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Clydebelt comments on West Dunbartonshire Draft Local Plan, sent 29 March 06

Clydebelt's response to the Finalised Draft Local Plan is at wdclp15-11-07.html.

and responses received 14 Nov 2006

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 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.

14 November 2006

Thank you for your comments dated 29 March 2006 to the West Dunbartonshire Local Plan. I apologise for the delay in responding, however I would ask you to note the Council's response to the representations Clydebelt has made as follows.

p18 Policy GN1 Green Network.

Clydebelt supports this Policy proposal.

The Council welcomes Clydebelt's support for the Green Network as set out in policy GN 1.

p19 Policy GB1 Green Belt.

1. Clydebelt generally agrees with this Policy, which is very similar to that supported in the current Clydebank and Dumbarton District Wide Local Plans. We welcome the new reasoned justifications paras 3.15 to 3.18.

The Council welcomes Clydebelt's support for the new reasoned justification to policy GB 1 as set out in paragraphs 3.15 to 3.18.

2. Having been involved in much discussion and representation on the draft SPP21: Green Belts, we are aware that you may wish to modify your Policy, and its reasoned justifications, after SPP21 appears, which may be within a few weeks of the deadline for comments on this draft Local Plan. We hope you will agree to enter into discussion on any modifications to Policy GB1 at an early stage before your final draft is produced.

You suggest modifications to Policy GB1 in light of the publication of SPP 21. The Council as part of the Local Plan process have undertaken a review of the Green Belt and have recently engaged consultants to complete a further technical exercise, the conclusions of this work are likely to be incorporated in to the Final Plan, and therefore the Council would be eager to enter into discussion with Clydebelt once the Green Belt review has concluded early in 2007, and Policy GB 1 will be revised to reflect the advice set out in SPP 21.

3. We agree with para 3.16 in the draft that coalescence is "a particular issue with regard to Old Kilpatrick/ Bowling and Bowling/ Milton", whether or not in Green Belt. We would like housing and transport Policies to clearly assert the need to prevent coalescence (in para 6.14 and in Policy T4).

You request that the housing and transport policies should clearly assert the need to prevent coalescence. It is the Council's view that this is not required as Policy GB 1 is a key policy, which sets the context for the settlement strategy and provides a framework ensuring against the coalescence of settlements. It is more appropriate that the Green Belt policies of the Local Plan address the issue of coalescence rather than housing or transport policies.

4. 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.

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.

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.

The Glasgow & Clyde Valley Structure Plan, effective from 1st May 2002, and not changed on Green Belts in the recent draft amendments, should be observed, 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 your draft Policy GN1, see map p20) which the Structure Plan proposed to be created, to link with and complement the Green Belt, integrating town and country.

Clydebelt object to removal of the Green Belt which extends south from Auchentoshan and the Ountocher Burn through Oalmuir Park, this matter was considered by the Council's planning Committee in October however they decided to continue consideration of this matter until the current application by Bobath Scotland had been determined. It is likely therefore that a further report on this matter will be presented to Members in January for a decision and I will inform of this in due course.

5. We object to the 4th bullet point: "it forms part of an establishment or institution standing in extensive grounds (such as park land), provided that the development does not adversely affect the countryside character of the area". This is the same objection to inclusion of this bullet point that we made for the currently adopted Clydebank Local Plan, and it also reflects concern about how SPP21 may treat this issue.

The wording of this point was introduced late into the process of establishing the previous Clydebank District local plan, and Clydebelt objected. This was carried through to the public local inquiry in 19th November 1993. As a result of that inquiry, the reporter recommended (in his paragraph 4.29) that a further modification be made to the local plan so as to read: "It forms part of an establishment or institutions standing in extensive grounds (such as Woodland Policies or park land), provided that the development is of limited scale and visual impact, such that the rural character of the area is not adversely affected..."

This modification would have been acceptable to Clydebelt, but unfortunately the District Council did not adopt it. We therefore object to this wording in the current draft West Dunbartonshire Local Plan, and propose wording as recommended by the previous inquiry reported. As we commented to the Scottish Executive in the recent consultation on "Getting Involved in Planning" we believe that the scope to depart from Reporter's recommendations should be limited.

You have also objected to 4th bullet point of policy GB 1, you may be aware that the recently published SPP 21 specifically excludes this criterion and therefore this will not be included in the Final Plan.

p22 Policy WC1 Wider Countryside.

Clydebelt agrees with this Policy.

The Council welcomes Clydebelt's support for this policy.

p22 Policy RSA1 Regional Scenic Area.

1. The wording of this Policy is generally better than Policy SA1 - Scenic Areas in the Clydebank Local Plan and Policy NHL19 in the Dumbarton District Wide Local Plan. However we object to inclusion of the last phrase "unless the development is supported by other Local Plan Policies". This phrase is far too broad and permissive since it seems to automatically give all other Policies greater weight. Reasoned Justification para 3.21 only partially counteracts this impression.

2. We hope you will delete para 3.22 of the Reasoned Justification, now that the Glasgow & the Clyde Valley Structure Plan will not include any of the Kilpatrick Hills Regional Scenic Area as a potential area of search for wind power generation development.

Clydebelt generally support policy RSA 1 but suggest some modifications to it. The Council agrees with your point with regard to this policy, and rewording is required. It is therefore proposed that "unless the development is supported by other Local Plan Policies" will be deleted from this policy and that paragraph 3.22 of the reasoned justification, and the final part of paragraph 3.23 will also be deleted from the Final Plan.

p23 Policy SUS1 Sustainable Development.

This Policy, introduced in the Clydebank Local Plan, is welcomed.

The Council welcomes Clydebelt's support for this policy.

p24 Policy GD1 Development Control.

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

The Council welcomes Clydebelt's support for this policy.

p24 Policy GD2 Redevelopment Opportunities.

We object to aspects of redevelopment opportunity sites GD2(4) Bowling Basin and GD2(5) Scott's Yard. Policy GD2 requires compliance with other Local Plan Policies, but inclusion of these sites 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.

We particularly object to 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). We are concerned that "new urban expansion areas" (para 6.14) "in the... Milton and Bowling area" would lead to undesirable coalescence of settlements.

Clydebelt object to aspects of redevelopment opportunities at Bowling Basin and Scott's Yard as incompatible with Policy E 2, BE 2 and BE 5. Scott's Yard has not been objected to by Milton and Bowling Community Council - they accept that the redevelopment of this derelict site would be an improvement to the village, and discussions between the Council, Scottish Enterprise Ounbartonshire, British Waterways, Clydeport and the Community Council have recently taken place concerning the regeneration of this site and land further to the west at Esso Bowling. Any development of this site would require to take account of the policies you refer to but it considered appropriate that this currently derelict site is identified and promoted for regeneration in order to improve the village and its setting. With regard to the site at Bowling Basin, this site has being recognised as having development potential for some considerable time, however it is no longer purely considered for residential development, but for other uses such as leisure and tourism which may have lesser impact. Any development of this site would require to take account of the development constraints that exist in this location, including the nature conservation interests and built heritage matters, such as listed buildings and scheduled ancient monuments, and the policy framework of the Local Plan sets out the Council's position with regard to development that affects such resources. It is also the Council's view that the Saltings and the Canal provide strong separation between Bowling and Old Kilpatrick, and therefore do not consider that the development of this site would lead to the coalescence of the two settlements.

Finally the reference to Clydebank, Milton and Bowling in paragraph 6.14 is to the name of the Structure Plan Housing sub Market Area, and does not intend to suggest that any urban expansion areas will be identified that gives rise to the coalescence of Bowling and Milton. This sentence indicates that in the period 2011 to 2018 if there is a shortfall of housing land, sites may be required to be identified within the sub Market Area to meet this demand.

p45 Housing.

Clydebelt welcomes the assessment in paragraphs 6.14 that any shortfall in the housing market area in the period up to 2017 may be met without Green Belt release. However we disagree with 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 foe housing than necessary.

Clydebelt disagree with Structure Plan premise about decrease in net migration. The Local Plan has to conform to the Structure Plan, and there is general agreement across and outwith the Glasgow & Clyde Valley Joint Structure Plan area that growth will be significant and overall in-migration may eventually become the norm. The technical background to the Structure Plan projections has not changed in essence although the conclusions are more optimistic. The Structure Plan technical work also embraces the concept of mobile demand and housing market areas, which should ensure that demand, will be met, where needed. The Structure Plan, the Local Plan and national policy all emphasise providing housing on brownfield sites. Housing supply and demand equation is assessed on a regular basis to ensure that there is no under or over supply.

p65 Policy RET2 Retail Developments Outwith Town Centres.

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

The Council welcomes Clydebelt's support for this policy.

p78 Policy T4 Accessibility to New Development.

>We ask you to add that this proposal must conform with other Local Plan Policies. We are particularly concerned that there should not be ribbon development along main roads and bus routes, for example to prevent the coalescence of settlements that Green Belts (para 3.13).

Clydebelt are concerned that there should not be ribbon development along main roads and bus routes. The Local Plan is meant to be regarded as a whole when determining applications and all Local Plan policies require to be considered. Policy GO 1 is the general development control policy which is the basis for consideration of planning applications and it refers to 'other local plan policies'. It would not be appropriate, therefore, to include in Policy T 4 and every other specific policy in the Plan a reference to 'other local plan policies'. There is a longstanding planning principle against ribbon development and whilst Policy T 4 suggests development should be close to the main road network this does not mean that direct access onto the main roads may be made by individual developments.

p80 Policies E1 to E8 and BE1 to BE9 Environment.

1. Clydebelt strongly supports Policies E1 to E8 on the environment and we hope that if they are approved they will be vigourously addressed.

2. We suggest that you ensure that in Policy E3 on Local Nature Conservation Sites, that it includes applicable areas of parks, woodlands and open spaces owned by the Council.

The Council welcomes Clydebelt's support for these policies. With regard to Policy E 3.

I can advise that the Council are intending to undertake a Nature Conservation Strategy which will identify relevant local nature conservation sites and it is hoped that this study will be completed in 2007 in order that these sites can be identified in the Final Plan. In addition Policy E 1 of the Plan outlines the Council's obligations with regard to biodiversity whilst national planning guidance, NPPG 14, also requires Councils to safeguard natural heritage interests.

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

Policies BE1 - BE9

The Council welcomes Clydebelt's support for these policies.

p87 Policy E8 Environmental Improvement Opportunities at Boulevard site

Clydebelt welcomes the inclusion, in Schedule E8 of Environmental Improvement Opportunity Sites, of 2.2ha of the Boulevard at the Kilbowie Roundabout for a Gateway feature and parkland, and its consequential removal from commercial zoning. We are pleased that you have followed our suggestion made during consultation on the now adopted Clydebank Local Plan, and supported by the Reporter at the Public Inquiry.

The Council notes that you welcomes the inclusion, in Schedule E8, of the Environmental Improvement Opportunity Site at Kilbowie road roundabout.

p94 Policies R1 to R7 Open Space, Access and Recreation

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. We particularly consider that (Policy R6) a new golf course within the Green Belt would be detrimental to the Green Belt.

The Council notes your general support for the Plan policies relating to access recreation and open space. With regard to Policy R6 concerning the development of a golf course, the requirement for a golf course has been determined by way of Sportscotland's facilities planning model. The Council is currently in discussions with Sportscotland regarding the redrafting this policy, to ensure that no substantial built developments such as housing are linked to any proposals, however it is the Council's view that countryside areas are the most suitable locations for such a facility provided they do not adversely impact on a number of interests, including landscape character.

This policy therefore will be redrafted along with the reasoned justification to take account of the advice from Sportscotland, but will continue to ensure that any proposals will require to be considered against the range of issues outlined in the existing R 6 policy.

p104 Policy PS2 Community Learning Campus at Boulevard site

1. Clydebelt welcomes the proposal in Policy PS2, 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 trust that the proposal for this site now clearly excludes housing, commercial zoning or a motorway services type facility or yet another car showroom. The Report of the CLP Inquiry also had para 6.15 " ... The council intimates that a motorway services type facility and possibly a car showroom, with direct access from the A82, are envisaged ... such developments can be visually intrusive unless handled properly. I would envisage that such a development would take up only a small proportion of the A82 frontage, the larger portion being devoted to landscaping/screening. Also, any such development would require to be well screened and separated from the housing development. On this basis, I am happy for these issues to be explored further through the preparation of a development brief for the site, which I would expect to involve Clydebelt as a consultee." We hope that we would indeed be involved if a development brief is prepared for the Boulevard site.

The Council welcomes your support for the community learning campus allocation at Boulevard, Clydebank.

p110 Policy DC4 Telecommunications.

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

The Council notes your request that criteria in Policy DC4 is rigorously applied, and can confirm that this policy will be a material consideration in determining planning applications.

p112 Policies DC6 and DC7 Renewable Energy.

1. We hope that, in pursuing Policy DC6 on renewable energy, the Council will be proactive in encouraging (as well as wind turbines on brownfield Clyde riverside sites) alternative forms of renewable energy such as tidal and wave energy (eg encouraging installation of the Scottish OPD system on the Clyde) and biomass.

We also ask that, somewhere in the policies or in design guidlelines, there is a requirement for a high level of energy efficiency through planning conditions on the specifications of the large number of new buildings to be erected along the Clyde river front, and in schemes for public buildings.

Clydebelt indicate a hope that the Council will be proactive in encouraging alternative forms of renewable energy such as tidal and wave energy (eg encouraging installation of the Scottish GPD system on the Clyde) and biomass, and I can confirm that this matter will be considered when the Council redrafts Policy DC 6 and the supporting text to provide a criteria based policy to renewable energy in accordance with the forthcoming revision to NPPG 6 and PAN 45.

2. We object to Policy DC7 (renewable energy, windfarms) and trust that you will remove it now that the Glasgow & the Clyde Valley Structure Plan (Draft Finalised Supplementary Written Statement Consultation Document, October 2005, Key Diagram Inset G) will not include any of the Kilpatrick Hills Regional Scenic Area as a potential area of search for wind power generation development (and has restricted maximum capacity on those sites they prefer to 20MW).

As well as conformity with the Structure Plan, our reasons for objecting to this policy proposal are:

The Council will delete policy DC7 from the Local Plan now that the Glasgow & the Clyde Valley Structure Plan does not include any of the Kilpatrick Hills Regional Scenic Area as a potential area of search for wind power generation development.

p114 Policy DC8 Minerals.

We are very concerned that current and forthcoming permitted quarrying is eroding much of the tourist views as they see it from across the Clyde, and pass through the Council's area, and that would deter them from staying. Furthermore archaeological and nature conservation sites have been sacrificed for quarrying. We consider that the Council should study past permissions for quarrying that have not been taken up and revise Policy DC8 to more strongly preserve these precious sites.

The importance of these issues is made clear in the Glasgow & Clyde Valley Structure Plan 2005 Strategic Environmental Assessment, State of the Environment and Trends, Objective 1, in which "... the hills that enclose the Clyde basin are important visual boundaries for a large population and their topographic variety is appreciated and physically experienced on a regular basis. The terraced lava cliffs and scarps of the ... Kilpatrick Hills ... are distinctive features to the north and west." "The interplay of natural topographic features, and the pattern of settlement, means that views from within the urban area are an important feature of the landscape in the study area. In part, this reflects the presence of hills and moors to the north and south of Glasgow. The Campsies and Kilpatricks to the north of Glasgow ... create strong and containing skylines. These come together west of Glasgow to emphasise the narrow part of the Inner Firth of Clyde."

Also in objective 10: Protect, Enhance and Where Necessary Restore the Historic Environment "The most significant visible evidence of prehistoric human endeavours is found in the hills South Lanarkshire and uncultivated areas of the Renfrewshire Heights, the Kilpatrick Hills and Campsie Fells."

Policy DC8 sets out the Council's position with regard to mineral workings, and in particular any mineral workings that would have an adverse impact on nature conservation interests or impact on built or natural heritage resources. No new mineral operations are proposed within the West Dunbartonshire Local Plan. The existing operations at Dumbuckhill and Sheephill have existed for some considerable period of time and have the benefit of planning consent however there are conditions attached to each concerning their restoration. The Council therefore does not propose to amend policy DC 8.

Model Policies.

We suggest that the SEDD's Pilot Model Policy Study's conclusions of January 2006 be examined, and wording of several policies in the draft Local Plan be modified to be closer to the examples given in the pilot.

The Finalised Plan reflecting the Council's position as set out above will be published in Spring 2007. You will be informed of its publication, and therefore there will be a further opportunity to make comments on the Finalised Plan. If you wish to discuss this letter please contact Steve Marshall in the first instance.

Yours Faithfully

Steve Marshall

Section Head : Forward Planning & Regeneration created 4/3/96, modified 20/5/2008 by Dutyhog.