Yesterday, the consultation period for Aberdeen City's new Local Development Plan finished and I know that lots of people, concerned about proposed developments to fill in Union Terrace Gardens, force a new road through Berryden and Tillydrone to connect to a 3rd Don Crossing and build 1500 houses and a Stadium at Loirston Loch will have made representations. I just hope that City councillors treat their efforts with more respect than I saw today at Aberdeenshire's Formartine Area Committee.
Now under the new planning regime, the Council can't itself make changes to the Plan at this late stage. But it is open to the Council to indicate to the Reporter which suggested modifications it really dislikes (and why), which it could live with if necessary and which it really doesn't mind at all. If the Reporter then finds that changes are necessary, consequential changes can then be in accordance with the Councils wishes. Without this "red, amber, green" signposting, the Reporter just has to assume that the Council doesn't care.
Now it was clear that at least three of the four Ellon councillors, including me, were relaxed about letting the proposed development at Foveran happen earlier. The argument made in the representations was that the larger development was needed to build the necessary infrastructure, especially sewerage. So we will now find that this development which is modest in total scale and therefore might actually be deliverable in the current economic climate, will be delayed until the larger project is permitted. Crazy.
For information, the majority of my colleagues voted to "Instruct officers to defend the proposed plan against all other unresolved objections at the forthcoming examination".
I, seconded by my colleague Paul Johnston wanted to recognise that the proposed plan was the settled will of the council but ask officers to note the following comments in framing the Council's response to the representations. We were, of course, defeated.
We wished to have comments in regard to Foveran, Oldmeldrum, Tarves, Balmedie West and Blackdog noted. (PJ - have I missed anything?)
Showing posts with label local plan. Show all posts
Showing posts with label local plan. Show all posts
Aberdeenshire - Final Local Development Plan
The Aberdeenshire Development Local Plan was agreed by the Council on 24th June. I did not vote for it but a future post - or perhaps posts - will talk about the issues. After all, we have until 1st October to lodge our representations on the plan. My previous post talked about the form required for representations. This post will discuss the form of the plan itself.
Instead of one document, the Plan has been published as a plan containing just 14 polices, 6 maps and a schedule. One of my colleagues described the plan as vacuous - there is so little detail in the Plan itself that it is difficult to see what objections there could be. Most of the detail is in the Supplementary Guidance.
In addition to the Plan there are (currently) 51 pieces of Supplementary Guidance, 6 of which are Settlement Maps for each Area within Aberdeenshire and the rest give details on the 14 polices.
Therefore, it is likely that if you wish to make a representation about anything you will need to make two representations - one for the policy in the main plan and one for the relevant Supplementary Guidance.
Aberdeenshire has provided two forms (in two forms, pdf and online), one for the Plan and one for Supplementary Guidance. But as you are not required to make your representation on the specified form, I would suggest that you make one representation per issue covering both the Plan and the Supplementary Guidance. If you follow the 7 required pieces of information from the Schedule 4 form, you will have provided all the necessary information. The Council can then cross reference your one representation into two parts to cover the Plan and the Supplementary Guidance.
Over the summer, I'll post some comments on the content of the plan itself. Remember, you only have until 1st October to make you voice heard.
Instead of one document, the Plan has been published as a plan containing just 14 polices, 6 maps and a schedule. One of my colleagues described the plan as vacuous - there is so little detail in the Plan itself that it is difficult to see what objections there could be. Most of the detail is in the Supplementary Guidance.
In addition to the Plan there are (currently) 51 pieces of Supplementary Guidance, 6 of which are Settlement Maps for each Area within Aberdeenshire and the rest give details on the 14 polices.
Therefore, it is likely that if you wish to make a representation about anything you will need to make two representations - one for the policy in the main plan and one for the relevant Supplementary Guidance.
Aberdeenshire has provided two forms (in two forms, pdf and online), one for the Plan and one for Supplementary Guidance. But as you are not required to make your representation on the specified form, I would suggest that you make one representation per issue covering both the Plan and the Supplementary Guidance. If you follow the 7 required pieces of information from the Schedule 4 form, you will have provided all the necessary information. The Council can then cross reference your one representation into two parts to cover the Plan and the Supplementary Guidance.
Over the summer, I'll post some comments on the content of the plan itself. Remember, you only have until 1st October to make you voice heard.
Local Development Plan - Consultation and Examination
On 24th June, Aberdeenshire Council agreed to publish its new Local Development Plan for public comment and that this plan should have some degree of materiality for planning decisions.
Since the previous round of Local Plans, there has been a change in legislation. This is not a draft plan that will then be turned into a Finalised Plan by the Council and then be subject to a Public Local Inquiry. This is IT. A reporter will be appointed and this plan will be subject to an examination to ensure it is "appropriate and sufficient".
So Representations (objections and expressions of support) will need to be made over the summer with a closing date of 1st October.
The process is new. The Council will turn your representation into a Schedule 4 form which will contain
Thanks to Planning Aid Scotland for the session from which I gleaned the above. Any errors are mine not theirs!
In my next post, I will comment on the format of the local plan and what that means for you if you want to make a representation - the form is very different from previous plans.
Since the previous round of Local Plans, there has been a change in legislation. This is not a draft plan that will then be turned into a Finalised Plan by the Council and then be subject to a Public Local Inquiry. This is IT. A reporter will be appointed and this plan will be subject to an examination to ensure it is "appropriate and sufficient".
So Representations (objections and expressions of support) will need to be made over the summer with a closing date of 1st October.
The process is new. The Council will turn your representation into a Schedule 4 form which will contain
- Issue Reference and Heading
- Development Plan Reference
- Body or persons raising the issue
- Provision of the Development Plan to which the issue relates
- Council's summary of issue
- Modifications sought by those submitting representations
- Summary of Response by Council
- Any further plan changes commended by Council
- Reporters Conclusion
- Reporters Recommendations
Thanks to Planning Aid Scotland for the session from which I gleaned the above. Any errors are mine not theirs!
In my next post, I will comment on the format of the local plan and what that means for you if you want to make a representation - the form is very different from previous plans.
New Aberdeenshire Local Plan
Yesterday and today I spent looking at allocating houses and employment land to settlements in Formartine (my bit of Aberdeenshire).
View Aberdeenshire Local Plan 2007-2023 in a larger map
It's difficult to get information out on what is happening but I'm trying so I've put the decisions so far onto a Google map. I've used symbols for housing, employment sites and written in the detail. Some sites are very large and you'll need to look at the full documentation.
A further report will come to a future meeting of Formartine Area Committee to look at development around Potterton as an alternative to development at the south of Oldmeldrum. The debate amongst the local councillors is mainly a) whether Potterton is in the Strategic Growth Area or not (50:50 according to the Head of Planning Policy) and b) whether development should be north or south of the Potterton.
But what do the people of Potterton think?
I'll post more as as I can try to expand to other bits of Aberdeenshire when I can - but currently I don't have the information.
Let me know what you think and I'll let you know when the formal plan is published and how you can comment or object to it formally.
View Aberdeenshire Local Plan 2007-2023 in a larger map
It's difficult to get information out on what is happening but I'm trying so I've put the decisions so far onto a Google map. I've used symbols for housing, employment sites and written in the detail. Some sites are very large and you'll need to look at the full documentation.
A further report will come to a future meeting of Formartine Area Committee to look at development around Potterton as an alternative to development at the south of Oldmeldrum. The debate amongst the local councillors is mainly a) whether Potterton is in the Strategic Growth Area or not (50:50 according to the Head of Planning Policy) and b) whether development should be north or south of the Potterton.
But what do the people of Potterton think?
I'll post more as as I can try to expand to other bits of Aberdeenshire when I can - but currently I don't have the information.
Let me know what you think and I'll let you know when the formal plan is published and how you can comment or object to it formally.
Main Issues: Flooding and Erosion, Hazardous Development, Contaminated Land, Carbon Neutrality in New Developments, Developer Contributions
Hopefully last but one lap - comments by 20/1/10 appreciated.
Flooding and Erosion : Stronger policy for both coastal and watercourse threats. 1:200 years limit for residential, commercial and key infrastructure. 5m and 10m countours considered for Flood. Impact of hardened surfaces on flooding elsewhere considered.
Hazardous Development: talks about pollution, flooding, nuisance and hazard - restricting such new sources and development sround existing sources.
Contaminated Land: Talks about assessement and remediation.
Carbon Neutrality in New Developments: 30% below 2007 standards increasing to 60% by 2012, 90% by 2014 and 100% by 2016. Lots of additional information re definitions and methods to achieve.. Off site permissible for Conservation Areas etc.
Developer Contributions: Appendix will include details of specific contributions required against major sites. Individual sets talking about Access, Water and Drainage (cf SUDS), Waste Management.
Often pretty technical stuff but useful to be specific about Access (maintenance of such can be an issue), water but I can;t see anything that will help us ensure maintenance of SUDS schemes. It'll be interesting to see how Carbon Neutrality pans out!
Flooding and Erosion : Stronger policy for both coastal and watercourse threats. 1:200 years limit for residential, commercial and key infrastructure. 5m and 10m countours considered for Flood. Impact of hardened surfaces on flooding elsewhere considered.
Hazardous Development: talks about pollution, flooding, nuisance and hazard - restricting such new sources and development sround existing sources.
Contaminated Land: Talks about assessement and remediation.
Carbon Neutrality in New Developments: 30% below 2007 standards increasing to 60% by 2012, 90% by 2014 and 100% by 2016. Lots of additional information re definitions and methods to achieve.. Off site permissible for Conservation Areas etc.
Developer Contributions: Appendix will include details of specific contributions required against major sites. Individual sets talking about Access, Water and Drainage (cf SUDS), Waste Management.
Often pretty technical stuff but useful to be specific about Access (maintenance of such can be an issue), water but I can;t see anything that will help us ensure maintenance of SUDS schemes. It'll be interesting to see how Carbon Neutrality pans out!
Main Issues: Masterplanning; Layout, Siting & Design; Public Open Space; Public Access; Community Facilities
This is all about building in quality design to new developments - all the way from how a development relates to its surroundings to the deatil of individual buildings. This is a hugely complex subject ....
Masterplanning of large developments : New requirement for development frameworks, masterplans and/or development briefs for large and medium sized developments. Community engagement highlighted. Differing requirements according to scale. Very large < 600, Large 50 to 600 houses, Medium 5 -49 houses.
Layout, Siting and Design of New Development: Reference to masterplans and designs briefs and also assessments against Urban Design Toolkit (PAN 67), Manual for Streets, and Index 21. Design Panel to advise on important design cases.
House Extensions: protection of amenity of area.
Infill development: OK subject to protection of character and amenity of area and important open space/woodland.
Public Open Space: Reference to Open Space Strategy and specific requirements for hierarchy of developments: 40% Major, 120m sq per dwelling, or 40 m sq for land previously allocated. Protection of open space from development with exceptions.
Public Access: Connection to existing non motorised access routes highlighted. If Core path or existing path, maintenance of it or replacement. Mention of access to water.
Community Facilities: Principles governing adequate provision and requirements for developer contributions towards such.
I like the emphasis on masterplanning and design. I strongly believe this leads to better development but it all depends on the "teeth" given - will we refuse purely on such grounds and will it stand up on appeal?
Not sure why developments in the Local plan have lower requirement for Public Space than others in Local Plan. Rules change all the time ....
Good to see Public Access higher up the priorities. Would like more emphasis on encouragement for walking/cycling rather than car use as part of the Design principles.
Comments by 20th Jnuary, please ...
Masterplanning of large developments : New requirement for development frameworks, masterplans and/or development briefs for large and medium sized developments. Community engagement highlighted. Differing requirements according to scale. Very large < 600, Large 50 to 600 houses, Medium 5 -49 houses.
Layout, Siting and Design of New Development: Reference to masterplans and designs briefs and also assessments against Urban Design Toolkit (PAN 67), Manual for Streets, and Index 21. Design Panel to advise on important design cases.
House Extensions: protection of amenity of area.
Infill development: OK subject to protection of character and amenity of area and important open space/woodland.
Public Open Space: Reference to Open Space Strategy and specific requirements for hierarchy of developments: 40% Major, 120m sq per dwelling, or 40 m sq for land previously allocated. Protection of open space from development with exceptions.
Public Access: Connection to existing non motorised access routes highlighted. If Core path or existing path, maintenance of it or replacement. Mention of access to water.
Community Facilities: Principles governing adequate provision and requirements for developer contributions towards such.
I like the emphasis on masterplanning and design. I strongly believe this leads to better development but it all depends on the "teeth" given - will we refuse purely on such grounds and will it stand up on appeal?
Not sure why developments in the Local plan have lower requirement for Public Space than others in Local Plan. Rules change all the time ....
Good to see Public Access higher up the priorities. Would like more emphasis on encouragement for walking/cycling rather than car use as part of the Design principles.
Comments by 20th Jnuary, please ...
Main Issues: Housing, 2007-2016, 2017-2023 and early draw down, Affordable Housing, Other Special Housing incl Special Needs, Residential Caravans, Traveller and Gypsy Sites.
In terms of the volume of housing, most of the decisions have already been made in the
Housing Land Supply : follows Structure Plan but "to assist in long term masterplanning of development areas beyond 2023 ... may bring forward site specific supplementary planning guidance for periods beyond 2023". 20% housing due to be delivered in via Countryside policies with other 80% in allocated sites in settlements. Attempt to address an issue that has arisen of plots being developed for more houses than originally envisaged via masterplanning/design briefs and justifications. Provision to bring forward to maintain 7 year supply.
Affordable Housing : The plan maintains 25% requirements for affordable (read subsidised) housing and encourages a mix of house types and integration with non affordable housing. (Hurrah!) However there are some get out clauses which could mean less provision or provision off site or provision via Low Cost Home Ownership rather than for rent.
Special Needs : there are new policies to deal with 3 type. Residential caravans are discouraged except as temporary arranagements. Special needs housing is accepted and most types are encouraged to be within or at edge of settlements. However there is explicit provision for "continuing care retirement communities" (CCRC) outside settlement. The need for Traveller and Gypsy sites is recognised.
There are no great surprises as this has to follow the Structure Plan which is available as a pdf, in rtf or as an MP3 audio file. I was worried about the sheer scale of the allocation overall and in particular in the Blackdog - Ellon corridor but we are where we are. I can understand why there is concern about over-development of sites but in general, if the design is good, it is better to try to achieve higher densities which mean more people can live closer to shops, bus routes and other services - and we lose less valuable farmland to development.
While there is some progress for improvement in affordable housing, I still worry that some developers will try to get out of on-site provision and there is enough wriggle room in policy for this. I also note that the rule allowing the additional of 3 houses at the edge of rural settlements is just below the 25% threshold - perhaps making slightly larger extensions that gave more scope for some affordable housing provision would be better.
Continuing care retirement communities outside settlements does not fits well with other policies. Visitors, staff and others servicing such facilities will need to travel and this seems to me to go against other policies aimed at reducing the need to travel and encouraging use of public transport. I also worry about isolating groups from the wider community.
The policy on Gypsy and Traveller site indicates that there will be sites allocated specifically for this need. We will see later where these sites are. Other sites could be allocated according to need. In all cases, there are requirements for sites not to "appreciably detract from the character and appearance of the area" not "significantly detract from the amenity currently enjoyed." This will be a challenge to us all to achieve but I see no need for such sites to be a blot if we work with the users on design to fit everyone's needs.
Over to you - comments back by 20th please.
Housing Land Supply : follows Structure Plan but "to assist in long term masterplanning of development areas beyond 2023 ... may bring forward site specific supplementary planning guidance for periods beyond 2023". 20% housing due to be delivered in via Countryside policies with other 80% in allocated sites in settlements. Attempt to address an issue that has arisen of plots being developed for more houses than originally envisaged via masterplanning/design briefs and justifications. Provision to bring forward to maintain 7 year supply.
Affordable Housing : The plan maintains 25% requirements for affordable (read subsidised) housing and encourages a mix of house types and integration with non affordable housing. (Hurrah!) However there are some get out clauses which could mean less provision or provision off site or provision via Low Cost Home Ownership rather than for rent.
Special Needs : there are new policies to deal with 3 type. Residential caravans are discouraged except as temporary arranagements. Special needs housing is accepted and most types are encouraged to be within or at edge of settlements. However there is explicit provision for "continuing care retirement communities" (CCRC) outside settlement. The need for Traveller and Gypsy sites is recognised.
There are no great surprises as this has to follow the Structure Plan which is available as a pdf, in rtf or as an MP3 audio file. I was worried about the sheer scale of the allocation overall and in particular in the Blackdog - Ellon corridor but we are where we are. I can understand why there is concern about over-development of sites but in general, if the design is good, it is better to try to achieve higher densities which mean more people can live closer to shops, bus routes and other services - and we lose less valuable farmland to development.
While there is some progress for improvement in affordable housing, I still worry that some developers will try to get out of on-site provision and there is enough wriggle room in policy for this. I also note that the rule allowing the additional of 3 houses at the edge of rural settlements is just below the 25% threshold - perhaps making slightly larger extensions that gave more scope for some affordable housing provision would be better.
Continuing care retirement communities outside settlements does not fits well with other policies. Visitors, staff and others servicing such facilities will need to travel and this seems to me to go against other policies aimed at reducing the need to travel and encouraging use of public transport. I also worry about isolating groups from the wider community.
The policy on Gypsy and Traveller site indicates that there will be sites allocated specifically for this need. We will see later where these sites are. Other sites could be allocated according to need. In all cases, there are requirements for sites not to "appreciably detract from the character and appearance of the area" not "significantly detract from the amenity currently enjoyed." This will be a challenge to us all to achieve but I see no need for such sites to be a blot if we work with the users on design to fit everyone's needs.
Over to you - comments back by 20th please.
Main Issues : Development in Countryside, Energy, Minerals, Coastal development, Green belt
Again, I try to summarise the policy proposals and give my comments on these. Your feedback, especially before 20th January, would be appreciated.
Development in Countryside: divides Aberdeenshire into 3 : Accessible (around Aberdeen and the A90 and A96 corridors), Regeneration priority (Peterhead-Fraserburgh and the Moray coast) and Rural (everything else). In Accessible, small scale developments suitable for Green Belt will be allowed plus refurbishment/replacement of existing. For Rural, add economic development proposals, max 3 houses close to edge of existing settlements, or single house for retirement succession of viable farm holding. (Rural includes Regeneration).
Wind Energy: technical rules re roads/railways, flights, TV reception, ice throw shadow flicker, noise, visual intrusion. Impacts on Core Paths and Cumulative Impact. Reference to existing Supplementary Planning Guidance.
Other renewable energy: sympathetic if well sited and designed.
Minerals: Reference to maps indicting area of search (not published in these documents - I will ask for copy), sand and gravel - 15 years supply maximum, cumulative impact considered if 3 more more consents for landfill for mineral extraction within 5km of a settlement, explicit reference to buffer zones etc.
Coastal Development: similar to existing policy - limited to developments requiring coastal location and where social and economic benefits outweigh adverse environmental impacts and no alternative site. List of other hurdles - coalescence of settlements, character and amenity, flooding, water quality, coastal processes or habitats. I make no comment!
Green Belt: extensions to existing; agri/forestry/horiticulture/nature conservation; recreation use compatible with countryside; sensitive restoration; worker in primary industry rerquired on-site; National Priority; Safeguarded resources in Areas of search (see Minerals above). Comment that development in Green Belt may reduced travel compared to development beyond.
The 3 houses on edge of rural settlements seems a pragmatic way to allow organic growth - but it will be interesting to see what happens with the maximum 20% in any 5 year period limit. It seems odd to allow retiring farmers in Rural but not in Accessible - the social factors are similar. I'll need to see the maps for Minerals areas of search. Coastal and Green Belt - very similar to existing. However, we were also expecting a review of the Green Belt maps in this local plan and as a result of the AWPR. We need this.
Development in Countryside: divides Aberdeenshire into 3 : Accessible (around Aberdeen and the A90 and A96 corridors), Regeneration priority (Peterhead-Fraserburgh and the Moray coast) and Rural (everything else). In Accessible, small scale developments suitable for Green Belt will be allowed plus refurbishment/replacement of existing. For Rural, add economic development proposals, max 3 houses close to edge of existing settlements, or single house for retirement succession of viable farm holding. (Rural includes Regeneration).
Wind Energy: technical rules re roads/railways, flights, TV reception, ice throw shadow flicker, noise, visual intrusion. Impacts on Core Paths and Cumulative Impact. Reference to existing Supplementary Planning Guidance.
Other renewable energy: sympathetic if well sited and designed.
Minerals: Reference to maps indicting area of search (not published in these documents - I will ask for copy), sand and gravel - 15 years supply maximum, cumulative impact considered if 3 more more consents for landfill for mineral extraction within 5km of a settlement, explicit reference to buffer zones etc.
Coastal Development: similar to existing policy - limited to developments requiring coastal location and where social and economic benefits outweigh adverse environmental impacts and no alternative site. List of other hurdles - coalescence of settlements, character and amenity, flooding, water quality, coastal processes or habitats. I make no comment!
Green Belt: extensions to existing; agri/forestry/horiticulture/nature conservation; recreation use compatible with countryside; sensitive restoration; worker in primary industry rerquired on-site; National Priority; Safeguarded resources in Areas of search (see Minerals above). Comment that development in Green Belt may reduced travel compared to development beyond.
The 3 houses on edge of rural settlements seems a pragmatic way to allow organic growth - but it will be interesting to see what happens with the maximum 20% in any 5 year period limit. It seems odd to allow retiring farmers in Rural but not in Accessible - the social factors are similar. I'll need to see the maps for Minerals areas of search. Coastal and Green Belt - very similar to existing. However, we were also expecting a review of the Green Belt maps in this local plan and as a result of the AWPR. We need this.
Local Plan: Main Issues: Employment, Offices, Homeworking, Tourism, Town Centres and Retailing
See below for details of the process and please get back to me with comments by say 20th January - else your concerns may not be raised. I'll just post here very quick summaries and my comments - do see the original documents for the full version.
Employment land - existing employment land protected for employment purposes (rather than silence in current local plan)
Office development - new specific policy allowing in employment land, existing derelict, despoiled or underused, with encouragement for accessible by public transport, cycling or walking, and a sequential test.
Homeworking - new policy saying it's OK so long as it doesn't interfere with the neighbourhood.
Tourist facilities - new specific policy encouraging if well related to existing settlements or there is a locational requirement. Resistance to converting tourist accommodation to other uses.
Town Centres and Retailing - retains (but does not strengthen) sequential approach to new retail. Specifies some sites for bulky comparison outlets. In Rural HMA allows new retail to support tourism.
Retail in Countryside - new policy allowing farm shops or ancillary to tourist or recreational use.
I'm generally supportive of the direction of this. I want to encourage more employment in Aberdeenshire and recognise that the fastest growth and maximum employment is usually from small enterprises growing.
I have some concerns that there may be a few loopholes opened. I find the identification of specific sites for bulky retail odd - the onus should be on the developer to find a site and make the case. I am wary of the rules for converting tourist accommodation to residential use - it's the weasel word "reasonable". And "the erection of a farm shop in the countryside does not require planning permission" seems a step too far to me.
Employment land - existing employment land protected for employment purposes (rather than silence in current local plan)
Office development - new specific policy allowing in employment land, existing derelict, despoiled or underused, with encouragement for accessible by public transport, cycling or walking, and a sequential test.
Homeworking - new policy saying it's OK so long as it doesn't interfere with the neighbourhood.
Tourist facilities - new specific policy encouraging if well related to existing settlements or there is a locational requirement. Resistance to converting tourist accommodation to other uses.
Town Centres and Retailing - retains (but does not strengthen) sequential approach to new retail. Specifies some sites for bulky comparison outlets. In Rural HMA allows new retail to support tourism.
Retail in Countryside - new policy allowing farm shops or ancillary to tourist or recreational use.
I'm generally supportive of the direction of this. I want to encourage more employment in Aberdeenshire and recognise that the fastest growth and maximum employment is usually from small enterprises growing.
I have some concerns that there may be a few loopholes opened. I find the identification of specific sites for bulky retail odd - the onus should be on the developer to find a site and make the case. I am wary of the rules for converting tourist accommodation to residential use - it's the weasel word "reasonable". And "the erection of a farm shop in the countryside does not require planning permission" seems a step too far to me.
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