Committee Reports and Agendas
May 2003 to April 2007
 | NORTH AYRSHIRE COUNCIL |
| Agenda Item 6 23 October 2006 |
| Subject: | East Ayrshire Local Plan Consultative Draft |
| Purpose: | To advise the Committee that the proposed housing land allocations in the East Ayrshire Local Plan Consultative Draft exceed the Finalised Ayrshire Joint Structure Plan requirements for the period 2005-2017. These are of a significant scale, detrimental to the interests of North Ayrshire Council;
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| Recommendation: | That the Committee agrees:
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1. Introduction
- The new housing land allocations identified in the Local Plan, greenfield release sites, significantly exceed Finalised Ayrshire Joint Structure Plan requirements.
- The Local Plan states that it does not preclude release of land for housing east of the A77/M77 and on either side of the A76 in the vicinity of the Bellfield Roundabout. Such an approach is contrary to the strategic guidance given in the Structure Plan.
- The proportion of the land supply realistically expected to be developed during the plan period.
- The sequence in which sites will be released for development considering:
management of greenfield release so as not to prejudice development of brownfield land;
transport and environmental issues;
phasing and provision of future infrastructure investment. - The need to clearly identify allocations attributed to Strategic Expansion Locations.
- The actual developable area of housing land release sites.
- An adequate assessment of urban capacity.
A copy of the East Ayrshire Local Plan Consultative Draft was received by North Ayrshire Council on 29 September 2006. The letter accompanying the Plan advises that any representations should be submitted to East Ayrshire Council by 27 October 2006.
2. Current Position
There are two significant issues for North Ayrshire Council arising from the East Ayrshire Local Plan:
With regard to the first issue, using the figures published in the East Ayrshire Local Plan and comparing them to the stated housing land requirement in the Structure Plan for East Ayrshire to 2017, the plan period, arithmetically there is an over-supply of sites for 1,365 houses, namely, +35%. In the Kilmarnock Core Area and the Glasgow Link Corridor, comprising settlements closest to North Ayrshire, there is over allocation of 827 units, namely, +37%.
Such additional allocations are contrary to Policy COMM 2 (A) of the Structure Plan. (Requirements are stated in Table 2 of the Structure Plan).
COMM 3(A) requires the management and programming of any greenfield land release so as not to prejudice development of brownfield land and COMM 3(C) requires the sequence in which sites will be released to be specified, both of which are designed to ensure the proper regulation and monitoring of development. The absence of such a programme is contrary to the Structure Plan and prejudicial to management of the land supply.
There are a number of issues which give rise to further concern:
i. Actual completions in 2005/06 amounting to 420 houses across East Ayrshire, have not been recorded and accounted for in the housing land calculation. It would be normal practice to include these.
ii. Also excluded from the existing land supply base data in the Local Plan are sites on which development has commenced where they will be completed by the time of anticipated adoption of the Local Plan. Again these would normally be included.
iii. No provision has been made for brownfield urban capacity within settlements beyond sites which are certain to be developed in the near future, despite the Structure Plan requiring previously developed land and buildings to be promoted in preference to greenfield land.
iv. The stated output (housing density) from greenfield release sites is very low when compared to sites currently under development throughout Ayrshire. This is in spite of a stated requirement for 25% affordable housing on most of those sites closest to North Ayrshire. Affordable housing is typically developed at higher densities than private sector housing.
To date, no satisfactory justification has been offered in respect of items (i) to (iii) above. In relation to item (iv) there are mitigating factors such as undermining, flooding, areas of trees and requirements for parkland that render the developable area of the sites less than the area allocated. Taking these factors into account the stated outputs from many greenfield sites still seem unrealistically low. East Ayrshire Local Plan Policy RES1 requires their prescribed site capacities to be adhered to, but without detailed investigation of site conditions such an approach would be easily challenged such that the policy is not considered to be robust. Accordingly, it does not offer any comfort on the issue of density at this stage.
Considering the first three factors above, at least a further 1,095 units should be added to the base land supply figures for the Kilmarnock Core Area and Glasgow Link Corridor, in addition to the 2,081 identified in the Draft Local Plan. This in turn means that the greenfield release should be reduced in these areas to only 1,144, rather than the 3,066 proposed. The difference represents an over-provision of 1,922 units in the areas most directly affecting North Ayrshire. In simple terms it appears that only one-third of the greenfield land release proposed in the Plan is required taking account of all the above factors.
In terms of the second significant issue, the draft East Ayrshire Local Plan states that "notwithstanding the provisions of the plan, the Council, in approving the local plan has not precluded from consideration proposals for development to the east of the A77/M77 and on either side of the A76 in the vicinity of the Bellfield Roundabout".
Officers on behalf of East Ayrshire Council have expressed the view that any such housing land release would be as an alternative to those sites proposed in the Consultative Draft Plan. The document, however, does not state that this is the case. The Strategic Environmental Assessment accompanying the Plan clearly states that development in this location would have a significant adverse environmental impact and accordingly is inappropriate . Such a proposal would be contrary to the provisions of the Structure Plan; contrary to Schedule 5 Strategic Expansion Locations and Policy STRAT1 Sustainable Development, if proposed as an alternative. If it is additional to the land supply, further concerns of over-provision are raised, and there is every likelihood it would give rise to concerns in relation to Policy TRANS 1 Land Use and Transportation of the Structure Plan.
These concerns are shared by the Structure Plan Manager who is currently seeking clarification on the substance of the following matters:
3. Proposal
It is proposed to make formal representations to East Ayrshire Council in response to the Consultative Draft East Ayrshire Local Plan in the terms set out above. Officers will continue to seek justification and to evaluate the implications for North Ayrshire Council, in the hope this matter can be satisfactorily resolved prior to consultation on the Finalised East Ayrshire Local Plan.
4. Implications
From the above analysis, it is clear that there is an unprogrammed excessive greenfield housing land release amounting to almost 2,000 additional houses (excluding any east of A77/M77 land release) in the Kilmarnock Core Area and Glasgow Link Corridor, the sector of particular interest to North Ayrshire. There is concern that this could be seriously prejudicial to housing development and regeneration in North Ayrshire. If the land east of the A77/M77 were to be additional, the effect would be even more prejudicial to North Ayrshire Council's interests.
There are serious implications for the jointly agreed Ayrshire Joint Structure Plan currently before the Scottish Executive.
5. Consultation
East Ayrshire Council and South Ayrshire Council officers from their respective Planning Services have been consulted as has the Manager of the Ayrshire Joint Structure Plan. Clarification on various matters was and is still being sought from East Ayrshire Council.
6. Conclusion
It is proposed to make formal representations to East Ayrshire Council in respect of their Consultative Draft Local Plan in that it is contrary to the recently agreed Ayrshire Joint Structure Plan currently before Scottish Ministers. The over-provision of land for housing proposed in the East Ayrshire Local Plan would be potentially seriously prejudicial to the interests of North Ayrshire Council. The hope is that this matter can be satisfactorily resolved before East Ayrshire Council progresses to a Finalised Local Plan.
| BRIAN MACDONALD Assistant Chief Executive (Development and Promotion) |
Reference : KMcK/LI
For further information please contact Kenneth McKelvie, Planning Officer , on 01294 225182
Win 23534
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