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Clydebelt comments on West Dunbartonshire Finalised Draft Local Plan, sent 15 Nov 2007

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

and responses received 9 May 2008

and our draft comments at 11-6-08 on whether we sustain or withdraw our objections.

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 We wish to have our sustained objections heard at any public local inquiry, and wish to be notified of the decision on the plan.

I refer to your letter dated 15th November 2007 making representations to the West Dunbartonshire Local Plan Finalised Draft. In summary of your submission, Clydebelt object to Policy GB1 (on 3 counts), the removal of five sites from the green belt, including the Dalmuir Wedge, the Redevelopment Opportunity Site at Bowling Basin (GD2 (10)) and Private Sector Housing Opportunity Site at Auchentoshan Estate (H2 (12)). In addition, comment has been made in respect to a number of policies and proposals, notably Policy R6, and upon the Green Belt Review.

The submission has been considered and the following response covers the objections and recommendations raised within your letter:

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.

GN1: Clydebelt's support for this Key Policy is acknowledged. Matters relating to the Dalmuir Wedge are considered below.

We withdraw this objection to GN1, but still object to removal of Green Belt at Dalmuir in a later objection.

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.

GB1, bullet point 4: I do not consider that this bullet point conflicts with SPP21. As per paragraph 26, the wording allows for non-conforming uses to be developed in the green belt where no other suitable sites are available. The exceptions are described as those with a specific locational requirement. To clarify the bullet point in accordance with SPP21 the following amendment (shown in italics) is proposed: 'where there is a specific locational requirement and established need for the development and it cannot be accommodated on an alternative site'.

This is modification 10. We sustain our objection. Although the wording is an improvement, SPP21 guidance, para 26 requires: "These exceptions to the policy should be highlighted in the development plan to allow for wide publicity and engagement." The development plan does not do this at all.

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.

GB1, bullet point 5: I note that paragraph 16 of SPP21 states that as a green belt is intended to achieve long-term certainty, it should have a timeframe of at least 20 years and that the green belt boundary should be drawn to reflect a long-term settlement strategy. The Glasgow and Clyde Valley Joint Structure Plan sets the long term settlement strategy for West Dunbartonshire and requires the continued designation and protection of the Green Belt, which is reflected in the West Dunbartonshire Local Plan and Policy GB1.

Future Strategic Development Plans may, however, require additional land for development purposes, which may not be reflected in the Local Plan. This bullet point allows for the release of green belt land if it is required for development by future Strategic Development Plans. It is not the case that strategic plans must respect 20-year green belt boundaries drawn in local plans/local development plans where a requirement for green belt release is identified.

Modifications 8 & 32 satisfy this objection. We withdraw our objection. However we are sure that strategic plans must respect 20-year green belt boundaries - see SPP21 guidance, para 26 req13-21).

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.

GB 1 bullet point 6: This bullet point is applicable where one of the previous five criteria is met (hence 'and' at the end of bullet point five, not 'or'). It is not intended to allow uses other than those specified in SPP21 and Policy GB 1, rather it is intended to ensure appropriate development in the green belt does not adversely affect landscape character. In the interests of clarity, however, this sentence will be incorporated into the last paragraph of Policy GB 1 as suggested.

Modification 11 satisfies this objection. We withdraw our objection.

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

Para 3.14: The purpose of designating green belts is described at paragraph 3.13. It states that green belt land is designated for the purposed of managing the long term growth of urban areas. This wording will be amended by the inclusion of the following sentence: 'As the Green Belt boundary is intended to achieve long-term certainty, it should have a timeframe of at least 20 years.' Paragraph 3.14 accurately reflects the key objectives of green belt policy, as described in paragraph 6 of SPP21.

Modifications 8 & 32 satisfy this objection. We withdraw our objection.

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."

Clydebelt's submission refers to the omission of reference within the Local Plan to paragraph 18 of SPP21 on the preparation of a master plan. Master plans in this context are only applicable where development plans identify green belt land to meet the areas' long-term development needs; land between the current settlement edge and the green belt boundary which is identified as the broad extend of future growth. The West Dunbartonshire Local Plan does not identify land beyond the settlement edge for development, instead long-term development needs are met by brownfield sites within settlements and therefore it is not necessary to prepare a master plan.

We accept this explanation, and withdraw our objection.

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).

Green Belt Review: I note that Clydebelt are not satisfied with the process by which the Green Belt was reviewed and disagree with a number of the recommendations made. The Ironside Farrar report 'West Dunbartonshire Local Plan. Landscape Assessment of Green Belt' forms the finalised Green Belt Review and supersedes previous work carried out by the Forward Planning Section, incorporating previous drafts where relevant. As a technical document forming an appendix to the West Dunbartonshire Local Plan, separate consultation and strategic environmental assessment is not necessary. All the recommendations made by Ironside Farrar have been incorporated into the Local Plan. Where Clydebelt have raised an objection to a specific site this is addressed below.

We understand that the Council now regards IronsideFarrar's report as the whole of the review, but we are sure that there were other parts of the process that have not been made public. Our objection to the process will be included in other detailed objections below.

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.

Paragraph 6 on page 3 of your submission states that Clydebelt cannot agree with the Green Belt Review in its recommendation that Site 11 (Cochno Small Holdings) should be removed from the green belt and notes that the Council has not removed this site from the green belt upon the Proposals Map. On the contrary, ,Site 11 has been removed from the green belt. It is agreed that as a residential dwelling, No.8 Holding, Cochno Road and its curtilage, the site is not compatible with green belt objectives.

We now agree that the Council has removed this site. We sustain our objection to removal of Site 11, or at least to the removal of the fields that lead down to he burn.

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
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.

The Council does not seem to have responded to this objection to the methodology (our paras 7-10) and interpretation of SPP21 para 9 (our para 11). We sustain our objection, and will include in with the one below concerning Open Space.

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.

Open space is protected within the Local Plan by Policy R1, which outlines a presumption against development which adversely affects the use, character or amenity of areas of functional open space. This reflects SPP 11, published by the Scottish Government in November 2007, which strengthens the protection of- existing open space. The SPP introduces a presumption against development of open spaces which are valued and functional or which are capable of being brought into functional use to meet a need identified in an open space strategy. Furthermore, similar to the case if development is proposed in the green belt, SPP 11 includes a requirement to notify Scottish Ministers before granting planning permission for development which would result in the loss of land identified as open space in the development plan.

It is clear that the protection afforded to designated open space is of a nature similar to green belt and should not be considered as being of lesser protection. Policy R1 thus provides a comparable level of protection for open space re-designated from green belt whilst better reflecting the nature of the land use of these sites. This approach has assisted in achieving a robust inner green belt boundary that takes account of appropriate landscape features which identify that boundary. In addition to Policy R1 and SPP11, open space is protected by Green Network policies in the Local Plan and Structure Plan. The reclassification of these sites does not weaken the green network or the protection of natural heritage interests, particularly wildlife corridors, within the Plan area and I draw your attention to paragraph 9 of SPP 21 states that green belt policy is not a designation to protect natural heritage.

We objection to Open Space being regarded as equally strong protection as Green Belt. We sustain our objection, and will include it with the one above.

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".

The West Dunbartonshire Local Plan Finalised Draft reflects the findings of the 'Landscape Assessment of Green Belt' Report (Green Belt Review) which recommends the removal of a number of sites from the green belt and their re-designation as open space. Clydebelt has objected to the removal of five such sites from the green belt and their re-designation as open space: Auchnacraig (composite site 5, north of Cochno Town Farm and site 10, west of Cochno Burn), Wester Cochno Holdings (site 14), Mount Pleasant Drive (site 32) and the Dalmuir Wedge.

In light of the above, no modifications are proposed to the West Dunbartonshire Local Plan Finalised Draft in respect of the Dalmuir Wedge or other sites which have been removed from the green belt and designated as open space.

We sustain our objections to all of these sites.

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.

WC1, RSA 1, SUS 1, GD1: The Council acknowledges Clydebelt's comments on these Policies.

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).

GD2 (12) Bowling Basin: The redevelopment opportunity site at Bowling Basin does not include ground within the Inner Clyde Ramsar/SPA site and does not have any nature conservation designations. With allowance for wildlife corridors along the canal and the river, the site is considered suitable for development in this regard. An Appropriate Assessment of proposed development will be required. Similarly, the heritage designations under BE 2 and BE 5 do not preclude development and given the condition of many of the structures on the site it is considered any redevelopment, which would be required to retain and enhance the historic environment, would be beneficial. The residential development of the Bowling Basin area would add vitality and activity to the Basin area and provide security and supervision over the canal area and would not prevent suitable leisure, recreation or tourism provision. The Council considers the residential use should be restricted to 90 dwellings or less in order not to over develop the site and to protect the greenspace between Bowling and Old Kilpatrick from coalescence.

We note that this objection was to GD2(10), not GD2(12). We sustain our objection.

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.

Chapter 6 - Housing: Paragraph 6.7 clearly summarises national policy in relation to housing by reflecting SPP3 Planning for Housing. Paragraphs 3.13 - 3.17 (as amended) describe green belt timeframes. I note that Clydebelt disagree with the housing needs assessment being projected assuming significant economic growth, however, the Structure Plan projections and policies in relation to future growth and housing projections have recently been approved by the Scottish Government. As you are aware, the Structure Plan concludes that there is no requirement to release any additional land from the Green Belt in West Dunbartonshire for housing development up to 2018.

Following the credit crunch and collapse of the housing market, and the return home of many Eastern European immigrants, we feel even more strongly that the projections are not correct.

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.

With regard to Clydebelt's objection to the Private Sector Housing Opportunity at Auchentoshan Estate (H2 (12)), following the decision of Scottish Ministers to approve outline planning permission for a replacement adult training centre and for a children's cerebral palsy therapy centre but refuse planning permission for a residential site, Site H2 (12) will be deleted from the Local Plan.

This is modification 35. We welcomed the refusal of permission for a residential site, and the removal of H2(12). We withdraw our objection.

p80 Policy RET2 Retail Developments Outwith Town Centres.

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

Policy RET2: Comment noted.

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.

Policy T2: I note that Clydebelt would object to the extension of the A814 into green belt, woodlands & parkland or the International nature conservation site. It is anticipated the extension of the A814 would partly follow the line of the disused railway solum east of Dumbuck therefore would not encroach on the Inner Clyde SPAIRamsar site, however, the final line of the route is not known. Consideration of the route would be subject to an Appropriate Assessment. It would be premature to dismiss this medium term transport project as unrealistic.

We sustain our objection.

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.

Chapter 9 - Environment: The Council welcomes Clydebelt's support for policies within the Environment chapter.

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.

E8 (3) The Boulevard, Clydebank: Clydebelt have welcomed the inclusion on this site within the schedule of Environmental Improvement Opportunity Sites. The site is currently subject to a planning application for the formation of park and ride car park with associated access and landscaping. Remediation works on part of the site have been carried out by the Council's Roads Section.

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.

Chapter 10 - Open Space, Access and Recreation: I note that Clydebelt generally welcome Policies R1 to R7 but state Policy R6 should be deleted. Indicative research suggests there is demand for a golf course in West Dunbartonshire and thus it is right to consider the development implications of such a development. Policy R6 sets out criteria which would be considered for any such proposal and aims to protect the countryside environment, heritage and nature conservation interests. Not to have such a policy would leave the area with lesser protection against unsuitable golf course development.

We accept the need to control golf course developments through the Local Plan, but believe that policy R6 should be much stronger. We sustain our objection.

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.

With regard to the identified Public Service Opportunity at Auchentoshan Estate for an adult learning centre (PS3 (7)), the Local Plan will be amended to reflect the decision of Scottish Ministers to approve outline planning permission for a replacement adult training centre and for a children's cerebral palsy therapy centre

We accepted the Scottish Ministers' decision, reflected in Modification 103, and withdraw our objection.

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.

Policy DC6 and Policy DC7: I note that Clyde belt generally support these policies and welcome the deletion of the Area of Opportunity for a windfarm within the Kilpatrick Hills.

Modifications to the Local Plan which are proposed to satisfy representations or to update the Plan prior to a Public Local Inquiry have been approval by the Council and will shortly be subject to a further consultation period. You will be informed of all the modifications made and you may make further representations or objections to them.

If you wish to pursue your objections you can to present your arguments either orally or in writing to a Reporter appointed from the Scottish Government Directorate for Planning and Environmental Appeals.

I would be grateful if you could indicate how you wish to proceed. Do you wish to withdraw your objection on the basis of the proposed modifications to the Plan? If you consider your objections have not been met do you wish: i) to be heard orally at a Local Public Inquiry or Hearing; or ii) do you wish to make Written Submissions?

I look forward to hearing from you on this matter at your earliest convenience.

Yours sincerely,

Steve Marshall,

Section Head, Forward Planning and Regeneration created 15/11/07, modified 11/6/2008 by Dutyhog.