Clydebelt

Clydebelt's previous response to the first Draft of the Local Plan is at wdclp24-3-06.html.

to Forward Planning & Regeneration Section
Development & Environmental Services
West Dunbartonshire Council Offices
Garshake Road
Dumbarton G82 3PU

Following Committee meetings and other consultations, I am writing with Clydebelt's agreements, objections and reservations on the West Dunbartonshire Finalised Draft Local Plan. An electronic copy of this text will be sent to epes.west@west-dunbarton.gov.uk. We wish to have our sustained objections heard at any public local inquiry, and wish to be notified of the decision on the plan.

p21 Key Policy GN1 Green Network.

Clydebelt supports this Key Policy proposal, but we object that the Green Network (see status map) would be severely interrupted by building development in the Dalmuir wedge, badly affecting wildlife and people. The principle of Green Belt wedges has been long established, and should not be relaxed in this case. Green Belt wedges and fingers into the urban area assist nature conservation and diversity of animals, birds and plants. The area includes a Site of Nature Conservation Importance, it is a Wildlife Corridor, it contains and provides habitats for a diversity of wildlife which should be preserved and should not put at risk by reducing its protective status.

p19 Key Policy GB1 Green Belt - wording of the policy

1. Clydebelt supports some of this Key Policy, but we object to half of its bullet points, and to areas of Green Belt being removed (as shown on the Proposals Map).

2. SPP21 on Green Belts has emerged since the Consultative Draft of this Local Plan. Although some of it has been taken into account in redrafting the Plan, we object that other parts have not been. Para 24 of SPP21 has "Development proposals, however, must still meet the requirements set out in paragraph 22" and para 23 has "The reuse of buildings of architectural or historic merit should be viewed positively." The first three points of GB1 do reflect these, but the remaining ones do not, and should be removed.

3. We object to Policy GB1 bullet point 4: "where there is a specific locational requirement for the development and it cannot be accommodated on an alternative site.". This was in the previous Local Plan Policy GB1, but it now conflicts with SPP21 guidance, para 26: "Where a proposed use would not normally be consistent with green belt designation, exceptionally it may still be considered appropriate, either as a national priority or to meet an established need, and only if no other suitable site is available. These exceptions to the policy should be highlighted in the development plan to allow for wide publicity and engagement." This GB1 Policy bullet point is far too wide ranging, and does not highlight the nature of exceptions.

4. We object to Policy GB1 bullet point 5: "where there is a necessity for additional land for development purposes, having regard to the requirements of the approved Structure Plan." This was in the previous local plan policy GB1, but now conflicts with SPP21 guidance: SPP21 para 16 "As a green belt is intended to achieve long-term certainty, it should have a timeframe of at least 20 years. The green belt boundary should be drawn to reflect a long-term settlement strategy, and ensure that settlements are able to accommodate planned long-term growth. This is necessary to avoid the cumulative erosion of a green belt's integrity through the granting of individual planning permissions." and para 20. "The continuing relevance of the green belt boundary should only be reconsidered after 20 years." SPP21 expects a Local Authority to specify land for development purposes and protect the Green Belt for a longer period than the lifetime of a Local Plan, and expects any Structure Plan to respect this.

5. We object to Policy GB1 bullet point 6: "the development does not adversely affect the landscape character of the local area." This point is not a kind of use, and implies developments far more wide ranging than any use specified in SPP21. It should be incorporated into the last paragraph of GB1 as another condition of acceptability.

6. Para 3.14 should include in its first sentence that the key objectives of SPP21 (from the Summary) are for clarity and certainty, long term land use, and avoidance of unmanaged and unplanned urban expansion

7. Nowhere in the Finalised Draft is there mention of the guidance from SPP21, para 18, that "Local authorities should work with the range of stakeholders to agree a master plan. A master plan can be adopted by the planning authority as supplementary planning guidance, and will then be a material consideration in determining applications and appeals, as set out in SPP1: The Planning System. This is an effective way to ensure that development can be phased and co-ordinated appropriately."

p19 Key Policy GB1 Green Belt - removal of Green Belt

1. Clydebelt objects to areas of Green Belt being removed, as shown by comparing the Proposals Map with those of the currently adopted Local Plans.

2. We are not satisfied with the process by which the Green Belt was reviewed. Its conclusions do not seem to have been subjected to a Strategic Environmental Assessment. The Review itself seems to have been carried out without public consultation, which SPP21 requires. The Review was made public only by including its conclusions in the Proposals Map of the Finalised Draft Local Plan. IronsideFarrar's report, which was only part of the review, has been made public, but only some of the consultants' recommendations were selected for the Local Plan. No justification has been given for this selectivity.

3. The consultants' recommendations to release Green Belt seem to have been unduly influenced by the Council's opinions, rather than by IronsideFarrar's own methodology. In section 3.3 Assessment Process, of the landscape assessment report, "The conclusions of each area assessment are largely based on the results of the surveys. However, where appropriate, the conclusions have also taken account of other considerations within the context of the evolving Local Plan, as advised by West Dunbartonshire, including existing planning consents and strategic land use objectives."

4. Clydebelt disagrees with most of the consultants' recommendations to release Green Belt. We feel that they deferred to the Council's desires to remove parts of the Green Belt, their methodology was flawed and their conclusions were not self-consistent

5. We believe that there must have been undue pressure on the consultant's to recommend removal of the Auchentoshan area from Green Belt, to justify at a Public Inquiry (SEIRU Ref:NA/WDS/002) the decision to approve of a mixed development of New Auchentoshan Adult Centre, Bobath Centre, Children's Cerebral Palsy Therapy Centre, Future Residential Site, All At Auchentoshan Estate, Clydebank (West Dunbartonshire Council Ref:DC06-077).

6. The consultants assessed each of 26 areas of Green Belt around two main criteria: consideration of the greenbelt objectives and functions described in SPP21, and current best practice for the assessment of landscape character and sensitivity. We disagree with many of the detailed conclusions that they draw. For example, Site Name Cochno Small Holdings Composite Areas: 11 and 12 We cannot agree that Site 11 is "residential in character and does not meet green belt objectives or uses and should be removed from the green belt." We note that the Council has not removed this site from Green Belt in the Proposals Map.

7. We disagree with many of IronsideFarrar's "statements on whether the area and component sites meet any or all of the three SPP21 objectives and perform any or all of the four green belt functions as well as preventing coalescence."
Does the site meet SPP21 objectives?
- Directs planned growth to the most appropriate locations and support regeneration
- Protects and enhances the character, landscape setting and identity of towns and cities
- Protects and gives access to open space within and around towns and cities, as part of the wider structure of green space
and
Does the site perform the SPP21 approved functions?
- Agricultural uses, including the re-use of historic agricultural buildings in keeping with their surroundings
- Woodland and forestry, including community woodlands
- Horticulture, including market gardening (but not retailing unconnected with or out-of-scale with this purpose)
- Recreational uses that are compatible with an agricultural or natural setting (eg. golf courses, equestrian uses, fisheries, non-motorised cycling facilities, walking, parks and playing fields)

8. On landscape character and sensitivity we maintain that value or importance should be judged by local people as well as landscape consultants, and that several of the Green Belt areas that are proposed to be removed are actually valued for Green Belt purposes, especially recreation.

9. IronsideFarrar's report is contradictory, lacks self-consistency, and often illogically suggest removal from Green Belt. For example, p37, "Sites 22, 24, 27 and 28 meet all three Green Belt objectives", "sites 22, 27 and 28 would be highly susceptible to development due to the steep topography and their high recreational, biodiversity and scenic value.", "Sites 22 and 27 perform two out of the four main Green Belt uses: woodland and recreational activities". But it "Suggest the removal of all the sites from the Green Belt"

10. SPP21 para 9 has "Green belts can encircle settlements but can take a variety of other forms including buffers, corridors, coastal strips or wedges, to take account of local circumstances." We disagree that, eg, the Dalmuir Wedge does not have appropriate Green Belt uses, and that separation from the main Green Belt by a road is an appropriate reason to remove from Green Belt.

11. The need to establish a robust and consistent boundary has sometimes led to the exclusion of potentially suitable areas from the green belt and their suggested reclassification as urban open space. We consider that Green Belt status provides much more protection than Open Space. There are only weak policy criteria to prevent Open Space being made available for built development (Policy R1). A change would follow developers' pressure, or a review of need for Open Space. Green Belt has a great deal of Local Plan, Structure Plan and national policy protection, and many tests are required to be considered if a Council wishes to permit development.

p19 Key Policy GB1 Green Belt - particular areas of Green Belt

1. Site Name: Auchnacraig , composite areas 5 and 10.
We object to the removal of Green Belt north of Cochno Town Farm (5), which would provide inadequate protection, and west of Cochno Burn (near Cochno Road) (10) which would severely narrow the corridor.

2. Site Name: Wester Cochno Holdings, composite area 14.
We object to the removal of Green Belt "14 is managed as amenity space, so it should be classified as urban open space and removed from the green belt" provides inadequate protection.

3. Site Name: Clydebank Crematorium , composite area: 20
We do agree that "Additionally a small sliver of land, south of the school is part of site 20 but has not been included in the green belt. This area links site 20 to Stark Avenue and should be included in the green belt." and we approve that the Plan now includes this.

4. Site Name: Mount Pleasant & Gavinburn Farms, composite area 32
We object to the removal of Green Belt north of Mount Pleasant Drive, Old Kilpatrick. The landscape report has "All the sites meet all three green belt objectives:" "Site 32 has only one green belt use with limited recreation occurring." but recommends removal from Green Belt because "Site 32 is isolated physically from the rest of the green belt to the north and west" As we have argued above, separation from the main Green Belt by a road is not an appropriate reason to remove from Green Belt.

5. Site Name: Renton, composite areas: 54, 71 and 72
We are pleased to see this designated as Green Belt, as well as designated as a local nature conservation site in the Local Plan

6. We object to removal of the Green Belt wedge which extends south from Auchentoshan and the Duntocher Burn through Dalmuir Park, including the area north of the Great Western Road around the Duntocher Burn. Our arguments are the same as when we objected to your same proposal in 2002 in the draft Clydebank Local Plan. We remind you that you eventually agreed (September 2003) to keep this area as Green Belt.

7. All of this area should remain Green Belt, and not become only "Open Space" or "Public Services" and certainly not be released for housing. Although there would be protection of some of this area under Policy E3 (Local Nature Conservation Site) and under Policy E7 (Woodland, Parkland Retention), we consider that it would have much stronger protection as Green Belt. The areas covered by E3 and E7 should be under GB1 as well.

8. Policy E9, Landscape Character, of the Plan has "... green corridors through the urban area ... Proposals should contribute to conservation or regeneration of these landscapes..." The site is clearly part of the wildlife green corridor which connects Dalmuir Park and Golf Course with the Kilpatrick Hills. Building development would further isolate these areas. The importance of this Green Corridor is shown on the GN1 map p 22 of the Plan. It is an integral part of the Dalmuir ‘green wedge' and compliments the differing topography and habitats of Dalmuir Park and the Golf Course. The estate has considerable potential as an informal woodland park and wildlife area. The site is adjacent to a Site of Importance to Nature Conservation which could only suffer if adjoining housing development was allowed. 2. Policy E7 has "there will be a presumption in favour of the retention of existing woodland or parkland". The site has both woodland and parkland and is at present the subject of a Tree Preservation Order.

9. The adopted Glasgow & Clyde Valley Structure Plan, in particular Strategic Policy 1, which requires Local Plans to safeguard the Green Belt (Paragraph 7.23 of the Structure Plan), provides for adjustments to the Green Belt boundary if meeting requirements of Strategic Policies 1, 3, 5, and 6, or if an equivalent area of brownfield land is restored for Green Belt purposes. None of these conditions apply to this case. This area is identified as "sensitive inner Green Belt". It is part of the Green Network (now incorporated in Policy GN1) which the Structure Plan proposed to be created, to link with and complement the Green Belt, integrating town and country.

10. SNH's 1998 "Glasgow & the Clyde Valley Landscape Assessment", as quoted on p6 of the report by IronsideFarrar, summarised: "SNH considers that planning... should aim to protect, conserve and enhance the green corridors".

p24 Key Policy WC1 Wider Countryside.

Clydebelt agrees with this Policy.

p24 Key Policy RSA1 Regional Scenic Area.

Clydebelt agrees with this Policy.

p25 Key Policy SUS1 Sustainable Development.

This Policy is welcomed.

p29 Policy GD1 Development Control.

Although Clydebelt agrees generally with this Policy, details of the specific design guidelines (which have not been produced for consultation, apart for the Riverside) may not be accepted.

p31 Policy GD2 Redevelopment Opportunities.

1. We object to aspects of redevelopment opportunity site GD2(10), Bowling Basin. Policy GD2 requires compliance with other Local Plan Policies, but residential/leisure/commerce redevelopment of this site would be incompatible with E2 (landfill/ flood defence measures and removal of all vegetation and majority of trees in Ramsar/ SPA site), BE2 (listed buildings - swing bridge, viaducts, Customs House, boathouse, lower locks) and BE5 (Forth and Clyde Canal scheduled ancient monument) and the nearby most westerly fort of the Antonine Wall may obtain World Heritage Site status.

2. We particularly object to any residential development in this area which would prevent suitable leisure, recreation and tourism provision in this important tourist attraction and canal gateway. It is an historic area which should be protected (NPPG18: Planning and the Historic Environment, para 37).

p55 Housing.

1. In p54, para 6.7 there is some confusion in what seems to be a summary of national policies. It seems worth adding to this paragraph (from SPP21) the need for the Local Plan to define the Green Belt, and protect it from housing development for a much longer period than the 5 years of most of the Plan's policy provisions. The reference to "Green Belt land" in the middle of this paragraph should then be changed to "greenfield land".

2. Clydebelt welcomes the assessment in paragraph 6.14, p 55, that any shortfall in the housing market area in the period up to 2018 may be met without Green Belt release. However we note here that we disagree with the Structure Plan housing needs being projected assuming that there will be significant economic growth to decrease net migration out. This optimistic assumption will led to far more land being made available for housing than necessary.

3. We object to the inclusion in p61 Schedule H2 Opportunities for Private Sector Housing, of H2(12) Auchentoshan Estate. We argue above that this should remain as Green Belt, and not have any housing, let alone the large number of 30 houses. Policy directs housing to brownfield sites (eg GB1, H2) of which there are more than enough. Preference is for housing on brownfield sites, and enough of these sites have been identified for the lifetime of the plan. development would conflict with Scottish Planning Policy on Land for Housing, SPP3, that housing should be mainly permitted in brown field sites in preference to green field sites. At the 2004 Local Plan Inquiry the reporter did not consider that there would still be a shortage of executive family housing in the area beyond those he recommended for Cochno Road.  This is still true.

p80 Policy RET2 Retail Developments Outwith Town Centres.

Clydebelt welcomes the retention of this Policy from earlier Local Plans.

p91 Policy T2 Access Improvements.

We would object to the extension of the A814 into Green Belt, Woodlands & Parklands, or the International Nature Conservation Site. We therefore regard this aspiration as not realistic.

p99 Policies E1 to E9 and BE1 to BE7 Environment.

1. Clydebelt strongly supports Policies E1 to E9 on the environment and we hope that if they are approved they will be vigourously addressed.

2. We support Policies BE1 to BE9 on the built environment. particularly BE6 on the setting of the Antonine Wall.

p107 Policy E8 Environmental Improvement Opportunities at Boulevard site

Clydebelt welcomes the inclusion, in Schedule E8 of Environmental Improvement Opportunity Sites, of E8(3) 2.2ha of the Boulevard at the Kilbowie Roundabout for a Gateway feature and parkland, and its consequential removal from commercial zoning.

p117 Policies R1 to R7 Open Space, Access and Recreation

1. Whilst generally welcoming Policies R1 to R7, Clydebelt considers that the application of this Policy is extremely sensitive and difficult. Balancing different people's values of the countryside and kinds of recreation is not easy

2. We particularly consider that (Policy R6) new golf courses within the Green Belt would be unlikely to satisfy this, and other Green Belt policies, and Policy R6 should therefore be deleted.

p130 Public Services

1. Clydebelt welcomes the proposal in Policy PS2, Community Learning Campus at Boulevard site, as shown as orange colour on the Clydebank Proposals Map, for the whole of the undeveloped Boulevard site apart from 2.2ha proposed for a Gateway feature and parkland, to be reserved for the regeneration of the school estate as a Community Learning Campus.

2. We trust that policy for the whole Boulevard site will be in accord with the Report of the CLP Inquiry para 6.14 "... I have some sympathy with the views of Clydebelt in relation to the desire for the provision of some open space and screening along the A82. Such screening would not only benefit the proposed housing but it would also enhance the view from the A82, an important route to Loch Lomond and Argyll."

3. We comment on the inclusion in schedule PS3, Public Service Opportunity Sites, of PS3(7) Auchentoshan Estate, that we object to development other than on existing sites of buildings, and consider that the area should remain as Green Belt.

p140 Policy DC4 Telecommunications.

We hope that proposals for telecommunications equipment installation will be rigourously assessed against the criteria listed.

p143 Policies DC6 and DC7 Renewable Energy.

1. We generally support these policies, and are glad that the policies no longer include any of the Kilpatrick Hills Regional Scenic area as a potential area of search for wind power generation development.

http://www.clydebelt.org.uk/wdclp15-11-07.html created 15/11/07, modified 11/6/2008 by Dutyhog.