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23rd April 2003
Thank you for your letter of 6th March and the List of Proposed Modifications to the Clydebank Local Plan. We are glad that several of the proposed modifications followed our earlier representations. We wish to make representations and objections on the following.
We support modifications 2, 3, 7, 8, 9 ,10, 14, 19, 21, 23, 27, 28, 31, 34, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 58, 60, 61, 72, 73, 74, 75, 79, 87, 88, 89 and 90 and make the further point that we would object to any dilution of their intentions. We particularly welcome the proposed introduction of Policy E8 (modification 53), modifications 50 to 52 on trees, and modification 8 to Policy SA1.
We would support this amendment only if the word "significant" were removed, or a satisfactory definition of "significant" were included in the Glossary. This point applies more generally than to this modification. We have not found an explanation of "significant" in planning documents, eg NPPGs and SPPs. It is a relative term, and needs explaining, eg to what kind of person something may be significant, or what is "significant" in the wider public interest. We suggest that you consider other government guidelines, eg in the Standards Commission's Codes of Conduct and associated guidelines, where there are tests of whether issues are significant to the public, officials and elected members.
We cannot comment because these modifications do not seem to be related to these policies. The word "significant" arises again - see above comments.
The development opportunities site at the Boulevard H1(14) (also listed in Schedule GD1(8) p24) is one which Clydebelt prefers to retain as a green open space, especially as part of the Green Network alongside the Boulevard. We question whether it can be entirely classified as a former industrial site, and it is vacant, but hardly derelict. It should be retained for an enhanced entrance to Clydebank. If the area were to be rezoned for housing and/or commercial development it should be screened from the Boulevard with no access directly from the Boulevard.
This is satisfactory provided that modification 78 is adopted. Otherwise Policy CD1 would need to include its definition of "Edge of Centre".
We welcome this modification, and propose the addition into the first paragraph of "existing access to the countryside". This would raise, in consideration of a development proposal, the safety and nuisance aspects of access by walkers, anglers etc near to or through the site. We also propose that the justification of this policy should note that The Glasgow and Clyde Valley Structure Plan, the Dumbarton Local Plan and NPPG6 on Renewable Energy discourage wind farm development in a Regional Scenic Area (such as the Kilpatrick Hills), or outwith designated preferred places (which the Structure Plan identifies as to the south and east of Glasgow). It would be helpful for the policy to point out that areas zoned for industrial use may be particularly suitable for some kinds of renewable energy developments.
We propose that the list of Wildlife Corridors be more specific about the "River Clyde and its tributary burns" by naming the Duntocher Burn, the Cochno Burn etc.
We welcome the modification to identify the area around the former Hardgate Post Office as Open Space, but - because the document is not specific about the extent of this area - we consider that the area should be contiguous with what is known as the Faifley Knowes.
The proposal to introduce a further bullet point to read "it does not have an adverse impact on the environmental character of the area" is undesirable. This would enable a proposal to be determined on opinions of the relative qualities of the design of the proposal and the condition of the area of Green Belt concerned. It is well known that part of a Green Belt area can be allowed to become unattractive, eg by dumping, so that opinions swing against its retention. This bullet point could be acceptable if it included some safeguard such that the earlier, restorable or potential environmental character of the area should be the quality considered. But we consider that it is safer to not use exclusions which would lead to the preservation of Green Belt depending on perceptions of its current relative quality.
The wording of this point is not consistent with the grammar of the policy, and omits the necessary "and". However we object to its inclusion as too permissive, and propose that the requirements of NPPG8 and the Structure Plan would be covered adequately by the 2nd bullet point (perhaps adding a few words).