TOWN AND COUNTRY PLANNING (SCOTLAND) ACT 1997

WEST DUNBARTONSHIRE COUNCIL

REPORT INTO UNRESOLVED OBJECTIONS
TO THE
CLYDEBANK LOCAL PLAN 2001

Reporter:     Douglas G Hope BSc(Hons), DIpTP, FRGS, MRTPI
Date of Inquiry: 4-7 & 10-13 November 2003
SEIRU File Reference: 1QD121160/1
Development Department                                                                                   Local Plans Panel
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Mr. Steve Marshall
Forward Planning and Regeneration
Department of Economic, Planning and
Environmental Services                                                                  Your ref: P/SP/LP4(v)
West Dunbartonshire Council
Council Offices                                                                               Our ref: IQD/2/l 60/1
Garshake Road
Dumbarton G82 3PU                                                                      March 2004

Dear Mr. Marshall

CLYDEBANK LOCAL PLAN 2001 
PUBLIC LOCAL INQUIRY

I refer to my formal appointment dated 2 June 2003 to hold a public local inquiry into, and report on, unresolved objections to the Finalised Draft Clydebank Local Plan published in March 2002 and to proposed modifications published in March 2003. I duly held a public local inquiry in the Clyde Suite, Clyde Shopping Centre, Clydebank, on 4-7 & 10-13 November 2003. I made unaccompanied visits to all the relevant sites prior to the inquiry and accompanied inspections of all the relevant sites during the course of the inquiry.

I have considered all the evidence presented in relation to the fifteen unresolved objections heard at the inquiry and the written submissions submitted in respect of a further twenty-seven unresolved objections. I now enclose my report, which summarises the evidence submitted, either at the inquiry or in writing, my conclusions and recommendations.

Yours faithfully

DOUGLAS G HOPE
Reporter

ABBREVIATIONS

CDLP	Clydebank District Local Plan 1994
FCLP	Finalised Clydebank Local Plan 2001
GCC	Glasgow City Council
GCVSP	Glasgow and the Clyde Valley Joint Structure Plan 2000
HMA	Housing Market Area
HMSA	Housing Sub-market Area
HS	Historic Scotland
HSE	Health and Safety Executive
LBAP	Local Biodiversity Action Plan
NPPG	National Planning Policy Guideline
PAN	Planning Advice Note
SAM	Scheduled Ancient Monument
SDD	Scottish Development Department (now SEDD)
SEDD	Scottish Executive Development Department
SEPA	Scottish Environment Protection Agency
SINC	Sites of Importance for Nature Conservation
SNH	Scottish Natural Heritage
SODD	Scottish Office Development Department (now SEDD)
SOEnD	Scottish Office Environment Department (now SEDD)
SPP	Scottish Planning Policy
SSSI	Site of Special Scientific Interest
WDC	West Dunbartonshire CouncilCHAPTER 1: INTRODUCTION

Background

1.1     The Finalised Clydebank Local Plan 2001 (FCLP) is a review of the Clydebank District Local Plan (CDLP) adopted by the former Clydebank District Council in December 1994. lii recognition of the fact that only 3% of the total planning applications submitted to West Dunbartonshire Council (WDC) between 1994 and 2001 had been advertised as a departure from the CDLP, the council considered it appropriate to undertake the review of the local plan under the expedited procedures, provision for which is made in Section 12(6) of the Town and Country Planning (Scotland) Act 1997 (the "Act").

1.2     The FCLP was approved by WDC in October 2001 and placed on deposit in March 2002. A total of 339 responses were received as a result of the publicity and consultation exercise. These responses comprised 243 objections and 96 representations. Following consideration of the responses, WDC proposed a total of 91 draft modifications to the FCLP, published in March 2003 (WDC 40). As a result, some 209 objections were withdrawn, including 169 objections relating to the re-designation of Dalmuir Park from green belt to open space and the identification of land at Kilpatrick School as a private residential development opportunity. WDC received 41 responses to the proposed draft modifications, including 13 objections.

1.3    A pre-inquiry meeting was held in the Town Hall, Clydebank on 5 August 2003 to discuss the scope of the forth-coming inquiry, the procedure to be followed at the inquiry, a draft programme for the inquiry and the pre-inquiry exchange of documentation (see Annex E). At that time, some 46 objections remained outstanding. WDC continued to negotiate with parties right up to the commencement of the local plan inquiry by which time the number of outstanding objections had been reduced to forty-two from some twelve parties (see Annex A).

1.4     Fifteen objections from five objectors were heard at the local plan inquiry, and twenty-seven objections from eight objectors were dealt with through the written submissions procedure. Four objections from two objectors, which had been withdrawn subject to further modifications to the local plan, were placed before the inquiry (see Annex B).	This report deals with each of the forty-six objections under the following headings:

	Site at Braidfield Farm (objections 21-24);
	Site at Carleith and related matters (objections 38, 39, 41-44 & 45);
	Site at Cochno Road (objections 66,67 & 129 and 7M, 9M & liM);
	Boulevard site (objections 27 & 28);
	Other housing related objections (objections, 53, 54, 56-58, 60, 70 & 5M);
	Land at Mount Pleasant Road, Old Kilpatrick (objection 61);
	Site at Mount Pleasant Farm (objections 62);
	Other green belt issues (objection 31M).
	Former Yarrow Playing Fields (objections 10 & 11 and 141 & 142);
	Retailing issues (126, 135, 137, 139, 140, 347, 1M, 19M, 21M, 22M, 23M & 32M); 

IQD/2/160/l                                                       1CHAPTER 5: SITE AT COCHNO ROAD

Objections 66 & 67 and 7M, 9M & 11M on behalf of Mactaggart & Mickel Limited Objection 129 on behalf of W & R Atkins

Summary of objections

5.1     Objections 66 & 67 on behalf of Mactaggart & Mickel and objection 129 on behalf of W & R Atkins relate to policies OBi and Hi & Schedule Hi of the FCLP. The objectors suggest that a site at Cochno Road should be removed from the green belt and identified as an opportunity for private sector housing in Schedule Hi. The original site to which objections 66 & 67 relate extended to approximately 22 hectares and included the whole area of land east of Cochno Road as far north as the east entrance to Cochno House (the area edged blue on Figure 1(Revision A) in M&M6). The evidence presented at the public inquiry related to a smaller area of approximately 3 hectares located to the south of Holding No.8 and comprising land attached to Holdings No.8 and No.4 (formerly No.5) (the area edged red on Figure 1(Revision A) in M&M6). Objection 129 relates solely to the land attached to Holding No.8. Prior to the inquiry, W & R Atkins agreed to rely on evidence presented at the inquiry on behalf of Mactaggart & Mickel.

5.2     Objections 7M, 9M & 11M relate to proposed modifications to the Technical Supplement of the FCLP. More specifically, the objections relate to the addition of the list of Wildlife Corridors incorporating the River Clyde and its tributary bums ft,(proposed modifications 48, 72 & 76). It is contended that specific tributaries should only be included following the carrying out of a Phase 1 Habitat Survey and thereafter mapped in the local plan.

The objectors' case

5.3     It was explained that Mactaggart and Mickel have been active in West Dunbartonshire since 1939. They are renowned for providing quality new residential developments throughout the Central belt and Ayrshire. With regard to Cochno Road, it was confirmed that the site which the objectors now wish to have removed from the green belt and identified as an opportunity for private sector housing is that shown edged red on Figure 1 in M&M6. It is pointed out that when this land was sold to the present owners in 1982, by the Secretary of State for Scotland, a clause was inserted in the disposition that intimated that if the land was sold to a third party for purposes other than agriculture within 5 years, the Secretary of State had a right of pre-emption. It is the objectors' opinion that this indicates that the former owners thought that development might be a possibility.

5.4     The objectors believe that the site would offer a range of house types at a low-medium density (13 houses per hectare). The indicative proposals envisage a development comprising a mix of approximately forty 3, 4 & 5-bedroom detached villas with garages (some integral), private garden space and public amenity areas/play areas. It is contended that the site could offer a natural expansion of Hardgate within the village envelope. The objectors would work with WDC to design houses within a woodland framework in keeping with the existing character of the area.

IQD/2/160/1                                                    465.5     The objectors welcome plans to regenerate Clydebank and hope that the requirement for 250 houses during the period 2006-2011 can be provided at Clydebank Riverside. However, the Clydebank Riverside regeneration proposals provide for high density flatted dwellings up to eight-storey height-a diametrically different range of house types from that which is proposed at Cochno Road. It is pointed out that, although a planning application has been submitted for Queens Quay, including proposals for some 800 houses, the application is not close to determination and there is no planning team dedicated to the project. Although the objectors agree that the regeneration of Clydebank Riverside will be achieved in time, it is pointed out that the framework document QMDC 24) indicates that it is a long-term project which will take at least 15 years to realise in full.

Strategic issues

5.6     Reference is made. to the requirements of the OCVSP (a) for a continuing five year owner occupied housing land supply and 0,) for the provision of choice in terms of size and type of housing, the second requirement being introduced by Scottish Ministers as a modification Q;o. 30). It is submitted that, whilst WDC considers that there is an increasing effective housing supply (from 685 in 2001 to 766 in 2002 and 884 in 2003), several of the sites that comprise the housing land supply and which are listed in schedule Hi of the FCLP are not effective. Mactaggart & Mickel, along with Bryant Homes and Homes for Scotland, dispute a significant number of the sites identified as effective by WDC.  It is also questionable whether these sites are capable of becoming effective over the next five years, in accordance with paragraph 64 of SPP 3.

5.7     It is considered that only 188 units from schedule Hi are available over the next five to seven years. Of these, only 99 units are on undeveloped sites: Miller Street and Auld St./Beardmore Place. The remaining 89 units are under construction on existing sites. Three sites in schedule Hi are proposed to be removed from the effective housing supply (sites H1(3), Hl(8) & H1(13)) and six sites are disputed (sites H1(l), Hi(s), H1(14), HI(15), Hi(i6) & H1(17)). The effectiveness of other sites not listed in schedule Hi is also questioned, including Queens Quays, where there is no stated developer or planning consent.

5.8     It is contended that, compared to the stated average of 785 effective units according to the WDC housing land audits, only some 218 units are available for development within the next seven years, amounting to a two year effective supply. It is acknowledged that SPP 3 and PAN 38 refer to HMAs as providing the basis for calculating the housing land requirement but it is considered that local plan areas must also be considered (see paragraph 71 of SPP 3). in this context, it is agreed that the 1999-2006 GCVSP housing requirement of 471 units can be met by sites identified in the effective housing supply.  It is also acknowledged that there is no identifiable housing requirement for the release of additional land within the local plan area in the period to 2006.

5.9     However, it is contended that there are no identified effective housing proposals in the FCLP to meet the strategic housing requirement from 2006. It is not considered that the sites listed in schedule GD1 will provide all the 250 housing units required from 2006. The regeneration of Clydebank Riverside is a long-term project and it is not believed that there will be any completions at Queens Quay before 2009. It is pointed out that the importance of timeous housing land release was the reason for the Scottish Ministers' modification 41 to the OCVSP, which added wording covering this specific point at the end of paragraph 11.29.

IQD/2/i60/1                                                      475.10     It is contended that the majority of the sites proposed in schedule Hi are for flatted developments. Neither would the sites listed in schedule GD 1, including Carless, provide a choice of house types. It is not considered that the development of the Old Kilpatrick Tank Farm is typical of the Clydebank Riverside sites since this was more a greenfield site than a brownfleld site. In any event, this site has provided more middle market housing than upper market housing. It is also contended that the other sites that are the subject of objections, Braidfield and Carleith, could not provide a full range of house types.

5.11     The Cochno Road site could provide an additional 40 family houses and introduce a choice of housing type. It would, therefore, not only contribute to the quantitative shortfall of effective housing land but also to the qualitative supply of housing land as required by paragraphs 23 & 24 of SPP 3 and the GCVSP. It is considered unacceptable that people living in Clydebank have to look to Glasgow and elsewhere for executive housing and move out of the area. The development of Cochno Road would also extend tenure choice, which is an important consideration in the FCLP when only 43% of the housing stock is privately owned.

5.12     Essentially, the objector is seeking 16% of the housing requirement for the period 2006-2011 to be directed to a Greenfield site at Cochno Road, whilst the balance can be met from brownfield sites, a smaller percentage than envisaged by WDC when allocating the site at Auchentoshan. The allocation of the Cochno Road site would assist in providing a range of housing opportunities, as previously envisaged when the Auchentoshan site was allocated in the FCLP. The allocation of the Cochno Road site would enable the FCLP to meet the strategic housing requirement in accordance with paragraph 64 of SPP 3.

Site specific issues

(a) Landscape character

5.13     It is explained that the objector's interest in housing development is confined to the landholdings associated with Nos. 8 and 4 holdings, as shown on Figure 1 in M&M6. The decision to restrict development to that area south of the overhead power lines followed the carrying out of a landscape capacity study. With regard to the landscape character of the area, reference is made to the SNH Glasgow and Clyde Valley Landscape Assessment (WDC 44). It is submitted that the landscape character north of the urban area at Hardgate is quite complex. Much of the area is defined as 'Drumlin Foothills', with the 'Rugged Moorland Hills' covering the Kilpatrick Hills. At Duntocher, a 'Green Corridor' follows the Duntocher Burn down to the River Clyde.

5.14 The development pressure for housing along the urban edge is accepted as one of the key landscape issues affecting the 'Drumlin Foothills' landscape type. The key aim of landscape planning and management should be to conserve and reinforce the area's distinctive character. In relation to development, the SNH study concludes that the 'Drumlin Foothills' landscape can be sensitive to development of a nature and scale that conflicts with its character. Therefore, developments should be of a small scale, sited between the drumlin ridges so as to maximise the natural screening and integration provided by topographic and woodland variety. It is pointed out that the boundary between the 'Drumlin Foothills' and the urban area in the SNH report continues straight across the Cochno Burn from Faifley to Hardgate. The finger of undeveloped land on either side of the Cochno Bum, including the objection site, is considered to be part of the urban area.

IQD/2/160/l                                                          48
5.15     Attention is also drawn to the drafting error on Figure 5.2 in WDC 44, when placing the location of the Duntocher Burn 'Green Corridor' (see also Figure 1 in M&M6). The description of the 'Green Corridor' on page 137 of the SNH report describes how it forms an important link from the Kilpatrick Hills to Golden Hill Park and then Dalmuir Park. This contrasts with the council'S production WDC 94, which suggests that the 'Green Corridor' continues up the Cochno Burn to the 'Drumlin Foothills'. Confirmation has been obtained from SNH (M&M8) that the 'Green Corridor' extends through Duntocher with a long finger extending north-westwards along the Loch Humphrey Bum into the Kilpatrick Hills. It is submitted, therefore, that the Cochno Road site is not within the 'Green Corridor' as suggested by the council.

5.16     It is acknowledged that the objection site exhibits many of the typical characteristics of the 'Drumlin Foothills' landscape character area, although at a smaller and more localised scale. The main ground cover is improved grassland. The main field boundaries are predominantly hawthorn hedges. The steep sided valley to the east of the site supports mixed broad-leaved woodland. The site contains few man-made features. The landscape pattern is established by the landform and rectangular field pattern. However, although the site has a rural appearance, the site is dwarfed by the transmission towers to the north and the blocks of flats at Faifley to the east. The houses and bungalows along Cochno Road influence the western side of the site, whilst the suburban houses and business at 'Three Acres' affect the southern part of the site. Essentially, the site is within an urban fringe area.

(b) Visual impact

5.17     It is contended that, despite its location. on rising ground, the site has surprisingly limited visibility from elsewhere in Hardgate and from the wider area. It is only partially seen from Cochno Road, being partially screened by the hedge alongside the road. The No.4 Holding land is completely screened by the hedge in the centre of the site. Only seven dwellings along Cochno Road have potential views across the site and many of these are bungalows with views partially blocked by mature trees, hedges etc. There are limited views from houses to the south and the views from No.8 Holding are over the site. There are some middle distance views of the site, principally from Faifley (the flats in Auchnacraig Road and the western end of Flanders Street) and Golden Hill Park. There are longer distance views from beside the World of Golf on Great Western Road and from the Erskine Shopping Centre.

5.18     It is submitted, therefore, that despite its edge of settlement location on rising ground, the site has surprisingly limited visibility from the adjacent urban area or the countryside beyond.  It does not play any significant role in any views from any major road or transportation route, from any scenic viewpoint, outdoor recreational facilities or from residential properties. Generally, it is seen in the middle or distant view, from where it forms a small and insignificant part of the view, which includes other significant urban features.

(c) Contribution to green belt

5.19     Reference is made to the purposes of green belts set out in SDD Circular 24/1985 (WDC 28) and to SPP 3. The purposes of green belts in Circular 24/1985 have been modified in the GCVSP to suit the particular circumstances of the Glasgow Conurbation. The relevant inter-related objectives of the GCVSP are set out in paragraph 7.22 as follows:

IQD/2/160/1                                                            49
• prevent neighbouring towns from merging and control sporadic and isolated development;
• preserve the special character of towns, including their landscape setting;
• protect and, where appropriate, enhance landscape character and biodiversity.

5.20     It is pointed out that the objection site is not included in the area identified as 'Inner Green Belt-including sensitive wedges' or 'Structural Corridor-separating major parts of the conurbation' on the Key Diagram Inset A on page 28 of the GCVSP. It is contended that the green belt boundary around Hardgate/Faifley in the FCLP rarely follows defensible boundary features and there appears to be an inconsistent approach to the treatment of the Cochno Burn and Loch Humphrey Burn valleys. In the latter case, the boundary cuts across the valley at the outer boundary of the urban area and the undeveloped land on either side of the burn is designated open space not green belt. In the former case, the finger of open space alongside the Cochno Burn is designated as green belt.

5.21     It is submitted that the lack of a comprehensive green belt review means that there has been no comprehensive assessment of the green belt purposes of land or the appropriateness and defensibility of green belt boundaries. As a consequence, no land on the inner green belt boundary has been identified that is "no longer making a significant contribution to the purposes for which the green belt in question was established", in accordance with paragraph 7 of Circular 24/1985 and paragraph 40 of SPP 3.  It is acknowledged that the last sentence of paragraph 40 of SPP 3 indicates that before any green belt land is identified for development, there should be a realistic appraisal of the opportunities for development on sites within the existing urban area.

5.22     With regard to the purposes of green belts, it is contended that the objection site serves no function in terms of preventing coalescence or the definition of the boundaries of settlements. Had this been the case, it would have been identified as such on the Key Diagram Inset A on page 28 of the GCVSP. As private farmland, it serves no function in terms of countryside recreation. Finally the site does not play a significant role in relation to the setting of Hardgate or Clydebank. There is limited visibility of the site either from the wider Glasgow Conurbation, from Hardgate/Faifley or from the countryside to the north. It is not seen from any major road or transportation routes or from any scenic viewpoints or countryside recreational facility. Whilst the site has a small role in the landscape setting of Hardgate, it has an imperceptible role in relation to the landscape setting of Clydebank and the wider Glasgow area. It is submitted that its development would not undermine the overall effectiveness and integrity of the wider green belt and, therefore, in accordance with Circular 24/1985 and SPP 3, the site may be released from the green belt.

5.23     Two indicative master plans have been prepared to indicate how the site might be developed for approximately 40 houses (see figures 10 & 11 of M&M6). These have been based on a landscape capacity study of the wider Cochno Burn area and a more detailed assessment of the objection site. Master plan (I) is based on a single access point and Master plan (2) provides for two access points. Both Master plans provide a remote footpath along Cochno Road linking with the existing footpath at the southern end of the site. An equipped children's play area would be provided if required. A new hedge would be provided alongside Cochno Road, between the road and the footpath. The existing woodland along the Cochno Burn would be extended into the eastern part of the site and along the northern boundary of the site. Both Master plans show the housing development broken down into two or three separate compartments.

IQD/2/1 60/1                                                   50
5.24     The revised green belt boundary could either follow the northern and eastern boundaries of the site, so that the Cochno Burn wedge would remain in the green belt (see Figure 10 in M&M6), or extend eastwards from the northern boundary of the site to the north west corner of Auchnacraig Road in Faifley (see Figure 11 in M&M6). In the latter case, the Cochno Burn could be designated open space, as in the case of the Loch Humphrey Burn. Designation as open space could encourage the enhancement of this area's recreational and ecological value and increase the benefits of the area to the community.

(d) Ecological impact

5.25     A phase 1 habitat survey of the site and the adjoining valley of the Cochno Burn was carried out in September 2003. This identified that the more valuable habitats are off-site in the valley of the Cochno Burn. The semi-natural broad-leaved woodland in the valley is not exceptional but there are characteristics that enhance its ecological value. There has been tree cover in this location since 1860 but the presence of Sycamore is a threat to the woodland. The Cochno Burn has a maximum width of 1 .5m but it is a valuable habitat.

5.26     The habitats lost as a result of the development will be improved grassland and a small element of scattered scrub.  The loss of improved grassland would not have a significant negative ecological impact. This loss would be offset by the creation of gardens. Some hedging would be lost but would be replaced by new hedging and hedgerow trees and the remaining hedges would be reinforced. New woodland would be planted. Overall, there would be a positive impact on the ecology of the site from the proposed development.

5.27     There would be no impact on the habitat of the Cochno Burn. With regard to the wildlife corridor along the Cochno Burn, reference is made to the definition endorsed by West Dunbartonshire Greenspace (WDC 52) and SNH (WDC 67) that "A wildlife corridor is any linear area of semi-natural vegetation...". It is disputed that any linear area of seminatural vegetation necessarily constitutes a wildlife corridor. In order to determine whether that is the case, the quality of the corridor requires to be determined. It is pointed out that no evidence has been presented by the council on the value or extent of the wildlife corridor in the vicinity of the objection site and there is no indication of its extent in the local plan.

5.28     Nevertheless, in this case, there is a topographical and ecological break along the eastern boundary of the objection site. Consequently, the proposed development would not have a negative impact on the semi-natural broad-leaved woodland in the valley of the Cochno Burn. Indeed, the proposals will enhance the corridor by extending the semi-natural woodland into the site. This approach is encouraged by paragraph 9.17 in the FCLP. It is also contended that there is support for the proposed development in NPPG 14 and PAN 60.

(e) Access and highway considerations

5.29     Subsequent to the inquiry, information was submitted in respect of a number of highway issues raised by the council in relation to the original objection, which related to an area extending to 22 hectares capable of accommodating some 250 houses (see WDC 43). The amended objection site extends to 3 hectares with a capacity of approximately 40 dwellings. In response to the concerns of the council's Head of Roads, Transportation and Environmental Services it was indicated by report dated 18 November 2003 (M&M9) that:

IQD/2/160/1                                                   51
• the proposed remote footpath along the frontage of the site would link to the existing footpath on the west side of Cochno road;
• the existing Cochno Road is 6.3m in width over the site frontage. This road serves some 400-500 houses and could accommodate a further 40 houses;
• visibility splays can be provided at the site accesses that meet the council's requirements;
• forward sight-lines on Cochno Road are satisfactory;
• the increase in traffic likely to be generated by the proposed development is unlikely to exceed the capacity of the junction of Cochno Road and the AS 10. This junction is not the only access to the site and the surrounding area from the AS 10. However, the junction may benefit from becoming a box junction due to its proximity to the Hardgate roundabout;
• the additional traffic on the Hardgate roundabout generated by the proposal would be insignificant; and
• the site is accessible by public transport (see timetables for routes 59 & 81).

(f) Other matters

5.30     The objection site is less than a kilometre from Hardgate cross, where there are convenience retail facilities. Public transport connections by bus can be taken from Hardgate Cross, or at closer locations on Glasgow Road or Cochno Road, to Clydebank or Glasgow. Local primary schools lie within one kilometre of the site. Secondary school and further education provision are located within 2k of the site. The centre of Clydebank, which provides the full range of retail, leisure, social and employment opportunities and public transport connections by train, is within 3k of the site. The proposed development would accord with the principles set out in NPPG 17 and would comply with policy T4 in the FCLP.

5.31     The site lies within an area of agricultural smallholdings established by the Government in the 1930's.  The Atkins family has resided in No.8 Holding since its inception in 1937.  It is widely acknowledged that the original function of these smallholdings has now ceased. Previous planning applications have been submitted for all or part of the objection site and refused. At the time these applications were considered (1988 & 1994) there was no strategic justification for greenfield housing land release.  It is contended that the present situation is markedly different. There is a strategic housing requirement for 250 houses in the period 2006-2011.

5.32     It is contended that there is a shortfall of family housing opportunities in Hardgate, evident in the recent visible extensions to properties in Cochno Road. The objection site would provide larger family houses and increase the choice of housing in Clydebank in accordance with the principles of SPP 3. The alternative master plans indicate how a quality residential environment can be provided.

Conclusions

5.33     In conclusion, it is submitted that;

• There are significant doubts about the effectiveness of sites identified in schedule Hl of the FCLP, coupled with doubts about the long term housing provision at the Clydebank Riverside;

IQD/2/160/1                                                               52
• WDC has failed to provide a choice, in terms of size and type of housing, to meet
the identified strategic housing land requirement for the period 2006-2011;
• The objection site no longer serves a useful green belt purpose; and
• WDC has failed to substantiate any basis for the creation of a wildlife corridor
along the Cochno Burn.

5.34     With regard to housing land supply, it is submitted that even if it is accepted that there is a sufficient supply of effective housing land capable of providing 471 completions in the period 1999-2006, there is a hiatus during the period 2006-2009. It is the objector's view that the objection site can make a useful contribution to meeting the 250-house requirement for the period 2006-2011. It would assist in filling the gap from 2006 to 2009, when it is hoped the Queens Quay development comes on stream. It would also introduce a choice of house type and size from 2006. Providing all 250 houses on one single brownfield site does not provide an adequate choice of housing.

5.35     With regard to the effectiveness of sites in schedule Hi, it is contended that only 188 units are effective in addition to 30 units on windfall sites not in schedule HI. Schedule Hl is woefully out-of-date and further sites are required to fill the gaps left by sites proposed to be removed and those that will be completed before adoption of the local plan. The inclusion of the objection site is supported by policy 5P6 of the GCVSP and by paragraph 24 of SPP 3, which promote choice in terms of house size and type.

5.36     In relation to the green belt, the council's treatment of the Auchentoshan site indicates that it has no objection, in principle, to the removal of land within the greenbelt for housing if it is no longer serving a green belt purpose. The objection site serves no purpose in relation to the prevention of coalescence, agricultural use or leisure and recreation. The landscape of the site has a capacity to absorb small-scale development. It is not highly visible from the surrounding area and it is surrounded on three sides by urban development. Its development would have little effect on the landscape setting of Hardgate/Clydebank. Its removal from the green belt is therefore justified, whether or not there is a need for housing land.

5.37     In relation to wildlife corridors, if the proposed wildlife corridor along the Cochno Burn were to impinge on the objection site, then the objections remain.  There is no indication of the extent of the corridor in the FCLP. It is submitted that the reference to wildlife corridors in the local plan should be excluded until such time as their extent is clarified. Parties using the local plan should not have to refer to other documents to ascertain such information.

5.38     It is submitted that the site is free of constraints and could become effective immediately. The site is within the control of a developer and is free from any infrastructural impediments. With regard to highway issues, these have been clarified in correspondence subsequent to the inquiry (see M&M9, 10 & 11 and WDC 109 & 110). There are no highway reasons for objecting to the principal of developing the site.

IQD/2/1 60/1                                                      53The Council's response

Housing land supply

5.39     It is contended that the FCLP is in accordance with national planning guidance in providing an adequate supply of effective housing land.  WDC acknowledges the requirements of paragraph 64 of SPP 3 and 5P6 of the GCVSP. The GCVSP was approved in 2002 and therefore the methodology by which housing demand and supply has been assessed has been recently scrutinised and approved by Scottish Ministers.

5.40     Schedule 6(1,)(ii) of the GCVSP sets out, for each Market Area/Sub-market Area and Local Authority, the effective supply as at 1999 and the additional requirements for the periods 1999-2006 and 2006-2011. There is no requirement for the identification of housing land within the West Dunbartonshire area of the Greater Glasgow North and West HMSA for the period to 2006 but there is a requirement for 250 houses during the period 2006-2011. The FCLP indicates that an element of the housing planned for Clydebank Riverside will provide for these houses. It is contended that the redevelopment sites listed in Schedule GD 1 have potential for residential development far in excess of the 250-house requirement. (see WDC 47). For example, the residential element of the proposals for the UiE/Kvaerner site include at least 800 homes on this single site.

5.41     With regard to the housing land audits, these provide an assessment of the effective land supply in accordance with the requirements of PAN 38. They reflect the council's view of the housing land supply having consulted with the house building industry, particularly their umbrella organisation, Homes for Scotland. The 2001 effective supply provided the basis for schedule Hi in the FCLP. The total of 685 units compares favourably with the figure of 471 units, which provided the base for the GCVSP. Of the 685 units, three sites totalling 139 units were disputed by Homes for Scotland. The most recent 2002 HLA, indicates an effective supply of 766 units of which some 304 units are disputed by Homes for Scotland (see Appendix A of WDC 47).

5.42     As at March 2003, 343 of the 1999 effective supply of 471 house units had been completed and a further 89 house units were under construction, leaving a net requirement of 39 houses to be provided by 2006. The latest audited position indicates that there is sufficient effective housing land to ensure that this can be achieved. It is acknowledged that the position in relation to the housing land supply frequently changes, which is why the annual housing land audit is so important. It is pointed out that the requirement to provide an effective supply of housing land is at HMA level, and that within the Greater Glasgow North and West HMSA there is a substantial surplus of housing land. It is contended, therefore, that there is no requirement to identify further housing land even if the level of dispute between WDC and Homes for Scotland is accepted.

5.43     With regard to future additions to the housing land supply, SPP 3 emphasises the need to make an efficient use of land and existing infrastructure. Councils are encouraged to promote the re-use of previously developed land in preference to greenfield land provided that a satisfactory residential environment can be created. NPPG 17 indicates that the settlement strategy should be consistent with the aim of reducing travel demand and reliance on the private car. Consequently, the strategy of the FCLP sets out a series of objectives to:

IQD/2/160/l                                                     54
• Secure regeneration and renewal;
• Embrace a sustainable approach to development;
• Improve key locations within the area; and
• Enhance quality of life.

5.44     The GCVSP also promotes the re-use of urban brownfield land and the key policies of the FCLP pursue the policy of urban renewal by maximi sing development opportunities on vacant and derelict land within the urban area. Almost 5% of the Clydebank urban area was classified as vacant and/or derelict in 2001. Policy URi promotes the re-use of urban brownfield land and buildings and policy URi addresses the regeneration of the Clydebank Riverside Area, which forms part of the wider Clyde Waterfront, a nationally important Flagship Initiative identified in the GCVSP. WDC anticipates that the riverside will provide substantial additions to the effective housing land supply in the medium term and a number of redevelopment opportunities have been identified in the FCLP (see schedule GD 1).

5.45     The council is committed to continually monitoring housing land supply and demand, and proposed modification 29 amends policy H2 to indicate that, if updated assessments indicate that additional housing land needs to be identified within the Plan area, sites will be brought forward as required. It also indicates that preference will be given to sites on brownfleld land.

5.46     It is acknowledged that other local authorities in the Greater Glasgow North and West HMSA have made provision for greenfield release as a means of achieving a balanced supply of housing land. It is contended, however, that there is no need for any Greenfield release in the FCLP area. With regard to the identification of a site at Auchentoshan, WDC considered that this site did not perform a green belt function and that the former playing fields would provide a suitable housing site. However, following the receipt of objections, WDC now proposes that the 'Dalmuir Wedge', including the Auchentoshan site should remain in the green belt.

Housing choice

5.47     In relation to choice, it is not accepted that brownfield land does not provide for sufficient choice in the type of housing. It is acknowledged that SPP 3 indicates that not every site will be capable of satisfying the full range of housing requirements. In terms of location, it is pointed out that SPP 3 emphasises the need to guide development to brownfield land and accessible locations rather than indicating a need to provide a choice of geographical locations. 5P6 and SP1O of the GCVSP also note the need to provide for choice in terms of size and type of housing in each housing market area. It is accepted, therefore, that the housing land supply must provide for a range of housing. It is pointed out, however, that there is no accepted methodology whereby demand and supply can be assessed objectively by market segment.

5.48     Market needs have been considered across the Greater Glasgow North and West HMSA. In 2002 the effective supply across this area amounted to 7,550 units, an increase of almost 2,000 units on the structure plan 1999 base figure (see WDC. 26, 48 & 49). The effectiveness of less than 6% was disputed by Homes for Scotland. WDC submits that there is a full range of sites across the HMSA and, whilst the majority are brownfield, there are some Greenfield sites outwith Clydebank.

IQD/2/1 60/1                                                     55
5.49     WDC strongly suggests that the brownfield nature of the land supply does not restrict the type and quality of housing which can be provided. In the past 12 years, almost 2,000 new homes have been built in the FCLP area, all on brownfield sites and providing a full range of house sizes and types. In this context, reference is made to the former Ministry of Defence Tank Farm at Old Kilpatrick. This previously contaminated site has provided housing to meet all sectors of the market. Also, sites such as Ocean Field (Hl(2)) and Second Avenue (H 1(11)) have provided lower density housing. WDC contends that the sites identified in Schedule HI, together with any windfall sites will provide an adequate choice and distribution of land for priv ate housing.

5.50     In the medium term, the major redevelopment opportunities along the riverside will provide the chance to create quality residential environments with a diversity of housing types (see WDC 24).  WDC does not accept that housing development on the Clyde Riverside will be exclusively high density flatted development, although there is no specific reference to the provision of large detached houses with gardens. WDC contends that the Carless site (GDl(l 1)) is capable of accommodating a range of house types, including larger houses. The Queen's Quay site (Site GDl(l0)) is also extensive enough to be capable of satisfying the full range of housing requirements.  WDC contends that the release of greenfield sites would only divert resources from these redevelopment sites.

5.51     WDC points out that the GCVSP notes that the aim to promote greater social inclusion and integration would be undermined if it were to be based upon an assumption that housing development in inner areas would be limited to a narrow range of owner-occupied dwellings. WDC contends that both the HMSA area and the local plan area provide considerable choice with regard to location, size, appearance, character and market sector.

Green belt considerations

5.52     Reference is made to purposes of green belts set out in SDD Circular 24/1985. Having regard to the site at Cochno Road, which it is accepted is within the urban fringe, WDC agrees that the issue of coalescence and the use of the site for recreational or other institutional uses are not particularly relevant.  However, WDC submits that the site establishes a physical boundary to the urban area and provides an important landscape setting for Hardgate. The urban edge of the settlement is well defined and views into the site from Cochno Road demonstrate the division between the green belt and the built up area (see WDC 92 & 93). Although the agricultural capability of the site is relatively low, it appears well managed and conveys a generally attractive appearance. The site forms part of an important 'green finger', having regard to its landscape and nature conservation interests.

5.53     WDC acknowledges that the amended site considered at the public inquiry differs substantially from that accompanying the original objection, to which WDC gave detailed consideration in its assessment of the objections.  In terms of aesthetic qualities, it is submitted that the scale of the amended site appears large and open, with little diversity and a simple topography. Although the amended site is not visible from any main road it is visible from Cochno Road. WDC considers that any development of the site would be prominent and significantly alter the appearance of the area. The northern part of the site is particularly prominent. It is submitted that the site has a low capacity to absorb development, which would alter the character and sense of place, contrary to advice in PAN 44. WDC considers that the site performs a number of green belt functions and that there is no justification for removing it from the green belt having regard to the advice in SDD Circular 12/1 985.

IQD/2/l 60/1                                                     56
Wildlife Corridors

5.54     With regard to objections 7M, 9M &   11M   , WDC points out that wildlife corridors are identified in NPPG 14 as being 'essential for migration or genetic change'. Paragraph 49 of NPPG 14 details features that may be of value in the development of habitat networks, which includes areas of woodland, rivers and burns. WDC believes that whilst wildlife corridors provide connectivity between habitats, they do not have to be habitats. If a habitat was identified through a Phase 1 Habitat Survey, it would be identified as a Site of Importance for Nature conservation (SINC). The council does not agree that a Phase 1 Habitat Survey is necessary before the designation of a wildlife corridor.

5.55     The GCVSP promotes the creation of a green network by promoting the maintenance and improvement of biodiversity through inter a/ia the protection and development of a network of linked habitats. It identifies strategic environmental resources at International, National and Strategic Level. The Kilpatrick Hills is identified as a strategic Resource. SNH has defined wildlife corridors as "Any linear area of semi-natural vegetation which links other areas of semi-natural vegetation" (WDC 67). West Dunbartonshire Greenspace has accepted the SNH definition of wildlife corridors.

5.56     The Glasgow and Clyde Valley Landscape Assessment identifies 'Green Corridor' landscapes as landscapes which "occur where river valleys or canals penetrate the urban fabric, producing an undeveloped corridor of open space feeding into the City". Key issues affecting this landscape type include the importance of conserving and enhancing the ecological value of these corridors. The Duntocher Burn is identified as a major green corridor linking the urban area with the Kilpatrick Hills. It is acknowledged that, contrary to the information depicted on production WDC 94, the Cochno Burn is not included in the Duntocher Burn 'Green Corridor'.

5.57     The Glasgow and Clyde Valley Landscape Assessment indicates that "Planning and management should aim to protect, conserve and enhance these corridors of open land. where possible, linkages with other undeveloped areas (including the countryside) should be created or reinforced". The Mid-Clyde River Valleys Project came into existence in 1992 and produced a Nature Conservation Strategy based on a habitat survey and faunal records. This strategy (WDC 50) identified important wildlife corridors including the Duntocher Burn. It is clear, therefore, that most of the wildlife corridors, including the tributary burns of the River Clyde, have been recognised for ten years

5.58     WDC points out that the objector did not object to the inclusion of wildlife corridors in policy E2 when they were not specifically listed. The objection is to the inclusion of a wildlife corridor described as the 'River Clyde and its tributary burns', which would include the Cochno Burn which feeds the Duntocher Burn. WDC submits that the evidence indicates that the topography of the wildlife corridor defines the boundary of the improved pasture, which constitutes the development site (see WDC 99). It is unlikely that any potential development on the objection site would extend into the wildlife corridor.

5.59     The council has not shown wildlife corridors spatially on the Proposals Map. It is the council's position that the impact that any development would have on a wildlife corridor should be assessed through the development control process. In this case, the existence of the wildlife corridor would have a limited effect on the specific interests of the objector.

IQD/2/l 60/1                                                     57
Highway considerations

5.60     When the council's Head of Roads was consulted on the original objection, which related to an area that extended to some 22 hectares and had a capacity to accommodate in excess of 250 houses, it was indicated that a development area of that size would cause concerns with respect to:

(a)     sub-standard or no pedestrian provision;
(b)     restricted road width;
(c)     sub-standard visibility splays;
(d)     sub-standard forward sight lines;
(e)     junction capacity at the A810;
(f)     junction capacity at Hardgate roundabout; and
(g)     remote from public transport.

5.61     Following the submission of further information in the report from the objector dated
18 November 2003 (M&M9) and a further response dated 9 January 2004 (M&M10), the
council's Head of Roads states that, subject to clarification of the items listed below, the
proposal would be acceptable from a highways point of view (see WDC 109 & WDC 110):

(a)     the geometry/construction and visibility at the connection of the proposed remote footpath with the existing footpath;
(b)     the width of Cochno Road; and
(c)     the sightlines to be provided at the access(es) should be 4.5m x 60m x 1.05m (min.)

Supporter's views

5.62     Clydebelt is dedicated to retaining and enhancing the green belt status of the Kilpatrick Hills and their surrounding environment in Clydebank, Dumbarton, Milngavie, Bearsden and Glasgow. Clydebelt supports the local plan's provisions for the protection of the green bert and is opposed to other objections relating to the preference for housing on brownfield land and the identification of a number of green belt sites for housing and other developments. Clydebelt considers that there is sufficient provision in the FCLP for the choice and quantity of private housing required in the local plan area. There is, therefore, no need to release any green belt land.

5.63     Clydebelt's views relate to the original objection site. It is considered that Cochno Road could not support the traffic that would be generated by the development of such a large area. It is considered most important not to re-designate this edge of green belt site as it includes a wildlife corridor and contributes to the setting of Clydebank. It is submitted that, although the site is on the very fringe of the urban area, the green belt must have a boundary and the fact that the site is on the boundary is not an argument for shifting the boundary.

5.64     With regard to the wildlife corridor, Clydebelt supports the council's proposed modification 46 and the proposed amendment to policy E2. It is pointed out that SNH emphasises the importance of retaining wildlife corridors to local biodiversity (WDC 67). Clydebelt members value the wildlife corridors in the local plan area and regard it as essential to retain the tributary burns of the River Clyde as wildlife corridors from the Clyde to their sources in the Kilpatrick Hills. It is pointed out that the Phase 1 Habitat Survey

IQDI2/l 60/1                                                     58
carried out on behalf of the objector confirms that the Cochno Burn is a valuable habitat and it should be protected from disturbance and pollution. Reference is also made to proposed modification 44, which refers to the preparation of a LBAP.  It is submitted that implementing the LBAP should improve the biodiversity of the objection site, making it more important to retain in the green belt. Reference is also made to proposed modification 7, which proposes an additional sentence in paragraph 3.14 of the FCLP indicating that 'The green belt has an important role in maintaining the wildlife resource of the Plan area, whilst it is also a key area for public access'. Clydebelt considers that those parts of the green belt that are also watercourse wildlife corridors should be identified and protected.

Conclusions

5.65     The site to which the original objections relate extended to approximately 22 hectares and had a capacity for approximately 250 houses. The amended site, which was the subject of examination at the public inquiry, extends to approximately 3 hectares and is confined to the land associated with Holdings Nos. 8 and 4 (formerly 5), the area edged blue on Figure 1 (Revision A) in M&M6. The decision to restrict development to the area south of the overhead power lines followed the carrying out of a landscape capacity study.

Housing land supply

5.66     The objectors submit that there are significant doubts about the effectiveness of sites identified in schedule Hi of the FCLP, coupled with doubts about the long-term housing provision at the Clydebank Riverside. The objectors agree that the 1999-2006 GCVSP housing requirement of 471 units can probably be met by sites in the effective housing supply. However, they consider that the available effective housing sites together with projected windfall sites only provide a two year effective supply of housing land within the local plan area rather than the required five years effective supply. The objectors contend that there are no identified effective housing proposals in the FCLP to meet the strategic housing requirement for the period 2006-2011. The effectiveness of the redevelopment opportunity sites in schedule GD 1 is questioned and it is doubted whether the requirement for 250 units during the period 2006-2011 could be met in full by these sites

5.67     With regard to housing land supply, paragraph 64 of SPP 3 states:

"Local plans must conform to the structure plan and provide sufficient effective land to meet the housing land requirement for at least five years from the date of adoption. Local plans should also identify further sites to meet requirements in the medium term. The effectiveness and programming of sites will be monitored through the annual housing land audit, to maintain sufficient effective land for at least the following 5 years at all times."

5.68     This statement is repeated in paragraph 11 of PAN 38, paragraph 20 of which states that housing market areas provide an established basis for calculating the housing land requirement. Paragraph 70 of SPP 3 indicates that planning authorities should ensure that the housing land requirement for each housing market area is provided in full. Paragraph 71 indicates that, irrespective of how housing market areas are defined, structure plans must allocate all land requirements specifically to the areas of individual councils, as the basis for local plans and development control decisions.

IQD/2/1 60/1                                                     59
5.69     Schedule 6(1,)(ii) of the GCVSP sets out, for each Market Area/Sub-market Area and Local Authority, the effective supply as at 1999 and the additional requirements for the periods 1999-2006 and 2006-2011. Schedule 6(1,)(ii) indicates that the effective land supply m West Dunbartonshire in 1999 amounted to 609 units. It has been established elsewhere (see Chapter 2 above) that the contribution from the Clydebank Local Plan area amounts to 471 units. Schedule 6Q,)(ii) also indicates that there is no requirement for additional housing land in West Dunbartonshire during the period 1999-2006 but that an additional supply of land for 250 units is required for the period 2006-2011. The council agrees that there is an expectancy that the effective supply plus the additional supply will be delivered during the timescale of the structure plan. As at March 2003, 343 of the 1999 effective supply of 471 house units had been completed and a further 89 house units were under construction, leaving a net requirement of 39 houses (see Appendices A, B & C in WDC 47).

5.70     The housing sites listed in schedule HI that remain undeveloped are as follows:

Site Ref.                            Original     Programmed
                                           Capacity     2003-2010
H1(1) Whiteinch Demolition       75     75
Hl(4) Miller Street                        80     84 (consent issued)
HI(S) 354-394 Dumbarton Rd.      28     28
H1(7) Add St/Beardmore Place     16     15 (consent issued)
HI(14)Boulevard                          80     80
H1(15)Erskine Ferry Road           55     55
H1(16)Former Union Church       30     30
H1(17)Cart Street                        20     20

Totals                                      384     387

5.71     The objectors dispute all of the above sites except site H1(4) and H1(7). Notwithstanding this high level of dispute, it is clear from the above table that there is sufficient capacity within these sites to deliver the requirement for a further 39 houses from the 1999 effective land supply. In this respect, I note that Strathclyde Homes has been granted planning permission for the Miller Street site, that the council intends to market the Boulevard site at the end of the local plan process, and that Whiteinch Demolition are currently developing an alternative location for their operations and intend to market site HI(l) in 2004. In addition, the policy framework within the FCLP allows 'windfall' sites to be added to the supply where they conform to policy. The evidence of the council is that sites at 'Dunclutha' (12 units) and 'Freelands' (14 units) have been agreed as effective by Homes for Scotland in the 2002 audit. I conclude that actual completions for the period 1999-2006 are therefore likely to exceed the GCVSP requirement.

5.72     With regard to the requirement for additional housing land for 250 units during the period 2006-2011, the FCLP indicates that an element of the housing planned for Clydebank Riverside will provide for these houses.  The objectors welcome plans to regenerate Clydebank Riverside but doubt whether there will be any completions in the first phase of development at Queens Quay before 2009. They point to a number of problems, including the contamination on the site, the lack of a planning team and the 'lead-in time' required for such a project. The objectors doubt whether other sites listed in schedule GD1 will provide any houses before 2011. They request that 16% (40 houses) of the 2006-2011 requirement

IQD/2/160/1                                                     60
for 250 houses be directed to a Greenfield site at Cochno Road. The council draws attention to the fact that SPP 3 promotes the re-use of previously developed land in preference to Greenfield land. Almost 5% of the Clydebank urban area was classified as vacant and/or derelict in 2001 and both the GCVSP and the FCLP pursue a policy of urban renewal in accordance with the guidance in SPP 3.

5.73     As stated in SPP 3, local plans must provide sufficient effective land to meet the housing land requirement for at least five years from the date of adoption. In this instance, the anticipated date of adoption is the end of 2004. The GCVSP housing land requirement for the FCLP area, for the period to 2011, which is beyond five years from the date of adoption of the local plan, amounts to 721 units. As indicated above, as at March 2003, 343 house units had been completed and a further 89 house units were under construction, leaving a net requirement of 289 house units to be delivered before 2011.

5.74     Based on the evidence presented by the council in its opening statement, particularly in relation to the latest position on the allocated sites (see Appendices B & C of WDC 47), I am satisfied that the allocated sites, such as Miller Street, Boulevard and Whiteinch Demolition, together with any contribution from 'windfall sites' and the redevelopment opportunity sites, will provide sufficient effective land to meet the housing requirement for at least five years from the anticipated date of adoption of the Clydebank Local Plan. In identifying redevelopment opportunities, I am also satisfied that the local plan has identified further sites to meet requirements in the medium term. I also note the council's commitment to continually monitor housing land supply and demand, and the amendment td policy H2 in proposed modification 29, which indicates that if updated assessments indicate that additional housing land needs to be identified, sites will be brought forward as required.

5.75     I am also conscious of the fact that the requirement to provide an effective supply of housing land is at housing market level, and that within the Greater Glasgow North and West HMSA there is a substantial surplus of housing land. The effectiveness of less than 6% of this surplus of some 7, 550 units in 2002 was disputed Homes for Scotland. I do not consider, therefore, that there is any justification from a housing land supply point of view for the allocation of further housing sites in the Clydebank Local Plan area.

Housing choice

5.76     Paragraph 23 of SPP 3 indicates that local authorities, developers and other housing providers should consider the need to provide a choice of housing types. It points out that not every site will be capable of satisfying the full range of housing requirements, some central sites, for example, may provide opportunities for new flatted development but be unsuitable for houses with gardens. Paragraph 24 of SPP 3 indicates that it is Scottish Executive policy to encourage more diverse, attractive, mixed residential communities. In order to achieve this, a range of house types is needed, providing for all segments of the market, from affordable housing to executive housing. It points out that there is now increasing demand for lower density housing with gardens as well as flatted accommodation. Paragraph 25 refers to the scope for mixed developments, where commercial, retail, leisure or other uses can form part of a development alongside housing.

5.77     The council has taken on the points raised in these paragraphs and the redevelopment opportunity sites, particularly, seek to achieve mixed developments in accordance with the guidance in paragraph 25 of SPP 3. The council considers that the remaining undeveloped

IQD/2/l 60/1                                                     61
sites in schedule Hi, together with the redevelopment opportunity sites in schedule GD 1, are capable of providing a range of house types and residential environments in accordance with paragraphs 23 & 24 of SPP 3 and policies 5P6 and SP1O of the GCVSP. The council also points out that the structure plan strategy recognises the need to direct development to brownfleld sites in preference to greenfield development. Whilst recognising that other planning authorities in the GCVSP area have promoted greenfield release in addition to brownfield development, WDC considers that green field release is not necessary or appropriate within the Clydebank area.

5.78     WDC argues that the question of house type, as with housing requirements, is a matter to be considered across HMAs. However, paragraph 24 of SPP 3 clearly refers to 'communities' and the council accepts that Clydebank is a community. I consider that the requirement for a choice of house types is as much a matter for communities. as it is for HMAs. I also consider that this requirement is more than simply a matter of tenure balance. I therefore consider that it is appropriate and desirable that a range of housing sites is available to provide a choice of house types within the Clydebank Local Plan area.

5.79     The first sentence of paragraph 6.11 of the FCLP states "The council aims to ensure that within the Plan area there is an adequate supply, distribution and range of effective land available for private sector development". These sentiments are repeated in paragraph 6.12. It may well be that this aim was satisfied by the opportunities for private sector housing listed in Schedule Hi in the FCLP, which indicates a range of seventeen sites with a capacity for 709 dwellings. However, the position has changed somewhat since the FCLP was approved by the council in October 2001 and published in March 2002. The up-to-date position is shown in paragraph 5.70 above, which indicates that the number of sites has reduced to eight with a capacity for 387 dwellings.

5.80     The council considers that the remaining sites identified in schedule HI, together with any windfall sites will provide an adequate choice and distribution of land for private housing. In this context, reference has been made to sites that have been developed in the past, such as the Old Kilpatrick Tank Farm, and other sites that are nearing completion, such as Ocean Field and Second Avenue. However, all the remaining sites listed in schedule Hi are brownfleld sites and all but the Boulevard site are within the Riverside Area or very close to it. It is evident from the location of these sites and the evidence provided in Appendix C of WDC 24 that the proposed densities on most of these sites do not suggest the provision of a full range of house types. Although I am sure that these sites could accommodate most house types, including executive flats, I am not wholly convinced that the sites will provide a full range of house types, including the larger executive type housing with gardens.

5.81     It is also contended by the council that redevelopment opportunity sites such as Queens Quay and Carless are also capable of satisfying the full range of housing requirements. However, I am not convinced that the development of the Old Kilpatrick Tank Farm, which the council relies on as an example of what can be done on sites within Clydebank Riverside, is a fair comparison with the sites listed in schedule GD 1. Also, the Riverside Framework document (WDC 24) indicates that housing densities will be a minimum 20-30 units per acre (50-75 units per hectare) and that building heights will be predominantly 3-4 storey. I am not wholly convinced, therefore, that the sites listed in schedule GD 1 will provide a full range of house types, including the larger executive type housing with gardens.

IQD/2/160/l                                                     62
5.82     I am also conscious of the fact that the majority of the undeveloped sites listed in schedule Hi are located between the Forth & Clyde Canal and the Clyde.  Only the Boulevard site is located outwith this riverside area. They are all brownfield sites, as are the redevelopment opportunity sites listed in schedule GD 1 Furthermore, the proposed removal of Auchentoshan Field, site H1(13), has resulted in the loss of a Greenfield site, the development of which would have lead to a wider distribution of housing sites within Clydebank.

5.83     I conclude that the aim of the council, stated in paragraph 6.11 of the FCLP, to ensure that within the Plan area there is an adequate distribution and range of effective land available for private sector development, can no longer be achieved by those sites remaining in schedule Hi. Neither do I consider that this aim can be achieved by the sites identified in schedule GD1.

Green belt considerations

5.84     The amended site differs substantially from that accompanying the original objection. With regard to green belt considerations, the council agrees that the issue of coalescence and the use of the site for recreational or other institutional uses are not particularly relevant. However, the council considers that the site establishes a clearly defined physical boundary to the urban area and provides an important landscape setting for Hardgate. Although the council intends to undertake a strategic review of the green belt as part of the preparation of a local plan for the whole council area, no comprehensive assessment of the green belt has been carried out to date and there has, therefore, been no comprehensive assessment of the appropriateness and defensibility of green belt boundaries. On the evidence presented to the inquiry and my site inspection, I do not consider that the urban edge of the settlement is well defined in the vicinity of the site. In fact, I would suggest that the boundary is somewhat convoluted, particularly south of the site and the property 'Three Acres'.

5.85     The council considers that the site forms part of an important 'green finger', having regard to its landscape and nature conservation interests.  However, on the evidence submitted, I am satisfied that the site only plays a limited role in terms of the landscape setting of Hardgate/Clydebank. The site is bounded to the west and south by existing development, and is dwarfed by the overhead power lines to the north and the Faifley flats to the east. Despite its location on rising ground, there is limited visibility of the site, other than from the adjacent Cochno Road and a small area of Faifley, principally the western end of Flanders Street. In more distant views from Golden Hill Park and beyond, the site simply forms part of the urban fringe. The site does not feature in views from any major road or transportation route, from any scenic viewpoint or from any recreational facilities.

5.86     With regard to the nature conservation interest, the evidence indicates that the more valuable habitats are off-site within the valley of the Cochno Burn and that the development of the objection site would have no impact on the habitat of the Cochno Burn. The loss of the site would not have a significant negative ecological impact, and any negative effect would be offset by the creation of new hedging and hedgerow trees and woodland. There also appears to be an inconsistent approach in the FCLP to the treatment of the Cochno Burn valley and the nearby Loch Humphrey Burn valley.  In the latter case, the green belt boundary cuts across the valley at the outer boundary of the urban area and the undeveloped land on either side of the bum is designated open space not green belt.

IQD/2/160/l                                                     63
5.87     The objection site is not included in the area identified as 'Inner Green Belt-including sensitive wedges' or 'Structural Corridor-separating major parts of the conurbation' on the Key Diagram Inset A on page 28 of the GCVSP. Based on my considerations above, I am persuaded that the amended site of approximately 3 hectares does not make a significant contribution to the purposes of green belts set out in SDD Circular 24/1985.

5.88     Although it was suggested by the council in documentation submitted to the inquiry that the objection site formed part of the 'Green Corridor' landscape type, which follows the Duntocher Burn, identified in the SNH Glasgow and Clyde Valley Landscape Assessment, after discussion at the public inquiry it was agreed that this 'Green Corridor' continues along the Loch Humphrey Burn valley into the Kilpatrick Hills and not along the Cochno Burn. There is some dispute as to whether the site is within the 'Drumlin Foothills' landscape type identified within the Glasgow and Clyde Valley Landscape Assessment. However, the evidence indicates that the site exhibits many of the typical characteristics of this landscape character, where developments should be small scale, sited between the drumlin ridges.

5.89     The council considers that any development on the site would be prominent and significantly alter the appearance of the area, and the site has a low capacity to absorb development. The objectors consider that the landscape of the site has a capacity to absorb small-scale development and have submitted alternative indicative master plans to indicate how the site might be developed for approximately 40 houses. Master plan 2 shows that the housing could be kept away from the more prominent part of the site, which could be retained as woodland/open space. Other woodland planting would compartmentalise the site and farther reduce the visual impact of development.  I recognise that the indicative master plans simply show the objector's initial ideas and any detailed proposals would require to be the subject of the fall development control process. Undoubtedly, any development will alter the appearance of the area. However, I consider that the indicative master plans provide sufficient evidence that an acceptable development could be accommodated on this site, consistent with the advice in PAN 44 and PAN 67.

Highway considerations

5.90     Subsequent to the inquiry, information was submitted by the objectors in respect of a number of highway issues raised by WDC in relation to the original objection. Responses to this information from the council's Head of Roads, Transport and Environmental Services (WDC 109 & WDC 110) indicate that there are no insurmountable difficulties as regards the provision of a suitable access or accesses to the site and no objections in principle to the proposed development, subject to the clarification of certain matters.

Wildlife Corridors

5.91     With regard to objections 7M, 9M & 11M, these relate to the inclusion of a reference to a wildlife corridor described as the 'River Clyde and its tributary bums' in the Technical Supplement of the FCLP. The objections were prompted by the concern that the definition of the Cochno Burn as a wildlife corridor might prejudice the development of the Cochno Road objection site. The council agrees with the objector that the boundary of the wildlife corridor along the Cochno Burn follows the topographical break along the eastern boundary of the objection site. The inclusion of the Cochno Bum in the FCLP as a wildlife corridor would not therefore prejudice the development of the objection site in principle and would have a limited effect on the specific interests of the objector.

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5.92  The objector nevertheless disputes the definition of wildlife corridors endorsed by SNH and West Dunbartonshire Greenspace and continues to be concerned that there is no indication of the extent of the wildlife corridors in the FCLP. It is submitted that the reference to wildlife corridors in the local plan should be excluded until such time as their extent is clarified through the carrying out of Phase I Habitat Surveys. The council does not agree that a Phase I Habitat Survey is necessary before the designation of a wildlife corridor since the council believes that whilst wildlife corridors provide connectivity between habitats, they do not have to be habitats themselves.

5.93  With regard to the principle of identifying the River Clyde and its tributaries as wildlife corridors, I consider that there is justification for this approach in NPPG 14 and the GCVSP. The Mid-Clyde River Valleys Project identified the main tributaries of the River Clyde, including the Duntocher Burn, as wildlife corridors linking designated wildlife sites such as SSSIs and SINCs. The Cochno Burn (and the Loch Humphrey Burn) is a tributary of the Duntocher Bum. With regard to the mapping of the boundaries of the wildlife corridors on the Proposals Map, I consider that this is both impractical and unnecessary. In this instance, I consider it sufficient for the local plan to flag up the fact that the Clyde and its tributaries have been identified as wildlife corridors. Nevertheless, some benefit may be gained by showing the line of the tributaries on the Proposals Map.

Recommendations

5.94     In relation to objections 66, 67 & 129, I conclude that, although there is no justification for the allocation of farther housing sites in the Clydebank Local Plan area from a purely quantitative point of view, I am not wholly convinced that there is an adequate distribution and range of effective land for private sector housing to provide the choice of housing type and residential environment required by SPP 3. I have, therefore, considered the appropriateness of removing the objection site (an area of 3 hectares) from the green belt and allocating it for private sector housing. I conclude that this site does not make a significant contribution to the purposes of green belts set out in SDD Circular 24/1985 and that there are no other reasons for not allocating the site for a development of approximately 40 houses.

5.95  I recommend therefore that a site at Cochno Road, with a capacity for approximately
40 houses be added to the list of opportunities for private sector housing in schedule Hi. With regard to the identification of the site and the green belt boundary on the local plan Proposals Map, I have no particular preference for either of the suggestions put forward by the objector. However, in view of the approach taken in the vicinity of the Loch Humphrey Burn, the council may wish to consider including all the land south of a line between the northern boundary of the objection site and Faifley within the urban area with the Cochno Bum valley between the objection site and Faifley allocated as open space.

5.96     I recommend that no change be made to the local plan as a result of objections 7M, 9M and 11M. However, some benefit may be gained by identifying the tributaries of the River Clyde, to which the reference 'wildlife corridor' in policy E2 and the Technical Supplement applies, on the Proposals Map.

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