Objector Name Jane Angus Agent 091a Ballater & Crathie Community Darroch Den Hawthorn Place, Ballater AB35 5QH Company Ballater & Crathie Community Council Policy/site Settlements - Ballater Representation to Deposit Plan The following comments and response to the Deposit Local Plan by the Ballater and Crathie Community Council have been prepared by the Council after consultation with the local community. Our comments are confined to matters having a bearing on the communities within our Community Council area. The Park should note that the Community Council is in full support of the future development outline for Ballater, as proposed by the Prince’s Foundation. These proposals have been received with widespread enthusiasm and have the support of the local population. GENERAL COMMENTS 1.The Local Plan concentrates more on the methods of producing affordable housing without first proposing methods of encouraging business incentives (i.e. rates relief, tax incentives, etc.) to first create the employment that in turn creates the need for the additional housing the Plan proposes. In addition, the Plan makes little comment on the need for sustaining the existing infrastructure as well as necessary new infrastructure such as schools, shopping and medical facilities etc to support the needs of the 250 housing units proposed. Affordable housing needs are directly linked to the requirements of full time employment in the area. 2.we note that the site map for Ballater does not include the Craigendarroch complex nor does it mark the wooded area round the school. Also omitted are historic features like the battlefield site and the souterrain. We note too that the settlement of Crathie has not been included in the Local Plan. Land for housing and tourist development in the Crathie area needs to be identified and we request that Crathie be included in the Plan. COMMENTS ON POLICY General - The Deposit Plan in setting out its policies (1-36) has attempted to make one size fit all. A policy advocated for other settlements is not necessarily suitable for Ballater. We believe policies must be more specific to the needs of individual communities. 1.12 The SEA Assessment needs to be more thoroughly examined. The conclusions of the Plan may result in irrevocable damage to adjacent rivers, the environment and the whole ethos of Ballater. 3. There are four conservation villages. 4. Water Resources and Sustainable Design Guide – we consider that this policy needs to be reviewed and to be more specific. Recent exception rainfall must change perceptions when considering the SEPA 200 year flood risk predictions. If the floodplain area designated by the Park Plan for housing development is to be implemented, major flood defences will be necessary on the Dee to prevent flooding of the H1 area and other areas already developed and identified on the SEPA flood-risk map. 13a makes the developer responsible. There is no detail of upstream retention or the condition of the Dee banking near Sluvanichie, for instance, where erosion continues and previous attempts at reinforcement have not continued. It appears from recent comments that the new sewage system for Ballater will not be adequate for a large development. 5.1-5.3 - Ballater came into existence as a residential place for enjoyment of the “Spa” and for retirement. Its history is very different from that of other places in the Park. The view of some members of the Community Council is that without the present day incomers Ballater will die, for they help to boost the village economy. Some members of the Community Council believe that land must be available for high value housing for such persons, which will help to subsidise affordable housing in the form of Planning Gain. 5.7 - The Community Council fully agrees with the need for good design in future developments and supports the work of the Prince’s Foundation and its proposals for the future development of Ballater, with emphasis on the use of good environmental design and materials in keeping with the style of our village. We hope therefore that the Park Authority will recognise this and act on these proposals. 5.12-5.20 - The need for sustainable business development is a matter of prime concern. Ballater’s needs are different from those of other settlements where commercial development is strong. Ballater needs incentives for new businesses to come to the village. The cost of renting industrial units is high. We hope the Plan will highlight the need for Government agencies to encourage new business by means of rates relief, etc. as available in other areas. 5.25 - 5.26 - Ballater and Crathie Community Council believes that the housing requirements as indicated in North East Together (NEST) 2001-2016 do not reflect the needs of the Park. Many residents consider the 250 housing units proposed for Ballater alone is over-development and is unacceptable. The Plan does not take into account the 60 or more houses built in Ballater since 2002. 5.7-5.41 The Park Plan has formed policy for the Park as a whole when in fact the affordable housing needs and housing development market potential are quite different in Ballater from that in other settlements in the Park. The number of affordable houses in Ballater for local people and for commercial employment needs has not been established. 5.42 – 5.60 (policy 23/24) Ballater and Crathie Community Council fails to see how any future development in Ballater can sustain 30% affordable housing. In addition, 5.52 states that between 15% to 25% of a development will be social rented housing. We are not all agreed with the principles of mixed housing development and the sustainable balance of affordable and open markets, and await fuller discussion on details. Some members considered that the Plan ignores the fact that many house purchasers, especially those buying expensive homes, will not buy property in a mixed development. With regard to house type and house size, the Park Plan should recognise the unique housing needs in Ballater. Low cost housing is certainly needed, for young families to get on the housing ladder, but also, two bedroom single storey private development for an aging population who can no longer manage stairs and large gardens, as well as high value private housing to achieve planning gain to help pay for the low cost housing. Above all we are determined to keep the character of our beautiful village. This is what delights tourists and residents alike. It is expected that most of these desirable features will be fulfilled if the expected plans of the Prince’s Foundation are put into action. The responses The Park received during consultation exercises highlighted the fact that the edibility criteria for affordable housing and social rented housing, to be taken from Local Authority and Housing Association waiting lists does not meet the needs of local people requiring affordable housing and has caused considerable anger in the community in the past. The needs of local people and those incoming workers in the Park requiring affordable housing should be considered. 6.5-6.9 - As tourism is vital to the village, land and building development for hotel and hostel accommodation should be identified. 6.11-18 The designated area for car and coach parking for Ballater Games is of much importance to the continued function of the Ballater Games and the Plan proposes to retain this, covering an area of c.3h. The remaining area of about 8h. is available for housing. However, the erection of the proposed 250 housing units would mean a density totally inappropriate in an area like Ballater. 6.18 Ballater is not well served with recreational facilities. The Schools Outdoor Centre was a splendid facility but was closed in a cost-cutting exercise. Its reinstatement for other purposes is a possibility. Facilities and activities for tourists need to encourage them to stay in Ballater rather than just pass through. The Park Plan should identify these aspirations. Ballater does not have purpose built facilities for indoor sport, theatre, cinema, etc. other than those provided by the Victoria and Albert Halls. There is no mention of the proposed woodland project as an amenity area, a requirement supported by many at the public consultation meetings. There appears to be no provision for football pitches planned by Aberdeenshire Council. CNPA analysis of objection to Deposit Plan a - The plan must ensure adequate housing provision. However additional focus will be placed on employment provision. The CNPA continue to work closely with infrastructure providers to build into their investment programmes sufficient capacity to meet the needs of the local plan. b - The boundary of Ballater has been drawn to include the main settlement and housing areas which form the village. This is in on way to imply that certain other developments do not play a key role in supporting the village, particularly economically. In regard to Crathie, the approach to the identification of settlements outwith those identified in the deposit plan will be reviewed, and in line with the requirements of SPP1 a detailed rational behind the approach taken will be drawn up. Where it is considered that additional detail including land allocations would assist in the level of detail provided for smaller communities and help attain their aspirations, the specific identification of those settlements will be considered as appropriate through modification both Section 7 of the Plan, the policies regarding housing outwith strategic settlements, and the proposals maps. Any change to the approach taken may also impact on the SEA. onfirm that settlement boundary has been drawn to exclude the SSSI. Also confirm that Crathie as a disperced settlement would be better served within a settlement boundary, as it allows a much greater degree of flexiblity for incremental growth which supports the settlement - policy 25 and 26. c - The approach taken attempts to create a clear planning framework for the Park area as a whole. The wording of individual policies should provide sufficient flexibility to account for the needs of individual communities, but further clarity will be included as a proposed modification within the Introduction Section to further explain how to use the Plan and its policies and proposals. d - The comments are noted, but CNPA must refer to the responses from the 4 statutory consultees on SEA who have all commented on the clarity and soundness of the Environmental Report. The findings of the ER will impact directly on the local plan, its policies and proposals and this will be done in line with the legislative requirements and in liaison with the consultees. e - The comment is noted. The conservation areas are marked on the proposals maps. No modification considered necessary as a result of this representation. f - The aim of the policy is to ensure that management of the water environment in line with the established legal framework which exists, and other national guidance regarding flooding and drainage. The issue of flood risk assessments will be reviewed in line with the comments received from SEPA and the appropriate changes will be made both to the policy wording and settlement proposals where necessary. Confirm modifications will be in light of comments received from SEPA and also approach to flood risk assessments. g - The approach to housing policy endeavours to recognise all sectors of the market, and provide a policy basis to meet the needs of all communities in their housing need. The approach tries to redress the current imbalance between cost of housing and those in need of affordable housing. However this is in no way to underplay the key role played by the open market sector including those who retire within or to the area. The wording of the supporting text will be amended to better reflect the various sectors within the housing sector. Confirm that only a portion of the land allocated would be for affordable houses and the remainder will be for open market housing which will support the economy and housing markets in the village. h - The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. I - The comments are noted, and whilst interesting are not linked to land use planning and so are not appropriate for inclusion within the Local Plan. The CNPA will however continue to work with partners to bring this issue to the attention of those involved to ensure the best approach is taken for businesses in the Park area. SETTLEMENT PROPOSALS Confirm that we will continue to work with the Local Authorities to promote sites where appropriate. BL/H1 is shown to have a planned capacity of 250 housing units yet the area is less than both the Monaltrie and Invercauld developments which contain only 85 j - Table 2 is based on work undertaken by consultants and available on line to consider the issue of need and housing land. The plan therefore allocates sufficent housing units, and this was at the time considered to be too dense. Many villagers can identify the detrimental effects on the village of these 85 houses built by Scotia and adequate land for housing development. Homes in the past few years. k - Amend policy to reflect findings of 3Dragons work on affordable housing provision.Two background papers undertaken by consultants relating to population This figure of 250 units has raised more comment and concern within the Community Council area than any other feature of the Plan. Therefore we are unable to figures and affordable housing requirements are available on line. A summary of the approach taken will be appended to the Local Plan. Also amendments will be support this proposal. made to the introduction to the housing section to clarify the need for housing in the Park. The approach to 'pepper potting' affordable houses is one which has The Plan has failed to identify land required for shopping, sports development and amenity use. been tried and tested across the country for many years. However, the approach taken will be assessed on a case by case basis and a prescriptive approach will not Area H1 as designated for housing development in Aberdeenshire Local Plan extends further east than the area shown on the Park Plan (page 73) What is correct? be imposed. l - Modifications will endeavour to ensure a more appropriate balance is struck between development and tourism opportunities and the protection of the special Whilst you state on page 72 ‘that the CNPA will work with community developers and the Prince’s Foundation’ the area H1 and the areas further east and qualities of the area. Within Ballater, general policies have been included to do this, rather than identify a particular site which may be considered by some as extending around Aberdeen Cottage are shown in the Prince’s Foundation proposal for development in Ballater. These proposals received mush acclaim by the restrictive. However work will continue with the local chamber of commerce to ensure that the approach taken meets with the aspirations of the local community. people of Ballater at the consultation meetings conducted during November 2006 and should be recognised on the Park’s map on page 73. Confirm that policies ( esp 33 and para 6.3 and 6.4) aim to promote development such as tourism rather than shoe horn proposals into particular sites. m - The comment is noted, and amendments will be included to the proposals maps to highlight the needs of the community and the various uses to which the site is put. The amendments will take into account the ongoing work of the Princes Foundation to prepare a masterplan and vision for the future growth of Ballater, and a design guide for the development of the site. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. Confirm community needs assessments will address the need for facilities and develop appropriate plans for such developments which will be supported by local plan policies. n - The allocated site at Ballater will be reviewed in light of additional information being sought from the Prince’s Foundation. Additional information may then be added to reflect the findings of this study and provide a level of detail regarding mixed uses, access, densities, and areas to be protected from development. Further consultation will then be required within the community to assess the level of support for any modifications. The addition of extra information may impact both on the SEA and the Flood Risk Assessment for the site. Confirm allocation is phased for the long term growth of the village. Confirm where the housing figures come from, and the demand for affordable homes in Ballater and the role of the this plan and the aberdeenshire plan. Response to 1st modifications The Ballater and Crathie Community Council wish to continue our objections to the proposed Local Plan. CNPA analysis of response to 1st modifications a - Additional land has been included for employment and tourism uses, and the text amended to reflect the importance of securing employment uses within the National Park. No amendment is therefore proposed. b - Dinnet has been recognised as a rural settlement. Crathie however remains as in the deposit local plan, to allow a degree of flexibility for small appropriate scale development to meet the local community needs. The approach taken to ensure that there is not a mentality of locating development purely on a boundary basis is intended to provide flexibility and opportunity. No further amendment is therefore proposed. c - The National Park is required to produce a local plan for the whole of the National Park. In particular regard to Ballater it has identified the central shopping area, additional employment land, and open space which contributes to the settlement. No further amendment is therefore proposed. d - The SEA has been amended and is available on line. No further amendment is therefore proposed. e - The comment is noted and the conservation areas are marked on the proposals maps. No further amendment or modification is therefore proposed. f - The policy has been largely altered to reflect the comments of SEPA and further work on flood risk on housing allocations is ongoing. No further amendment is therefore proposed. g - The housing allocations are a response to housing needs within the National Park for all sectors of the community. The wording does not therefore highlight particular sectors or age ranges. The allocations do not in any way intend to stifle development or opportunities, rather the opposite is true, and the policies aim to ensure that a greater cross section of the population are able to get an appropriate house. No further amendment is therefore proposed. h - The work of the Prince's Foundation has now been embedded within the site allocation. The allocations also reflect work undertaken to establish local need, and we continue to work closely with the local housing authorities to ensure the most up to date information. No further amendment is therefore proposed. I - The requirements for affordable housing have been reduced. The plan also identifies land for employment, and recognises the retail centres of particular settlements, including ballater. No further amendment is therefore proposed. j - The allocations also reflect work undertaken to establish local need, and we continue to work closely with the local housing authorities to ensure the most up to date information. No further amendment is therefore proposed. k - The work to calculate the housing need have been placed on the CNPA web site. The allocations reflect this work undertaken to establish local need, and we continue to work closely with the local housing authorities to ensure the most up to date information. The requirements for affordable housing have also been altered. No further amendment is therefore proposed. l - The local plan and park plan both recognise the vital role of tourism within the National Park. Rather than identify particular sites the policies have been worded in such a way as to encourage new developments in appropriate locations. No further amendment is therefore proposed. m - The allocation of land for housing has included space for the Games which are recognised as important to the community. The density reflects the on going work of the Prince's Foundation, and within that work appropriate space will be made available for recreation and open space. The Policies of the plan are supportive of recreation uses, and the approach taken allows flexibility in terms of location and size. No further modifications or amendments are therefore proposed. n - The density of development reflects the ongoing work of the Prince's Foundation who have studied existing densities within Ballater and reflected this in initial design concepts. The Foundation are also keen to include necessary community facilities such as shops and the allocation allows for this form of mixed use. The CNPA continue to work with the Princes Foundation to bring forward the development of the site and the plan has been modified to reflect this. No further modifications or amendments are therefore proposed. response to 2nd modifications Ballater and Crathie Community Council wishes to continue with the previous objections. Ballater and Crathie Community Council still considers the Craigendarroch complex as part of our settlement because they share and use the same public services. The area between Monaltrie House and the first Scotia Homes development should be maintained as part of a 'greenway' from Craigendarroch Hill to the Dee. Many people in Ballater enjoying the present size and ambience of the area strongly oppose further eastern enlargement. However a majority very much want to see the established need for social and affordable housing to be fulfilled and a more balanced demographic community maintained. With the present financial regime this requires private development at the same time. The work of the Prince's Foundation for building offers a reasonable opportunity to discuss methods of retaining community cohesion and the least removal of land from food production with sustainable uses of resouces, including energy. Ballater and Crathie Community Council wishes to see further discussion of the CNPA design guide and business opportunities in full consultation of plans by the whole community. (note of meeting 26th november 2008 - having met with Jane Angus and Robin Blyth BCCC have confirmed that whilst a lot of points have been raised regarding various parts of the plan, these all relate to the position in Ballater and they wish their objections to be heard in an informal session on Ballater only rather than make representation to the various policies of the Plan. The objection is therefore lodged as a single objection to Settlements - Ballater KM) HEARING Objector Name David Thomas Lapsley Agent 451 03 Ardlui 19 Braichlie Road Ballater AB35 5QR Company Policy/site Settlements - Ballater Representation to Deposit Plan Those of us who are involved with the football clubs from primary school level, up to adult summer league all believe we have a valid case to ask for a dedicated football facility in Ballater. Currently we are operating out of Monaltrie Park which is a fine large area with the adjacent dressing room’s however as it is an open public area and many other groups use the park, this results in an unsafe environment for the players to play there football on. By unsafe I am referring to the numerous holes in the ground created by people golfing, fence posts from Ballater Games and animals it is only a matter of time before the sprained ankles we are getting every other week to be a hill break. This is a risk we fee] is to high to take and as we don’t want to stop training the kids we feel this request is the best course of action. The Primary training sessions attract 20-40 kids The Secondary training sessions attract 20-25 kids The Adult training sessions attract 20-25 adults In total this gives us 60-85 people using the park per week for organized football. Our football schedule looks something like this: Tuesday- Secondary School/Adult Training session Wednesday- Primary School Training session & Adult Training session Friday- Adult Summer League Match* Saturday- Primary School Match* Sunday- Secondary School Match* * These match’s are every second week. We also try to run between 2-3 tournament’s per year inviting teams from all over the Deeside area. With the arrival of the Royal Guard we generally get 3 to 4 friendly games during there stay in Bal later. Hopefully from this you can get a rough idea of how much time is put in to all these events every week by those of us who are all volunteer’s. With the newly formed Running club starting in Ballater we believe the facilities listed below would be well used almost every night of the week and for most of the year, weather depending obviously. What we would love is an area of ground large enough to contain a full size pitch and running track. 1 training pitch (7-5 aside in size) which we would train on, Use in tournaments and the kids would use for match’s. Changing and shower facilities. Full floodlights to ensure all year use. We don’t want this to be an exclusive area to only Ballater Football Club the more people who would use it the better, We are trying so hard to get a female in our group to encourage the start up of a girls team and a safe area and quality facilities would strongly assist in this cause. I feel it would be more than beneficial to Ballater, the surrounding communities but most of all the kids who will learn how to work in teams, leadership, equality and any other attributes we can teach through sports they love and enjoy I would like to thank you for taking the time to read this letter and for any time you devote to this. CNPA analysis of objection to Deposit Plan The comment is noted, and in the work ongoing with the Princes Foundation, it is hoped to include additional detail within the Proposals map to identify the need for key services and recreational provisions. Work will also continue with the Local Authority to highlight issues such as this raised in the local plan process. Response to 1st modifications CNPA analysis of response to 1st modifications response to 2nd modifications WRITTEN Objector Name Phillip John Swan Agent 462f 30 Monaltrie Avenue Ballater AB35 5RX Company Policy/site Settlements - Ballater Representation to Deposit Plan This objection relates to the same documentation as Objection 3. New housing development in the area and on the scale proposed in the Plan would close off the only remaining access route for wildlife (particularly deer) to move between Craigendarroch Hill and the fields bordering the route of the old railway line, At certain times of the year, deer have been observed on numerous occasions, usually at dusk, crossing ‘Field 3’ (which lies between Monaltrie House and Monaltrie Avenue) en route to base of the hill. Although I have no expertise in this aspect of wildlife, I am concerned that changes of this nature do not comply with CNPA commitment “to conserve and enhance the natural and cultural heritage of the area”. Requested change: reduce the target of 250 new houses to a more realistic number (maximum 50) and seek to satisfy this requirement by means of intelligent infill developments and upgrading/conversion of existing properties. Please note that if there is a Public Local Inquiry, I would be happy to prepare written representations and to appear at the Inquiry. My ability to make an oral presentation is unfortunately constrained by a medical condition which causes a degree of speech impediment. If others have objected to the same part of the Plan, I would be happy to present a joint case with them at any Inquiry. CNPA analysis of objection to Deposit Plan The scale of development is linked to work done on establishing the housing need within the area, and further work will be done to prepare information which fully explains the thinking behind the approach taken. Additional work will also be undertaken to ensure that the scale of development is not out of character with the densities currently built in Ballater. This will be done in conjunction with ongoing work with the Princes Foundation to prepare a masterplan for the site, and a long term vision for the future growth of Ballater. Confirm the allocation is for the long term needs of Ballater and within the 0-5 years the development indicates 90 dwellings. Confirm policies also support alternative forms of provision such as conversion. Response to 1st modifications I wish to maintain my objections to the CNPA Deposit Plan. CNPA analysis of response to 1st modifications The consideration of the impact of development on wildlife is considered under policies 5 and 6. No additional modifications are therefore proposed. response to 2nd modifications INQUIRY Objector Name Phillip John Swan Agent 462c 30 Monaltrie Avenue Ballater AB35 5RX Company Policy/site Settlements - Ballater Representation to Deposit Plan Objection 3 This objection relates to Section 7, Settlement proposals, Ballater, pages 72-73. The location proposed for the 250 future houses comprises three existing fields totalling 10.99 hectares: • A field of ca. 4.3 hectares (‘Field 1’) on the north east side of Monaltrie Park • A field of ca. 5.5 hectares (‘Field 2’) on the north east side of Field 1 • A field of about 1.2 hectares (‘Field 3’) on the western side of Field 2, situated between Monaltrie House and Monaltrie Avenue The total area of ca. 11 hectares, if used for 250 houses, indicates a fairly high concentration of around 10 houses per acre. The individual plot sizes would be further reduced by the need for enhanced amenity spaces and additional parking for Monaltrie Park overflow. This strongly implies a high percentage of relatively modest ‘affordable’ homes, which would be housing people for whom there would be only limited employment opportunities in Ballater. This would lead to a potentially serious level of unemployment in the local labour market with attendant social problems. Requested change: curtail the proposed area for future housing to ‘Field 1’ only (4.3 hectares) which should be sufficient for up to around 100 affordable houses, plus additional allowances for enhanced amenity, parking requirements etc. Alternatively, find other solutions to the required increase in affordable housing, such as intelligent infill developments and upgrading/conversion of existing properties. CNPA analysis of objection to Deposit Plan The scale of development is linked to work done on establishing the housing need within the area, and further work will be done to prepare information which fully explains the thinking behind the approach taken. Additional work will also be undertaken to ensure that the scale of development is not out of character with the densities currently built in Ballater. This will be done in conjunction with ongoing work with the Princes Foundation to prepare a masterplan for the site, and a long term vision for the future growth of Ballater. Confirm the housing requirement comes from various reports and studies and is based on a long term growth projection. Response to 1st modifications I wish to maintain my objections to the CNPA Deposit Plan. CNPA analysis of response to 1st modifications The position regarding the need for affordable housing remains a key issue with the CNPA Board and within all housing developments the aim remains to secure a degree of affordable housing. Some economic land has also been included and reference to mixed use within the site will allow for some employment options including working from home. No further amendments or modifications are therefore proposed. response to 2nd modifications Third, I refer to page 43, policy 21, 2nd paragraph. In principle, I endorse the new statement that “Development solely for affordable housing will be favourably considered”, if this is accompanied by withdrawal of site H1 for housing allocation. If site H1 is retained for housing allocation, then I object to the new statement, on the grounds that it implies the building of public sector housing which would be additional to the housing at site H1. With respect to the concept of “Development solely for affordable housing” I would urge the CNPA to apply more creative energy than has been evident so far to this approach to addressing the real housing issue that confronts Ballater which is access to affordable housing for local people. I strongly suspect that the concept of “Development solely for affordable housing” could offer a more cost effective route (in terms of the net unit cost of affordable homes) to satisfying the needs of Ballater people for affordable housing than that achievable under the current CNPA strategy, which involves paying large public subsidies to a developer to damage the environment of Ballater by building houses which the Community does not need or want. Further, I believe that, if the concept of “Development solely for affordable housing” were combined with the removal of Ballater area H1 from the housing land allocation, and efforts were made vigorously to pursue opportunities for intelligent “brown field” and infill developments, then the recommendation by the Prince’s Foundation of 28 September 2007, that “social housing should not be clustered in groups of more than about 5 units to avoid creation of social divides” could be achieved more naturally than would be possible with mass development in area H1. It would also give the added benefit of resolving much of the public opposition regarding the housing proposals for Ballater, provided area H1 and the land beyond it is dedicated to amenity/recreational use in perpetuity. INQUIRY