Kilmacolm – Port Glasgow Road: The Plots

Background

7.413  This small area of green belt land lies on the south west side of Port Glasgow Road at the northern edge of the village. On the other side of the road is a long ribbon of detached and semi-detached houses. To the south east is the semi-detached house

'St Fillans' and further properties fronting the road.  The south western boundary is undefined on the ground, but beyond it is agricultural land sloping down to the former railway line which is now a footpath and cycle track.  The short north western boundary is the south eastern boundary of the garden of the property 'Creggan', to the north west of which is another detached property 'Penlee' and then open countryside. The site itself slopes down from the road to the south, and a small burn traverses it running from north west to south east. It is used for grazing.

7.414  I understand that the site is divided into plots, owned by the present or previous owners of the houses on the other side of the road. In the 1988 local plan it was shown as being in the green belt. In 1987 an application to build a house on one of the plots was refused by the former Inverclyde District Council for reasons relating to green belt, ribbon development and road safety, and a subsequent appeal was dismissed the following year (P/PPA/SN/95).  In the consultative draft local plan

(1998) the whole area was identified as a possible housing site, and in the 2000 local plan it is shown as housing site ho97 with a capacity of 8 houses. It is listed in Table

4.1 as change no.13 to the inner edge of the green belt boundary:

"Release of small strip of land rounding-off this settlement edge, which could accommodate 8 dwellings and, by so doing, will afford greater long-term protection to the sensitive landscape wedge of designated green belt running into the heart of Kilmacolm."

7.415  However, this allocation attracted 54 objections, and in September 2003 the council decided to remove the housing allocation and reinstate the site in the green belt (Draft Modification 101). That decision attracted 3 fresh objections.

7.416  In the 1998 consultative draft local plan, a much larger area to the west, north west and south west (known as 'The Wedge') was also shown as a possible housing site, but was not shown as such in the 2000 local plan. An objection was lodged by CALA to its non-allocation, but was subsequently withdrawn.

Objectors:    see Appendix 3

7.417  The 54 original objectors to the allocation of site ho97 feel that there is no good reason to remove this land from the green belt; there is certainly no need for more land to be used for housing.  If the council's 'rounding-off' argument (a subjective and cosmetic excuse) is taken to its logical conclusion, every little inlet of green belt is at risk, and every settlement will become a regular circle, oval or square. This particular site is seen as part of a green isthmus reaching right into the centre of the village, and greatly enhances the rural atmosphere which Kilmacolm enjoys. The village's special features are its stone walls and green spaces which contribute to an individual 'feel' that could so easily be lost if the balance between building and green space is adversely altered.  The amenity value of this green space for someone approaching from the north would be lost, and ribbon development created. The proposed allocation is contrary to local plan policies H3 & 4 and DS8 and to the council's stated intention to safeguard the green belt, and could result in increased pressure to build on land to the west.

7.418  Other concerns include additional traffic and access dangers; loss of recreation area and access to cycle track; loss of outlook and views towards village centre; effect on tourism; risk of flooding; effect on wildlife; and building should instead take place at the former brownfield quarry on Port Glasgow Road (see below).

7.419  At the inquiry, evidence in support of the council's change of heart was given by Kilmacolm Civic Trust, Mr D Biggart, Mr D Chandler, & Ms M McKenzie. Kilmacolm Civic Trust does not believe that the objection site should be removed from the green belt, and refers to the planning appeal in 1988 (para 7.414 above). Development on the site would be detrimental to the present attractive and rural character of one of the main arteries into the village; the edge of the farmland is only

150m from the centre of the village, and the appearance of Port Glasgow Road would be destroyed (as has happened at Gryffe Road). The fingers of green space leading into the village centre are characteristic of Kilmacolm and should be maintained; there is no case for 'rounding-off' the settlement boundary.  If houses have to be built, consideration should instead be given to building in the large gardens of large houses. A precedent would be created re the larger site to the west, and there would be traffic implications. If any development has to take place, this should be at the gap site further down Port Glasgow Road where the public toilet was situated. In post-inquiry correspondence, exception was taken to the comments made by Mr Hammond re the Trust's decision taking processes. See also paras 7.358-.60 above.

7.420  Mr Biggart and Kilmacolm Community Council are concerned that, in his evidence to the inquiry, Mr Hammond has made a number of factual errors and misrepresentations.

7.421  Mr Chandler believes – based on his experience at the Hydro pond – that bricks and mortar are no substitutes for nature, and that in planning matters what you see is not what you get. He fully supports the position now taken by the council re this objection site.  SDD Circular 24/1985 appears to be a veto against any further development on the edge of Kilmacolm, but developers are still prepared to try because of the high profits on offer. In recent years much new housing has been tacked on to the village, but it actually detracts from the village's basic appeal. The older parts remain the most interesting – for a large village, Kilmacolm has a delightful rural quality, lying in an undulating landscape providing green vistas and perspectives which we should not dream of touching.  The recent SNH document

'Scotland's Future Landscapes' highlights the detrimental cumulative effect on the landscape we inhabit through small incremental changes over several years.  The demand for new housing and infrastructure is one of the driving forces behind this deterioration.  The energies and skills of developers should be directed away from green belt sites.

7.422  Ms McKenzie stresses the need to see open green land as an essential of life for present and future generations.  A short-term view is inappropriate.  Fields and woods are required to feed urban and suburban populations. Building should instead take place  on brownfield  sites within settlements.   To build  more  houses  in Kilmacolm would merely increase the amount of traffic and hence pollution. As elsewhere, Inverclyde's green belt should be kept as near sacrosanct as possible and should not be eroded away even in small bites by individuals or companies whose sole desire is to make money from a resource which is a very important part of everyone's quality of life and a commodity which belongs to all living creatures now and in the future.

7.423  The council originally proposed the housing allocation of the objection site, not because of any strategic need to add to the housing land supply, but rather to rationalise the green belt boundary (para 7.414 above).  At the inquiry, Mr Malone

explained that the housing land supply was not the issue but that, having been made aware of the numerous objections, the council took the view that the pattern of development here was of  considerable importance to  the rural  character  and appearance at the entrance to the village, and that to allow development would detrimentally affect the existing character and would screen the remainder of the green belt wedge to the south which contributed significantly to the rural atmosphere of the village.  Development would not offer greater protection to the green belt wedge but rather would make it even more difficult to resist pressure for further development there – all of which would be to the detriment of the visual appearance of the area. It is understood that CALA has an option on 2 of the plots, which it might use as an access from the wedge to Port Glasgow Road.

7.424  There is no anomaly in the green belt boundary here. Rather it is considered unfortunate that the 2 houses to the north west were built, because the edge of the settlement on this side of Port Glasgow Road should have been the south east boundary of the objection site.  The crucial factor is the importance of the site to the rural character of the area. It is not an 'infill' or 'gap' site suitable for development. In the local plan, the former is defined as:

"Vacant or derelict 'gap' sites created by the removal of a building not in active or beneficial use within the urban area, which could be a development site…"

An 'infill' site could be quite large, but here it is in the green belt. A 'gap' site would normally be small if within an urban area, with development on at least 3 sides; if a greenfield site, it would be a 'gap' if its development would lead to a better settlement boundary. On this basis, the objection site cannot be compared with other small infill and gap brownfield sites that have been developed in Kilmacolm. Apart from the 2 houses to the north west, this part of the village remains undeveloped. There is no suggestion that allocating the objection site would necessarily lead to further ribbon development beyond the 2 houses to the north west.

7.425  Mr Hammond believes that the council's planning officials must have known what they were doing when they originally prepared the local plan with the objection site shown as a housing opportunity for 8 dwellings. It is clearly a 'gap' between 2 groups of houses built on similar amenity feus. Its development would not constitute a continuation of ribbon development, as the 2 houses to the north west already exist. Rather it would constitute a rounding-off of the edge of the settlement, which is one reason for altering a green belt boundary. This is one of the last gap sites left in Kilmacolm and should never have been in the green belt in the first place. Its development would, however, be noticed by people on the cycle track to the west and south west.

7.426  The council appears to have been influenced by the fact that there were 54 objections to the site's residential allocation, but 16 of these are invalid and irrelevant as they are from people supporting the allocation of a nearby site at the former quarry. More importantly, of the 10 houses opposite the site which would be most affected by the potential loss of view, the occupiers of only 5 have objected.  Only 29% of residents in Port Glasgow Road have objected, and some of these seem to think that the whole wedge is to go for housing. He also disputes the validity of the objection made by the Kilmacolm Civic Trust, which objects to almost anything, and believes that many of the other objectors have no direct interest. He thinks that the large number of objections was brought about by local lobbying. It is unacceptable for some objectors to claim that there is enough building in the village as soon as their personal needs have been satisfied.  SNH accepts the alteration to the green belt boundary here.

7.427  If 8 houses were built, the council would receive more than £20,000 in council tax for minimal outlay. This income could go a long way towards funding the running costs of the Community Centre, thus increasing the amenity and economic development of Kilmacolm.

7.428  CALA (which has concluded missives with all owners of the individual plots) points out in a written submission that, although the council claimed that no changes to green belt boundaries  were required on  the grounds  of  strategic housing requirements, it nonetheless took the opportunity to amend the boundary of the inner

edge at 15 locations – 2 of which were in Kilmacolm. In relation to those 2 sites, the reasoning was to make the boundary more permanent for the longer-term and to the fact that they were appropriate in order to help maintain a limited number of development opportunities of under 10 houses (within the threshold of structure plan schedule 9) to assist with some change and mobility within the local housing market. However, the council has now decided to retain the objection site in the green belt, against the advice of its planning officers and without any proper explanation. Presumably those officers remain of the view that the site "involves least servicing costs and minimum impact on agriculture, nature conservation and landscape setting", that it does not breach any of the 3 main purposes upon which green belts have been established (SDD Circular 24/1985), and that its development for local reasons would not impinge adversely on the 'sensitive wedge' shown in fig.3.6 of the local plan.

7.429  From its responses to other objections (including some to the non-allocation of the nearby former quarry), it can also be assumed that the council was originally satisfied  that  the objection  site  does not present a strong landscape edge  to Kilmacolm, that its allocation would not lead to ribbon development, that it would help to define for the long-term a secure and defensible green belt boundary, that it is little different from other small infill and gap sites that have been developed in Kilmacolm in recent years, that no adverse precedent would be set, that development limits would be set consistent with what is already there in terms of built form, and that its development would not constitute a major or environmentally damaging encroachment into the countryside.

7.430  The structure plan key diagram offers considerable scope to local plans in fulfilling the strategic policy requirement re green belts. One of the stated purposes of the green belt in the structure plan is to support the development of the green network, which includes the former railway line to the west of the objection site. Clearly the council did not originally think that there would be any adverse effect on this feature. In terms of strategic policy 6, land has to be allocated to provide choice in terms of size and type of housing for each HMA and the needs for social rented housing identified in local plans. As this was one of the express aims of the green belt review carried out by the council, it is perfectly in order for the local plan to make necessary adjustments to the green belt boundary to ensure compliance.

7.431  Mr Reid of 4 Lodge Park notes in a written submission that the council has provided no justification for its decision to retain the site in the green belt. If there is no strategic requirement for housing land to be released in Kilmacolm, he wonders why the council is proposing that 40 houses be built in the green belt at the former Balrossie School.

7.432  The entrance to Kilmacolm from the north west is currently characterised by ribbon development along Port Glasgow Road.  There is a substantial green wedge which runs between the houses on the south side of the road and the cycle track. While development of that wedge would be likely to be detrimental to the visual appearance of the entrance to the village, the same does not apply to the objection site, which comprises a number of undeveloped building plots and is clearly an infill site within the confines of the village.   Well designed housing often enhances the entrances to villages, e.g. the large house to the south of Houston Road which, while being in a particularly dominant location, has not been detrimental to the visual appearance of the southern entrance to the village.

7.433  The council's argument that the allocation of the objection site would make it more difficult to resist development pressure on the land to the west lacks any form of justification.  The south western boundary of the objection site joins the line of the rear gardens of the properties on either side and is therefore a natural boundary. There is no relationship between the objection site and land to the west. In relation to his attempt to obtain planning permission for a house on one of the plots in the 1980s, he points out that the planning committee of the former council was misled as to its precise location, and that the decision to refuse permission was only reached after some councillors had been swayed by comments made by the local councillor.  That same councillor was responsible for so many objections being made to the local plan.

Conclusions

7.434  I should say first that my consideration of the various objections here is not influenced by various allegations made re discrepancies in the minutes of the Kilmacolm Civic Trust, the hypocrisy of some objectors, or the involvement of the local councillor. I am merely considering the planning aspects, although I believe that several of the original objections have to be seen in the context of their main agenda: support for a proposal to release a nearby site for housing. Nor am I influenced by the fact that the plots are so called because they were originally envisaged as building plots; that was before the introduction of the Town & Country Planning legislation after the second world war.

7.435  Although 8 houses were originally proposed, I agree with almost all parties that the determining issue here does not relate to any alleged 'need' for more houses in Kilmacolm. I appreciate the point raised by CALA re the question of choice but, for the avoidance of doubt, I do not consider that this would be a good site for the building of affordable houses. In relation to Kilmacolm as a whole, I refer to paras 7.158-.159 above.

7.436  It is not possible to be certain that this site lies within the structure plan's Green Belt Structural Corridor between Kilmacolm and Port Glasgow, but it is reasonably clear that it forms part of the northern 'sensitive wedge' illustrated in fig.3.6 of the local plan. I accept that it forms a 'gap' between the 2 detached houses to the north west and the row of semi-detached houses to the south east, but I believe that it is sufficiently large a 'gap' and obviously part of the countryside to make it difficult to apply the general presumption in favour of developing 'gap sites' that are normally smaller and within built-up areas.  Looking at a 2-dimensional map, I can understand why infilling this 'gap' may appear logical in the sense of 'rounding-off' development on the south west side of Port Glasgow Road; however, this is much less obvious on the ground, where my site inspections have confirmed what many of the objectors have claimed re the importance of south westerly views over the site and the agricultural land beyond in terms of the rural character of the northern part of Kilmacolm for local residents and particularly for people entering the village from the north west. Although written 16 years ago, the words of the Reporter re a proposal for one house also seem to me to be still applicable:

"Despite the existence of the 2 outlying houses to the north, this large gap provides a pleasant view across the lower ground to the west…  I therefore conclude that there would be an adverse effect on local amenity and on the character of this part of the green belt… the overall result would be a line of about 8 new houses filling the gap in the road frontage, with agricultural land to the rear. These houses would link with those existing to form an extended ribbon development. The pleasant open character of this part of Port Glasgow Road would be lost."

7.437  To my mind, it is the 2 detached houses to the north west that provide the anomaly, not the objection site. Moreover, I also agree with several of the objectors that 'rounding-off' is not necessarily appropriate for Kilmacolm and particularly not for this part of it.  It is entirely possible that the houses that would be built here – particularly if by CALA – would be of high visual quality, but that would not overcome the loss of the rural aspect that is such a feature here.

Recommendation

7.438  Draft Modification 101 should be made.

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