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Departure Hearing Report

East Area Development Committee, 5 February 2004, Boarhills Village Hall

APPLICATION FOR PLANNING PERMISSION REF: 03/03141/EEIA

SITE ADDRESS: Site At Brownhills Farm/ Kinkell Farm St Andrews

PROPOSAL: Formation of 18 hole golf course and practice area, erect clubhouse, maintenance facilities, form access driveways and cycleway/footpath, associated parking/servicing areas

APPLICANT: The St Andrews Links Trust Pilmour House St Andrews Fife

CONSULTATIONS

Transportation Services - Comments
Archaeology - No objections
Health and Safety Executive - No comments
Scottish Environment Protection AgencyScottish Executive Development Dept - No comments
Scottish WaterWater and drainage - comments
Historic Scotland - EIA should take full account of the potential impact of proposed development on the milestones
St Andrews Preservation Trust - No objection
Royal Burgh of St Andrews CC - Objection: policy, road safety, design, premature to Green Belt, argument for additional course not sufficiently persuasive
Boarhills and Dunino Community Council - Support: demand has been demonstrated, would not significantly alter landscape, opportunities for walkers improved
Sportscotland (formerly Sports Council) - No response
Royal Fine Art Commission For Scotland - No response
Scottish Rights of Way + Access Soc - No objection
Scottish Natural Heritage - Objection but conditions
St Andrews Merchants Association - No response
Scottish Executive Rural Affairs Dept - No objections
Kingdom of Fife Tourist Board - Comments: would like to call for an independent economic impact assessment to be carried out before any planning consent is granted
Assoc for Protection of Rural Scotland - No response
Architectural Heritage Scty of Scotland - Objection: not required, separate to existing courses, unacceptable location which would set a precedent
St Andrews Green Belt Forum - No objection

REPRESENTATIONS

A total of 22 representations have been lodged to the application, of these 17 were objections citing the following issues.

- contrary to Development Plan
- not sufficient demand for development
- unacceptable visual impact
- detrimental impact on Area of Great Landscape Value
- development of a prominent site
- inappropriate site for proposals
- surface water concerns
- traffic generation
- access unsuitable for additional traffic
- footway required
- inadequate visibility
- problem will be caused by construction traffic
- economic impact on St Andrews and other golf courses
- danger to walkers from golf balls
- cumulative impact on coast
- premature to Green Belt
- development in Green Belt
- doubts over visibility of proposals
- light pollution
- impact on SSSI
- consider increasing capacity of existing courses
- proximity of Waste Water Treatment Works

The one letter of support has been received from Boarhills and Dunino Community Council raising the issues described in the consultation section.

The 3 other letters of representation commented on the following:

- habitat for rare species including grey partridges
- opportunity to extend cycleway further
- provide additional public car park
- additional tree planting required
- incorporation of rural style footpath

STATUTORY POLICIES AND APPROVED GUIDANCE

National Guidance SPP1 The Planning System
NPPG11 Sport Physical Recreation and Open Space
NPPG14 Natural Heritage
NPPG15 Rural Development
NPPG17 Transport and Planning
NPPG18 Planning and Historic Environment
PAN43 Golf Courses and Associated Developments
PAN57 Transportation & Planning
PAN58 Environmental Impact Assessment
PAN60 Planning for Natural Heritage

Memorandum of Guidance on Listed Buildings and Conservation Areas Fife Structure Plan 2002

SP1 Sustainability
SS1 Settlement Development Strategy
SS8 Green Belt for St Andrews and Dunfermline
T1 Transport and Development
T4 Developer Requirements
E2 New Employment Opportunities
E4 Rural Businesses
E6 Visitor Development
E7 Protecting the Tourist Industry
C4 Golf Courses
N1 Quality of Development in the Countryside
N2 Prime Agricultural Land
N6 Development of the Unbuilt Coast

St Andrews Area Local Plan 1996

E1 Environmental Impact
E5 Listed Buildings
E11 Access to the Countryside
E13 Development in the Countryside
E14 Redundant Buildings in Rural Areas
E15 New Buildings in the Countryside
E16 Areas of Great Landscape Value
E19 Nature Conservation E21 Development on the Unbuilt Coast
E20 Leisure Activities in the Countryside
ED6 Tourism
ED9 Prime Agricultural Land
ED10 Agricultural diversification
I5 Car parking
I7 Rights of Way
I11 Leisure and Recreation
S1 Skyline

Other Guidance

St Andrews Strategic Study 1998
St Andrews Tourism Strategy1998
Fife Tourism Strategy
Landscape Character Assessment Studies 1996
St Andrews Transportation Plan Planning
Guidelines for Golf Courses & Associated Development 1999
The Environmental Impact Assessment (Scotland) Regulations 1999

PLANNING SUMMARY

1.0 Background

1.1 The application was advertised as a potential departure from the development plan with regards to policies covering development in the countryside, an Area of Great Landscape Value, development on the unbuilt coast, golf courses and settlement development strategy. It was also advertised as a bad neighbour development and as an application subject to an Environmental Impact Assessment.

1.2 Prior to the submission of the current application, the applicants undertook preliminary discussion with Development Services. This was primarily though the procedures set down in the Environmental Impact Assessment Regulations to establish firstly that an EIA submission would be required and secondly to undertake a scoping exercise to agree the areas which should be covered by an EIA. The application when submitted was accompanied by an EIA.

1.3 The application site lies to the east of St Andrews and extends to an area of 90ha. The settlement of Brownhills abuts the site at the south-west edge. It is bounded by the A917 to the south and the coastline, and the Fife Coastal Footpath to the north. To the west lies Kinkell Braes caravan site whilst to the east is Kinkell House which has recently obtained planning consent for a 4 x 4 off-road vehicle facility.

1.4 The proposals and practice area involve the formation of an 18-hole golf course, erection of a clubhouse and maintenance facilities together with associated access driveways, cycleway/footpath and parking and manoeuvring areas. Vehicular access to the site would be of a single access off the A917 utilising the existing access to the St Andrews Waste Water Treatment Works (WWTW). To the north side of the site, abutting the St Andrews to Craig Hartle SSSI, lies the WWTW and the application site would bound this on 3 sides.

1.5 The clubhouse would be positioned towards the north-east corner of the site, where the site levels fall to their lowest point. The maintenance buildings would be adjacent to the east side of the WWTW. The practice area would lie between the clubhouse and maintenance buildings. A footway/cylceway would be formed linking the clubhouse with the existing footway at Brownhills to the south-west of the site and this facility would also extend to the full width of the site. Existing rights of way through the site are proposed for either retention or diversion.

1.6 The clubhouse would be developed in the form of a circular single storey building with a height of 5.3m and diameter of 37m. The facilities included would consist of changing and storage together with associated restaurant and golf shop. The maintenance buildings would enclose a service yard area and be single storey. The design of which would incorporate mono-pitched roofs with a maximum height of 5.6m.

1.7 The site is currently in agricultural use being Grade 2 and 3 arable land, although there are no agricultural buildings on the site. The topography is that of generally level ground to the south-west but this then slopes away more markedly and progressively towards the coastline.

1.8 The proposed golf course would be operated by the St Andrews Links Trust and would become the seventh course, joining the existing complex of links courses situated at the West Sands, St Andrews. The proposals would therefore be fully integrated with the existing operation. However, due to the distance of the proposed course from the West Sands, the proposals incorporate a clubhouse and maintenance building solely to serve this development.

1.9 By forming part of the range of golf courses and facilities operated by the St Andrews Links Trust, the proposed course would also be subject to the same terms of operation as the existing links courses, which are set down by Act of Parliament.

1.10 The application site lies fully within an Area of Great Landscape Value (AGLV).

2.0 Policy Issues

2.1 As this report is for a departure hearing, it is only appropriate at this stage to list the relevant planning issues that affect the determination of this application. An assessment of the application against these issues and a recommendation will be included in a subsequent report to this Committee when it meets to determine the application. The determining issues for Committee to consider in this instance are as follows:

- a) Whether the development conforms to the provision of the Development Plan and are there any material considerations which justify a departure from the Plan. The material considerations are:
b) National Policy Guidance
c) Development Plan
d) Landscape and Visual Impact
e) Green Belt
f) Nature conservation
g) Transportation
h) Economic and Tourism Impact
i) Other consultation comments
j) Representations

National Policy Guidance

2.2 Government policy and guidance seeks to support appropriate and well designed tourist and leisure related development in rural areas subject to specific performance criteria being achieved particularly in terms of sustainability and positive impact on the natural environment and built heritage. In particular SPP1 seeks to promote the use of previously developed land and better access by foot, cycle, and public transport. The guidelines also stress that planning decisions should favour the most sustainable option, promoting development that safeguards and enhances the long-term needs of the economy, society and the environment. The guidelines also state that conditions imposed on a grant of planning permission can enable development proposals to proceed where it would otherwise have been necessary to refuse planning permission.

2.3 NPPG11 recognises that recreation has a role to play in green belts but there is a general presumption against inappropriate development. However, outdoor sport and recreation may suit the purpose of a particular area of green belt and unobtrusive buildings or suitable conversions may be suitable. Such developments may improve wildlife habitats and the landscape.

2.4 NPPG14 gives guidelines on how the Government's policies for the conservation and enhancement of Scotland's natural heritage should be reflected in land use planning. The Guidelines state that planning authorities should have full regard to natural heritage considerations in determining individual applications.

2.5 NPPG15 sets out how the planning system can assist rural areas in achieving sustainable development. Tourism related developments can help support the rural economy but need to respect local character and landscape.

2.6 NPPG17 provides guidance and advice on the relationship between transport, planning and the environment whilst aiming to improve the transportation infrastructure and create sustainable transport choices and patterns of development.

2.7 NPPG18 requires development to be of a high standard and take account of landscape setting, access arrangements, local design characteristics and historic character of adjacent buildings and the surrounding area.

2.8 PAN43 recognises that golf courses using existing buildings or with no associated development other than clubhouse and storage facilities are likely to cause the least impact. Where a golf course is combined with other commercial facilities, the importance of the golf course amongst the other elements is a material consideration.

2.9 PAN57 highlights Transport Assessments and the resultant local transport impacts, the potential for developer contributions and the role of green travel plans.

2.10 PAN58 sets down the requirements for environmental statements in terms of when they will be required and what information is necessary. The information contained may be material but the application should still be determined in accordance with the development plan unless material considerations indicate otherwise.

2.11 PAN60 highlights the requirement to maintain and enhance landscape character, provide for a diversity of wildlife habitats, provide for a wide range of outdoor recreational activities and foster opportunities for learning about the environment.

Development Plan

2.12 Development Plan policy reinforces national policy and guidance.

Structure Plan

2.13 Policy SP1 requires the environmental implications of a proposal to be clear whilst Policy SS1 requires development to take place within a settlement unless it can demonstrate an essential need for a rural location. Under Policy SS8 development proposals likely to prejudice the process of identifying the green belt boundaries will be considered premature.

2.14 Policy T1 supports proposals where they are accessible to the existing public transport network, located where a road network capacity is available, and that they would not create or exacerbate a road safety problem, whilst T4 relates to Transport Assessments and Travel Plans.

2.15 Policy E2 supports business and tourism proposals subject to supporting the rural economy, on brownfield or contaminated land or reusing buildings and not prejudicing the Structure Plan strategy. Policy E4 of the Structure Plan sets out criteria for assessing rural business proposals. These include consideration of whether the proposals reuse brownfield land, and also the appropriateness of the development to the scale and character of the area. Policy E6 sets out criteria for the consideration of visitor development and Policy E7 presumes against development, which will have a significant adverse effect on Fife's tourist industry.

2.16 Policy C4 sets down the circumstances under which golf courses will be supported being, to meet an identified unmet demand which cannot be met on an existing course and constructed substantially on brownfield land. New player/visitor facilities are supported, of an appropriate scale.

2.17 Policy N6 requires development to demonstrate that it requires a coastal location.

Local Plan

2.18 Policy E1 of the St Andrews Area Local Plan indicates that proposals that would have a harmful environmental impact will not be supported, and that Environmental Statements will be required where necessary. Policy E5 protects the character and setting of listed buildings.

2.19 Policy E11 indicates that access to the countryside will be encouraged where it does not damage environmental resources. Policy E13 sets out circumstances in which developments in the countryside may be supported. These include uses that must have a countryside setting.

2.20 Policy E14 encourages the reuse of redundant buildings in the countryside, Policy E15 requires a particular justification for development in the countryside, and under Policy E16, within AGLVs the retention and enhancement of existing high quality in the landscape is required.

2.21 Policy E19 supports proposals which give new opportunities for nature conservation and Policy E20 encourages outdoor leisure activities.

2.22 The approach to development on the unbuilt coast under Policy E21 is that it should be protected and conserved as an important recreational and amenity resource. Development should be opposed where it would reduce public access from within or adjacent to existing urban areas.

2.23 Under Policy ED6 proposals which improve the quality and range of tourist facilities, attractions and accommodations are supported. Policy ED9 seeks to protect prime agricultural land, although ED10 supports agricultural diversification.

2.24 Unprogrammed and excessive infrastructure expenditure by the Local Authority is not supported (Policy I1) and Policy I7 aims to keep open rights of way. Policy I11 seeks to expand opportunities for outdoor recreation.

2.25 Policy S1 relates to the medieval skyline of St Andrews and the need to avoid adverse effects on this.

Landscape and Visual Impact

2.26 Much of the site is fully open to view from the A917, however, beyond this relatively level area the site falls away in level down to the north and north-east and the coastal boundary. The site is bounded by a stone wall to the A917 and is prominent in approaches both from the east and the west. The landscape of the site is one of open agriculture in character. The proposals involve extensive modification of the topography in order to accommodate the golf course layout, screen the clubhouse from views from St Andrews and to improve the landscape integration of the WWTW.

2.27 Extensive car parking is proposed to serve the development and this would incorporate lighting which would affect the visual impact. The site contains extensive stone walls which would be retained, for the most part.

Green Belt for St Andrews

2.28 Policy SS8 of the approved Fife Structure Plan 2002 sets out the requirements for local plans to identify a green belt boundary for St Andrews. The policy also states that there is a presumption against development or changes of use in green belts unless necessary for the purposes of agriculture, horticulture, forestry, countryside recreation, establishments and institutions standing in extensive grounds or other uses appropriate to the rural character of the area. In addition, where critical views to and from the town's historic core would be interrupted by intrusive development proposals, there is a presumption against all such development. The policy also makes it clear that development proposals likely to prejudice this process will be considered premature.

2.29 The implementation of the green belt proposals for St Andrews will be achieved through the East Fife Local Plan which is due to be published in draft in autumn 2004 and preliminary consultation is taking place. This wide ranging public participation exercise will allow views on the issue to be collated and combined with work which the Council has commissioned on a landscape capacity study for St Andrews, will form the basis for determining the green belt boundary for St Andrews. It is anticipated that the draft East Fife Local Plan will be published in the Autumn 2004 and the green belt boundaries identified at that time. The proposed development lies within the broad area identified for green belt status in the Fife Structure Plan and is therefore potentially prejudicial to defining the green belt. The proposals require to demonstrate that they do not prejudice the green belt's implementation, to enable them not to be considered premature pending the review of the local plan.

Nature Conservation

2.30 The site contains one plant species of note, Maiden Pink. The formation of a golf course would provide opportunities for the creation of new habitats and whilst management and monitoring would be affected by the drainage and chemicals required of the golf course these could be in the form of benefits to the SSSI. The site is relatively open and whilst there are opportunities for tree planting and linkages to landscape features, nevertheless again this would be dependent upon a detailed site management plan.

2.31 An irrigation reservoir would be formed and together with a wetland area have the potential to form a useful habitat. These would be linked through the site with a stream.

Transportation

2.32 The EIA contains a traffic assessment which indicates a low trip generation and an even spread of traffic throughout the day, being representative of golfers arriving and departing for their rounds. This total additional daily traffic would be in the order of 120 trips in and 120 trips out, equating to 10 in and 14 out at peak periods. The A917 carries approximately 4000 trips per day, 2-way in the summer period.

2.33 A new Links Trust shuttle bus would provide a link between the town, courses at the West Sands and the proposed course. In terms of construction traffic, approximately 20 deliveries per day are proposed although no information on haul routes has been provided. The applicants have included a staff travel plan.

2.34 Whilst a single golf course is not regarded as a large traffic generator, nevertheless cumulative impact on key junctions within St Andrews requires consideration. Current Scottish Executive advice is that Councils should seek "no net detriment" to the road systems and that adverse impacts should be mitigated against.

Economic and Tourist Impact

2.35 The proposals involve only a clubhouse and associated maintenance buildings to serve the golf course. There are no other elements involved. Access to the course would be open to the public and through ticket - the applicants propose 25 full-time equivalent jobs to be created as a result of the proposals and anticipate there to be recruited from within a 15 mile radius.

2.36 The Trust are required to provide access to the local links golf courses, and they have stated these are currently experiencing pressure. The proposed course is aimed at relieving local pressure on the existing courses, allowing the current visitor access to be maintained. The applicants consider this to protect existing golf tourism benefits to the St Andrews area. Many golfing visitors attempt to play The Old Course but if unsuccessful would access other golf courses. Clearly if successful they may still wish to access the other courses and the applicants therefore aim to ensure that such opportunities are maintained.

2.37 The Kingdom of Fife Tourist Board, together with some individual representations have called for a full independent Economic Impact Assessment to be carried out to examine the possible impact of the proposals on the existing businesses and economy of St Andrews, including golf courses not operated by the Links Trust. The EIA incorporated a section on economic impact. The key issue is that visitors to St Andrews are encouraged and increased to the improved benefit of local businesses. This therefore means increased overall usage of the golf courses and if there is a demonstrable demand from increased pressure that proper consideration be made as to how that could be met.

Other Consultation Comments

2.38 All other considerations are referred to elsewhere.

Representation

2.39 The Representations section of this report summarises the points raised by all letters of objection and support.

3.0 Next Steps

3.1 Following the departure hearing the application will be reported to a future meeting of the East Area Development Committee, subject to the need to resolve any issues arising from the hearing. The subsequent report will include conclusions and recommendations on the application.

BACKGROUND PAPERS

The documents, guidance notes and policies referred to in “Statutory Policies and Approved Guidance”.

Report prepared by Nick Brian, Team Leader

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