DEVELOPMENT SERVICES Local Member - Councillor B. Chennell PLANNING APPLICATION REPORT Date of Validity - 8th February 2005 Bute & Cowal Area Committee Committee Date - 5th July 2005

27th June 2005

Reference Number: 05/00220/DET Applicants Name: Western (Clyde) Ltd Application Type: Detailed Application Description: Erection of new linkspan; Infilling works with rock armour sea wall to create extended marshalling area; and associated infrastructure works. Location: Hunter’s Quay,

(A) DETAILS OF THE PROPOSED DEVELOPMENT

(i) Summary of development Requiring Permission:

• Erection of new steel linkspan (with pedestrian walkway) adjacent to existing linkspan; • Erection of new steel berthing structure (with walkway) adjacent to existing pier; • Formation of 1:1.5 rock armour on north western slope extending into the sea; • Infilling works to create extended and reconfigured marshalling area to provide 75m of HGV/PSV marshalling and 234m of car marshalling; • Additional car parking space (8 spaces) in the western corner of the new marshalling area.

(ii) Other Specified Operations

• Erection of passenger shelter. • Erection of compressor housing. • Existing culvert extended to new outfall. ______

(B) RECOMMENDATION It is recommended that permission be granted, subject to the standard condition and reason, and to the conditions and reasons, and notes to the applicant set out overleaf.

(C) DETERMINING ISSUES AND MATERIAL CONSIDERATIONS

Western Ferries propose to introduce a new linkspan at the existing terminal at Hunter’s Quay, which will take over the regular service from the existing linkspan. The existing linkspan in not proposed to be removed but will remain in situ to provide a fall back service including mechanical failure to allow vessels to continue to moor at the site giving shore access to the crew. These improvements will provide additional infrastructure capacity to deal with unexpected maintenance or as a bad weather alternative.

What is critical is that two linkspan(s) should not operate simultaneous or on the same day and a restrictive condition prohibiting the same is proposed due to the potential and obvious traffic management conflict and congestion.

The main issues in this proposal are considered to be :

1. Visual impact on adjacent Listed structure and building and surrounding Townscape Policy Area; 2. Potential simultaneous use of two linkspans. 3. Increase in marshalling area and number of vehicles using the extended and reconfigured terminal; 4. Environmental concerns i.e. noise and dust associated with construction operations; 5. The operation of the reconfigured and extended marshalling area; 6. Environmental issues in respect of wildlife and biodiversity.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

Part of the existing Hunter’s Quay terminal is a Grade B Listed structure comprising of a wooden jetty and rubble slip. This structure has already been absorbed into the main operational jetty and the proposed development will not have any greater impact than currently exists. The proposed development would not materially affect this listed structure, and the proposed development would not therefore be contrary to the development plan Policy BE1 (Listed Buildings).

Given the limited scale of the works proposed, the Scottish Executive have determined that there is no requirement for an Environmental Statement in respect of Harbour Works (Environmental Impact Assessment) Regulations 1999 or under Council Directives.

The consultees for this application before members have raised no specific line of objection whilst seven letters of representation have been received from the public. A main concern appears to be the actual ferry operation from this terminal (and Dunoon Breakwater), this application is solely for the erection of new infrastructure and extending the existing marshalling yard to improve the existing operation and should be determined on that basis.

To the best of the department’s knowledge the Council own the masonry wall and the Area Roads Manager has advised that the top part of the wall at the seaward side to the northwest requires to be lowered to one metre in height for a distance of around 43 metres. Equally three clumps of vegetation, primarily sycamore growing out the wall, require to be removed to provide safe and satisfactory visibility. The required works to the wall are outwith the application site and normally there would be the necessity for a Section 75 Agreement.

In this instance the department is satisfied that the applicant can undertake the necessary works to the seaward wall to the northwest and in perpetuity via a suspensive planning condition. This would make a Section 75 Agreement superfluous since the same end result would be achievable. The removal of the top part of the wall and vegetation is a prerequisite prior to all other works taking place. Condition 13 has been carefully tailored to address these matters.

It is considered that the development fully accords with both National and Development plan policy including in particular POL TR1 of the Adopted Cowal Local Plan that is geared towards supporting development of this nature in so far as “The Council will oppose changes or reductions in service on the Cowal-Clyde ferry routes which undermine the economic regeneration of Cowal but will support measures which will result in improved services and facilities on these routes.”

Conditions are suggested to be imposed that would cover the submission of an environmental management plan including such issues as dust, noise and pollution, navigation lights, together with requirements for a Sustainable Urban Drainage System, sightlines, revised car parking, signage, landscaping, relocation of an existing culvert, prohibition of simultaneous use of two linkspans and advisory notes.

Angus J Gilmour Head of Planning and Building Standards

Case Officer: B. Close 01369-70-8604 Area Team Leader P. O’Sullivan 01369-70-7983

"In reaching my assessment on this application, I have had regard to the documents identified in brackets above which are available for public inspection in terms of the Local Government (Access to Information) Act 1985".

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

CONDITIONS AND REASONS RELATIVE TO PLANNING APPLICATION 05/00220/DET

2. The development hereby permitted, shall be constructed in strict accordance with the approved plans titled “1:1250 Location Plan 03103/200 A received 25th February 2005, 1:250 Topographic Survey 03103/201 received 25th February 2005, 1:250 Proposed Site Plan 03103/202 received 8th February 2005, 1:200 Cross Sections 03103/203 received 8th February 2005, unless the prior written consent for variation is obtained from the Planning Authority.

Reason : Given that amended plans were submitted during the course of this application and for the avoidance of doubt and to ensure that the development is undertaken in strict accordance with the approved and amended plans.

3. No devolvement shall commence until an Environmental Management Plan has been submitted to and approved in writing by the Planning Authority in consultation with Protective Services and SEPA. In particular the Environmental Management Plan shall identity the potential environmental impacts associated with construction works and detail measures to be employed to mitigate such impacts, including procedures for dealing with complaints and necessary monitoring. The Environmental Management Plan shall include:

i) Detailed assessments of noise emissions and the potential sources of noise; ii) Mitigation measures to be adopted to control noise; iii) Dust and other emissions to the atmosphere and specify mitigating controls; iv) Methods of monitoring recording matters and complaints procedures relating to the control of noise; v) Provide for a method statement that details the protection of the coastal waters and groundwater.

The Environmental Management Plan, shall be fully implemented in accordance with such details as may be approved in writing by the Planning Authority during the implementation of the development, unless written consent is obtained to vary such details.

Reason: To ensure that the development is undertaken in a controlled manner and to ensure no adverse detriment to amenity by virtue of noise, emissions, contaminates or pollutants.

4. Within three months of the date of this permission, unless consent for variation is obtained from the Planning Authority, details shall be submitted for the prior written approval of the Planning Authority in consultation with SEPA of a drainage scheme that shall incorporate the basic principles of Sustainable Urban Drainage Systems identified in ‘Planning Advice Note 61’. This shall provide details of surface water run off, measures to slow down run off; methods of treatments and its release into the system precluding the use of an oil inceptor, unless prior written consent for variation is obtained in writing from the Planning Authority.

Reason: In order to provide for a sustainable drainage system, negating the need for an oil inceptor and to address pollution arising from the interaction of rainwater and the development, consistent with the advice of Planning Advice Note 61 ‘Planning and Sustainable Urban Drainage Systems’.

5. No development shall commence until full details indicating the diversion of an existing culvert have been submitted to and approved in writing by the Planning Authority in consultation with the Area Roads Manager. Such details shall include an access manhole on connection to the existing pipe outfall.

Reason: To allow the Planning Authority to consider this aspect in detail.

6. No external lighting shall be installed until full details of all external lighting to be used within the site (including any temporary lighting to be used during construction works) have been submitted to and approved in writing by the Planning Authority in consultation with the Area Roads Manager and the Public Protection Service. Such details shall include full details (including supporting structures) of the location, type, design, height, angle of direction and wattage of each light. Unless the prior written consent of the Planning Authority is obtained for variation, all lighting units within the application site shall be operated, positioned and angled to prevent any glare or light spillage outwith the boundaries of the ferry terminal site, having regard to the Institute of Lighting Engineers Guidance.

Reason: In order to avoid the potential of light pollution infringing on surrounding land uses/properties.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

CONDITIONS AND REASONS RELATIVE TO PLANNING APPLICATION 05/00220/DET (continued)

7. Notwithstanding the details submitted and those contained within the approved plans Drawing number 03103/202, no development shall commence until details in the form of a revised 1:250 plan has been submitted in writing to the Planning Authority (in consultation with the Area Roads Manager) indicating the proposed 8 car parking spaces reconfigured to avoid vehicles reversing into ‘live’ traffic lanes. This plan should also indicate dedicated car parking provision for staff.

Reason: In the interest of traffic and pedestrian safety.

8. No development shall commence until the following details, including the submission of scaled plans, have been submitted to and approved in writing by the Planning Authority in consultation with the Area Roads Manager.

i) Full details of the measures that will be provided to prevent unauthorised parking in the vicinity of the junction with the public road in that area lying in immediate proximity to the telephone call box.

ii) Full details of the areas identified for parking for staff.

iii)Full details of direction sign(s), in accordance with Traffic Signs regulations 2002 that shall be provided for disembarking traffic. Such a sign, as may be approve, shall detail A815 Dunoon, Innellan Parking and Tourist information to the south, A815 Sandbank, Strachur and A83 to north.

iv) Details of signage that shall be provided for pedestrian routes in and out of the terminal area.

v) Details of all signs and markings that shall be provided for bus service, taxi and car drop off point.

Such details )I – v) inclusive as may be approved, shall be brought into use prior to the first operational use of the new linkspan.

Reason: In the interest of traffic and pedestrian safety.

9. Notwithstanding the details submitted and those contained within the approved plans Drawing number 03103/202, no development shall commence until details in the form of a revised 1:250 plan has been submitted in writing to the Planning Authority (in consultation with the Area Roads Manager) of the main car parking or marshalling area. Such details shall provide for a scheme of hard and soft landscaping works that has been submitted to and approved in writing by the Planning Authority. Details of the scheme shall include:

i) Specific areas set aside outwith the parking/marshalling area to incorporate tree planting, low ground cover planting, and the use of alterative materials and landscape features. ii) Soft and hard landscaping works, including the location, type and size of each individual tree and/or shrub. iii) A programme for completion and subsequent on-going maintenance.

All the hard and soft landscaping works shall be carried out in accordance with the scheme approved in writing by the Planning Authority. All planting as may be comprised in the approved details shall be carried out in the first planting and seeding seasons following the commencement of the development unless otherwise agreed in writing with the Planning Authority.

Any trees or plants that within a period of ten years from the completion of the development die, for whatever reason are removed or damaged shall be replaced in the next planting season with others of the same size and species, unless otherwise agreed in writing with the Planning Authority.

Reason: In the interest of visual amenity and to break up and soften the large expanse of hard surfacing proposed in the interest of visual amenity having regard to the townscape setting.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

CONDITIONS AND REASONS RELATIVE TO PLANNING APPLICATION 05/00220/DET (continued)

10. No development shall commence until details have been submitted and approved in writing by the Planning Authority in consultation with Clydeport and the Area Roads Manager that indicate the nature and extent of the existing navigation lights and the proposed relocated position within the site. Such details, as may be approved shall include a timescale for their operational use that shall be agreed in writing with the Planning Authority and thereafter be brought into use.

Reason: In the interests of safe shipping movements.

11. Prior to the rock armour being first brought to the site details shall be submitted of the composition of rock armour including, source and size of material. Such material, as may be approved shall be used in the approved development.

Reason: In order to integrate the development along the shore.

12. At no time shall the new linkspan and the existing linkspan (as indicated on the approved plans) be used simultaneously or on the same operational day for embarking/disembarking of vehicles and/or foot passengers. The existing linkspan shall not be used for the embarking/disembarking of paying vehicles and passengers except in the sole instance of any mechanical failure of the new linkspan, unless the prior consent to vary the use of the two linkspans has been approved in writing by the Planning Authority.

Reason: In the interest of traffic management and to prevent congestion in the immediate area and on the public highway.

13. No other works or any part of the development shall take place until the following has been undertaken and provided:

(i) The provision of a clear sightline to the northwest of 120 metres from a setback of 2.50 metres from the centre line of the existing access. This shall entail the removal of the top part of the masonry wall on the seaward side adjacent to the A815 for not less than 43 metres. No part of the wall within this sightline shall exceed 1.0 metre in height above the carriageway with the road.

(ii) The provision of a clear sightline to the northwest of 120 metres from a setback of 2.50 metres from the centre line of the existing access. This shall entail the removal of all existing vegetation, primarily sycamore trees growing out of the wall on top of the wall buttress. Such vegetation shall be cut back, all rootballs completelty removed from the wall, chemically treated to prevent re-growth and the masonry wall suitably repaired in those areas where the rootballs of the trees are removed, to the satisfaction of the Planning Authority in consultation with the Area Roads Manager.

(iii) Thereafter any such vegetation that may reoccur/ re-grow shall be removed from the wall to the northwest in that sightline of 120 metres from a setback of 2.50 metres from the centre line of the existing access, as provided, that shall be retained in perpetuity as for such time Western Ferries operate from the ferry terminal to the satisfaction of the Planning Authority in consultation with the Area Roads Manager.

Reason: Having regard to the restricted sightline to the northwest by virtue of the top part of the masonry wall and vegetation that obstructs clear visibility in the interest of highway safety.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

Advisory Notes to Applicant.

(i) Prior to any works, the applicant should consult with the Public Protection Service and agree full details of the noise control and mitigation measures and dust suppression measures during the construction phase of this development and shall note that the Environmental Protection Act 1990, and Sections 60-63 of the Control of Pollution Act 1974 will be used by the Council to control noise emissions. The applicant is advised to liaise directly with the Council’s Public Protection Unit (Mrs. Jo H Rains, Area Environmental Health Manager tel. 01369-703959, ext. 219).

(ii) The Area Roads Manager has indicated in his consultation response that a Road-Opening Permit (S56) will be required for works encroaching on the public highway. Contact in this regard should be made with the Area Roads and Amenity Services Manager, Alan Lothian tel. 01369-708620.

(iii) The Area Roads Manager has indicated in his consultation response that :

• The applicant shall provide fully trained traffic management personnel for dealing with overspill traffic on the public road in times of exceptional traffic loadings in order to relieve Police from providing this service. Police are otherwise fully committed at these busy times.

Contact in this regard should be made with the Area Roads and Amenity Services Manager, Alan Lothian tel. 01369-708620.

(iv) Clydeport are the statutory authority responsible for maintaining the public right of navigation and a works licence to be issued to the applicant for the works from Clydeport under the Clydeport Confirmation Act 1965The applicant is advised to liaise directly with Clydeport Properties Ltd. (Mr. David Robinson, tel. 0141 221 8733).

(v) SEPA in their consultation response (letter dated 13th April 2005) have advised that it is important that during the construction phase good working practice is adopted and that habitat damage is kept to a minimum and contained within an agreed limit. There is potential for the pollution of coastal waters from the storage of materials, use of concrete, resuspension of sediments, oil etc. The applicant should provide details on the measures to reduce these risks. Works should be carried out in accordance with SEPA’s Pollution Prevention Guidelines. The CIRIA publication C584 “Coastal and Marine Environmental Site Guide” should also be referred to as it provides specific guidance to mitigate and avoid poor environmental practice on coastal and marine construction projects. SEPA would request that prior to any works commencing, a work method statement should be submitted to the local SEPA office in Lochgilphead for comment.

The applicant is initially advised to liaise directly with SEPA East Kilbride Office (Ms. Julie Gerc, tel. 01355 574200).

(vi) The applicant is advised that the development hereby approved may be the subject to the Construction (Design and Management) Regulations 1994, which govern health and safety through all stages of a construction project. The Regulation requires clients (i.e. those, including developers who commission construction projects) to appoint a planning supervisor and principal contractor who are competent and adequately resourced to carry out their health and safety responsibilities. Further information is available from the Health and Safety Executive Infoline (Tel. 0541 545500).

(vii) For the avoidance of doubt the applicant is advised that Condition 12 does not preclude the mooring of vessels by Western Ferries/use of existing linkspan for non-paying vehicles and passengers.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

A. APPENDIX RELATIVE TO 05/00625/DET

(i) PLANNING HISTORY

None directly related to the subject site, although various minor applications for office extensions, shelters, wheelchair ramps have been granted on the existing ferry terminal site.

OTHER HISTORY

Planning permission (03/01599/NID) was granted to Council on 30th January 2004 for the formation of a new breakwater with linkspan facility and associated infrastructure works at Dunoon Pier. This facility is now complete and in addition to protecting the existing historic Dunoon Pier structure and buildings, will provide a new ferry terminal for Dunoon. The matter of which ferry operator will utilise this facility is outwith the control of the Planning Authority and is not a relevant or material planning consideration in connection with this application.

Inverclyde Council has confirmed (copy of decision notice) that planning permission for the formation of a replacement linkspan at McInroys Point, Cloch Road was granted on 9th March 2005 subject to two conditions (Planning reference IC/05/039. Condition 2 stipulates that the “ existing linkspan be removed from the application site once the replacement hereby permitted is completed and operational”.

At the time of writing (27/06/05) no planning application to vary or remove this condition has been submitted to Council although any such application, as may be received, would be a matter for Inverclyde Council.

(ii) CONSULTATIONS

The following consultation responses have been received on this application :

Scottish Executive : Enterprise, Transport & Lifelong Learning Department (letter dated 3rd March 2005) : The department was consulted on any requirement for an Environmental Statement. The department responded (letter dated 6th April 2005) indicating that it was of the opinion that there was no requirement for an Environmental Statement under the Harbour Works (Environmental Impact Assessment) Regulations 1999. No further comments were received and the Scottish Executive have confirmed that a consent has been issued to the applicant in respect of the Harbour Works Regulations 1999.

Area Roads Manager (Revised memo dated 21st June 2005): No objections subject to conditions.

This proposal is for upgrading of the ferry terminal facilities at Hunter’s Quay to cope with the ferry traffic now being experienced and handled by a relatively new fleet of vessels. Western Ferries started operations at this site in 1973 when the vessel capacity was about 20-30 cars and when less traffic used the service. The current fleet of four vessels each have a carrying capacity of 36-40 cars and at peak times can cope with peak demands. The facility has not been replaced since the start of operations and any breakdown either at Hunter’s Quay or McInroy’s Point in renders the service inoperable. It is understood a mirror image development is proposed at McInroy’s Point.

The proposal is to better deal with existing traffic and whilst at peak times this can be very significant it is considered that matters can be conditioned without a Safety Audit and Traffic Impact Assessment.

The proposal utilises the existing access, which also serves a little used boat-slip. Sightlines from the junction are 100 metres southeast and potentially in excess of 150 metres northwest but are restricted in the near vicinity of the access to 47 metres by the raised height of masonry walling at the rear of the footway for some 43 metres. Vegetation growing from the base of the sea wall also restricts sightlines for a further 60metres. The sightline can be achieved by lowering the wall and the removal of vegetation.

Pedestrian provision is improved in the revised layout having a defined route to the ferry berth as well as a drop off cum bus pull in at the berth. A passenger shelter is also to be provided at the berth. The development indicates the diversion of an existing culvert. Details are required of the construction and must include an access manhole on the connection to existing pipe outfall.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

The proposal includes 8 designated parking spaces, which in discussions are understood to be for limited public use. The existing terminal suffers from a lack of defined public parking resulting in rogue parking at and around the entrance to the detriment of road safety and staff parking. The provision of the 8 spaces requires additional control measures to deter rogue parking and properly provided staff parking in the vicinity of the offices and workshops. An estimated 20 spaces can be provided for staff. The applicant quotes only 15 staff but this is understood to be office (shore based) only, whereas approximately another maximum 16 are sea-going. It is however understood that the applicant does provide minibus transport for the crews.

The layout of the proposal is reported by the applicant to double the capacity of the marshalling area – this is agreed only as far as the existing marked lanes are concerned. At peak periods all of the existing area is taken by vehicles, approx 51 cars, the new marshalling layout has a capacity of approximately 67 cars. The current fleet can carry approximately 152 cars per hour. The improved layout and operation will therefore clear waiting cars quicker than existing thus relieving the pressure on the public road during peak times.

The applicant has submitted an operational statement advising that:

• the existing linkspan will remain in service for the berthing and servicing of ‘out of service’ vessels and crews. • The normal and peak traffic will be catered for by the new linkspan and berth. • Simultaneous utilisation of both berths is not practicable for traffic management reasons. • The existing linkspan would be available should breakdown occur in the new facility, thus maintaining the service. • It may be that extreme traffic loadings can be cleared quicker if both berths were in use, again this being beneficial to the relief of congestion on the public road network.

This statement requires to be supported by an undertaking of the applicant providing additional manpower in the shape of trained traffic management operatives to control traffic which may be queuing on the public road- this currently falls to the Police at Bank Holidays, Cowal Games and the like.

In order to contain the traffic loadings at the current levels it is required that the applicant undertakes to operate the service on one linkspan only at any time. Te other linkspan is reported to be used for servicing of vessels, landing of crews etc exclusive..

Measures are required to prevent parking at and around the junction with the public road. Staff parking requires to be defined and similarly managed. The public parking whilst welcomed as an improved provision is not ideal, as vehicles will reverse out into a live lane. A revised layout may avoid this, albeit with a lesser capacity.

Advance direction signage is required, in accordance with the Traffic Signs Regulations 2002 for disembarking traffic detailing Dunoon, Parking and Tourist Information, Innellan as well as Sandbank and Strachur. Signs are required to direct pedestrian in and out of the berth.

Conditions and advisory notes are recommended on the following issues: -

• To achieve the required sightline of 120 metres to the northwest the roadside masonry parapet wall is lowered to a height not exceeding 1 metre above road channel level and vegetation within the visibility splay on the seaward side of the wall is removed and maintained clear. Approximately 43 metres of walling is required to be lowered.

• In order to control traffic loadings on the junction and immediate road network, the applicant shall not operate the service from more that one linkspan at any time.

• A disconnecting manhole, in accordance with the Council’s construction details is to be built on the 1200 dia culvert.

• Applicant is to provide fully trained traffic management personnel for dealing with overspill traffic on the public road in times of exceptional traffic loadings in order to relieve Police from providing this service. Police are otherwise fully committed at these busy times.

• 8 space parking layout to be amended to avoid vehicles reversing into live traffic lanes.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

• Positive measures required to prevent parking in the vicinity of the junction with the public road (outside the area occupied by the telephone call box). Measures required to prevent unauthorised parking within the development.

• Identified and controlled parking required for staff.

• Direction sign, in accordance with Traffic Signs regulations 2002 to be provided for disembarking traffic. This sign to detail A815 Dunoon, Innellan Parking and Tourist information to the south, A815 Sandbank, Strachur and A83 to north.

• Signs to be provided for pedestrian route in and out of the terminal area.

• Signs and markings to be provided for bus service, taxi and car drop off point.

SEPA: (letter dated 13th April 2005): Under the Water Framework Directive (WFD) that came into force in 2000 and the Water Environmental and Water Services Act () 2004, SEPA has a duty to achieve good ecological status in all water bodies by 2015. Under the Nature Conservation Act of 2004, SEPA has duties to further conservation and a duty to maintain biodiversity and productivity in intertidal areas in coastal waters, firths and estuaries.

The proposed ferry terminal at Hunter’s Quay is situated between the Holy Loch and Inner water bodies. It is approximately 0.4 ha in area and will include some further land claim of the intertidal areas adjacent to the existing marshalling yard. The area of land claim would be small representing a very small modification to the Holy Loch water body (~0.0008%). The proposed development is unlikely to breach Water Framework Directive objectives in the long terms and is unlikely to have any significant environmental impacts on coastal processes and biodiversity due to its scale and location.

An advisory note is recommended regarding the submission of a work method statement in accordance with SEPA’s Pollution Prevention Guidelines.

Clydeport Properties Limited (letter dated 1st April 2005): The applicant is required to obtain a licence for the works from Clydeport. The licence will cover any navigational issues, which may arise from the project. A ‘note to applicant’ would draw attention to theses matters. In terms of navigation lights a specific condition would be imposed (Condition 10) that required such details to be submitted to the Planning Authority.

Public Protection (memo dated 11th May 2005) : A number of consequences of the application which have the potential to give rise to nuisance both during and after construction, are described below :

• Air quality- Dust may be generated during the construction of the Linkspan and vehicle marshalling area. Whilst this Service has powers, in terms of the Environmental Protection Act 1990, to remedy any nuisance arising as a result of dust, a dust management plan should be submitted by the applicant, prior to the commencement of works. The plan should be commensurate with the nature of the works being undertaken. It is not anticipated that the proposals would lead to any adverse impacts upon air quality during the routine operation of the works.

• Noise and vibration – During the construction phase, noise will arise from construction of the infrastructure and the rock armour sea wall. Whilst this Service has powers, in terms of the Control of Pollution Act 1974 and the Environmental Protection Act 1990, to deal with noise nuisance, the applicant should be encouraged to liaise with the Public Protection Service, in order to discuss the minimisation of noise emissions throughout the construction phase.

The operation of the linkspan during extreme conditions will introduce a number of new noise sources. Plant and equipment, vehicle movements and personnel have the potential to give rise to annoyance at the nearest receptors, particularly here background noise levels are generally low. Therefore, whilst this Service has powers, in terms of the Environmental Protection Act 1990, to deal with noise nuisance. It is appropriate to apply conditions in order to protect the amenity of the surrounding area.

• Lighting – The provision and location of lighting is not detailed within the Planning Application. poorly designed, positioned in sensitive locations, can give rise to complaint. As there are currently no legislative provisions to deal with such problems should they arise, it is recommended that conditions be attached to any planning consent granted, in order to protect the amenity of the area both during and after construction.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

Public Protection recommend that conditions be attached regarding lighting units, dust suppression and noise management plan.

Scottish Natural Heritage (letter dated 30th March 2005): No objections or comments to make on the case.

Hunter’s Quay Community Council - (Letter dated 22nd June 2005) from the Chairman, Hunters Quay Community Council) :- Accept that application was sent out about the 19th March 2005 but since that time the Community Council has been dissolved, an election held and a new council formulated. Although there was a meeting of the Community Council at the beginning of June this was purely to format elected members, the first business meeting will take place on 7th July at which time the application will be discussed. Request that you delay this application until it can be considered by the Community Council at its meeting on 7th July 2005.

(NB. It is understood that “Special Meeting” to consider this application will take place on Wednesday 29th June 2005).

Crown Estates Commission: No response received.

Strathclyde Police – No response received.

Property Services – No response received.

(iii) PUBLICITY

The proposal has been advertised (8th April 2005) in terms of:

• Under Section 34 (Bad Neighbour) of the Town & Country Planning (Scotland) Act 1997. • In accordance with the requirements of the Town and Country Planning (Development Contrary to Development Plan) (Scotland) Direction 1996 the application has been advertised as a ‘Potential Departure’ from the Development Plan Polices POL RUR1, POL BE4, POL TR3 and POL COM 5 (‘bad neighbour’) of the Cowal Local Plan 1993. • The proposal was also advertised (site notice) under Section 60 of the Planning (Listed Buildings and Conservation Area) (Scotland) Act 1997- Development affecting the setting of a Listed Building.

The cumulative closing date for representations in terms of the above adverts was the 29th April 2005. As a result of the above publicity and Neighbour Notification procedures, seven letters (from 6 properties) of representation have been received from F.R.N., SM and A.C. McInnes, 265 Marine Parade, Hunter’s Quay (letters dated 1st February and 26th April 2005); James Brodie, Flat 6 Cammes View, 255 Marine Parade, Hunter’s Quay (letter dated 8th February 2005); Graham and Christine Togwell, Hunter’s Quay Hotel, Hunter’s Quay (letter dated 20th February 2005); James J. Wilson, Eastwood, 30 George Street, Hunter’s Quay (letter dated 5th April 2005); Scoular Anderson, Rockhill, 271 Marine Parade, Hunter’s Quay (letter dated 10th April 2005); Gibb Thomson, Rockbank, 303 Marine Parade, Hunter’s Quay (letter dated 20th April but stamped received on 17th June 2005). The issues raised are summarised below :-

1. The application is to “replace the linkspan” – the linkspan being the height adjustable portion that the ferry docks against, not the entire pier. The plans show a large extension to the existing area by infill, and in effect building a new “additional” pier. If constructed a new larger pier would be closer to existing housing and would increase the noise and pollution already experienced.

Comment – The application form and notification forms indicated a ‘replacement’ linkspan. The applicants were requested to submit an operational statement, which confirmed that the linkspan will be a new one and erected alongside the existing facility. The proposal was advertised as a ‘new’ linkspan with infilling works and rock armour to provide an extended marshalling area. Public Protection has requested an Environmental Management Plan to cover such issues as noise, dust and pollution. It should be noted that the existing lawful use of the site is a ferry terminal or transport interchange facility whilst condition 12 would prevent simultaneous use of the two linkspans.

2. There is a perfectly new and unused linkspan facility partly paid from the public purse at Dunoon that could and should be used before any extension is built at Hunter’s Quay.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

Comment – This application is to extend the existing Western Ferries facilities at Hunter’s Quay. Issues concerning the operation of Dunoon Pier not a material consideration and should not be considered or addressed in this application.

3. The existing pier at Hunter’s Quay is of considerable historic interest having been built by Mr. Hunter and presumably has some sort of preservation order.

Comment – The Grade B Listed pier is all but absorbed into the existing ferry terminal development. The proposed development will have no further impact on this structure than already exists. The proposed new linkspan and extended marshalling area would not have a detrimental visual impact on the adjacent Grade B Royal Marine Hotel.

4. Access to the public slipway will be further restricted and its use all but completely rendered unfeasible.

Comment – The public would still have access to this slipway. Existing concrete steps down to the slipway will be replaced while the existing tarmac slipway at the main entrance will be replaced with concrete.

5. The site is on a bad bend on the main traffic road and any increase in loading of ferries will increase traffic flow. Currently traffic waiting to load backs up along the main road effectively blocking it. Western Ferries no longer permit customer parking within their grounds leading to a strain on the parking space available on the public roads that have been less than successful if judged by the increase in the number of accidents. No expansion should be permitted until such time as this requirement is met.

Comment – The Area Roads Manager is satisfied (subject to conditions) with the overall proposals subject to lowering of the masonry wall and removal of vegetation, additional signage and measures put in place by Western Ferries to cope with overflow traffic on the A815. The reconfigured and extended marshalling yard should help to alleviate existing traffic problems at normal times.

6. The plans can be viewed in Rothesay, and Helensburgh but why not Dunoon, Hunter’s Quay or Sandbank. Why was it not published in the local press?

Comment – The application was originally incorrectly lodged by the agents at the wrong area offices. When the application package was finally delivered to the Dunoon office on 8th February 2005, it was validated on 23rd March 2005 and published in the Dunoon Observer on 8th April 2005.

7. The infill will represent an unacceptable level of noise, dust and pollution to local residents.

Comment – Public Protection have requested an Environmental Management Plan to cover such issues as noise, dust and pollution.

8. The existing views from properties on Marine Parade will be spoiled, reduced and house values will drop.

Comment – Existing views from Marine Parade will remain relatively unchanged although this is not material. The extension and reconfiguration of the marshalling yard and erection of a new linkspan will not have a detrimental visual impact on surrounding properties, given the scale and height of the new infrastructure. The only conceivable impact would be that vessels would berth slightly closer to the A815 Marine Parade, where there are waiting restrictions on the roadside nearest the terminal. It should be remembered that the existing lawful use of the site is a ferry terminal or transport interchange facility.

9. Comments raised regarding increased traffic movements, staff numbers, on-street car parking and traffic and directional signage.

Comment – Refer to Area Roads Manager’s comments above.

10. It would be necessary to depart from the local plan by permitting what is an industrial development within a residential area. All development should be proportionate to the needs and this application represents a totally unnecessary facility.

Comment – See assessment below.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

B. ASSESSMENT

(i) Policy Overview

A summary of the Policy Implications with respect to National, Strategic, Local and other Policy advice is given below.

National Planning Policy (SPP and NPPG) and Planning Advice Notes (PANS)

In considering this application for a new linkspan and berthing structure, considerable weight must be given to government policy that in particular promotes and sustains the economic well being and development of towns as well as safeguarding out historic heritage having regard to the principles that underpin sustainability. In this regard consideration has been given to the following, SPP2 ‘Economic Development’, NPPG13 ‘Coastal Planning’,NPPG14 ‘Natural Heritage’, ’NPPG 17 ‘Transport and Planning’ , NPPG 18 ‘Planning and the Historic Environment’.

SPP2 ‘Economic Development’ states that a successful economy requires an effective and efficient transport infrastructure, and that good, affordable and reliable public transport links are important. In making provision for economic development, planning authorities should seek to minimise adverse effects on the natural and built heritage, consistent with national planning policies in SPPs/NPPGS.

NPPG13 ‘Coastal Planning’ highlights the principles of sustainable development while maintaining and enhancing biodiversity, and that the criteria required by the various bodies responsible for environmental protection should be met.

NPPG14 ‘Natural Heritage’ provides guidance on the conservation and enhancement of the natural heritage and the role of SNH and other bodies.

SPP17 ‘Transport and Planning’ states that the protection of the environment lies at the heart of the Government’s policy making and has a key influence on transport policy. It seeks to ensure that transport and related land-use proposals do not undermine the quality of the historic environment. It also states that noise impact of new transport infrastructure should be taken in to account in addition to Sustainable Urban Drainage Techniques, impact on wildlife and landscape.

NPPG 18 ‘Planning and the Historic Environment’ stresses that development is of a high quality in terms of construction and design. It should pay respect to the historic character of adjacent buildings and the surrounding area.

Argyll and Bute Structure Plan 2002

Relevant polices of the Structure Plan include STRAT S1 (Sustainable Development); REC SI 1 (B)2. Rapid Transit Potential); PROP TRANS 1 (Transport and Access) STRAT DC9 (Historic Environment) together with the underlining objectives of promoting and sustaining tourism.

Cowal Local Plan Local Plan 1993

The Cowal Local Plan 1993 (Adopted in 1995) contains specific polices in relation to both the protection and setting of listed buildings and Townscape Policy Areas in particular Policy POL BE 1 and POL BE 4. Although such polices are aged and require to be updated within the new district wide local plan, the fundamental objectives that they seek to reinforce and the protection and enhancement to the historic environment will not be altered. Other strategic polices contained within the plan are:

STRAT 1 Regeneration of Cowal – prime strategy of economic regeneration in a sustainable manner that does not compromise the natural heritage of the area;

STRAT 2 Developments of sub regional importance will be encouraged and expected to locate in Dunoon;

Under POL TR1-The Council will oppose changes or reductions in service on the Cowal-Clyde ferry routes which undermine the economic regeneration of Cowal but will support measures which will result in improved services and facilities on these routes;

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

Under POL TR3- The Council will encourage road and traffic management improvements at locations included in Schedules 1 and 2 through the imposition of conditions on planning consents relative to development proposals. This includes access problems with all junctions on the A815 including the main access/egress to the existing ferry terminal at Hunter’s Quay;

In addition POL COM 5- potential ‘bad neighbour’ is also relevant is so far as consideration must be given to any nuisance from light, noise, dust, smell etc although this should relate to the development upon implementation rather than necessarily through the construction process which can be controlled through other means;

POL RUR 2 -Resists development and land use changes that would erode or adversely affect wildlife features.

(ii) Need for Additional Linkspan

The applicants were requested to provide an operational statement (received 22nd March 2005) and justification for a “replacement” linkspan facility and extended and reconfigured marshalling area.

“Outline Western Ferries propose to introduce a new linkspan at the existing terminal at Hunter’s Quay, which will take over the regular service from the existing linkspan. The existing linkspan will remain in-situ to provide a fall back service and to allow vessels to continue to moor at the site giving shore access to the crew.

Definitions For the purposes of this submission, peak service is defined as the maximum regular traffic, which uses the terminal on a daily and weekly basis. Extreme service is defined as the exceptional traffic, which occurs only at high season bank holidays and during the Cowal Games weekend.

Operating Conditions It is anticipated that, after its installation, all traffic (including peak service) will be carried via the new linkspan as this ramp is longer and more efficient than the existing linkspan. The existing linkspan would not be used for either passenger or vehicular traffic and it is not considered feasible to use both linkspans simultaneously as the traffic management would be too complex.

However, the existing linkspan could be used if there were a mechanical failure, a particularly troublesome direction of wind, sea and swell or in the event of some unforeseen circumstances. In addition, the linkspan is a mooring structure, which enables ferries to be held on the berth without mooring wires; a desirable feature, which it is hoped, can be retained, at least in the short term.

Extreme Conditions During the extreme periods where traffic volume is substantially higher than the peak service, there remains a contingency for the existing linkspan to be used to relieve pressure on the road networks. Loading and unloading cannot occur at both ramps simultaneously due to the above highlighted traffic management issues, but it is possible to berth a second ferry whilst another is loading or unloading. This would allow an improved turn-around at extreme periods but would only be practical when additional car marshals were available and not during normal services.”

(iii) Economic Issues

The improvements to the existing ferry terminal facility and its associated links with the mainland are now required to maintain and improve upon if the local economy is to compete within the wide market. The Hunter’s Quay Ferry Terminal provides for one of the two links with . Comments regarding the services provided at present and in the future by Western Ferries and Caledonian MacBrayne cannot be addressed in this application.

The new breakwater facility at Dunoon Pier provides for direct passenger access to the central belt linking with the train service at Gourock. Whether Western Ferries (or any other operator) competes for that route, is a strategic political issue and not one that can be dealt with in this application. The provision of the two routes serving Dunoon and East Cowal should be maintained and enhanced where possible in terms of the local economy. This application can therefore only address the planning issues of the proposed development, which essentially seeks to alter and improve the existing facility for future demands at that location.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

(iv) Proposed Development

The existing pier structure and linkspan extends some 55 metres into the Firth of Clyde. The proposed linkspan and berthing structure would extend approximately 73 metres into the Clyde on the western side of the existing facility (excluding infill). This figure comprises of approximately 30 metres for the new linkspan, approximately 45 metres for the berthing structure (overlapping the linkspan by 6 metres) and approximately 10 metres infill for the new marshalling area. This effectively means that the new structure would extend approximately 25 metres beyond the existing facility. In design terms, the new facility would be very similar to the existing linkspan and pier.

The new berthing structure would be constructed in steel tubular piles with a narrow walkway on top. The new linkspan will have a pedestrian walkway on its western side and anchored to a bankseat on the area to be infilled. The area to the west of the existing marshalling area will be infilled with clean imported rockfill and finished to create an extended marshalling area. Rock armour (1.5 tonne) is proposed along the edges on top of a 150kg secondary layer. Details of the rock armour are required in order that this marries with the existing shore and condition 11 in this regard is suggested. A 10-metre gap will be left between the edge of the new extended marshalling area and the existing concrete slipway.

The main alteration would be to the existing marshalling area, which would be reconfigured towards the new linkspan with 8 lanes for cars and 3 lanes for HGV/PSV vehicles. The marshalling area will effectively be increased by approximately one third.

(iv) Built Heritage and Listed Structures

Given the location, scale and design of the new facility and the fact that no works are proposed to the existing structure, neither the Grade B Listed pier structure nor surrounding historic buildings within the Marine Parade Townscape Policy Area, including the Grade B Listed Royal Marine Hotel, would be visually compromised by the proposed works.

In visual terms, the proposal would not introduce any high structures, or significantly alter what is a holding car park at a ferry interchange. Given the scale of the development, it is considered that the existing views of the main feature buildings such as Hunter’s Quay Hotel and the Royal Marine Hotel and surrounding Victorian villas, would not be compromised.

(v) Transportation and Operational Matters

The Area Roads Manager (in his amended detailed comments above) mentions a number of key areas where improvements could be made to the ongoing and revised operation at the terminal. Conditions are recommended regarding additional car parking, dedicated staff car parking and directional signage, an advisory note sets out the criteria to deal with such issues as overspill traffic on the public road, rogue car parking, manpower and training.

A main issue to consider relative to road safety and traffic emerging from the ferry terminal on to the A815 is the provision of acceptable sightlines. In the Area Roads Managers amended response it is clear that in order to achieve safe and acceptable sightlines to the northwest this will entail the removal of the top element of the existing masonry wall for about 43 metres to ensure that the wall does not exceed 1.0 metre above road level. In addition the removal of vegetation is required and in perpetuity. This raises the question of whether this aspect can be conditioned or should be addressed via a Section 75 Agreement.

As Circular 12/96 “Planning Agreements” stresses Section 75 Agreements have a limited role, are themselves subject to a number of tests and should only be sought when they are required to make a proposal acceptable in land use terms. Importantly they should not be used as an opportunity to obtain a financial or environmental benefit that is unrelated in nature, scale or kind to the development proposed. As a general rule planning conditions should be used, where possible, rather than a Section 75 Agreement to remove any obstacle that would otherwise prevent the development taking place.

To the best of the department’s knowledge the Council own the masonry wall that is required to be lowered for around 43 metres. The required works to the wall are outwith the application site (site edged red) and in normal circumstances the course of action would be to require the applicant to enter into a Section 75 Agreement with the landowner to secure the necessary works. Circular 4/1998 “The use of planning conditions in planning permissions” reminds that particular care needs to be taken over conditions which require works to be carried out on land in which the applicant has no interest … “if the land is outside the site

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC a condition requiring the carrying out of works on the land cannot be imposed unless the authority are satisfied that the applicant has sufficient control over the land to enable those works to be carried out.”

The key test is whether the Planning Authority is satisfied that the applicant can carry out the necessary works required by the Area Roads Manager as previously referred to. In this case the Area Roads Manager on behalf of the Council has sought the necessary works, the wall is owned by the Council and in the grant of any planning permission the Council are effectively endorsing and requiring the lowering of the wall. No third party is involved which is the norm with most other Section 75 Agreements.

With all such matters considered, the use of a Section 75 Agreement would appear superfluous since the same end result would be achievable via a suspensive planning condition. Such comments are equally applicable to the vegetation that currently obscures the sightline. In the main this relates to three clumps of self-seeded trees, predominately sycamore of no amenity value that are actually growing out of the wall. Such trees mainly in those areas on top of the wall buttress currently damage the structure of the wall.

The removal of such vegetation is a prerequisite prior to all other works and given that the main users of the entrance and the sightline to the northwest will be Western Ferry passengers/ travellers/staff it is considered both “necessary” and “reasonable” to secure the removal of this vegetation and in perpetuity. Essentially this will entail cutting back the self-seeded trees, cutting out the rootballs from the masonry wall, treating and repairing the wall. Condition 13 has been carefully tailored to address these matters.

(vi) Environmental Concerns and Nature Conservation

Given the scale and nature of the development Scottish Executive has determined that there was no requirement for an Environmental Statement. Scottish Natural Heritage has no comments to make on the proposal while SEPA has confirmed that the proposed development is unlikely to breach Water Framework Directive objectives in the long terms and is unlikely to have any significant environmental impacts on coastal processes and biodiversity due to its scale and location.

Cowal Local Plan Policy POL RUR 2 states that developments that would have an adverse effect on features of wildlife value will be resisted. From all information and knowledge available it is envisaged that any disturbance to birds would only be of a temporary nature and during the construction period. Such disturbance would be essentially negligible particularly given the suitable alternative roost sites available in the area. SNH has not raised any significant concern in this regard.

(vi) Wave Impact/Coastal Issues

The proposed berthing structure is an open span structure set on steel tubular piles. Given the similar design to the existing pier, it is not envisaged that there would be any significant impact upon the wave regime both locally in the vicinity of the terminal and further along the coastline. The new rock armour would protect the extended marshalling area from wave impact.

(vii) Aquatic Issues

The main way the development can impact upon aquatic life is via temporary disturbance through noise and vibration and change in water quality due to sedimental disturbance. While there will be the permanent loss to the seabed from the physical incursion and construction from the extended car parking/marshalling area into the seabed, including the subtidal habitats, this to a large extent is insignificant having regard to the scale of the proposed works.

The greatest threat to aquatic life is probably through dredging around the pier and accidental spillage of fuel and chemicals into the Firth of Clyde during the construction process. All construction activities have the potential to generate pollutant matter and surface water run off may potentially become contaminated with silts, cement, concrete and oils if mitigation measures are not adopted. Best practice methods including SEPA’s Prevention Guidelines and the proper location of plant and machinery are measures aimed at preventing the potential for pollutants engaging with the Firth of Clyde to the detriment of aquatic life. The applicant should be fully familiar with these, but a ‘note to applicant’ would be imposed as part of any grant of permission since Best Working Practices and stringent pollution control measures should mean that there is no serious cause for concern to aquatic life.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC

(viii) Noise and Construction Activities

In terms of noise this is low and generally confined to the mooring and manoeuvring actives at the pier primarily by the Western Ferries services. The site for the new linkspan is well distanced from residential properties. While some residential properties around Cammesreinach Brae may feel that the new linkspan is much closer than at present, the length of the new linkspan and berthing structure would mean that vessels are moored at approximately the same distance away from residential properties, as exists at present.

The main issue would be that the existing marshalling area, which is orientated in a west to east direction, would now line up in a southwest to northeast direction bringing vehicles visually closer to Cammesreinach Brae. In terms of Local Plan Policy POL COM5 ‘bad neighbour’ development is only applicable to operational rather than constructional matters. Concerns relative to increased noise would be difficult to substantiate so as to justify refusals given the scale of the development and the lawful use of the site whilst in addition a management plan would be imposed (Condition 3) to address this issue.

In the event of serious construction noise regulatory powers are available to Public Protection Services under the Control of Pollution Act 1974 that can be regulated and actioned in the event of justified noise problems which in any event are likely to be short term and temporary. Most issues arising from the constructional phase including disturbance, dust, noise and vibration are best controlled through the environmental management plan.

Given the scale of the development, it is anticipated that HGV’s would deliver the quantities of rock both imported rock fill and the two sizes of rock for the rock armour to the site. This is likely to create temporary but not insurmountable pressure on the local road network.

Requirement for a Hearing

Whilst members may wish to give consideration to an ‘informal hearing’ given that seven letters of representation from six properties have been received, the issues raised have been carefully considered and addressed and the proposed development accords with development plan policy including a Policy that is specifically geared toward development of this nature. Consequently, the department would advise that there is no requirement for a formal ‘PAN 41 hearing’.

F:\MODERNGOV\DATA\PUBLISHED\INTRANET\C00000242\M00002085\AI00023093\00220WRAWESTERNFERRIESLINKSPANHUNTERSQUAYDUNOON0.DOC