Paper 1 SVDLS 2013 (1) Scottish Vacant and Derelict Land Survey(SVDLS) Working Group Feedback on new guidance issued for the 2013 survey Background Guidance for completing the SVDLS had become out-of-date and overly complicated and so for the latest survey we updated and clarified the guidance. Once the 2013 survey had been completed we then contacted all Local Authorities asking for their opinion of the new guidance. The following are the collated responses to the questions that we asked. Question 1: Templates Most Local Authorities use the templates that we provide. Did you have any difficulties with these? Replies: Renfrewshire N/A as I prefer to use our existing database / datasheet and delete the fields not required for SVDLS. My reason for using my database is that it has additional fields which allows me to keep everything in the one place, verify other values and, generally, is just helpful when checking and changing data. North Lanarkshire We appreciate that you accept data from us which does not strictly adhere to the template. This flexibility is beneficial to us in trying to keep to the submission deadline. Glasgow No although Marcos had to be disabled so I wasn’t able to use the check button. Other LAs that replied that there were no problems with the templates were: Edinburgh, Eilean Siar, Stirling, East Dunbartonshire, West Dunbartonshire and Perth & Kinross. Question 2: Vacant or Derelict Sites Did you have any problems knowing how to categorise a particular site? Please explain. Replies: Glasgow No, the guidance was clear on what should be classed as derelict land, vacant land and vacant land and buildings. East Dunbartonshire No problems this year - we only had a small number of changes, none of which were unusual in any way. North Lanarkshire General Comments The definition provided in the guidance still infers that “vacant land” and “vacant land and buildings” are related. We disagreed that “vacant land and buildings” is ”vacant land” with a building on it. We feel that the definition for “vacant land” explicitly prevents this: Para 3.1 of the Guidance states vacant land “must not be in use… or include a useable building”. Obviously if the building in question is not useable then this can be considered an impediment to the development of the site and allow it to be categorised as “Derelict Land”. Otherwise the issue is about accurately defining the site with the useable building on it (including access arrangements) and not including it in our consideration of the remaining (presumably redevelopable) land. Specific Site Comments There were a couple of specific examples where sites were removed from the register because they no longer met the definitions for inclusion within the survey. This included the “Mexican Hat” bing where the site became a scheduled monument in 2003 Drumbowie Farm Anti Aircraft Battery which was scheduled in 2005 Sites close to the Antonine Wall World Heritage site We have treated these sites as definitional removal (Cat 34) as there was no obvious alternative in the guidance. However, we think that these sites should be recorded as having a new use… such sites could be given a new coding to reflect their archaeological value. This approach could also be used to address sites given a SSSI or other designation that effectively prevents rehabilitation. Other LAs that replied that they had no issues were: Edinburgh, Eilean Siar, Renfrewshire, Stirling, West Dunbartonshire and Perth & Kinross. Question 3: Adding, Amending and Removing Sites Did you have any difficulty knowing how to add, amend or remove sites? Please describe. Glasgow I was confused about how to record partly redeveloped sites on the SVDLSB list. Page 13 4.2 states that a new site code should be given but when clarifying with Dorothy I was advised to use the original site code. Perth and Kinross We also had to consult Dorothy regarding the coding of partly developed sites in both SVDLSA and B. Previously we had coded these sites alphanumerically (e.g. 403A and 403B). The need to class the field as either alphanumeric or numeric in the GIS system has stipulated using a simple numerical code this year with the same code for each dataset (e.g. 403 in both datasets). I would suggest this is the simplest way forward. East Dunbartonshire We have a site which has been on the register since 1988 and will almost certainly never be developed for any future use. It is semi naturalised but has some old, unsafe buildings on it. I am unsure about the value of retaining sites like this on the register but there is no obvious category or code for removing it. North Lanarkshire We feel the procedures are fairly straightforward albeit a good knowledge of GIS is a prerequisite for our handling of this dataset. We identified a minor issue relating to the frustration of collecting survey data for sites that turn out to be marginally too small to be included within the survey. These cannot be checked until measurements have been done back in the office. This is frustrating because in many cases very prominent town centre sites which would benefit from rehabilitation are excluded from the survey due to their small size. That said it is understandable that we have established size thresholds to ensure that very small (insignificant) sites do not clutter the survey. One longstanding issue is that we feel that there are benefits to tracking a site from inclusion to removal. Once sites are on the Register they should be dealt with through to their removal and not just disappear in bite size (<0.09ha) pieces. This year there were two instances in NLC of partial take up of sites resulting in the ‘disappearance’ of land parcels smaller than 0.1ha. It is our view that for the survey to be comprehensive details of take up should be accurately represented on the BList regardless of their size (it’s likely we record them anyway) rather than simply having them ‘disappear’ because they are too small. Argyll & Bute 1) I have had difficulty with a couple of sites where it remains hard to tell whether some kind of yard/storage activity is on-going. Basically if there is some very low key and occasional storage of equipment or materials on part of site it can be hard to quantify if the site should be on SVDLSA or not included/removed as it is technically being used for some form of storage (albeit very low key). It is likely down to a matter of making a best interpretation but any advice or case examples that the guidance can provide would be helpful. 2) We have got some historic sites on the register as vacant land where what appears to be a former greenfield site has been prepared for new housing (land levelled and prepared, roads laid out etc. (These are included on the basis that they are not previously developed but have only had basic ground preparatory works to create a development platform). With some of these sites their final development to housing can be very piecemeal with single units being built on individual plots while the rest of the site remains dormant in it’s prepared state. This raises the issue that when I remove these bits that have been built out they are often too small to include on SVDLSB and therefore, similar to how other people have mentioned, a whole large site could incrementally disappear off SVDLSA without mention in SVDLSB. 3) Some further guidance as to when to remove a site from SVDLSA would be helpful. It isn’t particularly clear whether this should be at the point that works on the end use have first commenced or when the works have been completed. If a site is removed at commencement of works it could become apparent that the developer is only commencing one stage and that a wider part would remain vacant/derelict and then would need to go back on the register when actually it should never have been removed. 4) Some guidance or examples of removal through naturalisation would be useful as it possible that different authorities will consider that naturalisation has taken place at different points to others. At what point do local authorities feel that sites covered with scrub, grass, saplings etc have become naturalised? Do they have to blend into wider natural surroundings or can ‘pocket sites’ in urban areas become naturalised? (Some sites could be seen as blending less clearly into a natural state if they are surrounded by urban character.) Other LAs that replied that they had no issues were: Edinburgh, Eilean Siar, Renfrewshire, Stirling & West Dunbartonshire. Question 4: Variable descriptions Did you have any difficulties choosing the code for any variables in either the SVDLSA or SVDLSB data? Please give details. Glasgow SVDLSB – NEWUSE variable. For a few developments I contacted Dorothy for advice on what they should be classified as but this is more due to my inexperience rather than the guidance. East Dunbartonshire The only issue I had was under the TIMEVD variable. I entered a new site, but the site had actually been vacant for a considerable period and was missed during previous surveys. Therefore the INSPYY and TIMEVD fields did not correspond. It may be useful to have some wording to the effect that this can happen from time to time. Perth and Kinross We also had issues with the INSPYY and TIMEVD fields not corresponding. North Lanarkshire DBHIST While it is useful to know whether a site has previously been identified in the survey, as time goes by the expectation is that more sites (or parts of sites) will re-appear following a further phase of development followed by dereliction. Through the use of GIS systems the re-occurrence of dereliction is easy to establish by comparing datasets over time. Relying on the user to indicate whether sites had a previous history is therefore redundant. In cases where part of a site had a previous history should these be handled in a different way? I have noted a number of these instances in the NLC return where the field has been tagged differently to clarify the site history of certain sites. The NLC submission of SVDLS-A has used 4 fields to describe the “history” using the following:1 - New Record 2 - Previous Record 3 - Part of Previous Record 4 - Split Site I would be interested on your thoughts on the use of this field and whether the above approach would be helpful in tracking changes to the data or whether it is redundant because you hold a historic record of the location of each site. SITETYPE If possible we would suggest that the Derelict Category which has been labelled as “11” should be changed to “12” to ensure continuity of data to match the previous code for Derelict Land. This would also make comparison of historic data easier as there would be no need to recode the previous Derelict Land Category. INTRLOCN2 The determination of settlement boundaries tends to be through local plan designation and in many cases it is often unclear what constitutes the extent of a settlement and again there is likely error in this process, especially if settlements are in or around the 2,000 mark. While we appreciate that it may be useful to differentiate between urban and rural sites, the method of collecting this data through the VDLS is odd. Given that you hold the information about which areas you consider to be a) urban, b) settlements over 2000, and c) settlements under 2000, and that this does not necessarily match what we might consider to be our settlements. It therefore makes sense for this to be done consistently by you using GIS systems and your own layers for settlements rather than asking each authority to undertake the task for their own sites. PREVUSE We have some concerns that this field is based on very old definitions of activity which means that some uses are not covered at all apart from being labelled as “Other” for example garages / pubs, etc. There is no information relating to Use Class in the dataset and I think that this is something we might want to have a look at given that it is a key feature of land use planning policy and how development is classified. DERCHAR Using the characteristics of dereliction was fairly straight forward although in the case of a site a “Gartcosh” part of the dereliction was due to the presence of Great Crested Newts (the site cannot be developed until these are translocated) and we spent some time discussing how this should be addressed. In this case category 2 seemed relevant although we suggest adding “Removal of Protected Species” to the listed elements for Category 2 to make this clear. NEWUSE Adding a category: Further to the comments for 2 above relating to the sites removed which had achieved an “archaeological” status. It is suggested that a new code might be required to cover instances where sites achieve a value based on their unique site characteristics. Not sure if the Green/Environmental field needs to be expanded or a new field created such as “Site Designated for Nature Conservation / archaeological Purpose”. Removing some redundant categories: We have some concerns regarding the use of Cat 31 and Cat 32 and it would be useful to consider when you expect these to actually apply and how frequently these codes have been used. It is our understanding, from the guidance, that the B-List is about the removal of sites from the register, largely this is through their development / rehabilitation / naturalisation or removal where they no longer meet the prescribed definitions for vacant or derelict land. NEWUSE describes their new use – not the actions taken to remove them. In the case of: Cat 31 sites, in all cases these sites have not been removed from the Register but merely subsumed within another site. We would deal with these by adjustments to the A-List with relevant explanation. They therefore would not form part and should not form part of the B-List and won’t have a NEWUSE code. Cat 32 sites where they have been split into smaller sites and then removed. This code makes no sense. If a site is removed during this VDLS, regardless of its size or previous size, then it should have its own NEWUSE code describing why it has been removed – i.e. Housing, Industry etc. These sites appear in the B-List anyway along with their relevant ‘development reason’ for removal (which won’t be Cat32). There is therefore no need for this category as it would appear to be redundant. Cat 25 sites, sites which have been Reclaimed to Vacant pending New use, we can not see why anyone would use this code. The data about whether the site is vacant or derelict is collected elsewhere. There does not seem to be an equivalent (and more likely vacant to derelict category) and we think this category is redundant and only likely to lead to double counting. Highland NEWUSE One observation in terms of new uses – you don’t have anything for marine or port development for example Wondering how to class redevelopment of fish farm site redevelopment of Nigg Other LAs that replied that they had no issues were: Edinburgh, Eilean Siar, Renfrewshire, Stirling & West Dunbartonshire. Question 5: Any Other Comments or Suggestions? Angus I am content with the current templates, arrangements and definitions. Only comment is that we generally use a simple 12 figure grid reference in our corporate GIS and Uniform. It is sometimes confusing when dealing with prefix’s like NO or NN at the start. East Renfrewshire I have no particular spectacular/startling comments. Just to say that it has been very useful and well used. The Planning technician who helps to undertake the survey is deaf therefore the method of carrying out the survey and following the guidance in a clear, straightforward and methodical way which is not overly wordy is especially invaluable for her and her interpreter to follow. With this in mind one wee tiny point is that it may be an idea to put the page number next to the field label show on the 2013 guidance P17 & p25. Otherwise you tend to be flicking back and forth with the pages which can be a bit cumbersome. East Dunbartonshire There may be a good reason why this isn't the case, but it would be useful if the template for the 'B' dataset (sites removed) included a field for the name and address of the sites removed, to allow for easier identification, rather than having to refer to the sitecode. Glasgow The guidance was useful and straight forward. It certainly helped me through all the stages of completing the survey. Scottish Borders Just to confirm that we at Scottish Border Council had no issues with the new guidance and format. I had not been through the process before, so cannot compare it to the previous format, but I asked my colleagues who are also involved in the process and the feedback was only positive. North Lanarkshire Para 3.5 of the Guidance suggests that if there is doubt about whether a site requires rehabilitation then it should be classified as vacant land rather than derelict land. From our experience of undertaking the survey we would suggest that this assumption is unhelpful. Dorothy, you might recall the site that we looked at in Coatbridge which appeared to be a flat, open, and developable site in 2007 and 2008. It was granted planning permission in 2009 and then once preparatory work began, massive concrete slabs were uncovered in 2012. Fortunately the site was able to tap into several assistance funds and has been developed – see 2013 photo. Our experience suggests that this is not a one off and that in many cases land that appears to be “vacant” on the basis of what it looks like – e.g. sites that are relatively flat, cleared and clean, may actually still require significant rehabilitation in some way. We have been working closely with our regeneration colleagues on this and have become aware of several seemingly attractive sites which have subsurface issues (i.e. undermining, subsurface foundations, or other ‘invisible’ type of dereliction). Unfortunately this has often been discovered after the site has been added as vacant and has required us to ‘downgrade’ sites to derelict once that information has been confirmed. In light of this I would suggest that in cases where we know that there has been a previous use likely to have resulted in characteristics of dereliction e.g. manufacturing works requiring the removal of concrete foundations, and where we have no evidence to indicate that this has been properly removed then we should be considering defining this as derelict for that reason. This is clearly a difficult consideration to make and each assessment will have to be undertaken on its own merits but we think its something that the group may want to discuss. Annex A Examples: Based on the above comments regarding the issue of land and buildings, we feel that Annex A is unnecessary and falsely suggests that all vacant schools / factories, etc that have associated land should be on the SVDLS. The key to inclusion in the survey is whether a site can be defined which meets the definitions in the guidance – not whether we can change the definition to ensure that a site is included. Argyll & Bute Generally I find the both the guidance and returns spreadsheet relatively easy to understand and complete. Perth and Kinross We are hoping to link our SVDLS and ELA with the UPRN this year to have a more standardized code for cross checking and database linkages across the Council but will omit this from the returns. We also prefer to use Eastings and Northings rather than an OS Grid reference for ease of use within our corporate GIS system Other LAs that replied that they had no issues were: Edinburgh, Eilean Siar, Renfrewshire, Stirling & West Dunbartonshire.