Statement by Penny Uprichard on behalf of herself and Jennifer Hopgood

The planning report for this hearing confirms that the proposal is 'significantly contrary to the Development Plan' - the TAYplan and the St Andrews and East Fife Local Plan. It is contrary to the Reporters' decision on the 2012 Local Plan. It is also contrary to the Fifeplan, the forthcoming single 'local' Plan, which says in the Strategic Environmental Assessment 'this site is not supported'.

The planning report confirms that applications have to be determined in accordance with the Development Plan unless material considerations indicate otherwise. Para. 2.3.5 of the planning report lists four documents which are ‘material considerations’, including the St
Andrews Strategic Study. None of them support the Pipeland Farm application, which would have a detrimental impact on St Andrews and its landscape setting.

Scottish Planning Policy 2010 - this Policy, published two and a half years before Adoption of the Local Plan, is an amalgamation of previous policies; it is national, and not site specific. It would be expected that local Plans would follow its general principles, and add details relevant to their own areas, which would then become statutory policies. SPP says on Green Belts:

‘. . . Scottish Planning Policy is a material consideration and it is national policy that development in the green belt may still be considered appropriate either as a national priority or to meet an established need if no other suitable site is available.’

We do not believe this sentence can be used to support the Pipeland Farm proposal. The Reporters would have taken S.P.P. into account when examining the Local Plan, but concluded that ‘development in this location would be detrimental to the landscape setting of the town’ and that ‘it should remain as part of the Green Belt’. There are three St Andrews areas which are in Green Belt but excluded from the constraints of Green Belt. Pipeland Farm is not one of them.

This application is not ‘a national priority’, nor is it to ‘meet an established need if no other suitable site is available’. In a Briefing Note of September 2012 from Mr. Alan Paul to Councillor Rowley, Mr. Paul says (in connection with the possibility of land purchase by a Compulsory Purchase Order) that because ‘the Council already owns a viable alternative option for the location of the school which has planning consent for educational purposes’, ‘if the Council made a CPO and objections were received, it is likely the Council would lose any enquiry to consider such objections’. So Mr. Paul formally advised Councillor Rowley that there IS a ‘viable alternative option’,
although not one favoured by the current administration.

A new school is badly needed. There is also a pressing need for affordable housing in St Andrews, and for employment land. If a school were to be approved at Pipeland Farm, there would be further applications for housing and other ‘needs’. If statutory policies are overridden once, they can be overridden again. If Councillors were to approve this proposal, could they defend Green Belt against other applications?

Pipeland Farm is in Green Belt and Countryside, and on Prime Agricultural Land, and there are statutory policies in the Local Plan on these three subjects. None of them support a school. In the case of Countryside, there is no clause permitting development like the one above from the Green Belt paragraphs of S.P.P.

In a recent decision on an appeal in St. Andrews, a Reporter said:
'The Council have made reference to Scottish Planning Policy (2010) and Scottish Historic Environment Policy (2009). These government policies are not part of the development plan. The local plan has only recently been adopted and takes into account these aspects of national planning policy.'

Fife Council has a duty to uphold the Local Plan and its statutory policies. It is therefore surprising that when the Plan was Adopted in October 2012, administration Councillors had already decided to propose Pipeland Farm as a site for the new school.

Green Belt – Community Council, Preservation Trust and many residents have campaigned for nearly 20 years for a Green Belt for the town, to maintain its landscape setting and to protect it against excessive profit-led development. We now have a Green Belt policy – not the one we wanted, because it encircles the town AND the proposed western extension – but it still represents the last chance we have of preventing the town being swamped by development.

It is difficult to understand the justification for proposing this site, with its potential planning, traffic, flooding and cost problems.

The importance of retaining the southern hillside had already been established when the hospital was built, some years before the Green Belt was approved It is a two-storey building, whereas the school would have four levels, and its existence does not set a precedent for building on the southern hillside. Its site was shown in the 1996 Local Plan; the Plan said that ‘The assessment of development beyond that catered for in the Local Plan will form part of the Council’s Strategic Study’, which was published in 1998.

Tyldesley’s Landscape Assessment Study was carried out on behalf of SNH and Fife Regional Council as technical input into the Strategic Study. It stated that there was a clear case for the designation of a Green Belt around the town, ‘one of the most historic towns in Scotland and one with a particularly distinctive appearance and relationship with its surrounding landscape’. It was also intended ‘to maintain the unique identity of St Andrews including its landscape setting’.


The Alison Grant Landscape Capacity Assessment and Proposed Green Belt Study of St. Andrews – this Study was a requirement of the 2002 Structure Plan. It was commissioned by Fife Council and published in 2003. Unlike recent Scoping Opinions, it was not related to any prospective development; it is a detailed document which concluded there was no scope for major development round St Andrews. The Study is still the most recent landscape capacity assessment for the town. It was and is a material consideration for the 2012 Local Plan and for this application.

As part of the southern hillside, Pipeland Farm is designated in Alison Grant’s Study as Category 5, where ‘development is inappropriate because of its potential impact on the landscape character, scenic quality or visual attributes of St. Andrews and its setting’. This is a Fife Council document, and it has been quoted by officials against development in other areas of St Andrews.

The landscape setting of St Andrews
– St Andrews has been said by Historic Scotland to be ‘the most important small historic burgh in Scotland’. The town and its landscape setting are nationally and internationally renowned, and are important factors in attracting over 650,000 visitors annually and contributing to Scotland’s main industry, tourism. Many developers and supporters of individual proposals have dismissed the importance of this setting – the green bowl in which the town sits. However, when refusing an appeal about a hotel in Green Belt in 2010 a Scottish Government Reporter said:

‘. . . my decision rests on one principal issue – the protection of the setting of the town is of vital importance to its future as a medieval borough of international renown. This protection is now being confirmed by the establishment. . . of the green belt, long considered essential for the protection of the town’s setting.

Now that St Andrews has an established Green Belt, it should be regarded as non-developable land, apart from the exceptions in the policy (horticulture, agriculture, forestry, etc.). Presumably when Councillors approved the Green Belt policy they considered it was robust enough to protect the town against inappropriate development. Development in Green Belt should be refused unless it complies with the requirement to direct planned growth, and at the same time to protect the landscape and character of St Andrews.

General – the applicant is the Education Service of Fife Council, which is applying for planning permission to the Council as local authority. By putting forward a single option on this site for what would be one of the largest buildings in St Andrews, the Council has created a divisive and very difficult situation.

J. A. Hopgood
P. M. Uprichard

We attach as an appendix a page from the FIFEplan Strategic Environmental Assessment, which says that 'this site is not supported'
.


APPENDIX

FIFEplan Site Assessments

Candidate Site Reference LDP-STA002
Proposed use of site
- Housing; Mixed Use Development; Leisure/Community
Site Name and Location
- Pipelands Farm, St Andrews
Area of site (Ha)
- 29.4
Indicative number of houses (if known) - Not Submitted
Officer Assessment
- Site not supported

Conclusion
This proposal for mixed used development is considered not to comply with the FIFEplan strategy due to the scale of existing allocations, and location within the recently established green belt. Proposals for mixed use development at the southern hillside of St Andrews were considered through the local plan examination. The reporter concluded that development would be detrimental to the landscape setting of St Andrews, that it should not be allocated for development and that the site should instead be part of the St Andrews Green Belt.
Proposal not supported.

FIFEplan strategy
Proposed extension to Tier 2 settlement of St Andrews. Within the green belt for St Andrews which has recently been established and sets a long-term strategy for the growth of the town. FIFEplan and TAYplan provide continued support for the St Andrews West Strategic Development Area which provides for the long-term growth of the town.

Local Plan Examination comments
Proposals for the southern hillside of St Andrews were considered through the SAEFLP examination report. The reporter concluded that development would be detrimental to the landscape setting of St Andrews, that it should not be allocated for development and that the site should instead be part of the St Andrews Green Belt.

Summary of Main Issues Report Comments
Objections to development in recently approved greenbelt (185, 474, 1125, 1629, 1655, 1691) Prime agricultural land outside settlement boundary (1691) Conflict with landscape studies/assessments undertaken (1691). General comment that fabric and landscape setting of town at threat - conservation should be the priority (1286) Significant development already proposed in St Andrews - further brownfield land likely to come forward. Concern over road network capacity (1763) In north-east Fife
development should be focused in Tayport/Newport/Wormit (1763).

Transport Assessment Summary
Two vehicular access locations are shown but are
relatively close together in relation to the size of the actual site and would not provide acceptable connectivity to the existing adjacent built up area. Design of proposed access to the south on Largo Road
would be difficult due to the gradient of the existing
road. A Transport Assessment would be required. Housing would not be supported

FIFEplan SEA Version 2 - Nov 2013