Response to Planning Application 16/01176/PP from Cunninghame Housing Association (CHA)

To: Mr James Miller, Head of Planning
cc: Mr Ross Middleton, Senior Planning Officer

Fairlie Community Council: Response to Planning Application 16/01176/PP from Cunninghame Housing Association (CHA)

Fairlie Community Council object to the planning application based on the following, after listening to the views of Fairlie residents:

Material Considerations:

  1. Proposed location is not in the North Ayrshire Local Development Plan 2014 (LDP):

The proposed plot is shown in the 2014 LDP as designated ‘countryside’, and thus the proposed development is contrary to Policy ENV2:Housing Development in the Countryside as it does not meet any of the criteria which would justify housing on the site.

The 2014 LDP “9.5. In terms of the natural environment, aims to: ·

  • Protect and enhance all areas of nature conservation value; ·
  • Support development in the countryside which has a specific locational need; ·
  • Increase recreational use of the coast and countryside; ·
  • Improve the perception, quality and range of recreational and tourism facilities in the area”.

FCC do not accept that this proposed development will achieve any of the LDP aims regarding ‘Natural Environment’ and specifically contradicts the four aims directly quoted above.

  1. Cunningham Housing Association’s argument that affordable homes are required in Fairlie:

The applicant has made no case that there is any specific locational need for housing of any type on this site, and has not demonstrated that there aren’t other sites within the Fairlie Village boundary on which affordable housing could be provided. FCC ask that Dawn Homes, who are currently finalising their detailed phase 2 planning application, should incorporate affordable housing in their plan should such a need be identified as an exception to the current LDP.

  1. Fairlie Village Infrastructure

Fairlie Primary School is also anticipating a considerable increase in demand from new residents on the Dawn Homes development, and current residents are concerned that there will be insufficient capacity for pre-school children already living in, or about to move to Fairlie. FCC ask that NAC consult their Education department regarding the projected demand and capacity of Fairlie Primary School.

Residents question whether the current sewage works will be able to service the increase in homes.

FCC question whether the lack of village facilities such as local GP, post office, village shop or public house, makes the development of any additional homes appropriate in Fairlie.

  1. Risk of Ribbon development.

FCC refer to a NAC precedent when a planning application was denied at the NAC’s ‘Local Review Body 20 January 2016’, ( Item 3. Notice of Review: N/15/00446/PP: Site to the North of Seaview Caravan Park, Ardrossan Road, Seamill, West Kilbride), because “the proposal would result in sporadic ribbon development and add to the coalescence with the built up area of Seamill, which would have an adverse visual impact on the character, appearance and amenity of this area of undeveloped coast.”

This would be exactly the case for Fairlie, adversely affecting the surrounding countryside, if this site were to go ahead.

The green space between Fairlie and Largs enables Fairlie to maintain it’s unique character and environment. Residents are concerned that any development in this space will ultimately lead to the loss of both, and lead to ‘ribbon development’ along the coast towards the north.

It is also clear from the ‘Proposed site plan and landscape plan’, that the development has been designed to enable further housing to be easily constructed in the adjacent field to the north of the site.

  1. Risk of increased flooding and detrimental environmental impacts.

This site is shown on the SEPA flood map as being at risk.

Fairlie residents are concerned that the increase in flooding and silt debris resulting from the nearby Dawn Homes development will be exacerbated by further housing.

NAC Planning have also indicated in their planning documents on the ‘SEPA checklist’ that “the planning authority is specifically seeking flood risk advice”. FCC request that a full assessment taking the impact of both the ‘Dawn Homes’ completed and proposed site, and this proposed development, is carried out as a matter of priority.

Re-direction of run-off water into local burns, including an increase in animal waste and farming by-products could have an adverse affect on the bio-diversity in the burns, natural coastal areas, and marine eco-systems.   FCC therefore ask how have potential adverse environmental impacts been assessed for this proposed development?

Other Issues regarding the application on which FCC request a response from NAC Planning:

  1. The limited consultation and timing of the planning application.

FCC and Fairlie residents were extremely disappointed with the lack of publicity and direct approach to potentially impacted homes in the vicinity.

FCC were given less than one week’s notice of the consultation event, so publicised the event on their website and the Fairlie facebook page. Despite this very short notice and few public notices, FCC directly observed that this event was well attended. FCC and residents are therefore surprised that there is no record of the feedback from Fairlie residents included in any of the planning application documents, as CHA expressed their commitment to listen to the Fairlie residents when the FCC Chair was notified of the event.

It is also noted that the planning application has been submitted just before Christmas. Is the applicant hoping that other priorities and holiday commitments may restrict interested parties, and individual residents from giving the application full attention in the time frame required?

  1. CHA and RDK’s attitude to the NAC LDP and planning process.

FCC note that CHA are claiming in their planning application that Lynne Richardson [LR], Development and Strategy Manager, North Ayrshire Council, was quoted in an email from Lynn Anderson of CHA to a RDK employee, as saying, “The one change was Fairlie where [LR], said Corporate did not want to include in the SHIP table at the moment because it’s contrary to the local plan. [LR] was at pains to assure me [Linda Anderson of CHA], that once the site had obtained Planning consent, they [LR], would take a special report to Cabinet to add into table 1 of the SHIP.”

This suggests that neither CHA, RDK or certain NAC officers respect the planning processes and believe that these can indeed be worked around.

  1. A78 Road Infrastructure and Congestion

The Dawn Homes Housing development with approximately 120 more homes has already commenced within ¼ mile of the CHA proposed site.

Residents have raised concerns regarding A78 congestion and road safety since the fatal accident in 2012. NAC have previously recognised these concerns and supported the development of alternative pedestrian routes and the introduction of speed sensitive road traffic lights to reduce the risk to residents.

FCC and residents do not believe that the A78 is currently safe, and that the risk to pedestrians will increase as the A78 becomes more congested.

The Fairlie Bowling Club Car Park already has inadequate capacity for its events, and it will be reduced if this development goes ahead, and indeed may be used by new residents as an ‘overflow or visitors’ car park. There is no additional parking available nearby and finding alternative parking adjacent to such a busy trunk road is clearly a risk to those concerned.

The 30 mph speed zone currently ends near the Bowling Club for northbound traffic; the start of a national speed limit presents an additional risk if the junction is regularly used. This also raises the question as to the appropriate location of the speed limit and village boundary should this development be approved against villagers’ wishes.

The coastal cycle path also restarts at the Bowling Club car park, putting cyclists at additional risk.

FCC objects to this development but requests that should this objection be ignored CHA/RDK provide a pedestrian bridge or similar road safety provision, particularly as Fairlie Primary School and play areas are on the opposite side of the A78.

FCC request that Transport Scotland complete a full impact assessment of this planning application, considering the already increased risks and congestion that the new Dawn Homes development will also bring.

  1. Housing Design

Residents have also raised concerns that the proposed homes’ designs are not conducive to a rural/coastal village.

For, and on behalf of Fairlie Community Council
Karla Tully: FCC Secretary 21/12/2016