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?