1.

Shortcomings of the Environmental Statement

2.

Errors in the Site Option Appraisal

3.

Opening the southern hillside to development

4.

Prematurity

5.

Traffic impact

6.

The viability of the town centre

7.

Visual impact on an Area of Great Landscape Value

The site layouts under the design options for the Largo Road site betray a mind-set which regards the views from the buildings as of far greater concern that the visual impact on the landscape. The consequences of a flawed choice of site are compounded by an indulgent approach to site layout. All of the three design options would result in much more environmental damage than is necessary, even on the proposed site.

8.

Loss of a designated business site

The problem of finding business and light industrial sites in St Andrews is far from easy. Surrendering the designated one on the Largo Road before an overall solution has been found in the Local Plan exercise seems ill-advised.

9.

Noise

The proposed site would be much noisier for patients than the present Memorial Hospital due to traffic noise, particularly the many HGV movements in the area.

10.

Proximity to the recycling centre

11.

Proximity to the Tetra mast and mobile phone masts

0.1

Further information on each of the above objections is given below. For ease of cross-referencing, the first digit of paragraph numbers tallies with the above objection number.

0.2

We would first, however, wish to record that we are very unhappy with the way in which the NHS has handled this process recently, putting us into the position of having to object to a hospital. For eight or nine years after the meeting in the Rusacks Hotel in December 1993. we worked with the various changing NHS Trusts with a primary aim on our part being to prevent any conflict between the health needs of the town and its broader planning needs. For many years, we had seats at the table, and, in particular, provided input for the Outline Business Case for the hospital. Since 2003, when the NHS abandoned its earlier declared preference for the St Leonards Fields site and chose the Largo Road one instead, we have effectively been excluded from the team. Repeated requests for the detailed reasons for the choice of the Largo Road site were left unanswered. This appears to have been a very deliberate decision. Had the decision been subject to immediate detailed scrutiny at that point, it would not have been possible, even allowing for the delay between the taking of the decision in early 2003 and its publication at the start of the school summer holidays in that year, to claim that reconsideration of the site would cause delay. We would assume that there was an awareness of the weakness of the case that would be presented for public scrutiny, and there seems to have been a calculation that waiting 17 months before revealing it would make it easier to present the matter as a fait accompli. There was clearly some confidence that the well-documented preference of the local community for St Leonards Fields could be brushed aside when the time came to apply for planning permission, or else it would not have been rational to pursue the path they chose.

1.1

Alternative sites. In our response to the Scoping Report for the EIA, we indicated that, as the principle that a new hospital and healthcare facility should be built is not dispute, our view was that “site selection is the major issue, which should form the greater part of the ES” (Environmental Statement). We noted that PAN 58 (para. 69) says “It has always been good practice for the ES to report on the alternatives considered by the applicant and it is a requirement of the 1999 Regulations”. In its scoping opinion Fife Council asked the developer to “Please also note the fundamental requirement to consider alternative sites in addition to the one subject to the proposed development”, whilst Appendix 2 of that opinion listed the “Rigorous and transparent assessment of alternative sites” as one of the key issues. We submit that the consideration of alternative sites in the Jones Lang LaSalle (JLL) ES is neither rigorous nor transparent. We have noted with interest the argument of the St Andrews Green Belt Forum that a failure to ensure that all environmental options have been adequately considered, or to make this evidence available for public inspection prior to the granting of planning consent, would leave the local authority open to possible judicial review. Whilst the focus of their argument was the visual impact of the proposed development, we would contend that similar considerations apply to the more fundamental question of site selection.

1.2

Missing maps. A first basic element of a comparability study is that the options be clearly defined. In this ES, no maps are provided of the alternative sites at St Leonards Fields and the Craigtoun Road, and no attempt made to give the public a clear idea of what the alternatives were. This vagueness means that readers often have no way of assessing the comments made against their own knowledge of the area.

1.3

Bias. Another key requirement of a comparability study is that you judge all the candidate sites by the same criteria. This is acknowledged in section 5.7 of the ES, which lists 10 criteria used in JLL’s cost appraisal exercise. No attempt is made in the ES to provide a systematic comparison of the three short-listed sites under each of these 10 criteria. Some of these aspects are addressed in sections 5.4 and 5.5 for the St Leonards Fields and Craigtoun Road sites respectively, but there is not even a corresponding section for the Largo Road site, with section 5.6 moving immediately to consideration of alternative designs for that site. Section 5.7 provides just four relatively brief bullet points in support of the chosen site. This falls far short of providing a transparent exhibition of the environmental options to the public.

1.4

PAN 58 (para. 66) says that in an ES (Environmental Statement), “Conclusions should be drawn from the data, rather than tailored to favour the proposal”. The JLL comparability study is largely devoid of numeric data, and it is not just the conclusions, but rather the whole discussion which is tailored to favour the proposal.

1.5

AGLV designations Section 5.5 says that the Craigtoun Road site is “located within an Area of Great Landscape Value, and the land could potentially be designated as green belt...”. The ES fails to record that part of the Largo Road site also has an AGLV designation, and could also potentially be designated as Green Belt.

1.6

Conservation Area requirements The impact of these requirements on the St Leonards Fields site is exaggerated. In §5.4 the ES refers to “the constraints on the building massing and form, and material specification as dictated by the sensitive setting of the site.” The pertinent point here is in fact acknowledged, but then forgotten earlier in that section. It notes that St Leonards Fields “lacks visual prominence from the main roads and is well screened in terms of the existing mature landscaping”. As the proposed hospital will only be one or two storeys high, it makes no sense at all to pretend there is a major problem here. The Largo Road site is far more sensitive.

1.7

Transportation. The transportation problems of the St Leonards Fields site have also been exaggerated. If the problems over visibility splays were as great as we are led to believe, one would expect Fife Council to have noticed. Yet Fife’s transportation officials repeatedly indicated their preference for St Leonards Fields over several years. (See sections 2.22 and 2.23) In terms of accessibility, it has long been our view that the St Leonards Fields site is best placed, being closest to the area of town in which car ownership levels are lowest.

1.8

Visual Impact Section 5.5 says that the Craigtoun Road site would require “additional screening to address views into the site from the north”, giving the impression that a hospital on the low-lying land of the Kinness valley would cause significant visual impact problems. The site comparability section of the ES fails to record the far greater problems of visual impact associated with the Largo Road site.

1.9

Services. Section 5.5 says that the Craigtoun Road site “contains a major Transco distribution gas pipeline that bisects the site.” For the Largo Road site, there is a declaration in section 13.2 that “A gas main crosses the site underground from north to south and a high voltage power line also crosses the site overhead from east to west”. The site comparability study in section 5 chooses, however, to remain silent about these two features.

1.10

Ownership The ES is inconsistent on the question of ownership of St Leonards Fields. §5.4 says that “elements of the site” have passed into the control of the developers, thus suggesting multiple ownership, whilst section 5.8 indicates that the site is “in the control of a third party.”

1.11

The comparability study tells us that the owners of the two rejected sites may aspire to housing developments on their land. The reader is supposed to believe that nothing could be further from the mind of the Muir Group, with their extensive holdings on the southern hillside.

1.12.

Para. 3.3 of the Scoping Report indicated that the assessment “will revisit past site selection exercises”. Section 5.2 of the ES reports that the previous consultants, RPS Consultants, identified three sites as having the greatest potential. We understood that RPS, however, had viewed St Leonards Fields as being the preferred site. There is no explanation in the ES for the divergence in the conclusions of the two consultants.

1.13

In our advice on the Scoping Report (Para. 17) we specified the general comparative approach that we would find acceptable in the Environmental Statement. We wrote “The methodology should include a precise statement of the site requirements, and a careful and fully justified evaluation of how far each candidate site meets each requirement. The same criteria should be seen to be applied to each site, and with an equal degree of rigour. Where problems are identified with a site, the extent to which they could be overcome or mitigated should be specified and an approximate indication given of any ensuing costs. There should be a clear distinction between inherent properties of a site and considerations of its likely availability.” The Environmental Statement as submitted fails on every sentence in this paragraph.

1.14

More crucial, however, is whether the ES satisfies the requirements of Fife Council’s Scoping Opinion. (See Appendix 3) This includes, “particularly significant matters to be addressed under each of the topic headings”. A range of these topics is not addressed at all:-

2. Site selection

1.15

The final item on this list is a reference to the methodological concerns of the Community Council, which Fife Council thus deemed to be “particularly significant matters to be addressed”. Very few of these points have been taken on board.

1.16

One item under “Policy and regulatory context” is the St Andrews Strategic Study. The ES covers this very briefly, despite the fact that the Strategic Study is the most recent authoritative statement of the views of the local community on the future development of the town. The ES fails to mention the relevant Study Conclusions:- “5. The landscape setting of St Andrews is crucial to its character and must be protected and enhanced.; 20. The community supports a new hospital for St Andrews, the preferred site being at the existing Memorial Hospital”.

1.17

The letter from the Planning Division of the SEDD to all Heads of Scottish Planning Authorities (ref PGD/5/12) says in para 19.1 “The planning authority should be prepared to challenge the findings of the ES if it believes they are not adequately supported by scientific evidence. If it believes that key issues are not fully addressed, or not addressed at all, it must request further information. The authority has to ensure that it has in its possession all relevant environmental information about the likely significant environmental effects of the project before it makes its decision whether to grant planning permission. It is too late to address the issues after planning permission has been granted.”. We would urge Fife Council to follow this advice.

2.1

The problems with the site comparability discussion in the ES cannot be resolved by just asking the applicants to rewrite it in a more thorough and logical way. Inspection of the JLL site option appraisal (SOA), which we obtained under the Freedom of Information (Scotland) Act, shows that the shortcomings are not simply presentational. The information from the Summary Sheet in the SOA is given as Appendix 1 to this letter, with a revised layout to assist legibility.

2.2

As the basis for a comparative study in an ES, the ten criteria used in the JLL SOA provide an uncertain foundation, being a mixture of environmental and commercial factors. There is also an unhelpful degree of overlap between the factors with essentially the same point making repeated appearances. Nevertheless, for brevity, we will organise our remarks according to their structure.

2.3

JLL gave each site a score under each of the ten chosen criteria and formed a weighted total. The weights, described in the SOA as percentages, sum to 94%, but the lack of a standard normalisation does not, of course, affect the relative outcomes. On the basis of weighted totals of 3.91 for the Craigtoun Road site, 5.27 for St Leonards Fields and 6.17 for the Largo Road, the last of these sites is deemed to be the best choice. The impression given here of scientific accuracy is highly misleading. It is highly debatable whether these answers have any real basis when rounded to the nearest integer, never mind two decimal places.

2.4

To see the frailty of JLL’s conclusions, we consider in detail some of the arguments under some of JLL’s criteria:-

2.5

Visual and Landscape

2.6

Transportation

2.7

Site characteristics

2.8

Ownership

2.9

Infrastructure

2.10

Value

2.11

Heritage

2.12

Perception of Trust

2.13

Planning

2.14

Deliverability

2.15

Numerical Comparison

2.16

Our revised scores are shown in the table below. Where the score awarded by JLL differs from ours it is given in parentheses. In judging our assessment, readers should note carefully the manner in which each of the JLL criteria is implicitly defined by the various sub-criteria in their text: the resultant meaning of their terms is not always what might initially be expected. The correspondence between our chosen scores and the corrections to the text described above should be apparent.

2.17

The most substantive changes we have made are under the “Visual & Landscape” criterion, for which JLL’s assignment of equal scores must appear an absurdity to anyone acquainted with the topography of the town. It is evident that the Largo Road site is the most damaging in landscape terms, whilst the Community Council has pointed out for very many years that, of the sites on the periphery of the town, development of those on the relatively low-lying ground near the Craigtoun Road would cause the least damage.

2.18

Our scores on the relative transportation merits of the St Leonards Fields and the Largo Road sites are consistent with the recorded view of Fife’s transportation officials (see below). We have left unchanged the scores under “Perception of Trust”, despite our view, indicated above, that some of the information on which it may be based is ill-founded. Equally, as we do not have access to all the information, we have made only minor amendment to the scores for “Value”, again simply correcting for the misconceptions in the JLL summary. Note also the large change we have to the Craigtoun Road site’s score under “Planning” given our assessment that the planning problems of that site have been seriously exaggerated.

2.20

Fife Council’s Site Analysis We include as Appendix 2 to this submission, a comparative site analysis made by Fife Council in 2001. This document was obtained in late August under the Freedom of Information (Scotland) Act, following a request originally made in February. It should be noted that the analysis appears to be incomplete, that the required floor area of the facility is now somewhat larger than was envisaged at that stage, and that there has been a subsequent change to the definition of the Largo Road site which might well have changed some of its assessments for landscape impact.

2.21

It is nonetheless notable that at this stage this analysis gives the St Leonards Field site a total score of 433, as opposed to 291 for the Largo Road and 255 for the Craigtoun Road site. It is indeed remarkable that, under the 17 criteria for which scores are given, there is not one on which the Largo Road site is rated more highly than St Leonards Fields. This document shows very starkly the magnitude of the volte face performed by Fife Council in now including the Largo Road in the draft Local Plan. A sense of betrayal by those who have worked for an environmentally acceptable solution is inevitable.

2.22

Although we have not been told their current view, there is evidence that Fife’s transportation officials retained their preference for St Leonards Fields for some years. In April 2003, Bill Lindsay wrote to Jones Lang LaSalle quoting his colleagues in Transportation as saying, “In terms of accessibility, the St Leonards Fields site provides the best potential access for pedestrians, cyclists and public transport due to its central location. ... As the Largo Road site is easily accessible by car, sustainable travel modes will be less able to compete. ... Fife Council Transportation Services does not agree with the statement that Largo Road is the best site in terms of transportation.” After considering other aspects of the sites, Bill’s conclusion includes “We remain to be persuaded at this time that an acceptable solution at St Leonards cannot be achieved.” The complete text of this letter is given below in Appendix 4.

2.23

The preference of Fife Council’s Transportation Service was also indicated in the Scoping Opinion. They said, “We still consider St Leonards as our preferred site in terms of land use transportation and NPPG17” (Scoping Opinion, Appendix 1, para 10.1). They added, “We still consider that St Leonards should be the preferred location in terms of accessibility, transport and land use.” (Scoping Opinion, Appendix 1, para 10.3).

3.1

Some, including the NHS, have argued that the present application has no wider planning implications. We believe this shows at best a complete lack of understanding of how planning works, and, on the part of the NHS, a convenient lack of memory. A few years back the NHS did indeed show the Planning Committee of the Community Council indicative plans for the Largo Road site which included a road which headed from west to east, its only purpose being to open up further development to the east. The present application is almost as blatant with a potential access road running along the eastern boundary of the site.

3.2

In fact, use of this site makes continued development eastwards along the hillside inevitable. The history of St Andrews over the last decade shows how hard it is to prevent development on the outskirts of the town, even on glaringly sensitive sites on the coast. If consent is granted for the Largo Road site, it seems entirely implausible that Fife Council could put in place any effective protection for the strip of land from the east of the site to the Grange Road. There is no reason to believe that the Muir Group, with its considerable financial resources, has abandoned the intention it has held since 1993 to put an “urban village” of up to 1000 houses on the southern hillside. It is far more plausible that the Muir Group regard the hospital as the Trojan Horse, opening up to them the profits denied them since 1993.

4.1

It is completely inappropriate to determine this application before the planning parameters for the town for the next 20 years are known. The suitability of the site and its ability to cope with the demand will clearly be affected by whether or not the Draft Structure Plan is adopted. In particular, if, as is proposed, the population of St Andrews were to increase by some 16% over the next decade, much of the submitted Transport Assessment will be irrelevant.

4.2

The implications of this application are far-reaching with effects on transportation in the town, on the viability of the town centre, and on the availability of industrial land. We consider each of these more fully below, but what is really needed is a complete overview ensuring that the overall strategy for the town is coherent. We would therefore strongly support a judgement of prematurity with respect to the Local Plan.

4.3

Green Belt A further major implication of this application is for the future of the Green Belt for which the town has campaigned for many years. For us, the two key elements of the Green Belt are the view from the Strathkinness High Road, and the southern hillside from the Largo Road to the sea. If either of these is lost, so too is the rationale for the Green Belt, namely the retention of the landscape setting of the town.

4.4

In fact, the Draft Local Plan implicitly acknowledges the truth of our argument on the inevitability of further development should this application receive consent. It proposes the exclusion from the Green Belt of the whole strip of land that extends east to the Grange Road from the Largo Road site. Mr Bill Lindsay has told us verbally that, at present, Fife Council envisages only a 5 hectare light industrial site immediately to the east of the Largo Road site, but the reality is that the whole strip would be a sitting duck for developers. It would then prove even harder to prevent development to still higher levels of the hillside. The map of the land holdings of the Muir Group presented to the 1994 Local Plan Inquiry, shown in Appendix 5, suggests the pressure for even more development would be considerable.

4.5

In the Scoping Opinion (Appendix 1, para 9.10), Fife Council Development Services said “Both Craigtoun Road and Largo Road options would be considered in terms of the current Structure Plan policy SS8 – Green Belt. The proposal is likely to prejudice the process of identifying the Green Belt and therefore be considered premature in terms of SS8.” It is indeed evident that the process of defining the boundaries of the Green Belt has already been distorted by Fife Council’s response to this application in the Draft Local Plan. This should not be allowed to stand: the hospital application should be deemed premature.

5.1

Trip generation The submission of August 4 from JLL declares that ‘The trip generation estimates are thought to be “extremely robust” as they are based on a pro-rata increase: trips/increased floor area’. Leaving aside the precise nature of this quotient, this appears to imply a scaling-up of current numbers to reflect the increased size. This contrasts with the impression given in the transport assessment (TA) by Colin Buchanan and Partners (CBP). They used questionnaire data to estimate modal choice, but demand prediction appears to be based only on the floor areas of the hospital and the health centre. The TA para. 5.2.3 says “Version 2004b of TRICS database was used to calculate the total number of person trips to and fro the proposed health facility.” The reader is unable to judge the suitability of the given figures, since reference is made to Appendix 5, but the TA concludes with Appendix 4. No assessment can therefore be made of whether suitable comparators have been adopted. The absence of any figures for the usage of the existing facilities is also noteworthy. The only survey work carried out appears to have been by questionnaire. Observational data on the present facilities could readily have been obtained, and the NHS must have at least partial data. Allowance would need to be made for the increase in size, the new services being offered and the larger catchment area, but observational data would enable more robust estimates to be given.

5.2

The staff questionnaire appears to have gathered some data on staff arrival and departure times (though not at lunch time), and on those who would make multiple trips from the hospital during the working day. There is no indication that this information has been used in the production of Table 5.3 on person trip generation in the morning and evening peaks.

5.3

Modal choice It should be noted that the CBP survey of the existing modal choice was conducted during two weeks in September 2004, implying that at most one of those weeks could have been during the University term. The results will therefore be distorted by under-representation of students.

5.4

The survey data given cannot be appropriately analysed without information on the response rates for patient and staff groups. It is highly likely that these response rates were very different, with the response rate for patients being very small in comparison to that for staff. The given modal choice predictions result from naively aggregating the responses from these two groups and excluding those patients who did not answer the relevant question. In statistical terms, this is a stratified survey with two strata, patients and staff, and the appropriate analysis would make allowance for the differing sizes of the two strata.

5.7

Traffic Impact The traffic impact appears to be assessed for 2006. This is inappropriate when the NHS has indicated that the new hospital would not open before 2009. Levels of congestion will also be highly dependent on whether the Structure Plan proposal for a 16% expansion of the town over the next decade is adopted.

5.8

Lamond Drive In the 1990s Fife Council spent £250,000 remodelling Lamond Drive to make it safer following a fatality. This was rapidly forgotten when Fife Council agreed to additional traffic there for the St Andrews Bay Hotel. Many of those from the East Neuk would use Lamond Drive if travelling to a new hospital on the Largo Road site, thus further ratchetting up the potential traffic dangers. There is no investigation in the TA of the impact on Lamond Drive.

5.9

The lack of local knowledge of the consultants is also evident from the failure to investigate the impact on the Lamond Drive/Largo Road intersection. Attempts to enter Largo Road from Lamond Drive already often necessitate long waits, and these would be further extended by the extra hospital traffic.

5.10

Scooniehill Road Another road which would attract further traffic were this application to receive consent is Scooniehill Road. This road is already potentially dangerous, as it is essentially an estate road which is used as a thoroughfare. Problems are often increased by the presence of many parked cars, as most of the residents do not have off-road parking spaces. The dangers are further increased by the daily flows of buses taking children to the Kilrymont Building of Madras College, and by the number of pupils who are pedestrians. Again there is no investigation in the TA of the impact of additional hospital traffic on this road. Although some might believe that the problems of Lamond Drive and Scooniehill Road might be alleviated by a southern bypass, it is clear that this would need to be developer-funded and would only be provided in conjunction with the housing on the southern hillside which the town is so anxious to avoid.

5.11

Staff numbers The paucity of the data on staff numbers is pertinent to several aspects of the TA. The recent supplementary information from JLL says “The total staff numbers in the new facility are estimated at 134”, but no disaggregation is provided into medical/ non-medical, nor any indication of how many of these posts will be full-time. No explanation is given of the lack of coherence between this figure and the 151 members of the existing staff stratum who responded to the CBP questionnaire. Unless CBP ran their survey in a manner reminiscent of a totalitarian regime, it would be extremely surprising if the figure of 151 represented more than a 90% response rate, but, as previously noted, no information on the response rate is given. Is the new figure of 134 intended to be a Full Time Equivalent (FTE) number, or will the new hospital and healthcare facility, with an enhanced range of functions, operate with fewer staff? Is there to be a reduction in local employment opportunities?

5.12

There is no indication that CBP were in possession of good data on staff numbers when selecting comparator sites from the TRICS database, yet trip generation is likely to be affected by staff numbers and the range of facilities as well as simply by the floor area.

5.13

Car parking The statement in para. 5.4.2 that “Based upon current mode share, it is estimated that the car park will be marginally over capacity for only two hours of the day”. This should certainly not be read as reassuring in view of the possible combined effects of the uncertainties in the analysis which we have highlighted. As predictions are being made for at least three years before the hospital will open, the details of the trip generation methodology are not revealed and there is no information given on the lengths of patients’ visits, the reader can have little confidence that the proposed parking provision would be adequate or that overflow problems would not occur for much more protracted periods.

5.14

Closer specification of staff types would also assist estimation of the required number of car parking spaces. Whether it is appropriate to use FTE figures will depend on the working patterns of the staff.

5.15

Obfuscation. As part of the ES, the TA should represent a genuine attempt to communicate the issues to the public at large. The sections relating to the Paramics model are particularly unsatisfactory in this regard. No independent corroboration of the results is possible even by a reader in possession of the computer package, as insufficient data are provided. Parts of the text read like a private conversation with the transportation officials (e.g. “The link from Zone 64 was corrected from bus only to all vehicle.”)

5.15

Questionable reality The reader also gains little confidence that the Paramics modelling will correspond to the situation on the ground. Para. 7.4.1 of the TA appears to imply that the Fife officials believed that the model should include interruptions to town centre traffic flow caused by stationary vehicles such as refuse lorries. CBP seem to have decided subjectively that the effect was unrealistic, and zapped the refuse lorries from the screen. They contend that “In the medium term it is likely that collections would be re-timed to be undertaken outwith the peak hour period.” In practice, town centre traffic flow is frequently brought to a halt by a various types of lorry and by other vehicles. Drivers in Bell Street, for instance, often experience some difficulty in zapping the stationary lorry in front of them.

6.1

The decision on the hospital site will also have major consequences on trading patterns in the town The new hospital will clearly be a major point of activity in the town, and, use of the Largo Road site would give an extra boost to Morrisons at the expense of the town centre stores. This is another reason why the hospital plans should be part of the whole Local Plan exercise, and not taken in isolation.

6.2

We are told that bus services will be re-routed to the new hospital, but the consequences of this have not been explored. At present local bus services are mainly focussed on getting people to the town centre or the bus station. Since it seems fanciful to imagine that there will be any major increase in overall capacity, the assumption has to be that there will be fewer services taking people to the centre. Add to this Fife Council’s ongoing attempts to dissuade motorists from approaching the town centre, and the implied problems for local traders begin to mount.

6.3

The extent of the problems for the town centre traders appear even worse when it is appreciated that any new bus service serving the Largo Road site would also be providing a service to Morrisons. The net effect is clearly contrary to Fife’s supposed desire to ensure that peripheral stores do not damage the vitality of the town centre. Indeed one wonders how far the major expansion presently planned by Morrisons is predicated on the windfall that they would be given.

7.1

Under the current Local Plan, most of the southern hillside of St Andrews falls within an Area of Great Landscape Value (AGLV), and indeed around half of the proposed site has this designation. We noted above that the comparability study in the ES was silent on this point, and it does indeed seem to have played a relatively limited part in their thinking. The intention to “use the slope of the site to benefit views” is candidly declared as one of the design objectives. The views under discussion here are not the views of the AGLV, but the views from within the buildings, as is made clear in para. 4.3 of the ES, which boasts that under the proposed plan “in-patients benefit from the best views”.

7.2

This mind-set is reflected in the three design options, which closely approximate the site layout that yields the maximum impact on the AGLV. For this reason we would urge that consent for this application should not be contemplated before scaffolding has been used to demonstrate the height and the visual impact of the proposed buildings. As we have often noted in the past, a reasonably competent professional can prove anything by using photo-montages.

7.3

In each of the three cases, the buildings are located close to the top of the site, thus maximising their impact on the landscape. Whilst a car park is not a thing of beauty it is far more susceptible to screening than a two-storey building, and hence environmental considerations would indicate putting the car parks rather than the buildings on the upper part of the site. As indicated in section 11 below, placing the buildings at a lower level would also reduce exposure to electromagnetic radiation.

7.4

We assume that the access road to Pipeland Farm Cottages has been located at the eastern side of the site to facilitate further development along the southern hillside. The visual impact of the hospital would be reduced by locating the access road on the western side of the site, thus moving the buildings eastwards, further away from the Largo Road. From a patient perspective, this would also reduce noise (see sections 9 and 10 below).

8.1

On many occasions in recent years, the Community Council has expressed regret when light industrial and business sites have been lost, usually to residential development. The proposed expansion of Morrisons implies the displacement of two further businesses. We are increasingly facing a situation in which tradesmen will be unable to base themselves in the town, leading to a consequential deterioration in the standard of service available to the people of the town. Fife Council’s assessment of the shortage of business land is even more grave than our own, with the Draft Development Plan indicating a need for a huge area for business use in the town. This poses a severe problem as it is far from easy to identify suitable land for this purpose.

8.2

Around half of the Largo Road site is currently designated for business use, and whilst, for many of the foregoing reasons, it is not an ideal site for this purpose, to surrender it when there no agreed substitute appears reckless. The problem will be further exacerbated if Fife Council hands over Bassaguard for housing development, as they have indicated. The Community Council has been strongly opposed to any such move. We are appalled by Fife Council’s suggestion that there be a 5 hectare business site immediately to the east of the Largo Road site. We do not wish to see the southern hillside developed: it should be in the Green Belt.

9.1

The out-patients area of the present St Andrews Memorial Hospital has a pleasantly tranquil setting. We fear that the proposed site on the Largo Road will be a lot less peaceful. Whilst proximity to a major road may be judged advantageous for transportation purposes, the implied noise levels are less desirable. Moreover it is not just the noise of passing traffic with which the selected location would have to contend. Morrison’s supermarket on the opposite side of the road generates a large volume of car movements. The Community Council has also recently been made aware of the problems caused by deliveries to Morrisons. We understand that HGV deliveries start as early as 5.30 a.m. with the latest ones occurring in the late evening.

10.1

Further noise problems will arise when the town’s long-awaited recycling plant, located behind Morrison’s, starts to function. Its presence implies both more car movements and a further stream of HGVs to remove the deposited waste. The recycling plant will operate compacting machinery, and, at the time when planning consent was being sought, the Community Council proposed that the levels of noise generated should be monitored at least for the first year.

10.2

With respect to the prevailing westerly wind, the proposed hospital site is immediately downwind of the recycling centre. This will exacerbate the noise problems mentioned above, and nuisance from wind-blown litter may also be experienced. Problems from vermin are also not unknown at recycling plants.

11.1

Opinions on the dangers from electromagnetic radiation vary widely. Whilst some on the Community Council would dismiss the problems entirely, others would regard the way in which the public has been exposed to ill-researched risks as completely reckless. The majority position has been to support the precautionary principle. We are therefore appreciative of the measured approach that the East Area Development Committee has taken, in difficult circumstances, on the dangers from proximity to mobile phone masts.

11.2

Experimentation with different microwave monitors gives a fairly consistent picture of the extent of the problem in different parts of the town, and the Largo Road area is one in which effects are most readily detected. With some of the phone masts in the town, such as the one on the Purdie Building, it is easy to demonstrate the effect of ‘getting under the umbrella’ as one approaches the mast. ‘Lobe’ effects around masts have also, however, been reported, and the presence of the Largo Road phone mast was readily detectable from the Largo Road pavement fifteen months ago. Since that time, a TETRA mast has also been installed adjacent to the previous mast. A further measurable factor on north-facing slopes in St Andrews with direct line of site to Leuchars is the pulse of the radar every few seconds.

11.3

We are aware that there is no recognition of deleterious effects of microwave radiation on human health by much of the scientific community. We have, however, obtained repeated readings of 4.0-6.5 V/m on the Largo Road, and somewhat lower readings on the Largo Road site, with the highest readings unsurprisingly occurring on the higher parts of the site. We understand that the Italians operate an exposure limit of 6 V/m in respect of buildings in which people work for more than four hours per day.

11.4

Web searches indicate an increasing volume of anecdotal evidence on the adverse health effects caused by phone masts, and, disturbingly, evidence of inappropriate attempts by vested interests to discredit results contrary to their interests. Santini et al (Pathologie Biologie, 2002) discuss a range of health effects (headache, sleep disturbance, nausea, depression, loss of memory, loss of appetite, dizziness, libido decrease, and visual perturbations) on those living under 300m from base stations. But, if little is known about the effects on health of single masts, still less is known about the interaction effects from a number of different sources.

11.5

Two further points are worth making in the special case of a proposed hospital close to phone masts. One is that in the hospital environment the switching off of mobile phones is often mandatory to avoid adverse effects on sensitive medical equipment. To turn a blind eye to the transmitter seems at best curious. Secondly, some may judge that concerns about mobile phone masts are greatest amongst those prone to stress or hypochondria. As such people will doubtless be disproportionately represented amongst those using the health centre, it would not seem entirely appropriate to dismiss their views, even if, in the fullness of time, their fears should be shown to be misplaced.