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