< w:st="on">East Lothian Local Plan 2005 – Public Inquiry<>

Objection (Ref ENV011) by Mr P G & Mrs R Stephen

Housing Allocation at Letham Mains, Haddington (Policy H4)

STATEMENT OF CASE

1. We have lived in Haddington for 30 years, having chosen to move to this town from w:st="on">Edinburgh , to enjoy its high quality and compact environment and its comprehensive public services, which we considered ideal to bring up our family. We were most concerned therefore when it was proposed to expand Haddington with 750 (now 1000) new houses. Such a scale of development (1000 houses) would create a potential increase in population of at least 25% (based on the Council’s 2.2 persons per household), which would have a major impact on the historic character of the town, its traffic, infrastructure, schools and other public services.

2. We examined East Lothian Council’s document “East Lothian Local Plan: Development Options 2000-2015” which identified five possible sites for new housing. Only two sites, Haddington West (Letham Mains) and Haddington East (Amisfield) were identified as having the capacity to accommodate up to 1000 houses each. The other three sites - Haddington North, West Road Field and Commerce Park West Road – were estimated to have a combined capacity of 290 houses. In our letter to the Council dated 19 April 2002 (to which we only received an acknowledgment with no analytical comment) we offered our critique of the identified sites in the context of our own view and of the Council’s “Criteria for the Location of New Development” having the aim of minimising the impacts on site and surroundings as stated in their Development Options document, and listed below.

1.      Their impact on the appearance of existing settlements.

2.      Where Green Belt land is required, ensuring that any impact on its objectives is minimised by selecting land of lower landscape quality.

3.      Minimising additional travel on the road network by locating where alternatives to the private car ie public transport walking or cycling are available or can be made available by transport investment that will be delivered with the development.

4.      There is safe access and no unacceptable traffic or safety impacts on the wider road network.

5.      In the case of housing, having good access to social and community services such as schools and local shops or where these services can be provided.

6.      In the case of extensions to existing settlements locations where the new development can most easily be integrated.

7.      Areas in which people want to live or businesses can succeed.

8.      In the case of housing, providing for all requirements not just those of owner occupiers.

9.      Water, drainage and other essential services can be provided.

10.   The site is physically and economically capable of development.

11.   Avoiding where possible development on prime quality agricultural land.

3. Of the eleven criteria a majority failed to be met or cannot be justified then, now or both. Significantly the criteria omitted to refer to the impact the scale of development could have on the historic character of a town, a criterion of particular relevance to a conservation area of such importance as Haddington. Our 2002 letter was incorporated into our formal letter of objection dated 20 September 2005 to the housing allocation at the Haddington West (Letham Mains) site. The Council, in their letter dated 9 February 2006 ref. RELLP/12, rejected our objection where the following summarises their reasons for identifying the Letham Mains site as the preferred site:

·        The Structure Plan requires that land for 750 houses is identified in Haddington.

·        There are no brownfield sites within the town for this scale of growth.

·        The site is well contained in landscape terms.

·        Haddington can accommodate this level of growth (18.6% for 750 houses). (NB.This increases to 24.9% for 1000 houses @ 2.2 p/household)

·        Impacts on services and infrastructure must be addressed by and paid for at the developer’s expense.

·        The site will result in a new primary school, sports facilities and an integrated mixed-use neighbourhood area.

·        Additional public transport facilities to serve the site are a matter for public transport operators to provide.

I their letter the Council appeared to accept our contention that people will use their cars in preference to walking by their admission that “it is accepted that people may still exercise the choice to use the private car for journeys”. The Council also stated that “Haddington is a popular place to live in as evidenced by the property market and general vitality and vibrancy of the town”.

In our view this is planning by numbers, full of broad assumptions and unsubstantiated claims. We intend to demonstrate that the Council has failed to validate its case for the proposed new development through the evidence of our witnesses in the key areas of impact and that therefore the allocation of 750/1000 houses for Haddington is unsafe and should not be confirmed.

4. The following sections expand on the foregoing and contain the data and information which our evidence will examine.

a) Haddington is the county town of East Lothian and has grown incrementally over the years. From national census records Haddington’s population has grown from 4498 in 1951 to 6442 in 1981, 8844 in 1991 and may exceed 9000 in 2006. Houses are being built at the moment at Briery Bank, the Maltings and Alderston Meadow. Since 2001 approximately 196 houses and 75 flats have been built in Haddington. The proposal to increase the size of the town by a further 750/1000 houses is a major proposal in terms of its size and its impact upon the setting of this historic burgh, its compact medieval street pattern and infrastructure and services. These impacts should be carefully considered and assessed in advance of any decision to allocate land for housing on the proposed scale.

b) Haddington Town Centre is one of the best conserved extant examples of a medieval Scottish Royal Burgh. It contains a large number of listed buildings which are afforded protection through conservation area status. The Town’s growth and the grant of planning permission for traffic generating activities in the centre (eg TESCO Supermarket and John Muir House) have had the predictable consequence of causing congestion at peak periods and increasing the need for traffic control measures and street furniture/signage to the visual detriment of important buildings. Shortage of parking space is now at crisis point and there is no space for further provision in the tightly constrained centre. There are genuine fears for safety in congested parts of the town particularly in the vicinity of schools. The subsequent impact of a development of the proposed size would seriously compromise safety, amenity and the conservation status of the town. There has been insufficient regard in this proposal to the relationship of such an important townscape to its rural hinterland and the significance of that in relation to creating a “sense of place” for the people of Haddington itself and of its landward areas. The Council’s contention that the Letham Mains “site is well contained in landscape terms” would not sit well with PAN 44 – Fitting New Housing into the Landscape. The proposal should therefore not be confirmed.

c) Evidence will be led by reference to previous transport and traffic studies that the Town has, even now, exceeded its capacity to accommodate traffic pressures generated by those living in and visiting the town – this is confirmed by observation by residents and visitors and is capable of measurement. The impact of the Letham Mains site will be assessed against criteria and objectives set out in National Transport and Environmental Policy as set out in NPPG 17 and in other documents. Doubts will be raised about the wisdom of concentrating residential development in a few disproportionately large additions to existing towns, a policy of which Letham Mains is just one possible example. One aspect of these doubts will be the unlikely match of sufficient local job opportunities and the consequent extended journey-to-work to and from Edinburgh ’s expanding economic base. Such numerous, long journeys are contrary to documented national policy. A transport strategy for South-East Scotland under the terms of the Transport ( Scotland ) Act is in preparation and decisions on the size, concentration and location of large developments would be prejudicial and premature. This evidence will demonstrate that the building to the west of the town of a development of the proposed size would have impacts which are wholly unsustainable and that for this reason the allocation is unsafe and should not be confirmed.

d) The site of the town was carefully chosen – it is no accident that the town had its beginnings in a bend in the River Tyne at a point where strategic routes from north, south, east and west converged and crossed the river. The relationship between the medieval centre and the river is critical in understanding the history of the town and what makes it today so special and worthy of careful stewardship. A long campaign locally to resist the development at Briery Bank failed and the natural boundary of the river has been breached to the south. The implementation of the proposed allocation at Haddington Letham would further skew the shape of the town and suburbanise the approach to the Town from the west.

e) It will be stated in evidence that the inclusion of the site at Haddington Letham in the Finalised Local Plan is contrary in a number of ways to the specific objectives and requirements of national and development plan policy and that the flouting of these policies appears to have been possible through a numbers driven process which has held sway over well established policies relating to the built heritage, landscape setting, transportation and sustainable development.

Witnesses

It is the current intention to lead the following witnesses :

Mr P G Stephen                                                Resident and Objector              

Mr I Arnott                                            Haddington & District Amenity Society (HADAS)

Mr B Heath                                           HADAS

Mrs J Wilson                                        Haddington Community Council

Mr N Lawrie                                          Haddington Community Council

Mr J Richardson                                   Haddington History Society

Mr T Levinthal                                      Scottish Civic Trust

Mr B J Hutton                                       Traffic/Transportation Consultant

Mr A W Robinson                                  Planning Consultant

Length of Evidence

It is anticipated that the case will take one to two days to present through the above witnesses. At the time of drafting this statement it was not known how many parties would be giving evidence at the Inquiry relative to the proposed allocation at Haddington Letham and it is therefore not possible to say how long questioning of others will take.

Documents

The Council’s list of Core Productions is not to be published until mid July as advised by the Programme Officer. It is assumed that this will contain all the documentation relating to the preparation and finalisation of the Local Plan and all relevant national policy guidance and advice.

The list of documents intended to be lodged are listed separately on the accompanying

“List of Documents for Public Inquiry”.

The right to add to the list of documents to be lodged is reserved pending the publication of the list of Core Documents.

List of Documents for Public Inquiry

PGS1 HADAS letter dated 21/1/04 to Scottish Executive in respect of Edinburgh

and Lothians Structure Plan Draft Modifications

PGS 2 Scottish Executive standard letter of acknowledgment of PGS 1

PGS 3 HADAS letter dated 12/2/04 to Scottish Executive in regard to PGS 2

PGS 4 Scottish Executive response dated 10/3/04 responding to PGS 3

PGS 5 Andrew Robinson letter dated 19/1/04 to Scottish Executive in respect of

  Edinburgh and Lothians Structure Plan draft Modifications

PGS 6  Scottish Executive response dated 4/2/04 to PGS 5

PGS 7 Andrew Robinson letter to East Lothian Council in respect of East Lothian

  Local Plan 2005

PGS 8  Designing Places

PGS 9 Correspondence between Royal Fine Art Commission for Scotland and East

            Lothian Council regarding Briery Bank

PGS 10Letter to Head of Planning and Development re. P\0971\95 Proposed

Development at Simpson’s Maltings, 4 June 1997

PGS 11Letter from the Community Council to the Head of Transportation, East

Lothian Council on the Oscar Faber Traffic and Environmental Study, 20 May

2002

PGS 12 IRU decision of November 2002 on the 2^nd expansion of Tesco’s stores,

Haddington (from the file on planning application 00/01143/FUL)

PGS 13 Letter from Pritchett Planning Consultancy, 30^th June 2005 (from the file on

planning application 03/00729/FUL)

PGS 14 Precognition of Colin Bathgate B.Eng, MICE at the Planning Appeal in 2002

for the extension of the Tesco store

PGS 15 Extracts from Community Council minutes on traffic and parking matters

(one item)

PGS 16 Two letters from Brian Cooper re. parking at the Newton Port car park

PGS 17 Letter from as yet unspecified person re. parking for patients for the Newton

Port Surgery in the Newton Port car park

PGS 18 Haddington History Society statement on the proposal for 750 to 1000 houses

to be built in Haddington

PGS 19 Haddington : Royal Burgh – a paper on the historical background of

Haddington and Letham House prepared by Haddington History Society

PGS 20 Haddington History Society PowerPoint presentation text

PGS 21 Haddington Community Council survey of public opinion

PGS 22 Insert into Haddington Community Council Handbook on Development

 Proposals

PGS 23 HADAS letter to East Lothian Council regarding FELLP dated 20/9/05

PGS 24 Lothian and Borders Structure Plan – Supporting Statement March 2003

List of Documents for Public Inquiry cont.

Reference will be made to the following items in the Objector’s Case. It is assumed that these items will be produced either by the Council as core documents / Council documents or by the Developer Consortium:-

1. Haddington Traffic and Environmental Study, dated November 2001, by Oscar Faber , Consulting Engineers, commissioned by East Lothian Council.
2. Final Report on the Transport Assessment of the Letham Mains site, dated September 2005, by Sir Colin Buchanan & Partners Limited, commissioned by the Developer Consortium (CALA Homes, AWG Residential, Taylor Woodrow Developments).
3. Letham Mains, Haddington – Masterplan Report for 750 Units – Final, dated September 2005, prepared by the developer Consortium.
4. East Lothian Council – East Lothian Local Plan: Development Options 2000-2015, dated Approved for Consultation 01 February 2002.
5. East Lothian Council – East Lothian Local Plan: Development Options – Site Appraisals, dated 18/2/03.
6. PAN 44 – Fitting New Housing into The Landscape.
7. PAN 52 – Planning in Small Towns.
8. PAN 59 – Improving Town Centres.
9. PAN 58 – Environmental Assessment
10. PAN 68 – Design Statements
11. PAN 75 – Planning and Transport
12. SPP 17 – Planning and Transport
13. Planning Advice Note #75 – Planning for Transport (Scottish Executive)
14. Scottish Planning Policy #17 – Planning for Transport
15. Transport ( Scotland ) Act 2005
16. Guidance for Regional Transport Partnerships in Preparing Regional Transport Strategies – Scottish Executive, March 2006
17. Urban Traffic Engineering Techniques. Scottish Development Department