Neil McDonald
Comment submitted date: Tue 12 Jan 2016
I wish to submit a representation in respect to the above planning application.
Significant investment and development is to be welcomed where the development adds value to the sustainability of a community by helping create a quality living environment, excellent educational and community facilities, encourages a vibrant local economy and enhances the natural and built environment. The planning process has been established so applications can be properly evaluated against these, and other, key criteria. The process can successfully help deliver real benefit and a quality project where all parties involved work in a spirit of openness and collaboration and the information provided to support the application is full, clear and has been robustly tested against the relevant development criteria.
My current view is the application as submitted fails to meet the quality and type of development which will add value to the sustainability of our Town and wider community. I therefore wish to object to the application as submitted on the following grounds:
1. On a procedural matter, in light of the application submission date in relation to the holiday period and Highland Council office closures, what is the deadline for public representations and neighbour notification? I trust it will be extended to give everyone the opportunity to submit representations for a project of this scale and significance.
2. There is insufficient information accompanying the application to be able to take an informed and balanced view on the merits of the application bearing in mind the potential impact the application will have on the Town and established businesses.
3. Planning Policy at local, regional and national level has a presumption of "Town Centre First" when it comes to assessing the impact significant development might have on existing Towns. Most recently the Scottish Government's policy outcome from the "Review of Scottish Town Centres" has reinforced this key planning principle. The application fails to address this fundamental planning issue.
4. Local Plan issues.
a. The current Local Plan envisaged the Council preparing a development brief with the owners to explore a range of alternative uses. What were the outcomes of this options appraisal exercise with the applicant and indeed the previous site owner? I note the Local Plan states:
"In planning terms redevelopment for business/light industrial workshops, further education facilities, a community/art centre and residential uses would be appropriate. Non-food retail warehousing would only be considered as part of a mixed development which incorporates the other appropriate uses and benefits for the wider community".
Refer further comment below in "5".
b. I note that in respect to this site the updated Local Plan states under Developer
Requirements:
"In addition (to
08/00494/REMCA consent) an active travel route is to be established along the east side of Ormlie Road and through the site from Janet Street as part of "Safer Routes to Schools"; high quality and design"
Refer further comment below in "5".
5. In my view, the recent community engagement exercise "A New Vision for Thurso" and the subsequent updated Local Plan which itself was informed by the engagement exercise has been substantially ignored by the applicant. I note the updated Local Plan has now been approved as the settled view of the Council and must be treated as a material planning consideration for development management purposes as of 4 November 2015. It is unacceptable that after spending tens of thousands of pounds of public money on community engagement and the preparation of the updated Local Plan, that the first application of significance submitted after the Council has agreed their settled view should ignore aspects of the community and Councils aspirations for the Town's sustainable development. It singularly fails to address key criteria referred to above in "3 & 4" such as:
a. The site use should be mixed. The application only envisages retail which is likely to be Aldi or a similar budget supermarket with other national retail chains tagging on behind. This will only happen if the developer's negotiations are successful in driving down site development costs to keep lease terms at the keenest level possible in order to attract national retailer's interests and maximise commercial return.
b. High quality and design. The site layout ignores the grain of the existing Town planning which is of National historical significance and the building designs as presented have minimal design merit. The proposals fail to deliver in any meaningful way on the community and policy aspirations for appropriate development which enhances the Town's built environment by means of quality development.
c. The north east corner of the site forms a key visual end stop to Princes Street and the Town Conservation Area vista. The application completely misses the opportunity to make a positive contribution to the richness of the Townscape which is bitterly disappointing.
6. The application has insufficient detail to merit proper evaluation in respect to:
a. Traffic management.
b. "Safer Routes to School" bearing in mind the proximity of Miller Academy Primary
School, Thurso High School and the UHI.
c. Contaminated land assessment for brownfield site development.
d. Contextual visualisations to clearly communicate the impact the development will have on the Townscape.
e. The drainage assessment refers to an historical flagstone field drain through the centre of the site. It is likely that this drain connects with other unrecorded historical field drains which may act as a direct conduit to Thurso River. Any such direct conduit may reduce the efficacy of the treatment proposals for surface water disposal to the environment. If historical flagstone drains are not dealt with by best practice there remains a significant risk that environmental pollution, flooding or surcharging of existing drains may occur.
7. The applicant has only applied for consent for part of the site extending to 1.75 hectares and
2 retail units which create less than 10,000mē of floor area. If they had applied for consent for the whole site development (for example as envisaged by the applicant in the plan forming part of the Drainage Strategy Plan and Flood Risk Assessment) then my understanding is the application process may have to had been dealt with as a Major Planning application as the whole site area exceeds 2 hectares and total building floor area would almost certainly exceed 10,000mē. I would contend that an incremental approach to the control of development for this site is wholly inappropriate and has more to do with the applicant wishing to avoid project development costs and short cut the planning process. In my view the applicant should be required to submit an application setting out their proposal for the development of the whole site and have it determined as a Major Planning application so that an appropriate level of information is provided to enable proper scrutiny and due diligence in assessing the applicant's proposals.
8. The applicant acquired 14 Tesco sites across the country. It would be logical if those sites which offered the best return for shareholders were to be developed first. In this context the applicant should be required to make a statement on where the development of the Thurso site lies in their priorities.
The timing of the application submission to coincide with the holiday period, the lack of supporting information and the ignoring of Policy raises real concern that this application is ill considered and of minimal (if any) value to the community. Whilst not forming part of the application, recent press statements have referred to 100's of jobs being created but there has been absolutely no substantiation as to how these jobs will be created and how many existing jobs they will displace. There is no mention of the potential negative economic impact this development will have on our established Town centres hard pressed retailers. Tacit reference has also been made to mixed use but is not realised in the application because commercial returns on anything other than retail use will not maximise a commercial developer's return on this site. Reference to student accommodation is highly unlikely to be deliverable as the developer is not the current UHI Framework Development partner for delivering student accommodation across the region.
The minimal investment in the preparation of the application and the lack of any attempt to demonstrate an understanding for our Town, the site, its context, the communities' aspirations and planning policy says it all. The application as presented is not in the Town's best interests. I suspect when the developer progresses to the detailed design stage that the commercial realties in developing this site will then come home to them and development will drift as it did with Tesco.
The press statements are all spin, of no substance, and are designed to construct a perception of a reality which cannot and will not be delivered. In my mind an application of this importance to the Town should not even have been validated due to the lack of information never mind ultimately possibly receive approval. The appropriate development of this site as envisioned in the Local Plan and community engagement exercise has the potential to unlock far greater community benefit than is being offered here. The application must be refused in its present form as our Town deserves much much better than this.
Bookmarks