Cupar Development Trust (CDT) met with Persimmon recently to discuss their response to the Trust’s letter to Fife Council (19 Mar 2024) on the subject of the proposed Cupar North development.  The letter is reproduced below with Persimmon’s comments added in red italics.  Chair of CDT, Tony Miklinski, says: “CDT continues to adopt a neutral stance towards the development, reflecting the broad range of community views, and supports a rapid determination of the application.”

Reference: 15/04279/EIA Cupar North proposed Development

Dear Steve

I write, as the new Chair of Cupar Development Trust (CDT), to comment on the above application for the development at Cupar North. As a recognised Community-Controlled Body under the Community Empowerment (Scotland) Act 2015, we are mandated to support the growth of a successful and sustainable community within Cupar Ward boundaries, and have conducted extensive[1], recent public consultations as part of the development of our Community Action Plan (CAP) and Local Place Plan (LPP).  Both consultations attracted extensive comment on the Cupar North planning application, and the results are detailed below for your consideration and action.  I stress that CDT adopts a neutral position regarding planning approval, but if the development is to proceed, then we would wish to see these community views incorporated.

Delay:  There is strong public consensus that Cupar North has been delayed for too long, stifling alternative housing and economic development within the area.  The application needs to be settled, urgently, for the community to thrive and grow.  We really need to move this on. Noted and we agree. Persimmon are looking for determination of the Application at the earliest.

Housing:  CDT supports the commitment to 20% of the dwellings being affordable. Our CAP showed a lack of smaller, lower council tax band properties in the wider area and Cupar town. This is preventing those on lower incomes from accessing suitable housing in Cupar. We urge the developers to make a large proportion of the new properties 1- and 2-bedroom units. On a site of this size it was always intended that a broad mix of house sizes will be catered for.  Persimmon will be providing smaller starter and family homes in order to meet unmet demand in this important sector of the market. The application includes an indication of densities across the sites which addresses the need for smaller houses which we are happy to work within. The Application  Local residents are concerned that the development could lack character if the same design and colour scheme is repeated across the entire development. Design and palette should echo the existing Cupar settlement and avoid the impression that Cupar North is “bolted on”.  Our proposals in respect of detailed design will form part of  the AMSC application stage however we would intend to reflect the local character in our elevations to creative distinct areas that are attractive and fit well into the local surroundings.  There is a compelling case for more bungalows and disability adapted properties within the new development; there are very few in Cupar town and demand is outstripping supply, meaning elderly and disabled residents’ needs are unaddressed. We will be providing homes to meet this requirement through the delivery of our on-site Affordable Housing and may, subject to market demands offer single storey dwellings in certain areas of the site. Whilst we welcome the additional communal green spaces in the new plans, we seek assurances that the garden spaces for the new dwellings will meet current minimum guidelines. They will indeed meet the current standards as a minimum.  Local residents feel that new dwellings should have PV provision to reduce rural fuel poverty and to comply with climate mitigation recommendations. PV is currently part of our specification as it is required to ensure our dwellings meet the required building standards. EV charging spaces, both within residential dwellings and within any communal parking areas should also be a high priority. The current building standards require the necessary infrastructure to be ‘built in’ to enable EVC to all plots.  EV charging facilities should be available at the proposed new petrol station. Once we identify an operator, it would be up to them to confirm how they will meet this demand however most (all ?) new facilities are providing EV charging facilities.  We also welcome the lowering of the height of the higher 2 story properties and the planting of additional tree cover to reduce the visual impact of the proposed new development. Additionally, when we met you asked about the introduction of an element of Assisted Living. In response we have made contact with a provider and hope to take this forward. Clearly this will gather impetus if planning permission is approved.

Primary School:   The allocated site must be large enough to cope with projected future pupil numbers. The site currently proposed  measures c1.6Ha which is greater than the Scottish Futures Trust minimum requirement of 1.2Ha for a single steam primary school. We support the proposal that Fife Council will undertake a review of school provision requirements on completion of the 350th and 450th home, which will determine the size and scale of the new primary school. Noted  We assume that the capacity of Bell Baxter High School has also been reviewed to ensure it can absorb the predicted intake increase from the development. The capacities at Bell Baxter were taken into consideration by the Council and it was concluded that there was sufficient capacity to accommodate this development. In terms of the financial assistance given by the developers to local schools, we would likeall local schools to benefit from financial assistance from the developers, including, in particular, special education schools. Fife Council’s Planning and Education departments have previously been consulted and will be again to ensure that the impact of this development on the local school estates is fully mitigated.

Commercial and employment land:  CDT welcomes the increase in employment area to 8 hectares on the new plan. We support a broad range of possible employment/retail opportunities on the proposed development and note the developer’s suggestions as to the type of retail and business provision. Our LPP consultations revealed a lack of hotel space locally, so we would support a new budget hotel in the area. We agree and would be pleased to work with hotel providers to accommodate a new hotel if the planning application is approved.  However, whilst we support some retail within the proposed new development (e.g. convenience grocery stores), we feel there should be limited recreational retail (e.g. restaurants) allowed within the proposed development to encourage the use of existing recreational facilities in Cupar town centre (which will also serve to promote community cohesion).  It is vital that existing businesses within Cupar town centre feel the benefit of the expanded population.  Cupar town centre should be the focus and hub of the development and the centre for retail services, and travel routes should reflect that. We are sympathetic to your comments in relation to the town centre as we also want Cupar North to form a cohesive part of the wider Cupar community. It is likely that the commercial development will be demand led which as we know varies depending on operator needs. It will also have to comply with Planning requirements and so any detailed proposals will be subject to a further planning application which will in turn be subject to public consultation.

We re-iterate the point made to Head of Business and Employability, Gordon Mole, recently, that the community urgently needs more serviced business and manufacturing sites to become available. We are witnessing interested businesses being directed to other areas in Fife due to lack of available serviced land. This is a serious shortfall that Cupar North needs to address.  We advocate ringfencing unallocated land for future commercial and industrial purposes. We have identified the area for Commercial development in our planning application. We also note the re-siting of the roundabout at the east end of the proposed new development.  This potentially impacts on access to the Prestonhall East site (as featured in the current LDP).  The Prestonhall East site offers potential for larger businesses, particularly those in manufacturing and industry where noise and traffic constraints will prevent their siting in the proposed new development, and it must be a priority to allow access to this site as soon as possible. We support the Prestonhall East site for these uses and believe that the site can be easily accessed via a new T junction off the A91 prior to our proposed Eastern roundabout or indeed directly via existing roads within the existing trading estate.

Recycling facilities:  It is disappointing that there is no land allocated on the revised plans for recycling facilities. There have been repeated calls for a new recycling centre in Cupar with a larger range of recycling options, an onsite re-use facility and full-time public access. Additional housing will put further pressure on the small existing site. We are aware that funding for a new recycling centre has been allocated by Fife Council, and after consideration of the site options available, our forthcoming LPP proposes that the new recycling centre and re-use facility should be located at the Prestonhall East site. As discussed above, the re-siting of the roundabout at the east of the proposed development would restrict access to the Prestonhall East site. We urge, therefore, that you coordinate with fellow Council Officers and determine whether land for a recycle centre should be allocated in the Cupar North proposal or, whether that should be facilitated at Prestonhall East.  An early decision is needed. We would support the allocation of land at Prestonhall East and consider that this is a better suited location rather than in a predominantly proposed residential area.

Relief road:  CDT supports the construction of the relief road in the early phases of the proposed development and do not wish to see any step back from the predicted finish date of 2031. It is intended that the Relief Road is completed by the 600^th home per the Adopted Local Development Plan. 2031 is the estimated date for completion however clearly this will be dictated to by market conditions and house completions. We trust that you will oversee the implementation of a suitable Traffic Management Plan to minimise disruption and inconvenience to local residents, with an emphasis on safety and acceptable air quality. We anticipate that Fife Council will seek details of our Construction & Environmental Management Plan (CEMP) as part of any future detailed planning application – this is normally governed by planning Condition at PPP stage – any CEMP will cover details including traffic management and noise, dust and vibration control measures.

Roundabout at Cupar Trading Estate (east end of the development):  As mentioned above, the relocation of the roundabout at the eastern edge of the proposed development will now lead to questions about how the present Cupar Trading Estate and the Prestonhall East site will be accessed. We note the suggestion of direct access to these sites from the A91 at Ferniehall cottages. We view the access to the trading estate and Prestonhall East as a matter of the highest priority and access points must be clarified to allow much needed future development to take place. We now seek a firm commitment from Fife Council to open up access to employment and commercial land at the east end of Cupar to support business growth and employment opportunities in the area.  We support the Prestonhall East development and would encourage the Council to assist with access but again, suggest that direct access can be taken to the site from the A91 or indeed directly via existing roads within the existing trading estate plans show that the roundabout on the western edge of the proposed new development has been relocated to serve the new Gilliesfaulds development. This removes the possibility of developing land at the western approach to Cupar for business use. We understand that Gilliesfaulds planning consent includes business land accessed from the new roundabout shown on the approved plans – the new western roundabout location (it was adjusted very minorly) will suitably service this land.

Active travel routes:  We welcome proposals for active travel routes along Kinloss Drive, Bishopgate, Bank Street and St Mary’s Road as a means to allow safe, active travel options and to assist with integration with the present Cupar town centre. These routes should be segregated from vehicular traffic wherever possible to allow safe passage for children. The revised plans still lack a suitable active travel route running from west to east, and this should be addressed. In addition to the internal roads which includes a public transport route, a path catering for pedestrians and cyclists is proposed along the site’s southern boundary extending east-west across the entire site. CDT also note from our public consultation exercises that the community have repeatedly called for a connecting route from the Elmwood SRUC site to the proposed new development, as a means to access Bell Baxter High School, the sports centre and the southern reaches of the existing town. We urge you to ensure that this connecting route to Elmwood is incorporated into the plans. The path catering for pedestrians and cyclists extends from Balgarvie Road to the A91 following the existing core path located on the western boundary of Elmwood SRUC – other existing routes already exist through Duffas Park.

Land allocated for future healthcare facilities:  Please note that our CAP consultation responses mentioned extreme difficulties in accessing NHS dentistry services in our area. Noted however Dentists are effectively private businesses and tend to follow demand. We are unable to provide a conclusive response to this point which is not only a local issue but country wide.

Land allocated for community allotments:  We support this. There have been calls for additional allotment space during our LPP consultation. Good, we are looking to provide this early in the process and would welcome the opportunity to work with you on delivery.

Green spaces:  We support the new plans that allow for an even distribution of parks and enhanced green open spaces throughout the proposed new development, with a larger area than on previous plans. We also welcome the provision of playparks and outdoor play spaces for children and families. Noted, having listened to previous Planning and community feedback and we changed our plans – we are pleased that they now meet with your approval.

Recreation and community centres:  CDT notes that these have been removed from the new plans in favour of more green spaces and open recreation ground. We support this decision as the existing facilities in Cupar town centre would benefit from additional footfall, which will help to ensure their financial sustainability. We don’t recall having proposed community centres however we do support the regeneration of facilities in the town centre and we would welcome dialogue on how we can assist with this. Also, we suggest that the new Primary School would be able to serve as a valuable dual purpose community asset should Fife Council wish to consider.

Visual impacts:  We note from the LVIA that there are predicted to be severe visual impacts for several properties surrounding the new development and for the wider area, and would encourage the use of appropriate tree planting options as a method to limit the visual impact of the new development. We have submitted Landscape proposals as part of the application to assist in mitigating any visual impact as much as possible.

Flooding:  Fife Council will be aware of the serious flooding issues that continue to plague the eastern end of the proposed new development site (including the Cupar Trading Estate and residences in that locale). With frequent and intense, heavy rainfall, water cascades off the hills to the north of the A91 (within the boundary of the site of the proposed new development) and routinely floods the road and the Trading Estate. We seek assurances that you will examine whether the re-siting of the relief road and the roundabout at the east end of the development will exacerbate the flooding. We also seek assurance that suitable and sufficient mitigation measures are put in place to remediate both current and any elevated risk of future flooding in this area. It is the community view that SUDS will be overwhelmed by these new weather patterns, and more robust measures will be required. Any development on the site including all roads and other infrastructure are required to incorporate Sustainable Urban Drainage (SUDS) measures which collect, attenuate and control rainfall release into the nearest watercourse or sewer – our SUDS proposals are submitted to the appropriate statutory bodies for approval as part of the planning process.

SUDS drainage ponds:  CDT is concerned that no plans for maintenance and cleaning of the SUDS and culverts has been suggested by the developers. There must be a suitable maintenance plan in place for these as the increased intensity of rainfall has resulted in blockages in existing culverts and has exacerbated recent flooding events in Cupar town. SUDS and road culverts of the proposed relief road will not function if they are allowed to block. Once constructed by the developer per the approved details, Scottish Water and/or Fife Council are required by statute to adopt and thereafter manage and maintain any SUDS features.

CDT have an overall concern about the use of 1:200 flooding event models (with climate change upshift). Recent events have shown that Cupar town may suffer from increased instances of high intensity rainfall events and consequent flash flooding.  We are also concerned that the Flood Report states that the proposed development will cause a loss of floodplain in eastern areas in order to create the road embankment, and recommends compensatory storage elsewhere. We seek assurances that some of the proposed compensatory storage locations (such as possible flooding of sports pitches and the mention of an area close to Kilmaron school) will be fully discussed with the local community. We also seek assurances that flood risk will be fully investigated and mitigated in line with NPF4 guidelines. The Flood Risk Assessment (FRA) submitted with the PPP application considers the 1 in 200 year predicted flood event with an additional consideration of climate change in line with NPF4 requirements – the FRA identifies that there are historic flood issues relating to the Lady Burn adjacent to Balgarvie Road and where possible, our detailed proposals will mitigate these issues as far as they relate to the site – the FRA also identifies that the construction of the relief road will have some impact on the existing flood predictions but our detailed design will propose mitigation (in the form of locally reducing levels to the north and south of St Mary’s Road) that will not only address any increased flood predictions but provide additional mitigation as far as possible – it is worth noting that the proposed primary school site is considered against the 1 in 1000yr flood event in line with legislation thereby ensuring it is unaffected by such events – finally, it is worth pointing out that we are not proposing any sports pitches that relate to the proposed school within any areas that flood before or after mitigation.

Sewerage:  CDT notes that the EIA suggests that the existing sewage system has insufficient capacity for the proposed new development and that an upgraded system would be required. We would welcome an upgrade to the existing provision as a means of addressing existing flooding issues, some of which are felt to be caused by the existing drainage system. When linked with the flooding risk, we feel this is an area of significant concern that should be addressed before proceeding. Scottish Water have confirmed that, in respect of sewerage, there are no network issues and no mitigation is required – as we are introducing SUDS which effectively controls surface water discharge, the development will not impact on the existing surface water sewers.

CDT would be grateful for the opportunity to discuss and enlarge upon these comments with you, in person.  Please let me know if that will be possible.

Yours sincerely,

Tony Miklinski CBE

Chair, Cupar Development Trust

 

Thanks for reading.