The following letter was sent by Mike Barnacle on 31 March 2015 in relation to the Main Issues Report
Dear Colleagues
Review of Local Development Plan (LDP) – Main Issues Report
I circulated the Kinross-shire Ward Community Councils and fellow elected members on 12/2/15 regarding your call for issues for the above and have since attended a number of meetings to discuss same.
I would like to particularly commend the submissions of Fossoway and Portmoak Community Councils and the Kinross-shire Civic Trust, copied to me, which I find much agreement with. I now outline my thoughts on issues I would like you to consider for the review of our LDP, viz:-
TRANSPORT ISSUES
I refer to my letter of 16/3/15 to Jim Valentine on the need for ‘major’ mitigation measures for the A977 reinforced by Paragraph 7.1.18 of our current LDP. On 26/2/15 elected members met with Paul Tetlaw from Transform Scotland regarding the restoration of a rail link through Kinross-shire and an aspiration that Perth should be a new inter-city rail hub; I have their Inter-City Express campaign literature to support this.
The use of certain roads within Kinross-shire by HGV’s and repeated requests for directional signage of suitable routes and speed control measures remain an issue. There is a distinct lack of areas zoned for parking in settlements; this should be looked at particularly in Crook of Devon, Kinnesswood, Kinross and Scotlandwell.
POLICIES AND SUPPLEMENTARY GUIDANCE
On the 23/3/15 I emailed Committee colleagues regarding Landscape Guidance expressing my strong disagreement to the loss of 2 former AGLV areas, namely the Cleish Hills and the River Devon and its gorge, from securing Local Landscape designation. I am highly critical of the consultants’ exercise on this, in ignoring the strong representations made within the Review Panel and I would like the Planning Department to reconsider their stance on this matter, being particularly aggrieved that you emphasised delay at Committee if amendments were made when it has taken PKC 5 years to address this matter, so ask if you would agree to look again at these areas, as requested by local members at their meeting on 26/3/15.
In a letter to Nick Brian of 18/1/12 I called for a halt to any further large scale windfarm developments in the Ochil Hills and reiterate this, given developments since; it is now urgent that a spatial framework for wind energy developments is completed, noted by me in April 2012 and still awaited.
We should be seeking greater protection for prime agricultural land, in accordance with national planning policy, whilst promoting more development at appropriate brownfield sites. Policy PM4 failed to protect a former village setting area from development at Keltybridge and I feel it should be reinforced, whilst allowing for exceptions on grounds of community benefit. Could you explain why the concept of village setting was dropped from our current LDP?
I would like to see a review of our open-door policy RD5 on gypsy/traveller sites, which are a particular problem in Kinross-shire. Mostly retrospective in their development, it is clear that the ‘protocol’ between SEPA, SNH and PKC adopted in October 2014 is not effective in dealing with these. It is essential that drainage arrangements are authorised before planning applications are approved and I submit that this policy should not apply in the Lochleven Catchment Area which would by default enhance protection of the Loch under Policy EP7. My email to Committee colleagues of 14/3/15 relating to the considerable number of breaches of conditions at the Crook Moss site is very relevant, particularly on drainage, with planning to bring back a Report to Committee within 6 months but noting the applicants have been on site within the catchment since March 2012 and no drainage or water supply conditions have been met, which I find completely unacceptable; if no progress is made during this period then revocation of permission has to be a serious option.
I would like to see the Crook Moss and the Perth Lade considered for declaration as SSSI’s.
I am aware of reluctance to propose new conservation areas but reiterate previous calls for Back Crook, Keltybridge/Maryburgh and Milnathort to be considered and consulted on.
Policy EP13 covers Airfield Safeguarding, which I had called for; however, I have noted some recent planning decisions around Portmoak that concern me and seek some re-assurance that the gliding facility there will not be compromised given its huge importance to the area.
SETTLEMENT PLANNING AND BOUNDARIES
This review is a good opportunity to examine Employment, Housing and Opportunity Sites allocated in our current LDP and make sure they are deliverable.
It is particularly relevant to Employment zoning because I have always been against development west of the M90, whilst existing sites remained underdeveloped. There is also a further opportunity to clarify the retention and status of Turfhills Environment/Roads Depot. An employment site for Crook for Devon should be considered.
I would like the work of the Fossoway Community Strategy Group acknowledged in Paragraph 7.1.12 of our current LDP to be built on and perhaps the finalised maps for Blairingone, Crook of Devon, Powmill and Rumbling Bridge produced by that Group could be looked at again alongside the current settlement plans in our LDP, perhaps involving Fossoway Community Council and Kinross-shire Civic Trust in further meetings with yourselves, elected members and the wider public. This is relevant when one considers paragraph 7.1.18 on A977 mitigation referred to earlier and possible proposals coming forward for housing that may assist in delivering same at Blairingone, Crook of Devon and Powmill. I would not, however, support re-consideration of the Naemoor Road site in Crook of Devon that I asked to be dropped from our LDP in October 2011; its exclusion vindicating the long campaign by the community over many years opposed to this development.
Nine of the 12 settlements that had their boundaries removed in Kinross-shire are located within the Lochleven Catchment Area and I would like consideration of their re-instatement. Carnbo has seen considerable development recently but has no services, so I strongly suggest the provision of mains drainage should be an aspiration, with the apparently permanent builders’ yard to the west of the village boundary returned to agricultural usage.
Drum needs a local ditch and watercourse management scheme in the absence of a flood prevention scheme, given its very high water table (Policy EP3D should apply?) The capacity of the current WWTP at Drum should be considered for expansion, given current development constraints.
Can the Greenacres gypsy/traveller site boundary in our current LDP be enclosed to prevent further retrospective expansion beyond it, perhaps with adequate landscaping and tree screening as suggested in Policy RD5B(b)?
Finally, in the Portmoak area, I would support the inclusion of Stephen’s Field into the Kinnesswood boundary and the linkage of Kilmagadwood and Scotlandwell into one settlement boundary with consideration of ensuring that H54 should be single storey housing possibly extended eastwards to achieve same, whilst ensuring an open space corridor between Leslie Road and the southern settlement boundary.
I have resisted detailed comment on the Kinross/Milnathort settlement boundary, although maintaining site H46 and the Market Park site as open space/community woodland are important to the community.
CONCLUSION
As you will appreciate most of my comments relate to the Kinross-shire Ward I represent but I hope you will find them helpful as a basis for further consultation on the Main Issues Report.
Yours sincerely
Cllr Michael Barnacle
Independent Member for Kinross-shire
ps Please let me know if you require clarity on any points or any background correspondence referred to.
cc Kinross-shire Ward Community Councils
Kinross-shire Civic Trust
Councillor Dave Cuthbert
Councillor Joe Giacopazzi
Councillor Willie Robertson