The ST Andrews Environmental Protection Association Limited

The Association has been set up with the aim of protecting the environment of St Andrews and North East Fife.

New Park School Playing Fields

STEPAL response to Planning Permission in Principle application 15/02815/PPP

Dear Sir,

15/02815/PPP | Planning permission in principle for residential dwellings, open space and associated works | New Park School Playing Fields Priory Gardens, St Andrews Fife

STEPAL is an environmental organisation and our comments on this application are consequently focussed on environmental issues. It should not be assumed that matters we do not comment on are supported by STEPAL. We wish to object to this application on the following grounds:

  1. The former New Park School playing fields are designated Protected Open Space in the Adopted St Andrews and East Fife Local Plan. St Andrews has been assessed as having shortage of Green space/Open Space in the most recent audit of Green Space/Open Space published by Fife Council. There is therefore no justification for this protected open space being seen as a development opportunity.

  2. It is noted that there is a local policy requirement for Green Space, to be incorporated in all new development. For instance in local Plan site STAO 1, the requirement is for “generous open space, paths and habitat corridors”. It follows that it is important to retain open space in existing development particularly when it is used for informal recreational purposes and there is an assessed need for more recreation and amenity land. This land is valuable for recreational purposes and clearly enhances the amenity of this area, despite its neglect in recent years.

  3. The policy imperative to preserve or enhance existing Open Space/Green Space is clearly articulated in Local Plan policy C4. The concept of “usable (my emphasis) open space” in this policy is important. The area proposed by the developer to be retained as open space is a tree-covered significantly sloping river valley, which has amenity value, but does not meet this criterion.

  4. It is noted that Local Plan Policy E5 states that “a minimum, 0.6 hectares of usable (open space) will be required for every one hundred houses proposed on Greenfield sites. Smaller schemes will be assessed on a pro-rata basis”, and also states: “Policies C4 and C5 deal with established areas of open space and seek to prevent their loss”. The details provisions of Policies C4 and E5 are therefore important in determining this application.

    This scheme proposes to eliminate the usable open space presently available to local residents and users of the Core Path Network and leave no
    usable open space to serve the existing properties or those proposed to be built on this site.

  5. Provision is made for Adopted Local Plan site STAO1 to provide for a notional 1000 houses, a figure experience indicates is likely to be exceeded. Other sites such as ST Leonard's and Memorial Hospital site (STA 07) show densities greater than the indicative figures proposed in the local plan and Grange Road (STA 03 is assessed to provide an additional 50 houses with other “windfall” sites also being currently and prospectively developed for housing. The assessed housing requirement for St Andrews is therefore met or exceeded within the currently planned housing sites. It is noted that the Adopted Local Plan also states: “Beyond the 20 year Structure Plan period, development pressures will be directed away from St Andrews”.

  6. The approval of ad-hoc developments such as that proposed in this application increases the likelihood that planned sites, such as STA 01 would become unviable

  7. The land subject to this application has a history as a quarry which was subsequently used as a rifle range and more recently as a landfill site. It needs therefore to be regarded as unsuitable for building on because of the nature of the landfill is not known, although it is reputed to have been used as a general waste tip. Building on this site could potentially expose hazardous material.

  8. A house in neighbouring Newmills Gardens, which was built on another part of the same former quarry, collapsed in the 1980's as it was built on unstable land. PAN 33 and Local Plan Policy E6 are therefore relevant in the consideration of this application. It is not appropriate remit this issue to future site investigations and the disturbance of land-fill is to be avoided on environmental grounds.

  9. Local Plan Policy T1 Requires that all new developments require to have multiple vehicle accesses. The indicative layout of this development is contained within a cul de sac and would not meet the policy requirements of Scottish Government policy as outlined in “Designing Streets” and the Council's own document with the same title.

  10. It is important for the credibility of planning processes that the long term strategy and policies which have emerged as a result of public engagement with the local plan are not set aside as a result of the speculative ambitions of developers.

In summary, we conclude that there are no material considerations which would merit multiple planning policies being overturned in order grant approval of this application. It should therefore be refused.

We note that a representation to this application comments on missing information and responses from key agencies on statutory requirements applying to this scheme. We may therefore wish to submit further representations, when this additional information becomes available on the planning website.

Yours sincerely,

Sandra Thomson,
Secretary, STEPAL.



Dear Sirs,

Ref: PPA – 250 – 2270
Planning Permission in Principle for residential dwellings etc. at the former New Park School playing fields, Priory Gardens, St Andrews.

STEPAL, the St Andrews Environmental Protection Association Ltd., wishes to submit the following supplementary information in response to the above planning application appeal. This should be read in conjunction with the original objection submitted to Fife Council on 3rd September, 2015.

  1. This appeal should be considered in the context of its designation as Protected Open Space. This area is very important as an integral element of the green network serving the St Andrews built-up area. It should not be regarded as a development opportunity. The primacy of Adopted Local Plan designations should be a deciding factor in this appeal and no substantive or persuasive arguments have been produced to permit the Local Plan to be disregarded.

  2. The proposed site is an integral part of the Lade Braes Green Network which allows access from the South West of St Andrews to the town centre and beyond to the coast. As it is relatively flat, it has particular importance as it is an area where adjacent open space is steeply sloping terrain.

  3. The density of housing in the proposed development would be too great for the adjacent Lade Braes area and would not be appropriate compared with nearby older residential development.

  4. This application is opportunistic, rather than complying with or responding to the land use allocations of the adopted Local Plan which makes adequate provision for housing. It would undermine the viability of the proposed western development of the town and its supporting infrastructure. It is not a ‘windfall site’ as its designation as Protected Open Space is established in the adopted Local Plan.

  5. The unsuitability of this site is further emphasised by its previous uses as a quarry, a rifle range and a waste-fill site. Such land should be disturbed only if there is evidence of real need. There is no such justification in this case.

  6. Access to this land is limited and it does not meet Fife Council’s own policy requirements for new developments which should have multiple access. It would therefore be contrary to Fife Council’s Local Plan Policy T1, which is supported by the Transportation Appendix of the Council’s ‘Planning Places’ policy which in turn reflects the provisions of the Scottish Government Policy, ‘Planning Streets’.

    There are thus many areas where this proposed development fails to comply with local and national planning policies and there are no obvious material considerations which would overcome these serious shortcomings.

    Accordingly, STEPAL submits that this appeal should be refused.

    Yours sincerely,

    Sandra Thomson, Secretary, STEPAL.
    9 September 2016



Further Submission from the St Andrews Environmental Protection Society Ltd (STEPAL)

Reference: PPA-250-2270 Planning Permission Appeal - New Park School Playing Fields St Andrews, Fife

I am writing in relation to the further representation submitted by the applicant in relation to this appeal. Although it is not currently on the DPEA website I presume that the copy received by STEPAL is intended to provide an opportunity to comment on it.

I consider that additional contentious issues have been raised in this submission. Further, that submission has significant omissions. I wish to comment on these from an environmental perspective.

(1) Current Use of Protected Open Space.
The applicant states that this Protected Open Space is private land and is not a “publicly (sic) available resource”. This is incorrect. The “Right to Roam” provisions of Part 1 of the Land Reform (Scotland) Act 2003 apply to this land. There are no applicable exemptions which would curtail this legal right. The shortage of Open Space/Green Space in St Andrews has been established through Fife Council audits. This land is the only reasonably level accessible open land in the area. It currently provides a useful space for recreational use and a valuable environmental resource, which if developed will be lost forever.

It can be concluded that the land-use designation of this area in the development plan is not intended as a temporary measure until a development proposal comes along, but is intended to provide certainty for the foreseeable future.

(2) Open Space and Green Network Policy
PAN 65
Planning and Open Space includes relevant development management advice. TAYplan 2 includes a number of relevant policies, such as Policy 8 Green Networks. Those matters have not been addressed by the applicant. In addition, the urbanisation of this area would produce a discordant and atypical experience for users of the existing core path which is essentially a green corridor linking in with the valley of the Kinness Burn and open countryside beyond.

(3) Vehicular Access Difficulties
The limited access for vehicles to this site would result in a cul-de-sac development which would not meet the Scottish Government's or Fife Council's policies for multiple points of vehicle access for new development. There is no reason why these standards should be ignored in order to facilitate this development.

I would be grateful if the Reporter would give consideration to these issues.

Sandra Thomson


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