Issue 4 Arrochar and Succoth Development plan reference: Section 3 Place, Arrochar and Succoth pp.51-54 Reporter: Body or person(s) submitting a representation raising the issue (including reference number): Arrochar and Tarbet Community Council (37) Sportscotland (188) Vivienne MacTavish (646) Fiona Jackson (655) Cherry MacTavish and Peter McFarland (658) Nick Kempe (662) Iain Dick (702) Scottish Natural Heritage (712) Provision of the development plan to which the issue relates: Park Authority s summary of the representation(s): Arrochar & Succoth - General Arrochar & Succoth - General MU1 Land next to Three Villages Hall p.53 MU2 Succoth p.54 ED1 Church Road p.52 H1 Cobblers Rest p.51 H2 Succoth p.52 H3 Church Road p.54 VE1 Ben Arthur p.54 TR1 Arrochar Pier p.51 Camping Provision pp.51 Ask what is the development of Arrochar over the next 20 years based upon, given the Torpedo Range site has been derelict for 27 years along with 4 other sites. Arrochar should include toilet and shower facilities for hill walkers. Two local businesses have closed recently. No help to encourage new businesses or established ones to survive. Expresses concern that the amount of housing outweighs development for employment. Require better wording to make areas of flood risk exempt from zoning. Major problem in Arrochar is rubbish washed up at the head of the loch onto the car park areas. MU1 Land next to Three Villages Hall Recommend more housing and small employment opportunities. There is also concern over the protection of trees and seeking the land behind the village hall for outdoor recreation.
Sportscotland (188) From aerial imagery, this site appears to include an outdoor sport facility. Request reference is made to presence of this outdoor sports facility on site. Sportscotland wishes a reference to Scottish Planning Policy (CD1, p.51, para.226) to ensure outdoor sports facilities are taken into consideration by the developer. Fiona Jackson (655) Supports the proposed allocation as it will maximize the cultural heritage and recreational tourism markets for social benefit. The proposed uses will complement the adjacent Hotel and create a much needed community civic space with views to Ben Arthur and the loch. MU2 Succoth With the exception of the land running towards Stronafyne Farm, the site is a flood plain, and if developed would require extensive land fill operations, so should be designated for open space. Vivienne MacTavish (646) Expresses concern that the site would not be suitable for large scale development, but no objection to low key development i.e. picnic tables or a small play area. Development should be on brownfield sites not this green area which is marshland and home to wild species, and the gateway to the Glenloin walking route. Fiona Jackson (655) Welcome this space set aside for community use. The site could not accommodate large buildings that would affect views down the loch (inappropriate for visitor experience use) and negatively affect the aesthetics of the natural environment and openness. The land floods intermittently and is very marshy but could accommodate community recreation area if raised. Cherry MacTavish and Peter McFarland (658) The natural landscape and wildlife could be affected by this allocation. Iain Dick (702) The site lies within the tidal flood plain (SDR31 Flood photographs) associated with the River Loin and its tributaries. This is contrary to one of the guiding principles of the plan to avoid development in flood risk areas. The area is not suitable for development except open space. Even if the site was reduced in size there is limited opportunity for vehicular access from Glen Loin Crescent. ED1 Church Road This site should be removed and a new economic development site should be allocated on the land opposite the Cadet Centre, as indicated on a map (CD42) to
create a more joined up community through utilising the open land between the two villages. The alternative site has better access to the A83 Trunk Road for easy transport to industrial units. This site will impact on the siting of the village mountain rescue, helipad, fire and ambulance stations. Sportscotland (188) From aerial imagery, this site appears to include an outdoor sport facility. Request reference is made to presence of this outdoor sports facility on site. Sportscotland wishes a reference to Scottish Planning Policy (CD1, p.51, para.226) to ensure outdoor sports facilities are taken into consideration by the developer. Scottish Natural Heritage (712) Highlight that the mitigation highlighted within the Strategic Environmental Assessment should be included in the Plan. Environmental Report states that the topography is an important consideration on this site. The higher part of the site is visually prominent and not suitable for development so a landscape assessment icon should be added. A minor watercourse culverted in sections runs through the site. There is a record of flooding attributed to the culvert under Church Road. These represent a potential risk of flooding. A basic Flood Risk Assessment will be required. H1 Cobblers Rest A minor watercourse culverted in sections runs through this site and is a potential risk of flooding. A basic Flood Risk Assessment will be required either prior to, or in conjunction with any planning application. Adjacent to coastal flood extent so recommended that cognisance is taken on 4.47mOD Coastal Flood Boundary level. This will need to define the areas at risk of flooding, the relative vulnerability of the proposed use and confirm design layout and levels. H2 Succoth Social housing is welcomed. Access, cost viability and amenities should be taken into consideration when earmarking sites for housing. The villages need to be more compact rather than the creation of stretched out ribbon community. H3 Church Road This site should be removed and a new housing site should be allocated on the land opposite the Cadet Centre (CD42) to create a more joined up community through utilising the open land between the two villages. The alternative site has better access to the A83 Trunk Road for tenants.
A minor watercourse culverted in sections runs through the site and this represents a potential risk of flooding. A basic Flood Risk Assessment will be required in conjunction with any planning application. VE1 Ben Arthur The responder expresses concern over the unsightly appearance of the undeveloped allocated sites that are at strategic entrances. If the current planning permission expires then renewal should be questioned given the site has not been developed and been kept untidy. High concern over asbestos contamination on site due to former MoD buildings demolished. A Flood Risk Assessment will be required to define the areas at risk of flooding, the relative vulnerability of the proposed use and confirm design layout and levels. Approximate Coastal Flood Boundary level is 4.47mOD. TR1 Arrochar Pier Support the pier proposal as it will be very welcomed and a valued asset to the village. There are operational/locational reasons for this proposal being within the coastal flood extent. It is recommended that cognisance is taken on 4.47mOD Coastal Flood Boundary level. Arrochar & Succoth - Camping provision Nick Kempe (662) The responder highlights that there is limited camping or touring caravans/motor homes facilities at Glen Loin campsite. Campervans use the parking area at the head of the loch. There is a lack of camping provision around Loch Long. Modifications sought by those submitting representations: Arrochar & Succoth - General Assume Community Council asking for clarification on why p18 of the Plan refers to development in Arrochar taking place over the next 20 years. Asking for the Plan to support initiatives for new businesses and encourage instalment of public toilets and shower facilities for Arrochar. Clarification over the amount of housing which outweighs development for employment. Assume Arrochar & Tarbet Community Council asking for: a) better wording to avoid areas of flood risk, and b) place marking to highlight problem of waste washed up
from sea lochs to help feasibility studies and clean up initiatives. MU1 Land next to 3 Villages Hall Assume reference or allocation to include housing provision and wording added in relation to retention of outdoor recreation space. Sportscotland (188) Request reference is made to the presence of the outdoor sports facility on site and to Scottish Planning Policy (CD1, p.51, para.226). MU2 Succoth ; Vivienne MacTavish (646); Iain Dick (702) The site should be allocated as a flood plain / open space. Fiona Jackson (655) Change the allocation to community recreation area. Cherry MacTavish and Peter McFarland (658) Site to be removed. ED1 Church Road The site should be replaced by an alternative site as mapped (CD42) located on the land opposite the Cadet Centre between Tarbet and Arrochar. Sportscotland (188) Request reference is made to the presence of the outdoor sports facility on site and to Scottish Planning Policy (CD1, p.51, para.226). Scottish Natural Heritage (712) Landscape Assessment icon to be added to site map Assume that they wish the flood risk icon to be added to the allocated site map. H1 Cobblers Rest and VE1 Ben Arthur Assume wish site developed and eyesore removed. Assume consideration of onsite asbestos is sought.
Assume that they wish the flood risk icon to be added to the allocated site map. H2 Succoth No modification specified. H3 Church Road The site should be removed and an alternative site located on the land opposite the Cadet Centre (between Tarbet and Arrochar) as mapped (CD42). Assume that they wish the flood risk icon to be added to the allocated site map. VE1 Ben Arthur Assume want land contamination icon added to site map. Scottish Environment Protection Agency (0713) Assume that they wish the flood risk icon to be added to the allocated site map. TR1 Arrochar Pier No modifications sought. Assume that they wish the flood risk icon to be added to the allocated site map. Camping provision Nick Kempe (662) Sites should be allocated for camping provision around Loch Long. Summary of responses (including reasons) by Park Authority: Arrochar & Succoth - General The 20 year period on p.18 of the Plan relates to the time period which the Plan has to cover as set out in Scottish Government Development Planning Circular 6/2013
(CD6, p.20, Table 1). Table 1 states that: Ministers expect that Local Development Plans should provide a broad indication of the scale and location of growth up to year 20. Ministers expect Local Development Plans to focus on their specific main proposals for the period up to year 10 from adoption. In terms of the delivery of the sites that have not been developed, the plan seeks to bring a focus on these by continuing to identify them and introduce greater flexibility in the policies or requirements that would apply where possible. In terms of support for toilet and shower facilities in Arrochar, this is not the purpose of the Plan although overall strategy for the area is to improve the area for visitors and its community. In terms of support for business the Plan identifies three sites in Arrochar which support future businesses being created ED1 Church Road, MU1 Land next to Three Villages Hall and MU2 Succoth. There will also be employment opportunities at VE1 Ben Arthur through tourism use. In addition, section 4 of the Plan offers support for established and proposed business through Economic Development policies on p97 of the Plan. Economic Development departments in Argyll and Bute Council should be contacted for advice for the creation of new businesses and support for established businesses in Arrochar and Succoth. The housing proposed is over a 10 year period and would complement these economic development sites. No modification proposed. Delivering our Strategy section within the Plan p.23 states: 'avoiding development in flood risk areas'. In addition, allocated sites within Section 3 in the Plan where there is a risk of flooding, such sites will have an icon showing a water droplet. The meaning is explained on p.122 of the Plan in Appendix 4 Site Map Icons Explained and asks developers to submit a flood risk assessment at the planning application stage to ensure development is acceptable, and if so, sufficient mitigation is provided. For non-allocated sites, development proposed in flood risk areas will be assessed against; a) Plan policies Overarching Policy 1 All development should contribute to the National Park being: A natural, resilient place by: avoiding significant flood risk, and b) Natural Environment Policy 13: Flood Risk (p.104). In terms of waste, planning has a responsibility to support the sustainable management of waste and has done so in the Plan through policies and identification of strategic recycling locations throughout the Park. However, in terms of place marking areas adjacent to sea lochs, it is not the purpose of the Plan to highlight such. Respective local authorities have the responsibility in relation to waste management and it is for their departments to effectively address this matter. No modification proposed. MU1 Land next to Three Villages Hall ; Sportscotland (188) This site is important to the redevelopment of a central focus for Arrochar and is currently allocated as a mixed use site within the Adopted Local Plan, site Allocation ST2 & CU1, Arrochar (CD29, pp.97-98). It contains a derelict football pitch which is overgrown and has not been used for formal sport for some time. The pre Main Issues Report engagement with the landowner and the community reconsidered the potential options for this land which concluded on a mixed use development that capitalised on the central location, views and accessibility to the Loch as well as the Three Villages Hall. This is summarised as a Key Initiative in the Local Development Plan Charrette Report, Part 2 (CD40, pp.101-105). It is envisaged there will be an element of public space and cultural heritage as part of
the community use and visitor experience. In relation to the derelict football pitch, it is recognised that Scottish Planning Policy (CD1, p.51, para.226) states that where an outdoor sports facility would be lost (even an unused facility) that it would be replaced either by a new facility of comparable or greater benefit for sport in a location that is convenient for users or by upgrading an existing outdoor sports facility. The Scottish Planning Policy also states that if a relevant strategy and consultation with Sportscotland shows a clear excess in provision to meet current and anticipated demand then the loss of the facility is accepted. Any proposal would need to be assessed against Open Space Policy 1 of the Proposed Plan which meets the requirements of Scottish Planning Policy. The Community Council wish a small area of the site to be retained for outdoor recreation. The need to include public space and/or green space on this site is stated on the Placemaking Priority PP description on p.51, with this expected to be a village centre place potentially along with green space on the slope behind the Three Villages Hall but this detail is more appropriate for the planning application process. The annotation on p.53 for MU1 states that the community and visitor facility will be supported by retail and housing so an element of housing will be supported. No modification proposed. MU2 Succoth ; Vivienne MacTavish (646); Fiona Jackson (655); Cherry MacTavish and Peter McFarland (658); Iain Dick (702) The site is within a natural flood plain and identified in the 1 in 200 year on Scottish Environment Protection Agency s indicative flood maps. The photographs submitted (SDR31) illustrate a recent flood event. There are two distinct areas, the area to the east of Loin Water which is slightly higher ground to the east of the access road leading to Stronafyne Farm and the area to the west of Loin Water which has a tributary to Loin Water and is a low lying area with reeds and is known to flood. We requested additional comments from Scottish Environment Protection Agency and Argyll and Bute Council as Flood Authority about the known flooding on the site. Both confirmed that even though the site has known flooding there is potential for development (CD48 Further comments). The site map icons indicate that a Flood Risk Assessment would be required to be submitted with any application relating to the site. The assessment at the application stage would identify the areas that have potential for development and those that are not suitable due to flooding. In terms of the allocation, the site is currently allocated for community and recreational uses in the Adopted Local Plan (CD29, pp97-98, site allocation ST3 & CU2 Succoth). The adopted Local Plan contained a list of potential uses and this confirmed that large scale tourism development was not envisaged for the site. In changing to the new style of Plan this site was allocated for visitor experience (which now covers recreation and tourism uses) and community use. The list of the potential uses is also not included in this Plan. However, the move to the concise map-based approach presents the sites in an accessible way as per Planning Circular 6/2013, (CD6, p.19, para.79). In order to present an accessible style map-based approach the Plan cannot include the same level of detail on the potential uses in a table format. However in order to address this issue there is an opportunity to clarify the potential acceptable uses of this site by annotating the map similar to Tyndrum MU1,
p.89. At the planning application stage a flood risk assessment would be required and this would identify flood areas that would be unsuitable for buildings or certain uses but may be suitable for passive recreation (paths, picnic facilities) and enhancement work to remove the invasive species, litter and plant native species, create wetland areas. Minor modification to add/amend: a) Change Mixed Use Community & Visitor Experience to include Open Space on the site map. b) Annotate the site map for MU2. This would include the following annotation: Low intensity development Retain element of open space for local and visitors to use for passive recreation (on the lower area of the site) Biodiversity enhancement Community uses Careful consideration of flood risk and access into eastern part of site ED1 Church Road The alternative site (CD42, Land opposite the Cadet Centre) is not considered a suitable site due to landscape sensitivities and being too distant from Arrochar and Tarbet centres and facilities. The proposed site is already allocated in the Adopted Local Plan, (CD29, p.97, ED1 Arrochar and Schedule 2, p.29) which contains the mountain rescue and fire station which are compatible with industrial and business uses. The access to the A83 Trunk Road is nearby and there is no impact on residential areas. No modification proposed. Sportscotland (188) The site contains an informal kick about area with goal posts. Scottish Planning Policy (CD1, p.51, para. 226) states that if a relevant strategy and consultation with Sportscotland shows a clear excess in provision to meet current and anticipated demand then the loss of the facility is accepted. As with MU2 above, any proposal would need to be assessed against Open Space Policy 1 of the Proposed Plan which meets the requirements of Scottish Planning Policy. Minor modification proposed to add some additional text to site map for Arrochar ED1 p52 to state outdoor sports facility present on site and it must be demonstrated at the planning application stage that the proposal complies with Open Space Policy 1. Scottish Natural Heritage (712) It is recommended that a landscape assessment icon is included on the site map given this issue was highlighted in the Strategic Environmental Assessment. This was responded to by restricting the site area to the break of slope and it is not therefore considered necessary to include a landscape assessment icon. No modification proposed. The comments regarding flood risk are noted and a flood risk assessment should be
submitted with any planning application. Minor modification to add a flood risk assessment icon to site map for Arrochar ED1. H1 Cobblers Rest Minor modification to add the flood risk assessment icon to proposals map for Arrochar H1, p.52. H3 Church Road The Community Council s comments suggest allocating the land across from the Cadet Centre but this alternative site is not considered a suitable site due to landscape sensitivities and being too distant from Arrochar and Tarbet centres and facilities. This wasn t an opportunity that was proposed during the Plan preparation nor has the landowner highlighted it. The housing site is immediately adjacent to an existing housing area with easy access into the centre of the village. It is also near facilities such as the church and local play park. No modifications proposed. Minor modification to add the flood risk assessment icon to site map for Arrochar H3, p.54. VE1 Ben Arthur Minor modification to add land contamination icon on site map for Arrochar VE1, p.54. Minor modification to add a Flood Risk Assessment icon to site map for Arrochar VE1, p.54. TR1 Arrochar Pier The comments regarding flood risk are noted and a flood risk assessment should be submitted with any planning application. Minor modification to: a) Add an individual site map for TR1 Arrochar Pier in the Arrochar & Succoth section p.53 b) Add the flood risk assessment, landscape context, access icons to this new site map. Camping provision Nick Kempe (662)
There are a number of sites allocated which could include visitor experience development, including MU2 and MU1 that could make provision for caravans or motorhomes and also a campsite. The Plan s Visitor Experience Policy 1 supports tourism sites within safe walking distance of a town or village so camping proposals could be supported on suitable sites surrounding Arrochar and Succoth. No modification proposed. Reporter s conclusions: Reporter s recommendations: