Borders Main Issues Report 'premature and inappropriate'

by DOUG COLLIE

The consultation on Scottish Borders Council's so-called Main Issues Report (MIR) in preparation for the region's second Local Development Plan attracted more than 300 responses from organisations and individuals.

An indication of how the public has reacted to the MIR, setting out priorities and possible policies on housing and other aspects of development, is expected to form a report to members of the local authority next month.

The publication and formal representation phase of the key LDP2 is scheduled for winter 2019/20 with an examination of the proposals to follow in summer 2020 and adoption of the plan in early 2021.

It is already evident that future levels of housing construction will be one of the main topics for discussion, and several of the MIR submissions focus on the need for new homes.

Homes for Scotland [HfS], 'voice' of house builders across the country, have criticised the MIR in their submission to SBC.

According to HfS in preparing a LDP, the planning authority is to “ensure that the plan prepared is consistent with the strategic development plan.

 

"Homes for Scotland is therefore surprised that Scottish Borders Council has taken the decision to prepare, publish and consult on its MIR as the first statutory stage of its new LDP at this time without an approved Strategic Development Plan (SDP) in place.

"Homes for Scotland believes that the publication of the MIR is premature and when SESplan2 [South East Scotland Plan2] SDP is approved, it will have to be amended accordingly. The necessary amendments to the number of new homes that require to be delivered over the LDP plan period after the approval of SESplan2 by Scottish Ministers in due course, will substantially change the plan’s course."

The umbrella organisation has asked that the Council provides a far more detailed Housing Technical Note to explain in a robust and transparent way how all of the assumptions within the ‘Planning for Housing’ chapter of the MIR have been reached, to allow all parties to be able to analyse these, and comment on their appropriateness. 

In a section of their report dealing with housing land allocations Homes for Scotland say: "HFS would support a range of sizes and locations of sites being allocated within the emerging LDP to support different scales of home builders from small scale home builders, to larger home builders.  

"This would allow a range and choice for the delivery of new homes.  An over reliance on smaller scale sites will not allow meaningful and sustained housing growth in the Borders to be achieved to help build communities and stabilise the population. This requires some larger sites as part of the range of allocations.

"Given the nature of the Scottish Borders, we recognise that there are opportunities for small scale home builders to operate and flourish in the region, and we would like to see the inclusion of policies to support these small scale home builders in particular, to help to strengthen and encourage this sector of the market, as well as overarching policies supporting the delivery of homes more generally."

In a forthright conclusion to their report HfS declare: "HFS believes that the publication and consultation on a Main Issues Report at this stage, in the absence of an approved Strategic Development Plan to be premature and inappropriate. Furthermore, given the level of uncertainty over the methodology within the assumptions in the Housing Technical Note, we question the accuracy on all levels of the housing numbers provided within both the MIR and the Technical Note."