Objection 1 - Applying policy 1, 5 & 6 to Business units and commercial centres.

With the Fifeplan that was adopted in 2017 with a 5 year life span and now in review should it not be considered wether this type of application still fits with the adopted plan.

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The economic and environmental landscape has changed since 2021 , particularly with Scotlands largest school learning campus and college being built right next door, along with a further 193 houses. The Calais Muir area has become far more used and valued area for health and well-being in a natural environment, woodland in and around town so to speak. The requirement for further HGV traffic, lack of access and damage to environment could be catastrophic far a much loved site that has already been affected by previous development and failure to implement a proper plan to protect environment and access.

 

There are even more brownfield and industrial sites in and around Dunfermline

The adopted plan policy 1 states that development can only be approved for employment land or industrial in a location where there is clear evidence of a shortfall.

 

There are numerous vacant lots ( brownfield ) already in the area - a fact accepted in the developers originally PPP application.

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The fact that Fife Council have been very slowly building a similar site across the road for over 3 years now also amplifies the fact there is no demand for these types of units in this area.

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Both Axis point developers and Fife interchange developers have said the units are booked to be occupied but both fail to reveal who these occupiers may be. And would any potential occupier wait over 3 years.

 

The axis point planning statement states the main material consideration for approval is based on the economic benefits of the proposed development. This states that 315 Full time equivalent jobs (FTE) would be created. However, according to the home and communities agency, FTE for light industry should be calculated on the NET internal area (NIA) of the buildings against a density matrix appropriate for the site use. For industry & office space the gross figure is typically 15-20% higher than net internal space therefore calculation being: Gross area 14189m2 x (100-15%) = 12060m2 NIA. Applying a benchmark of 47sqm per FTE to industry (as per guidance) this give the equivalent = 12060m2 / 47 = 256 FTE. The majority of this development will be apparently be light industry so the calculated FTE in fact comes in less if you apply an element of distribution & storage. This means the figures being used to demonstrate economic benefit are in fact incorrect.

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None the less, the provisions of SPP state: "The planning system should support economically, environmentally and socially sustainable places by enabling development that balances the costs and benefits of a proposal over the longer terms. The aim is to achieve the right development in the right place: it is not to allow development at any cost.

 

As per the fife development plan map of all the designated employment land both for development and to be retained protected. This is as per the current Fife council adopted plan. Within the 16 employment areas identified there are currently over a dozen vacant brownfield sites and over 50 plus number of vacant built units, most of which are modern and many similar in size to those being presented. These are within a 2 to 2.5mile radius of this Axis point site and also lie some 2 miles from the town centre. To go that extra half mile would also include numerous site and proerties at Rosyth and Dalgety bay.

 

Fifeplan Policy 6 - Town centres first, establishes a sequential approach for approving planning applications associated with business and commercial centres. This means that the existing protected employment areas, from the town centre outwards, should take precedence over out-of- town greenfield sites.

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It states: if a development cannot be located in a particular town centre or edge of centre location, the next nearest town centre and edge of centre areas must be considered before out of centre locations. To be acceptable, development will require to be clearly justified against the requirements of the sequential approach. Exceptions may be made where new development cannot be physically accommodated in a defined centre (town, local or commercial) or has specific locational requirements.

The fact that there are numerous older vacant sites and units in the Dunfermline area lying empty is far from a justification to build more new ones out-of-town. Large areas of land exist in Pitreavie business park which offer the same if not better locational and transportation links as Axis point.

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Fifeplan policy 5 - Employment land and property states: areas will only be supported if it will not restrict the activities of existing or future businesses on the site or neighbouring employment sites. Fife interchange is directly opposite this site and is to be of similar character. The Fife interchange development is financially supported by the Scottish Government regional city deal and will therefore go into direct competition for the unit spaces with the private developer. The economic development response from Fife Council has somehow sighted this as a positive thing and states there 'would be a strong demand'. Where is this evidenced?  And how come Fife Interchange is still being built after 3 YEARS ( two high schools have been built in that time) there is clearly no demand for these types of units at these sites and how can 2 out of town developments comply with policy 5 when there are so many vacant protected employment areas closer to the town centre?

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Irrespective of the perceived economic benefit, the planning application runs contrary to policy 1, 5 and 6 for the reasons stated above. The 'cost' paid in this instance is large vacant areas of existing employment sites and the loss of rural greenspace. The same due weight should be accorded to these factors in the determination of the application.

 

Objection 2 - Policy 13 Natural Environment - Woodland Buffer zones.

Whilst there is a condition that a 15 m buffer zone being provided to the Eastern boundary of the ancient Calaismuir woods. How come this was allowed to be breached back in 2022 when groundscraping and fence building was done by the developer within the 15m buffer zone  to restrict public access. Where was the enforcement ?

This wood is identified as SNH Ancient Woodland and is subject to a Tree Preservation Order Area designation. The Forestry commission and woodland trust recommend that a minimum 15m zone is provided to ancient woodland in order to protect the trees from development and root damage. There is an argument based on English law and European planning laws that the best form of tree protection is the 15m buffer zone should be taken from the extremities of the tree canopy, which may not necessary be the property boundary line.

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The root protection area is stated in the applicant's development tree survey report (clause 6.1) but does not follow the correct guidance. Scottish Planning Policy (Paragraphs 194 and 216) state that the planning system should protect and enhance ancient woodland as an important and irreplaceable resource and should be protected from adverse impacts resulting from development. The 15m buffer condition had been applied to the Northern boundary of the woodland bordering the Persimmon and Bellway housing development to protect the trees and provide a screen when viewed from within the woodland.  Unfortunately that has since been compromised by the rerouted school path and cycle route.

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Why are these environmentally important conditions be put in if they can then be easily removed as and when further tarmac and concrete appears more appropriate.

There is a clear inconsistency in how the 15 buffer zone is actually protected around the woodland by Fife Council and conditions need to be more rigid.

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There still only appears to be only a 6m buffer being provided to the ponds/ watercourse that links with Pinkerton Burn, these ponds are very large, very old and fertile and far wider than 1m and within the FDP green network.

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Making Fifes places guidance states "Buffer strips need to be provided around areas of still water and on either side of watercourses or ditches. For sites identified as proposals in FIFEplan there may be information on the requirement and appropriate width of a buffer strip as part of the development requirements or green network priorities. For other sites a minimum 10m buffer should be provided around or on either side of watercourses which are over 1m wide, and a minimum 6m buffer should be provided either side of watercourses which are less than 1m wide. These buffer strips provide opportunities to enhance the ecological quality of the water body and biodiversity and should be designed to form an integral part of green networks on and around the site".

North Boundary.

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There are still contradictory terms and drawings being used on the boundary line between the axis point and northern side Shephard developments. The Axis point masterplan (2641(PL) 02 E) referred  to retention of an existing tree belt. This tree belt was actually on the adjacent shepherd property and has since been removed to accommodate the Southern access road under 21/01229/ARC.

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A planning condition imposed by Fife Council in adjacent site in 14/00809/PPP stated

FOR THE AVOIDANCE OF DOUBT, The landscape framework required to form part of the masterplan by condition 2 (a) (ii) shall: ensure adequate separation distances between residential and employment land uses with, as a minimum, a 15 metre wide tree belt of native species being implemented to provide this separation. In addition, the landscape framework shall also prescribe suitable forms of boundary treatment to define the limits of each of the phases addressed in the masterplan. Reason: To ensure appropriate levels of separation are in place between adjacent sensitive uses and phases.

It is clearly shown on the drawings that units 6 and seven back right up to the edge of the site and no screen or allowance for a tree planted buffer has been allowed.

 

The separation in the case of the Southern core road 21/01229/ARC (residential & educational access) and the axis point site (employment). A 15m tree buffer / tree belt between both sites is required as stated by Fife Council however under the current road and Axis point plans this condition cannot and will not met. The Axis / Shepherd boundary is shown as being 10m from the core road kerbline. There is a 2m footpath and 2m swale / verge which only leaves 6m for soft landscaping and compensatory planting. The compensatory planting proposed obetween the southern extremities of the footpath kerb line and boundary of the Shephard site is a mix of whitebeam, Scots pine and birch native to the Calais woodland. These trees will reach 30m+ in their lifetime and are being planted in a landscape strip 6m wide and only 5m from the walls of Unit 5 and block 7 on the Axis site.

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This same boundary issue is also referred to in FC Transportation Development Management teams assessment of the application but no resolution or condition is offered. A 15m buffer zone as per the original masterplan condition is required for the health and longevity of these trees including the visual screening they may provide. There is a clear inconsistency in planning policy being applied here between the 2 sites with original plans stating trees being planted to form a boundary to hide industrial from education site but this is obviously not the case , which will no doubt result in any trees that still remain their now being cut down before reaching maturity.

Axis Point Boundary Shephard site Boundary

 

Objection 3 - Policy 13 Natural Environment - Wildlife

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FIFEplan Policy 13: Natural Environment and Access states that development proposals will only be supported where they protect or enhance natural heritage and access assets including: biodiversity in the wider environment and protected and priority habitats and species. Where adverse impacts on existing assets are unavoidable proposals will only be supported where these impacts will be satisfactorily mitigated. Bird breeding grounds and high value deer & bat foraging habitat is present within and along the edges of this site and adjacent plantations. The site provides high value wildlife commuting lines linking with the Calais Muir woodland to the East, South and the wider countryside. There is an absence of a comprehensive up to date ecology report for this site and an attempt by the Save the Calais muir group to do this on Fife Council / the developers behalf was rejected.Although in 2022 Calais Wood conservation group funded and received a full ecological survey of the woodland and Duloch park which found the area to be rich in species that require wildlife protection.

 

DRAINAGE

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Regarding the drainage into ponds and water course of the ancient Pinkerton burn it also states in the site investigations that within the provided risk assessment highlighted in red, noted that it is “highly likely” that this development will contaminate these watercourses in the future.

This basically proves that inadequate mitigation is in place with this application.

 

The developers original planning statement states:

'with appropriate mitigation, the proposed development would not have an unacceptable impact on biodiversity or protected and priority habitats and species, and it therefore complies with the terms of Policy 13.'

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What mitigation or enhancement is the developer providing as there is none noted in the ecological appraisal? The appraisal for this site is old and was carried out in winter months so it is fair to state that this is inconsistent with the current plans and is no longer relevant. For example, the appraisal refers to the retention of a forging area of the North tree line and pond for protected species (noted as being bats and badgers). These forging areas are actually designated to be removed under site clearance.

The original Ecology report even actually stated

 

" 7.1.3 Residual impact The loss of this area of scrubby grassland will have a locally significant impact"

The development does not in any way protect or enhance the natural environment so runs contrary to policy 13.

 

Objection 4 - Transportation & Southern core Road

Since the PPP approval in 2021 there has been a major change of use to the local traffic and transportation arrangements With the building of the Supercampus and college along with a further 193 houses. This has added further traffic to sandpiper and southern approach roads and the school campus is already having police intervene into the build up of traffic at dropping off times.

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Further HGV vehicles in a site next to the schools and likely to also be used as a dropping off point for school pupils, spell s nothing but further traffic problems and major safety issues.

 

General arrangement 8891/518 contained in 21/01229/ARC shows a visibility splay contained with this site noted as being 'by land owner agreement'. This area is currently shown in 20/00774/PPP

 

as being 'existing dense woodland. This not shown in any of the details of the application nor is it referenced in the FC Transportation Development Management teams response or assessment of the site. A large area of tree line of the axis point land (adjacent to the pond) will require to be removed to comply with the Southern core road sight lines. There is a clear inconsistency in planning conditions here.

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Transport report does not adequatley assess the transport requirements for the area using data information gathered during Covid Pandemeic and using copied data from Planning applcation 20/03250/PPP . This is lazy and lacks integrity as each application should be decided on its own merits.

 

It also fails to recoginse that one of the largest warehouses in Europe which attracts HGV traffic, increased levels of pollution, traffic and peak traffic movements at shift changes.

Aditional school and college traffic is also not recognized and there are no

No restrictions or as to why local Amazon workers will not use the new estate as a car park or even worse School children will not use for a drop off point. Actually by offering further access points through the estate it looks like this is being offered and certainly comprimises what classed as safe routes to school.

 

This site will be positioned within what we call the Duloch loop which includes Dunlin,Sandpiper and Lapwing, and as it stands there are no industrial units within this loop, only housing, retail, recreational areas and now a Superschool complex. The Local development plan has changed within this loop to accommodate alternative uses that are more suited to this inner area and this plot of land allocated as industrial is no longer a viable, safe or attractive option for the area.

 

Objection 5 - Policy 1, 3 and 13 Loss of greenspace & employment designation

This site has never been developed and was up to the early 1990s previously arable land owned by Calais Farm. The designation of this site was changed to employment through the LDP in around 1996 and subsequently adoption of the Dunfermline & Coast Local Plan in April 2002. Since then, a number of the areas in the original 2000 masterplan shown below, have changed designation from employment to education & housing.

The site is in a sensitive location, has a lot of natural beauty, is well used by the local community and if developed effectively land locks the Calaismuir woods with built development on 3 borders Green space is required to be protected by planning policy irrespective of historic designation. The fifeplan is in its last year of a 5 year lifespan as such the DUN051 designation requires to be reviewed to its relevance to the change of use of the adjacent DUN059 (employment to education and residential) and current demand for community active space.

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Making Fifes places refer to green networks as being: The Green Network ... comprises the network of green spaces within and around our towns and cities, linking out into the wider countryside, which underpins the region's quality of life and sense of place and provides the setting within which high quality, sustainable growth can occur.

 

Fife plan policy 1 requires any new development to address the impacts on natural environment, landscape, historic environment and community resources. We see very little evidence of this in this application.

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The proposed unit are all metal clad and offer no environmental building products that could work better in a natural environment, sedum roofs for instance would be a nicer alternative as they would do in Europe. There are no solar panels even.

 

Fife plan policy 3 states that development proposals will not be supported where they would result in the loss of community resources an /or the loss of existing open space. There is a clear need for this to be reviewed.

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Fife plan policy 13 states that development will only be supported where they protect or enhance natural heritage and access assets including green network & right of way. There is a community right of passage over this property and beyond into DUN59 by a number of routes created by usage over time. This exists through common law and cannot be extinguished simply by ownership or a LDP designation. Whilst an access entrance has been allowed at the west of the site into the woodland it still remains to tight for any emergency access.

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This site also cuts off the last chance for people of all disabilities to access this part of the woodland as the only parking available to the public in the area is at Duloch Library.

 

A access has also been put in place to the north side of the site  but again this states it is only steps with a ramp for bikes. To provide a short cut through the site but limit that to only those people that are able to walk or cycle seems a bizarre line of thought. Wheelchair users go the long way.

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This development will cut through an existing undeveloped green network. The developers planning statement refers to 'a significant amount of landscaping being proposed within the development site to assist in integrating the site with the surrounding green network and minimising visual impact'. This in fact equates to minimal trees and shrub  being planted as compensation for a loss of 5.3 hectare of wild open green space which has been used by the community for over 25 years. If approved this site runs contrary to policy 1, 3 and 13 in respect of protection of greenspace network and natural environment.

 

Objection 6 - Policy 14 - Built and Historic Environment

Policy 14 (Built and Historic Environment) states the planning system should afford to the historic environment, whether designated as such or not, and refers to the cultural and economic value of the built heritage. The Council should apply the 6 qualities of a successful place when assessing development proposals. These qualities are: distinctive; welcoming; adaptable; resource efficient; safe and pleasant; and easy to move around and beyond.

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In response to this development the group would consider these as follows:

- Distinctive - The units will be built from composite cladding, thus visually out of character with the surrounding area and will not complement the rural character of the green belt or green network.

- Safe and pleasant - Car parks, service yards artificial lighting and movement of large vehicles will dominate the site and thus create a negative impact for the adjacent recreational, housing and educational areas.

- Easy to move around and beyond - A pedestrian footpath network within the site is proposed however the street design does not consider all users particularly especially children from the future neighbouring school. Nor does it in any way provide the same safe footpath links the current site has with adjacent properties or the wider countryside.

- Welcoming - The development will have a negative impact on the social interaction the current site offers. These will be wholly industrial units of no character and will not encourage active pedestrian movement within.

- Adaptable - The units have been designed to accommodate a specifically a mix of uses within Classes 4 (business), 5 (Industrial), and 6 (storage and distribution). There is no built-in adaptability for changes in market or any future use.

- Resource Efficient - Reference is made to incorporating sustainability features and promoting active/sustainable travel options, but no evidence is provided of how this will be achieved. The green guide used to assess materials to be used is dated and does not in any way meet the low carbon criteria set out in policy 11

 

The planning statement and application does not recognise any historic significance in the area nor has it carried out the appropriate investigations. The area previously was bordered by a railway and limestone quarry network. The historic limekiln still stands under 100m from the site boundary and the significance of which should be acknowledged and mitigation provided in the plans. The historic map below shows this along with the clear marked right of way across the middle of the site from North Duloch as highlighted in objection 5.

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This application may well support the outdated aims of the Local development Plan in providing economic / employment investment in east Dunfermline. It does however contravene a number of Fife councils own planning obligations on development, protection of existing employment lands, protection of green networks and the safeguarding of the character and qualities of the landscape. It should not be approved for these reasons.

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Objection 7

The Fife development Plan for site DUN051 states that " To create a high quality landscape and access links from fife leisure park to calais muir wood and beyond to north Duloch and " wider link over the motorway to Dalgety bay"

 

This requirement has been recognised by the developers plans but fails to offer any

proposal and solution to the second part regarding "the wider link" . Understanding is then that this PPP application is not being fully fulfilled by not addressing all the aspects and requirements.

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Just thought I would end with a reminder of the Fife local development plan aims to ensure:

- Fife's environmental assets are maintained and enhanced

- Green networks are developed across Fife

- Biodiversity in the wider environment is enhanced and pressure on ecosystems reduced enabling them to more easily respond to change

- Fife's natural environment is enjoyed by residents and visitors

Planning policy safeguards Fife's natural heritage through the protection of priority habitats, species and habitat networks of wildlife sites and corridors, watercourses, wetlands, landscape features and open space, some of which may not fall within designated sites.

Thoughtful development design can deliver high quality, successful places that protect and enhance natural heritage assets and biodiversity. However, without care poorly sited and designed development can affect species and habitats and lead to habitat loss, degradation and fragmentation.

Development proposals must provide an assessment of the potential impact on natural heritage and biodiversity and include proposals for the enhancement of natural heritage and access assets, as detailed in Making Fife's Places Supplementary Guidance.