Proposed Plan – Representation

1. Introduction

The Braes of the Carse Conservation Group (BCCG) was formed in 2009 to try and conserve the unique beauty, character and historical environment of the Braes of the Carse of Gowrie.  Our Group’s aim is to provide a voice for residents and interest groups in an area north of the Perth – Dundee dual carriageway (A90) approximately between Glendoick in the West and Knapp in the East.  

We have more than 150 local members and thus represent a significant proportion of the population in this relatively sparsely populated area.  We have extensively canvassed the views of our members (via email, letter, posters, direct contact and website survey) and this representation reflects their views.

In summary:

We support the spatial strategy. ( Our detailed comments in para 2.1 – 2.9)

We support the proposed boundaries of the Green Belt but wish to discuss our proposal for a Local Landscape area. (Para 3)

We support the proposed settlement boundaries for Kinnaird, Rait and Baledgarno.  ( paras 4.4-4.6)

We object to the removal of the existing settlement boundary for Abernyte and wish the existing settlement boundary of Abernyte reinstated. (para 4.7)

We have specific comments on Ballindean and Westown (para 4.9-4.11)

We support the Council’s proposal not to have settlement boundaries for small settlements (para 5) , BUT ONLY IF the proposed Housing in the Countryside Supplementary Guidance is adopted into the new LDP and is robustly, consistently and rigorously applied.  If there is any doubt over this we would wish boundaries drawn tightly round the existing built areas of settlements, whatever their size, allowing for small scale infill development.  Our wish is for the “natural” existing boundaries of smallest tier settlements to be protected whilst allowing for small scale infill development appropriate in pace and character.

We support the terms of the Housing in the Countryside 2009 Policy.  We support its inclusion as Supplementary Guidance in the LDP and consider that its terms, if amended at all, should be tightened not relaxed to strengthen its regulation of development in the rural environment.  We have specific proposals in this regard
(paras 6.1-6.5)

We support the Policies for the Natural Environment but have specific proposals with regard to Policy NE3. (paras 7.1-7.4)



2. Spatial Strategy

2.1 On behalf of our members we wish to register our full and unqualified support for the spatial strategies of both TAYPlan and the Proposed Plan and the principal of directing new development to the principal settlements – the 3 tier approach.  We also support the definition of the Perth Core Area.

2.2 We support the spatial strategies for the following reasons:   
The current economic climate is unlikely to improve in the short to medium term.  It will be absolutely vital that all money spent on costly infrastructure required for future development is spent so as to maximise benefit. We support the focussing of development on Dundee and Perth where the existing infrastructure could be expanded and improved in the most cost effective manner.  The Proposed Plan would maximise the ability to deliver development and transport infrastructure that would have economic benefits to the wider area and would result in development in areas best suited for it.  
2.3 Deliverability is a key issue in the current economic climate and we accept that infrastructure is very costly for the largest developments.  We have no reason to doubt that the proposed sites included in the Proposed Plan are deliverable within the required timeframe.  We believe, for a variety of reasons, including environmental reasons, that it is preferable to focus infrastructure on a small number of large sites rather than for a plethora of smaller sites to be promoted with the risk that a developer might be allowed to develop without the provision of adequate infrastructure due to the much higher proportionate cost.  
2.4 The Carse of Gowrie, and in particular the Braes of the Carse, is an area of remarkable natural beauty of which we are proud. It is an area where, particularly north of the A90, villages have by and large retained their original character. They fit well into the existing landscape, many houses fronting directly on to the unclassified single track road network and villages nestled into the valleys or at the foothills of the Braes. These hamlets have a long established sense of place and community and have evolved sympathetically in their rural setting. These are places that have evolved a characteristic form of development that cannot be replicated on a large scale and deserve to be cherished and conserved not expanded to the prejudice of existing and future generations of residents and visitors.  Our members consider that this is properly recognised in the spatial strategy of the Proposed Plan.   We feel that the accepted need to develop has been properly balanced with the need to preserve the historic and the natural environment.

2.5 We support the view taken in the Proposed Plan that there is adequate land capacity for growth in the existing Principal Settlements and we support the rejection of the Carse of Gowrie corridor as an area suitable for major development.  The danger would be that a vast anonymous development could be created lacking any pivotal points and completely out of keeping with the small communities in the area.

2.6 The Carse of Gowrie is an area of great biodiversity including designated areas on the River Tay.  We support the Spatial Strategy in the Proposed Plan in terms of which development is focussed within the Principal Settlements and therefore no need to develop in areas with existing nature conservation interest and which would be contrary to the Biodiversity Action Plan.  Due to the wide range of EU/UK and Scottish BAP Priority Habitats and Species found within the Braes of the Carse the Central Sidlaws Farmland Wildlife Restoration Project was set up in 2008 with funding from the Scottish Rural Development Programme. The aim of this project is to protect, restore and sensitively manage areas of Priority Habits such as species-rich grassland (including Calcareous Grassland), wetlands, hedges, tree lines and watercourses to benefit species such as the Northern Brown Argus butterfly, otters, water vole, bats and lapwing. There is also an impressive number of Priority Species associated with the agricultural “habitats” of the Braes of the Carse including hare, skylark, tree sparrow, linnet, grey partridge and curlew. The farm buildings on the Carse of Gowrie and the Braes of the Carse are also home to other protected species including barn owls, bats, swifts, swallows and house martins. The historic orchards also add to the outstanding biodiversity resource of the Carse of Gowrie and the Braes of the Carse.

2.7 We further support the spatial strategy as it reduces the contribution to climate change as it reduces the need to travel. Development of the Carse of Gowrie would inevitably increase travel demand as there are limited local services and most residents work and socialise in either Perth or Dundee. There is a limited public transport system and inevitably there would be an increased car use with its detrimental effects on the environment with carbon emissions. The existing roads infrastructure in the Carse, and in particular in the Braes of the Carse area, is totally inadequate for any significant development.

2.8 We consider that locally produced food will be of increasing importance to our future economy.  We support the Proposed Plan as it does not countenance significant development of the Carse of Gowrie for housing with the consequent permanent loss of prime agricultural land.  To allow development of agricultural land would reduce our ability to provide local produce and would not deliver sustainable development or promote sustainable food security.

2.9 We further support the Proposed Plan in its recognition of the risk of future flooding issues.   The Strategic Environmental Assessment indicates that large areas within the Carse are already at medium to high flood risk which would increase with any sea level rise. The land north of the Higher Carse road is steeply rising land and its valleys form the route for the natural water courses that run off into the flood plain. As a result of the topography and soils the flood plain land has significant water run offs and this results in regular flooding. In some areas the existing drainage system and the ancient “Pows” cannot cope with the existing water and consequently there are problems with repeated flooding and serious drainage issues that affect both residential property and agricultural land, inspite of much money spent on maintenance of these systems. As well as risk to any new development our members are concerned that increased water run-off would exacerbate existing problem areas. Members of our Group attended Climate Change panel meetings organised through PKC last year.  It is an area of concern for our members.   With climate change we are told that rainfall is likely to increase and the Carse therefore has the twin threat of flooding from rising sea levels and increased rainfall. Schemes to protect areas from all types of flooding are costly and, as stated previously, in the current and likely future economic climate optimising investment is key. Money spent to alleviate flood risk in terms of the spatial strategy in the Proposed Plan would maximise its benefit.

3. Green Belt
We support the proposed boundaries of the Green Belt but would wish to engage with the Council to discuss the future inclusion of the Braes of the Carse as a Local Landscape Area.   

Our members consider that the Carse of Gowrie and its Braes warrant recognition for their outstanding distinctive characteristics and features.  The Tay Landscape Partnership Scheme recognises the value of the area as a whole due to its unique landscape and natural and built features, but this integrated aspect is not given sufficient explicit consideration in the planning process in the assessments of future development in the individual settlements in this area.  The Tay Landscape Partnership Scheme has secured substantial funding from the Heritage Lottery Fund and is hoping to progress with Projects such as the restoration of the Historic Orchards found in the Carse of Gowrie and its Braes. Policy EP6: Lunan Valley Catchment Area provides an integrated approach to development where the Council seeks to protect and enhance the nature conservation and landscape interests of an area of Perthshire. The members would like to see this approach applied to the Braes of the Carse.


4. Small settlements – boundaries and the Housing in the Countryside Policy (HCP)

4.1 The question of whether small settlements should have boundaries and the terms and application of the Housing in the Countryside Policy (to be included, we understand, as enforceable Supplementary Guidance) are interlinked.

4.2 Whilst our members almost unanimously support the spatial strategy in the Proposed Plan and wish to protect the characteristics and identity of the small villages within the Braes of the Carse they have differing views regarding the most appropriate way to achieve this.

4.3 We understand and accept the reasoning behind the principle of not identifying settlement boundaries for the smallest settlements but are concerned that unless the terms of the current 2009 HCP are incorporated as Supplementary Guidance into the new LDP without any relaxation (and possibly with further strengthening as mentioned later) and are rigorously and consistently applied there is a risk of ongoing creeping expansion of rural “small settlements” and ribbon development outwith any existing “natural” settlement boundary.

It is proposed that there are to be only 3 settlements with boundaries in our area: Rait, Kinnaird and Baledgarno.  

4.4 Our local members agree with the proposed settlement boundary for Rait.  It provides the village, that has Conservation Status, with a tight boundary that protects its character.  It allows for appropriate infill, but precludes any large scale, development.

4.5 We have no comment to make on the proposed settlement boundary for Baledgarno, a village that also has Conservation status.

4.6 Our local members support the slightly extended  proposed settlement boundary for Kinnaird. They are happy that it protects the character of the village and protects open space whilst allowing for limited future infill development.  

4.7 Kilspindie and Abernyte have existing settlement boundaries in the current LDP but do not have boundaries in the Proposed Plan.   Our Kilspindie members appear happy to accept that, due to the size of the village, it will not in future have a settlement boundary but only provided that the HCP is rigorously enforced.  

4.8 Most of our Abernyte members are concerned at the proposed loss of their village boundary.  This is partly due to the fact that a submission for a fairly large scale development was made (albeit not recommended in the Main Issues Report and not included in the Proposed Plan) on land that lies outwith the existing settlement boundary.  The concern amongst some of our members that the removal of a boundary where one previously existed is an open invitation for development and that having a boundary provides them with certainty.   If the main driver for whether a settlement has a boundary or not in the new LDP is its size then we suggest that Abernyte would logically be entitled to retain its boundary.  Kinnaird and Rait (both having settlement boundaries) have fewer houses than Abernyte which already has 32 houses and existing planning permission for a further 4 or 5 houses at the current farm buildings in the village.   The figure of 20 houses had been previously mentioned in the Main Issues Report in relation to the size of settlement that might be classed as “small” and Abernyte has considerably more houses than this.  Abernyte also has its own primary school (Rait, Kinnaird and Baledgarno do not) and it has its own Church (Rait and Baledgarno do not.)   We would therefore ask you to reconsider the removal of the Abernyte boundary and to reinstate the existing boundary which allows for future development of a scale appropriate to the village.

4.9 In our area there are several small hamlets with less than 20 houses, for example Ballindean and Westown (and also now Kilspindie), or clusters of houses that are not classed as settlements in the current LDP and that have no boundary in the Proposed Plan.  The prime concern of our members in such hamlets is possible failure in the future of the planning authority to enforce the current Housing in the Countryside policy or a future relaxation of the policy resulting in straggling ribbon development and suburbanisation of the countryside.  

4.10 With regard to Ballindean, Sites 132 or 133 have not been included in the Proposed Plan and all of our members who do not have an interest in either site fully support their exclusion.  The inclusion of either area either as a development site or within a settlement boundary would allow potential development on a scale inappropriate to the character of the existing settlement.

4.11 Our members at Westown (and indeed our membership in general as the proposed development would adversely affect the whole of the Braes of the Carse area) support the exclusion of the sites 805 and 806 at Valleyfield from the Proposed Plan.  We are strongly of the opinion that the proposed large scale development at Westown that included proposals for a mart, car auction site, hotel and housing is totally inappropriate to its proposed setting.  We consider that it is important to retain the rural nature of the area and that the loss of agricultural land should be avoided if at all possible.

5. Settlement Boundaries
On balance we are therefore happy to support the Council’s proposal not to have settlement boundaries for small settlements to avoid arbitrary delineation and to allow case by case assessment of small sites for development, BUT ONLY IF the proposed Housing in the Countryside Supplementary Guidance adopted into the new LDP is legally enforceable and is robustly, consistently and rigorously applied.  If there is any doubt over this or the philosophy of the current 2009 Policy is likely to be relaxed in any way due to, for example, economic arguments by developers, we would wish tight settlement boundaries drawn round the existing built areas to prevent spillage of new build properties.  These boundaries should allow for limited future infill development to regulate the scale and pace of change within the settlements so that their character and sense of identity is not lost.

The current Housing in the Countryside Policy was unanimously approved by Councillors as recently as 2009 and we feel is generally still fit for purpose.  It amended and tightened up the previous 2005 Policy that, with the benefit of hindsight, had allowed inappropriate development to spoil areas of our rural landscape.

6. Supplementary Guidance
There are, however, a few additional points that we would wish considered and perhaps incorporated into the new Supplementary Guidance.  

6.1 (a)  Our members would wish the status of our historic heritage orchards to be properly recognised within the planning process.  There is evidence of a current disregard of their importance shown by potential developers of sites.  For example, we were disappointed to note the statement (P22 of  representation 0926) that part of Site 132 in Ballindean is located to the south west of “an existing copse of trees, formerly an orchard, but no longer recognised as such.”   The Wester Ballindean Orchard has historic value and importance and contains some extremely rare varieties of pear.  In the Historic Orchards of the Carse of Gowrie Survey Report by Dr Crispin Hayes it is recognised as “one of nine orchards in the premier league of what remains in the Carse”.  As such it is of significant interest to the Historic Orchard Forum and projects being undertaken as part of the Heritage Lottery funded Tay Landscape Partnership Scheme.  These orchards are an important part of the local heritage and are also of considerable biodiversity value.  Owners of orchards should be prevented from following a strategy of “planned dereliction” in the hope of securing permission for the erection of houses. Formal recognition of designated heritage orchards in the planning process would assist in preventing their further decline.

(b) Our members support Policy NE2B where a tree survey will be required to accompany all planning applications in order to ensure that the landscape of the area and significant trees are protected. However, the members would like to see the policy tightened to prevent the removal of trees, prior to the submission of a planning application, as has occurred on the Carse of Gowrie, where the developers deliberately remove any obstacle that may limit the amount of development that can be fitted onto a site.  The Policy should be amended to make it clear that this deliberate removal of trees will not be tolerated and that additional planting will be required to compensate.       

6.2 We would like to see the 2009 HCP clearly state that conversion of steadings into housing should be limited to vernacular/traditional stone and slate steadings only and that also they are genuinely redundant for agricultural purposes (i.e. they are no longer suitable for modern agriculture in terms of their relatively small traditional dimensions) and that relatively modern purpose built sheds are excluded from conversion/removal/replacement with housing. The push by developers to purchase relatively modern farm sheds for development is putting pressure on the future sustainability of agriculture in Perthshire as farming businesses cannot compete with the monetary value offered by developers for the opportunity of replacing a perfectly suitable agricultural shed with numerous houses. The potential for this pressure could be excluded if the purchase of actively used farm buildings with a view to leaving them unused and thus “redundant” no longer qualified the building as “redundant” i.e. “constructive redundancy” would not be permitted.  More requires to be done to ensure that farm buildings can be retained for agricultural use or utilised for other employment uses as opposed to housing.   


6.3 We do not consider that the HCP should be relaxed in respect of the conversion of redundant buildings.  Developers may argue that the current policy lacks understanding of the requirement for new build to crosssubsidise the conversion element.  We however support the restriction of a maximum of 25% of the total units or floor area comprising new build or rebuilt development which prevents developers overdeveloping sites.  Developers naturally seek to maximise profit and their economic arguments should not be allowed to override other policy and environmental considerations to the detriment of local people and landscape.

6.4    There seems to be some ambiguity in respect of the application of the policy in respect of Brownfield Land.  We consider that the policy, particularly with regard to small scale development and the maximum number of houses being 5, should apply whether the site is within or outwith a settlement boundary.  This would make having or not having a settlement boundary of less importance.   This would clarify the situation as we feel that the policy should apply to all Brownfield land in rural areas.  

6.5    We particularly support the wording in the sections regarding Building Groups and Infill Sites that “proposals in any location which contribute towards ribbon development will not be supported nor will proposals which would result in the extension of a settlement boundary.”


7. The Natural Environment and Biodiversity

7.1 Our members fully support the aims of Policy NE3: Biodiversity, which commit the Council to “protect and enhance all wildlife and wildlife habitats”.  Specifically, the LDP identifies four obligations on developers, based on criteria and principles identified in the Tayside Biodiversity Partnership Planning Manual.  However, the wording in this section does not demonstrate a firm policy and commitment to apply these principles.  For example, it states only that “developers may be required … [to follow the requirements 9a) – (d) as detailed in the Tayside Biodiversity Partnership Planning Manual. As the BCCG argued in its consultation response to the PKCMIR (10.02.2011), Supplementary Guidance on biodiversity is not robust enough to ensure that the LDP delivers the admirable objectives outlined in Policy NE3. Clear policies (rather than guidance) are needed to ensure this aspect is fully taken into account and incorporated. Guidance alone will not be robust enough to deliver the objectives outlined by PKC.

7.2 As with Policy NE2B relating to Forestry Woodland and Trees, Policy NE3 relating to Biodiversity should state that a survey of all protected species and all habitats should be submitted with all applications for Planning Permission. This is essential as protected species are found across all areas of Perthshire, many on farmland (such as skylark, tree sparrow, lapwing, linnet) and buildings (bats, barn owls, swifts, swallows etc) as well as the priority/protected species associated with habitats such as hedges, woodlands, wetlands, moorland and grasslands (spotted flycatcher, bullfinch, reed bunting, song thrush, black grouse, red squirrel etc). Any proposed development is likely to impact upon wildlife and as such the precautionary principal should be adopted, if not the Council will not be able to meet its policies laid out under Policy NE3. Policies relating to Environment and Conservation (NE1), National Designations (NE1B), Local Designations (NE1C) and European Protected Species (NE1D) all affect Biodiversity. With the exception of Local Designations, legal protection commits the Council to apply these policies, and affords protection to such sites. However, EU/UK/Scottish BAP Priority species and habitats are widespread in Perthshire but rather few sites of Local Nature Conservation or geological interest have been identified. If PKC does not have the relevant information, it will not be possible to determine when an ecological survey is required, as often the impact of a development is not apparent until surveys have been undertaken.

7.3 If Policy NE3 is to be achieved by PKC, there needs to be a method of ensuring that mitigation is enforceable and also that it has to be continued in the long term. There are reports of mitigation not being carried out at all or that after a short while mitigation features such as bat boxes or swift holes are dismantled/blocked.  Additional resources would require to be allocated to the enforcement department of PKC.

7.4 The Braes of the Carse is unusual in that it is one area of Perthshire where badgers have been increasing. Perthshire as a whole has an extremely small population of badgers in comparison to other parts of Scotland in spite of having excellent habitat. Badgers are extremely sensitive to disturbance near their setts and foraging areas, and due to their faithfulness to their movement corridors they are very vulnerable to being killed on the roads. Although badgers and their habitats are protected by the Protection of Badgers Act 1992, developments and increased traffic can have a significant impact on badgers and therefore the members are pleased to support the proposed Spatial Strategy directing development away from the Braes of the Carse.

Following the meeting regarding the Rait Conservation Area these are the two documents referred to. These are obviously mainly of concern to those who live in Rait, but may also be of wider interest to members. The PKC are wanting comments as they are carrying out an Appraisal on the Rait Conservation Area and are keen to get the views of the locals. Alison, plus a number of others, attended the public exhibition at Annat Hall and were told that PKC are more likely to take action regarding any issues if there is a good response from the community, so the more people that send feedback the better. BCCG are also wanting to put in a response from its membership.

http://www.braesofthecarse.org/pdf/Raityourview.pdf

 Please do get your comments to PKC before the deadline of the 14 May, and if you would like BCCG to put together a response from it's members please get your comments to Marilyn Webb This email address is being protected from spambots. You need JavaScript enabled to view it. by the 7 May in order to give BCCG time to prepare a response. 

{pdf}www.braesofthecarse.org/pdf/RaitApp.pdf {/pdf}

THE BRAES OF THE CARSE CONSERVATION GROUP
www.braesofthecarse.org

       
Local Development Plan Team    
Perth & Kinross Council    
Pullar House      
25 Kinnoull Street
Perth
PH1 5GD      10th February 2011


Dear Sir

General Comments and Responses to Questions from the Main Issues Report (MIR)

The Braes of the Carse Conservation Group (BCCG) was formed in 2009 to try and conserve the unique beauty, character and historical environment of the Braes of the Carse of Gowrie.  One aspect of our vision is to secure recognition of the importance of this area for future generations by a special designation (our responses below to specific MIR questions provide further detail on this) and we would value the opportunity to work with PKC to explore and achieve this.  Our Group’s aim is to provide a voice for residents and interest groups in an area north of the Perth – Dundee dual carriageway (A90) approximately between Glendoick in the West and Knapp in the East as outlined on the attached map (Attachment 1).   We have more than 150 local members and thus represent a significant proportion of the population in this relatively sparsely populated area.   

We recognise the significant amount of work that has gone into the preparation of both TAYPlan and PKC’s MIR and wish to register our unqualified approval of the preferred spatial strategies of both TAYPlan and PKC’s MIR. 

We wish to provide responses to some of the questions from the MIR and also to provide comment on some of the submissions relevant to the Braes of the Carse area even although none of these is recommended for inclusion in the Local Development Plan (LDP) given that they would be contrary to the preferred spatial strategies of TAYPlan and PKC.

1. Responses to Questions

Q4.  We agree with minimum density policies, but, most importantly, only in respect of larger greenfield sites over 2ha.  For smaller greenfield sites we consider that density should always be appropriate to the character and density of any existing settlement to which the site relates so that such existing settlements are not “swamped” and retain their sense of community.  We further suggest that whenever a development would increase the number of households by a given percentage (say 10%) that prospective development should always require extra scrutiny and consultation.  A basic rule of this type would provide an additional safeguard to a small community and require the developer to undertake prior consultation where no obligation at present exists.

Q6.Yes.  We agree with the statement in the MIR that the 2005 HCP has led to some unacceptable steading developments (in terms of the landscape impact, the number of units, the lack of services for the new sizeable community relative to the size of the plot etc) and are pleased that the 2009 HCP has tightened up on this. However, we would like to see the 2009 HCP clearly state that conversion of steadings into housing should be limited to vernacular/traditional stone and slate steadings only and that also they are genuinely redundant for agricultural purposes (i.e. they are no longer suitable for modern agriculture in terms of their relatively small traditional dimensions) and that relatively modern purpose built sheds are excluded from conversion/removal/replacement with housing.
The push by developers to purchase relatively modern farm sheds for development is putting pressure on the future sustainability of agriculture in Perthshire as farming businesses cannot compete with the monetary value offered by developers for the opportunity of replacing a perfectly suitable agricultural shed with 10 or so houses. The potential for this pressure needs to be clearly excluded by clarifying the 2009 HCP to ensure that developers are clear that this ‘back door’ approach is closed to them. More requires to be done to ensure that vacant and/or redundant farm buildings can be retained for agricultural use or utilised for other employment uses as opposed to housing. The housing developments that have been previously allowed have been amongst some of the worst in Perthshire with high density urban-style housing, completely out of character with the surrounding countryside and the local housing stock.
The Perthshire Countryside is extremely attractive and it is good to see that PKC have responded to this by tightening up the 2005 HCP to create the 2009 HCP. However, it is essential that this policy is adhered to and that the pressure for new housing does not result in the policy being only partially applied.
A lot of extremely useful and detailed work has been carried out on the historic orchards in the Carse in recent years.  We consider it essential that the importance of the area’s historic orchards is acknowledged and the remnants of these orchards given appropriate protection against future development by making them subject to the recent changes to Tree Preservation Order rules or providing them with some kind of other conservation status.  We understand that Fife and other Council authorities now provide protection for their historic orchards and we would ask PKC to do likewise.  These orchards are an important part of the local heritage and owners should be prevented from following a strategy of “planned dereliction” in the hope of securing permission for the erection of houses.
PKC provide general support to tree initiatives such as “Big Tree County” but we would ask you to do more, for example, by strengthening planning policies imposing clear and enforceable requirements on the preservation and restocking of trees.  We would wish to see the continuous diminution of our stock of amenity and roadside trees and hedgerows halted and the trend reversed with replanting of trees, many of which were planted in the 19th Century, when they die or fall.


Q7.  It is essential that the HCP 2009 Policy is stringently applied if it is to be successful in protecting the smallest tier of settlements from on-going creeping expansion. The ‘Infill Sites’ Policy needs to be rigorously enforced when it comes to the refusal of applications which either lead to ribbon development or the extension of the existing natural settlement boundary. We understand and accept the reasoning behind the preference not to draw boundaries round the smallest settlements and agree with it but only if the Housing in the Countryside policy will be rigorously enforced. If there is any doubt at all over the efficacy of the policy then we consider that, in those situations where a small settlement could have a logical closely drawn boundary defined, then this should be done, especially in areas of local landscape value if not included in the Perth Green Belt.  Our overarching wish is for the “natural” existing boundaries of smallest tier settlements to be protected.
In addition, with any development, there should be a requirement that existing trees are retained and protected from any damage during the development following accepted industry standards. Also, it is essential that all protected species are surveyed for and that legal protection and any agreed mitigation is enforced.  Further reference is made in our response to Q18.

Q13. We consider that the protection of prime agricultural land in general and in the Carse of Gowrie in particular is of great importance and this ties in with the preferred spatial strategies of both TAYPlan and PKC’s MIR. This area has productive fields that, in the main are good quality and cropped intensively. They provide employment for farmers, farmer workers, food processors and shops providing local produce. On a local basis there are therefore sound financial reasons why such agricultural land should now be protected and retained. There are also many important non-financial reasons why the retention of agricultural land is important. The Braes of the Carse area provides a unique combination of gently undulating farmland with hedges and field boundary trees, mixed woodland and historic orchards. We consider that the rural landscape requires protection and, whilst business opportunities should be encouraged, they should be appropriate to their setting.
For example, we are strongly of the opinion that the proposed large scale development on land with an agricultural zoning at Westown (Sites 805 and 806) that includes proposals for a mart, car auction site, hotel and housing is totally inappropriate to its proposed setting. 

We believe that locally produced food will play an increasingly important part of our future economy. This will be of not only local but also national and global importance. To allow housing or other commercial development on our prime agricultural land resulting in its permanent loss would run contrary to PKC’s avowed green ethos and widely held current thinking as it would have detrimental effects on sustainability and increased food miles.  As a result of climate change it is generally accepted that some areas currently used for agriculture will no longer be suitable for such purposes.  We therefore consider that the preservation of agricultural land that is likely to remain prime agricultural land notwithstanding the effects of climate change in the future is paramount.
 
 
Q14 Yes.  As stated in our response to Q6, we would like to see the 2009 HCP clearly state that conversion of steadings into housing should be limited to vernacular/traditional stone and slate steadings only and that also they are genuinely redundant for agricultural purposes (i.e. they are no longer suitable for modern agriculture in terms of their relatively small traditional dimensions) and that relatively modern purpose built sheds are excluded from conversion/removal/replacement with housing.
The push by developers to purchase relatively modern farm sheds for development is putting pressure on the future sustainability of agriculture in Perthshire as farming businesses cannot compete with the monetary value offered by developers for the opportunity of replacing a perfectly suitable agricultural shed with 10 or so houses. The potential for this pressure needs to be clearly excluded by clarifying the 2009 HCP to ensure that developers are clear that this ‘back door’ approach is closed to them. More requires to be done to ensure that vacant and/or redundant farm buildings can be retained for agricultural use or utilised for other employment uses as opposed to housing.

Q17. Yes we are in general agreement with the approach proposed.  If a “tight” Green Belt is ultimately accepted for Perth (see our response to Q24) then the importance of designating and protecting high quality landscapes becomes even more important. 
As far as the policy approach is concerned we suggest that perhaps a combination of a landscape character analysis with a more subjective approach based on visual qualities might provide sufficient flexibility but also the necessary objectivity. 

Whilst we appreciate that the MIR is not the vehicle for designating such landscapes at this stage we would suggest that the Braes of the Carse could be an example of a landscape suitable for designation based on a combined objective and subjective approach.  As mentioned in the introduction to these responses, we would value the opportunity to work with PKC to achieve this.   Its distinctive qualities are both recognised objectively as of high value by SNH in their Tayside Landscape Character Assessment and the spectacular views from and to the Braes are appreciated and valued by the general public with the hills forming a spectacular backdrop when viewed from the dual carriageway by residents, commuters and tourists alike.  The variety of landscape in the area, to quote from The Illustrated Architectural Guide to Perth & Kinross is “remarkable” with the view from the top of the Braes at Evelick Hill deemed “spectacular”. 
We would wish the criteria based policies to regulate development to which reference is made to be robust and unambiguous so that proper protection can be afforded to areas which, although not within any Green Belt are, due to their landscape value, worthy of protection.  We would be very concerned that future Supplementary Guidance would not have the same legal standing and enforceability as a Policy.  Supplementary Guidance could provide a “get-out” for planners and would thus not provide appropriate landscape protection.  

Q18. We agree with the statement in the MIR that there is a need to avoid further fragmentation of habitats and wildlife corridors and also the need to consider the impact of climate change on biodiversity.
Designated Sites already have legal protection, so there is less need for PKC to focus on these sites and more need to focus on the EU/UK/Scottish BAP Priority species and habitats that are widespread in Perthshire, making Perthshire one of the most important counties in Scotland for many scarce and threatened habitats and species. Steps should be taken to identify local biodiversity hot-spots and also collect data on all Priority species and habitats within Perthshire to provide a comprehensive data base.  At present this information is extremely poor.
We do not agree that the approach to protection and enhancement of biodiversity outlined in the MIR is wholly appropriate for the following reasons –
Firstly, our concern is that the inclusion of Supplementary Guidance would not be robust enough to protect, let alone enhance, the biodiversity of Tayside. There needs to be clear policies (rather than guidance) within the PKC planning framework to ensure this aspect is fully taken into account and incorporated. Guidance alone will not be robust enough to deliver the objectives outlined by PKC.
Secondly, there is only very limited data available on many habitats and species in Tayside and yet the county is home to many of Scotland’s rarest species such as water vole, sea eagle, red kite, red squirrel etc. As PKC do not have the relevant information to hand, it will not be possible for PKC to determine accurately when an ecological survey is required, as often the impact of a development is not apparent until surveys have been undertaken. For example, it is a legal requirement to protect not only badgers and their setts, but also foraging areas, and as badgers mainly come out after dark, it may be that the presence of badgers is unknown until a survey is undertaken.
Thirdly, it should be assumed that all buildings are used by  protected birds (e.g. owls, swallows, swifts, house martins etc) or bats and therefore a survey of protected species should always be required as part of any planning application where buildings are involved. Likewise with any mature trees that could be affected by the application, a survey should be required to see if they are being used by birds or bats or even squirrels.
Fourthly, any approach needs to recognise that some agricultural areas (rather than just semi-natural habitats) are important as habitat to some of our nationally declining  species and that these areas are in need of protection – such as areas that are used by nesting wading birds. Also, as mentioned in our response to Q6, all Historic Orchards should be protected from development as they are of outstanding biodiversity, historic and cultural value. They should be subject to the recent changes in TPO rules to ensure that all remnants are protected with TPOs or a similar conservation designation.  These orchards are an important part of the local heritage and owners should not be allowed to follow a strategy of “planned dereliction” in the hope of securing permission for the erection of houses when there is a desire and willingness amongst local groups and residents to restore and manage the orchards for the benefit of wildlife etc.

We recommend that the entire process for protecting and enhancing biodiversity  within the planning system needs to be overhauled and that a different approach is taken to the one suggested in the MIR. We recommend that PKC should follow the policy of several other Scottish local authorities, such as Lanarkshire, where an applicant has to submit biodiversity surveys with a planning application, at the application stage, in order for the application to be considered complete. The requirement regarding legally protected species and habitats  should be clearly spelt out with the application process and that these surveys are a required component of the planning application process for all legally protected species and all EU/UK/Scottish BAP Priority Species and Habitats, and when the appropriate time of year is for the surveys to be undertaken. The species and habitats to be surveyed for should be determined by the PKC Biodiversity Officer and should always include a basic habitat survey, including all buffer areas, plus all legally protected species following the established survey protocols.  These surveys should be undertaken by an independent professionally qualified surveyor and be submitted with the application before determination can commence. This avoids the excuse that there isn’t time for surveys to be undertaken within the time PKC has to respond, or for the applicant to argue that they do not have to undertake surveys at the correct time of year.
As part of this new approach it is essential that the full ramifications of a development are taken into account when identifying the impacts and preparing mitigation. For example, the impacts of climate change are likely to have significant impacts on water quality, where future increased flooding will result in pollution from private sewage treatment works, adversely affecting watercourses and possibly wetland habitats, causing harm to BAP Priority Species such as otter, water vole, lamprey, salmon etc. Safeguards need to put in place to ensure that the increased risks of flooding and their impacts on biodiversity are taken into account prior to approving development proposals.
If the MIR objective of protection and enhancement of biodiversity is to be achieved by PKC, there needs to be a method of ensuring that mitigation is enforceable and also that it has to be continued in the long term. There are reports of mitigation not being carried out at all or that after a short while mitigation features such as bat boxes or swift holes are dismantled/blocked.  Enforceability is a key issue.
The MIR mentions enhancement of biodiversity as well as protection and yet there is very little in the way of enhancement that would be achieved by the approach out-lined in the MIR. The new approach should be that every development has to produce a net biodiversity gain. It should not only be limited to trying to reduce the losses, but these should always be compensated for if losses are unavoidable (i.e. through enforceable mitigation), but there should also be an Enhancement Plan agreed as part of the planning application process. This should not just be limited to tree planting, but should also include many other habitat creation options and built-in options. 


Q19 We agree that the key issues have been addressed.  We agree that the spatial strategy reduces the need to travel which is a key issue in climate change by ensuring growth takes place close to Perth and other existing larger settlements.  We would, however, ask that the likelihood of additional traffic using the minor, many being unclassified single track, roads over the Braes is recognised and planned for (or against) when more houses are built in for example Scone or Balbeggie.  There is a danger that these narrow roads become a “rat run” for those heading towards Dundee. 

Q20.  We are particularly concerned about flood risk in the Carse of Gowrie and are reassured by the assertion that development will be guided to areas that do not flood or increase flood risk elsewhere.  We have concerns regarding SEPA’s 1 in 200 year indicative Flood Map as we are already aware of areas in the Carse that have been deemed suitable for development when local residents are aware of existing, let alone future, flooding problems.
We consider that flooding is a key issue for Carse residents.  For example, serious flooding has recently (Jan 2011) occurred at the Grange adjacent to a new housing development where there had been no flooding prior to the erection of the houses and their associated hard landscaping. 
Large areas of the Carse are low-lying, flat with heavy clay based soil.  The drainage systems put in place, including the ancient system of pows built many centuries ago to aid drainage for agricultural purposes, are simply inadequate to cope with increased run off from new housing.  The effects of climate change will only exacerbate this problem.
Whilst much of the Carse is flat, a significant part of the Braes of the Carse north of the Higher Carse road is steeply rising land.  The small valleys that run North/South in this area contain various hamlets and form the route for the natural water courses that run off into the flood plain.  As a result of the topography and soils the flood plain land already experiences significant water run offs and this has resulted in regular flooding at the foot of the Braes and beyond.  We would also ask that cognisance is taken not only of recognised streams and water courses in this area but also of existing and likely future increased “informal” water run off from the Sidlaws as this presently causes, and will increasingly cause, extensive flooding on the flood plains.
We would also ask that all applications relating to sites where drainage is into any of the pows should be examined with particular care and that enforceable conditions in respect of future maintenance of the pows is included. This should include access for plant and compulsory regular maintenance and preclude culverting.
PKC has already acknowledged that the Carse of Gowrie is an area with serious existing and future flooding issues as it is the location chosen, in association with the Scottish Climate Change Impacts Partnership, for a series of workshops on the affects of climate change.  
 
Q24  We note that the proposed outer boundary of the Green Belt (GB) is the closer outer boundary suggested by David Tyldesley  and Associates in their Perth GB Study although the conclusion of the Study was that the wider outer boundary was justified.  The Study accepted that the area of GB could potentially extend outwards from Perth in all directions for any distance that it was necessary to achieve the GB objectives. 

We consider that Perth’s relationship to its landscape setting is of great importance. As acknowledged in the Tyldesley’s Study and even if the preferred TAYPlan and PKC MIR spatial strategies are adopted, there is a danger of modern development spreading over the Igneous Hills (Sidlaws) and down the Tay corridor so destroying that special relationship.
We endorse the terms of the Housing in the Countryside Policy 2009, but unless its terms are rigorously applied the lack of or limited nature of other current policies (although this of course may be remedied by the proposed policies to which reference is made in paras 4.4.1 – 4.4.14 in the MIR) may allow inappropriate development that would prejudice the landscape setting of Perth without an appropriate GB designation.

The existing AGLV designation around Perth appears somewhat arbitrary and to relate neither to landscape character nor quality.  The Tyldesley Study (6.6) suggests that “the Igneous Hills of the Sidlaws are of equivalent landscape value all along the range but the AGLV stops well short of Kilspindie”.  It then suggests a wider outer boundary of the GB (approximately to Rait in the east) incorporating a larger part but not all of the distinctive Sidlaw range.  There seems no logical reason why this boundary should not extend further east to Knapp to take in more of the Sidlaw range.
The Tyldesley Report’s justification for the wider outer boundary of the GB was the need to protect those rural settlements that would otherwise lie outwith the GB from the effects of the GB itself.  A wider boundary would provide protection for small rural settlements e.g. Kinnaird, Westown, Ballindean, Abernyte (and Rait, Kilspindie and Pitroddie if the proposed closer GB boundary was adopted) where development of any significant scale would be inappropriate but, notwithstanding the preferred spatial strategy of TAYPlan, could experience pressure for development if a closer GB boundary was adopted for Perth.
An extended east boundary could be well defined and could follow the route of existing roads. 

We do, however, acknowledge that the purpose of a GB is quite different from simply protecting the landscape.  If ultimately it is decided (and we would not necessarily disagree with such a decision) that either no GB is appropriate for Perth or a GB with a closer outer boundary then, as explained further in our answer to Q17, we suggest that the part of the Braes of the Carse outwith a GB designation should be protected and designated a “local landscape area” due to its remarkable natural beauty and importance as the iconic view seen by countless commuters, residents and tourists when travelling between Perth and Dundee on the A90.
 
Q25 We agree with the proposed hierarchal approach to the identification of sites to meet the additional requirement. 

Q30.  We endorse your view that none of the villages outwith the Perth Core area and within the BCCG area have potential for development.   


2. Comment on submissions within the BCCG area

As mentioned previously, we note and support the view taken by PKC that none of these submissions are in line with the preferred TAYPlan spatial strategy and note and support PKC’s preference to take none of them forward into the LDP. 
In our opinion the rural sparsely settled character of the Braes of the Carse deserves protection.  In the Tayside Landscape Character Assessment regarding development (5.8.10) SNH suggested that the previous creation of suburban houses extending from farmsteads or existing hamlets had had a “suburbanising influence” on the Sidlaws’ landscape.  In their, and our, opinion new development should be avoided in the Sidlaws and development in open countryside in general should be discouraged.

The following comments are relevant in relation to all of the submissions in the BCCG area.

Landscape character and setting
The natural environment within the entire Braes of the Carse area and especially the beautiful uninterrupted views northwards from the A90 towards the Braes are an irreplaceable asset for local residents, commuters and tourists alike and we strongly believe require protection for future generations.
As well as the outstanding natural beauty of its landscape the area is also rich in historic and cultural interest with a history extending back to the Romans, Picts and Gaels.  The hamlets within the Braes area, with previous protection by Perth & Kinross Council, have by and large retained their original character unlike some of their counterparts in the Carse south of the A90.  They fit well into the existing landscape, many houses fronting directly on to the unclassified single track road network and villages nestled into the valleys or at the foothills of the Braes.  These hamlets have a long established sense of place and community and have evolved sympathetically in their rural setting. 
The uninterrupted view towards the Braes at night is also to be cherished.  The absence of street lighting means that apart from small clusters of house lights from uncurtained windows in the hamlets in the foothills and isolated house lights shining in the hills the area is free from light pollution.  This would inevitably change with any large scale residential or commercial development.

Traffic impact –physical constraints of unclassified road network
The Braes of the Carse area is networked by mainly unclassified roads. Running parallel with the A90 and from the Glendoik to Inchture junctions the unclassified road, sometimes known as the Higher/Upper Carse road, is in the main suitable only for single vehicle traffic and there are only limited passing places. 
The Higher Carse road is the original Perth – Dundee high road and has historical significance.  Widening opportunities are limited due to its location just above the Carse flood plain.  In addition a significant number of houses and hamlets are located with boundaries directly onto this road further limiting capacity for road improvements.

There is limited South to North traffic as the minor roads into the Perth-Scone-Balbeggie-Coupar Angus valley are similarly limited in width with the only B class road being the B953 through Abernyte and all other South/North routes being unclassified and mainly single track with passing places.

SNH in their Tayside Landscape Character Assessment expressed the view specifically in relation to the Braes of the Carse area that the small scale and rural character of these roads should be retained and that widening and other “improvements” should be resisted.   

We believe that further developments leading to increased commuter traffic into Perth/Dundee via either the Higher Carse road or other unclassified roads would place an undue traffic load on these routes.

We also believe that allowing additional housing in this area, where is no regular public transport system, shops or services would of necessity increase commuting which is contrary to the Council’s policy of sustainable development.

Safety aspects
We believe that any significant development of the hamlets located on the Higher Carse road, for example at Ballindean, or on other unclassified roads, for example at Rait, or any change to zoning of currently agricultural land to other use, for example at Westown, would be damaging both to the road condition and also to the safety of residents. 

These roads do not have any pavements or footpaths or space for such and most are bounded with drainage ditches critical to reducing flood risk in the area.  As already stated, a large number of houses have boundaries directly onto the unclassified roads (and many have parking spaces through historical precedent and necessity) and as such increased traffic would be dangerous to local residents and children in particular.

Amenity/Leisure
The road network within the Braes of the Carse area is used by a variety of local groups including Perth and Dundee based formal cycling clubs and many individual cyclists as well as runners/joggers.  At an even slower pace the roads network is a facility well used by dog walkers,horseriders and various formal walking groups as well as individual walkers/ramblers. 

The Council has already recognised the importance of the Braes of the Carse for walking with the proposed establishment of several “Core Paths” within the area.  Some of these Core Paths involve walking on sections of the public road which is considered safe and to be encouraged due to the limited amount of traffic.  With little space for passing places, pavements/verges any significant increase in traffic would have a corresponding increase in danger to non vehicle users of the roads and would thus be at direct odds with the promotion of the paths network and cycle routes.  As one of the Council’s aims is to improve the health of its residents and to encourage healthy outdoor activities such as cycling and walking any development involving a significant increase in traffic would be incompatible with this.

Flooding and drainage
The BCCG area comprises two discrete topographical areas.  The land between the A90 and the Higher Carse road is primarily agricultural, clay soil based, flat land with little drop from the foothills of the Braes to the A90.  This land is primarily used for cereal crop growing with limited livestock raising.  This land is prone to repeated flooding.

The land north of the Higher Carse road is steeply rising land and wooded in many areas.  The small valleys that run North/South in this area contain various hamlets and form the route for the natural water courses that run off into the flood plain.

As a result of the topography and soils the flood plain land has significant water run offs and this results in regular flooding along many areas adjoining and south of the Higher Carse road.  In some areas the existing drainage system and the Pows cannot cope with the existing water and consequently there are serious problems with repeated flooding and serious drainage issues that affect both residential property and agricultural land, inspite of much money spent on maintenance of these systems. 

We are pleased that the Council is taking a lead to protect these areas from additional problems and is not proposing to accept submissions that relate to land that has any current or future flooding issues.

The existing houses within the Braes of the Carse are not connected to the mains sewage system.  On the flat, heavy clay saturation renders septic tanks problematic.  Any new developments would therefore require private sewage treatment works to be set up within the development and these are notorious for having problems and being unreliable.  If these were situated on areas that already suffered from significant drainage and flooding problems then they could become a serious public health hazard and also result in pollution of watercourses and agricultural land.

Summary
The Braes of the Carse has not previously been significantly developed due partly to the infrastructure restrictions noted above and partly, we hope, by Perth & Kinross Council’s appreciation that this is a unique area of such landscape and historical importance and character that it deserves to be treasured and conserved for future generations.

We consider that, apart from small scale development within the boundaries of existing hamlets appropriate in character, density and amenity, that all significant development should be in locations in accordance with the proposed TAYPlan and PKC spatial strategies.   

The concern of members of our Group is that solutions to road, flooding and drainage issues would only be surmountable with very significant investment and this could only be funded by inappropriately large scale residential or business developments which would destroy the character, architectural and natural heritage and amenity value of this area. 

We appreciate that as none of the submissions relating to land within the BCCG area are being put forward for inclusion in the LDP (all being contrary to the preferred spatial strategy) that the initial assessments of the sites are probably not as detailed as might otherwise have been the case. There are, however, glaring inaccuracies in some of the officer’s comments. We therefore hope that the following comments, given from our member’s local knowledge and making reference to the headings in the initial assessments of the sites, will be of assistance.

A. Ballindean (Sites 132 and 133)

Ballindean is not presently designated as a settlement although a boundary was put forward in the draft 2004 Plan.  The preferred LDP strategy does not seek to identify new small settlements (Ballindean would be classed a small settlement as it has less than 20 dwellings and no community services whatsoever) or provide them with boundaries and we are happy to rely on this if the Housing in the Countryside Policy 2009 is rigorously enforced.

However, in our view if it is considered that a settlement boundary is required for the hamlet it should be tightly drawn as shown in Attachment 2.  Both submissions 132 and 133 would allow potential development on a scale inappropriate to the setting of the existing settlement.  There are only 17 houses in the hamlet. Planning permission has within the last year been granted for a further 2 houses i.e. an increase of more than 10%.  It should be noted that BCCG and neighbouring proprietors did not object to the planning application as it was considered appropriate infill within the logical boundary of the hamlet and would thus allow modest expansion of the hamlet appropriate in both scale and pace.  There would be further limited scope for development within our preferred boundary and we consider that no development over and above this would be appropriate during the term of the LDP otherwise the hamlet could be swamped and its sense of community lost.

We would also ask that consideration be given to designating  Ballindean with Conservation status.  Some of the reasons for so doing are given below and the community would value the opportunity of exploring this further with PKC.

Assessment topic
Sustainable locations – Proximity to Services and Facilities
We disagree with the assessment and suspect that perhaps the wrong information has been detailed for the site.  It is indeed within walking distance of the village but the village has NO services of any description.  The bus service is very infrequent –just twice a week- (as acknowledged in the assessments of the submissions for Rait and Abernyte) and there is no bus stop in the village.  There is no realistic potential for sustainable transport links to services or other settlements (as acknowledged in the Rait and Abernyte assessments indicating they are not sustainable locations.)
Biodiversity
Part of the eastern section of site 132 would affect a marshy wetland area where Lapwing, Skylark and many other birds breed.  Lapwing and Skylark are both BAP Priority Species and therefore should be protected from the impacts of development. They require large areas of open habitat and also wetland areas for feeding. Any development within approximately 100m would cause these priority species to abandon this site, and as there are very few sites on the Carse where permanent wetlands occur, this would be likely to prevent them from establishing successful territiories elsewhere. There is also a barn owl that regularly hunts on the fields forming the east end of site 132 so that any development in this area would put this rare species at risk. 
The site also wraps around the Wester Ballindean Orchard that has been recognised as a Historic Orchard being an ancient orchard worthy of preservation because of its biodiversity.
Landscape
If a Green Belt designation does not extend eastwards to include inter alia Ballindean we would hope that the value of the Braes of the Carse landscape would be considered worthy of protection in terms of paras 4.4.1.-4.4.14 of the MIR.  Even if neither of these proposals find favour we suggest that that any development in either of sites 132 and 133 would still be inappropriate given the landscape setting of the village as we do not consider that development would be possible without adversely affecting the key characteristics of the Landscape Character type.  As suggested by Scottish Natural Heritage (SNH) in their Tayside Landscape Character Assessment  such development would have a “suburbanising influence on the Sidlaw’s landscape” and in our view also should not be allowed.
Cultural Heritage
The importance of the Wester Ballindean Orchard has already been mentioned in relation to site 132.
Any development of either site would have a material adverse impact on the setting of Easter Ballindean House and Easter Ballindean Lodge listed C(S) and B respectively.  These distinctive red sandstone Georgian buildings feature prominently and form the eastern end of the village with open farmland to the north and south enhancing their setting.  Even taking into account the topography of the sloping site the setting of these listed buildings would be materially prejudiced by development of either site.
The majority of the other houses in the village, several of which are also listed, are also built of the local red sandstone and form an attractive small settlement or, as stated in “The Illustrated Architectural Guide to Perth & Kinross” (a publication supported by PKC, PKHT and Perth Civic Trust and others) “a picturesque estate hamlet”.  It has evolved a characteristic form of development that cannot be replicated on a large scale and deserves to be conserved for existing and future generations of residents and visitors.
Site Description
We agree with the assessment that both sites would have significant adverse affects on the village setting with views into and out of the village being materially affected.  Development of either site would be visible from the A90. The size of the sites would have an adverse impact on the character of the village.
Access
The proposed re-routing of the road in connection with site 132 would be of no local benefit and would be contrary to SNH’s recommendation (Tayside Landscape Character Assessment clause 5.8.9) that “improvements” to rural roads in the Braes of the Carse should be resisted.  The distinctive sharp bend within the village has been in place for many generations.  The oldest resident in Ballindean, who has lived locally for more than 60 years, confirms that to her knowledge there have never been any serious accidents at the bend.  Indeed the bend in the road has the advantage of slowing down traffic as it passes through the village.
Air Quality
Again, we would wish to correct the comment in the initial assessment.  The sites are NOT proximate to public transport (in the same way as the Rait and Abernyte sites)
Soil
Where possible we consider that PKC should protect agricultural land.   
Water and Flooding
It is stated that there is no known flooding in the area.  This is patently incorrect.  The Roads Department from their records will be able to verify that the public road leading to and through the village, as in many other places in the Carse, frequently floods after periods of heavy rain.  (See Attachments 3 and 4) The water run off from the Braes immediately to the North of the village is significant and, from local knowledge, has worsened over recent years and, with climate change, is likely to become even more significant. After heavy rain or snow melt water pours off the hill along the route shown forming the east boundary of site 133. (See Attachment 5).  It continues down the driveway of Easter Ballindean House and directly into the field forming part of the eastern end of site 132. (See Attachment 6) As  previously mentioned part of the site and the adjoining land to the east is well established marshland and has been uncultivated for many years despite recent attempts to improve drainage.  The water runs into this field (north of the Higher Carse road) and it is often under water for lengthy periods (See attachment 7) as is site 132 south of the Higher Carse road – a haven for birdlife but not suitable for housing.  (See Attachment 8).
At Wester Ballindean water again cascades off the hill and frequently floods the site 132 to the south of the existing village.  More photos can be made available if required.
With the break up of farms and reduced labour forces there is less regular clearing of silt traps and so with increased water run off as a result of climate change the culverts that already block and overflow will do so even more frequently.
There is no public drainage system in Ballindean.  Any new houses would require private drainage arrangements which, from local knowledge, are sometimes problematic given the soil type in the Carse and the inability of the existing field drains and Pows to cope with the existing, let alone increased future, water run off.


B Rait (Site 720)

Green Infrastructure
Over the past the 3 years there have been 3 new houses built with a further 2 in progress leaving very little open space in the village.
Biodiversity 
The village plays host to a number of protected species such as bats, red squirrels and owls and the site is a valuable wildlife corridor.
Landscape
Any development sensitive or not would have a major impact on the village landscape both looking into and out of the village.
Cultural Heritage 
Not only does the village contain the archaeological sites and listed buildings referred to in the assessment it also has a C listed churchyard.  It is a Conservation area and would be materially affected by any development of the site.
Site Description
The view from the top of the hills to the west and up from the east would undoubtedly be affected.
Site Orientation 
The site is now extremely limited since the latest permission was granted.
Access 
Most of the local road network is single track with limited passing places, which are particularly difficult during bad weather.
Soil
Due to the lack of mains sewerage and occasional flooding old septic tanks can pose contamination issues.         
Water
Tailraces from septic tanks are discharged into Rait burn.
Flooding
The burn within the village regularly floods. (Photos can be provided by our local members.)

As a final point we would wish to comment that although Rait’s importance to the area has been acknowledged by it being designated a Conservation Area, as far as we are aware, it has not had any appraisal carried out on it since its initial designation.  We understand that there is extensive guidance given to Councils on the proper treatment of Conservation Areas and we would suggest that a reassessment of Rait is now long overdue.

 

C Abernyte (Sites 29,30 and 31)
Site 29
Biodiversity
Red squirrels and barn owls have been sighted at the north end of the Site.
Landscape
Development of the site would alter the character of the village and create a more linear settlement.
Site description
The size of the site would be out of all proportion to the existing village
Soil
The site is good agricultural land
Water
A burn flows under the site via an underground channel and has been recorded as overflowing during periods of heavy run off.  Access to and future enhancements of the burn could be an issue if the site was developed and it would cause difficulties building on unstable land. Under the Water Framework Directive, there is a requirement that all watercourses are protected from degredation, and, where possible, degraded watercourses are improved. Building over a culverted watercourse would make such improvements very difficult and cause the burn to be nothing more than a drain, with no habitat or ecological potential for many years into the future.  It is also understood that den through which the burn flows was filled in with “unknown materials” which could cause problems for future “daylighting” in the burn.
There is no mains sewage system currently in the village.
Flooding
The underground channel has been choked in the past and has overflowed in the area of the proposed site.

There is no initial assessment of Sites 30 and 31 but we would make the following comments.
Site 30
This area has been used for many years by the Abernyte community and by the School as amenity ground and a playing field.  The Abernyte Community has a Scottish Government approved “Register of Interest” in the field with the intention of retaining its use for the community as a park and playing field.
Site 31
We agree that this appears contrary to the Housing in the Countryside policy.

D Westown (Sites 805 and 806)
There is no initial assessment of these large sites and so we feel unable at this stage to make specific comments.  We would, however, wish to register our extreme concern about any large scale development on these sites.  We note that development of this area of agricultural land is considered contrary to the preferred spatial strategy and are reassured by this.
We are strongly of the opinion that the mooted large scale development on the land that includes proposals for a mart, car auction site, hotel and housing is totally inappropriate for the site.

E Flawcraig (Sites 426 and 427)   
Again, no assessments carried out of these sites and therefore no comments to make other than supporting the view stated that development of neither site complies with the Housing in the Countryside policy.

BCCG’s representations submitted to TAYPlan Proposed Plan
1: Seek changes or Support as written
We need to know whether your representation is seeking a change or whether it is supporting the part of the
Proposed Plan that you are making representations on.
Question 1: Please tick one of the following to tell Support as written
us if you seek a change to or if you support as
written part of the Proposed Plan -Seeking a
change = you want to see a change (however
major or minor). -Support as written = you wish
to see it stay as it presently and do not wish to
see it change.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Your answer will generate question 3.
Question 2: Please tick one of the following to tell 2. Location Priorities
us which chapter your representation relates to.
You chose - 2. Location Priorities
We need to know the page and section of the Location Priorities Chapter that you wish to comment on.
Question 3: Please tick one of the following to tell Page 9: Policy 1 - the whole policy
us the page and section you are commenting on.
4: Supporting (which part)
If you are supporting part(s) of the Proposed Plan as presently written and do not wish to see it change this is where you need to tell us specifically which part.
Use Question 5 to tell us why.
Question 4: Please tell us which part(s) of the Proposed Plan you are supporting and wish to remain unchanged.
We support the whole policy as proposed. We particularly support the statement that development in rural areas should only be considered where it can be accommodated and supported by an existing settlement and genuinely contributes to the objectives of the plan and meets specific local needs or supports regeneration of the local economy.
5: Reasons
This is where you can explain the reasons for your answer to question 4.
Question 5: Please tell us why you think this
As a general principle we feel that any development of existing small rural settlements should not
encroach on agricultural land and that the pace and scale of all development should always be
appropriate to the existing character and density of the settlement so that such small settlements are not "swamped" and they retain their sense of community.
1: Seek changes or Support as written
We need to know whether your representation is seeking a change or whether it is supporting the part of the
Proposed Plan that you are making representations on.
Question 1: Please tick one of the following to tell Support as written
us if you seek a change to or if you support as
written part of the Proposed Plan -Seeking a
change = you want to see a change (however
major or minor). -Support as written = you wish
to see it stay as it presently and do not wish to
see it change.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Question 2: Please tick one of the following to tell 3. Shaping Better Quality Places
us which chapter your representation relates to.
You chose - 3. Shaping Better Quality Places
We need to know the page and section of the Shaping Better Quality Places Chapter that you wish to comment on.
Question 3: Please tick one of the following to tell Page 11: Policy 2 Part A - covering resilience
4: Supporting (which part)
If you are supporting part(s) of the Proposed Plan as presently written and do not wish to see it change this is where you need to tell us specifically which part.
Question 4: Please tell us which part(s) of the Proposed Plan you are supporting and wish to remain unchanged.
We strongly endorse the presumption against development in areas vulnerable to flood risk and rising sea level.
5: Reasons
This is where you can explain the reasons for your answer to question 4.
Question 5: Please tell us why you think this
We do not consider that significant development in the Carse of Gowrie is appropriate due to the risk of flooding. The Strategic Environmental Assessment indicates that large areas within the Carse are already at medium to high flood risk which would increase with any sea level rise due to climate change.
As far as we are aware little or no investigation has yet been carried out into flooding issues in relation to smaller watercourses or run off from the Sidlaws. The land north of the Higher Carse road is steeply rising land and its valleys form the route for the natural water courses that run off into the flood plain.  As a result of the topography and soils the flood plain land has significant water run offs and this results in regular flooding. In some areas the existing drainage system and the ancient "Pows" cannot cope with the existing water and consequently there are problems with repeated flooding and serious drainage issues that affect both residential property and agricultural land, inspite of money spent on maintenance of these systems. We doubt if even more regular maintenance of the Pows and drainage ditches would alleviate the problems. As well as risk to any new development we are concerned that increased water run-off e.g. from the Sidlaws would exacerbate existing problem areas. With climate change we are told that rainfall is likely to increase and the Carse therefore has the twin threat of flooding from rising sea levels and increased rainfall. We would wish it noted that many parts of the Carse north of the A90 are as low lying, poorly drained and prone to flooding as areas to the south of it and the arguments against development due to flooding and drainage concerns in the Carse are as relevant to this area.
1: Seek changes or Support as written
We need to know whether your representation is seeking a change or whether it is supporting the part of the
Proposed Plan that you are making representations on.
Question 1: Please tick one of the following to tell Support as written
us if you seek a change to or if you support as
written part of the Proposed Plan -Seeking a
change = you want to see a change (however
major or minor). -Support as written = you wish
to see it stay as it presently and do not wish to
see it change.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Your answer will generate question 3.
Question 2: Please tick one of the following to tell 4. Managing TAYplan's Assets
us which chapter your representation relates to.
You chose - 4. Managing TAYplan's Assets
We need to know the page and section of the Managing TAYplan's Assets chapter that you wish to comment on.
Question 3: Please tick one of the following to tell Page 13: Policy 3 Natural and Historic Assets
us the page and section you are commenting on.
4: Supporting (which part)
If you are supporting part(s) of the Proposed Plan as presently written and do not wish to see it change this
is where you need to tell us specifically which part.
Use Question 5 to tell us why.
Please do NOT write 'see attached'.
Question 4: Please tell us which part(s) of the Proposed Plan you are supporting and wish to remain unchanged.
We support the whole policy of safeguarding habitats, sensitive green spaces etc etc in the second
paragraph.
5: Reasons
This is where you can explain the reasons for your answer to question 4.
Question 5: Please tell us why you think this
There are areas of remarkable natural beauty in the TAYPlan area of which we should be proud. For example the Carse of Gowrie provides a combination of gently undulating fertile farmland with hedges and field boundary trees, a network of predominantly unclassified roads with scattered trees, shrubs and wild flowers, large estates including Fingask and Rossie Priory both Designated Landscapes, mixed woodland and historic orchards. The area already provides valuable wildlife corridors and we would like to see these further enhanced. It is an area where, particularly north of the A90, villages have by and large retained their original character. They fit well into the existing landscape, many houses fronting directly on to the unclassified single track road network and villages nestled into the valleys or at the foothills of the Braes. These hamlets have a long established sense of place and community and have evolved sympathetically in their rural setting. These are places that have evolved a characteristic form of development that cannot be replicated on a large scale and deserve to be cherished and conserved. In our view the accepted need to develop requires to be carefully balanced with the need to preserve the historic and the natural environment.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Question 2: Please tick one of the following to tell 6. Housing
us which chapter your representation relates to.
You chose - 6. Housing
We need to know the page and section of the Housing chapter that you wish to comment on.
Page 17: Policy 5 Part C - covering land releases
surrounding Dundee and Perth Core Areas
Question 3: Please tick one of the following to tell us the page and section you are commenting on.
5: Reasons
This is where you can explain the reasons for your answer to question 4
Question 5: Please tell us why you think this
In the current economic climate that seems unlikely to change in the short to medium term to maximise the ability to deliver development and transport infrastructure that would have economic benefits to the wider area development should be focussed on the main settlements of Perth and Dundee. Focussing on development in the Dundee and Perth Core areas would reduce the contribution to climate change as it reduces the need to travel. Development of the Carse of Gowrie would inevitably increase travel demand as there are limited local services and most residents work and socialise in either Perth or Dundee. There is a limited public transport system and inevitably there would be an increased car use with its detrimental effects on the environment with carbon emissions. The existing roads infrastructure in the Carse, and in particular in the Braes of the Carse area is totally inadequate for any significant development.
Question 1: Please tick one of the following to tell Support as written
us if you seek a change to or if you support as
written part of the Proposed Plan -Seeking a
change = you want to see a change (however
major or minor). -Support as written = you wish
to see it stay as it presently and do not wish to
see it change.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Your answer will generate question 3.
Question 2: Please tick one of the following to tell 11. General comments on the whole Plan
us which chapter your representation relates to.
4: Supporting (which part)
If you are supporting part(s) of the Proposed Plan as presently written and do not wish to see it change this
is where you need to tell us specifically which part.
Use Question 5 to tell us why.
Question 4: Please tell us which part(s) of the Proposed Plan you are supporting and wish to remain unchanged.
We wish to offer our general support for and endorsement of the policies contained in the whole of the proposed Plan
5: Reasons
This is where you can explain the reasons for your answer to question 4.
Question 5: Please tell us why you think this
We consider that all of the relevant factors have been considered and due weight has been given to them in the Proposed Plan.
BCCG’s representations submitted to TAYPlan Proposed Plan
1: Seek changes or Support as written
We need to know whether your representation is seeking a change or whether it is supporting the part of the
Proposed Plan that you are making representations on.
Question 1: Please tick one of the following to tell Support as written
us if you seek a change to or if you support as
written part of the Proposed Plan -Seeking a
change = you want to see a change (however
major or minor). -Support as written = you wish
to see it stay as it presently and do not wish to
see it change.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Your answer will generate question 3.
Question 2: Please tick one of the following to tell 2. Location Priorities
us which chapter your representation relates to.
You chose - 2. Location Priorities
We need to know the page and section of the Location Priorities Chapter that you wish to comment on.
Question 3: Please tick one of the following to tell Page 9: Policy 1 - the whole policy
us the page and section you are commenting on.
4: Supporting (which part)
If you are supporting part(s) of the Proposed Plan as presently written and do not wish to see it change this is where you need to tell us specifically which part.
Use Question 5 to tell us why.
Question 4: Please tell us which part(s) of the Proposed Plan you are supporting and wish to remain unchanged.
We support the whole policy as proposed. We particularly support the statement that development in rural areas should only be considered where it can be accommodated and supported by an existing settlement and genuinely contributes to the objectives of the plan and meets specific local needs or supports regeneration of the local economy.
5: Reasons
This is where you can explain the reasons for your answer to question 4.
Question 5: Please tell us why you think this
As a general principle we feel that any development of existing small rural settlements should not
encroach on agricultural land and that the pace and scale of all development should always be
appropriate to the existing character and density of the settlement so that such small settlements are not "swamped" and they retain their sense of community.
1: Seek changes or Support as written
We need to know whether your representation is seeking a change or whether it is supporting the part of the
Proposed Plan that you are making representations on.
Question 1: Please tick one of the following to tell Support as written
us if you seek a change to or if you support as
written part of the Proposed Plan -Seeking a
change = you want to see a change (however
major or minor). -Support as written = you wish
to see it stay as it presently and do not wish to
see it change.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Question 2: Please tick one of the following to tell 3. Shaping Better Quality Places
us which chapter your representation relates to.
You chose - 3. Shaping Better Quality Places
We need to know the page and section of the Shaping Better Quality Places Chapter that you wish to comment on.
Question 3: Please tick one of the following to tell Page 11: Policy 2 Part A - covering resilience
4: Supporting (which part)
If you are supporting part(s) of the Proposed Plan as presently written and do not wish to see it change this is where you need to tell us specifically which part.
Question 4: Please tell us which part(s) of the Proposed Plan you are supporting and wish to remain unchanged.
We strongly endorse the presumption against development in areas vulnerable to flood risk and rising sea level.
5: Reasons
This is where you can explain the reasons for your answer to question 4.
Question 5: Please tell us why you think this
We do not consider that significant development in the Carse of Gowrie is appropriate due to the risk of flooding. The Strategic Environmental Assessment indicates that large areas within the Carse are already at medium to high flood risk which would increase with any sea level rise due to climate change.
As far as we are aware little or no investigation has yet been carried out into flooding issues in relation to smaller watercourses or run off from the Sidlaws. The land north of the Higher Carse road is steeply rising land and its valleys form the route for the natural water courses that run off into the flood plain.  As a result of the topography and soils the flood plain land has significant water run offs and this results in regular flooding. In some areas the existing drainage system and the ancient "Pows" cannot cope with the existing water and consequently there are problems with repeated flooding and serious drainage issues that affect both residential property and agricultural land, inspite of money spent on maintenance of these systems. We doubt if even more regular maintenance of the Pows and drainage ditches would alleviate the problems. As well as risk to any new development we are concerned that increased water run-off e.g. from the Sidlaws would exacerbate existing problem areas. With climate change we are told that rainfall is likely to increase and the Carse therefore has the twin threat of flooding from rising sea levels and increased rainfall. We would wish it noted that many parts of the Carse north of the A90 are as low lying, poorly drained and prone to flooding as areas to the south of it and the arguments against development due to flooding and drainage concerns in the Carse are as relevant to this area.
1: Seek changes or Support as written
We need to know whether your representation is seeking a change or whether it is supporting the part of the
Proposed Plan that you are making representations on.
Question 1: Please tick one of the following to tell Support as written
us if you seek a change to or if you support as
written part of the Proposed Plan -Seeking a
change = you want to see a change (however
major or minor). -Support as written = you wish
to see it stay as it presently and do not wish to
see it change.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Your answer will generate question 3.
Question 2: Please tick one of the following to tell 4. Managing TAYplan's Assets
us which chapter your representation relates to.
You chose - 4. Managing TAYplan's Assets
We need to know the page and section of the Managing TAYplan's Assets chapter that you wish to comment on.
Question 3: Please tick one of the following to tell Page 13: Policy 3 Natural and Historic Assets
us the page and section you are commenting on.
4: Supporting (which part)
If you are supporting part(s) of the Proposed Plan as presently written and do not wish to see it change this
is where you need to tell us specifically which part.
Use Question 5 to tell us why.
Please do NOT write 'see attached'.
Question 4: Please tell us which part(s) of the Proposed Plan you are supporting and wish to remain unchanged.
We support the whole policy of safeguarding habitats, sensitive green spaces etc etc in the second
paragraph.
5: Reasons
This is where you can explain the reasons for your answer to question 4.
Question 5: Please tell us why you think this
There are areas of remarkable natural beauty in the TAYPlan area of which we should be proud. For example the Carse of Gowrie provides a combination of gently undulating fertile farmland with hedges and field boundary trees, a network of predominantly unclassified roads with scattered trees, shrubs and wild flowers, large estates including Fingask and Rossie Priory both Designated Landscapes, mixed woodland and historic orchards. The area already provides valuable wildlife corridors and we would like to see these further enhanced. It is an area where, particularly north of the A90, villages have by and large retained their original character. They fit well into the existing landscape, many houses fronting directly on to the unclassified single track road network and villages nestled into the valleys or at the foothills of the Braes. These hamlets have a long established sense of place and community and have evolved sympathetically in their rural setting. These are places that have evolved a characteristic form of development that cannot be replicated on a large scale and deserve to be cherished and conserved. In our view the accepted need to develop requires to be carefully balanced with the need to preserve the historic and the natural environment.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Question 2: Please tick one of the following to tell 6. Housing
us which chapter your representation relates to.
You chose - 6. Housing
We need to know the page and section of the Housing chapter that you wish to comment on.
Page 17: Policy 5 Part C - covering land releases
surrounding Dundee and Perth Core Areas
Question 3: Please tick one of the following to tell us the page and section you are commenting on.
5: Reasons
This is where you can explain the reasons for your answer to question 4
Question 5: Please tell us why you think this
In the current economic climate that seems unlikely to change in the short to medium term to maximise the ability to deliver development and transport infrastructure that would have economic benefits to the wider area development should be focussed on the main settlements of Perth and Dundee. Focussing on development in the Dundee and Perth Core areas would reduce the contribution to climate change as it reduces the need to travel. Development of the Carse of Gowrie would inevitably increase travel demand as there are limited local services and most residents work and socialise in either Perth or Dundee. There is a limited public transport system and inevitably there would be an increased car use with its detrimental effects on the environment with carbon emissions. The existing roads infrastructure in the Carse, and in particular in the Braes of the Carse area is totally inadequate for any significant development.
Question 1: Please tick one of the following to tell Support as written
us if you seek a change to or if you support as
written part of the Proposed Plan -Seeking a
change = you want to see a change (however
major or minor). -Support as written = you wish
to see it stay as it presently and do not wish to
see it change.
2: Which Chapter of the Proposed Plan
We need to know which chapter of the Proposed Plan you wish to make a representation on.
Your answer will generate question 3.
Question 2: Please tick one of the following to tell 11. General comments on the whole Plan
us which chapter your representation relates to.
4: Supporting (which part)
If you are supporting part(s) of the Proposed Plan as presently written and do not wish to see it change this
is where you need to tell us specifically which part.
Use Question 5 to tell us why.
Question 4: Please tell us which part(s) of the Proposed Plan you are supporting and wish to remain unchanged.
We wish to offer our general support for and endorsement of the policies contained in the whole of the proposed Plan
5: Reasons
This is where you can explain the reasons for your answer to question 4.
Question 5: Please tell us why you think this
We consider that all of the relevant factors have been considered and due weight has been given to them in the Proposed Plan.

Sections of Perth & Kinross Council’s Main Issues Report (MIR) and Questions relevant to BCCG

The MIR is a lengthy and comprehensive document that runs to some 168 pages.  For those of you who have neither the time nor the inclination to read the whole Report we have selected those sections of the MIR and the questions relating to these sections that we consider most relevant to our area.  We wish to provide responses to these questions (and any others that members consider relevant), and would therefore like to hear from you with your comments.

It is reassuring to note that at this point, in line with the TAYPlan preferred spatial strategy, development in the Carse of Gowrie is not part P & K Council’s preferred strategy which focuses most development in the Perth core area.  However, as you may recall, there were a number of submissions made for land within the Braes of the Carse to be included for development within the MIR.  As mentioned, all of these are contrary to the preferred spatial strategy or the Housing in the Countryside Policy 2009 and are therefore not intended to be included in the Local Development Plan.  Initial assessments have, however, still been carried out for all submissions and these can be seen below.  Please let us know if you wish us to comment on any particular aspects of, or inaccuracies in, any assessment relevant to you.

We are particularly concerned by the submissions relating to Westown due to their large scale and potential adverse effect on the rural nature of the area.
Click on the links below to view the initial assessments of the submission sites.

Abernyte  http://www.pkc.gov.uk/NR/rdonlyres/07FAA57C-7E0C-40B9-92F9-8B288EE58D41/0/Abernyte.pdf

Ballindean  http://www.pkc.gov.uk/NR/rdonlyres/A3D52E3E-F265-49EC-A9A6-B0B99D151C89/0/Ballindean.pdf http://www.pkc.gov.uk/NR/rdonlyres/BED9960D-C1F6-4F29-8D2B-9413FD12BEF2/0/Flawcraig.pdf

Flawcraig

Rait  http://www.pkc.gov.uk/NR/rdonlyres/4EDCB8FD-1F12-4FB8-A85E-8B0A997B023E/0/Rait.pdf

Westown  http://www.pkc.gov.uk/NR/rdonlyres/6A33AC93-EBF4-4703-A7A6-9F3D4D00DD1F/0/Westown.pdf

If you wish to see the full Main Issues Report the following link will take you to it http://www.pkc.gov.uk/NR/rdonlyres/3BCEBE0F-3D11-476A-A76C-5D01AA0C37D0/0/MIRforpublication.pdf

If you wish to see Perth & Kinross Council’s Housing in the Countryside Policy 2009 the following link will take you to it
http://www.pkc.gov.uk/NR/rdonlyres/31C0D9AC-DAAE-47F0-99CD-82C4CAA80313/0/HousingintheCountrysidePolicyAugust2009.pdf


Please note that to allow a formal response on behalf of the BCCG to be prepared and lodged prior to the deadline of 14th January 2011, and due to the Christmas and New Year holidays, we would like your comments prior to 24th December 2010.  Please either pass on your comments to your local committee rep or any committee member or email them to This email address is being protected from spambots. You need JavaScript enabled to view it.

The eight questions that we would like you give us your views on are…..


Key Issue 7 – Housing in the Countryside Policy
4.2.31.  The Council last reviewed its Housing in the Countryside Policy in 2009. The review tightened the policy of 2005 which had allowed for the erection of significant numbers of new houses in the countryside, particularly associated with steading redevelopments. Monitoring the effects of this policy and the reaction of the rural communities established that the application of this policy was potentially detrimental to the character of the countryside of Perth & Kinross. The 2009 policy is considered fit for purpose and the preferred option is for it to be included in the Local Development Plan for most of Perth & Kinross except in areas where a tighter policy may be required to deal with specific environmental issues such as controlling development within the Loch Leven and Lunan catchments or within the Perth green belt. These specific issues are discussed further in Chapter 5.
4.2.32. The policy as revised offers more scope for infill, conversions and replacement housing than in the previous Local Plans. It is therefore considered that the smallest tier of settlements are adequately covered by this policy and do not require to be identified within a specific settlement boundary plan. The preferred option is to not identify settlement boundaries for the smallest settlements (generally these settlements have less than 20 houses and no facilities such as schools, shops or community facilities) unless there are specific reasons for doing so such as controlling rural development in the Loch Leven catchment or encouraging small scale developments in more remote parts of the Council’s area.
Q6 – Do you support the inclusion of the 2009 Housing in the Countryside policy in the LDP? If not, what changes would you like to see and why?
Q7 – Do you agree with the principle of not identifying settlement boundaries for the smallest settlements? If not, please give reasons.

Key Issue 13 – Rural Businesses
4.3.21.  Not all businesses in rural areas are related to the tourism industry, many are there because of the availability of natural resources i.e. agriculture, sawmills and minerals extraction or because of local entrepreneurs. In addition e-communication has opened up opportunities for a wider range of businesses to operate from rural locations.
4.3.22. Whilst the identification and allocation of sites capable of helping to deliver sustainable economic growth will be a key task for the Proposed Plan, particularly in the main towns of the area, it must be recognised that a variety of new business opportunities develop not just on established business sites but on a far more diverse range of locations. The Proposed Plan will need to develop flexible criteria-based policies that balance the needs of rural based businesses whilst still protecting the amenity of residents.
4.3.23.  This does not mean that sites in rural location will be acceptable in all cases. The most sustainable location for most businesses will remain within or adjacent to existing settlements where a rural location is required criteria based policy should require this to be justified.
Q13 – Do you agree with the policy approach to support key rural businesses?
Q14 – Vacant and redundant farm buildings tend to be redeveloped for housing rather than business uses. Should more be done to reuse them for farming or other employment purposes?

Key Issue 16 – Landscape
4.4.1.  Perth and Kinross is renowned for its high quality, distinct and diverse landscapes, many of which form a significant part of Scotland’s natural and cultural heritage. These landscapes are an important resource that contributes to the social and economic well-being our area. They provide the surroundings for our daily lives, adding positively to the quality of life and economic performance of the area. And they provide the special places whose character and scenic quality is the main attraction for tourism and outdoor recreation and can contribute to health improvement and wellbeing.
4.4.2.  The landscape character of Perth and Kinross is constantly changing as a result of various forces that affect the physical appearance of the landscape and consequently, landscape character. By controlling the location, siting and design of new development and proactively planning for change, the Local Development Plan will have a strong influence on the nature of change and the character and appearance of the landscape.
4.4.3.  The factors which affect the change to landscape character are policies such as those advocating renewable energy, meeting the area’s housing requirements, improving infrastructure, creating employment sites and improving countryside management. Both the Council and the Scottish Government have recognised the need to marry development and environmental protection in order to achieve a balanced approach to implementing wide-ranging policies. Concern for the landscape is therefore part of wider efforts for a more sustainable future.
4.4.4.  In addition, an important quality found in some of Scotland’s mountainous and coastal landscapes are the perception of wildness or tranquility. Perth and Kinross has many areas of this type which are also worthy of recognition and protection. Historic landscapes are also of importance and worthy of protection.
4.4.5.  Scottish Planning Policy suggests that the LDP should take a broader approach to landscape rather than just conserving designated or protected sites. It encourages planning authorities to limit non-statutory designations to ‘local landscape areas’ and these will replace areas such as Areas of Great Landscape Value (AGLVs). The SPP suggests that protection of landscape is a matter to be considered by the Local Development Plan particularly where it would:
• “safeguard and enhance the character and quality of landscapes which are important or particularly valued locally or regionally, or
• promote understanding and awareness of the distinctive character and special qualities of local landscapes, or
• safeguard and promote important settings for outdoor recreation and tourism locally”
4.4.6.  The overall aim of any policy should be to achieve ‘sustainable’ landscapes that are as visually rich, culturally rich, bio-diverse, meeting the area’s social, economic, and environmental objectives. There are, however, different policy approaches:
4.4.7.  One, which appears simple, would be to say that all landscapes in Perth and Kinross are of great beauty and of worth and should be protected though criteria based policies.
4.4.8.  Another could be to designate areas based on an assessment of certain, largely visual, aesthetic qualities, which people respond to instinctively and value. However, this value is not absolute and tends to reflect prevailing ideas about which landscapes are seen as ‘attractive’ or have value, but nonetheless has considerable merit as it is often more easily understood by people as they value ‘the view’; or
4.4.9.  Alternatively one based on an analysis of landscape character informed by the Tayside Landscape Character Assessment. This identifies the distinct and recognisable pattern of elements that occurs consistently in a particular type of landscape and the way in which people perceive these.
4.4.10.  In addition, the development of policies for the protection of landscape will need to protect those areas which show wild land characteristics and are important for
people’s recreation and wellbeing. Other policies or Supplementary Guidance for wind energy and forestry will also be important to protecting such areas from inappropriate development.
4.4.11.  While it is important to value all landscapes this is not a substitute for identifying and taking action for landscapes which merit special attention, either because they are of particular value and warrant protection or because they are degraded and require active management or positive restoration or are under threat from inappropriate development. Consequently, a ‘local landscape’ designation to replace the existing AGLV designation, could continue to play an important role in protecting and enhancing those landscapes which are recognised as being of particular value and merit special attention. Therefore, the challenge for us is to find a way of accommodating change, whilst at the same time retaining and, where possible, strengthening the area’s character and local distinctiveness.
4.4.12.  Consequently, in order to meet these challenges we need to do more than just identify important or “high quality” landscapes. This means that we will also have to develop criteria based policy or policies and Supplementary Guidance which will protect landscape qualities against particular types of development.
4.4.13.  In addition to policies there are a number of tools such as green belts and similar greenspace policies (green networks, wedges and corridors), which could and would make an important contribution to landscape objectives through maintaining the identity and setting of towns, and contributing to the quality of life in and around settlements.
4.4.14.  Consequently, the preferred approach is to:
• Proactively designate and protect areas of scenic quality and their associated viewpoints
• Enhance existing criteria based policy to regulate development
• Identify and protect landscape features of significance
• Define the inner and outer limits of the proposed Perth green belt
• Prepare Supplementary Guidance for those land uses which may have the potential to have a significant effect on landscape, for example wind energy or forest and woodland expansion
Q17 – Do you support the approach proposed to protect and enhance the landscape quality of Perth and Kinross? Please give reasons for your views

Key Issue 17 – Biodiversity
4.4.15.  The Scottish Biodiversity Strategy aims to halt the decline and where possible reverse losses in biodiversity. The threats to biodiversity come not only from development but also from the impacts of climate change which will increase over time. Many species and their habitats will need to be able to move if they are to survive and therefore need robust and well connected wildlife habitats. Further fragmentation of habitats will limit even more the ability of species to move and respond to the impacts of climate change.
It will be important to ensure that areas for development are not allocated on land that may be needed in the future to provide compensatory habitats for species affected by climate change for example along the Inner Firth of Tay.
4.4.16.  The local Biodiversity Action Plans already address many of these issues and identify clear targets and actions for priority species and habitats and these should be integrated into the Local Development Plan to ensure that, wherever possible, the same priorities are targeted. This is most appropriately done through the preparation of Supplementary Guidance. Whilst the implementation of many areas of the Biodiversity Action Plans are outwith the scope of the land use planning system, there are areas where it can contribute including:
• The protection of the most valued areas (from international to local designated sites) and green networks from disturbance by development
• The sensitive design of new development to minimise the impact on biodiversity and seeking opportunities to protect and enhance biodiversity interests through appropriate species selection in landscaping and in-built provision for biodiversity
• Where impact is unavoidable, provide for mitigation, either on or off site, to ensure a net biodiversity enhancement
• Identifying, promoting and encouraging the active management of the green belt and green networks
• The proactive management of Council controlled land to benefit biodiversity
4.4.17.  The Proposed Plan options could attempt to identify all sites of importance providing detailed policy guidance. The preferred approach is a simple all encompassing policy echoing the provisions of the Nature Conservation (Scotland) Act 2004 by seeking to protect and enhance biodiversity throughout the Plan Area. The Proposed Plan would identify only major designated sites and green corridors leaving the others to be protected by the general policy which would be expanded upon in Supplementary Guidance giving detailed advice on subjects such as:
• When an ecological survey is required
• Timing of development to minimise impact on wildlife
• Mitigation measures and enhancement opportunities
• Appropriate species choice
• Where to get advice
• Examples of best practice
Q18 – Is the approach being proposed to the protection and enhancement of biodiversity appropriate? If not, why not, and what alternative would you suggest?

Perth Green Belt
5.2.8.  The Perth and Kinross Structure Plan proposed that a green belt be identified around Perth to manage its growth and protect its landscape setting. This proposal is supported by the TAYPlan MIR which recommends that the Local Development Plan set the specific boundaries. Clearly, there is a strong relationship between identifying the extent of the green belt and the housing strategy, bearing in mind that the green belt needs to take a long term view and fix boundaries which should endure beyond the life of the Local Development Plan, potentially for a period of at least 30 years. Draft boundaries for the green belt were drawn up and consulted on as part of the Draft Perth Area Local Plan of 2004 and there was general support for the proposed extent of the green belt which is generally that indicated on Map 1, with some amendments made in the Berthapark area and land to the west of Perth to accommodate future major development and infrastructure. The preferred green belt boundary is shown below:

green_belt


Policy Framework for Green Belts
5.2.9.  Appropriate development for a green belt may include agriculture, woodland and forestry, market gardening and essential infrastructure. Reuse of existing buildings may also be appropriate. Green networks should extend from settlements into the green belt and opportunities to improve recreation, education and tourism should be considered. Green belt policy should be robust and as an example it is proposed to limit housing in the countryside to conversions or replacement buildings, excluding infill and brown field development categories. Any small settlements within the green belt will have settlement boundaries drawn to limit development opportunities.
Q24 – Do you agree with the preferred green belt boundary shown in Map 1 and the general approach to development within it?

Strategy Options for the Perth Area
5.2.10.  The Strategy of the Perth Area seeks to adopt a hierarchal approach to the identification of sites to meet the additional requirement:
• Sites within boundaries of Perth
• Strategic expansion areas adjacent to Perth
• Sites within or adjacent to the Core Area villages
• Smaller allocations in villages outwith the Core Area
5.2.11.  In the light of the need to make best use of agricultural land and the increasing trend towards higher densities there is also the potential to review the capacities of a range of current sites.
Q25 – Do you support the hierarchal approach to the identification of sites to meet the additional requirement? If not, why not and what other approach would you suggest?