APPENDICES

APPENDIX 1 - FEASIBILITY STUDY

1.1 In the course of the preparation of the City Development Plan, a shortfall in the supply of housing land was identified in the Strategic Development Plan. The area north of Summerston was submitted as a proposed release from the green belt in response to this shortfall. In the Report of Examination on the City Development Plan in June 2016 the Reporter did not recommend that the area be released at that time, but concluded that it would be appropriate to undertake a feasibility study to examine in detail a number of matters which included, but were not limited to, environmental, hydrological and infrastructural issues. The full list of issues which the Council agreed to include within the study are as follows:

a. Landscape, Visual Impact and Hydrology; b. Green Belt/Green Network; c. Biodiversity; d. – Setting and Impact on Buffer Zone; e. Flooding and Drainage; f. Sustainability of Location for Facilities/Services; g. Traffic / Roads Infrastructure; h. Improvements to Blackhill Road – Timing and Phasing; i. Education Capacity; j. Placemaking; k. Impact of Landfill Site on Study Area – Landfill Gas Migration and Leachate Pollution; and l. Luddon Construction Site – Potential Inclusion in Development Area

1.2 In view of the passage of time since the City Development Plan Examination was concluded, the study will also consider an updated housing land supply position in order to assess the current need for additional housing land.

1.3 The study area (see Map 1 overleaf) included the part of the Green Belt north of Summerston between the and the west side of Road identified as having potential for development in the Green Belt Review of 2013. The area north of Milton, to the east of Balmore Road was also included, in order to investigate the feasibility of the construction of the Northern Circumferential Route, which was also identified as a proposal in the City Development Plan.

1.4 A study group was convened in 2017, comprising Council officers, Montagu Evans (who are representatives of the landowner, Caledonian Land) Summerston and Community Council, and various heritage and environmental bodies, including Scottish Natural Heritage and Historic Environment . The Council is grateful to the group for their participation and expertise.

Map 1– Summerston Feasibility Study Area

1.5 The group visited the area, and met regularly between 2017 and 2018, gathering information and comments from all parties on the proposal. These comments are summarised under the relevant headings in Section 3.

1.6 At the same time, the Council met Montagu Evans to discuss a related proposal for the construction of a northern circumferential route from Maryhill running across the top of Summerston to Milton, and eventually meeting the Springburn Expressway. The purpose of this route was to relieve commuter traffic congestion on Maryhill Road and Balmore Road. Montagu Evans indicated that the landowner would be willing to contribute financially to the investigation and construction of this route.

1.7 Given the existing traffic congestion identified, discussions on the circumferential route were considered to be important to the assessment of whether additional housing land could be identified in the Summerston area. These matters were therefore prioritised, before further progress on the study could be made. After further examination, the Council concluded that the complexity of the issues surrounding the construction of the route, including land ownership, environmental and natural heritage issues, meant that it would not be pursued in the medium term. At that point, Montagu Evans and transport consultants were advised to re-visit the proposal, with the objective of identifying a solution to the transport infrastructure constraints.

1.8 The study group paused at this point, until further information could be provided by Montagu Evans.

1.9 In late 2019, Montagu Evans submitted an Environmental Impact Assessment, followed by an application for Planning Permission in Principle. The application indicated a phased development, with an initial 3 phases of 500 houses at the western side of the area (see Map 2 overleaf). In light of the fact that the Northern Circumferential Route would not be progressed, no development was proposed in the area east of Balmore Road. For the purposes of the feasibility study, it was therefore appropriate at this point to focus mainly on those matters which were relevant to the area west of Balmore Road. Council officers met Montagu Evans in February 2020 to discuss next steps. It was agreed that the time period for determination of the planning application would be extended to allow time for completion of the feasibility study. Once approved by Committee, the study would be a material consideration in the determination of any planning application.

Map 2: Indicative Masterplan

1.10 It should be noted that the application for Planning Permission in Principle relates to the entire feasibility study west of Balmore Road. This means that the applicant is seeking to establish the principle of residential development for the whole area. However, it is also relevant to state that the assumptions used to support the planning application, for example in terms of traffic generation, are based on only part of the study area, i.e. the first phases of up to 500 houses. This should be borne in mind when considering the potential impact of development in this location.

1.11 Information gathered from the planning application has also been used to assist in the study, and is summarised with other study findings in Section 3.

2. HOUSING LAND SUPPLY

2.1 The need for a feasibility study was identified in response to a shortfall for the period 2012-24 identified in the 2012 Strategic Development Plan. The 2012 Plan was replaced by the 2017 Strategic Development Plan, which included an updated assessment of housing requirements, and identified a significant decline in the level of housing need and demand. For example, SDP1 identified a housing requirement for of 19,900 (3,980 per year) for the period 2020-25, while SDP2 identified an equivalent housing requirement of 12,510 (2,502 per year). The study area lies within the North and West Housing Sub Market Area (GGN&W HSMA) which also includes the City Centre, in West and in .

2.2 As required by Scottish Planning Policy, Strategic Development Plan Policy 8 sets out the requirements for Local Development Plans in terms of providing a 5 year effective housing land supply to meet the Housing Supply Targets. The requirements are specified at the following geographies:

Glasgow all tenure and private sector supplies GGN&W HSMA private sector supply

2.3 As at 2019, there was a surplus in the all-tenure and private sector supplies for Glasgow, and a surplus in the private sector supply at HSMA level. This surplus has been calculated by comparing the total land supply for the period 2019-2024 with the 5 year Housing Supply Target for the period 2019-24.

2.4 In circumstances where there is a shortfall in housing land supply, Policy 8 sets out a sustainable location assessment for proposals. In view of the surplus in housing land supply, however, the sustainable location assessment is not engaged. City Development Plan policy CDP 2: Sustainable Spatial Strategy policy preference for brownfield sites over greenfield sites would also not support the proposal in these circumstances.

2.5 In order to meet the terms of the feasibility study, however, there is a requirement to consider matters such as environmental sustainability, traffic/roads infrastructure and other issues specified by the Reporter

3. SCOPE OF FEASIBILITY STUDY

a. Landscape, Visual Impact and Hydrology

Study Findings

3.1 In response to the Green Belt Review conducted in 2013 in support of the City Development Plan, Scottish Natural Heritage (SNH) provided comments on the area now identified as the Feasibility Study area. As noted in Section 1, the proposed development was now primarily focused on the area west of Balmore Road. Some of the comments provided by SNH (which relate to the area east of Balmore Road) were offered in the context of possible future development as a result of the construction of the Northern Circumferential Route, and are therefore not entirely relevant. However, the potential impact of development on Possil Loch SSSI, which is east of Balmore Road, remains a matter of importance to SNH. The response covers the following issues:

a Protection of the nationally important freshwater habitat within Possil Marsh SSSI. Development of fields which may drain to this SSSI is not precluded, but would require highly specified SUDS. b The landscape setting provided to the surrounding communities by the existing green belt, particularly as experienced in certain key views. c Effect of development on landscape character, in the context of the Site of Special Landscape Importance (SSLI) designation. d Potential provision of robust new green belt edge, create sustainable settlement pattern and provide enhancement to the green network. e Consider net effects on opportunities for recreation, particularly in the Corridor.

3.2 SNH attached a map (see Map 3 overleaf) showing the areas which, taking the above matters in consideration, it considered to have potential for development. These areas were identified as Site A – north of Milton, and Site B – north of Summerston. Only Site B is west of Balmore Road, and is considerably smaller than the study area. It may be concluded that SNH’s principal objection to the development of housing on the remainder of the study area west of Balmore Road is the impact that it would have on the quality of the landscape, and in particular the setting that it provides for the City from key views. Map 3 – Scottish Natural Heritage Consultation Response

Consultant Response

3.3 In support of the planning application, the applicant submitted an Environmental Impact Assessment (EIA) which included a Landscape and Visual Impact Assessment (LVIA). This assessment considers the impact of the proposed development on landscape character, key landscape features and visual amenity. The EIA also includes a series of photomontages from various viewpoints showing views to the site as existing, at Year 1 and at Year 10. These are shown in the EIA Figures.

3.4 The EIA acknowledges that the development “has the potential to result in significant adverse effects on landscape and visual receptors within proximity of the site, and at sensitive locations further afield.” A series of mitigation measures is proposed within the design “with the aim of avoiding or reducing potential effects on the landscape and views, where possible.” These are as follows:

 The retention of existing boundary features where possible;  Adequate development standoffs from sensitive features such as the River Kelvin;  Ensuring the development fits with the scale, character and patterns of existing nearby development;  Provision of structural tree belts to reduce the impact of development on localised views;  Provision of a ‘green corridor’ and additional planting throughout the development to ensure compliance with Policy CDP6: Green Belt and Green Network of the Glasgow City Development Plan (, 2017); and  Providing connections with both the existing settlement edge of Summerston and the nearby Kelvin Walkway.

3.5 The EIA considers that while there will be direct adverse residual effects on the landscape of the area, these will be apparent during the construction phase and year 1 of operation of the development. The implementation of the measures noted above will reduce these effects to moderate to minor and not significant by year 10 of operation.

3.6 In terms of the effects on views and visual amenity, these were assessed as experienced from selected settlements, transport routes, recreational routes and representative viewpoints.

(a) Of the five settlements assessed, three (Summerston, properties on Lochfauld Road, and the single settlement at Blackhill Farm), were considered to experience significant adverse effects, with the remainder expected to experience no significant adverse effects. (b) Blackhill Road is the only route considered to experience significant adverse effects across its extent, while two further routes, Millichen Road and Kelvin Walkway would experience significant adverse effects “where the site is clearly visible; effects would be negligible across the route extents.” (c) Seven viewpoints were assessed, with three of these predicted to experience significant residual effects, namely, two viewpoints from Millichen Road and one which is in close proximity to the northern site’s southern boundary, leading to a highly sensitive long distance footpath. The remaining viewpoints were considered to experience residual adverse effects.

Further Response from Scottish Natural Heritage

3.7 In response to the additional information provided by the applicant, SNH has had the opportunity to comment further on this work. SNH considers that insufficient information has been provided in relation to the potential impact of development on Possil Marsh SSSI, and therefore maintains a holding objection until this information has been provided and assessed. Nevertheless, the response provides detailed comment in relation to landscape and visual impact, and hydrology.

Landscape and Visual Impact

3.8 SNH recognises that the development layout and landscape framework aims to set development back from nearby visual receptors, and proposes to accommodate housing areas within a large scale and extensive landscape framework. The response concludes that the development will have landscape and visual impacts, which should be carefully considered.

3.9 The important role of the proposed vegetation retention and planting, which would develop over time, in containing and framing views to and from the site, is stressed by SNH. Vegetation also has the potential to promote a degree of accommodation of the development within the landscape as the planting matures.

Hydrology

3.10 It is acknowledged that the development area has been set back from the SSSI. More detailed analysis will be required for SNH to assess any potential impacts on the SSSI, in particular the potential for hydrological connectivity between the development area and the SSSI, and to consider any mitigation proposed.

3.11 SNH notes that there will be a long term increase in traffic on Balmore Road, and considers that careful design of SUDS areas outwith the housing development areas will be required to reduce surface water drainage into the SSSI.

b. Green Belt/Green Network

Study Findings

3.12 As noted previously, the changed housing land supply position, allied to the declaration of a Climate Emergency, provides a different context to the consideration of the release of greenfield land for housing, and gives additional weight to environmental considerations.

3.13 Glasgow and the Clyde Valley Green Network partnership and SNH provided comments on the planning application, which are relevant to the feasibility study. These are summarised as follows:

 Green Infrastructure – the future management and maintenance of all greenspaces, including how this would be funded should be set out within a Stewardship Plan. It is acknowledged that this would be expected in a detailed proposal.

 River Kelvin Walkway - as a regionally strategic access route it would be expected that this would be enhanced to a much higher standard than is currently indicated. It would also be expected that it's future maintenance and management, where it interacts with the site, be part of the Stewardship Plan for all green infrastructure, including management prescriptions.

 Other paths - all the paths in the masterplan are currently indicative, and therefore the comments are necessarily general. It is recommended that these are designed to accommodate both walkers and cyclists at the same time (and future social distancing) i.e. 3m wide, and that all surfaces be tarmac for all users to avoid future maintenance issues. It is also considered that more detail should be provided as the proposal progresses to ensure that the network isn't diluted during phased delivery.

 Greenspace – The greenspaces shown in the masterplan are all indicative, for example the “pocket parks". The functionality of the spaces should be clear, and any greenspace provision should meet the quantity, quality and accessibility standards set out in the SG6: Green Belt and Green Network.

3.14 SNH acknowledges the submission of a Landscape Framework, and considers that the its stated aims, including the scale of open space provision, existing vegetation retention, planting layout, habitat creation, and drainage and path networks, should be secured as proposed. The Landscape and Management Plan proposed by the applicant requires to be long term and appropriately financed, including the management of all open spaces.

Consultant Response

3.15 The detailed proposals contained within the Landscape Framework are considered to address comments from the Green Network Partnership and SNH.

c. Biodiversity

Study Findings

3.16 The Biodiversity team within GCC Neighbourhoods and Sustainability has provided comment on the planning application, which are of relevance to the study. In summary, the team maintains an objection to the proposal, for the following reasons:

(a) The retention and enhancement of some habitat networks does not sufficiently compensate for the loss of habitat as a result of the proposal. There would be a net loss of wildlife habitats in the farmland landscape used by farmland birds and larger mammals such as roe deer; and (b) A net loss in greenbelt and further erosion of rural greenspace, which would be unacceptable in the current climate and ecological emergency.

3.17 In relation to the preservation and enhancement of habitats, Glasgow and the Clyde Valley Green Network Partnership notes that the Access and Design Statement states "A varied mowing regime throughout the site, including areas of long grass and wildflower meadow will increase the diversity of habitats present" and "understorey planting along the existing substantial hedgerows and adjacent to proposed structural woodland to provide enhanced habitat networks". The proposal should provide detail on how any habitats are reflective of what's currently within and adjacent to the site, and how they would benefit habitat networks and connectivity. Future management of hedgerows and wildflower meadows should also be set out.

3.18 SNH notes that an updated protected species survey, and a bird survey would both be required. Overall, SNH concludes that the proposals would provide appropriate support to biodiversity within the study area.

Consultant Response

3.19 A response to these comments has been provided by Brindley Associates, the key points of which are as follows:

(a) Approximately 61% of the site area is retained as open space, providing opportunities for biodiversity; (b) Development is focused on areas where biodiversity is of low value, due to the uniformity of habitats and the lack of species diversity. It is considered that there are areas of similar value to the north and east of the site which could provide suitable habitats for farmland birds and roe deer. (c) Other detailed proposals which would enhance biodiversity within the site include:  Semi-natural boundary planting;  The creation of substantial habitats and open spaces adjacent to the River Kelvin, as well as native species along spine roads and Blackhill Road;  Retention of existing habitat features and the addition of SUDS;  Standoff areas from ecologically important areas, such as the River Kelvin and its associated flood plain; and  Buffer planting along the River Kelvin riparian habitat.

3.20 Arrangements for management of open spaces, green networks and habitats would be considered by means of a detailed proposal.

d. Antonine Wall – Impact on Setting and Buffer Zone

Study Findings

3.21 The study area is located to the south of the route of the Antonine Wall, but is adjacent to the Antonine Wall World Heritage Site Buffer Zone. The study found that the development would have the potential to affect the setting of the Buffer Zone.

Consultant Response

3.22 The Environmental Impact Assessment (EIA) prepared to accompany the planning application has assessed the level of impact on a number of cultural heritage assets within the study area. In relation to the Antonine Wall World Heritage Site and Buffer Zone, the EIA concludes that the development would have a Minor to Moderate adverse indirect effect upon its setting. This effect is considered to be capable of mitigation though the design of any development, and is expected to diminish over time as trees within the development mature.

Historic Environment Scotland (HES) Response

3.23 HES remit is limited to direct impacts on statutory designations and visual impacts on the landscape settings of these designations. Based on the information provided, HES offered no objection, but advised that the local archaeological service should be consulted.

West of Scotland Archaeological Service (WoSAS) Response

3.24 WoSAS noted that the Environmental Statement included mitigation measures relating to the evaluation and excavation of archaeological features. The response concluded that, provided these were undertaken before and/or during development, no objection to the proposal would be offered.

3.25 In relation to the potential impact on the setting of the Antonine Wall Buffer Zone, WoSAS agreed that the Environmental Statement had considered the degree of alteration to the setting appropriately, and that the proposal would be likely to have a non-significant impact.

e. Flooding and drainage

Study Findings

3.26 The applicant has submitted a Flood Risk Assessment (FRA), and has used analysis contained within the 2017 River Kelvin Study to consider flood risk from the River Kelvin and the small watercourse which runs through the site.

3.27 The Scottish Environment Protection Agency (SEPA) has provided comments on the FRA, the key points of which are noted as follows:  It is not clear whether development would avoid the functional floodplain, although the FRA notes that the western area of the site would be designated greenspace. A condition to prevent development within the functional floodplain would be required;  The 2017 study considered a 20% uplift in fluvial flow within the Clyde Basin due to climate change. The latest guidance recommends a 44% climate change uplift;  Finished Floor Levels of properties adjacent to the River Kelvin require to be set a minimum of 600mm above the design flood level.

3.28 SEPA has requested further information, clarification and analysis in order to reach a final view on the proposal. In the meantime, it maintains its objection to the proposal on the grounds that it may place buildings and people at flood risk, contrary to Scottish Planning Policy.

3.29 It is a statutory requirement that any new development is required to ensure that it can be satisfactorily drained through Sustainable Urban Drainage System.

Consultant Response

3.30 A revised Flood Risk Assessment (FRA) was submitted in May 2020 to support the planning application. In summary, the FRA concluded that:

Flood Risk

(1) “Fluvial flood risk associated with the River Kelvin, is considered to be low, assuming that Finished Floor Levels (FFLs) within the adjacent development plots are set at a minimum of 600mm above the design flood level”.

(2) “The risk of groundwater exacerbating flooding from other sources is considered to be medium, and further investigation is required to determine groundwater levels in the site vicinity.”

(3) “Isolated pockets throughout the site are at medium to high risk of surface water flooding”. In the light of the increase in impermeable surfaces that will result from the development, suitable drainage measures are recommended, and it is noted that this would reduce the flood risk in these areas to low.

(4) All ground is recommended to generally slope away from buildings at a sufficient gradient in order to prevent surface water from entering. Over and above the minimum of 600mm FFLs in areas adjacent to the River Kelvin, a further 150mm above adjacent external ground levels is recommended in all other development areas.

(5) These conclusions are subject to agreement with GCC agreement to a 30% climate change uplift in FFLs, rather than the 46% uplift recommended in SEPA guidance. Drainage

The FRA included a Preliminary Drainage Assessment, the findings of which are summarised as follows:

(1) It is acknowledged that the areas of hardstanding within any development could contribute to increased surface water runoff, however, this could be addressed by the inclusion of plot-scale measures, such as bio-related features, permeable paving, filter trenches and roadside swales. Secondary treatment of surface water, though attenuation features such as SuDS ponds, may also be necessary where appropriate.

(2) Design measures, including site levels, drains and landscaping, to route excess flows away from buildings and infrastructure to drainage outlets and landscaped areas should be incorporated within a detailed proposal.

(3) Scottish Water infrastructure plans indicate suitable connection points for foul water flows. This should be confirmed through a Pre-Development Enquiry to Scottish Water.

e. Sustainability of Location for Facilities/Services

Study Findings

3.31 SG11 includes guidance on the Location of New Development, which states:

Scottish Planning Policy notes that “planning permission should not be granted for significant travel generating uses at locations which would increase reliance on the car, and where:

 direct links to local facilities via walking and cycling networks are not available or cannot be made available;  access to local facilities via public transport networks would involve walking more than 400m; or  the transport assessment does not identify satisfactory ways of meeting sustainable transport requirements.”

3.32 The Transport Assessment submitted in support of the planning application uses 1600m isochrones to assess the accessibility of the site to shops, schools and other facilities. This is considered to be inadequate, as it does not take account of actual routes and walking distances, and includes only a limited number of facilities.

3.33 In order to provide a detailed assessment of accessibility, GIS analysis by Development and Regeneration Services was undertaken, using the digitised road and footpath network to measure 400m and 800m actual walking distances from two access points from the site to local services and facilities. This work considered walking access to public transport, and a full list of facilities in the area, including shops, schools, community halls, GPs, dentist surgeries, sports facilities and libraries. The results of this analysis indicate that:

(a) Summerston railway station is more than 800m from the site; (b) The nearest bus stops are within 400m of the site, although they provide a less frequent service, and therefore are considered to provide base accessibility to public transport; (c) Bus stops providing a more frequent service, and therefore high accessibility to public transport, are within 800 metres of the site; (d) The nearest shopping facilities are more than 800m from the site at Summerston retail centre, which includes a large supermarket and other smaller shops and food outlets; (e) The nearest Council run community facility is more than 800m from the site; (f) The closest dentist is within 1,500m of the site; (g) The nearest GP practice is around 2km from the site; (h) The closest library and sports facilities operated by the Council are on Maryhill Road, around 2km from the site; and (i) There are two primary schools and 1 secondary school within 400m of the site, and one further primary school within 800m of the site.

3.34 When assessed against SG11, the analysis indicates that access to these facilities involves longer walking distances than would be advisable, which would lead to increased dependence on car travel. This could be mitigated to an extent by a package of improvements to encourage walking and cycling, secured by legal agreement, but this would not overcome completely the lack of accessibility that the site experiences. The lack of accessibility increases in those parts of the site towards Balmore Road. It is considered, therefore, that this location would not meet the requirements of SG11 without significant mitigation.

3.35 In initial stages of the Feasibility Study, the indicative layout made provision for a small neighbourhood centre. The current planning application is for residential development, and omits this provision. It is suggested that, given the lack of accessibility to shops and other facilities referred to above, further consideration should be given to the re-introduction of local shopping and community facilities in the form of a small neighbourhood centre. This would also comply with the requirements of retail policy in SG4. It is acknowledged that a development of a scale significantly greater than the initial 500 houses proposed in the first phase would be required to make a neighbourhood centre financially viable.

Consultant Response

3.36 The Access Strategy submitted by the applicant indicates that pedestrians and cyclists will be able to connect into the existing network, and that schools and other facilities are within 5-10 minutes walking distance. New footways are proposed along Blackhill Road, and a new cycle link to the River Kelvin walkway.

3.37 In relation to the potential for the inclusion of a neighbourhood centre within the proposal, the Planning Policy Statement provided for the planning application notes that this was omitted from the proposal in response to community concerns regarding noise. It is also stated that this could be reinstated at a later date.

f. Traffic / Roads Infrastructure

Study Findings

3.38 The location of the study area at the edge of the urban area meant that the ability of the proposed community to access employment, services and recreation opportunities in a sustainable manner would be a fundamental consideration for the feasibility study.

3.39 Most of the study area has below base accessibility to public transport, with less than one third of the Phase 1 site having base accessibility. Furthermore, as discussed in paragraph 3.32, access from the study area to a number of local facilities and services would involve long walking distances. A high reliance on private car transport is therefore anticipated. While the DRS Transport Policy response considers that the suggested improvements to junctions adjacent to the site would be sufficient to cope with the traffic generated by the development, the main concern related to the impact of additional peak time traffic on junctions further south in the Balmore Road/ Saracen Street corridor. It was further considered that the residential quality of the existing communities at Ruchill, Possilpark and Cowlairs, and the success of the regeneration projects proposed for them, would be likely to be affected by an increase in traffic at peak times as a result of the proposal.

3.40 The comments conclude therefore that development of the initial phases would be dependent on the inclusion of a new or diverted bus route into the site. It is acknowledged that the commercial viability of such a route would be challenging, given: (a) the expected higher car use profile of future residents, (b) the requirement for financial subsidy to support the service in the initial 3-5 years, and (c) the need for extensive physical infrastructure within the Phase 1 site. These improvements would therefore be required to be secured by legal agreement.

3.41 Information from the applicant indicates that the potential capacity of the entire study area would be around 1,200 houses, albeit that the TA does not model the impact of this scale of development.

Consultant Response

3.42 A Transport Assessment (TA) was submitted in support of the planning application, based on analysis relating to initial phases of up to 500 houses. The TA set out proposals to mitigate the impact of the development on the local transport network. These are summarised as follows:

 New roundabout at Blackhill Road / Balmore Road junction, giving potential to divert Balmore Road bus services along Blackhill Road;  Discussions with First Bus indicate that there is capacity within the 61 Bus timetable to accommodate additional services;  Alternatively, discussions with SPT and First Bus indicate a willingness to provide a new bus service with the assistance of subsidy;  Bus turning facility within development site;  Peak time shuttle service from development to Summerston Railway Station;  New or improved junctions off Blackhill Road;  Vehicle parking to GCC standards;  Potential car club provision – initial discussions with operators;  Safeguarded route for potential future connection to Acre Road;  Land for future park and ride facility east of Balmore Road – not part of current application and not funded by applicant.

3.43 The TA concludes that up to 150 houses could be constructed within the existing roads infrastructure, and that up to 500 houses could be accommodated with the completion of these interventions.

Further Comment from Transport Policy

3.44 A response to the planning application has been provided by the Transport Policy team in DRS, and has indicated the following:

1. The Transport Assessment was considered by Transport Policy using a national guideline. This is essentially a technical approach which assesses traffic counts at peak times, and considers their impact on junction capacities. It does not consider the circumstances of the site itself, the wider impacts of development on the transport network, or any placemaking impacts on adjacent communities of increased traffic.

2. The assessment has concluded that a development of up to 500 houses could technically be accommodated within the capacity of existing junctions, subject to the improvements in the transport infrastructure recommended. The reduction in peak traffic over recent years has contributed to the spare capacity in these junctions, and this has clearly benefited the amenity of adjacent residential communities and town centres.

3. The proposal for the subsidised provision of a re-routed bus service serving the first three phases within the site, has the potential to reduce car journeys, but would be vulnerable to reduced take up and removal by the bus company once the subsidy had been removed.

4. Concerns remain about the potential effects of increased traffic on the Maryhill Road and Balmore Road/Saracen Street corridors, and in particular on the placemaking objectives of the regeneration proposals in the Maryhill, Ruchill, Cowlairs and Hamiltonhill communities.

5. Additional housing in phases to the east of Blackhill Farm, in excess of the 500 houses indicated in the first three phases, is unlikely to be accommodated by the junction improvements proposed, and would not benefit from the proposed improved bus service, due to the distance from housing to the indicated route.

6. Transport Policy has concluded that development cannot be successfully accommodated in this location without impacting negatively on the ongoing regeneration of neighbouring communities which are in preferred locations. It would also run counter to the Council’s overall approach towards traffic restraint, particularly in the context of the climate and ecological emergency declared in May 2019. The Council has committed the city to being carbon neutral by 2030, and it is considered that this proposal would make the achievement of this objective less likely.

g. Improvements to Blackhill Road – Timing and Phasing

Study Findings

3.45 In order to accommodate the increase in traffic, Blackhill Road will require to be upgraded to distributor road standard, with associated junction improvements where Blackhill Road meets Balmore Road and Invershiel Road respectively. The Council would require to approve detailed proposals for these works, and early delivery would be essential for any residential development to take place.

3.46 The road upgrade would also require the removal of the established hedgerows along Blackhill Road, which is identified as a Green Corridor in the City Development Plan. This would require suitable assessment and mitigation.

Consultant Response

3.47 It is recognised in the Transport Assessment that these improvements are necessary to accommodate the development. Discussions with Glasgow City Council over phasing will be necessary at detailed proposal stage.

h. Education Capacity

Study Findings

3.48 Education Services provided comments on the planning application, which are relevant to the study. There are 6 schools potentially affected by any proposal within the study area based on current catchments.

Berkeley Street Gaelic Primary School St Mary’s Primary School Caldercuilt Primary School

Cleveden Secondary School Berkeley Street Secondary School John Paul Academy

3.49 The comments are qualified to the extent that the housing capacity of the area has not been established. The number, type and size of housing will give an indication of the number of children likely to require a school place, and are therefore important factors in determining the impact on local schools. Nevertheless, based on current school rolls and capacities, the following conclusions can be made:

Berkeley Street Gaelic Primary

3.50 The school is currently oversubscribed, and as such increasing the catchment area as a result of the development may increase pressure. However, due to the distance from the school to the development, and the likelihood of a more limited audience for Gaelic education, it may be that the impact on school capacity may be minimal.

St Mary’s Primary School

3.51 The capacity of the school is currently of concern. This is likely to be made more pressing by the development of new housing within the catchment.

Caldercuilt Primary School

3.52 There is spare capacity within this school. The ability of the school to absorb additional capacity will depend on the style and number of dwellings.

Cleveden Secondary School

3.53 The study area is at the north part of Cleveden’s catchment area, with the school located in the south. Current Council policy suggests that transport would be likely to be provided. The school has capacity.

Berkeley Street Gaelic Secondary

3.54 The distance between the school and the development, and the likelihood of a more limited audience for Gaelic education, suggests that the impact of the development on school capacity may be minimal.

John Paul Academy

3.55 The capacity of the school, which is the closest secondary school, is currently of concern. This is likely to be made more pressing by the development of new housing within the catchment.

3.56 In summary, the comments from Education Services indicate that (based on the initial phases of development of around 500 houses) the minimum impact on school provision would be to require extensions to the John Paul Academy Secondary School and St Mary’s and Caldercuilt Primary Schools. These extension have been costed at £5m for the secondary school and £2m for each primary school.

3.57 Development of the entire study area west of Balmore Road, as shown in the indicative masterplan, would require the construction of a new primary school within the area, at a cost of around £15m.

3.58 The City Development Plan does not require developer contributions in relation to education provision. In the light of the importance of ensuring that any new community should be able to access facilities locally, and therefore reduce its impact on local transport infrastructure, it is recommended that contributions to additional local provision generated by any development should be the subject of further discussions with the landowner/developer.

Consultant Response

3.59 Subject to the provision of detailed pupil roll projections, the applicant has indicated a willingness to contribute to investment in additions to school capacity that arise as a result of any development.

i. Placemaking

Study Findings

3.60 Any proposal is required to apply the Placemaking Design Process set out in City Development Plan Supplementary Guidance SG1. As the purpose of the study is to consider whether there is potential for housing development in this location, it is recognised that the appropriate approach would be to assess the study area within those elements of the Placemaking Design Process up to the detailed design stage. The key elements of the Design Process to follow are therefore:

1. Site and Context Appraisal; 2. Urban Design Strategy; and 3. Design Concept

Consultant Response

3.61 A Design/Access Statement has been submitted as part of the planning application. Although it is acknowledged that the study should focus on broad principles, and that these issues, will be addressed at a more detailed design stage, the following specific proposals are identified to contribute to placemaking objectives and the provision of accessible open space:

 “A green corridor between Blackhill Road and proposed areas of open space leading to the River Kelvin;  Extensive areas of structured planting and open space within the eastern part of the site to connect with the adjacent Lambhill Cemetery; and  Understory planting along the existing substantial hedgerows and adjacent to the proposed structural woodland to provide enhanced networks.

3.62 The proposal will also incorporate play areas, informal and formal sports areas, in compliance with City Development Plan Guidance IPG 12, as well as footpath networks to allow connections in and around the site.

3.63 The design, alignment and character of the streets and road layout will directly contribute to placemaking, as well as fulfilling a traffic calming role. The principles of Designing Streets, as interpreted in the GCC Residential Design Guide, will be fully embraced.

j. Impact of Landfill Site – Landfill Gas Migration and Leachate Pollution

Study Findings

3.64 The Design and Access Statement notes that development would be set back from the landfill site. GCC Environmental Health has been consulted on the planning application, and has responded that no housing should be located adjacent to the boundary of the landfill site.

Consultant Response

3.65 The indicative masterplan shows a linear open space along the boundary of the landfill site, which would have the effect of setting back any housing from this facility. This could be conditioned in any planning permission.

k. Luddon Construction Site – Potential Inclusion in Development Area

Study Findings

3.66 Representatives from Luddon Construction were invited to participate in the feasibility study group, and attended a number of meetings to discuss whether there was potential to include their site within any proposal. The company also sought to protect their continued operation should the development not include the site. The indicative masterplan contained within the PPP application does not include the Luddon Construction site within the red line boundary, which indicates that discussion on this matter concluded with agreement that the development area would not include the Luddon site.

Consultant Response

3.67 Luddon Construction has submitted a representation to the planning application, and although the company does not object to the proposal, an appropriate setback from their operation is sought. The masterplan indicates such a setback, and it is considered that this could be accommodated within a detailed proposal. The Luddon Construction site would therefore remain in the green belt.

4. DETAILED CONCLUSIONS

4.1 The purpose of the feasibility was to determine whether there was potential for additional housing land in the Summerston area, and if so, the extent of that potential. The study would take into account a number of matters, including hydrology, infrastructure and environment. These conclusions will draw on information gained by the feasibility study group, and that provided on behalf of the landowner and by public agencies and other interested parties.

4.2 The conclusions will aim to distinguish between matters which are fundamental to the acceptability in principle to housing development in this locations, and matters of detail which could be considered in a detailed proposal, should the principle be acceptable. The conclusions will therefore be grouped as follows:

(a) The principle of development in the area north of Summerston, and (b) Detailed matters for further consideration.

(a) The Principle of Development in the Area North of Summerston

Housing Land Supply

4.3 Strategic Development Plan Policy 8 states that where a shortfall in housing land supply is identified, a sustainable location assessment is engaged to consider housing proposals. Assessment of the supply position in 2019 against the Housing Supply Targets set out in the approved 2017 Strategic Development Plan indicates that there is a surplus in housing land supply for the period 2012-24. As there is not a housing land shortfall at present, the sustainable location assessment is not engaged.

4.4 For the purposes of the feasibility study, Strategic Development Plan and City Development Plan objectives of protecting the green belt, maintaining a compact city form through development in sustainable locations, and giving preference to brownfield sites required further assessment. The study’s conclusions on these matters are set out in detail below.

Landscape and Visual Impact

4.5 Given the sensitivity of this location, the potential impact of development on the landscape in this location is one of the fundamental matters for consideration in the study. Scottish Natural Heritage initially expressed strong reservations about proposals for housing in this area, and had concluded that, with the exception of a relatively small area in the western part of the study area, development would be likely to result in a significant change in the landscape quality, particularly as experienced from key views. The area identified as being capable of accommodating development is in the same area as the potential first three phases of housing identified in the application for Planning Permission in Principle, but does not extend as far to the east to reach Blackhill Farm.

4.6 As the study developed, the applicant continued to provide more detailed proposals on how any development would be accommodated within the landscape. These included an extensive landscape framework, setting back any development from important visual receptors, provision of open spaces, and measures to retain and enhance existing features which would contribute to biodiversity.

4.7 It is recognised in the planning application that impacts on landscape quality will be significant, but it is stated that these impacts will be in the early years of development and operation of the site, and that they will reduce as the effect of mitigation measures takes place. SNH considered that these measures had the potential to contain and frame views to and from the site

4.8 It is considered that development in this area will inevitably change the quality of the landscape, from one that is essentially rural to one with a more urban feel. The mitigation measures proposed have the potential to soften this change, but not remove it completely. Nevertheless, SNH concludes that, subject to the applicant committing to the objectives set out in the Landscape Framework document, and to ensuring that the open spaces and mitigation measures are delivered, development is capable of being accommodated within the landscape with a visual impact that will become acceptable over time.

Hydrology

4.9 SNH has maintained a holding objection to the planning application, subject to the provision of further information on the potential implications of development for Possil Loch SSSI. These concerns relate to the extent to which there may be hydrological connectivity between the development area and the SSSI, and the potential for surface water run off to affect this feature. SNH notes that development areas are set back from the SSSI, and it may be concluded that these concerns may be addressed by the provision of further information, and the design of surface water drainage systems.

Traffic / Roads Infrastructure

4.10 In the absence of proposals to add new roads infrastructure to the area, specifically in the form of the Northern Circumferential Route, new housing in this location would result in an increase in car journeys using the existing road network. The extent of any increase would depend on the capacity of the proposed development. Information provided in the Transport Assessment measures the traffic impact of a development of around 500 houses in the initial phases.

4.11 Development of up to 500 houses in three phases could technically be accommodated within the capacity of existing road junctions, subject to suggested improvements, as a result of the reductions in peak time traffic in recent years. The impact of this scale of development on traffic movement beyond immediate junctions, and on the quality of place of neighbouring communities, which have benefited from reduced traffic, is not included within this technical assessment.

4.12 Proposals for a subsidised bus route into the first three phases of development has the potential to influence travel choices towards public transport solutions. But these changes may be unlikely to persist if the service is removed once the subsidy period ends. Evidence from previous greenfield releases indicates that the bus operator has reduced or withdrawn services as patronage has declined, thereby increasing car dependence.

4.13 Future phases of development are unlikely to be supported by junction capacity, or by the proposed improvements to the bus services due to the distance between housing areas and the bus route.

4.14 Transport Policy has concluded that, as a result of the likely traffic increases, it would not be appropriate to develop additional housing in this location. This is particularly the case in the context of the climate emergency, the lack of certainty regarding long-term alternative public transport options, and the impact of increased traffic on the ongoing regeneration of adjacent communities in preferred locations. The proposal would also not contribute towards the Council commitment of Glasgow being carbon neutral by 2030.

Sustainability of Location for Facilities/Services

4.15 GIS analysis by Development and Regeneration Services indicates that access from the study area to facilities and services would involve longer walking distances than would be preferable. This could lead to an increase in car journeys, although improvements to walking and cycling routes would mitigate this.

4.16 The inclusion of a neighbourhood centre, where some facilities could be located, would improve the sustainability of the location. This would in all likelihood require a substantial scale of development to make the development of the centre viable.

(a) Detailed Matters for Further Consideration

Biodiversity/ Green Network

4.17 The study area provides habitat for a variety of wildlife, some of which would be lost as a result of any development. Information from the planning application states that habitat loss is not of high quality, that alternative locations for wildlife habitats are available nearby, and that opportunities for biodiversity will be created within the retained and new open spaces and green networks. The objection from GCC Neighbourhoods and Sustainability indicates that there would be a net loss of habitat, and that this would not be compensated for by the proposals. In addition, the loss of rural open space would not be appropriate in the context of the climate emergency.

4.18 It will be important to ensure that any proposals for development maximise opportunities for the retention of existing habitats, and the creation of new ones that are reflective of those that exist. Connecting the development into existing green infrastructure through the creation of high quality open spaces will allow habitat networks to develop, and will provide opportunities for recreation within the site, and in the wider countryside.

4.19 The Landscape Framework sets out a series of principles and objectives which, if fulfilled, would provide appropriate assurance that the green network and existing habitats would be supported and enhanced.

Education Capacity

4.20 There are two primary schools and one secondary school which are accessible from the study area, albeit that accessibility improvements would be beneficial. Capacity issues exist at one of the primary schools and at the secondary school, and it is recommended that investment in capacity would be required to address likely needs from the first phases of development of up to 500 houses. Development of the entire study area is likely to require more significant investment in capacity, specifically the construction of a new primary school.

4.21 Should the principle of development by established, early discussions with the developer on investment in education capacity should be initiated. The applicant has indicated a willingness to contribute to investment in additional school capacity that arises as a result of any development.

Antonine Wall

4.22 The study area does not overlap with the designated area of the Antonine Wall, but does fall within the buffer zone for the Antonine Wall, which would suggest that any impacts would be on the setting of the Wall, rather than the Wall itself. The Environmental Impact Assessment indicates that the impact of the development on the setting of the Antonine Wall would be likely to be minor to moderate, and would diminish over time through mitigation. It is considered that the detail of any proposals would be critical to ensure that the setting of the Antonine Wall is preserved.

Impact on Luddon Construction Site

4.23 It has been agreed that the Luddon Construction site will not be part of any proposal going forward. The need for an appropriate setback between any development and this site is indicated in the masterplan submitted with the planning application, and the detail of this provision can be secured by an appropriate condition on any permission.

Flooding and Drainage

4.24 The revised Flood Risk Assessment submitted in May 2020 concludes that risks from flooding and surface water runoff can be reduced to acceptable levels by:

a. the specification of appropriate Finished Floor Levels in areas of flood risk; b. other design measures, such as directing water flows from buildings and infrastructure to landscaping areas and drainage systems; and c. the incorporation of appropriate features to attenuate and drain surface water, including Sustainable urban Drainage System (SuDS).

4.25 These conclusions are subject to the agreement of the Council regarding the appropriate level of uplift in requirements as a result of the impact of climate change. It is considered that these could be addressed at a detailed proposal stage.

Improvements to Blackhill Road – Phasing and Timing

4.26 The upgrading of Blackhill Road to distributor road standard, and the associated junction improvements requires early delivery. This would require a legal agreement linked to a detailed planning application.

Impact of Landfill Site on Study Area – Landfill Gas Migration and Leachate Pollution

4.27 GCC Environmental Health notes the inclusion of a setback from the landfill site, and concludes that no housing should be located on the boundary with the landfill site. The inclusion of a linear open space between any housing and the landfill site appears to secure this, and should be appropriately conditioned.

4.28 More detailed requirements relating to landfill gas and leachate pollution would be a matter for a detailed planning application.

5. OVERALL CONCLUSION

5.1 The purpose of this study was to consider the potential for additional housing in this location, and, if there were potential, to indicate the scale of development that might be appropriate. The focus of these conclusions is on matters of significant principle, i.e. those affecting whether development should be permitted or not.

5.2 The submission of an application for planning permission in principle has provided a considerable amount of detail which has been of great benefit to the study. The expert work of the study group is also acknowledged by the Council. Overall, the scope of the study has been successfully fulfilled.

5.3 In housing land terms, the supply position has changed significantly from the shortfall position which existed at the time the need for the study was identified, to the extent that there is now a surplus of housing land supply in Glasgow, and in the Housing Sub Market Area in which the study area lies. The requirement for additional housing in this location is therefore not established at this point in time. As a result, the sustainable location assessment included in Policy 8 of the approved Strategic Development Plan is not engaged.

5.5 There is no housing land justification to depart from the broad objectives in Scottish Planning Policy, the Strategic Development Plan and the City Development Plan relating to protection of the green belt, and maintaining a compact city form through a preference for brownfield land. It is concluded that Glasgow’s needs can be accommodated by the delivery of housing in more sustainable locations, and deliver more housing choice through the Community Growth Area programme

5.6 In relation to the sustainability of this location, two issues have emerged from the study as fundamental to the consideration of whether housing development should be supported:

(1) Landscape, Visual Impact and Hydrology

5.7 It is self-evident that development on sensitive land within the greenbelt would have an impact on the landscape, and that ‘no impact’ would be preferable to a ‘mitigated impact’. That said, it can be concluded overall that, as a result of: the considerable measures to mitigate the visual impact of development from key views, proposals to protect and enhance biodiversity, and the inclusion of significant open space provision within a robust landscape framework, new housing could be successfully accommodated across the study area within the landscape with a visual impact which will be acceptable over time. This conclusion is subject to more detailed information to be provided by the applicant that, in terms of hydrological connectivity or surface water runoff, development will not impact negatively on Possil Loch SSSI.

(2) Traffic and Transport,

5.8 Technical consideration of the Transport Assessment concludes that a maximum of 500 houses could be accommodated in three phases by an improved transport infrastructure. It is also stated that the successful development of this housing area would be assisted by the provision of a re- routed bus service, with subsidy in the early years. It is considered, however, that the long term viability of an unsubsidised service is unlikely to be sustained by a development of this scale. The relatively poor accessibility to facilities and services is likely to lead to an increase in car journeys, and would not contribute to the attractiveness of public transport alternatives.

5.9 The wider impacts of development through increased traffic on the road network, particularly in the Maryhill Road and Balmore Road/Saracen Street corridors, has the potential to reverse the benefits that these communities have felt recently, and would not contribute in placemaking terms to the ongoing regeneration of these locations which are preferred in policy terms. In the context of the climate emergency, this would appear to send a conflicting message to that supported by the Council.

5.10 On balance, the conclusion of the study is that the limitations of the location in relation to accessible transport infrastructure have not been successfully overcome by the proposal. It is anticipated that development in this location would contribute to unsustainable travel patterns.

5.11 When considered in the context of a surplus in housing land supply, the climate and ecological emergency and the move towards a carbon neutral city, it is concluded that additional housing should not be supported, and that the study area’s green belt designation should be retained.

References

1. Adopted City Development Plan https://www.glasgow.gov.uk/cdp

2. Application for Planning Permission in Principle – 19/03776/PPP https://www.glasgow.gov.uk/onlineplanning