Inverclyde Local Development Plan: letter on proposed plan and draft supplementary guidance

Dear Alan,

Inverclyde Council – Inverclyde Local Development Plan – Proposed Plan and 5 X Draft Supplementary Guidance (Affordable Housing in the Inverclyde Villages, Enabling Development, Energy, Planning Application Advice Notes and Priority Places)

I refer to your correspondence dated 18th May, 2021, inviting comments on the above documents. Please see below representations from the Scottish Government.

Proposed Plan

Proposed Plan - Page 42 - Policy 31 - Scheduled Monuments and Archaeological Sites

Proposed Change: Insert the following after first paragraph “Any works directly affecting a designated Scheduled Monument requires Scheduled Monument Consent (SMC) which is obtained from Historic Environment Scotland. Advice on the SMC process and requirements should be sought at an early stage.

Reason: To align with paragraph 145 of Scottish Planning Policy (SPP) as Historic Environment Scotland are the consenting authority for direct works affecting Scheduled Monuments. When considering development affecting scheduled monuments, it should be made explicit that there is a separate Scheduled Monument Consent process for any direct works to a scheduled monument which is sought from Historic Environment Scotland.

Proposed Plan – Spatial Development Strategy – Land allocated to meet the HLR

Proposed Change: the plan should demonstrate that a sufficient range of sites have been allocated to meet the housing land requirement of the SDP up to year 10 from the expected year of adoption.

Reason: to meet the requirements of paragraph 119 of SPP which states that LDPs in city regions should allocate a range of sites which are effective or expected to become effective in the plan period to meet the housing land requirement of the SDP up to year 10 from the expected year of adoption.

Proposed Plan – Spatial Development Strategy: – Specialist Housing

Proposed Change: It is welcome to see the plan introduce Policy 21 – Wheelchair Accessible Housing. However, the plan would benefit from clarifying what other need, if any, was identified as part of the HNDA and what the plan intends to do to support the delivery of other specialist housing, if a need was identified.

Reason: to meet the requirements of paragraph 132 of SPP which states ‘as part of the HNDA, local authorities are required to consider the need for specialist provision that covers accessible and adapted housing, wheelchair housing and supported accommodation, including care homes and sheltered housing. This supports independent living for elderly people and those with a disability. Where a need is identified, planning authorities should prepare policies to support the delivery of appropriate housing and consider allocating specific sites’.

Proposed Plan – Spatial Development Strategy – Gypsy/Travellers and Travelling Showpeople

Proposed Change: The plan should confirm whether there is a need for sites to be allocated for Gypsy/Travellers and Travelling Showpeople.

Reason: to meet the requirement of paragraph 133 of SPP that states local development plans should identify suitable sites for these communities if there is a need. It is unclear from the plan whether this need has been considered.

Proposed Plan – Policy 37 – Delivering Green Infrastructure Through New Development

Proposed Change: The policy should be amended to include the following wording:

‘In addition to SuDS, proposals may be requested to demonstrate how green infrastructure is supporting resilience of the development to risks from climate change.’

Reason: Paragraph 19 of SPP encourages uptake of adaptation opportunities. Although paragraph 11.22 references a range of benefits from green infrastructure which are in fact potential climate change risk adaptation measures, these don’t get referenced in Policy 37 and the presentation of 6 aspects to be addressed suggests that the policy may not provide flexibility needed to seek further green infrastructure based adaptations in the future if needed.

Proposed Plan – Page 12 – Policy 8 – Climate Change Adaptation

Proposed Change: The policy should be amended as follows:

‘Where required by planning guidance, Major Developments are to be accompanied by a Climate Risk and Vulnerability Assessment, the results of which are to be reflected in the design of the development.’

Reason:  Paragraph 19 of SPP encourages uptake of adaptation opportunities. Although Policy 8 positively generates consideration of risk assessment it should also be clear that the subsequent design should respond to that assessment.

Draft Supplementary Guidance

Draft Supplementary Guidance - Priority Places

Comment: Under the heading ‘Former Inverkip Power Station’, it refers to the A73 trunk road. This should be the A78 trunk road

Comment: There is reference to flood vulnerability and slope instability within the draft Supplementary Guidance. It would be helpful if such matters could be clearly identified as risks from climate change, and dealing with them, being actions of climate resilience or adaptation, to encourage uptake of appropriate actions and responses.

Comment: The Proposed LDP has clear policy on climate adaptation and the robustness of the guidance would be enhanced with clear connection to that policy approach, meaning that the guidance should include prompts requesting Climate Risk and Vulnerability assessments for major developments. Given the significance of the places identified in the guidance and their delivery over the longer term, it may be helpful to consider specifically requesting Climate Risk and Vulnerability Assessments to accompany masterplanning approaches for the sites.

Draft Supplementary Guidance - Energy

Comment: Policy 5 – relevant proposals should take account of heat network zones as set out in the Heat Networks (Scotland) Act, when they become available.

Policy 6 – relevant proposals should take account of heat network zones as set out in the Heat Networks (Scotland) Act, and Local Heat and Energy Efficiency Strategies as defined in the draft Heat in Buildings Strategy, when they become available.

Draft Supplementary Guidance - Affordable Housing in the Inverclyde Villages

Comment: Page 4, Table 1, the second column should read ‘Housing Supply Targets’ instead of ‘Housing Land Supply Targets’.

Paragraph 3.2 on page 5 makes reference to ‘More Homes Scotland Funding Programme’, this should be changed to ‘More Homes Scotland approach’.

Comment: At paragraph 5.4 on page 11 - the wording that indicates that legal agreements will be prepared at the developers’ expense should be removed. There are no provisions in current regulations for the payment of charges relating to the drafting or conclusion of legal agreements under section 75 of the Town and Country Planning (Scotland) Act 1997. It is not considered appropriate that the supplementary guidance should refer to the potential payment of such charges.

Yours sincerely,

Allen Hughes,

Planning & Architecture Division

Inverclyde Local Development Plan: letter on proposed plan and draft supplementary guidance

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