20 June 2005 Mr Vincent Goodstadt Structure Plan Manager Glasgow & Clyde Valley Structure Plan Joint Committee 10 Killermont Street GLASGOW G2 3NW Dear Sir Glasgow and Clyde Valley Structure Plan Consultative Draft, May 2005
I wish to make comment on the above document. Detailed comment is offered in the context of the Structure Plan aspirations for major development when considered with regard to current proposals for the Royal Ordnance Factory (ROF) site, Bishopton. The Consultative Draft recognises that economic growth has been better than anticipated since the Structure Plan of 2000. Population decline was forecast previously to stabilise at 2025 – now expected at 2015. Consequently, it is to be expected that the Structure Plan revise the details of the 2000 document. However, I am very concerned that the Consultative Draft as presented does not safeguard the Bishopton community. The “Agenda for Sustained Growth” (p.4, paras. 1.9 – 1.13) predicts a 95,000 increase in the total number of households in the Structure Plan area at 2017. I believe that figure represents an extreme analysis. > In the absence of balanced explanation or analysis I would ask that this area of the consultative draft be re-visited to facilitate a more detailed analysis and robust projection of demand for households. The 2000 plan clearly states that Bishopton has a largely rural setting and cannot be considered to be an urban site. > If Bishopton has a largely rural setting then why has it been defined as an Urban Expansion Area? Indeed, consideration of the Principles of Urban Expansion (p 14, paras. 2.13 – 2.18) would seem to eliminate Bishopton on the criteria that there is a “need to ensure the long-term quality and stability of any new urban boundary and the provision of adequate social and community facilities, especially education.” I do not believe the development proposals for ROF Bishopton satisfy these criteria. Furthermore, an Urban Expansion Area must be “served effectively by public transport.” (p. 14, para. 2.14) Whilst Bishopton has a good rail service, it is my understanding that the rail system is operating near to infrastructure capacity. Any significant housing or retail/commercial development around Bishopton will place unmanageable operating pressures on that rail system. When one also considers that the only non-subsidised commercial bus service operating in Bishopton (Arriva Bus Service 27) is to be withdrawn in its entirety from August 2005 I do not accept that Bishopton is served effectively by public transport. I wish to express concern that no significant local consultation has taken place before the Structure Plan definition of Bishopton as an Urban Expansion Area. Surely such important and far-reaching policies cannot be justified without significant input from local residents and their representatives. The lack of such consultation renders many of the statements in this regard sterile. More work should be done before any final decision is taken on such a definition for Bishopton. > Consequently, I would propose that Bishopton not be defined as an Urban Expansion Area. I believe it would be more appropriate to define Bishopton as a Rural Investment Area (p 18, paras. 2.27-2.31). The proposals for ROF Bishopton cannot meet the “National policy (that) aims to prevent small settlements increasing in size to the extent that they lose their identity, and ensuring … modest growth.” Indeed, an aspiration of the Structure Plan is to strengthen communities. Supporting a local community should not impact unacceptably on the physical identity or quality of life of that community. As stated above, Bishopton has a good rail service. In consideration of Internal Transport Linkages (p. 25, para. 3.7) I note the Structure Plan aspires to “… the ability to interchange with other transport modes, particularly from areas of high car ownership.” Bishopton simply cannot sustain an increase in rail demand at current infrastructure levels. Local representation to Renfrewshire Council and thereafter to the Strathclyde Passenger Transport Authority has not succeeded in securing any capital investment in Park and Ride facilities. Consequently, the secondary town centre of Bishopton (although not recognised in Renfrewshire Council’s Local Plan, despite recommendations to the contrary from the Reporter) is littered with parked cars; emergency and delivery vehicle movements are hindered. Such general vehicle congestion acts as a disincentive to the use of the bus and rail stations. > The Structure Plan aspirations for Internal Transport Linkages clearly fail when applied to Bishopton. Schedule 9(B), Appendix B (p.48) indicates that Urban Regeneration should be promoted through "… the use of brownfield urban land rather than greenfield or open space." Whilst I acknowledge Planning officials refer to the ROF Bishopton site as "brownfield" I do not believe Bishopton could be defined in any context as "urban". > Does this not define the proposed expansion of Bishopton as a departure from the Structure Plan? If so, should such a significant departure be permitted? I do not see an appropriate explanation for this suggested departure and would wish this issue clarified. The Private Housing Supply and Demand, Appendix C (p.52) indicates that Renfrewshire is forecast to have by 2010 a local surplus of private housing supply of 1,700 units. How can development rights be granted for 2,300 new homes in a single location (Bishopton) when these 1,700 units are considered? There is much in the Consultative Draft Structure Plan, May 2005 that is positive. Examples of this are the promotion of ICT technologies in any new development, the Woodlands strategy, the aspiration to develop sustainable communities and renewable energy policies. It is correct that such positive aspects of the Consultative Draft are acknowledged. However, I believe the definition of Bishopton as an Urban Expansion Area is not justified. I suggest that such a definition is in place to justify a release of the ROF Bishopton site for housing and not to satisfy any identified demand for housing supply. I would wish to see a better balance between the aspirations of those communities that would be affected by Urban Expansion Area definition and the wider strategic aspirations of the Glasgow and Clyde Valley Structure Plan team. I would seek reassurance that the interests of commercial developers are dealt with appropriately and do not unduly influence the outcomes of this consultation. There is considerable unrest in Bishopton at present. Many residents, including myself, are apprehensive of what may lie ahead. If Bishopton is defined according to the aspirations of the Structure Plan team then the community that I live in will be irretrievably changed. I do not believe that change would be for the better. I ask you to consider these comments very carefully and to be aware of the life-changing impact that your decisions may have on a stable, interested and caring community. Please do not do anything that could facilitate the loss of, or even the destruction of, a true community spirit as witnessed throughout Bishopton. I look forward to receiving your acknowledgement and detailed response in due course. Yours faithfully, Iain A Langlands cc. Mr R Darracott, Director of Planning and Transport, Renfrewshire Council |