. We will work with you and other key agencies where relevant to agree any changes needed to the plan (or the record of HRA) before adoption to demonstrate that the plan will not have any adverse effects on the integrity of the River Dee SAC. We also recommend a number of relatively minor amendments to ensure that the SEA is robust. We provide our advice on this in the annex to this letter. If you have any queries please do not hesitate to contact Nina Turner, [email protected] in the first instance. Yours sincerely Ewen Cameron Operations Manager Tayside and Grampian cc [email protected] [email protected] [email protected]

Annex I – SNH advice on SEA for the proposed Aberdeenshire LDP 2016

of 7

Section SNH comments Non-Technical Summary, page 5, section headed ‘Environmental Report’

Re: “In August 2014 we published an Interim Environmental Report alongside the Main Issues Report” – we understand the correct date is October 2013.

Page 7-8 Table 1.1 Assessment of Effects – (i) Water

Re:“The scale of development envisaged is so large that the plan is likely to have long term implications for water abstraction…Although the [LDP] promotes water efficient technologies, the scale of water efficiency technologies envisaged may not be able to compensate for the volume and quality of water resources needed to support the allocations” The implication of this is that the issue needs to be addressed as part of the Habitats Regulations Appraisal (HRA) of the LDP in respect of the River Dee (SAC). It would be helpful to include a reference here to the HRA appraisal, and possibly also to the relevant section of the City & Shire SDP (page 31).

Page 7-8 Table 1.1 Assessment of Effects – (ii) Biodiversity, flora and fauna

Re: “If we develop 30,000 new houses in the area, we must take some greenfield sites, fragment habitat and lose species and habitats and disturb other species” We recognise this is an attempt to write in non-technical language, but we consider that it exaggerates the scale of the impacts. This is because in practice, there are a range of approaches to development delivery that will mitigate the impacts. A well-designed development could actually enhance rather than ‘fragment’ habitat networks and with the right mitigation, species need not be disturbed In order to address this, we suggest that information about mitigation should, wherever possible, sit alongside assessment of the impacts.

Page 7-8 Table 1.1 Assessment of Effects – (iii) Population

Re: “The scale of the development is so large that if implemented, many people in Aberdeenshire will potentially find homes to buy or rent” This is a positive economic and social effect and therefore does not belong in an SEA. The positive effect of new homes on peoples’ health is covered under the assessment of the plan on Human Health.

Page 9-10 Table 1.2 Mitigation Measures

In broad terms mitigation for significant negative effects on water, soil, biodiversity and landscape is that general policies in the LDP will be applied through the development management process. The key will therefore be for such negative effects to be identified at the DM stage and relevant protective policies applied. In order to support this process, we suggest that relevant development considerations and developer requirements are set out in the plan alongside site allocations, or are at least visible (and easily accessible) to development management staff

Page 18 Table 3.2 Settlement Strategy

An alternative (2) is stated here of “Alternative strategies may be promoted following a review of responses to consultation


of 7

on the main issues”. This therefore needs bringing up to date because presumably alternatives (if appropriate) will have been considered as part of the proposed plan-making process

Page 42-46 Table 4.3 Environmental Problems Relevant to LDP - (i) Biodiversity, flora and fauna

Under ‘Possible role of LDP’ it is stated that “Greater emphasis could be given to identifying, protecting and enhancing green networks” and “Water efficiency and the incorporation of water saving technologies could be promoted for all new development”. This again needs updating – have these measures been taken forward by the Proposed Plan? To what extent have existing environmental problems relevant to the plan been addressed in the preparation of the Proposed Plan?

Page 42-46 Table 4.3 Environmental Problems Relevant to LDP - (ii) Water

In terms of water abstraction from the River Dee, we suggest that the report highlights that the conservation status of one of the SAC qualifying interests (freshwater pearl mussel) is currently unfavourable

Page 49-56 Table 5.2 Mitigation Measures Applied to Policies, SG and Sites – (i) Water

Re: “Preferred allocations listed in Table 5.3 will be strictly subject to the mitigation issues listed in this section” – while this is welcome, how will this work in practice? We have suggested (in our plan representation) that the plan includes the following wording “Development proposals must take account of the mitigation measures highlighted in the SEA”

Re: “Water abstraction level should be agreed with SEPA, SNH and Scottish Water before development takes place” – This is not a matter that should only be considered on a case-by-case basis. Rather, this is a key issue that will need fuller consideration as part of the Habitats Regulations Appraisal in respect of the effect of the plan on the integrity of the River Dee SAC.

With regard to water abstraction affecting the River Dee SAC, we recommend that consideration is given to including Scottish Water and SEPA as parties responsible for mitigation. This is because they are responsible for water abstraction/licensing of water abstraction, and so could be expected to monitor compliance with the relevant water abstraction license(s) for the SAC. Notwithstanding the above, the Council will need to be able to confirm, based on up-to-date (and predicted for the levels of proposed development) water abstraction levels information (sourced from Scottish Water) and compliance with licensed abstraction (sourced from SEPA) that any proposed changes in abstraction that would arise from the proposed development allocations is still as described at the time the SDP was drawn up and remains achievable without having an adverse effect on the integrity of the SAC. Please refer to our comments on the HRA record for more details.

Page 49-56 Table 5.2 Mitigation Measures Applied to Policies,

Mitigation measures listed here include “Allocations for development should be directed away from peat and carbon-


of 7

SG and Sites – (ii) Climatic Factors

rich soils” and “Land should not be allocated for forestry activities and wind farms unless the benefits from those activities save more carbon than the peat soil displaced”. It would be helpful if such statements were brought in line with SPP, eg “Allocations for development were directed away from peat and carbon-rich soils”.

Page 49-56 Table 5.2 Mitigation Measures Applied to Policies, SG and Sites – (iii) Soil

There is no mitigation here for soil compaction, loss, sealing, erosion, degradation and there appears to be no protective policy in the Proposed LDP for soils.

Page 49-56 Table 5.2 Mitigation Measures Applied to Policies, SG and Sites – (iv) Biodiversity

“Policy E1 Natural Heritage refers to Green Networks and the need to protect and conserve habitats which contribute to them” – there does not appear to be any explicit reference to green networks in Policy E1 (instead there is some reference to green networks in Policies PR1 and P2).

Page 57-58 Table 5.3 Preferred Sites with likely significant effects on environmental receptors

(i) a note should be added under ‘Water’ that cumulatively all preferred sites supplied by water from the River Dee will have a likely significant environmental effect; (ii) the mitigation for all these sites with likely significant negative environmental effects is the application of mitigation measures as set out in the preceding table. For biodiversity this refers to –

Maintenance and enhancement of habitat links through masterplans.

Connectivity to green network. Safeguarding of watercourses. Application of ecological assessments and species

surveys. Requirement for enhancement strategies. Compliance with relevant general protective and

enhancement policies.

Although we welcome this, as noted above we wonder how this will be delivered in practice. Have development factors and developer requirements been included alongside site allocations to ensure relevant protective general policies are applied?

Page 65-70 Table 5.5 Monitoring Plan – (i) Water quantity

Under remedial action it is stated “Review development allocations, e.g. when drought condition suggests that water abstraction cannot cope with development”. More detail is required as to how would this work in practice, it raises the question of whether this is feasible occur within the lifetime of this plan if necessary and whether it is still in accordance with the predictions given at the time the SDP was drawn up need to be addressed.

Page 65-70 Table 5.5 Monitoring Plan – (iii) Biodiversity

As well as habitats and species, we suggest the green network should be monitored, to identify whether the plan is successfully protecting and enhancing these areas. Reference to Policy 11 here should presumably be amended to Policy E1 (same for Landscape – Policy E2 rather than Policy 12).

Page 96 - 123 Appendix 1.1 Policies and Supplementary Guidance

Policy B1 Employment and Business Land: It is unclear why this is assessed as positive for landscape.


of 7

Supplementary Guidance: Safeguarded Areas and Areas of Search for Minerals Development – it is unclear why this SG is assessed as positive for soil, biodiversity and landscape when its purpose is to identify land for present or potential future mineral working. Policy PR2 Protecting Important Development Sites – it is unclear why this policy is assessed as positive for biodiversity and landscape when it protects land for development. Policy RD1 Providing Suitable Services – it is unclear why this policy is assessed as positive for soil and landscape when it is concerned with the delivery of services and infrastructure for new development (e.g. roads, water and sewerage, waste management).

Page 128 – 134 Appendix 1.2a Banff and Buchan Preferred Sites

Fraserburgh OP2, OP3, BUS1, CC1, BUS4, P3 – it is unclear why these development sites for housing, employment, retail and business are assessed as significantly positive for landscape. Macduff BUS2, OP1 and CC1 – likewise it is unclear why these sites allocated for employment, housing or a commercial centre are assessed as significantly positive for biodiversity and/or landscape, unless the enhancement of landscape and biodiversity is a requirement of any masterplans. Rosehearty OP1 - likewise it is unclear why this site allocated for 50 houses is assessed as significantly positive for landscape, unless this is because of the requirement for strategic landscaping in the masterplan.

Page 138 – 147 Appendix 1.3a Buchan Preferred Sites

Other sites assessed as significantly positive for landscape or biodiversity which are greenfield and hence where the rationale for the positive impact is unclear (e.g. there is no criterion for ++ assessments for landscape in Appendix 1.9) are –

Crimond OP1 (25 houses) Mintlaw OP1 (500 houses, business, community,

services for the elderly, neighbourhood retail centre, employment land) – it is unclear how this will “enhance the habitat of the South Ugie Water”

Page 196 – 204 Appendix 1.6a Kincardine and Mearns Preferred Sites

Chapelton of Elsick OP1 – some more commentary would be helpful here, given this is an allocation for 4045 houses etc, and given negative assessments for all but material assets, population and human health. Reference could be made to mitigation included in planning permissions. Portlethen R2 – park and ride facility – it is unclear why such development of a greenfield site is assessed as significantly positive for biodiversity. Stonehaven OP1 – it is unclear why this proposed housing development (110 houses) on greenfield land is assessed as


of 7

significantly positive for biodiversity, especially as this site is near the confluence of Toucks Burn and Carron Water, with associated habitat margins. Can reference be made to biodiversity enhancement measures in the approved masterplan?

Page 224 – 232 Appendix 1.7a Marr Preferred Sites

Banchory OP2 and R3 – from a desk appraisal the western part of OP2 (west of Hill of Banchory) and R3 are wooded (ancient woodland – type 2b, long established, of plantation origin), implying significant loss of ancient woodland here. This does not appear to be reflected in the assessment re biodiversity and landscape. Kincardine O’Neil OP3 and OP2 – these sites are either adjacent or close to the River Dee SAC (including Neil Burn) which should be referred to as part of the biodiversity assessment. Torphins OP1 – this site is close to the River Dee SAC (including Beltie Burn) which should be referred to as part of the biodiversity assessment. (The site is assessed again as MA039 in Appendix 1.7b where it is assessed as significantly negative for biodiversity, because of its close proximity to the SAC).

Page 245 – 254 Appendix 1.8 Cumulative Effects of the Preferred Options

Water (assessed as +/- -) – we are unsure of the meaning of “Developments under the current LDP 2012 are supported by agreements reached with SNH, SEPA and Scottish Water under the LDP”. Please see above comments re need for Habitats Regulations Appraisal to consider this matter more thoroughly. If this refers to our understanding of the situation at the time the City & Shire Strategic Development Plan was drawn up it should say so. If not, it should confirm that the predicted demand for abstraction from the Rive Dee during the life of the LDP still remains as it did at the time the matter was addressed by the SDP. The need for the HRA to tackle this issue in a comprehensive and transparent way is highlighted here by such statements as “Increased requirement for water abstraction will lead to adverse effects on River Dee as well as protected species through time lag effects …. Water resources could be over-exploited if a combination of measures is not put in place to tackle it …………. The scale of development is so large that the LDP is likely to have long-term implication for water abstraction depending on how the LDP is implemented …… Although the LDP promotes water efficiency technologies, the scale of water efficiency technologies envisaged may not be able to compensate for the volume and quality of water resources needed to support the allocations”. Soil (assessed as +/--) – it is unclear why soil sealing, compaction and loss is considered a short-term effect only, rather than long term. It is stated that there will be significant adverse effects on Aberdeenshire soils, and that the scale of development is large scale. However there appears to be no


of 7

mitigation to reduce this negative effect. For example there doesn’t appear to be any policy in the Proposed LDP to safeguard soil quality.

Page 263 – 272 Appendix 1.10 Allocation/Bid Assessment Criteria

Water - we suggest if a proposal is able to connect to WWTW with adequate capacity this should be assessed as neutral rather than positive. A positive effect would be where a WWTW would be upgraded to a higher standard as a result of investment stimulated by increased demand. Biodiversity – likewise in we suggest proposals that conserve, protect or maintain habitats/species should be assessed as neutral rather than positive. Proposals that enhance habitats/species can be assessed as positive.

Page 304-307 Appendix 3.5 – Biodiversity, flora and fauna

Data from the Native Woodland Survey of Scotland can be added – there are 37,855 ha of native woodland in Aberdeenshire, which is 6% of the land area (includes the Cairngorms National Park area within Aberdeenshire) – see - http://scotland.forestry.gov.uk/supporting/strategy-policy-guidance/native-woodland-survey-of-scotland-nwss/reports

Page 345 - Appendix 3.28 – Peat Land

A new spatial dataset should shortly be available (in approved rather than draft form) – carbon-rich soil, deep peat and priority peatland habitat - http://www.snh.gov.uk/planning-and-development/advice-for-planners-and-developers/soils-and-development/cpp/.

Scottish Natural Heritage, Great Glen House, Leachkin Road, Inverness, IV3 8NW Tel: 01463 725000 Fax: 01463 725067 www.snh.gov.uk

Dualchas Nàdair na h-Alba, Taigh a’ Ghlinne Mhòir, Rathad na Leacainn, Inbhir Nis, IV3 8NW Fòn: 01463 725000 Facs: 01463 725067 www.snh.gov.uk/gaelic

BY EMAIL Piers Blaxter Planning Policy Team Leader Aberdeenshire Council Woodhill House Westburn Road Aberdeen AB16 5GB Our ref: CEA135958/CPP135985 6 May 2015 Dear Mr Blaxter Habitats Regulations Appraisal – Aberdeenshire Local Development Plan (LDP) 2016 Thank you for the opportunity to provide comments on the Habitat Regulations Appraisal that accompanies the proposed Aberdeenshire Local Development Plan 2016. Summary We do not consider that the HRA Record has demonstrated at this stage that there would be no adverse effect on the integrity of River Dee SAC. However the inclusion of further advice and supporting information from Scottish Water and/or SEPA on future abstraction levels (and the effectiveness of the proposed mitigation on abstraction levels) may enable a future iteration of the HRA Record to demonstrate that there will be no adverse effect on the integrity of River Dee SAC. We would be pleased to discuss this further in early course so that the issue can be resolved before the plan and the ‘schedule 4s’ are submitted for examination. We also recommend a number of other amendments to ensure that the HRA is robust for other Natura sites. We provide our advice on this in the annex to this letter. If you have any queries please do not hesitate to contact Nina Turner, [email protected] in the first instance. Yours sincerely Ewen Cameron Operations Manager Tayside and Grampian

Annex I – SNH comments on draft HRA Record for Aberdeenshire Proposed LDP 2016

Page 2 of 8

1. Layout and due process In order to clearly demonstrate that this plan will not adversely affect the integrity of a Natura site(s), you will need to change the layout of this record of Habitats Regulations Appraisal. This is because the current layout/terminology used does not follow the guidance on the Habitats Regulations Appraisal of Plans (see below). Whilst HRA can seem complex, in simple terms, Habitats Regulations Appraisal (HRA) of a plan is a 2 stage process: i. determining whether policies or proposals would be likely to have a significant effect on

the qualifying interest(s) of a Natutra site(s) (the “Likely significant effect (LSE) stage”) and

ii. for those policies or proposals likely to have a significant effect, doing an ‘appropriate

assessment’ to ascertain that the plan will not adversely affect the integrity of the site(s) Up to page 60, the document takes a systematic approach to the first stage. Table 4.10 identifies that appropriate assessment is required for a range of polices and sites. However, in the chapter headed ‘Appropriate Assessment’ (Table 5.1), instead of addressing the question ‘will policy/site x have an adverse effect on the integrity of Natura site y’, the question posed is “Risk of LSE persisting?” This is not the right question for the appropriate assessment stage. In order to resolve this, we refer you to The Habitats Regulations Appraisal of Plans Guidance for Plan-Making Bodies in Scotland (http://www.snh.gov.uk/docs/A1500925.pdf). If you are genuinely concluding in Table 5.1 that there is no risk of LSE ‘persisting’, then there is no need to do stage 2. If however, it is just a case of confusion over the process and terminology, then the simplest and quickest solution would be to re-label the right hand column of Table 5.1 to “Adverse effects on site integrity”. 2. Reliance on general protective policies We note that the plan includes policy restrictions (E1) that require that some developments will not be permitted until additional works have been carried out (i.e. infrastructure put in place) to ensure the new development will not adversely affect the integrity of Natura sites. However, these are not ‘case specific’ but general in nature. We do not recommend that you rely only on the general Natura protective policy alone to offset possible adverse effects of specific allocations. This leaves the tension between some specific allocations and the Natura policy to be resolved at the development management stage. Instead, we recommend that the need for any mitigation/ infrastructure should be specifically set out against the allocation in question within the LDP itself, e.g. submission of construction method statement to protect water quality, need for upgrade to sewage works, etc. We have suggested where this might be done for specific allocations in our representation on the proposed plan itself. Likewise the need for contributions to larger-scale mitigation strategies being coordinated by the Council through developer contributions should be included in the LDP and cross-referred from relevant site allocations. 3. Assessment vs appraisal We note you have called the document ‘Habitats Regulations Assessment’. We suggest you rename it “Habitats Regulations Appraisal”. This is because HRA is a 2 stage process (see above). Calling this 2 stage process ‘Habitats Regulations Appraisal’ avoids confusion with stage 2, the appropriate assessment. HRA applies to the whole plan, but only parts of the plan may need an appropriate assessment.


Page 3 of 8

4. Housing allocations and abstraction from the River Dee We do not consider it possible at this stage for the HRA Record to conclude that there would be no adverse effect on the integrity of River Dee SAC. We note that the mitigation measures in this HRA refer to plan policies that require developers to “make adequate provision….for water as appropriate…”.and that development will not proceed until the infrastructure for water supply is in place. We also note that Policy C1 ‘Using Resources in Buildings’ requires developments to be water-efficient (Gold sustainability level for domestic buildings and BREEAM level 5 standard for non-domestic buildings), though there is no information about the possible impacts of this on water demand. Given that, in practice, there are no alternative water sources to service many of the new allocations, we understand that (whatever new infrastructure is in place) water will be still need to be sourced from the Dee for the majority of new allocations. This is recognised by the Strategic Environmental Assessment (Table 1.1 and Appendix 1.8) which states that “although the LDP promotes water efficiency technologies, the scale of water efficiency technologies envisaged may not be able to compensate for the volume and quality of water resources needed to support the allocations”. The HRA therefore needs to ensure it has adequately demonstrated (at the plan level) that housing allocations would not have an adverse effect on the integrity of the River Dee SAC. This issue was most recently addressed by the Aberdeen City and Shire Strategic Development Plan (ACSSDP). It was concluded with respect to that plan that the level of water abstraction needed to service the housing allocations would not have an adverse effect on the integrity of the River Dee SAC. This was partly because it could rely on HRA of the lower tier plans (LDPs) to revisit the issue, but we understand that this conclusion was also largely based on advice from Scottish Water that because of upgrades to infrastructure (and provided strict water efficiency measures were applied to new developments), abstraction from the River Dee would not need to increase (beyond that currently licenced) to service the new housing. The ACSSDP also included (as mitigation) an explicit target set out on page 31 to “avoid having to increase the amount of water Scottish Water are licensed to take from the River Dee, as a result of the new development proposed in the plan”. Given that the LDP sets out in spatial terms how part of the development envisaged in the strategic plan will be delivered, there is a clear need for the LDP to address whether that target will indeed be achieved in practice, because it is fundamental to assessing the effects of the plan on the River Dee SAC. If a later iteration of the HRA record for the LDP therefore includes explicit confirmation that Scottish Water and SEPA advise (supported by the most up to date information about abstraction levels, the levels of proposed development and the implications of the water efficiency policies) that this target still remains achievable (in the context of LDP proposals) then it will be possible to conclude that the Aberdeenshire LDP will not have an adverse effect on the integrity of the River Dee SAC. While all the settlements near to the River Dee SAC are noted as having LSE (among other reasons) for water abstraction (WA), it should be borne in mind that this issue is not confined to just these particular settlements, but to all the settlements in the LDP area which draw their water supply from the River Dee. We understand this to be north as far as Ellon and Gartly, and south as far as Stonehaven. We therefore advise that you include all such settlements and allocations in the relevant table and identify them as having LSE on the River Dee SAC.


Page 4 of 8

5. Other comments a. Pages 15-28 Table 3.2 Analysis of Natura sites We suggest this table is updated and/or corrected to reflect more recent condition monitoring results. In addition, some qualifying interests need to be removed, because they seem to have been included in the table in error: - Buchan Ness to Collieston Coast SAC:

Vegetated sea cliffs, still favourable maintained but date should be changed to 21/05/10 – Hill of Towanreef SAC:

Blanket bog Unfavourable Declining – change date to 28/08/2013 Marsh saxifrage (Saxifraga hirculus) Favourable Maintained change date to 27/08/2008 Alpine and subalpine heaths Favourable Maintained change date to 12/09/2007 Dry heaths Unfavourable Declining change date to 12/09/2007 Juniper on heaths or calcareous grasslands Favourable Maintained change date to 12/09/2007 Grasslands on soils rich in heavy metals Favourable Maintained change date to 12/09/2007

– Ythan Estuary, Sands of Forvie and Meikle Loch SPA:

Little tern (Sternula albifrons), breeding Favourable Maintained change date to 01/08/2012 Sandwich tern (Sterna sandvicensis), breeding Favourable Maintained change date to 01/08/2012 Lapwing (Vanellus vanellus), non-breeding Favourable Maintained change date to 18/08/2012 Waterfowl assemblage, non-breeding Favourable Maintained change date to 19/10/2012 Redshank (Tringa totanus), non-breeding Favourable Maintained change date to 19/10/2012 Pink-footed goose (Anser brachyrhynchus), non-breeding Favourable Maintained change date to 06/11/2012

– Sands of Forvie SAC:

Shifting dunes Favourable Maintained change date to 11/08/2011 Humid dune slacks Favourable Maintained change date to 11/08/2011 Shifting dunes with marram Favourable Maintained change date to 12/08/2011 Lime-deficient dune heathland with crowberry Favourable Maintained change date to 19/05/2010

– Loch of Strathbeg SPA:

Pink-footed goose (Anser brachyrhynchus), non-breeding Favourable Maintained change date to 01/04/2009 Svalbard Barnacle goose (Branta leucopsis), non-breeding Favourable Maintained change date to 01/04/2009 Whooper swan (Cygnus cygnus), non-breeding Favourable Maintained change date to 01/04/2009 Teal (Anas crecca), non-breeding Favourable Maintained change date to 01/04/2009 Waterfowl assemblage, non-breeding Favourable Maintained change date to 01/04/2008 Sandwich tern (Sterna sandvicensis), breeding Unfavourable Declining change date to 31/07/2004

– Troup, Pennan and Lion’s Heads SPA – remove habitats from the list of interests

– Moray Firth SAC – remove the habitats listed after bottlenose dolphins from the list of

interests (the subtidal sandbanks listed above the dolphins should remain though)


Page 5 of 8

– Dinnet Oakwood SAC, Morven and Mullachdubh SAC, Muir of Dinnet SAC, Glen Tanar SAC and the Cairngorm Massif SPA - we suggest these are removed from this table. They are either not within the plan area and/or we do not consider there likely to be connectivity between these sites and the policies and/or allocations in the LDP.

b. Pages 35-36 Table 4.3 Assessment of sites - Buchan We note site R2 is not included under Peterhead. This is an allocation related to the national developments for CCS and energy-related development at Peterhead Power Station. While accepting that the HRA of NPF3 has considered this, it would be helpful for this HRA to confirm that there is nothing about the specific site allocation that changes the conclusions of the HRA of NPF3 in relation to this site. It would also be useful to confirm that the mitigation proposed in relation to that assessment is relevant to the specific sites now allocated. c. Pages 45-48 Table 4.9 Risk of LSE from Settlements/ Allocations – Gardenstown: We note this is included in the table (though without any effects being

identified) and understand this may have been because of previous informal SNH advice. We have re-considered this proposal and now advise that because of the small scale of the proposal, there is no likelihood of a significant effect on the qualifying interests of Troup, Pennan and Lion’s Heads SPA.

– Drumoak, Kirkton of Maryculter, Park: We note these are included in the table, though

without any effects being identified. We advise that allocations in these settlements could have a likely significant effect on the River Dee SAC because of possible effects on water quality, water abstraction and effects of pollution. In practice, if the specific infrastructure required to be in place before the development proceeds is set out in the proposals section (as is partly the case with Park), it will be reasonable to conclude that in these allocations will not (individually) have an adverse effect on the integrity of the River Dee SAC.

– Stonehaven (Garron Point SAC and Fowlsheugh SPA): We note these are included in the

table (though without any effects being identified) and understand this may be because of previous informal SNH advice. We have re-considered the proposals for Stonehaven and advise that a likely significant effect on the qualifying interests of these sites can be ruled out because there is no connection between what is proposed and the qualifying interests of these sites.

– Longhaven: We suggest this is removed from Table 4.9. The allocation is about 800m

from the Buchan Ness to Collieston Coast SPA/Buchan Ness to Collieston SAC. We advise there would be no likely significant effect on the qualifying interests of either Natura site because of the distance from the site and the size of the proposal.

– Foveran: Allocations for 56 units are included in the LDP, the largest being OP1 (50 units)

north of Foveran Burn. This is about 3 km upstream of Ythan Estuary, Sands of Forvie and Meikle Loch SPA. We advise there would be no likely significant effect, and that these can be screened out (alone and in combination) because of the distance from the site and the relatively small size of the proposal.

– Newburgh: Allocations for 100 units are included in the LDP, across two roughly equal

sites on the west side of the village. Newburgh lies adjacent to Ythan Estuary, Sands of Forvie and Meikle Loch SPA. Therefore these allocations are about 300-500m distant from the SPA. Issues relate to recreational impact but more significantly water quality. The LDP already includes a policy caveat for both allocations that any revised masterplan or a planning application will need to contain a construction method statement to take account of the potential impacts to the qualifying interests of the SPA/Ramsar.


Page 6 of 8

Such a CMS should therefore cover safeguarding of water quality. Accordingly while we advise a likely significant effect on the qualifying interests of the SPA, the HRA Record can note this mitigation already in the LDP as policy caveats to OP1 and OP2, so that there should be no adverse effect on site integrity.

– Westhill: Allocations for 200 units are included in the LDP, along with business

allocations. Loch of Skene SPA is located about 2 km west of Westhill, and the housing allocations are on the west edge of the settlement. Recreational activity – both on the water and along the shore – is being monitored at Loch of Skene, with guidance panels having been placed in 2010. We advise that significant effects can be ruled out because of the relatively small scale of the proposals and the negligible increase in activity this is likely to result in near the loch.

– Chapelton of Elsick: This new settlement includes over 4000 homes and 11.5 ha of

employment land. Its western boundary is about 500m from Red Moss of Netherley SAC, but it is outside the relevant water catchment, and so there will be no impact on the drainage/hydrology of the SAC. We therefore advise there would be no likely significant effect, and that this can be screened out (alone and in combination).

– Logie Coldstone: An allocation for 25 units is included in the LDP. The River Dee SAC

(which includes Logie Burn) runs along the western edge of the settlement. A small watercourse is marked on the map as running from the southern corner of site OP1 draining to Logie Burn. Apart from water abstraction (which is a general issue relating to many settlements in the plan area reliant upon the River Dee for water supply) the likely significant effects relate to water quality and possible disturbance to otter if present on the site. Standard mitigation to safeguard water quality would include buffers by watercourses, construction method statement, SUDS and connection to WWTW with sufficient capacity. Standard mitigation to safeguard species would be a species survey and protection plan. Therefore while there would be a likely significant effect from this allocation, these forms of mitigation can be noted to demonstrate no adverse effect on site integrity. We would also recommend that text should be added to the LDP for OP1 that a construction method statement is required, to take account of potential impacts to the qualifying interests of the River Dee SAC.

– Strachan: An allocation for 15 units is included in the LDP. The River Dee SAC (which

includes the Water of Feugh) is immediately to the south of the settlement. A small watercourse runs along the western side of site OP1 and flows into the Water of Feugh. Apart from water abstraction (which is a general issue relating to many settlements in the plan area reliant upon the River Dee for water supply) the likely significant effects relate to water quality and possible disturbance to otter if present on the site. Standard mitigation to safeguard water quality would include buffers by watercourses, construction method statement, SUDS and connection to WWTW with sufficient capacity. Standard mitigation to safeguard species would be a species survey and protection plan. Therefore while there would be a likely significant effect from this allocation, these forms of mitigation can be noted to demonstrate no adverse effect on site integrity. We would also recommend that text should be added to the LDP for OP1 that a construction method statement is required, to take account of potential impacts to the qualifying interests of the River Dee SAC.

– Tarland: Allocations for 86 units are included in the LDP (plus 10 units near Alastrean

House), plus employment land. The River Dee SAC (which includes Tarland Burn and Burn of Glaaick) runs through the settlement and near its western edge. Site OP1 (50 units) is adjacent to the SAC, separated by Burnside Road.


Page 7 of 8

Site OP3 (36 units) is about 200m from the Burn of Glaaick, separated by open farmland, and has full planning permission. For site OP3 the HRA Record can note any mitigation included as part of the planning application or required within the planning permission. For site OP1 apart from water abstraction (which is a general issue relating to many settlements in the plan area reliant upon the River Dee for water supply) the likely significant effects relate to water quality and possible disturbance to otter if present on the site. Standard mitigation to safeguard water quality would include buffers by watercourses, construction method statement, SUDS and connection to WWTW with sufficient capacity. Standard mitigation to safeguard species would be a species survey and protection plan. Therefore while there would be a likely significant effect from this allocation, these forms of mitigation can be noted to demonstrate no adverse effect on site integrity. We would also recommend that text should be added to the LDP for OP1 that a construction method statement is required, to take account of potential impacts to the qualifying interests of the River Dee SAC.

– Torphins: An allocation for 48 units plus a business park is included in the LDP. The

River Dee SAC (which includes the Beltie and Learney Burns) runs along either side of the settlement. Site OP1 is about 100m from the SAC, separated by open farmland, and has planning permission in principle. Apart from water abstraction (which is a general issue relating to many settlements in the plan area reliant upon the River Dee for water supply) the likely significant effects relate to water quality and possible disturbance to otter if present on the site. Standard mitigation to safeguard water quality would include buffers by watercourses, construction method statement, SUDS and connection to WWTW with sufficient capacity. Standard mitigation to safeguard species would be a species survey and protection plan. Therefore while there would be a likely significant effect from this allocation, these forms of mitigation can be noted to demonstrate no adverse effect on site integrity. We would also recommend that text should be added to the LDP for OP1 that a construction method statement is required, to take account of potential impacts to the qualifying interests of the River Dee SAC.

d. Pages 62-65 Table 5.1 Appropriate Assessment of policies Policies H1 Housing Land and B1 Employment/Business Land – as noted above, this is a place where the in-combination cumulative effect on the SAC of all housing and business allocations served by the River Dee in terms of water supply can be considered. We understand this to require inclusion of all allocations as far north as Ellon and Gartly, and as far south as Stonehaven (ie bringing in other settlements not so far considered in this HRA, e.g. potentially Inverurie/Port Elphinstone, Kintore, Newmachar, Balmedie, Blackdog, Alford). e. Policy C2 Renewable Energy The key issue here is likely to be the indirect effect on SPAs of the identification of ‘Areas of Strategic Capacity’ or ‘Areas with potential for wind farm development’ within wind energy spatial frameworks and policy maps. A wind energy proposal within such an area may have a likely significant effect on an SPA because of connectivity with the qualifying species (eg flight paths, feeding or roosting area). There appears to be nothing in Policy C2 Renewable Energy that says that impact on natural heritage, including birds, is a policy criterion for planning applications (as included in paragraph 169, bullet point 7 of SPP).


Page 8 of 8

Therefore, we would advise that the HRA should explain how the protective aspect of Policy E1 Natural Heritage will be applied alongside Policy C2 and associated policy frameworks (e.g. cross-referencing, to add effect on the natural heritage as an identified policy criterion (SPP, Table 1, Group 3 areas with potential for wind farm development). f. In-combination likely significant effects? The HRA should consider if minor residual effects (MRE) may combine to result in in-combination likely significant effect (see guidance). We advise that in combination, as well as alone, Drumoak, Kirkton of Maryculter, Park, Crathes and Finzean/Whitestone would have minor residual effects on the River Dee SAC and this should be recorded in the HRA Record. The Scottish Government has established a Knowledge Databank for HRA Records, to enable future HRAs to access data for in-combination assessment – see http://www.gov.scot/Resource/0046/00466525.pdf

In terms of public water and wastewater provision in these remote areas, private supplies and treatment may be a viable option. However, should a developer wish to connect to the public system and there be insufficient capacity at one of our WTW or WWTW, Scottish Water is funded to provide growth, whatever the size of the development, as long as one development meets our 5 Growth Criteria. Insufficient capacity should not be seen as a barrier to development as growth can only be triggered once demand exceeds the available existing capacity. Aside from the statement highlighted above, Scottish Water fully supports the approach of promoting sustainable development near the smaller settlements, thereby making use of existing infrastructure and reducing the cost to developers for off-site infrastructure extensions. Section 7 – Shaping Formartine, page 17, paragraph 1 - Insufficient capacity should not be seen as a barrier to development and should not “restrict what can be planned”. Scottish Water is funded to provide growth at our WTW and WWTW, so long as one development meets our 5 Growth Criteria, so we would discourage the removal of allocations solely on the basis of limited water or wastewater capacity, as this can be overcome. We acknowledge that the timescale for delivering the growth project at Ellon WWTW means that there could be a delay to some developments getting their connection to the public sewer system. Scottish Water are doing all that they can to keep this project on track and, once delivered, it shall provide sufficient capacity for all known domestic development programmed out to 2027. Section 17 – Protecting Resources & Section 18 – Climate Change, page 55 & 60 – Scottish Water fully supports Aberdeenshire Council’s commitment to protecting the water environment and conserving water through the implementation of Policy PR1 Protecting Important Resources and C1 Using Resources in Buildings. From source to tap and then sink to sea, the production of drinking water, its daily consumption and its eventual safe return to the environment requires a substantial amount of energy. Therefore, the efficient use of water can have a positive impact on the water environment, as well as providing opportunities to reduce the amount of energy consumed and carbon produced as part of this water cycle. Section 19 – The Responsibilities of Developers, page 65 – Policy RD1 Providing Suitable Services sets out very clear guidelines for developers in relation to water and wastewater provision. Scottish Water is especially pleased to see that early engagement with SEPA and Scottish Water is encouraged. The earlier discussions can take place regarding a development, the easier it is to work together to mitigate against any potential issues without affecting the developer’s build programme. In regards to our Development Impact Assessments, these have been superseded by Pre-Development Enquiry (PDE) forms (found at www.scottishwater.co.uk). We recommend all planned development relating to more than a single house connection submits a PDE to Scottish Water as early as possible. In response we will provide an assessment of available capacity at the WTW and WWTW in question, as well as indicating whether further investigations will be required to provide a full assessment on whether local infrastructure upgrades may be necessary. Having this information upfront can prevent delays further down the line. Strategic Environmental Assessment – page 37 & 282 – The Strategic Asset Capacity Demand Plan (2009) referenced on these two pages is updated annually. The 2015

version can be found here: - https://www.scottishwater.co.uk/assets/business/files/connections%20documents/asset%20capacity%20search/2015sacdpreport.pdf. At the time of publication the number of public wastewater treatment works were recorded as 1836 and 256 for water treatment works. Strategic Environmental Assessment – page 265 & 273 – The link for Scottish Water’s Asset Capacity Search Tool is now: - https://www.scottishwater.co.uk/business/connections/connecting-your-property/asset-capacity-search. However, it is currently offline while enhancements are made to its functionality. We trust that these statements are helpful and will add value to your document and help to clarify Scottish Water’s own obligations. Should you require any further assistance, please do not hesitate to get in touch.

Yours faithfully

Susanne Stevenson Development Planner – Scottish Water

Admin Area Settlement Scottish Water Comment on Capacity and Infrastructure

Banff and Buchan MemsieScottish Water will initiate a growth project at Memsie Cairn Stone ST, if demand exceeds available capacity, once one development meets the 5 growth criteria.

Banff and Buchan New Aberdour

There is limited capacity at New Aberdour WWTW. Scottish Water will initiate a growth project , should demand exceed available capacity, once one development meets the 5 growth criteria. Developers should engage with Scottish Water as early as possible.

Limited capacity should not be viewed as a constraint to development as funding will be made available for a growth project if required.

Banff and Buchan New BythThere is limited capacity at New Byth WWTW. Scottish Water will initiate a growth project , should demand exceed available capacity, once one development meets the 5 growth criteria.

Banff and Buchan Rathen

There is no public wastewater treatment in Rathen. SEPA would need to be consulted and full authorisation sought for relevant licensing of private treatment.

"Lack of waste water treatment infrastructure" suggests that there is insufficient capacity, rather than no public treatment.

Banff and Buchan RoseheartySome sites may need to upgrade local sewers to support their development, but we do not forsee the need to upgrade local water mains. The developer would fund this themselves and could then claim a Cost Constribution from Scottish Water. This would not be funded through Developer Obligations.

Banff and Buchan TyrieThere is limited capacity at Tyrie Bell Terrace ST. Scottish Water will initiate a growth project , should demand exceed available capacity, once one development meets the 5 growth criteria.

Buchan LonghavenNo public wastewater treatment available. SEPA would need to be consulted and full authorisation sought for relevant licensing of private treatment.

Buchan LongsideA growth project has been triggered at Longside WWTW, which will take into account all known domestic development up to 2027.

Buchan Maud

There is capacity at Maud WWTW, however it is insufficient to treat all sites allocated for both Maud and New Deer. Scottish Water will initiate a growth project, should demand exceed available capacity, once one development meets the 5 growth criteria.

There is no longer an issue with New Deer Service Reservoir. Any comments alluding to this can be removed from the Action Programme.

Any local network upgrades required to support new development would be the responsibility of the developer.

Buchan New Deer

There is capacity at Maud WWTW, however it is insufficient to treat all sites allocated for both Maud and New Deer. Scottish Water will initiate a growth project, should demand exceed available capacity, once one development meets the 5 growth criteria.

There is no longer an issue with New Deer Service Reservoir. Any comments alluding to this can be removed from the Action Programme.

Any local network upgrades required to support new development would be the responsibility of the developer.

Formartine Balmedie

Local infrastructure upgrades may be required at OP1 and OP2 and will certainly be required for OP3. OP3 will also need to undertake a Water Impact Assessment.

Balmedie WWTW no longer has sufficient capacity to treat all allocated sites at Balmedie, Belhelvie, Newburgh and Potterton now that the Menie allocation has been added. Therefore the comment for Balmedie should be changed to read:‐

There is insufficient capacity at Balmedie WWTW to treat all sites allocated at Balmedie, Belhelvie, Newburgh and Potterton. Scottish Water will initiate a growth project, should demand exceed available capacity, once one development meets the 5 growth criteria.

Formartine BelhelvieThere is insufficient capacity at Balmedie WWTW to treat all sites allocated at Balmedie, Belhelvie, Newburgh and Potterton. Scottish Water will initiate a growth project, should demand exceed available capacity, once one development meets the 5 growth criteria.

Formartine Ellon

A water strategy is being developed for Ellon and it is not yet certain whether a new service reservoir will be required at Cromleybank or whether a new strategic reservoir will be built, this should be agreed in the next few weeks. Water Impact Assessments and Drainage Impact Assessments will be required for the larger developments. In regards to Ellon WWTW, as the settlement statements are to become Supplementary Guidance it may be best to say:‐Scottish Water has initiated a growth project at Ellon WWTW. Completion is currently programmed for 2017/18, but this could be subject to change as the project progresses. Developers are encouraged to engage with Scottish Water as early as possible to discuss the needs of their development.

Formartine Foveran Local mains and sewer upgrades may be required, rather than will.Formartine Garmond Local mains and sewer upgrades are unlikely. Any comment relating to this can be removed.

The comments below relate to the text presented in the Settlement Statements on water and wastewater infrastructure. Suggested amendments, which can replace the existing text verbatim, are shown in column C in black type. Additional information, which you may wish to take consideration of, is provided in red type.

Formartine Kirkton of AuchternessThere is currently no available capacity at St Donan's Cottages ST. Scottish Water will initiate a growth project once one development meets the 5 growth criteria.

Formartine Methlick Local mains and sewer upgrades may be required, rather than will.

Formartine Newburgh


Local main and sewer upgrades may be required, rather than will.Formartine Oldmeldrum Local mains upgrades may be required, rather than will.Formartine Pitmedden There is sufficient capacity at Pitmedden WWTW for site OP1.

Formartine Potterton

There is currently no development allocated at Potterton. Therefore it will be sufficient to say:‐Network investigations may be required by new developments.


Formartine Rashierieve Foveran

The Services and Infrastructure comments state that there is no public wastewater treatment available but also that a connection to public wastewater treatment is required. The nearest works is 1.5km away and may by economically unviable for the development. Therefore, it is suggested that text be amended to read:‐There is no public wastewater treatment in Rashierieve Foveran. SEPA would need to be consulted and full authorisation sought for relevant licensing of private treatment.

Formartine Rothienorman There is available capacity at Rothienorman WWTW. A growth project was delivered here at the end of 2013.

Formartine St Katherines

The Services and Infrastructure comments state that there is no public wastewater treatment available but also that a connection to public wastewater treatment is required. The nearest works is 3.5km away and may by economically unviable for the development. Therefore, it is suggested that text be amended to read:‐There is no public wastewater treatment in St Katherines. SEPA would need to be consulted and full authorisation sought for relevant licensing of private treatment.

Formartine Turriff

A growth project has not been triggered at Turriff WWTW yet, but it will once one development meets the 5 criteria:‐

There is currently insufficient capacity available at Turriff WWTW to meet the demands of all development allocated in the LDP. Scottish Water will initiate a growth project, should demand exceed available capacity, once one development meets the 5 growth criteria.

Garioch BlackburnThere is currently available capacity at Inverurie WWTW, however it is insufficient to to treat all development allocated at Blackburn, Inverurie, Keithhall and Kintore. A Capital Maintenance project has been triggered at Inverurie WWTW which will deliver growth.

Garioch Chapel of GariochNo public wastewater treatment available. SEPA would need to be consulted and full authorisation sought for relevant licensing of private treatment.

Garioch Cluny and Sauchen

There is capacity at Sauchen WWTW, however it is insufficient to treat all development allocated at Cluny and Sauchen. Scottish Water will initiate a growth project, should demand exceed available capacity, once one development meets the 5 growth criteria.

Site OP2 is 0.6km away from Sauchen WWTW. SEPA would need to be consulted and full authorisation sought for relevant licensing if development to have private treatment.

Garioch Dunecht There is currently sufficient capacity at Dunecht WWTW.

Garioch InverurieThere is currently available capacity at Inverurie WWTW, however it is insufficient to to treat all development allocated at Blackburn, Inverurie, Keithhall and Kintore. A Capital Maintenance project has been triggered at Inverurie WWTW which will deliver growth.

Garioch KeithhallThere is currently available capacity at Inverurie WWTW, however it is insufficient to to treat all development allocated at Blackburn, Inverurie, Keithhall and Kintore. A Capital Maintenance project has been triggered at Inverurie WWTW which will deliver growth.

Garioch KintoreThere is currently available capacity at Inverurie WWTW, however it is insufficient to to treat all development allocated at Blackburn, Inverurie, Keithhall and Kintore. A Capital Maintenance project has been triggered at Inverurie WWTW which will deliver growth.

Garioch OyneThere is currently limited capacity at Oyne Housing ST. Scottish Water will initiate a growth project, should demand exceed available capacity, once one development meets the 5 growth criteria.

Kincardine & Mearns

Edzell Woods

The information included for site OP1 is a little confusing. There are no public sewers at Edzell Woods, just the private works owned by Edzell Woods Owners Group. The nearest public WWTW is in Edzell, approx. 2km away. The developer could put in their own private treatment, which would require agreement from SEPA, or they they could seek permission from Edzell Woods Owners Group to connect into the private works. If the developer wishes to connect to the public Edzell WWTW they would need to lay all necessary infrastructure and a growth project would be required from Scottish Water to meet the demand of the full allocation. If the latter is the developers preferred option they should engage with Scottish Water as early as possible.

Kincardine & Mearns

GourdonA growth project has not been triggered at Nether Knox WWTW yet, but will once one development meets the 5 criteria.

Kincardine & Mearns

St CyrusA growth project has not been triggered at Nether Knox WWTW yet, but will once one development meets the 5 criteria.

Marr Clatt

Scottish Water will only initiate a growth project when demand exceeds the capacity available at a wastewater treatment works and the development meets the 5 growth criteria. The criteria have been set out by Scottish Ministers to provide reasonable certainty that the development will proceed before growth funding can be released. We have not received any development enquiries for Clatt for a number of years and so do not feel wastewater provision can be labelled as a constraint. Any developers interested in developing in Clatt should engage with Scottish Water as early as possible.

Marr DrumbladeNo public wastewater treatment available in Drumblade. SEPA would need to be consulted and full authorisation sought for relevant licensing of private treatment.

Marr Gartly

There is currently sufficient capacity at Gartly WWTW.

The comment regarding the need for a water growth project can be removed, as our preferred option is to increase flexabilty between water operational areas.

Marr KennethmontA growth project has been triggered at Kennethmont WWTW, which will take into account all known domestic development up to 2027.

Marr Logie ColdstoneThe comments regarding local water mains reinforcement and the need for a Drainage Impact Assessment for site OP1 can be removed.

Marr LumphananThere is currently capacity available at Lumphanan WWTW, however should demand exceed available capacity Scottish Water will initiate a growth project, once one development meets the 5 criteria.

Please use this form to make comments on the Proposed Aberdeenshire Local Development 2016. If you are making comments about more than one topic it would be very helpful if you

Please email or send the form to reach us by 8th May 2015 at the following address:

Post: Planning Policy Team Infrastructure ServicesAberdeenshire CouncilWoodhill HouseWestburn RoadABERDEENAB16 5GB

Email: [email protected]

Title

First name

Surname

Date

Postal Address

Postcode

Telephone Number

E-mail

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

Are you responding on behalf of another person? Yes No

If yes who are you representing

YOUR DETAILS

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

Mr

John

Wright

Strutt & Parker, 5 St John Street, Perth

PH1 5SP

01738 567 892

[email protected]

✔

✔

Aberdeen Endowments Trust

LDP – Proposed Plan Representation

Appendix 5 “New Housing Land Allocations” (Tables 1 “Summary of

housing land allocations” & 6 “New Housing Land – Kincardine and

Mearns”).

1. Modification that you wish to see

Allocate land west of Muchalls for a development of up to 32 houses to meet the shortfall in

the LDP in line with our other representations elsewhere.

2. Reason for Change

Strategic Development Plan (SDP) Figure 10 sets the Housing Requirement for the Aberdeen

and Rural Housing Market Areas (HMA) for the periods 2011-2016 (9,965 homes and 4,237

homes respectively), 2017-2026 (15,017 homes and 6,411 homes respectively) and 2027-

2035 (13,506 homes and 4,836 homes respectively).

SDP Schedule 1 shows the Housing Allowances needed to meet this requirement and, as

required by Scottish Planning Policy (SPP), these provide a “generous supply” of land for new

housing. The SDP requires both authorities to make land available in line with the Spatial

Strategy and Schedule 1 and indicates that phasing of land allocations for the period 2017-

2026 may be put in place where appropriate with a target density of 30 dwellings per

hectare (not specific whether net or gross) to be achieved.

However, the Schedule 1 Table indicates a total allowance for Aberdeen and Rural HMA for

the periods 2017-2026 of 14,750 and 5,700 homes, and 2027-2035 of 14,850 and 4,900

homes. Whilst the allowance for the Aberdeen HMA in the period 2017-2026 appears to be

some 267 homes less than the requirement, we acknowledge that this would have been

considered at the previous Examination and cannot now be revisited.

Turning to LDP Appendix 5, Table 1 Summary of housing land allocations we note the

contents of that table and are satisfied that the SDP allowances have been correctly

reflected in the table, and that as the allowances incorporate and allowance for a “generous

supply” of land there is no need to exceed these, we would nevertheless expect them to be

met in full by allocations in this LDP.

In most cases, the columns in the LDP indicate LDP Allocations short of the SDP Allowances

in both periods some 1,434 homes to 2016, and 1,493 homes in 2017-2026, across the LDP

Area. SPP is very clear that Local Development Plans “in city regions should allocate a range

of sites which are effective or expected to become effective in the plan period to meet the

housing land requirement of the strategic development plan up to year 10 from the expected

year of adoption” (SPP Para 119) and we believe that this should be rectified in order to

facilitate adoption of the plan.

In particular, in the Portlethen – Stonehaven Strategic Growth Area (SGA) there is a shortfall

in provision in the period to 2016 of 65 homes, and in the period 2017-2026 of some 30

homes against the SDP Allowance for this SGA.

Turning to Table 6, we would firstly highlight that Drumlithie would appear to fall within the

Portlethen to Stonehaven SGA rather than as shown on the table within the Local Growth

part of the area. However, as this site was an LDP2012 site, we believe that it should not

count towards meeting the SDP Allowance. Even if it were counted, it would only reduce

the shortfall by 15 units in the period to 2016 and 15 units in the period 2017-2026.

Chapelton of Elsick is obviously the significant development in this area; however, we would

question the ability to achieve the completions anticipated in the Housing Land Audit of 125

in 2016 and 200 units per year thereafter. This is a very significant level of completions

which, even in very strong market areas, if quite aspirational. Therefore, we believe that

there is the potential for further under delivery here which would have an impact on the

ability to meet the SDP Allowances in full.

Therefore, we are of the view that there is an under provision of housing land in the

Portlethen to Stonehaven SGA in the period to 2016 of at least 50 (potentially 65) homes

with a corresponding shortfall in the period to 2017-2026 of at least 15 (potentially 30)

homes, regardless of any shortfall resulting from under delivery of the current Chapelton of

Elsick programming. We believe that this must be met by additional housing allocations in

this SGA in this LDP and we have proposed an effective and deliverable site at Muchalls to

help address this.

LDP – Proposed Plan Representation

Appendix 8 “Settlement Statements Kincardine & Mearns”

(Muchalls Settlement Statement and Plan on pages 56 & 57)

1. Modification that you wish to see

We object to Appendix 8 (Muchalls, Page 56 & 57) and the non-allocation of land on the

western boundary of Muchalls for a medium scale residential development of up to 32

houses in this Local Development Plan period.

2. Reason for Change

As highlighted in our representations to Appendix 5 (Tables 1 & 6) we believe that there is a

shortfall of housing land in this Strategic Growth Area which requires further allocations of

land to be made.

The land outlined in red on the attached site plan has been promoted previously, but not

considered at the Local Development Plan Examination. The site has been put forward in

response to the “call for sites” and again at “Main Issues Report” stage of preparing this LDP.

The site has previously been identified by Officers in part as a “preferred” site for a

development of up to 10 houses with the balance of the site “not preferred”.

In response to the Main Issues Report a number of representations were received to the

preferred annotation at Muchalls highlighting the following issues:

• Transport (congestion, parking, road safety in the village, junction with A90 and possible

closure of the southern junction with A90, and impact on children’s play area);

• Impact on the heritage and amenity of the area (undermines status as Conservation

Village, visibility from A90, urban sprawl, ribbon development);

• Scale of development, location and benefits in would bring (insufficient scale to attract

services and facilities, projected declining population, disproportionate impact);

• Sustainability impacts (loss of agricultural land, unspoilt coast and coastal footpath,

commuting, flood risk);

The landowner has engaged a Transport Consultant to liaise with Aberdeenshire Council and

Transport Scotland regarding transport impact of development, and commissioned a Flood

Risk Assessment. Both of these reports are submitted as part of this representation. The

details are discussed below.

We have noted the reference in the Main Issues Report that the Conservation Area has been

degraded by inappropriate extensions to many of the cottages using poor materials which

has had a detrimental impact on the Conservation Area status. We believe that an

appropriately designed and landscaped development on this site could in fact enhance the

conservation area, and the currently open views of this exposed edge of Muchalls from the

A90.

We note and acknowledge the planning objectives for the settlement in the Proposed Plan

to preserve the amenity of the village which we believe can be accommodated through an

appropriately designed and landscaped development on this site.

Whilst it is encouraging to see capacity at Nigg Waste Water Treatment Works, we believe

that any capacity issue at Portlethen Academy could be dealt with through developer

contributions and does not need to prevent development from happening.

The Councils Strategic & Environmental Assessment indicates a neutral or positive impact on

all features except for “soil”. Whilst this is identified as grade 2 (and therefore prime quality)

agricultural land it is nevertheless a self contained parcel of land and would not set a

precedent for further development on surrounding land.

We have undertaken an access strategy (See attached Ramsay & Chalmers Report) which

has been prepared in consultation with the Council and Transport Scotland and concludes

that there is no safety issue with the junction of Dunyfell Road and the A90, and that subject

to development commencing post 2018 (still within the currency of this Local Development

Plan) Transport Scotland would have no objection to this. An access point for the

development site onto Dunyfell Road has been identified and is reflected on the attached

indicative layout for the development. This provides a loop through the site linking with

Nethermains Road (which could be a pedestrian only link if necessary) as well as providing

pedestrian connections to the rest of the settlement. We do not believe that this

development would have any impact on parking or traffic on the roads within the settlement

with all parking accommodated on site, and no need for any resident to drive through the

core of the settlement.

We have similarly undertaken a Stage 1 Flood Risk Assessment of the surface water drain

along the western boundary of the site and it has concluded that there is no flood risk to the

proposed development associated with this.

We believe that the land forms a logical infill and rounding off of the settlement and would

not set a precedent for further development or represent “urban sprawl” or “ribbon

development” as alleged in responses to the MIR. We are also of the view that this

development provides an opportunity to enhance the degraded Conservation Area through

a high quality landscaped development.

Capacity either exists or is a capable of being provided, there are no ownership issues that

would prevent development happening within the anticipated time frame and this is seen as

being a very marketable area helping to demonstrate the suitability of this site as an

allocation in the Local Development Plan to meet the current shortfall in this area.

The additional development could help support the Bistro, and potentially justify its

extension or expansion to provide additional services as well as supporting the existing bus

service. It would also make the existing refuse collection, mail delivery, and other services

more cost effective to provide.

We have undertaken a desktop development appraisal, taking into account build costs,

estimated planning gain and other costs associated with the development and have

discussed this with the land owner. This has confirmed that the development is viable

generating an appropriate return for the developer and an acceptable receipt for the

landowner. Therefore there is no land owner constraint and the site will be brought forward

upon receiving an allocation.

Telephone: (01224) 560700 Fax: (01224) 560701


Consulting Structural and Civil Engineers

Ramsay Chalmers Limited trading as Ramsay and Chalmers. Registered in Scotland No. SC210566 Registered Office: Chattan Mews Offices 18 Chattan Place Aberdeen AB10 6RD

Chattan Mews Offices 18 Chattan Place,

Aberdeen AB10 6RD

www.ramsaychalmers.co.uk

B9984

PROPOSED RESIDENTIAL DEVELOPMENT

AT MUCHALLS, ABERDEENSHIRE

PRELIMINARY ACCESS APPRAISAL

12/02/14


Project: Job No: B9984

Proposed Residential Date: 12/02/14

Development at Muchalls By: Tony Kivistik

Aberdeenshire Page: 2

3. PRELIMINARY ACCESS APPRAISAL / OPTION SIFTING

Access and egress to/from the site over the south or west boundary has from the outset been assumed unfeasible due to the requirements for 3rd party land-take. 3 potential access location options, from either the north or east boundary, have been appraised against ‘Key’ access criteria. A matrix comparing each option is shown in Figure 2.

Figure 2 – Option Appraisal Matrix for Simple ‘T’ Junction Vehicular Access

Location 1 – Access directly to/from Dunnyfell Road – Access to the development site could feasibly be taken

at this location. Visibility splay and junction spacing standards could be met and the number of residential units proposed could be accommodated.

Location 2 – Access to/from Marine Terrace via Nethermains Road - Access to the development site could

feasibly be taken at this location if visibility standards are relaxed. Junction spacing standards are currently met and the number of residential units proposed could be accommodated.

Location 3 – Access to/from Marine Terrace via unadopted road – Access at this location would likely not meet junction visibility splay guideline standards (even 1 below minimum standard).

Alternative Junction Types

Roundabout – Implementation of a small roundabout at Location 1 would potentially be feasible. A roundabout at this location could provide a ‘gateway’ to the settlement and provide a self enforcing traffic

calming measure on Dunnyfell Road. Other than at Location 1, implementation of a roundabout is likely unfeasible due to 3rd party land constraints and Stopping Sight Distance (SSD) requirements.

4. ACCESSIBILITY

A preliminary site layout plan and connectivity plan are attached in Appendix 1. The plans indicate a looped access/egress housing road through the site and the existing bus services and path networks in the area. As

shown, a network of footpaths are located adjacent to the proposed development which would link the development with recreational walking routes and bus service provision (access to northbound bus services requires crossing of the A90 at drop-kerb locations north of the Dunnyfell Road junction).

5. CONSULTATION

Aberdeenshire Council

A meeting was held between Ramsay & Chalmers (Tony Kivistik, Principal Consultant) and Aberdeenshire Council’s Roads & Transportation service (Mark Peters and Alasdair Macdonald, Principal Engineers) on 04/12/13 to discuss potential opportunities and constraints of the proposed site.

Access to/from the site was discussed and Aberdeenshire Council agreed that access and egress via a new

junction at Dunnyfell Road (indicated as Location 1 within Figure 1) is conceptually feasible. Aberdeenshire Council stated that, should the site be allocated within the Local Development Plan, their preference would be






for the site to be accessed from both Dunnyfell Road (Location1) and Nethermains Road (Location 2). The

council stated that a loop through the site would be desirable to accommodate access/egress at both locations.

Aberdeenshire Council stated that local residents are concerned at the vehicle waiting times regularly experienced at the A90/Dunnyfell Road junction. It was therefore suggested that Ramsay & Chalmers undertake a weekday peak period surveys to determine the spread of waiting times on a ‘typical’ day. Peak period surveys have therefore been undertaken and the full results are attached as Appendix 2.

The accessibility of the site to sustainable modes of transport such as walking, cycling and public transport was discussed at the meeting. All parties at the meeting agreed that existing services would be within the required 400m walking distance of the site (PAN 75 requirement). All parties agreed that there is a perceived safety issue in crossing the A90 using the existing informal drop kerb arrangement.

Road safety at the A90 adjacent to Muchalls was discussed and both parties agreed that it would be beneficial for the access appraisal to consider recent accident data/statistics (available by request from Transport

Scotland).

Transport Scotland

A consultation response was received by Transport Scotland on the 19th of December and is attached in full as Appendix 3 to this appraisal. The response includes a plot showing the severity and location of road traffic

accidents recorded between July 2010 (date of closure of the right-turn at the A90/Walker Street junction) and July 2013 at the A90 adjacent to Muchalls. The accident plot shows 1 Serious injury accident and 1 Slight injury accident located on the northbound carriageway approximately 170m and 210m north of the A90/Dunnyfell Road junction respectively.

Transport Scotland have stated within their response that the introduction of the AWPR in 2018 would result in a decrease in traffic flows on the section of the A90 adjacent to Muchalls. To develop the proposed site post-

opening of the AWPR would therefore likely be a condition of approval by Transport Scotland.

In further correspondence with Transport Scotland (see Appendix 3), the implementation of local road safety improvement measures (or a contribution towards their implementation) on approach to the A90/Dunnyfell Road junction have been proposed as part of the development of the site. These measures could, for example, include upgrade of the existing pedestrian crossing warning signs to flashing Variable Message Signs (VMS) – similar to those provided at other locations on the A90 that alert drivers to turning vehicles

ahead.

6. TRIP GENERATION

Table 1: Trip Rates calculated using TRICS Database*

Trip Rates

(per unit)

AM Peak (0800-0900)

Arrivals Departures

PM Peak (1700-1800)

Arrivals Departures

Total People 0.202 0.845 0.857 0.440

Vehicles 0.167 0.500 0.595 0.393

Car Occupants 0.190 0.714 0.714 0.417

PT Users 0.000 0.060 0.024 0.000

Pedestrians 0.000 0.060 0.083 0.024

Cyclists 0.012 0.012 0.036 0.000

*Refer to Appendix 4 for full TRICS output data.






Table 2: Trip Generation (Vehicles) calculated using TRICS Database*

Trip Generation

(32 units)

AM Peak (0800-0900)

Arrivals Departures

PM Peak (1700-1800)

Arrivals Departures

Total People 7 28 28 15

Vehicles 6 16 20 13

Car Occupants 6 23 23 14

PT Users 0 2 1 0

Pedestrians 0 2 3 1

Cyclists 1 1 1 0

*Refer to Appendix 4 for full TRICS output data.

It is considered that the calculated number of vehicle trips associated with the development proposals (approximately 1 vehicle every 2 minutes during peak periods) would not result in a significant adverse impact on either the local roads network or A90 trunk road.

7. SUMMARY

A preliminary site layout plan and connectivity plan are attached in Appendix 1. The plans indicate a looped access/egress housing road through the site and the existing bus services and path networks in the area. Extensive footway and path links are shown to/from Dunnyfell Road and Marine Terrace which are accessible

to the site.

Appendix 2 contains the full results of the turning vehicle waiting time surveys undertaken at the A90 / Dunnyfell Road junction. The results can be summarised as follows:

• during the surveyed AM peak period, 56% of vehicles make their required turn in 30 seconds or less

and 92% have a waiting time at the junction of less than 2 minutes;

• during the surveyed PM peak period, 44% of vehicles make their required turn in 30 seconds or less and 81% have a waiting time at the junction of less than 2 minutes.

As tabulated in Section 6 of this appraisal, the introduction of approximately 32 residential units would add approximately 1 vehicle every 2 minutes at peak periods and therefore would not result in a significant adverse impact on the roads network in the area.

The introduction of the AWPR in 2018 will likely result in a decrease in traffic using the section of the A90 adjacent to Muchalls. This will result in larger gaps between vehicles, consequently reducing crossing vehicle and pedestrian waiting times at locations such as the A90/Dunnyfell Road junction. It would be appropriate,

therefore, as stated by Transport Scotland, for any consented development at Muchalls to be conditioned as post-opening of the AWPR.


APPENDIX 1

PRELIMINARY SITE LAYOUT PLAN


APPENDIX 2

TURNING VEHICLE WAITING TIME SURVEY – A90/DUNNYFELL ROAD

A90 Junction at Muchalls A90/Dunnyfell Road

A (A90) C* (A90) *Location C1 is the midpoint of the junction

(central reservation) and location C2 is

B (Dunnyfell Rd) the Northbound A90 carriageway

Time Movement Delay/Waiting Time

727 B-A 12 seconds

730 B-C1 5 seconds

730 C1-C2 19 seconds

731 B-C1 28 seconds


733 B-C1 0 seconds


734 B-A 0 seconds

735 B-C1 2 seconds

735 C1-C2 1 min 51 seconds

737 B-C1 0 seconds


737 B-C1 1 min 48 seconds


738 B-A 1 min 55 seconds



746 B-A 12 seconds

746 A-B 7 seconds

747 B-C1 0 seconds


748 B-C1 0 seconds


753 B-C1 5 seconds


756 B-A 0 seconds

800 B-C1 12 seconds


801 B-A 0 seconds

805 B-C1 0 seconds


807 B-C1 0 seconds


808 B-C1 35 seconds

808 C1-C2 0 seconds

809 B-C1 21 seconds

809 C1-C2 2 mins 37 seconds

810 B-C1 13 seconds


812 B-C1 0 seconds

812 C1-C2 2 mins 37 seconds

813 B-C1 2 mins 9 seconds

08/01/2014


813 C1-C2 0 seconds

814 B-A 14 seconds

814 B-C1 0 seconds


816 B-C1 8 seconds


822 B-C1 0 seconds


822 B-C1 25 seconds

822 C1-C2 8 seconds

824 B-A 0 seconds

825 B-C1 4 seconds


826 B-C1 0 seconds


827 B-A 0 seconds

827 B-C1 20 seconds


828 B-C1 8 seconds


830 B-A 0 seconds

831 A-B 0 seconds

833 B-A 16 seconds

834 B-C1 2 seconds


835 B-C1 0 seconds




838 B-C1 7 seconds

838 C1-C2 0 seconds

840 A-B 0 seconds

840 B-C1 6 seconds

840 C1-C2 6 seconds

843 B-C1 0 seconds


843 B-C1 0 seconds

843 C1-C2 8 seconds

844 B-C1 3 seconds


844 B-C1 12 seconds


844 B-C1 57 seconds


845 B-A 10 seconds

845 A-B 5 seconds

849 B-C1 0 seconds


850 B-C1 51 seconds



851 B-A 0 seconds


851 C1-C2 0 seconds

851 B-C1 47 seconds

851 C1-C2 0 seconds

851 B-C1 0 seconds

851 C1-C2 0 seconds

852 B-C1 0 seconds

852 C1-C2 6 seconds

853 B-C1 18 seconds

853 C1-C2 4 seconds

857 B-C1 5 seconds


858 B-C1 2 seconds


859 B-A 2 seconds

900 B-C1 0 seconds


901 B-C1 5 seconds


902 B-C1 2 seconds


903 B-C1 16 seconds

903 C1-C2 0 seconds

903 B-C1 7 seconds


906 B-A 0 seconds

909 B-A 0 seconds

911 B-C1 46 seconds

911 C1-C2 0 seconds

922 B-C1 0 seconds

922 C1-C2 6 seconds

922 B-A 2 seconds

924 B-C1 4 seconds


926 B-C1 8 seconds

926 C1-C2 9 seconds

A90 Junction at Muchalls A90/Dunnyfell Road

A (A90) C* (A90) *Location C1 is the midpoint of the junction

(central reservation) and location C2 is

B (Dunnyfell Rd) the Northbound A90 carriageway


1600 B-A 17 seconds

1601 B-A 6 seconds

1602 A-B 50 seconds

1606 B-A 15 seconds

1608 B-C1 6 seconds

1608 C1-C 13 seconds

1609 A-B 18 seconds

1612 B-C1 9 seconds

1612 C1-C 0 seconds

1616 B-C1 32 seconds

1616 C1-C 0 seconds


1623 C1-C 9 seconds


1624 C1-C 0 seconds

1627 B-A 0 seconds

1627 B-A 30 seconds

1627 A-B 2 mins 10 seconds

1632 B-C1 8 seconds

1632 C1-C 9 seconds



1633 A-B 10 seconds

1640 B-A 7 seconds




1643 B-A 3 mins 25 seconds

1649 B-A 40 seconds





1655 C1-C 0 seconds

1657 B-C1 2 mins

1657 C1-C 0 seconds

1657 B-A 2 mins


1702 C1-C 0 seconds


1703 C1-C 5 seconds

1703 B-C1 4 mins

12/12/2013


1703 C1-C 0 seconds


1704 C1-C 5 seconds


1705 C1-C 0 seconds


1707 C1-C 0 seconds


1707 C1-C 5 seconds

1708 A-B 49 seconds

1708 A-B 57 seconds

1712 A-B 1 min 36 seconds


1714 C1-C 7 seconds

1716 B-A 1 min 6 seconds


1719 C1-C 8 seconds


1720 C1-C 8 seconds


1725 B-C1 6 seconds

1725 C1-C 4 seconds

1732 B-A 14 seconds







1736 B-A 10 seconds


1739 C1-C 0 seconds


1740 C1-C 0 seconds

1742 B-C1 9 seconds

1742 C1-C 0 seconds



1751 A-B 20 seconds



1754 B-A 10 seconds

1754 A-B 5 seconds

1755 B-C1 9 seconds

1755 C1-C 0 seconds

1757 B-A 12 seconds



1804 A-B 26 seconds




1814 B-A 10 seconds

1816 B-A 13 seconds



1820 B-A 7 seconds



1823 B-C1 2 seconds

1823 C1-C 5 seconds


1824 C1-C 0 seconds

1827 B-C1 5 seconds

1827 C1 - C 0 seconds

1828 A-B 8 seconds


APPENDIX 3

TRANSPORT SCOTLAND CONSULTATION RESPONSE

1

Tony Kivistik

From: [email protected]

Sent: 19 December 2013 11:26

To: Tony Kivistik

Cc: [email protected];

[email protected];

[email protected]; [email protected];

[email protected]

Subject: Muchalls Site - LDP Review

Tony, Further to your discussions and correspondence with Jason Gillespie I have reviewed the available information and can provide a response as follows… The intensification of use of the existing A90 at grade junction at Muchalls is not desirable from a road safety perspective in advance of the AWPR. As stated in SPP; “Development proposals that have the potential to affect the performance or safety of the strategic transport network need to be appraised to determine their effects. If required, mitigation measures should be agreed with Transport Scotland that would, where practicable, achieve no net detriment to safety or in overall performance, including journey times and connections, emissions reduction and accessibility.” Due to the current traffic flow on the A90 at this location and the limited options for proportionate and practicable mitigation measures to achieve no net detriment (in particular in terms of the potential safety concerns relating to increased turning movements) I would suggest that any further consideration of developments affecting the junction would almost certainly be conditional on completion of the AWPR. Kind Regards, _______________________________________________

a

David Torrance BEng CEng MICE MCIHT Technical Analysis Branch Major Transport Infrastructure Projects T: 0141 272 7587 M: 07827232456 Transport Scotland Buchanan House 58 Port Dundas Road Glasgow G4 0HF _______________________________________________ Transport Scotland, the national transport agency

1

Tony Kivistik

From: Tony Kivistik

Sent: 23 January 2014 15:47

To: '[email protected]'

Subject: Road Safety at Muchalls Site _ LDP Review... [Filed 23 Jan 2014 16:22]

Attachments: A90 Muchalls _ Accident Plot.xlsx

David,

Further to our telephone discussion earlier this afternoon, the attached plot shows the number of recorded

accidents which occurred between July 2010 (date of closure of the right-turn at the A90/Walker Street junction)

and July 2013 at the A90 adjacent to Muchalls…

My client is aware that local residents of Muchalls have safety concerns regarding the current and potential future

safety of pedestrians crossing the A90 to access bus services.

My client understands that the inclusion and timing of the proposed site within the LDP would potentially be

conditional on the opening of the AWPR and the consequential reduction of traffic flow on the A90. It is my

professional opinion and also that of my client, however, that a reduction of traffic flow following opening of the

AWPR will not significantly reduce the safety concerns that the local community have regarding crossing of the dual

carriageway.

In order to help improve road safety at this location it is therefore proposed, as part of the development of the site,

to provide local improvement measures (or a contribution towards their implementation) on approach to the

A90/Dunnyfell Road junction. Measures could include, for example, the introduction of signage to alert drivers to

the likelihood of crossing pedestrians (perhaps VMS signs similar to those provided at other locations on the A90

that alert drivers to turning vehicles ahead). Would proposed measures such as this potentially be welcomed by

Transport Scotland?

Best regards Tony Kivistik BSc (Hons), MSc, MCIHT

Principal Transport Planning Consultant Mobile: 07507 540 083

Consulting Structural & Civil Engineers Chattan Mews Offices Telephone: (01224) 560700

18 Chattan Place Fax: (01224) 560701

Aberdeen Email: [email protected] AB10 6RD Web: www.ramsaychalmers.co.uk

A90 - ACCIDENT PLOT _ MUCHALLS AREA

Date Period: 01/07/2010 - 30/06/2013

Year Fatal Serious Slight

2010 - from 1st July 0 0 0

2011 0 1 1

2012 0 0 0

2013 - Data up to 30th June 0 0 0

TOTAL 0 1 1


APPENDIX 4

TRICS DATABASE OUTPUT

TRICS 2013(b)v6.12.2 281113 B16.07 (C) 2013 JMP Consultants Ltd on behalf of the TRICS Consortium Tuesday 17/12/13

Muchalls Page 1

Ramsay & Chalmers 18 Chattan Place Aberdeen Licence No: 854401

TRIP RATE CALCULATION SELECTION PARAMETERS:

Land Use : 03 - RESIDENTIAL

Category : A - HOUSES PRIVATELY OWNED

MULTI-MODAL VEHICLES

Selected regions and areas:

02 SOUTH EAST

ES EAST SUSSEX 1 days

06 WEST MIDLANDS

SH SHROPSHIRE 1 days

16 ULSTER (REPUBLIC OF IRELAND)

CV CAVAN 1 days

This section displays the number of survey days per TRICS® sub-region in the selected set

Filtering Stage 2 selection:

This data displays the chosen trip rate parameter and its selected range. Only sites that fall within the parameter range

are included in the trip rate calculation.

Parameter: Number of dwellings

Actual Range: 10 to 37 (units: )

Range Selected by User: 10 to 50 (units: )

Public Transport Provision:

Selection by: Include all surveys

Date Range: 01/01/09 to 30/05/13

This data displays the range of survey dates selected. Only surveys that were conducted within this date range are

included in the trip rate calculation.

Selected survey days:

Tuesday 1 days

Friday 2 days

This data displays the number of selected surveys by day of the week.

Selected survey types:

Manual count 3 days

Directional ATC Count 0 days

This data displays the number of manual classified surveys and the number of unclassified ATC surveys, the total adding

up to the overall number of surveys in the selected set. Manual surveys are undertaken using staff, whilst ATC surveys are

undertaking using machines.

Selected Locations:

Edge of Town 3

This data displays the number of surveys per main location category within the selected set. The main location categories

consist of Free Standing, Edge of Town, Suburban Area, Neighbourhood Centre, Edge of Town Centre, Town Centre and

Not Known.

Selected Location Sub Categories:

Residential Zone 1

No Sub Category 2

This data displays the number of surveys per location sub-category within the selected set. The location sub-categories

consist of Commercial Zone, Industrial Zone, Development Zone, Residential Zone, Retail Zone, Built-Up Zone, Village, Out

of Town, High Street and No Sub Category.


Muchalls Page 2


Filtering Stage 3 selection:

Use Class:

C 3 3 days

This data displays the number of surveys per Use Class classification within the selected set. The Use Classes Order 2005

has been used for this purpose, which can be found within the Library module of TRICS®.

Population within 1 mile:

1,001 to 5,000 2 days

5,001 to 10,000 1 days

This data displays the number of selected surveys within stated 1-mile radii of population.

Population within 5 miles:

5,001 to 25,000 2 days

75,001 to 100,000 1 days

This data displays the number of selected surveys within stated 5-mile radii of population.

Car ownership within 5 miles:

1.1 to 1.5 3 days

This data displays the number of selected surveys within stated ranges of average cars owned per residential dwelling,

within a radius of 5-miles of selected survey sites.

Travel Plan:

Yes 1 days

No 2 days

This data displays the number of surveys within the selected set that were undertaken at sites with Travel Plans in place,

and the number of surveys that were undertaken at sites without Travel Plans.


Muchalls Page 3


LIST OF SITES relevant to selection parameters

1 CV-03-A-01 D E T A C H E D CAVAN

DUBLIN ROAD

C A V A N

Edge of Town

No Sub Category

Total Number of dwellings: 3 7

Survey date: TUESDAY 18/12/12 Survey Type: MANUAL

2 ES-03-A-02 PRIVATE HOUSING EAST SUSSEX

SOUTH COAST ROAD

PEACEHAVEN

Edge of Town

Residential Zone


Survey date: FRIDAY 18/11/11 Survey Type: MANUAL

3 SH-03-A-03 DETATCHED SHROPSHIRE

SOMERBY DRIVE

BICTON HEATH

SHREWSBURY

Edge of Town

No Sub Category


Survey date: FRIDAY 26/06/09 Survey Type: MANUAL

This section provides a list of all survey sites and days in the selected set. For each individual survey site, it displays a

unique site reference code and site address, the selected trip rate calculation parameter and its value, the day of the week

and date of each survey, and whether the survey was a manual classified count or an ATC count.


Muchalls Page 4


TRIP RATE for Land Use 03 - RESIDENTIAL/A - HOUSES PRIVATELY OWNED

MULTI-MODAL VEHICLES

Calculation factor: 1 DWELLS

BOLD print indicates peak (busiest) period

ARRIVALS DEPARTURES TOTALS

No. Ave. Trip No. Ave. Trip No. Ave. Trip

Time Range Days DWELLS Rate Days DWELLS Rate Days DWELLS Rate

00:00 - 01:00

01:00 - 02:00

02:00 - 03:00

03:00 - 04:00

04:00 - 05:00

05:00 - 06:00

06:00 - 07:00

3 28 0.083 3 28 0.357 3 28 0.44007:00 - 08:00

3 28 0.167 3 28 0.500 3 28 0.66708:00 - 09:00

3 28 0.226 3 28 0.321 3 28 0.54709:00 - 10:00

3 28 0.167 3 28 0.202 3 28 0.36910:00 - 11:00

3 28 0.250 3 28 0.262 3 28 0.51211:00 - 12:00

3 28 0.488 3 28 0.369 3 28 0.85712:00 - 13:00

3 28 0.607 3 28 0.595 3 28 1.20213:00 - 14:00

3 28 0.560 3 28 0.560 3 28 1.12014:00 - 15:00

3 28 0.357 3 28 0.321 3 28 0.67815:00 - 16:00

3 28 0.655 3 28 0.440 3 28 1.09516:00 - 17:00

3 28 0.595 3 28 0.393 3 28 0.98817:00 - 18:00

3 28 0.500 3 28 0.429 3 28 0.92918:00 - 19:00

19:00 - 20:00

20:00 - 21:00

21:00 - 22:00

22:00 - 23:00

23:00 - 24:00

Total Rates: 4.655 4.749 9.404

This section displays the trip rate results based on the selected set of surveys and the selected count type (shown just

above the table). It is split by three main columns, representing arrivals trips, departures trips, and total trips (arrivals plus

departures). Within each of these main columns are three sub-columns. These display the number of survey days where

count data is included (per time period), the average value of the selected trip rate calculation parameter (per time

period), and the trip rate result (per time period). Total trip rates (the sum of the column) are also displayed at the foot of

the table.

To obtain a trip rate, the average (mean) trip rate parameter value (TRP) is first calculated for all selected survey days

that have count data available for the stated time period. The average (mean) number of arrivals, departures or totals

(whichever applies) is also calculated (COUNT) for all selected survey days that have count data available for the stated

time period. Then, the average count is divided by the average trip rate parameter value, and multiplied by the stated

calculation factor (shown just above the table and abbreviated here as FACT). So, the method is: COUNT/TRP*FACT. Trip

rates are then rounded to 3 decimal places.

Parameter summary

Trip rate parameter range selected: 10 - 37 (units: )

Survey date date range: 01/01/09 - 30/05/13

Number of weekdays (Monday-Friday): 3

Number of Saturdays: 0

Number of Sundays: 0

Surveys manually removed from selection: 0

This section displays a quick summary of some of the data filtering selections made by the TRICS® user. The trip rate

calculation parameter range of all selected surveys is displayed first, followed by the range of minimum and maximum

survey dates selected by the user. Then, the total number of selected weekdays and weekend days in the selected set of

surveys are show. Finally, the number of survey days that have been manually removed from the selected set outside of

the standard filtering procedure are displayed.


Muchalls Page 5



MULTI-MODAL CYCLISTS






00:00 - 01:00

01:00 - 02:00

02:00 - 03:00

03:00 - 04:00

04:00 - 05:00

05:00 - 06:00

06:00 - 07:00

3 28 0.000 3 28 0.024 3 28 0.02407:00 - 08:00

3 28 0.012 3 28 0.012 3 28 0.02408:00 - 09:00

3 28 0.000 3 28 0.012 3 28 0.01209:00 - 10:00

3 28 0.000 3 28 0.012 3 28 0.01210:00 - 11:00

3 28 0.000 3 28 0.000 3 28 0.00011:00 - 12:00

3 28 0.000 3 28 0.000 3 28 0.00012:00 - 13:00

3 28 0.000 3 28 0.012 3 28 0.01213:00 - 14:00

3 28 0.000 3 28 0.000 3 28 0.00014:00 - 15:00

3 28 0.000 3 28 0.000 3 28 0.00015:00 - 16:00

3 28 0.012 3 28 0.000 3 28 0.01216:00 - 17:00

3 28 0.036 3 28 0.000 3 28 0.03617:00 - 18:00

3 28 0.000 3 28 0.000 3 28 0.00018:00 - 19:00

19:00 - 20:00

20:00 - 21:00

21:00 - 22:00

22:00 - 23:00

23:00 - 24:00

Total Rates: 0.060 0.072 0.132






the table.







Parameter summary













Muchalls Page 6



MULTI-MODAL VEHICLE OCCUPANTS






00:00 - 01:00

01:00 - 02:00

02:00 - 03:00

03:00 - 04:00

04:00 - 05:00

05:00 - 06:00

06:00 - 07:00

3 28 0.071 3 28 0.393 3 28 0.46407:00 - 08:00

3 28 0.190 3 28 0.714 3 28 0.90408:00 - 09:00

3 28 0.286 3 28 0.369 3 28 0.65509:00 - 10:00

3 28 0.202 3 28 0.262 3 28 0.46410:00 - 11:00

3 28 0.357 3 28 0.357 3 28 0.71411:00 - 12:00

3 28 0.702 3 28 0.500 3 28 1.20212:00 - 13:00

3 28 0.893 3 28 0.917 3 28 1.81013:00 - 14:00

3 28 0.762 3 28 0.726 3 28 1.48814:00 - 15:00

3 28 0.548 3 28 0.417 3 28 0.96515:00 - 16:00

3 28 0.869 3 28 0.548 3 28 1.41716:00 - 17:00

3 28 0.714 3 28 0.417 3 28 1.13117:00 - 18:00

3 28 0.655 3 28 0.524 3 28 1.17918:00 - 19:00

19:00 - 20:00

20:00 - 21:00

21:00 - 22:00

22:00 - 23:00

23:00 - 24:00

Total Rates: 6.249 6.144 1 2.393






the table.







Parameter summary












102030 Strutt and Parker Muchalls Survey

Appendix A Location plan of Site

Reproduced from Ordnance Survey data with the permission of the Controller of Her Majesty’s Stationary Office. Crown Copyright reserved. Licence No. AL 100018954

Site location plan. – Grid Ref : NJ 901 921

Site location plan. (Extent of Site Boundary)


2/ View looking East to South of site

3/ View looking North along Western boundary of site


4/ View looking East to midpoint of site

5/ View looking North to midpoint of Western site boundary


6/ View looking West towards A90

7/ View looking East towards Site


8/ View looking North towards Nethermains Road

9/ View looking South towards Walker Drive


12/ View looking South towards Walker Drive culvert

13/ View looking on inlet Walker Drive culvert


14/ View looking South East at Walker Drive culvert outfall

www.fairhurst.co.uk

Aberdeen Bristol

Dundee Edinburgh

Elgin Glasgow

Inverness

Leeds London

Manchester Newcastle upon Tyne

Sheffield Watford

Wellesbourne

CIVIL ENGINEERING • STRUCTURAL ENGINEERING • TRANSPORTATION • ROADS & BRIDGES

PORTS & HARBOURS • GEOTECHNICAL & ENVIRONMENTAL ENGINEERING • PLANNING &

DEVELOPMENT • WATER SERVICES • CDM COORDINATOR SERVICES

Please use this form to make comments on the Proposed Aberdeenshire Local Development 2016. If you are making comments about more than one topic it would be very helpful if you

Please email or send the form to reach us by 8th May 2015 at the following address:

Post: Planning Policy Team Infrastructure ServicesAberdeenshire CouncilWoodhill HouseWestburn RoadABERDEENAB16 5GB


Title

First name

Surname

Date

Postal Address

Postcode

Telephone Number

E-mail

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

Are you responding on behalf of another person? Yes No

If yes who are you representing

YOUR DETAILS

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

Mr

John

Wright

06.05.15

Strutt & Parker, 5 St John Street, Perth

PH1 5SP

01738 567 892

[email protected]

✔

✔

Monymusk Land Company

Please provide us with your comments below. Please feel free to add any extra pages you may require. We will summarise 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.

YOUR COMMENTS

Reason for change

Amend Appendix 5,Table 7 New Housing Land - Marr (pg 12) to include reference to Phase 3 at Monymusk for adevelopment of up to 46 houses in the period to 2026.

The Monymusk Masterplan 2006-2015 was prepared in association with Aberdeenshire Council and the Community torationalise the ALP land allocations (some of which were within areas at risk of flooding, others on commercialwoodland) and to arrive at a phased programme of development for the settlement.

Members supported the Masterplan and were very complimentary of it in issuing their approval of it. The approvedMasterplan, which is still listed on the Councils website as "Planning Advice", identified three phases of development,the first phase is complete, the second is under construction and the final phase was acknowledged at the time as beingsimply "2015 onwards".

As part of the process of considering the Phase 2 development, the Council requested that the Masterplan be updatedand, whilst it showed a detailed layout for the Phase 2 development, a layout for Phase 3 was shown indicatively onFigure 12: Finalised Masterplan diagram contained in Section 7 (extract attached) of that document. Whilst this wasapproved by Members at Committee in September 2013, it does not appear to have been uploaded to the website asPlanning Advice.

We acknowledge the level of recent development, and the desire of the Council to allow the village to consolidate andreact to the level of growth, we nevertheless believe that this opportunity has for some time now been acknowledgedand identified as the future direction for growth of the settlement and should continue to be so identified.

Whilst SPP requires LDP's to identify a range of sites which are effective or expected to become effective in the planperiod to meet the housing land requirement of the strategic development plan up to year 10 from the expected year ofadoption (para 119), there is nothing to prevent longer term opportunities being identified in the plan as such.

As has been demonstrated through the developments of phases 1 and 2, there are no technical constraints todevelopment that cannot be overcome and Monymusk is a very marketable location making any land allocation hereeffective and deliverable within the required timeframes.

Proposed Aberdeenshire Local Development Plan 2016

Objection - Policy P1 - Protecting Important resources - Prime agricultural land - Mr A Murison

Suller & Clark Planning Consultants on behalf of their client , wish to respond to the Proposed Aberdeenshire LDP 2016 to the proposed amended wording of Policy P1 - Protecting Important Resources. Whilst appreciating the need for this policy to safeguard land as a finite resource, we seek assurances that this will not result in a blanket embargo on any land which is classified as prime.

The policy is worded as:

"Prime agricultural land, as defined as classes 1, 2 and 3.1 of the Soil Survey of

Scotland Land Capability for Agriculture series, should not normally be developed

unless it is allocated in the local development plan."

This implies a complete embargo on development of prime agricultural land.

This gives my client concen, as he is aware of parts of Aberdeenshire where prime agricultural land is present but where there may be development opportunities in terms of housing for agricultural workers, organic growth of named settlements or additions to cohesive groups of housing. Examples of these set of circumstances can be found around the settlements of Daviot, Chapel of Garioch, Auchleven, Kemnay, Insch and Oyne,where development has been permitted within the current LDP, and where it has been shown that the social and economic benefits of development outweigh the status of prime agricultural land. This has previously been demonstrated by an agricultural specialist, where they have been able to demonstrate that the loss of poorly performing margins, stony ground or poorly draining areas do not result in the loss of prime land. Examination of those planning approvals around the above noted settlements will show that settlements have been allowed to grow without whole scale loss of productive land. All of the examples quoted above involve the minor loss of Grade 3.1 land.

We appreciate that the interpretation and guidance as to how this policy will be applied will be provided by Supplementary Guidance, but seek reassurances that the blanket embargo which is suggested in the policy wording, will be explained and broadened to allow for minor development additions (single houses, organic growth and cohesive group additions) where the benefits outweigh the loss of a small area of prime land.

The current policy for protection of prime agricultural land SG Safeguarding 2 :Agricutural land, was reviewed as part of the Main Issues Report, and was identifed as requiring an update of references and cross referencing to other policies only. Significantly, it is not identified as a Main Issue.

This was reiterated in the Position Papers for Policy Review, released as part of the MIR: see below:

Within the text of the Document at para 2.14.3, the discussion focuses on the argument relating to business development on prime agricultural land, rather than opportunities for small scale residential development.

In the current LDP, Policy 14 Safeguarding of resources and areas of search, merely states development will not be supported where it involves prime agricultural land. The detail is found in SG Safeguarding 2: Protection and conservation of agricultural land.

The SG states that development on prime agricultural land will only be permitted if

it has been allocated in the LDP, or the applicant has demonstrated that the social or economic benefits outweigh

the agricultural value AND that there are no suitable alternative sites to develop.

On behalf of our client we seek assurances that any SG proposed to clarify Policy 1 - Protecting Important resources, specifically relating to the issue of prime agricultural

land, introduces a caveat which will allow small scale development in the countryside, where it can be proven that the development will result in a social or economic benefit and not involve significant loss of productive land. We believe that given the land distribution noted above, the majority of examples will involve minor loss of Grade 3.1 land only, not the higher grade land classifications.

Modification sought: Clarification in Policy P1 - Protecting Important resources - Prime agricultural land - ensuring small scale development in appropriate locations where no loss of prime agricultural land can be demonstrated, is permitted.


Objection - Policy P1 - Protecting Important resources - Prime agricultural land - Mr A Cheyne










Objection - Policy P1 - Protecting Important resources - Prime agricultural land - Mr D Jamieson










Objection - Policy P1 - Protecting Important resources - Prime agricultural land - Mr F Booth



"Prime agricultural land, as defined as classes 1, 2 and 3.1 of the Soil Survey of Scotland Land Capability for Agriculture series, should not normally be developed unless it is allocated in the local development plan."









• it has been allocated in the LDP, or • the applicant has demonstrated that the social or economic benefits outweigh




Objection - Policy P1 - Protecting Important resources - Prime agricultural land - Mr I Gilbert










Objection - Policy P1 - Protecting Important resources - Prime agricultural land - Mr L Cooper










Objection - Policy P1 - Protecting Important resources - Prime agricultural land - Mr R Young

Suller & Clark Planning Consultants on behalf of their client wish to respond to the Proposed Aberdeenshire LDP 2016 to the proposed amended wording of Policy P1 - Protecting Important Resources. Whilst appreciating the need for this policy to safeguard land as a finite resource, we seek assurances that this will not result in a blanket embargo on any land which is classified as prime.








Please provide us with your comments below. Please feel free to add any extra pages you may require. We will summarise 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.

YOUR COMMENTS

Reason for change

Improved access route to proposed development OP1

The access route to this proposed development would be via Bogbeth Road. At present i am in discussion with theCommunity Council who are raising Bogbeth Road as a Safety concern with Aberdeenshire Council.

Every weekend when events/football takes place at Bogbeth Park, cars are lined along one side of the street from theentrance to Bogbeth Road right along to the skatepark. This makes it extremely difficult for residents to get to and fromtheir houses as the road is then reduced to single track. Now add a further 65 houses, with approximately 120 cars tothis already busy and unsafe road then we have a huge problem.

Bogbeth Brae, cars also park down the whole side of this street, visitors to the park and also residents who do not haveenough parking for their own properties, this is also a street you would use to access the new development. This alsoposes a safety risk as cars again are having only one lane to use and no passing areas.

We also have a safety issue whereby boy racers are using Bogbeth Road as a racing strip and this has been anongoing issue for the last 5 years i have lived on this street. This i have made Police Scotland aware of but we canthave an extra 120 cars using this street whilst boy racers use it to race on.

The access route via the Leschangie road is pure ridiculous. Has anyone actually viewed this road. A single track roadwhich definitely does not have capacity to carry any extra traffic.

Basically, approving this development, would be a huge safety issue that urgently needs addressing before anyconsideration is put into approving it.

I have supplied the community council with photographic evidence of the parking problem on Bogebeth Road and i amhappy to provide for this also.

For attention of the Planning Policy Team Infrastructure Services

Aberdeenshire Council,Woodhill House,Westburn Road,ABERDEEN


TitleFirst name

Surname

Date 6th May 2015

Postal Address

Postcode

Telephone Number

E-mail

Are you happy to receive future correspondence only by email - Yes

Modification that you wish to see

I would wish, as a minimum modification, to see the entire field (annotated FM 072 and FM 071 on the map**)

adjacent to Wellpark looking towards Daviot Estate protected and the area looking down from the Stone Circle

monument towards Pitblain (Highbury cluster) to ensure inappropriate development is stopped so that future

generations can inherit what we have currently.

In addition the small play park at Kirkton Park and the area of land used as a car park at the Bus Stop and adjacent to

the Church annexe should be protected. The designated “open space” at the new Hunter’s View development should

also be protected to ensure that it remains an open space for future generations.

Reason for change

Following the exercise completed by the Community Council on behalf of Daviot residents on 18th January, 2014, I

am extremely disappointed that the views of residents on having further areas in and around the village of Daviot

protected have been completely ignored. Ken Gordon's e-mail of 1st February, 2014 to Piers Blaxter and his meeting

with him explained fully the outcome of the exercise. Copies of his e-mail with analysed results and documents**

were sent to myself, Andrew McCartney, Chairman of the Community Council and our four councillors. The individual

letters of representation were handed to Piers Blaxter at Woodhill House by Ken Gordon also on 1st February.

In relation to protected areas I would re-iterate that 83 out of 93 respondents wished areas 1,2 and 3 to continue to

be protected and this appears to be the case but 76 respondents expressed their concerns about the rash of sporadic

developments coming to planning (not conforming to any master plan for the village) and now we see that more and

more Applications are being made. Most individuals marked their preferred areas for Protection on the map

attached to their letter of representation while a few made explanatory comments.

The reason for the desired change is obvious - unless areas near to the village ARE protected, the uniqueness of the

village will be destroyed forever. The start of this process has already begun at Hunter's Park (referred to as OP1 in

the LDP). While it is appreciated that this was down to the Scottish Reporter not understanding that it was

classification 3.1 Prime Agricultural land - a mistake that was perpetuated going forward and exacerbated by the

house designs now evident. This does not fit with the design of neighbouring houses in Wellbrae Terrace and

Wellpark and therefore destroys the nice line of the village from the 9001 approach. Planners in the past insisted on

no two storey houses or houses with dormers. Also extensive planting to soften the then new housing of Wellpark

especially was part of the planning conditions. It would indeed be sad if the wisdom of their effective planning was

eroded by bad decisions now to accommodate the wishes of developers with no real tie to the village.

I appreciate that it may not be possible to accommodate the wishes of everyone but I (and many others) will be very

concerned if any further development is allowed between Wellpark and Daviot Estate as this will be detrimental to

the village setting and Daviot Estate. Accordingly the field marked on the attached map (FM071 and FM072) should

be protected. You will recall that development is not preferred by Aberdeenshire Council and the Scottish Reporters

have turned down Planning Applications in this area on a number of occasions. It is 3.1 Prime Agricultural Land and

the whole field gives a real country- green aspect to the village setting and greatly enhances the setting of Daviot

Estate, the Daviot Community Trust's Walks/Woodland and the village itself. The area down from the Loanhead of

Daviot Recumbent Stone Circle towards the house cluster at Pitblain should also be protected as no one would wish

to have house elevations protruding into the view from this ancient monument - a classic view in Daviot.

I would implore Planners and Councillors to take action and be seen to be supporting the village residents by

protecting the areas indicated - we deserve better than being always at the mercy of developers and speculators who

are currently using (I would say abusing) the provisions of the Rural Development Policy. This appears to be set to

continue at least until the 2016 LDP comes into effect and assuming that Daviot remains out of Appendix 4 Policy R2

when the LDP procedures are complete.

Yours sincerely,

The following submission has had its supporting documents removed due to file size. If you require a copy of the original digital submission please contact Poliy Planning at [email protected]

Proposed inclusion of additional land for 18 housing units in Ythanbank alongside business/employment facility & enhancement of existing community facilities including leisure and recreation space.

Community Opinion

It should be noted that if this site was successfully adopted within the next local plan that a planning application would follow and it would be fully encouraged and recommended that community engagement take place with this site, establishing the communities exact requirements in terms of local facilities & amenities.

Generally the community’s opinion towards development in Ythanbank can be derived from a review of the comments submitted toward various applications within the current local development plan.

On the following pages are a selection of extracts from various representations with the corresponding planning reference number.

01/05/2015 2 TDS Ref: 10387

APP/2012/2340 & APP/2012/2996

Applications for the 10 site development currently denoted as OP1 in the draft ALDP 2016

“The current facilities in the hamlet are non existent and as such expansion cannot be justified”

“more thought, communication and discussion regarding property types, access, safety, village facilities and recreation areas”

“ The creation of a village green with a communal point of interest”

The 10 site development concerned local residents due to the lack of facilities in Ythanbank. That said however the size of development could not justify the provision of any community facilities or recreation space, as agreed with the planning department and can be confirmed by the report of handling stating that “with regard to public open space, no specific provision has been highlighted with this application. However the Planning Service recognises that the provision of 1200m2 of formal public open space from each of the plots would prejudice the development of the site.”

As such the planning department has identified that in order to satisfy the required open space & community facilities a development should be of a scale that does not suffer from these provisions.

01/05/2015 3 TDS Ref: 10387

The community’s concerns are broadened in the subsequent organic growth applications in Ythanbank as follows.

APP/2014/3100

“Given there are no retail facilities, very few public amenities”

APP/2014/3474

“The application has little merit in community planning terms”

APP/2014/4252

“ The development of this site will not bring any improved services to the Ythanbank area, no shops or playing area for children etc.”

“There are no amenities in the village for children, young and older children. I feel this situation needs to be addressed before adding more housing to the village.”

Although the community have voiced concerns in various forms it should be noted that the Ythan Community Council state that “Enlargement of the settlement of Ythanbank by the use of suitable and good quality building is of benefit to the community”

01/05/2015 4 TDS Ref: 10387

Environmental Impact

• Drainage

With no current sewer network in Ythanbank it would be suggested that communal drainage systems be utilised, with the inclusion of treatment plants and SUDs.

A site currently being considered by the council under organic growth policy adjacent to the proposed development site and suggests that ground conditions would be suitable for these drainage types.

• Flood

The SEPA flood maps do not highlight any site issues however further investigation would always be undertaken during any planning application.

• Heating/Power

There is currently no gas route in Ythanbank, as such heating would be provided by more sustainable means. Consideration could be given to a combined heating & power unit serving the development.

• Water Supply

The current water main serving Ythanbank has been recently upgraded to serve the sites considered under OP1 in the draft 2016 ALDP. It would be proposed to extend onto this main to serve future development.

01/05/2015 5 TDS Ref: 10387

Environmental Impact (cont)

• Connectivity to existing settlement

The draft settlement statement of Ythanbank now states that “Ythanbank is a small linear village, with development occurring on either side of the B9005. This pattern has recently been broken with new development to the west of the main street”

With this is mind the proposed development to the rear of Wellpark offers an alternative to the linear precedent of the village without detracting from its rural character.

To promote connection of the proposed development and its facilities to the existing settlement both vehicular and pedestrian access is to be provided adjacent to the village hall.

Additional pedestrian routes are to be promoted by linking existing public rights of ways to the proposed development.

The current “hub” of the community is its village hall which is to be central to the access of the site linking the existing and proposed communities to a common point.

• Sustainable travel links

Adequate pedestrian and cycle routes would be promoted with the inclusion of bus stops to enhance current routes.

01/05/2015 6 TDS Ref: 10387

sent via scottish government sea gateway – piers blaxter ... · dear mr blaxter . 00840...

Documents