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Agenda Document Pack - Council - 27/11/2024

North Lanarkshire Council · 27 November 2024
Back to Council — 27 November 2024 and its agenda

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18 November 2024 
Members of the 
Council
Chief Executive’s Office
Archie Aitken
Chief Officer (Legal & Democratic)
Civic Centre, Windmillhill Street,
Motherwell ML1 1AB
www.northlanarkshire.gov.uk 
Notice is given that a Special Meeting of the Council is to be held in the Council Chamber,
Civic Centre, Windmillhill Street, Motherwell, ML1 1AB on Wednesday, 27 November 2024
at 10:30 AM which you are requested to attend. 
The agenda of business is attached. 
Archie Aitken
Chief Officer (Legal & Democratic) 
Members : 
Clerk Name: Mark Hamill
Clerk Telephone: 07811294702
Clerk Email: hamillm@northlan.gov.uk 
D Ashraf, A Ballinger, C Barclay, B Baudo, A Beveridge, M Boyd, H Brannan-McVey, G
Brennan, B Burgess, A Bustard, J Cairns, A Campbell, T Carragher, C Costello, M Coyle, S
Coyle, D Crichton, G Currie, P Di Mascio, K Docherty, K Duffy, A Duffy-Lawson, H Dunbar,
T Fisher, F Fotheringham, W Goldie, H Gray, K Harmon, M Hughes, J Hume, L Jarvie, D
Johnston, T Johnston, J Jones, P Kelly, J Keltie, A Khan, K Larson, J Leckie, G Lennon, J
Logue, H Loughran, F MacGregor, A Masterton, M McBride, B McCluskey, A McCrory, B
McCulloch, M McCulloch, P McDade, F McKay, R McKendrick, J McLaren, C McManus, M
McPake, J McPhilemy, A McVey, L Mitchell, L Nolan, P Patton, C Quigley, J Reddin, L
Roarty, D Robb, G Robinson, N Shevlin, W Shields, A Smith, A Stubbs, L Stubbs, R
Sullivan, A Thomas, J Toner, S Watson, C Williams, N Wilson, G Woods.  
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Agenda 
1 Declarations of Interest In Terms of the Ethical Standards
In Public Life Etc. (Scotland) Act 2000   
2 Planning Application 21/01414/PPP - Proposed
Residential-Led Development Including Roads,  Access,
Landscaping, Open Space, Suds and Associated 
Development - Land at Dullatur Golf Club, Constarry
Road, Croy, Cumbernauld
Submit report by Chief Officer (Place) on an application for
planning permission by Hallam Land Management Ltd &
Dullatur Golf Club. 
5 - 72 
3 Finance Update
Submit report by Chief Officer (Finance) providing an update
on the potential impact of the UK Government Autumn
Statement. 
73 - 82 
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Application No:  
21/01414/PPP
Proposed Development: 
Proposed Residential-Led Development Including Roads,
Access, Landscaping, Open Space, Suds and Associated
Development  
Site Address: 
Land At Dullatur Golf Club
Constarry Road
Croy
Cumbernauld 
Date Registered: 
8th October 2021 
Applicant:
Hallam Land Management Ltd & Dullatur Golf
Club  
c/o 16 Gordon Street
Glasgow
G1 3PT 
Agent:
Stantec
5th Floor
9 George Square
Glasgow
G2 1DY 
Application Level:
Major Application 
Contrary to Development Plan:
Yes
Ward:   
02 Cumbernauld North 
Danish Ashraf, Tom Fisher, Alan Masterton,
Gordon Currie,
Representations:
294 Total (211 objecting and 83 in
support).
197 within the statutory time period
(188 objecting and 9 in support)
including objections from Gillian
McKay MSP, Stuart McDonald MP
and Jamie Hepburn MSP.
97 late representations received (23
objecting and 74 in support). 
,  
Recommendation: Refuse 
Reasoned Justification: 
The proposal is contrary to policies within National Planning Framework 4 and the North
Lanarkshire Local Development Plan 2022 and would represent a significant departure
from the development plan and its spatial strategy. There are no material planning
considerations at this time that would justify the release of this green belt site for
residential purposes. 
Item 2
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Reproduced by permission of
the Ordnance Survey on behalf
of HMSO. © Crown Copyright
and database right 2009.  All
rights reserved. Ordnance
Survey Licence number
100023396.
Planning Application: 21/01414/PPP 
Applicants: Hallam Land Management Ltd
& Dullatur Golf Club 
Site Address: Land At Dullatur Golf Club,
Constarry Road, Croy, Cumbernauld
Development: Proposed Residential Led
Development Including Roads, Access,
Landscaping, Open Space, Suds And
Associated Development   
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Recommendation: Refuse for the Following Reasons:- 
1. The proposed development is contrary to Policy 8 Green Belts within National Planning
Framework 4 (NPF4), and Placemaking Policy 4 - Green Belt, PP 4 Purpose of Place and AD4
Amount of Development within the North Lanarkshire Local Development Plan 2022 (LDP) as
the development would result in the unacceptable impact of the loss of a valuable area of
green belt which strongly contributes to defining the settlements of Cumbernauld and Croy and
contributes to the landscape character and outdoor recreational space of that area. No
adequate justification, special circumstance or material considerations have been
demonstrated to merit a departure from the development plan.  Furthermore, the proposal is
considered to undermine or be at odds with the aims of NPF4 Policy 1 Tacking the Climate
and Nature Crisis, Policy 2 Climate Mitigation and Adaption and Policy 6 Forestry Woodland
and Trees   
2. The proposed development is contrary to National Planning Framework 4 (NPF4), Policy 9,
Brownfield, Vacant and Derelict Land and Empty Buildings, which advises Local Development
Plans to encourage, promote and facilitate reuse of such land and buildings and identify such
opportunities. Policy 9b) advises proposals on greenfield sites will not be supported unless the
site has been allocated for development or the proposal is explicitly supported by the Local
Development Plan. Neither applies in this case so the development should not be supported.
In addition, the proposed development is also contrary to the Local Development Plan’s Spatial
Strategy and LDP priority PROM LOC 1 Regeneration Priorities in as much as the proposal
does not promote the physical regeneration of the existing urban area or identified Centres
and should not therefore be given priority. No adequate justification, special circumstance or
material considerations have been demonstrated to merit a departure from the development
plan. 
3. The proposed development is contrary to National Planning Framework 4 (NPF4), Policy 16 -
Quality Homes, including  Policy 16 f) in that the residential aspect of the proposed
development does not meet the criteria to justify residential development on a site not allocated
for housing in the North Lanarkshire Local Development Plan.   
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Background Papers: 
Consultation Responses:   
NLC Education – July 2022, July 2024. 
NLC Environmental Health (including Pollution Control) – March 2022, August 2022, October 2022,
February/March/April 2023. 
NLC Local Housing Strategy (New Supply Team). – November 2021, January 2023, July 2024.
NLC Greenspace Development – June 2022. 
NLC Planning and Place (Policy and Strategy Team) – November 2021, July 2023, September
2023, May 2024, September/October 2024.
NLC Play Services - August 2023, February 2024.
NLC Traffic & Transportation - May 2022, October 2023.
NLC Archaeology Service - October 2021. 
The Coal Authority –October 2021. 
Network Rail – November 2021, May 2023.
Scottish Power Energy Networks  - October 2021.
Scottish Water - October 2021.
Scottish Environment Protection Agency, January 2022.
Sports Scotland – July 2022.
Strathclyde Passenger Transport – August 2024.
Transport Scotland – December 2023, January 2024, May 2024. 
Contact Information: Graeme Lee at Planningenquiry@northlan.gov.uk or 01236 632487 
Report Date: 15th November 2024    
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Executive Summary 
1. Background, Site & Proposals 
1.1 Planning Permission in Principle (PPP) is sought for a residential development of 600 to 650
dwellings on a site east of the B802 road linking the north of Cumbernauld to Croy. The
application is submitted jointly by Hallam Land Management Ltd and Dullatur Golf Club. Should
Planning Permission in Principle be granted, the site would be marketed onwards to housing
developers who have expressed an interest in the site. 
1.2 The site is approximately 37 hectares/94 acres in size and is currently part of the Antonine Golf
Course (one of two 18-hole golf courses at Dullatur Golf Club). The site is located adjacent to
the existing residential area of Smithstone and Croy railway station to the west; Craigmarloch
residential area, Craigmarloch local retail area, and further golf course land to the east; the
Edinburgh to Glasgow railway line to the north; and a wide tree belt and a major local distributor
road, (Eastfield Road), to the south.  The site falls significantly in height - by approximately 20-
25m from east to west but also has undulating ground of various heights within the general
downwardly sloping topography. 
1.3 The site is designated as Green Belt within the North Lanarkshire Local Development Plan
2022 (LDP), to protect its open landscape character, for its recreational value both for golfing,
and for other outdoor activities such as walking, cycling and other informal recreation. There
are areas of long-established trees, more recent scrub vegetation, a designated nature
conservation site and open space and local core footpaths across the site connecting the
Craigmarloch residential and retail areas to Smithstone and Croy. As such, there is a
presumption against development in the green belt designated area except in specific
circumstances such as development proposals for recreation, agricultural, forestry or low-
impact tourism 
1.4 The planning application was validated in October 2021 and the submission includes an
Indicative Development Framework document and Planning Statement, which details at a
strategic level the layout and design of the site including the location, number of development
phases, and the anticipated timescale for site completion if planning permission is granted 
1.5 Road access would be from two access points on Constarry Road, with a distributor road
looping around the site and a series of seven residential development phases served from this.
There would also be an area set aside at the main site access point for community facilities
such as GP surgery facilities, or for retail – although the application does not include provision
of these, and other agencies or private investors would have to provide these. The applicant
advises that development phases would be contained within sensitive landscape planting and
extensive green corridors to minimise the ecological and visual impacts to the existing site and
wider landscape. They indicate that existing features such as designated core footpaths would
be protected and valued ecological and landscape areas would largely be preserved or
compensated for in the long-term by replacement planting and new habitat creation 
1.6 The applicant is of the view that the development is required in order to address what they
consider is a need for immediately deliverable housing sites and have therefore provided a
background report commissioned by Homes for Scotland (the representative organisation for
a number of house builders in Scotland) which states that there is an immediate need and
demand for housing. The report states this need/demand affects 32% or 49,000 households
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in North Lanarkshire. Reasons given are housing unaffordability, overcrowded or concealed
households, and households not adapted for special or additional needs. The applicants
consider that existing allocated housing sites within the Local Development Plan are not
delivering sufficient housing at a rate which would address this need/demand and that, on that
basis the site should be released for housing. The applicants also consider that the proximity
of the site to Croy railway station, local bus routes and local retail centres at Craigmarloch,
adjacent to the site, and Broadwood, within 1.2km, makes the site sustainable and would
generate less additional road traffic by private car than other housing sites due to the nearby
availability of public transport options.  Whilst accepting the locational advantages of the site,
you will note from your report that we do not share the applicants view of the demand/need for
additional housing in North Lanarkshire.   
1.7 The applicants also provide details on what they see as being the community benefits that
would arise if the development were to proceed. They feel that the development would assist
in meeting local housing requirements (including affordable homes), that it would provide or
enhance local infrastructure, facilities and services (highlighting the provision of land for
community facilities and the traffic signalisation improvements and physical junction
improvements to improve flow at Craiglinn roundabout, over and above any increased traffic
impact generated by the development) and that the development would improve the residential
amenity of the surrounding area. Over and above this, specific economic information is
provided, and the applicant highlights a range of economic benefits including: 
• 263 direct and 309 indirect employment opportunities 
• In terms of Gross Value Added (GVA), it is projected that the proposed development will
deliver £94.5m directly, £117.2m indirectly, and in total £211.7m GVA during the
construction phase; 
• Once the proposed development is occupied, it will deliver an increase of 1,443 residents
to the area, resulting in £33.8m GVA per annum and £646m in employment; and
• Retail and leisure expenditure is expected to be £12.4m per annum, with council tax
opportunities of over £1.1m per annum 
1.8 The applicants also advise that planning permission for the proposal would provide funding to
allow a Golf Course Improvement and Development Plan to be fully implemented which would
allow the golf club to continue and expand, since at present there is a general decline in golf
club membership across Scotland. The improvement plan provides opportunities to allow
future generations to participate in the sport and encourage more youth participation. Funding
from the residential development would also provide for the implementation of a range of other
activities within the improvement plan which it is stated, would benefit the local community and
allow greater participation and use of these facilities by sections of the community who are not
currently members or guests of the club, the golf club being active in promoting community
access to these.   
1.9 Whilst acknowledging the golf club’s plans you will note from the report that these are not
considered to be sufficient either in isolation or in conjunction with other community benefits
stated by the applicants to warrant an approval of permission in principle. 
1.10 In addition to addressing the policy requirement for affordable housing (indicating they will
provide this at 25% rather than 20% as required by the LDP) the applicant also indicates their
willingness to provide developer contributions to address impacts of the development on the
capacities of local schools, to address children’s play provision and increases to traffic on local
roads, the applicant has submitted a traffic solution for Craiglinn roundabout which is currently
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a traffic congestion point. This solution would be achieved by providing a “smart” signalisation
system and physical changes to several exits from the roundabout to improve traffic flow. If
permission were to be granted, the applicant would be required to implement these
improvement works at their own cost prior to the commencement of development on site. 
Whilst this is noted, these are matters that would be required to mitigate the impacts of any
development so are not additional benefits. 
2. Consultations 
2.1 This development would represent a significant and unjustified departure from the
development plan and for this reason the planning service is not supportive of it, so whilst not
indicating support for the proposal, where comments from consultees could be addressed by
planning conditions this has been highlighted in the report. 
2.2 A range of consultations were undertaken and NLC Archaeological Service, NLC Education,
NLC New Supply (Affordable Housing), NLC Play Services, NLC Protective Services, NLC
Greenspace Development, NLC Traffic and Transportation, Scottish Power Energy Networks
(SPEN), The Coal Authority, Network Rail, Scottish Water, Transport Scotland and Strathclyde
Partnership for Transport (SPT) all provided comments that would make the development
acceptable subject to planning conditions being included if Planning Permission in Principle
were to be granted. These included additional surveys and reports, and preparation of
implementation plans and strategies and subject to some amendments to the current Indicative
Development Framework, focusing mainly on proposed locations of play areas. 
2.3 The Scottish Environment Protection Agency (SEPA) required that some minor re-alignment
of the main access road and additional measures such as wider culverts to prevent a 1-in-200-
year flood event and mitigate against other potential off-site flooding. 
2.4 NLC Traffic and Transportation and Strathclyde Partnership for Transport (SPT) requested
additional bus stop provision on Constarry Road. NLC Traffic and Transportation also required
an additional pedestrian road crossing along Constarry Road, measures at Craiglinn
roundabout to improve traffic flows and safety and traffic calming measures within the site. 
2.5 Whilst it is the case that there were no objections from consultees (subject to the imposition of
a range of planning conditions) there were however objections from both Craigmarloch and
also Kilsyth Community Councils. Craigmarloch CC raising a number of concerns regarding
loss of green spaces in this part of Cumbernauld, existing public service provision, access to
GP and dental provision, increased traffic congestion, impacts on school provision, lack of safe
walking routes to school, parking under-provision at Croy railway station, impacts on
landscape and wildlife, the development being contrary to development plan policies and a
lack of early publicity for an applicant’s non-statutory consultation meeting with local
community groups. 
2.6 Kilsyth Community Council objected to the application being contrary to development plan
policies, the loss of green belt land if planning permission is granted, and a precedent being
set to allow development of other green belt designated areas around Kilsyth and the Kelvin
Valley. 
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3. Representations 
3.1 A total of 197 Representations were received during the official consultation period of 14th
October 2021 until 4th November 2021 with a clear majority opposing the application proposal
(188 objecting and 9 in support). Objections were received from Gillian McKay MSP, Stuart
McDonald MP and Jamie Hepburn MSP who all have serious reservations about this
development such that it is their shared opinion that permission should not be approved. They
point out that the site is not an allocated residential site and also highlight concerns with
regards to the scale and adverse impacts of the development 
3.2 Other representations were received late and are not included in the above figures however
these later submissions are discussed within the main body of this report. 
3.3 Reasons given in representations for opposing the application proposal included: 
• The application was contrary to Development Plan policy as it was a designated Green
Belt site in the Local Development Plan. 
• The application was contrary to National Planning Framework 4 policies and
objectives.   
• Loss of a valuable area of recreational open space with adverse landscape, wildlife
and recreational impacts for the local and wider communities.
• Traffic congestion adversely affecting the north of Cumbernauld where congestion
issues are already experienced and regarding road safety concerns particularly for
school children going to and from school.
• Air and noise pollution increases.
• Additional impacts to infrastructure and additional public services such as schools, and
primary health care provision (general practice and dentistry).
• Potential flooding impacts
• That housing provided would be unaffordable for large sectors of the community.
• Issues over the legal (title) status of the land. 
3.4 With regards to supporting comments – reasons given include: 
• Shortage of/need for new and affordable homes
• Job creation during construction
• Will lead to improved facilities
• Community hub is welcomed
• Increase in Council tax will help the Council deliver better services 
4. Development Plan 
4.1 The development plan comprises the National Planning Framework (NPF4) adopted in
February 2023 and the North Lanarkshire Local Development Plan (NLLDP/LDP) adopted in
2022. You will note from the report that there is a detailed and lengthy assessment of the
proposal against the provisions of the development plan.   
5. Assessment against the Development Plan and Other Material Considerations 
5.1 Section 25 of the Town and Country Planning (Scotland) Act 1997 states that planning
decisions must be made in accordance with the development plan unless material
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considerations indicate otherwise. 
5.2 As this proposal relates to a Green Belt site that is not allocated for residential purposes in the
Local Development Plan a key policy and material consideration relates to the interpretation
of National Planning Framework 4 - Policy 16 (Quality homes). This policy deals with new
homes and including sub-section 16 f) relating to the development of new homes on sites not
allocated for residential purposes in the LDP and the limited circumstances in which these will
be supported. 
5.3 Since the adoption of NPF4, the interpretation of NPF4 policy 16 has been evolving and has
been informed by the outcome of judicial reviews, Chief Planner Letters and Planning Appeal
decisions. These matters are discussed in some detail in the report, suffice to say that when
the proposal is considered against Policy 16, it is concluded that there is no justification at this
time to release this green belt site for residential purposes and to do so would represent a
significant departure from the development plan and its spatial strategy.  Indeed, recent appeal
decisions are of some note and relevance to this case.  The thrust of these decisions is that if
there is no housing land pipeline in place, the effect is to remove the possibility of the exception
provided by Policy 16 f) iii being triggered. There is currently no housing land pipeline in place
in North Lanarkshire. The Planning Service is progressing with this and a separate report on
the matter will be presented to the planning committee in due course. As such, the general
restriction on development on non-allocated sites established by Policy 16 f) therefore still
applies.   
5.4 In tackling the Housing Emergency and as recently as 12th November 2024, the Scottish
Government further explained its rationale behind the changes introduced in NPF4. They
advise NPF4 signals a move away from past practice which allowed for additional land, which
is not supported by plans, often in more easily developed, greenfield locations, to be released
if insufficient land for housing was available. The context for the statement is that, according
to the Scottish Government, across Scotland there are sites with planning permission that
could deliver more than 164,000 homes but are not, they set out measures to identify the
reasons for this, and actions to be taken to support delivery. In doing this they indicate what
their objectives will be for the next 6 months, identifying 4 key objectives, none of which relate
to the allocation of additional land for housing. 
5.5 In addition, the application is also assessed as contrary to National Planning Framework 4,
Policy 8 Green Belts as the development would result in loss of an area of land which strongly
contributes to the landscape character and defining the settlements of Croy and Cumbernauld.
The proposal is considered to be at odds with the aims of NPF4 Policy 1 Tackling the Climate
and Nature Crisis, Policy 2, Climate Mitigation and Adaption and Policy 6 Forestry, Woodland
and Trees. 
5.6 Furthermore, the proposal is assessed as being contrary to NPF 4 Policy 9, Brownfield, Vacant
and Derelict Land and Empty Buildings which advises Local Development Plans (LDPs) to
encourage, promote and facilitate reuse of such land and buildings and advised that
development on green belt sites will not be support unless allocated for development or
explicitly supported by other Local Development Plan policies. 
5.7 With regards to the Local Development Plan the proposal is assessed as contrary to the LDP
Spatial Strategy and LDP priority PROM LOC1 Regeneration Priorities in that the proposal
does not promote regeneration of an existing urban area or within identified Centres within the
LDP and should not therefore be given priority. The proposal is also contrary to Placemaking
Policy 4 - Green Belt, PP 4 Purpose of Place and AD4 Amount of Development as the
development would result in the unacceptable impact of the loss of a valuable area of green
belt which strongly contributes to defining the settlements of Cumbernauld and Croy and
contributes to the landscape character and outdoor recreational space of that area
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5.8 As required by NPF4 for development proposals of 50 or more houses the applicants have
provided a Statement of the Community Benefits they feel that the development would deliver
in relation to meeting local housing requirements including affordable homes, providing or
enhancing local infrastructure, facilities and services and improving the residential amenity of
the surrounding area.  In addition, information has been provided on the economic benefits
associated with the development and the Golf Club has provided extensive information on the
benefits this development will bring including a Golf Course Improvement and Development
Plan which they state will secure the long-term future of the club. These matters have been
considered and assessed in detail in the report and are not considered, either in isolation, or
cumulatively to be sufficient to warrant support for a development that represents such a
significant departure from the development plan and its spatial strategy. 
6. Conclusions 
6.1 With regards to NPF4 and the North Lanarkshire Local Development Plan 2022 there is no
policy support or other sufficient justification at this time to release this green belt site for
residential purposes and to do so would represent a significant departure from the
development plan and its spatial strategy.  As such planning permission in principle should be
refused 
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APPLICATION NO. 21/01414/PPP 
REPORT 
1. Purpose of Report   
1.1 To advise Committee regarding a planning application for large-scale residential development
at land north of Cumbernauld which is currently designated as Green Belt and to seek
Committee agreement to the report conclusions and recommendations. 
2.  Background 
2.1 A planning application was submitted in September 2021 seeking Planning Permission in
Principle (PPP) for residential development with associated infrastructure of approximately 600
to 650 dwellings at land east of the B802 road between Cumbernauld and Croy village. 
2.2 During the application process statutory and internal consultees provided consultation
comments regarding the proposal.  Neighbour notification and public consultation resulted in
a significant number of responses. The applicant subsequently submitted additional
information to support the application. At the time of this report there are no outstanding
planning matters to be addressed at the level of detail required for a Planning in Principle
(PPP) application. 
2.3 A site layout and design framework for the site has been provided however if permission were
granted, detailed, Matters Specified in Conditions (MSC), planning applications would be
required to provide greater detail and to be assessed for each development phase as
development progressed. 
3. Site Description 
3.1 The 37 hectares (94 acres) site lies north of Cumbernauld and south of Croy village. Site
boundaries are: the Glasgow/Edinburgh railway line and a designated core footpath to the
north; the B802 Constarry Road, Smithstone residential area and Croy railway station/park-
and-ride to the west; a wide belt of woodland and Eastfield Road to the south; and
Craigmarloch local retail centre, Craigmarloch residential area and an area of golf course land
to the east. 
3.2 The site consists of a western section of the Antonine 18-hole golf course containing
approximately six golf course fairways and greens, blocks of woodland, scattered semi-mature
woodland and regenerating scrub. Core footpath 74 follows the northern site boundary parallel
to the railway line. Core footpath 90 a tarmac surfaced, street-lit footpath, crosses the middle
of the site east-to-west from Craigmarloch retail area towards Croy station while more minor
paths provide access to golf course fairways and greens. Site height drops significantly (by
approximately 20 to 25 metres) from east to west but includes areas of undulating land within
the general downward slope. 
3.3 A Site of Importance for Nature Conservation (SINC) comprising wooded, marshy ground, lies
at the lowest point in the north-west corner of the site. Several wooded areas are designated
by Tree Preservation Orders (TPOs). High voltage electricity transmission lines traverse the
site north-east to south-west with two large pylon towers located on the site. 
3.4 The development proposal does not encroach into the protective landscape buffer zone of the
Antonine Wall World Heritage site.  Part of the site is shown to be within a designated Air
Quality Action area as identified in the Local Development Plan. However, as air quality has
improved in the area this Action Area was revoked in July 2022.
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4.  Proposed Development 
4.1 The application is for 600-650 dwellings, associated access, internal distributor and residential
roads, landscaping, open space and play areas. Eight separate development phases or “pods”
are proposed within an indicative development framework document, with the phase adjacent
to the proposed site access allocated for community uses such as local medical practice or
local shops although delivery of these facilities is not part of the current application and would
require to be delivered by other means subject to market conditions and community demand. 
4.2 A drainage pond and basins, landscaped buffer zones and equipped play areas are proposed
between development phases. Buffer areas would also be located around the SINC, the
watercourse, part of the main footpath bisecting the site and beneath the electricity
transmission lines. A 25m wide tree-belt at the east of the site, between the golf course and
housing at Craigmarloch, beyond the site boundary but within ownership of Dullatur Golf Club
would be retained. 
4.3 Acoustic fencing is proposed along the northern site boundary with access points to and from
the development to the core path (No.70) located adjacent to the railway. Replacement tree
and shrub planting is proposed between development phases to compensate for losses of
existing trees due to development and bolster adjacent natural habitats areas. A key distributor
road within the site would take access from two points on Constarry Road with secondary
accesses from the key distributor to individual development phases. 
4.4 Whether housing would be exclusively low-rise or include flatted housing is not stated. The
application advises that house types will be designed and sympathetic to each landscape
location. The applicant’s original Planning Statement (2021) suggested a delivery rate of 70 to
100 units per year starting within six months of a grant of planning permission which would
suggest a construction period of six to nine years. However, a recently updated planning
statement addendum advised of a construction-to-completion period of 6 years although this
would be subject to prevailing economic circumstances. 
4.5 The application is jointly submitted by Hallam Land Management Ltd and Dullatur Golf Club.
The golf club buildings and parking are approximately 1000 metres east of the eastern site
boundary beyond Craigmarloch residential area. Club facilities currently comprise a
clubhouse, two eighteen-hole golf courses, tennis courts, a bowling green, golf practice area,
three existing small business leases and a separately managed restaurant. 
4.6 The applicants advise that development of the application site would provide funding for a golf
club improvement plan comprising clubhouse upgrade, tennis dome provision for year-round
use, retention of the existing bowling green and structural tree-planting within the remaining
golf course areas. The golf course at the application site would be reduced in from 18 to nine
holes. The improvement plan aims to improve accessibility for the local community to club
facilities, for pay-and-play golf, shorter rounds of golf and use of other club facilities such as
the tennis courts. This would be encouraged by active community outreach methods. The
improvement plan does not advise of a legal mechanism to ensure the proposed community
access to these facilities. 
5. Applicant’s Supporting Information 
5.1  The following supporting package of documents were submitted. 
• Site Drawings/Plans: including revisions/amendments,  
• Location Plan,
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• Golf Course Improvement Plan, 
• Landscape Framework and Landscape Visual Assessment, 
• Tree Survey, Tree Constraints and Tree Removal/Retention Plans,
• Indicative Development Framework Plan (including revised versions),
• Statement of Community Benefit,
• Title Plans,
• Craiglinn Roundabout Upgrade Options ,
• Meeting Minutes with local Community Representatives (December 2023). 
Reports 
• Air Quality Impact Assessment    (July 2021)
• Air Quality Impact Assessment – Update    (April 2023)
• Design and Access Statement     (September 2021)
• Dullatur Golf Club –Statement of Proposed Development  (September 2021)
• Ecology Assessment      (October 2021)
• Ecological Assessment: Addendum: Bats   (February 2022)
• Ecological Surveys – Updated    (September 2022)
• Education Review       (May 2021).
• Engineering and Drainage Summary Report   (July 2021)
• Flood Risk Assessment,     (July 2021)
• Geotechnical Report -(within Engineering Report)  (July 2021) 
• Historic Environment Statement    (March 2021)
• Landscape and Visual Impact Appraisal   (September 2021)
• Mining Risk Assessment Report    (October 2021)
• Noise Impact Assessment     (June 2021)
• Pre-Application Consultation (PAC) Report   (September 2021)
• Planning Statement      (September 2021)
• Planning Statement Addendum (Policy Review – NPF4) (December 2022)
• Planning Statement Addendum - (Following Local 
Development Plan Adoption).     (December 2022)
• Planning Statement Addendum 3 (Following Scottish  (August 2024)
Government/Chief Planner’s Letter regarding NPF4)
• Transport Assessment and Supporting Statements (August 2021 onwards)
• Craiglinn Roundabout Traffic Modelling/Data Assessments (March 2023 onwards) 
• Tree Survey/Arboricultural Report and Appendices,  (June 2021)
• Woodland Strategy and Mitigation Planting   (June 2021)
• Housing Land Supply Statements     (multiple dates)
• Statement of Community Benefit    (December 2023) 
5.2 Updates to documents and additional information has been submitted up to the finalisation of
this application report, for example multiple traffic modelling documents to improvement traffic
flow at Craiglinn roundabout and updated information to address changes to national planning
policies resulting from the adoption of National Planning Framework 4 (NPF4). 
6. Site History 
6.1  No planning applications have been submitted nor planning permissions granted within the
application site since prior to 2000.  The applicants state within the application that they are
sole landowners of the application site. 
The following all relate to the current planning application. 
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• 21/00177/EIASCR Proposed Residential Development with Roads, Access, Parking,
Landscaping, Suds & Associated Development, 
• 21/00165/PAN Residential Development with Roads, Access, Parking, Landscaping,
Sustainable Urban Drainage Systems and Associated Development. 
7. Development Plan   
7.1 Under Section 25 of the Town and Country Planning (Scotland) Act 1997 planning decisions
must be made in accordance with the development plan unless material considerations
indicate otherwise. The Development Plan consists of the National Planning Framework 4,
(NPF4) adopted February 2023, and the North Lanarkshire Local Development Plan
(NLLDP/LDP) adopted July 2022. 
7.2 NPF4 policies supersede both the Scottish Planning Policy (2014) and the Clyde Plan Strategic
Development Plan (2017) and have precedence over policies in the current North Local
Development Plan 2022 in situations or circumstances where LDP policies are incompatible
with the aims and objectives of NPF4. The national document was adopted more recently, and
national guidance advises that its policies have more recent planning policy relevance. 
7.3 The scale of this planning application proposal requires the application to be assessed from
both national strategic and local development plan perspectives and assessed against the
policies in both documents. 
7.4 Relevant NPF4 and Local Development Plan polices that apply are stated below and
discussed in detail in the context of the planning application assessment within section 10
below, the Planning Assessment section of this report 
National Planning Framework 4 (NPF 4) 
7.5 NPF Policy 1 Tackling the climate and nature crisis - advises that when considering all
development proposals, significant weight will be given to the global climate and nature crisis.
This includes promoting compact urban growth as part of climate mitigation and adaption. 
7.6 NPF Policy 2 Climate mitigation and adaptation – advises that development proposals will
be sited and designed to minimise lifecycle greenhouse gas emissions as far as possible and
development proposals will be sited and designed to adapt to current and future risks from
climate change 
7.7 NPF Policy 3 Biodiversity - advises development proposals should contribute to
enhancement of biodiversity, including where relevant, restoring degraded habitats and
buildings and strengthening nature networks and connections between them. Proposals
should integrate nature-based solutions with development were possible. 
7.8  NPF Policy 6 Forestry Woodland and Trees - is intended to protect and expand woodland
and trees. 
7.9  NPF4 Policy 8 Greenbelt - seeks to encourage, promote and facilitate compact urban growth
and land use around our towns and cities sustainably and to ensure that: 
• Development is directed to the right locations, urban density increased, and unsustainable
growth prevented.
• The character, landscape and natural setting and identify of settlements is protected and
enhanced.
• Nature networks are supported, and land managed to help tackle climate change.
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7.10 NPF 4 Policy 9 Brownfield, Vacant and Derelict Land and Empty Buildings - advises Local
Development Plans should set out opportunities for sustainable reuse of brownfield and vacant
and derelict land and empty buildings to help tackle carbon climate emissions, to support local
living and limit use of additional land for development. The policy has cross-cutting objectives
supportive of Policy 8 Green Belt - managing development in the greenbelt, and Policy 3
Biodiversity, by improving degraded habitats and buildings and integrating nature-based
solutions. 
7.11 NPF4 Policy 13 Sustainable Transport - seeks to encourage, promote and facilitate
developments that prioritise walking, wheeling, cycling and public transport for everyday travel
and to reduce the need to travel unsustainably. 
7.12  NPF4 Policy 14 Design, Quality and Place - aims to ensure that developments are of good
design, are not detrimental to amenity of the surrounding area and are consistent with the six
qualities of successful places – Healthy, Pleasant, Connected, Distinctive, Sustainable and
Adaptable. 
7.13 NPF4 Policy 15 Local Living and 20 Minute Neighbourhoods - aims to achieve this
sustainability objective of development including considering existing settlement patterns and
the level and quality of interconnectivity of proposed development with the surrounding area. 
7.14 NPF4 Policy 16 Quality Homes - supports new homes on land allocated for housing in Local
Development Plans and sets out various requirements including meeting local housing
requirements, providing or enhancing local infrastructure, local facilities and services and
improving residential amenity of the surrounding area 
7.15 NPF4 Policy 20 Blue and Green Infrastructure - aims that Development Plans protect and
enhance blue and green networks (natural habitats, watercourses and water bodies).
Development proposals resulting in fragmentation or loss of this infrastructure will only be
supported where development does not result in a deficit nor exacerbate such impacts on this
asset. Developments incorporating new or enhanced blue/green infrastructure will be
supported subject to compliance with other policies and with effective management and
maintenance plans and funding provision for upkeep of the enhancements. 
7.16 NPF 4 Policy 21 Play, Recreation and Sport - supports provision of spaces and opportunities
for play, recreation and sport.  Subsection 21 a) considers circumstances where loss of outdoor
sports facilities may be acceptable and subsections 21b) and 21 d) assess loss or new
provision of children’s play area, 21c) is not relevant and sections 21e)-g) deal with design
detail and future maintenance.  Subsection 21a) is more relevant to this application. 
7.17 NPF 4 Policy 22 Flood Risk and Water Management - considers development proposals
that may exacerbate or lead to flooding elsewhere off-site or may be at risk of flooding due to
the development. It aims to ensure that development can be connected to water supply and
sewerage systems and where possible, can create, protect or expand opportunities for
blue/green infrastructure for natural flood risk management. 
North Lanarkshire Local Development Plan (NLLDP) 2022. 
7.18 The following priorities and policies within the North Lanarkshire Local Development Plan are
relevant to the planning application. 
7.19 PROM LOC 1 Regeneration Priorities 
PROM LOC1 states that North Lanarkshire Council will promote regeneration and sustainable
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growth, by applying the Policies in the Plan to deliver the right amount of development in the
right places, developed to the right quality, and for the benefit of the communities they affect.
Physical regeneration of the existing urban area and the Centres identified therein will be given
priority. 
Any development proposals will require to take into account all Promote and Protect Policies
and the Council’s Regeneration Priorities: 
7.20 PROT A - C Protecting Assets 
Policy PROT A - Protecting Assets: Natural Environment and Green Network Assets not
relevant in this case – site is green belt. 
Policy PROT B - Protecting Assets: Historic Environmental Assets, PROT B1 International.
B1 seeks to protect the internationally designated, Frontiers of the Roman Empire (Antonine
Wall) World Heritage Site and the Frontiers of the Roman Empire (Antonine Wall) World
Heritage Site Buffer Zones. This policy states there will be a presumption against development
which has an adverse impact on this heritage asset and its setting. 
The policy also seeks to preserve or record Sites of Archaeological Interest by either
preserving the asset at the location or by removing/recording the remaining asset. 
Policy PROT C - Protecting Assets: Mineral Resources contains a presumption against
development which would potentially sterilise valuable mineral resources. As this site is
designated as protected green belt the policy does not apply. 
7.21 Placemaking Policy PP4 Greenbelt – Purpose of Place and Placemaking Policy AD4
Greenbelt - Amount of Development 
Policy PP4 advises the purpose of the Green Belt is to protect the setting of communities,
support regeneration by directing growth to urban areas, protect natural assets and provide a
high-quality environment by promoting a Green Belt as defined on the Promote Map. The
policy sets out that the council seeks to support developments for agriculture, forestry,
recreation, or developments that need a non-urban location. 
Policy AD4 Amount of Development requires that housing proposals support a Green Belt
appropriate use as identified in Policy PP4 above.   
7.22 Policy CI Contributions to Infrastructure 
Policy CI sets out that the council will seek developer contributions for new developments that
generate a requirement for new or enhanced services or infrastructure in terms of Affordable
Housing, Education, Transportation improvements, Amenity Space and Play Areas and Green
Infrastructure. 
7.23 Environmental and Design Quality Policies 
EDQ1 - Site Appraisal 
EDQ2 – Specific Features for Consideration 
EDQ3 – Quality of Development
These policies set out the processes by which proposed development will be appraised. Policy
EDQ1 is to assess the site and its surroundings to ensure it will integrate successfully into the
local area and avoid harm to neighbouring amenity. Policy EDQ2 takes account of hazards
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such as flooding and existing infrastructure, Policy EDQ3, provides guidance and the need for
assessment to ensure quality design within the development.   
8. Consultations   
8.1 The following consultation responses were received regarding the application proposal. 
Note: This development would represent a significant and unjustified departure from the
development plan and for this reason the planning service is not supportive of it, so whilst not
indicating support for the proposal, where comments from consultees could be addressed by
planning conditions this has been highlighted. 
8.2 NLC Archaeological Service Consultee – agreed that the development did not materially
impact on the Antonine Wall or its buffer zone but recommended if permission were granted
that further archaeological investigative work be required in advance of construction. An
appropriate model planning condition was provided to be included in a PPP permission and
future detailed permissions, if permission in principle were to be granted. 
8.3 NLC Education – Primary school catchments for the site had available capacity but the
development would add capacity constraints to secondary provision at Our Lady’s High School
requiring provision of additional modular teaching units. A developer contribution of £606,666
was requested subject to review if development did not commence within 3 years of
submission of the application in 2021.As the original consultation was in 2021 NLC Education
were asked to look afresh in July 2024 at the impacts and have confirmed that the amount
remains the same at present subject to future indexation following any grant of planning
permission to account for inflation. 
A Section 75 legal agreement could secure these contributions including indexation to ensure
that inflationary increases would be accounted for.   
8.4 NLC New Supply (Affordable Housing) – requires 20% provision of affordable housing on-
site in accordance with Local Development Plan Policy CI – Contributions to Infrastructure. 
The applicant stated (March 2023) willingness to provide up to 25% affordable housing which
the New Supply (Affordable Housing) service would support. Further consultation with New
Supply in July 2024 confirmed that despite NPF4, NLC’s position remains that 20% affordable
housing was the requirement but that developers providing 25% would mark a positive
contribution to affordable housing. 
New Supply also advised appropriate house type mixes for affordable housing including
housing for varying needs and that affordable housing should be integrated with other housing
tenures throughout the development. The proportion of housing sought is 28% 1bedroom
cottage flats, 50% 2 bedrooms (houses preferred) 14% 3-bedroom houses and 8% 4
bedrooms. 10% of the housing should be wheelchair standard and all property must be
Housing for Varying Needs compliant. If planning permission in principle is granted the
developer must consult with North Lanarkshire Council New Supply Team regarding the
housing mix for each development phases. 
If permission in principle were to be granted, compliance with the policy could be secured by
planning condition requiring subsequent MSC applications to be accompanied by affordable
housing agreements (this could reflect the applicants offer of a 25% affordable housing
contribution). 
8.5 NLC Play Services - advised that as development would be delivered over a number of
phases, the three currently proposed indicative play areas were inappropriate in size and
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location including due to their proximity to electricity transmission lines.  Instead, appropriate
play provision should be assessed for each development phase application, or for several
phases if being built at a similar time. Provision should consider existing and other planned
local play provision. Multi Use Games Areas (MUGA), (which included football/basketball
courts), and local equipped children’s play areas would be required at appropriate locations
with delivery by either developer contribution or direct provision and funding contributions and
mechanisms for future maintenance to be determined at the time of detailed applications. 
If permission in principle were to be granted these matters could be addressed by planning
conditions. 
8.6 NLC Protective Services - raised concerns regarding initial level of detail of site investigations
particularly as some site areas had historic quarrying and shallow coal mining activity. In
response, the applicant requested that more detailed site investigations take place at individual
development phases rather than at Permission in Principle (PPP) stage. This is not
unreasonable given a PPP planning decision primarily determines the principle of a proposed
use is acceptable for a site. Further site investigations would be required for MSC applications
to address potential impacts for health, water environment, plant life, gas risk, former mine and
landfill areas and contamination screening of imported soil materials. 
If Permission in Principle were to be granted, planning conditions requiring further site
investigations would be imposed for individual phases and potentially remediation measures
as required. 
A Noise Impact Assessment was submitted indicating locations where excessive noise would
require to be addressed. Protective Services would require further detailed noise modelling for
each detailed phase application once site layouts were confirmed. Additional noise
assessments of retail vehicle deliveries at Craigmarloch retail centre and of road and rail noise
from site boundaries was also required, as was a Construction Environmental Management
Plan for the overall site to address noise, dust, operating hours and other matters during
development. 
If permission in principle were to be granted, these matters could be addressed by planning
conditions. 
An Air Quality Management Area which included part of the site adjacent to Croy station was
revoked in July 2022.  The applicant’s submitted Air Quality Assessment was initially
considered to underestimate traffic volumes and predicted NOx (Nitrogen Oxide) levels
however Protective Service advised this was due to reduced traffic flows during the Covid
lockdown period. More details supplementary information was submitted which indicated no
predicted breaches of relevant air quality standards. Protective Services provided model
planning conditions to address air quality mitigation and monitoring for detailed application
phases. 
8.7 NLC Greenspace – advised permission should only be granted if no adverse impacts occurred
to the Site of Importance for Nature Conservation (SINC) or to two blocks of native woodland
(one within the SINC). Habitat loss in other areas should also be prevented. Preliminary
Ecological Appraisals would be required for each development phase including habitat and
protected species surveys. The main access road should be re-aligned to prevent
fragmentation of the SINC and by use of buffers areas to prevent adverse impact to the SINC,
and a habitat management plan and green network strategy prepared.   
If permission were to be granted these matters could be addressed by planning conditions at
PPP stage for individual development phases. 
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8.8 NLC Traffic and Transportation –protracted and involved discussions have taken place with
consultants acting on behalf of the applicant to address the question of whether this scale of
development could be accommodated on the local road network without adverse impacts,
especially in relation to the nearby Craiglinn interchange which experiences significant
congestion at peak times. 
Various physical solutions have been explored by the applicant including adding lanes to the
roundabout. The impacts of this solution when measured against the disruption the works
would cause were not considered proportionate in terms of the improvements that would be
achieved. Instead, an alternative solution has been demonstrated by the applicant’s Transport
Consultant to NLC Traffic and Transportation, which involves minor widening to several
roundabout exits, realignment of exit lanes and installation of an updated traffic signalisation
system which assesses traffic volumes more effectively at access points and adjusts
signalisation accordingly to improve traffic flow. In combination, these measures are assessed
as addressing the impact of the proposed development and improving on existing traffic flow. 
Should planning permission be granted the applicant would be required to implement the works
and pay the cost of the works. The works would require to be completed before any
construction work commences at the application site and this could be controlled by means of
a suspensive planning condition. 
NLC Roads and Transportation also provided a number of other comments regarding road
safety and for other traffic matters more specific to the site itself and immediate surroundings.
There would be requirement to provide pedestrian crossings and active travel routes for
pedestrians/cyclists across the site and to the wider local active travel network. A bus route
around the site was considered if Strathclyde Partnership for Transport (SPT) in consultation
with the bus companies had requested this however SPT advised that this was not practical.
(See SPT consultation response below). 
Provision and implementation of pedestrian/cycling crossings and routes would require to be
delivered by individual developers as part of a strategic site active travel network. Again, this
travel network, the main site distributor road and provision of access links and junction
upgrades from the site to the existing road network would require to be delivered and paid for
by the applicant or future developers following consultation with NLC Roads and
Transportation.   
These matters could be addressed by planning conditions within an initial permission in
principle requiring detailed provision of the requirements above to ensure a co-ordinated
approach by developers to share the implementation of roads infrastructure. 
8.9 Scottish Environment Protection Agency (SEPA) 
SEPA advised measures were required to address compensatory flood storage to offset loss
of floodplain due to the new access road and that any new bridges or culverts required to
accommodate a 1-in-200year flood event. As such further detailed survey work would be
required for individual phases to future-proof the overall impact of the planned development. 
These matters could be addressed by planning conditions within an initial permission in
principle requiring detailed provision of the requirements above. 
8.10 Scottish Power Energy Networks (SPEN). SPEN advised that they required to be contacted
regarding detailed development proposals due to the presence of high voltage overhead and
low voltage underground cables. Stand-off areas for access, maintenance and associated
works to existing infrastructure would be required unless the developer were to fund re-routing
of such infrastructure. 
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If permission were to be granted these matters would need to be addressed by the developer
with regards to how development could proceed in relation to these constraints. Further
consultation with SPEN would be required.   
8.11 Coal Authority advised an area at the east of the site was defined as a Development High
Risk Area due to the mining legacy with potential for ground instability and gas emissions.
Intrusive site investigation works were required to establish risk and provide remediation.
Future technical reports should also be provided including information to address potential
implications relating to previous coal mining and the creation of sustainable urban drainage
infrastructure. 
Should planning permission be granted these matters could be addressed by planning
conditions. 
8.12 Network Rail had no objections to the proposal subject to the applicant providing a 1.8m high
trespass-proof fence adjacent to the railway boundary and provision for fence maintenance
and renewal. In addition, Network Rail required a minimum 10m stand-off area between
sustainable urban drainage systems and the railway boundary. Draft planning conditions were
provided to address these matters which would be included should planning permission in
principle be granted. 
8.13  Scottish Water (SW) advised that the developers should ensure no damage to existing water
and sewerage infrastructure by contacting SW prior to construction, providing stand-off
distances and providing access to maintain infrastructure which includes a 18”/400mm trunk
water main. Sufficient water and wastewater capacity was available at the time of consultation
although the proposed development had not been incorporated within these capacity
assessments. Therefore, the developer would be required to discuss potential investment
needs and programming and future water supply and foul water disposal requirements. 
8.14 Sportscotland took reference from the Scottish Planning Policy (now replaced by NPF4) and
North Lanarkshire Local Development Plan policy PROM LOC 4 Special Landscape Areas
and Green Network Improvements and policy PROT A Natural Environmental and Green
Network Assets regarding the safeguarding of outdoor sports facilities. They also consulted
Scottish Golf who advised that the proposed reduction from an 18 to 9-hole golf course was
acceptable given falling levels of participation. Sportscotland agreed with this assessment from
Scottish Golf. 
Sportscotland also recommended measures to address issues related to golf course activity
and the close proximity of the proposed development to these, for example protective
fencing/netting near proposed new housing. Should permission be granted measures to
address the interface between residential development and golfing activity could be addressed
by planning conditions. 
8.15 Transport Scotland did not object to the application provided the development did not exceed
650 dwellings in order to ensure no negative impact on operation of the trunk road network
(M80). 
8.16 NHS Lanarkshire – No response was received. 
8.17 Strathclyde Partnership for Transport (SPT) advised that whilst bus penetration into the site
was possible it would be unlikely to be attractive to bus operators due to the proximity of Croy
railway station and existing adjacent bus services. SPT did advise however that bus stop
provision should be considered between Strath Brennig Road and Smithstone Road and
should align with pedestrian exits from the site ie Two new bus stops on the B802. Proposals
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for stops should be discussed with the road authority and SPT prior to occupation of any
phases of development. These matters could be address by planning conditions. 
8.18 Craigmarloch Community Council (CCC) – objected advising there was a petition with over
2000 signatures objecting to destruction of Cumbernauld green spaces. This did not however
state that the petition only related to this planning application. Other concerns raised were that
infrastructure in the north of Cumbernauld was already inadequate with minimal GP and
dentistry provision and with GPs not registering new patients, that there was traffic congestion
along Eastfield Road in the vicinity of the application site and that recent planning permissions
had exacerbated this problem, that there was a lack of safe routes to primary school and a
lack of safe pick up and drop off parking, insufficient parking at Croy railway station, that
spaces allocated in previous developments for such community facilities had failed to provide
these, that the site had considerable environmental value for wildlife and people as had been
demonstrated during Covid lockdowns and that the proposal would lead to urban sprawl. 
8.19 Craigmarloch Community Council Addendum – submitted further consultation comments
as an Addendum to their original submission by email dated 25 June 2024The Addendum
updated previous comments to reflect the adoption of National Planning Framework 4 and
NPF4 policies. 
The submission added additional comments opposing the development on the grounds that
Dullatur Golf Club is a business and private members club and had not been a community hub
for use by all local resident’s contrary to the suggestions in the Golf Club Improvement Plan
that facilities will be made more widely publicly available through community engagement. 
The Addendum also stated that 
• planning permissions granted to the golf club in recent years for other smaller-scale
housing development opposed by residents had caused problems and inconvenience
for residents during construction. 
• The application proposal is contrary to NPF4’s policy on Blue and Green Infrastructure,
(NPF4 Policy 20), which states development would only be supported where it does
not result in fragmentation or loss of blue-green infrastructure (natural habitats and
watercourses/waterbodies). 
• A community meeting by the applicants had been arranged at short notice and the
subsequent Minutes produced were not an accurate reflection of the meeting or matters
raised. 
Response: The club is a private one as indicated.  The wider community benefits are therefore
perhaps limited beyond those of potentially retaining the club as a viable entity going forward
for local residents to join.  That said no information has been provided on the state of the golf
clubs accounts or its current financial viability. Nor has the application provided information on
the nature of the deal between them and Hallam Land in terms of financial benefit. 
It is true that in some cases, contrary to local residents wishes, the golf club previously
benefited financially through the sale of land it owned for residential use, (a total of 28 houses
– 10 as individual plots and 18 developed by CALA homes). Nevertheless, any disturbance
caused by previous permissions granted for housing development at the golf club is not
material to this application.  Those permissions were however granted following assessment
by the statutory planning application decision-making process and were subject to public
consultation. 
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With regards to the community meeting the planning service was not aware of this meeting,
and did not attend so cannot comment on the accuracy or otherwise of the minutes. 
Other objections raised in relation to planning policy and NPF4 are addressed in the Planning
Assessment section of this report. 
8.20 Kilsyth Community Council (KCC) – objected advising that whilst the site was not within
their Community Council boundary they objected to the proposal as it was contrary to North
Lanarkshire Local Development Plan policy as the site is designated for protection as green
belt and that if the development was approved there would difficulty in protecting similarly
designated green belt and countryside around Kilsyth and Kelvin Valley villages.   
9. Representations/Objections 
9.1 The statutory public consultation on this application took place from 14th October up to 4th
November 2021 (triggered by neighbour notification letters and a press advert) and this
resulted in 197 representations being received within this time period (188 objecting 9 in
support) including from Gillian McKay MSP, Stuart McDonald MP and Jamie Hepburn MSP
(who all have serious reservations about this development such that it is their shared opinion
that permission should not be approved. They point out that the site is not an allocated
residential site and also highlight concerns with regards to the scale and adverse impacts of
the development).  A total of 97 representations were received outwith the public consultation
period (23 objecting 74 in support).  The Council policy is that only those representations
received within the statutory time periods are taken into account. 
The comments objecting to the application proposal are summarised within the subject
headings below followed by comments in support.   
9.2 Planning Policy and Development Plan Compliance: Representations: The proposal is
contrary to Local Development Plan policy as the site is Green Belt, was previously assessed
for housing by the Local Plan Report of Examination process and rejected in that Examination
for residential use. Significant housing allocations are already available in the LDP at the South
Cumbernauld Community Growth Area at sites at Mid Forest and Palacerigg. Local plan policy
gives clear direction to where development should take place and the application ignores the
purpose of the development plan process and community consultation. The proposal
represents significant unplanned growth and increases pressure on local infrastructure and
there is not a shortfall in housing land supply in the area. 
9.3 Response: Agreed. The site is not allocated as a development site and the application is
assessed as contrary to the development plan which consists of NPF4 and the Local
Development Plan. The application site was submitted in response to the consultation on the
Modified Local Development Plan, as the applicant objected to its green belt designation rather
than as a residential development site and subsequently therefore was presented as an
unresolved objection to the Examination of that plan. However, as the site was not included in
the Plan because it was submitted too late it was not assessed at Examination.  The Reporters
concluded that the site was not included in the LDP Main Issues Report, had not been the
subject of public consultation and had not been subject to Strategic Environmental
Assessment which the Reporters required. Accordingly, the site was retained as green belt.
There is no need at this time to release more housing land in Cumbernauld where planned
expansion has been plan-led with significant releases allocated at South Cumbernauld (the
Community Growth Area) and Orchardton Woods.   
9.4 Traffic Congestion, Parking and Public Transport: Representations: Congestion is
currently experienced at key junctions and within the local road network including at
Craigmarloch and Broadwood local retail centres, local primary schools and St Maurice’s High
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School particularly during morning and afternoon commutes.  Development will generate
significant additional vehicle movements and parking issues at these locations. The recently
granted planning permission for 77 dwellings at the Croy Quarry site has already added
cumulatively to congestion. Congestion also occurs on the local road network as local
distributor roads are used as alternative routes when there are accidents, motorway
congestion or long-term maintenance works on the M80 motorway. The site is distant from
primary schools serving the area and would increasing road traffic to local schools. The
development will add to this congestion including by causing disruption during the construction
period. 
There is a lack of parking at Croy railway station with minimal land availability for additional
provision other than by a multi-storey parking solution. There is existing dangerous roadside
parking along Constarry Road and Strath Brennig Road some distance from the station.
Roadside safety fencing has exacerbated this issue by displacing some previously safer
roadside parking at the station to a wider local area.  There would be additional passenger
capacity issues on trains due to increased resident commuting if the application granted. Bus
services in the area are already limited and minimal in evenings and on Sundays. 
There would be an increased need for road maintenance due to increased traffic from the
development. There is already an Air Quality Management Area at the north end of the site
adjacent to Croy. Development would exacerbate air pollution including at the Antonine
Community Hub, Croy, where primary school children and others use the outdoor sport
facilities. 
9.5 Response. Existing congestion at sections of the local network are confirmed by NLC Traffic
and Transportation however the applicant has submitted proposals to improve flow on the road
network particularly addressing off-site issues at a key congestion point at Craiglinn
roundabout. This is discussed at the Planning Assessment section of the report. 
Passenger statistics indicated that passenger numbers using Croy Station had fallen since
Covid potentially due to an increase in home working however parking provision pressures
were confirmed by site visits in June and October 2024 when the station car park was operating
at capacity with some illegal parking within the car park although no roadside parking was
taking place beyond the car parks in roadside locations. The application does not propose to
provide additional parking provision other than to serve the residential development although
some of the site would be within walking distance of the station in reasonable weather
conditions. 
There are currently bus stops and services at Croy Station and along the B802 Constarry Road
and also bus stops along Eastfield Road to the south of Craigmarloch retail centre. 
Some disruption to traffic flows would be inevitable during site construction due to increased
construction traffic and physical engineering works off-site.  Road maintenance is prioritised
on the basis of need and the resources available to the road authority and subject to monitoring
inspections. 
The Air Quality Management Area mentioned was revoked in 2022 due to improved air quality. 
NLC Protective Services has recommended air quality monitoring prior to applications for
individual development phases adjacent to the existing main distributors road at the site
(B802). If permission in principle were granted these matters could be addressed by planning
conditions. 
Regarding the objection suggesting a mound of materials that may be pollutants, full site
investigations would be required at MSC application stage. 
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9.6 Road Safety :Representations. Concerns were raised regarding increased road safety risks
due to additional traffic along routes to schools at Constarry Road and Eastfield Road, at Holy
Cross Primary School, Croy, at the railway station, and towards the primary school campus
containing Cumbernauld and St. Andrew’s primary schools and also at other facilities south of
Eastfield Road due to a lack of bridge or underpasses and limited crossing points.  An objection
stated various new site residential roads would cross the east-west Core footpath (No. 90)
within the application site with associated road safety issues. 
9.7  Response. The applicant’s Indicative Strategic Framework document indicates only one point,
where Core Path 90 from Craigmarloch retail area to Croy station would be crossed. This is
by a distributor road between development phases 4 and 5. The applicant would, as part of
the detailed design process be required to consider the need for safe road crossing points and
pedestrian links from housing to core paths for each phase of the development. NLC Roads
and Transportation has requested an active travel plan for walking and cycling. With regards
to general road and pedestrian safety matters in the wider area NLC Traffic and Transportation
have not objected or highlighted any concerns.   
These matters could be addressed at MSC application stage if planning permission in principle
were to be granted. 
9.8 Education: Representations. The local primary and secondary schools that would serve the
application site have capacity issues. The development would result in temporary and sub-
standard accommodation provision in portacabins and huts. The projections for the number of
school pupils in the application submission is too low and is unrealistic. Holy Cross Primary
School in Croy is locationally nearer than existing catchment primary schools. The
development residents would seek placements there resulting in additional resource pressures
on that school. The developer should be required to pay for any addition educational provision
needed if planning permission is granted. 
9.9 Response. NLC Learning Services have advised there is not currently a primary school
capacity issue for schools serving the area. One secondary school, Our Lady’s HS, would
require additional modular accommodation. A developer contribution of £606,666. would be
required based on this 2022 assessment and would be subject to indexation to reflect future
inflation trends. 
if permission in principle were to be granted a legal agreement would require to be concluded
before planning permission is issued to secure the required developer contributions for
education.  
9.10  Environment, Landscape and Natural Hazards: Representations. 
Environmental Impacts. The site is designated as green belt. A significant area of one of
Cumbernauld’s last large open greenspace areas and this character would be lost. The
proposed mitigating planting does not have the same biodiversity value as established trees,
would take significant time to mature and does not compensate for the resultant loss of
landscape features, habitats and wildlife. Tree Protection Orders may be removed. The site
acts as a wildlife corridor and development will result in loss of this wildlife link and habitat. 
The application site is not only used by golfers but by many local residents for various uses
including walking, dog walking, other active exercise, enjoyment of open space and the natural
environment, with associated physical and mental health benefits This function was particularly
apparent during Covid lockdowns including for nearby residents in flatted property who do not
have gardens. 
There will be increased noise and light pollution, loss of residential amenity for existing
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properties and an adverse impact on mental health and wellbeing. 
The development is contrary to global, national and local policies to tackle climate change.
Brownfield land and sites should be used before greenbelt. Developers should be required to
install environmentally friendly technologies such as solar panels and heat pumps. 
One objection states that there is a mound of unknown material on site which may contain
pollutants. 
Landscape Impacts The proposal would result in coalescence between Croy village and
existing residential areas in Cumbernauld with no large open landscape between resulting in
loss of the area’s character, peace and tranquillity. The greenbelt landscape contributes to the
setting of the Antonine Wall World Heritage Site. Housing near the railway line and main road
would require bunds or fencing as noise protection resulting in further negative landscape
impacts. 
Flooding Impacts Areas of the site are susceptible to surface water flooding including of parts
of the existing road which the development will exacerbate which may also impact on existing
residents. 
9.11 Response 
Environment: It is acknowledged that an area of green belt would be lost and coalescence
between Croy and Cumbernauld in this current area of open space. This would represent a
significant departure from the development plan and for this reason the planning service is not
supportive of this development proposal 
In biodiversity terms, replacement tree planting and vegetation would take time to mature and
be colonised by associated species therefore not having the same positive biodiversity impact
as existing habitats. However, NLC Greenspace Services have requested ecological surveys
for each subsequent planning application for individual development phases in order that
protected species are identified and proposals and management can be provided or altered to
allow for biodiversity mitigation. 
The value of the site - not only for golfing - but as an asset for active exercise and the physical
and mental benefits associated with a natural/semi natural environment to the local community
is acknowledged. 
The issue of noise mitigation measures on the local landscape would only become clear as
applications containing proposed design detail and site layouts for individual phases of the
development were submitted, but, in addition to the impact of housing there is also potential
for positive or negative landscape impact by noise mitigation measures such as earthworks
(bunding) and acoustic fencing. NLC Protective Services have requested further noise
assessments once individual phase site layouts have been submitted.  These matters could
be addressed by planning conditions if permission in principle were to be granted. 
Regarding impact to the setting of the Antonine Wall World Heritage Site - the application is
not within the defined landscape protection buffer zone for the Heritage Site which was subject
to a consultation process with Historic Environment Scotland. Additionally, the archaeological
consultant employed by North Lanarkshire Council advises that the development would not
impact on the Heritage Site setting. 
Climate change - NPF 4 Policy 1 and Policy 2 relate to Tackling the Climate and Nature Crisis,
and Climate Mitigation and Adaptation. Policy 1’s policy intention is to encourage development
that addresses the global climate emergency which requires future Local Development Plan
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strategies to reduce, minimise and avoid greenhouse gas emissions and to support adaptation
to current and future risks by guiding development away from vulnerable areas. 
Policy 2 states development proposals should be sited and designed to minimise greenhouse
gas emissions. The policy does not specify the level of detail regarding these measures.
However, most developers now install solar panels as a matter of course although this is not
yet required by building regulations. Devices such as air heat pumps are normally left to
individual householders due to cost issues. Any detailed measures to address the above NPF
4 policies, for example to orientate buildings for maximum solar gain and to fit technologies to
reduce carbon emissions would be assessed at a detailed application stage and not at
Planning Permission in Principle stage.  A condition could be required for the developer(s) to
provide a statement of actions to address the policy objectives above. 
The North Lanarkshire LDP policy EDQ 3 a) regarding Development Quality requires
developments to move towards carbon reduction by reducing energy needs, provision for EV
charging points, reducing waste and resources use through effective storage and
collection/composting of waste and recyclable materials including the installation and
operation of low and zero-carbon generating technology. Such measures would be assessed
as part of assessment of applications for Matters Specified in Conditions level and a planning
condition to address this could be included in any Planning Permission in Principle. 
Regarding the representations submitted that the applicant should have sought a brownfield
site for development, NPF 4 Policy 9 Brownfield, Vacant and Derelict Land and Empty
Buildings is intended to encourage, promote and facilitate the reuse of such land and buildings.
The policy advises that Local Development Plans should identify such opportunities. Policy
9b) also states that proposals on greenfield sites will not be supported unless the site has been
allocated for development or the proposal is explicitly supported by the Local Development
Plan. This matter is discussed further at the Planning Assessment section of the report 
Landscape 
It is acknowledged that the proposal would result in a loss of open landscape between Croy
village and existing residential areas. The applicant has however submitted a Landscape and
Visual Impact Assessment (LVA) which aims to replace or compensate for losses of habitats
and landscape features such as trees and woodland. The applicant’s strategy also proposes
to use landscaping between development phases and around the site boundaries to break up
the urban visual impact of the development.   
The site is not within the designated landscape buffer zone for the Antonine Wall World
Heritage Site although the LVA advises that views from the Heritage Site would be minimally
affected due to the proposed landscape strategy. 
Bunding or fencing is acknowledged as being required along parts of the site boundaries within
the application’s Noise Impact Assessment. The nature of such noise buffers cannot be
confirmed until detailed MSC applications for individual phases are submitted although the
application submissions suggested willow fencing and bunding could include landscape
planting to mitigate landscape impacts. It is inevitable however that the currently relatively
tranquil nature of the golf course would be altered by the development of the site for housing. 
Flooding: Regarding flooding issues, SEPA has requested specific planning conditions to
address potential flood issues. NLC Protective Services have advised of a need for planning
conditions to require detailed site investigation for each phase of development which would
also provide data to address any potential flooding issues due to the mining legacy. 
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9.12 Housing Supply, Types and Tenure: Representations. Sufficient housing sites are already
allocated within the Local Development Plan, by the Local Development Plan housing land
supply review process including a Community Growth Area in the south of Cumbernauld. Other
representations suggest the site is not designated for housing and any provided will be luxury
housing unaffordable to many. Each previous new development in the area has been
increasingly expensive. Affordable housing is needed. 
9.13 Response. It is correct that the application site is not an allocated site for housing but is
designated as green belt. In terms of house prices, the planning process not directly in control
of these however it is correct that sufficient land has already been allocated in the Local
Development Plan to provide a continuous supply of housing for new development for the short
and medium term with regular monitoring to bring new sites forward if required for the longer
term. 
Regarding affordable housing, the Local Development Plan, affordable housing policy for the
Cumbernauld Area is that 20% of new dwellings within larger residential developments require
to be affordable. The applicant stated by e-mail dated 31st March 2023 that they would be
willing to provide up to 25% affordable housing which NLC New Supply (Affordable Housing)
have advised would be welcomed. 
9.14 Community Facilities: Representations received state there is a lack of sense of community
due to lack of local amenities; New estates have been built locally but with no community
facilities despite areas being designated for such within previous planning permissions. There
is therefore a lack of confidence in developer or Council’s ability to deliver these. Plans for
community infrastructure investment should be required. 
The only GP surgery and primary health facility north of M80 stopped accepting new patients
as it was oversubscribed. New residents have to go south of the M80 to Condorrat or
Cumbernauld town centre for GP appointments and the development will increase this
pressure There is also a lack of dental and veterinary provision. Cumbernauld (north of the
M80) needs a community centre and increased GP, dental and pre-school nursery provision. 
9.15 Response. A review of the local medical practice (Glen Medical Practice website) in 2022
confirmed that new patients were not being accepted. A more recent review of July 2024, (by
telephone call to surgery), confirmed the previous situation may have been due to unfilled
posts. The surgery was now accepting new patients but may have to restrict registration of
patients again if numbers become unmanageable. 
The applicant advises an area within the site will be reserved for community facilities such as
retail and medical or dental practices. The planning system is not in the position to deliver
shops, GP facilities or similar types of community facilities directly as these are within the remit
of other agencies or the private sector. However, it is possible through the planning
permissions process to negotiate for areas be reserved so that land is available to that market
to deliver the facilities/services.  If permission were to be granted, a planning condition could
be used to safeguard this area indicated for future community facilities and use. 
9.16 Legal Matters Regarding Land Title: Representations. The land is stated to have been
gifted to Dullatur Golf Club by Cumbernauld Development Corporation for a nominal fee
specifically for the public good or the purpose of creating a golf course. Also suggested in
representations is that there is a burden on the title (a restriction on the types of use of land)
which permits public or recreational use only and not development as proposed in the
application. 
9.17 Response. The applicants have stated on the application form that Hallam Land Management
are the sole owners of all the land. The Land Ownership Certificate within the same planning
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application form is signed on behalf of both Hallam Land Management and Dullatur Golf Club
hence the application has been registered as being by both parties. The legal status of the
land title, previous land titles or burdens on the title are not material planning considerations
for the planning authority but a separate legal matter which would require to be considered
separately by the parties involved should planning permission in principle be granted. If there
are burdens on the land title the landowner should address these matters prior to
implementation of any development. 
9.18 Representations from MPs and MSPs: 
Elected representatives also submitted comments including mentioning a survey of local
residents. Objections were received during the consultation period from: 
Stuart McDonald Constituency MP
Jamie Hepburn Constituency MSP 
Gillian MacKay List MSP 
The issues raised were similar to those raised by other participants during the neighbour
notification and public notice consultation period. 
Stuart McDonald MP and Mr Jamie Hepburn MSP’s joint submission advised of concerns
raised to them by constituents in terms of pressure on various infrastructure including schools,
roads, public transport and associated parking and medical facilities, the fact that the proposal
is contrary to Local Development Plan policy and regarding the scale of the development.
Additionally, the elected representatives stated that their latest survey with over 700 responses
indicated an overwhelmingly negative reaction to the development and similar developments
in the area and requested these concerns be considered by the Council.  The nature of the
survey quoted or when it had taken place was not stated. 
Gillian MacKay MSP raised similar concerns from constituents and also regarding increased
air pollution, loss of open space adverse impact on nature and that development should
minimise the use of private cars in favour of public transport and active travel to promote health
and tackle the climate emergency. 
All three have serious reservations about this development such that it is their shared opinion
that permission should not be approved. They point out that the site is not an allocated
residential site and also highlight concerns with regards to the scale and adverse impacts of
the development 
The matters raised by the elected representatives relating to specific policy areas are covered
in the responses above. 
9.19 Representations in Support of the Application: Comments received during the statutory
consultation period supporting the application are summarised below: 
Investment in the area should be welcomed, the developer has made provision for a
community facility and affordable housing within the development which is needed in
Cumbernauld. Employment will be created in construction and for local suppliers and council
tax income will be increased. 
Local schools are operating below capacity so there will not be pressure on schools however
the new development must include new provision for medical and community facilities. The
community hub site provides the opportunity for this and for more car parking provision at Croy
Stations. The council should ensure money generated by the development is spent locally to
provide community facilities.
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The occupiers of the new housing will create vacant housing elsewhere. The provision of a
community hub gives opportunity to increase local provision of GP, dental and community
facilities. The close proximity of the site to the station will reduce the necessity for private car
use and maximise public transport and active travel. The Council should ensure the money
brought by the development is spent local to provide facilities for the community. 
Response. If the development goes ahead new housing and affordable housing would
become available and construction and supply industries would receive investment although
the benefit in terms of specific local employment is not confirmed. The applicant’s have
submitted a Community Benefit Statement as required by NPF4 and the contents are detailed
below.  The developer has allocated an area for community facilities but has not specifically
included such facilities in the application.  Council tax revenue would increase from the
development increasing the number and value of housing stock however the need for
infrastructure and services investment would also increase. 
9:20  Late Representations 
As indicated above, a total of 97 representations were received outwith the statutory public
consultation period i.e. late (23 objecting and 74 in support). These were submitted in 2022,
2023 and 2024 well after those representations received as part of the formal statutory
neighbour notification and public notice in 2021. These recent representations do not represent
part of the statutory planning application assessment process but are included for purposes of
transparency and open government and to allow elected members and others to be aware of
the representations. The points of objection reflect the comments already received so are not
reiterated here. For information purposes the sources of the supporting representations are
detailed below. 
Just Build Homes – representations were received in June and July 2024 from a residential
lobbying organisation, “Just Build Homes”. These were on behalf of residents of various areas
of Cumbernauld.eg Abronhill, Blackwood and Carbrain. All but one of these supported the
application mainly citing a need for new affordable housing. One representation of those
submitted objected to the proposal. The responses forwarded by the lobbyist were individual
responses from residents. 
Scottish Golf submitted a letter of support dated 20th December 2022 that they were supportive
of the proposed development proposals to retain and grow membership and the proposals
within the Golf Club Improvement Plan submitted with the original application. 
Employees of Dullatur Golf Club – a number of letters of support in the form of a proforma
letter were submitted in August 2024 from employees of the golf club and advised the
development would support the continuation of the club and the employment of those signing
the letters.   
9.21 The planning service does not usually comment on representations which were submitted late. 
10 Planning Assessment 
10.1 In accordance with Section 25 of the Town and Country Planning (Scotland) Act 1997 planning
decisions should be made in accordance with the Development Plan unless material
considerations indicate otherwise. The Development Plan consists of the National Planning
Framework 4 (NPF4) adopted in February 2023 and the North Lanarkshire Local Development
Plan adopted in July 2022. Where there is incompatibility between policies, the policies within
NPF4 have precedence. 
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10.2 The site is designated as being within the Green Belt in the North Lanarkshire Local
Development Plan and is not an allocated housing site. As this is a Planning in Principle (PPP)
application, the key issue is whether the principle of the proposed use of residential
development is suitable for the site in policy terms unless other material considerations indicate
otherwise. 
National Planning Framework 4 (NPF 4). 
10.3 Policies within NPF4 which have relevance to the application and are assessed are: 
• Policy 1 Tackling the Climate and Nature Crisis
• Policy 2 Climate mitigation and Adaptation
• Policy 3 Biodiversity 
• Policy 6 Forestry, Woodland and Trees 
• Policy 8 Greenbelt
• Policy 9 Brownfield, Vacant and Derelict Land and Empty Buildings
• Policy 13 Sustainable Transport
• Policy 14 Design, Quality and Place
• Policy 15 Local Living and Local Living and 20-minute Neighbourhoods 
• Policy 16 Quality Homes
• Policy 20 Blue and Green Infrastructure
• Policy 21 Play, Recreation and Sport
• Policy 22 Flood Risk and Water Management 
These policies are assessed below. 
10.4 NPF4 Policy 1 - Tackling the Climate and Nature Crisis. 
The intention of this policy is to encourage and facilitate development that addresses the global
climate emergency and nature crisis with policy outcomes being to move towards zero carbon
developments and have nature positive places. 
The policy states Local Development Plans must address these outcomes by ensuring a
spatial strategy which will reduce emissions and adapt to current and future risks of climate
change by promoting nature recovery and restoration. Significant weight must be given to
impact of development in terms of these objectives. Proposals are to support policy aims of
conserving and recycling assets, supporting local living and delivering compact urban growth. 
10.5 Policy Assessment 
The Local Development Plan (LDP) had already incorporated many NPF4 Policy 1 objectives
through LDP policies and development site allocations including for residential development
within a wider and considered spatial strategy that seeks to direct development to allocated
sites and avoid development of green field sites through the promotion, reuse and
redevelopment of vacant and derelict sites.   
Specific to NPF4 policies the Design and Access Statement submitted by the applicant
confirms current building regulations for energy efficiency requirements will be met and
housing layouts be designed to maximise passive solar gain. Solar panels for energy capture
are not currently required by building regulations legislation but many developers provide these
to address climate change. The carbon surplus or deficit from such technology cannot be fully
quantified in a Planning in Principle application for a site of this scale since details of house
types, design and carbon capture measures would be provided at MSC (Matters Specified in
Condition) application stage for individual phases and since for a site of this scale there may
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be a number of different housebuilders/developers who will determine their own house designs
layouts and energy efficiency measures at MSC stage. 
The latest Chief Planner’s guidance letter issued 20th September 2024 outlines that the current
year’s Programme for Government will develop new guidance to support NPF 4 Policy 2,
Climate Mitigation and Adoption to integrate climate considerations into development
proposals, increase sustainable energy capture and minimise greenhouse gas emissions and
it is hoped such guidance will be completed to allow incorporation into the individual
development phases. 
Policy 1 objectives cannot be fully assessed until more detailed individual planning applications
are submitted with detail regarding woodland replacement and carbon capture and carbon
reduction measures. If permission in principle were to be granted, planning conditions could
be imposed at that stage to secure compliance with these NPF4 objectives and aims. 
However, this site is green belt and within the spatial strategy for the local development plan
there are allocated residential sites. There is considered to be no current argument that would
justify this site being developed before allocated sites. On this basis it could be argued that the
development proposed would undermine these policy aims 
10.6 NPF4 Policy 2 Climate Mitigation and Adaption 
The intention of this policy is to encourage, promote and facilitate development that minimises
emissions and adapts to the current and future impacts of climate change. 
Of relevance to this application, the policy states that development proposals will be sited and
designed to minimise lifecycle greenhouse gas emissions as far as possible and designed to
adapt to current and future risks from climate change. 
10.7 Policy Assessment 
Whilst such measures could be addressed at a detailed application stage if permission in
principle were to be granted, this development is significantly contrary to the local development
plan spatial strategy.  It is considered that there is no current argument that would justify this
site being developed before allocated sites. 
On this basis it could be argued that the development would undermine these policy aims.   
10.8 NPF4 Policy 3 - Biodiversity 
Policy 3 intentions are to protect biodiversity, reverse biodiversity loss, strengthen nature
networks and deliver these by positive development mechanisms. Policy outcomes should
enhance biodiversity with the objective of better connected and strengthened nature networks. 
Policy 3 a) requires development proposals to contribute to biodiversity enhancement, where
relevant restoring degraded habitats and creating nature networks and connections between
them. Nature-based approaches and solutions are to be applied. 
Policy 3 b) applies to major developments such as the application site and advises proposals
will only be supported where it can be demonstrated the proposal will conserve, restore and
enhance biodiversity assets to a point where they are in a demonstrably better state than
without intervention. Proposals are to consider existing site ecological characteristics, assess
potential negative impacts and provide suitable mitigation and biodiversity enhancements
along with arrangements for long-term monitoring and management of biodiversity assets. 
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The Preliminary Ecological Assessment submitted with the application surveyed the site during
an optimal ecological survey period in July and August (2021). The Assessment recognised
the sites’ biodiversity value including the Site of Importance for Nature Conservation (SINC)
and two woodland areas protected by Tree Preservation Orders. Other woodland areas, tree
belts and regenerating scrub including the valley of the east-west watercourse were also
confirmed as having biodiversity value or potential. UK protected species, (badger and several
bat species), used the site for foraging and feeding although permanent presence of bats was
not confirmed. Existing site habitats indicated presence or potential for a wide range of native
and migratory bird species, (over 20 species). NLC Greenspace advised that currently
unmanaged grassland areas had potential value for avian wildlife and UK protected species
of water vole and great crested newt. 
10.9 Policy Assessment. 
The ecological assessment provides recommendations including retention and enhancement
of identified valuable habits such as wildlife corridors the watercourse corridor, residential
street lighting guidance to minimise adverse impact to bat species, and protective measures
for the SINC. A list of further required surveys is recommended for future phases including a
bat protection survey, species surveys and a local Site Biodiversity Action Plan.  Most links
between existing green corridors would remain although some more isolated areas of existing
woodland and other habitat would be lost to development. The proposal avoids development
at the SINC and provides buffer areas and supplementary planting around both these and
locates sustainable urban drainage (SUDS) ponds or detention basins in areas adjacent to
existing habitats providing potential for additional habitat creation and enhanced biodiversity if
correctly managed. New woodland planting is proposed to augment remaining existing
woodland in the green corridors to create buffers between and around development phases. 
Land re-profiling which is required to create residential development platforms on the sloping
site, could have either positive or negative biodiversity impacts to habitats and species in the
long term but would have negative impacts during construction and in the short term afterwards
as replacement planting would take some years to compensate for habitats lost. 
Assessment by planning staff using site visits and aerial photographic reviews indicate that the
Indicative Development Framework layout represents an approximate equivalent replacement
area of habitat to that lost, although some existing woodland would be lost within some
development phases. 
At PPP application stage, details such as species mix to be planted and future management
are not available or outlined to allow fuller assessment of biodiversity impacts. If permission in
principle were granted further updated ecological surveys and protective measures would be
required for each detailed MSC planning application. A biodiversity replacement and
enhancement plan in the form of a local Site Biodiversity Action Plan is recommended at a
strategic level if Planning Permission in Principle were granted both for the overall
development, with more detailed requirements for each development phase. 
In conclusion, full assessment of impact in terms of this policy is complex and multifaceted
until the various factors affecting individual phases and proposed mitigation measures are
known. Overall impact cannot be fully measured without more detailed information although in
the shorter term there is potential of some biodiversity loss but a later gain if biodiversity friendly
species are used and a Site Biodiversity Action Plan prepared and implemented. 
It is noted that measures have been proposed to maintain and enhance biodiversity as required
by Policy 3 however this would require full commitment to implementation and future
management including funding by future developers. Overall, the application is assessed as
neutral in terms of Policy 3 impact.
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10.10 NPF4 Policy 6 Forestry, Woodland and Trees. 
The intent of this policy is to protect and expand forests, woodland and trees and policy
outcomes include protecting what exists and expanding woodland cover and sustainable
management of development sites. 
The policy requires Local Development Plans to fulfil these intentions and outcomes but also
to avoid habitat fragmentation and support ecological connectivity. 
Specifically, Policy 6 a) which advises development proposals that enhance, expand and
improve woodland and tree cover will be supported, 6 b) which seeks to safeguard woodland
of high biodiversity value and prevent woodland fragmentation and 6 c) which advises
proposals involving woodland removal will only be supported where they achieve significant
and clearly defined additional public benefits in accordance with government policy on
woodland removal. Where woodland is removed, compensatory planting will be expected. 
NPF4 Policy 6 advises that LDP spatial strategy is to identify and set out proposals for forestry,
woodlands and trees to meet these aims and should be supported and informed by an up-to-
date Forestry and Woodland Strategy. There is not currently a Forestry and Woodland Strategy
linked to the Local Development Plan since the LDP was adopted prior to this NPF4
requirement however there are LDP policies which address biodiversity protection and
enhancement in LDP policy EDQ1 Site Appraisal and policy EDQ3 Quality of Development,
specifically EDQ3 c). The aims of the policy as set out in National Planning Framework 4 Policy
6 are therefore addressed largely through existing Local Development Plan policies. 
10.11 Policy Assessment 
Policy 6 for Forestry, Woodlands and Trees is inter-related to NPF4 Policy 1Tackling the
Climate and Nature Crisis, and Policy 3 Biodiversity with many mutually supporting policy
objectives. 
The submitted Tree Survey and Arboriculture Report (June 2021) informed the development
masterplan layout. Over 1000 trees were surveyed and assessed in four categories. 15% were
classified category A (best quality) and 38% category B (good quality) and were recommended
for retention where possible, subject to those lost to development. Other poorer quality tree
categories (C and D) would only be removed if included within development proposals or for
safety reasons. 
Woodland areas protected by TPOs, trees along Constarry Road and at Craigmarloch retail
park and residential areas along with trees along the southern site boundary would all be
retained (the latter due to their screening function). Set-back distances between existing
mature trees and development, planting with viable native species to compensate for tree
losses and to enhance the post-development landscape character, are all proposed. The Tree
and Arboricultural report recommended a Woodland Management Plan be prepared for longer-
term maintenance and management. 
Site visits and aerial photography comparison to the Indicative Development Framework
indicates areas of established mixed woodland of approximately 1ha each would be removed
at development phases 2, 4, and 5 with more minor losses of smaller groups and individual
trees elsewhere on-site. However compensatory planting is proposed to replace these. 
Policy 6 a) aims to protect and expand woodland and forestry resources and ensure that
woodland and trees on development sites are sustainably managed. The development
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proposals do not expand the amount of woodland in the short term and appears to result in
some loss of woodland area but could improve woodland quality in biodiversity terms in the
longer term if appropriate native species are planted and managed.   
In terms of Policy 6b) the development does not propose loss of ancient woodland or trees or
significant fragmentation of existing woodland. Where fragmentation does occur,
compensatory planning is proposed. 
Policy 6 c) requires that proposals involving woodland removal will only be supported where
they will achieve significant clearly defined public benefits. The applicant has provided a
statement on what they perceive to be the community benefits arising from the proposed
development and these are discussed below. However, it is the planning authority view that
these are not sufficient to justify planning permission being granted. 
In conclusion whilst the proposal has the potential to comply with parts of Policy 6 it is assessed
as being at odds with 6 c) as there is not considered to be significantly clearly defined public
benefits arising.   
10.12 NPF4 Policy 8 Green Belt 
This policy intends to encourage, promote and facilitate compact urban growth and use of the
land around towns and cities sustainably. The projected policy outcomes are that development
is directed to appropriate locations, urban density increased, and unsustainable growth
prevented, the character, landscape, natural setting and identity of settlements are protected
and enhanced, nature networks are supported, and land is managed to help tackle climate
change. 
To achieve these outcomes NPF4 advises that Local Development Plans should use green
belts to support their spatial strategy to restrict development around towns and cities. Green
belts can be zoned where there is significant danger of unsustainable growth in car-based
commuting or suburbanisation of the countryside. 
Green belts are to be identified or reviewed as part of LDP preparation on an evidential basis.
This process has already taken place as part of preparation of the North Lanarkshire LDP
which was adopted in 2022 - and after the planning application was submitted.  
The applicant states in their submitted Planning Statement Addendum 3 (August 2024) that
they consider that the site is not countryside nor edge-of-settlement in character and is instead
a man-made, managed golf course within an urban area and that the application proposal is
an appropriate infill development and suitable urban extension, the implication being that the
site should not be designated as green belt in the LDP. 
The Addendum also contends that NPF4 Policy 8 supersedes the LDP and that Policy 8 states
that green belts are to be zoned around settlements where there is significant danger of
unsustainable growth in car-based commuting or suburbanisation of the countryside. The
applicant considers that the site and proposed development are located within a settlement
not outside it, surrounded by development, is not countryside in character, nor unsustainable
and has links to public transport and public transport facilities nearby and that following the
adoption of NPF 4 the applicant notes that the council website supporting text advises that
where there is incompatibility between the North Lanarkshire LDP and NPF4, that the latter
document will take priority. The Addendum acknowledges however that whilst the proposed
development does not fall within the list of exemptions identified within NPF4, the development
should be supported. 
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10.13 Policy Assessment 
The development proposal is not compatible with policy requirements of NPF4 Policy 8. The
Local Development Plan has allocated housing sites on the basis of need and demand and
prepared policies for the green belt at LDP Placemaking Policy 4 Green Belt, and its sub-
policies PP4 Purpose of Place and AD4 Amount of Development. However, NPF4 Policy 8a)
i) states that development proposals within a green belt designated within the LDP will only be
supported in a limited set of circumstances with many of the uses highlighted already included
in the Council’s LDP policies i.e.  for certain specified uses such as 
• development associated with agriculture, woodland and forestry, 
• residential accommodation for key workers, 
• horticulture, outdoor recreations and tourism uses and other uses which require a
greenbelt location. 
Just to be clear, large scale residential development (such as is proposed in this application)
or even modest scale residential developments are not included within the categories identified
as being suitable developments within the green belt. 
NF4 Policy 8a) ii) goes onto state that, in addition to fulfilling the above requirements in order
for a development to be supported, reasons should be provided as to why a green belt location
is essential and why development cannot be located on an alternative non-greenbelt site, and
the purpose of the green belt at the location would not be undermined, the proposal is
compatible with the surrounding established countryside and landscape character, the
proposal is of an appropriate scale and external appearance, and uses materials to minimise
visual impact to the green belt and that there will be no significant long-term impacts on the
environmental quality of the green belt. 
The application proposal does not comply with these criteria in terms of scale, visual impact -
in terms of being compatible with the surrounding landscape character, nor other specific
exceptional reasons mentioned at a strategic level for using the green belt. 
The open space area, including the two golf courses between Croy and Dullatur, represent the
last areas of green belt in north Cumbernauld between Constarry Road and Dullatur Road and
would occupy most of the remaining open space area between Cumbernauld and Croy at the
widest remaining section of greenbelt.  The green belt represents a community asset in terms
of landscape, natural setting and providing identity to settlements. It is an informal recreational
asset for surrounding established communities hence the Local Development Plan designation
and the reason that its status as green belt should be robustly protected. 
The applicants Addendum 3, at sections 3.4 to 3.12, argues that a submitted Diffley and Rettie
Report demonstrates that there is significant housing need within North Lanarkshire and that
the National Housing Emergency and intention to make housing a National Outcome elevates
the urgency of housing delivery to meet critical need. It is also argued by the applicant that: 
• The site is not countryside or edge of settlement but is a man-made, managed environment
within the urban area surrounded by development. 
• NPF4 Policy 8 Green Belt supersedes LDP Policy PP4 Purpose of Place Greenbelt. That
the LDP does not meet the principles of NPF 4 in that the NLC website states “where there
is an incompatibility between the LDP and NPF 4, the NPF4 will take priority” and that the
site represents a logical infill development within defensible man-made boundaries. 
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Whilst these comments are noted, this site is designated as green belt in the LDP and was
identified as such following the LDP preparation process and Report of Examination. As
indicated in the Representations section of this report, the application site was submitted in
response to the Consultation on the Modified Local Development Plan, as the applicant
objected to its green belt designation rather than the site being designated as a residential site,
and subsequently therefore the site was presented as an unresolved objection to the
Examination. However, the Reporters concluded that the site was not included in the LDP Main
Issues Report, had not been the subject of public consultation and had not been subject to
Strategic Environmental Assessment which the Reporters required. Accordingly, the site was
retained as green belt. 
It is the planning authority view that there is nothing in NPF4 in relation to green belts that
indicates that previously approved green belts should be set aside or reviewed except as part
of new LDP preparation. There is therefore no need to release more residential land and when
the next LDP is prepared consideration will be given to the guidance in NPF4 to determine
whether the green belt status of this site should remain. 
Even if the applicant’s assertion was accepted i.e. that this site should be regarded as part of
the urban area and not green belt, the site would still be offered significant protection as part
of the urban green network and LDP Policy PROT A4 would then require to be assessed. 
In conclusion, the development fails to meet the objectives of NPF4 Policy 8 to increase urban
density, is not directed to an allocated residential site, and is considered unsustainable as it
would undermine the green belt objectives for which the land is designated. There are no
material considerations that justify development of the site.  The development proposal fails to
meet both NPF4 Policy 8 Policy Intent and Policy Outcomes. As such the application should
be refused for these reasons 
10.14  NPF4 Policy 9.  Brownfield, Vacant and Derelict Land and Empty Buildings 
The intent of this policy is to encourage, promote and facilitate the reuse of brownfield, vacant
and derelict land and empty buildings, and to help reduce the need for greenfield development
with policy outcomes that include that development is directed to the right locations,
maximising the use of existing assets and minimising additional land take. 
The Policy requires Local Development Plans to set out opportunities for sustainable reuse of
brownfield land including vacant and derelict. These objectives were considered, policies
prepared, and sites identified within the LDP prior to publication of NPF4 however an
assessment of relevant NPF4 issues is given below. 
10.15 Policy Assessment 
Policy 9 directs focus to maximising brownfield development opportunities. The application
proposal in this context does not represent the reuse of a vacant brownfield site within an
existing urban area and does not therefore address the issue of reuse of vacant and derelict
land nor does it comply with Policy 9 due to its location within the green belt and at a site not
allocated for residential development in the local housing sub-market area. The purpose of
Policy 9 is to direct development to allocated sites and the reuse of brownfield and derelict
sites before greenfield.   Specifically, Policy 9b) states that proposals on greenfield sites will
not be supported unless the site has been allocated for development or the proposal is
explicitly supported by policies in the LDP. This is not the case for the application site. In
conclusion the application proposal is considered to be contrary to NPF4 Policy 9. 
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10.16 NPF4 Policy 13 - Sustainable Transport 
The intent of this policy is to encourage, promote and facilitate developments that prioritise
walking, wheeling, cycling and public transport for everyday travel and reduces the need to
travel unsustainably, to support connectivity and reflect place-based approaches and local
living to provide more, better, safer and more inclusive active and sustainable travel
opportunities. Developments should be in locations which support sustainable travel. 
NPF4 advises Local Development Plans to prioritise locations for further development that can
be accessed by sustainable transport by making best use of existing infrastructure and
services to reduce car dominance. Policy 13 is supported and is inter-related to NPF4 Policy
15, Local Living and 20 Minute Neighbourhoods 
Policy 13 b) advises development proposals will be supported that demonstrate that transport
requirements have been considered in line with sustainable travel and they provide direct,
segregated safe links to local facilities for walking, wheeling and cycling including by
introducing such travel networks, are accessible to public transport ideally existing services.
Development should also incorporate safety measures including safe crossings and reduce
the number and speed of vehicles and take account of transport needs of diverse groups to
ensure safe and easily accessible use. The policy is also to mitigate against any impacts on
local public access routes. 
Policy 13 d) advises that proposals for significant travel generating uses will not be supported
in locations which would increase reliance on the private car taking account of specific
locational characteristics and Policy 13 g) requires that development proposals fully assess
impact on the Strategic Transport Network. 
Other outcomes of the Policy would apply more to detailed planning application phases, for
example the provision of electric vehicle charge points and are therefore not assessed at the
level of assessment for a Planning in Principle application. 
10.17 Policy Assessment   
The applicant considers the site is appropriate as it is near the railway station, bus routes and
a local retail centre for convenience shopping.  This would allow residents to benefit from the
use of these facilities. In this respect the development had locational advantages in terms of
the sustainable transport options available. 
Objections from residents however raised a number of concerns. These relate to the frequency
of bus services and the lack of these, particularly in evenings and on Sundays, a perceived
issue of lack of parking at Croy Station leading to roadside parking, congestion and road safety
concerns. 
It is assessed that while sustainable transport facilities are within the locality access to these
would be difficult for the elderly and those with restricted mobility requirements. There is also
however potential for residents of the proposed development site to use cars when accessing
the railway station, dependant on where they reside within the site, exacerbating any existing
parking problems.  The development has not incorporated any proposals to provide additional
station car parking to address this potential issue. 
The applicant has indicated that within the site path networks would allow sustainable access
from the development to local sustainable transport facilities and would be required to provide
safe crossing points across Constarry Road to link into the wider active travel network. 
Matters of reducing speed can be built into detailed design for the distributor road and internal
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road network, as could measures which as far as possible ensure safe and easily accessible
use of active travel network 
The applicant has considered and taken measures to mitigate and safeguard against adverse
access impacts to the existing path network by safeguarding Core Path routes 74 and 90
although the character of these routes in landscape terms would alter due to the development. 
In terms of fully assessing the impact on the road network, the applicant has carried out
modelling studies of the wider local road network. This has indicated that traffic generated from
the development site at completion without appropriate mitigation measures would impact
adversely at the Craiglinn roundabout junction which already experiences congestion at peak
times. The applicants traffic modelling has however produced a solution in terms of rephasing
the traffic signalisation at this junction along with alterations to exit roads from the junction to
improve traffic flow. Based on the modelling this solution has been analysed and accepted by
NLC Traffic and Transportation with a requirement that the works are implemented prior to
development commencing on site, and that the applicant implements and funds the necessary
works. 
In conclusion, the applicant has demonstrated that the transport requirements generated have
been considered in line with the sustainable travel policy and by investment can address the
requirements of Policy 13 by measures already planned, agreed or which can be delivered by
planning conditions for detailed development phase applications. 
10.18 NPF4 Policy 14 Liveable Places. Design, Quality and Place 
The intent of this policy is to encourage, promote and facilitate well-designed places by a
design-led approach and applying the Place Principle which focuses on six qualities of
successful places with the outcome of ensuring that the qualities of healthy, pleasant, distinct,
connected, sustainable and adaptable places are delivered. 
10.19 Policy Assessment 
Policy 14 states that development proposals should be designed to improve the quality of an
area regardless of scale.  Proposals will be supported if the development is consistent with the
six qualities above. In the case of this objective Local Development Plan polices EDQ 1-3
(Environmental Design Quality policies) are also key considerations and are discussed later. 
As the proposal is an In Principle application the detailed design at a local level cannot be fully
assessed at this stage.  However, at a strategic level the applicant has considered existing
features such as natural habitats and existing key footpaths and measures to protect or
compensate for these such as where habitat is lost to development. The current landscape
would clearly be significantly altered were the development to proceed. However, if planning
permission in principle were to be granted there is potential within the application site to create
an attractive environment and for developers to devise layouts that could deliver on the six
quality of place objectives. Having said this, the development of the site would inevitably result
in there being an impact and an erosion of the quality of place through the loss of green belt
land that existing residents in the locality currently enjoy. 
In conclusion, the proposal is assessed to have the potential to comply with Policy 14
objectives although matters of detailed design and layout would require further assessment
during applications for detailed design phases which could be subject to planning conditions
in any permission in principle that may be granted. 
Matters of detailed development design quality are assessed further within the Local
Development Plan section of this report at the section assessing LDP policies EDQ 1-3
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(Environmental Quality) policies. 
10.20 NPF4 Policy 15 Local Living and 20 Minute Neighbourhoods 
The intent of this policy is to promote and facilitate the Place Principle to create connected,
compact neighbourhoods where residents can meet most daily needs at a reasonable distance
from home, preferably by walking, cycling or using sustainable transport. An additional aim is
to increase community engagement within local areas by focusing on the daily needs of
communities in their local areas. 
The policy outcomes are that development creates high-quality, accessible, mixed-use
neighbourhoods, which support health and well-being, reduce inequalities and that new and
existing communities are planned together with homes and key local facilities such as schools,
community centres, shops, greenspaces, health and social care and digital and sustainable
transport links. 
Local Development Plans are to support the policy through mechanisms such as spatial
strategy and masterplans with the 20-minute approach taking account of the settlement pattern
and the characteristics and challenges faced in each place. 
Scottish Government Planning Guidance for Local Living and 20-minute neighbourhoods (April
2024) advises the timeframe of 20 minutes is research-based examining health, design and
site planning, and therefore ease of access to local services, infrastructure and community
spaces based on an approximate 10-minute walk to any destination and 10-minute return
journey i.e. A 20-minute round trip. Such trips vary based on factors such as quality of walking
environment, individual age and ability, and topography and by the distance people are willing
to walk, wheel or cycle to access. The 20-minute timeframe is an approximate guide and does
not rigidly define the term local living. 
10.21  Policy Assessment 
Whilst being significantly contrary to the spatial strategy of the local development plan, the
application site is relatively well-placed to access the benefits of local living with Croy Station
to the west and Craigmarloch retail area (containing a supermarket, pharmacy, hairdressers
and hot foot takeaway) to the east and further to the west shopping facilities at Broadwood
Retail Park. 
The site is sizeable being approximately 600 m wide from east to west and 650m from north
to south however, and greater walking and cycling distances would be involved taking account
of future road and path layouts. The site slopes generally downhill from east to west with some
undulating sections which would add to journey times and as such some areas in the south
and east of the site are not a 10-minute one-way walk from the station and main bus route at
Constarry Road, nor are some areas in the west, north and south of the site within ten minutes
of the Craigmarloch retail facilities. Local primary school provision for the site is again some
distance being further along Eastfield Road. 
Assessment of Policy 15 therefore is that whilst some areas of the site benefit from proximity
to either of these retail and transport nodes other areas do not, particularly for a proportion of
future residents who may have more limited mobility. That said it is acknowledged that whilst
the site is perhaps no worse located than other existing neighbourhoods in this part of the town
it is the case that those developments predate the advent of NPF4 and NPF4 Policy 15.
Crucially where those sites differ to the application site, the sites were planned additions to the
housing supply and were plan-led.  So, whilst not strictly being within the definition of a 20-
minute neighbourhood, the site could benefit from some of the advantages of local living.
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However, this of itself is not sufficient to override the other more fundamental policy failings of
the site. In particular, the development of this site is significantly contrary to the spatial strategy
of the LDP which has the site as protected green belt and there is no justification sufficient to
permit the site being developed for residential purposes at this time.         
10.22 NPF4 Policy 16 Quality Homes   
The intentions and outcomes of this policy are to promote and facilitate delivery of high quality
affordable and sustainable homes in the right location with a range of tenure choice to meet
diverse housing needs, and places that contribute to well-being of communities, supported by
appropriate infrastructure, providing energy efficient greener homes and tackling issues such
as fuel and child poverty. 
The policy supports new homes on land allocated for housing in Local Development Plans and
sets out various requirements including meeting local housing requirements, providing or
enhancing local infrastructure, local facilities and services, and maintaining or improving the
residential amenity of the surrounding area 
Relevant subsections of Policy 16 advise that: 
16 a) Development proposals for new homes on land allocated for housing in LDPs will be
supported.  
16 b) Development proposals over 50 homes should be accompanied by a Statement of
Community Benefit which meets local housing requirements including affordable homes,
provide or enhance local infrastructure facilities and services, and improve residential amenity
of the surrounding area. 
16 c) Development proposals for new homes that improve affordability and choice by being
adaptable to changing and diverse needs and addressing gaps in provision would be
supported. 
16 e) Development proposals for new homes will be supported where they make provision for
affordable homes to meet an identified need. Proposals for open market, (i.e. private-for-sale),
homes will only be supported where the contribution to the provision of affordable homes on a
site will be at least 25% of the total number of homes, unless the LDP sets out locations or
circumstances where higher or lower contributions can be justified. 
Policy 16 f) importantly advises that development proposals for new homes on land not
allocated for housing in the LDP will only be supported in limited circumstances where: 
i) the proposal is supported by an agreed timescale for build out and, 
ii) the proposal is otherwise consistent with the plan’s spatial strategy and other relevant
policies including local living and 20-minute neighbourhoods 
iii) and either: 
• delivery of sites is happening earlier than identified in the deliverable housing land
pipeline determined by reference to two consecutive years of the Housing Land
Audit evidencing substantial delivery of new housing earlier than pipeline
timescales with a general trend being sustained; or 
• the proposal is consistent with policy on rural homes, or 
• the proposal is for smaller scale opportunities within an existing settlement
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boundary; or 
• the proposal is for the delivery of less than 50 affordable homes as part of a local
authority supported affordable housing plan. 
10.23  Clarification of NPF4 Policy 16 Interpretation provided by the Chief Planner Letter of
26th June 2024 and Subsequent Applicant’s Addendum 3. (August 2024). 
Following a Court of Session judicial review regarding a planning application for an unallocated
green belt site in West Lothian, further national planning guidance entitled Planning for
Housing was issued by letter on 26th June 2024 by the Chief Planner, Dr Fiona Simpson and
Ivan McKee MSP, Minister of Public Finance.   
The letter advised that NPF 4 Policy 16 required to be considered in terms of all its various
criteria i.e. sub-sections 16 a) to 16 f), and not only the Policy 16 f) criteria which only allowed
release of unallocated sites in specific exceptional circumstances. 
Following issue of this guidance the applicant submitted a further Planning Statement
Addendum, (Addendum 3), stating that Policy 16 f) criteria should therefore not be the only
consideration in determining compliance with Policy 16 where an application site is
unallocated, and that all Policy 16 criteria (and indeed all NPF4 Policies) should be assessed
as the updated Chief Planner guidance raised further significant material considerations
applicable to the application. 
The applicants Addendum 3 stated that whilst the Court of Session upheld the W. Lothian and
the Scottish Government Directorate of Planning and Environmental Appeals, (DPEA),
decision to refuse that application, the Court also confirmed only how Policy 16 f) should be
applied but not the other criteria of Policy 16 as the Court of Session judgement focused only
on Policy criteria 16 f) as a consideration and did not specifically provide comment or
interpretation of other criteria within Policy 16. 
The Addendum submitted by the applicant takes the view that the new Housing for Planning
guidance of 26th June 2024 states a development proposal is not contrary to the Development
Plan just because there is conflict between individual policies within it, (in this case the National
Planning Framework policies of the Development Plan and specifically NPF4 policy 16), and
that since there is no hierarchy of policies, no one part of a policy should outweigh others and,
on that basis, a balanced judgement of all policies and all criteria and sub-sections within a
policy should be made when assessing applications. 
The Addendum specifically mentions Policy criteria 16 c) which states support for proposals
for new homes on sites which improve affordability and choice, and which crucially identify
gaps in provision of accessible, adaptable and affordable housing, new rented housing,
supported and care homes provision and more specialised categories such as student or
military personnel accommodation. 
The applicants Addendum noted that the Planning for Housing letter advises that the Scottish
Government has recently declared a national housing emergency and that the First Minister
had confirmed an intention to engage constructively to expand housing supply to tackle
homelessness and having an all-tenure approach which diversifies supply to achieve these
priorities, the applicant’s assertion being therefore that the National Housing Emergency
declared on 27th May 2024 is a significant material planning consideration requiring action
across all parts of Scotland. 
A number of Scottish local authorities have declared local housing emergencies following the
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National Housing Emergency declaration. These include neighbouring local authorities of
Glasgow City, West Lothian and South Lanarkshire. Declaration reasons vary but include
pressures on homelessness services, lack of affordable houses, long waiting lists and high
temporary accommodation households. (Scottish Parliament Information Centre: SPICe
Spotlight, 27th June 2024). 
The applicant’s Addendum asserts there are very significant gaps in housing provision in North
Lanarkshire and provides a series of figures for the Council area from a report titled Existing
Housing Need in North Lanarkshire, (January 2024), by The Diffley Partnership and Rettie and
Company consultants who were commissioned by Homes for Scotland the organisation
representing housebuilders in Scotland. The survey suggests that around 32% of households
are in some form of acute housing need which the report defines under categories including
concealed households, inability to afford an existing occupied household, overcrowding, a
need for housing adaptation or housing in poor condition. 
The applicant’s Addendum also proposed an analysis of housing provision in North
Lanarkshire based on published Council documents i.e. the Local Development Action
Programme (LDAP) (September 2022) and the Housing Land Audit (HLA) for 2023 (March
2023) stating that the LDAP had a majority of sites which are not programmed for delivery, or
programmed sites for early delivery which were disputed by Homes for Scotland and stated
that as a consequence  of the National Housing Emergency additional unallocated sites should
be given more significance when assessing planning applications. 
10.24 Policy Assessment (Housing Land Supply Commentary) 
From the outset it is important to note that there is no specific guidance from the Scottish
Government regarding how the National Housing Emergency applies locally however the
government programme for 2024-25 mentions the housing emergency stating that the
planning system will respond to the housing emergency by allocating a land pipeline for new
homes and promote consistent monitoring and delivery. Crucially, North Lanarkshire has not
declared a housing emergency. 
The matters raised within the applicant’s Planning Statement Addendum 3 regarding the
national housing emergency and North Lanarkshire Council’s current housing land supply and
delivery position and the Chief Planner/Scottish Government updated guidance letter of 26th
June 2004 implications for NPF 4 Policy 16 are assessed below.   
• Scottish Government - National Housing Emergency (declared 27th May 2024). Whilst a
number of Scottish local authorities have declared a local housing emergency to date,
North Lanarkshire has not.  However, analysis by the Planning Service in conjunction with
Housing Services indicate that there are sufficient allocated sites allocated for private
housing and programmed to meet this demand during the time periods set by Scottish
Government guidance. In areas with an identified need for affordable and social housing,
such as the Cumbernauld housing area, allocated sites for larger-scale private housing
developments are required to provide a minimum of 20% affordable housing by LDP Policy
CI - Contributions to Infrastructure. 
• North Lanarkshire Council Housing Land Availability and Delivery – the applicant’s
Planning Statement Addendum 3 states that North Lanarkshire Council has significant
gaps in housing provision and the applicant therefore uses a national survey commissioned
by Homes for Scotland, Existing Housing Need in North Lanarkshire, (January 2024), to
justify this statement.  The local authority position in contrast is based on housing need
and supply audits, site commencement and house completion monitoring and regularly
reviewed projections to maintain a housing supply “pipeline” of new sites which is as
required by NPF 4 Policy 16. This is to provide transparency regarding phasing of housing
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for the short term (1-3 years), medium term (4-6 years) and long term (7–10 years). The
annual Housing Land Audit (HLA) monitors housing delivery to inform the pipeline and
guide necessary interventions in terms of inclusion of new sites or de-selection of sites
now considered non-deliverable. An updated Action Programme in the form of a Delivery
Programme has been prepared with a target date of submission to the December 2024
Planning Committee. The draft Housing Land Audit 2024 is being completed in consultation
with Homes for Scotland. 
• North Lanarkshire’s housing land position is considered sufficient at present, exceeding
the Minimum All-Tenure Housing Land Requirement, (MATHLR), set by Government in
Annex E of National Planning Framework 4, of 7,350 units over a 10-year period. The
finalised 2023 Housing Land Audit to 31st March 2023) is the Council’s most up to date
land supply position and the established housing land total for North Lanarkshire is 17,318
units, of which 8,646 units are programmed as deliverable over the next 7-year period.   
The applicant’s Addendum’s position that the report commissioned by Homes for Scotland
Existing Housing Need in North Lanarkshire, (January 2024) indicates a significant gap in
housing provision is therefore not accepted by the planning authority.  Additionally, both
Fife Council’s and Moray Council’s Local Development Plan Evidence Reports when
reviewed by different Scottish Government Reporters found that although the report
provided some indication of the scale of potential need in each area based on primary data,
it did not represent a robust alternative or additional evidence that those councils needed
to rely on. 
The Scottish Government wrote to planning authorities in parallel to the Planning for
Housing guidance letter to require that local development plan action programmes be
reviewed, updated and republished as Delivery Programmes by 31 March 2025 to ensure
Action Programmes included sequencing and timescales for housing sites delivery within
LDPs. 
The annual Housing Land Audit will monitor the delivery of housing land to inform the
pipeline and the actions to be taken in the Delivery Programme. The Delivery Programme
will be reviewed every two years, and the review represents an opportunity to re-evaluate
sites, including whether these sites can be delivered earlier in the plan period. The Delivery
Programme sets out where action is needed to overcome identified constraints 
The guidance within the Housing and Planning letter requires local authorities to review
the deliverable housing land pipeline and update delivery programmes by 31 March 2025.
The Planning Service is progressing this by preparing an Action Programme which will
become a Delivery Programme with a view to this matter being reported to the planning
committee in due course. 
As recently as 12th November 2024, the Scottish Government Published its ‘Planning and
the Housing Emergency - Delivery Plan’. In this the Government advise that they have
reformed Scotland’s planning system to strengthen a plan-led approach to development.
They indicate that NPF4 sets out a strong vision for the future and includes a single set of
national planning policies which is now being applied to all planning decisions. They advise
that National planning policy is clear that planning applications will be supported in
principle, where they are on sites allocated in local development plans. In particular, the
Government advises that NPF4 signals a move away from past practice which allowed for
additional land, which is not supported by plans, often in more easily developed, greenfield
locations, to be released if insufficient land for housing was available. 
The context for the statement is that, according to the Scottish Government, across
Scotland there are sites with planning permission that could deliver more than 164,000
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homes but are not, and they set out measures to identify the reasons for this, and actions
to be taken to support delivery. The Government’s short-term objectives are identified in
this plan and the allocation of additional land in response to the housing emergency is not
a solution identified or supported in this delivery plan. 
In conclusion, the planning authority consider that there is no present need for this
unallocated green belt site to be brought forward. Of course, circumstances may change
going forward but the release of the site should be plan-led and the applicants should
engage with the council in the preparation of North Lanarkshire Local Development Plan 2
process (NLLDP2) which has been commenced 
10.25 Policy Assessment 
An assessment against Policy 16 follows below: 
Policy 16 a) states development proposals for new homes on land allocated for housing will
be supported. The application site is not allocated and the proposal represents a significant
and unjustified departure from the plan and its spatial strategy. 
Policy 16 b) The development proposal is accompanied by a Statement of Community Benefit
which explains the contribution the development will make towards the three specific criteria 
With regards to Policy 16 b) i. meeting local housing requirements including affordable homes.
The applicant has indicated their intention to contribute towards affordable housing at 25%
which is more that the LDP requirement of 20%. This is not of itself considered to be sufficient
to lend support to the development   
Policy 16 b) ii. requires that the development provides or enhances local infrastructure,
facilities and services. Beyond mitigation of the direct impacts (education contributions etc of
the development which would also be a requirement of an allocated residential site), the
applicant has indicated a willingness to set aside part of the site that could be used for
community facilities such as shop units and the golf club has indicated improvements that it
will make to the course and club and to allow wider community access. The Craiglinn
interchange improvements, whilst required to mitigate extra traffic arising from the
development, is projected to improve traffic flows through the junction. Again, this is not
considered to be of sufficient benefit to justify support for the development. 
Policy 16 b) iii. advises that development should improve the residential amenity of the
surrounding area. The surrounding residential areas currently look onto open space at the
application site in the form of a golf course with groups of trees and other habitats. The
applicant has advised that tree cover around the edge of the site will be retained or enhanced,
and compensatory planting take place where vegetation and habitat is lost to development. In
this respect whilst views in terms of contribution to residential amenity are subjective, the
impact on the surrounding area is considered to be either as an adverse or at best no better
than what it replaces. This is reflected in the objections received. Overall, in terms of impact
on amenity it has to be acknowledged that as this is a planning application in principle there is
a lack of absolute detail to be able to come to a fully considered view on the impact on
surrounding residential amenity. However, as the site is identified as being green belt and
given the scale of the development proposed, it is difficult to see how this will improve the
residential amenity of the surrounding area. 
To support the application, the applicant submitted a Landscape and Visual Impact
Assessment (LVA) which advised that the site’s visibility is largely contained within the
immediate local area due to its location and the site’s rolling, undulating landform. 
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The LVA identified landscape features and key viewpoints into the site likely to be affected by
the development and identified impacts on landscape and visual amenity and measures to
mitigate these including during the construction period.  The loss of existing landscape,
introduction of new landscape features and matters such as impact of lighting at completion of
the development to avoid significant light pollution were also highlighted. 
The LVA advised that the site is already partially or largely screened by belts of woodland on
three sides with only views from the north adjacent to the railway particularly open. However,
at other points to the south- west and west the site can actually be seen from areas of higher
ground, for example from parts of the Smithstone residential area. 
Sensitivity to landscape change was measured from High meaning the site was vulnerable to
small changes, through to Low sensitivity which would apply to areas of low quality where
change can be positive. The assessment considered how development would impact on the
landscape overall, community facilities, e.g. open space and paths, the Green Belt, the natural
environment, the nearby built and historic environment and adjacent residential areas. 
Loss of open space by removal of part of the golf course was acknowledged however the
assessment advised that the proposal includes around 30% of remaining open space and
would retain recreational resources for new residents and existing communities by retaining
the existing core paths and other informal routes and adding other site-wide paths, many of
which would follow the proposed interlinked green corridors. Open space areas would be
created to compensate for loss by the creation of a large centrally located community park,
and a smaller park in the south of the site with other interspersed open space around the site
– although the council’s Play Services has raised concerns regarding the location of the larger
park and responsibility for future maintenance is not confirmed. 
The LVA argued that the site, rather than being typical green belt, has a strong urban context
being within the urban edge of Cumbernauld with existing development to the west, east and
south-east and the Edinburgh to Glasgow railway line enclosing the northern boundary, and
that the enhanced landscape framework would support a more robust, re-aligned Green Belt
boundary consolidating the edge of the built up area at the railway line and strengthening the
urban/rural boundary along its northern boundary. 
The LVA acknowledged the conservation value of areas of ecological and green network
importance, the SINC, small mature tree groups woodland belts and links to the wider green
network area. However, the assessment also acknowledged that the proposed residential
development would require the loss of some of these features due to necessary site-wide
cutting and filling and earthwork re-modelling operations to create housing development
platforms, hence the need for a compensatory site-wide landscape strategy should permission
in principle be granted. 
The key built cultural feature potentially affected is the Antonine Wall as the site would be seen
from Croy Quarry 300m to the north and from more distant Croy Hill which is partially located
within the designated World Heritage Site boundary. The application emphasis on an
integrated landscape strategy around and interspersed within development phases and
sensitive orientation of some dwellings could minimise visual impact from the nearby Croy
sporting hub and from the area having World Heritage Site status. 
The LVA assessed impact on adjoining residential areas as being mitigated by the landscape
strategy and the existing trees and the trees and wider tree belts along the west, south and
east of the site boundary. Sensitivity to change is considered low from the edge of the
Smithstone area and Constarry Road at the west although from Croy to the north sensitivity to
change is considered higher but impact was assessed as moderate or moderately adverse
during construction, and more beneficial in the long term. At the east towards Craigmarloch
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visual impact is assessed as being less due to existing screening. In summary the LVA
considers the overall short terms impacts to be moderate or slightly adverse but generally
visual beneficial in the longer term after site completion and as the landscape features mature. 
In response the planning authority consider that the site is not allocated for residential
development in the LDP, as sufficient land has been allocated for housing in the local area and
across the whole of the council area. Should there be a financial burden in maintaining this
part of the golf course and the club wished to reduce to a nine-hole course, the maintenance
of this area could be removed to allow regeneration to a natural condition until such time as it
may be necessary to develop the site. 
In summary, from a planning authority perspective the applicant’s Indicative Development
Framework Plan, Landscape Visual Assessment (LVA) and other supporting information
shows (amongst other measures) the retention of green corridors around and through the site
as a means of mitigating the impacts. However, the impact on the green belt would be
significantly less if all that was involved was taking part of the course out of play rather than
being developed for housing. There is considered to be no justifiable reasons for the release
of this land for residential purposes. Therefore, whether or not the proposed mitigation
measures are sufficient to comply with the policy are largely academic. 
Policy 16 c) advises that development proposals which improve affordability and choice, are
adaptable and cater for diverse needs and address identified gaps in provision are supported. 
The application proposal could provide for such needs however the published housing land
supply and demand figures including the Housing Land Audit and Housing Action Programme
advise that there are not identified gaps in provision. 
Policy 16 d) refers to development proposals for traveller sites and is not relevant to this
application. 
Policy 16 e) states that proposals for affordable homes to meet an identified need will be
supported. Housing Land Audit and Housing Action Programme projections do not identify a
need at present. In the case of private market housing provision this policy states that unless
local circumstances can justify differently at least 25% affordable housing would be required
as part of the proposal which the applicant has stated they would meet (the Council’s LDP
policy requirement is for 20%). 
Policy 16 f) refers to new homes on sites not allocated in the LDP and the limited
circumstances in which these will be supported. This part of the policy supersedes PROM LOC
3 of the LDP – Housing Development Sites, which included an ‘exceptional release’ policy
where there was a shortfall of housing in the Housing Land Supply. 
In order to activate Policy 16 f) to justify a release of non-allocated land a proposal would need
to be deemed to comply with branches (i) and (ii) and at least one of the four factors listed in
branch (iii). 
With regards to Policy 16 f) i in April 2024 the applicant provided information on the build out
projections for the site which indicated a timeline from obtaining consent to the completion of
the first new home and until final completion of the development. This timeline (including the
conclusion of a S75 legal agreement to allow the consent to be released), a first MSC
application being submitted four months later, this being determined by the Council three
months after that. Then starting on site with the first completed home being ready within 16
months of permission in principle being obtained and the whole application site being complete
within 6 years. 
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In addition, the applicants forwarded letters on 29th April 2024 from the following housebuilders
or development interests supporting the application as a site they would consider developing
:Cala Homes, Miller Homes, Barratt Homes, Bellway Homes, social housing provider
(Sanctuary Homes), and Places for People Scotland, also representing housing providers,
developers and property interests. 
Whilst developer interest is acknowledged this is not surprising as Cumbernauld and the
Northern Corridor have always been a preferred location for developers as sites are more often
than not green field in nature and easier to develop than brownfield sites (acknowledged by
the applicant who advise that they view the site as being free from insurmountable constraints). 
With regards to the applicant’s indicative projections for the grant of planning permission and
build out programme this is considered not only unrealistic but also overly optimistic by the
planning authority (particularly as this level of delivery, 110 units per year, is not being achieved
on any housing site in North Lanarkshire).  In any event, as there is no current need for the
site and the developer indications of support for developing the site are not considered relevant
in planning terms during the current LDP lifecycle.   
In relation to Policy 16 f) ii – the site is allocated as green belt so the application does not
comply with the local development plan spatial strategy and given the scale of the development
it is significantly contrary. In addition, the site does not fully comply with the Local Living and
20-minute neighbourhood  policy as, whilst achieving in part a level of compliance with the
Local Living objective, the scale of the site and distances from both local facilities at
Craigmarloch retail centre and accessible public transport at Croy Station and local bus routes
are more than 10 minutes in each direction from a significant proportion of the proposed
housing areas within the site.   
As indicated above, proposals need to satisfy both 16 f) i) & ii) above (not achieved in this
case) to then go on and be assessed against the 4 bullet points in 16 f) iii). Although not
required in this case, for completeness bullet points 1-4 are discussed below 
Policy 16 f) iii bullet point 1 as there is no housing delivery pipeline bullet point 1 cannot be
activated in favour of the proposal. 
Policy 16 f) iii bullet point 2 is not relevant in this case as the site is green belt and not within
the identified rural area in North Lanarkshire’s LDP   
Policy 16 f) iii bullet points 3 & 4 the site is of such a scale that it cannot conceivably be
regarded as a smaller scale proposal within an existing settlement boundary nor is it a proposal
for delivery of less than 50 affordable homes having local authority housing plan support 
In summary the proposal is not compliant with bullets 2, 3 and 4 and as there is no housing
delivery pipeline bullet point 1 cannot be activated in favour of the proposal. The proposal
therefore fails to satisfy the provisions of Policy 16 f). 
Furthermore, in recent weeks there have been a number of appeal decisions that are of some
note and relevance to this case.  The thrust of these decisions is that if there is no housing
land pipeline in place, the effect is to remove the possibility of the exception provided by Policy
16 f) iii being triggered. The general restriction on development on non-allocated sites
established by Policy 16 f) would still apply. 
In conclusion, with regards to Policy 16 there is considered to be no sufficient justification at
this time to release this green belt site for residential purposes and to do so would represent a
significant departure from the development plan and its spatial strategy. 
10.26 NPF4 Policy 20 Blue and Green Infrastructure
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This policy aims to protect and enhance blue and green networks (natural habitats,
watercourses and water bodies) and to ensure that such blue and green infrastructure is
integrated into a development design to deliver a variety of objectives including climate
mitigation, nature restoration, biodiversity benefits and flood prevention and management.  
Policy 20 a) advises development proposals resulting in fragmentation or net loss of blue green
infrastructure will only be supported where it can be demonstrated that the proposal takes
account of existing such assets and would not result in a deficit nor exacerbate such impacts
on this asset and that the overall integrity of the network is maintained. 
Policy 20 b) advises that developments incorporating new or enhanced blue and green
infrastructure will be supported where design takes account of existing provision and integrates
new provision into the design, and blue-green network connections in terms of the quality,
quantity and accessibility to such assets and where possible is designed to be multi-functional. 
Policy 20 c) and d) refer to regional and country parks and temporary open space areas or
greenspace and are not relevant to this application. 
Policy 20 e) requires that effective management and maintenance plans which cover funding
arrangements for long-term delivery and upkeep of blue-green infrastructure and identifies the
responsible mechanisms and ownership of this management and maintenance. 
10.27 Policy Assessment 
Given the site is currently green belt and a golf course if it were to be developed then overall
inevitably there would be a reduction in green infrastructure.  The applicant’s Indicative
Development Framework Plan and other supporting information shows the retention of green
corridors around and through the site as a means of mitigating the impacts. However, the
impact on the green belt would be significantly less if only taking part of the course out of play
rather than developing housing was proposed. 
The site has one watercourse and several open but maintained drainage ditches. There is an
area of ponded marshy ground in the north-west corner of the site designated a Site of
Importance for Nature Conservation (SINC). 
In terms of Policy 20 objectives the application proposal safeguards some of the current blue-
green infrastructure on and in close proximity to the site by creating buffer zones around both
the Site of Importance for Nature Conservation (SINC) and the burn crossing the site and its
valley. 
The Indicative Development Framework also indicates that sustainable urban drainage ponds
and intermittently wet drainage basins will be located around the SINC and valley of the
watercourse and elsewhere on site and that buffer stand-off areas will be left along the more
minor drainage ditches. 
In terms of green infrastructure, again where not located in proposed development areas trees
and other habitat features are proposed for retention and where woodland is lost to
development compensatory planting is proposed around development phases. 
If there were considered to be a justifiable reason to grant permission, which is not applicable
in this case, any net loss of green infrastructure could be accepted and mitigated as far as
reasonably practicable through the use of planning conditions.  With regards to other NPF4
Policy 20 objectives further detail could be required by condition for a site blue-green
biodiversity strategy to mitigate impacts and enhance green and blue infrastructure along with
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biodiversity to address both the overall development site and more detailed blue-green-
biodiversity plans for each development phase application. This should also address future
maintenance and management responsibilities Therefore, in other circumstances, and if the
development were otherwise considered to be acceptable, then appropriate planning
conditions could as far as is practicable secure compliance with Policy 20. 
10.28 NPF 4 Policy 21 Play, Recreation and Sport - This policy supports provision of spaces and
opportunities for play, recreation and sport with the outcome that natural and built
environments are improved, more equal access to play and recreational opportunities are
provided and that spaces should be integrated with existing provision.   
• Policy 21 a) considers circumstances where loss of outdoor sports facilities may be
acceptable, or whether compensatory provision is considered necessary. 
• Policies 21 b) and 21 d) assess loss or new provision of children’s play area. 
• Policy 21 c) considers temporary and informal play provision on underused land and is not
relevant to this application. 
10.29 Policy Assessment 
Policies 21 a), iv) is relevant in terms of the loss of part of the golf course. This policy
subsection advises that development proposals resulting in loss of an outdoor sports facility
will only be supported where the proposal can demonstrate that there is a clear excess of
provision to meet current and anticipated demand and that the site would be developed without
detriment to overall provision. 
The submitted Golf Club Improvement Plan and accompanying Development Statement
includes reasons to support development and the reduction of one of the two current golf
courses to nine holes. Reasons given for the reduction in course size and the development
include falling membership and levels of participation, potential employment losses amongst
golf course staff and the viability of the golf club being threatened including several currently
occupied small business units owned by the club. 
The applicants state that finances raised by the sale of land for development would be used
to improve, redevelop and maintain existing facilities and to widen involvement and youth
development processes by encouraging wider local community use. Scottish Golf the
organisation representing golfing interests made a separate submission also supporting the
Improvement Plan and Development Statement 
Sportscotland’s consultation response advised that they had liaised with Scottish Golf who
advised that the reduction from 18 to nine holes was acceptable in terms of the capacity for
golfing facilities in the area, Sportscotland did not therefore object to the loss of part of the golf
course but did provide suggested planning conditions to protect the safety of adjacent
residents and property from golf activities. eg stray golf balls. 
The consultation response advised that comments related only to the loss of part of the golf
course as a sporting amenity and facility and that the response was not commenting on other
possible impacts on the open space area. 
It is worth noting that the reduction of the existing course to a nine-hole course could happen
without the accompanying residential development and that permission would not be required
to only take part of the course out of play.  Nevertheless, it is assessed that the application
proposal complies with Policy 21 a) in that loss of some of the golf course facility is acceptable.
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Policy 21 b) and 21 d) concern adequate provision of children’s play and detailed design and
maintenance of such facilities. The developer has confirmed play provision will be incorporated
into the development. The facilities could therefore be assessed in greater detail within
subsequent more detailed MSC applications. 
The development proposal currently has three play areas, two adjacent areas centrally located
in the north of the site largely surrounded by drainage basins and green infrastructure to act
as part of larger green corridors across the site and the third play area at the centre of the
southern part of the site at the axis of two other strategic green corridors. 
The northern play areas would serve development phases 2, 3 and 4 and be immediately north
of phase 1; the area set aside for community facilities or small-scale retail provision. The
southern area would serve development phases 5, 6, 7 and 8. 
Play Service had concerns that the northern play areas are located in a corridor which also
contains electricity transmission cables above which may have safety implications. The
location could also result in temporary closures if the utility provider required to carry out
maintenance or inspections works, although this is likely to be infrequent. 
NLC Play Services have advised that given the development timescale of a number of phases
and over six or more years, the currently proposed play areas within the application submission
are inappropriate in terms of size and location and that play provision should be considered
on an incremental basis during development of individual phases.  Play areas should be
provided for individual phases or, for several development phases simultaneously where
adjacent phases are being developed concurrently and developers agree to joint provision of
a larger shared play area. As such, if the application were granted permission in principle the
applicant should submit a revised indicative development framework indicating that the
northern play area is to become part of the green corridor network and each MSC application
would require to provide details of play provision. 
A planning condition would be required to consider play provision for each development phase
or several concurrent phases. The provision of such a condition or conditions would allow the
application proposal to comply with Policy 21 b) and d) therefore with the above requirements
for detailed plan provision proposals for individual/several phases the application complies with
Policy 21. 
10.30 NPF 4 Policy 22 Flood Risk and Water Management - considers resilience to flooding risk
by promoting avoidance of such risk and reducing vulnerability of existing and future
development. It also promotes the wider use of natural flood management mechanisms to
benefit people and natural assets. A precautionary approach is recommended which suggests
alternative land uses are appropriate if flood risk from the proposal is not manageable. 
It aims to ensure that development can be connected to water supply and sewerage systems
and where possible, protect or expand opportunities for blue/green infrastructure for natural
flood management. 
Policy 22 a) advises development at risk of flooding or in flood risk area will only be support
for certain uses such as essential infrastructure, redevelopment of existing buildings or sites
where a positive use can be identified by the Development Plan. Policy 22 b) relates to small
scale extensions and alterations to existing buildings. Neither policy is relevant to the
application proposal 
NPF4 Policy 22 c) is relevant. It advises that development proposals should not risk surface
water flooding to others and that the development site should manage rain and surface water
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by means of sustainable urban drainage (SUDs) which should integrate with blue-green
infrastructure and ensure surface water does not add to combined sewerage systems. 
10.31 Policy Assessment 
The submitted Flood Risk Assessment report included a projected climate change allowance
and advised that the majority of the site is at little or no risk of surface water flooding. However,
both low lying land upstream from a culvert under the B802, (Constarry Road), and land south
of the footpath culvert under the same road were at risk of medium to high fluvial flooding from
the main burn crossing the site, including from potential lack of maintenance or blockages of
culverts. 
Site mitigation measures recommended included minimising the number of crossings (roads
and culverts) and other impacts on the functional flood plain and the area of the proposed site
access roundabout and that these minimum or high-risk areas should not for housing or other
buildings. 
The SEPA consultation response had no objection to the planning application subject to
several planning conditions being applied to any planning permission to address
compensatory storage to offset a loss of floodplain capacity due to provision of the access
road and that any new bridges or culverts in that area had to be sized to accommodate a 1 in
200year flood event. 
The application proposal therefore largely avoids the area of flood risk.  The inclusion of the
SEPA-recommended conditions the proposal would comply with NPF 4 Policy 22 a) and c)
however a planning condition for future individual phases would also be required providing
detailed drainage assessment for each development phase. 
10.32 North Lanarkshire Local Development Plan 2022 (NLLDP) 
Although the North Lanarkshire Local Development Plan (NLLDP) was adopted in June 2022,
nine months before the National Planning Framework 4 was applied, many NPF4 policy
objectives are incorporated and also addressed through LDP policies and during the NLLDP
preparation and Examination process. The LDP policies relevant to this planning application
are listed and then discussed below. 
Promoting Policies 
PROM LOC 1 Regeneration Priorities 
Protecting Policies 
PROT B Protecting Assets: Historic Environmental Assets,
PROT C Protecting Assets: Mineral Resources 
Placemaking Policies 
PP 4 Greenbelt – Purpose of Place
AD 4 Greenbelt - Amount of Development 
Contributions to Infrastructure 
CI Contributions to Infrastructure 
Environmental and Design Policies
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EDQ 1 - Site Appraisal
EDQ 2 – Specific Features for Consideration
EDQ 3 – Quality of Development 
Each of these policies are assessed below. 
10.33 PROM LOC 1 - Regeneration Priorities 
This policy advises that North Lanarkshire Council will promote regeneration and sustainable
growth by applying the policies in the plan to deliver the right amount of development in the
right places and to the right quality for the benefit of the communities they affect. Physical
regeneration of the existing urban area and the identified Centres within these urban areas will
be given priority. 
10.34 Policy Assessment 
The application site does not comply with the Council’s regeneration priorities in terms of its
location as it is an unallocated site in an area designated as green belt and other residential
development sites are already allocated and available locally in urban and urban-edge
locations. The proposal does not promote the physical regeneration of the existing urban area
or identified Centres and should not therefore be given priority. 
Whilst it could be considered to have some sustainable growth benefits due to its proximity to
several modes of public transport and local smaller-scale retail centres and as economic
support to these through increased footfall this does not outweigh the regeneration policy
objectives of focussed urban and town centre development and redevelopment. 
10.35 PROT B Protecting Assets: Historic Environmental Assets 
The key objectives of Policy PROT B are to safeguard historic environment assets with the
policy divided into two sub-policies to assess international and national site designations
International - Category B1, and National - Category B2. Development should avoid adverse
impacts to the character or setting of designated sites. 
The policy also seeks to preserve or record Sites of Archaeological Interest by either
preserving the asset at the location or by removing/recording the remaining archaeological
asset 
Category B1 International has relevance to the application site as it seeks to protect the
internationally designated, Frontiers of the Roman Empire (Antonine Wall) World Heritage Site,
and, the Frontiers of the Roman Empire (Antonine Wall) World Heritage Site Buffer Zones
stating there will be a presumption against development which has adverse impact on the
World Heritage Site asset and its setting. 
10.36 Policy Assessment 
The application site is not within the World Heritage Site boundary or Buffer Zones. The
applicant’s Landscape and Visual Impact Assessment advises that due to careful landscape
design and orientation of buildings any visual impact from the World Heritage Site, for example
from Croy Hill would be minimised with minimal adverse impact. 
The other relevant element of policy PROT B seeking to preserve or record sites of
archaeological interest is relevant. The archaeological service providing guidance to North
Lanarkshire advised that the application site has potential to damage previously unknown
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archaeological remains but that there are insufficient grounds to object. The service therefore
recommended that if the application is granted planning permission, a suitably qualified
archaeological contractor undertake a scheme of investigation. The archaeological service
required a condition providing details of what was required to implement the investigation
works. 
It is therefore assessed that with implementation of planning conditions compliance with Policy
PROT B can be achieved. 
10.37 PROT C - Protecting Assets: Mineral Resources 
This policy contains a presumption against development which would potentially sterilise
valuable mineral resources.  As this site is designated as green belt this policy does not apply. 
10.38 PP4 Purpose of Place – Greenbelt 
LDP Placemaking Policy PP4 advises that the purpose of the Green Belt is to protect the
setting of communities, support regeneration by directing growth to urban areas, protect
natural assets and provide high-quality environments within the Green Belt as defined on the
LDP Promote Map. The policy sets out that the council seeks to support developments for
agriculture, forestry, recreation, or developments that need a non-urban location such as visitor
economy development. Development that does not include these uses or does not specifically
need a green belt location will be resisted. 
An Assessment of Appropriateness for any proposal for development in the Greenbelt should
be supported by 
• a business plan, or statement justifying that the development is compatible with the Green
Belt. 
• a statement that the proposal is not best suited to being located in a Centre, or General
Urban Area taking the Town Centres First sequential approach where appropriate. 
• a statement on the scale and nature of existing development in the Green Belt (all
proposals require to satisfy the provisions of all EDQ Policies).  
• evidence that there is a specific locational requirement for the proposal. 
• evidence that the proposal will result in significant economic benefit. 
• its impact on travel patterns and accessibility by sustainable modes of transport (all
proposals also require to satisfy the provisions of Policy CI and Policy EDQ 3) 
Policy PP4 also advises that the application will require to be assessed against its impacts
determined by LDP policy AD4 Amount of Development and other relevant legislation and
policies within the LDP. 
10.39 Policy Assessment 
The applicant contends that the site is not compatible with its Green Belt status, that it is
already enclosed by other development or urban related uses and a railway line, that the site
itself is a man-made maintained space  being a golf course and would form a logical rounding-
off of the urban area and a more robust future defensible Green Belt boundary. 
Comment: The planning authority position is that the site was assessed during the preparation
and consultations for the Local Development Plan regarding its designated LDP status, that
the site forms a valuable green belt connecting to the remainder of the golf course and other
areas of green belt to the east towards Dullatur and represents an environmental and
recreational asset used by the local community. 
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The green belt status of the site was upheld by Reporters during the Report of Examination
including in response to a submission by the applicants to have the site included within the
LDP. If the applicants consider that the site should be removed from the green belt they would
have another opportunity to make the case for this as part of the next LDP preparation cycle. 
Policy PP4 also requires an Assessment of Appropriateness (AoA). In this respect whilst no
specifically titled Assessment of Appropriateness document has been received many of the
requirements have been covered by the applicant’s other submitted documents. 
The applicants have provided documents to support the development’s compatibility with the
Green Belt including the Landscape and Visual Impact Assessment. Planning Statement
Addendum 3 contains reasons why the applicants consider the site should not be green belt
along with their assessment, to justify developing the site for residential purposes. 
Of the other PP4 policy requirements 
• With regards to the requirement that the proposal is not better suited to a town centre
location or the general urban area taking a sequential Town Centre First approach the
applicant has argued that the site should not be green belt. 
• With regards to the applicant justification of a specific locational need for the proposal.
Again, the reasons put forward in relation to housing need and community benefits
(both the wider benefits relating to the national housing emergency and those specific
to golf club viability) are not considered sufficient to justify support for the application. 
• As the application is at PPP stage it is not possible to assess in detail whether the
application would fully satisfy all EDQ policies however the applicant has provided
information to a level appropriate for an In Principle application in terms of policies EDQ
1 to EDQ 3. 
• There is a reasonable case that there would be of economic benefit in terms of
employment created during the construction phase of the development and for
suppliers of materials and skilled employment.
• A statement of the impact on travel patterns has been provided. 
However, overall the application is not considered to comply with LDP Policy PP4 and
approval of the development would represent a significant departure from the Local
Development Plan. 
10.40 Policy AD4 Amount of Development 
Policy AD4 Amount of Development requires that housing proposals support a Green Belt
appropriate use as identified in Policy PP4 above. The policy requires the development to be
assessed for its implications based on an assessment of its scale and location. Where applied
to housing proposals the proposed development should support Green Belt appropriate uses
as defined in Policy PP4. 
The policy goes onto state that Assessment of amount of any development, or change of use
within the Green Belt should include, but not be limited to: 
• a statement on whether the proposal is an intensification of an existing use.
• its impact on land supplies including all housing proposals over 10 units on the Housing
Land Supply.
• evidence regarding the existence of suitable alternative sites.
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Development not meeting these requirements will not be supported. 
All proposals for housing of over 10 units should include an assessment of its impact on the
Council’s Housing Land Supply. 
10.41 Policy Analysis 
The development does not comply with Policy PP4 as it is not a Green Belt appropriate use.
Policy AD4 advises of matters that need to be taken into account include appropriateness
(which refers to scale and nature of the development). On this point, clearly a development of
600- 650 houses in the green belt represents a significant departure from the Plan. 
Regarding other policy matters the application proposal is not an intensification of the existing
use it but represents the introduction of a significant contrary use in the green belt The impact
on the Housing Land Supply has been covered at some length above, particularly in relation
to assessment of the proposal against NPF Policy 16 (which superseded LDP policy PROM
LOC 3).  There is considered to be no justifiable reason that would support the development
of this site for residential purposes.   
The proposed development is considered contrary to Policy AD4 and the policy indicates that
development proposals not meeting these policy requirements will not be supported 
10.42 CI Contributions to Infrastructure 
Policy C1 seeks to secure developer contributions where developments generate a
requirement for new or enhanced infrastructure or services. This includes contributions
towards affordable housing in the Cumbernauld housing market area, education, transport and
green infrastructure, amenity and play space provision. 
10.43 Policy Assessment 
The applicant has indicated a willingness to provide affordable housing at a rate of 25% (in
excess of the LDP requirement for 20%).  The applicant has also agreed to provide the
financial sums requested by NLC Learning Services towards the necessity to increase  the
capacity of the school estate on an identified need for extra accommodation at Our Lady’s
High School. The submitted Transport Assessment and discussions with NLC Roads and
Transportation has identified a need for improvement works at Craiglinn Roundabout which
will been designed and paid for by the developer prior to any work commencing on the
application site. The applicant has proposed a landscape strategy to augment the green
infrastructure lost due to development and provide an interlinked green network and play areas
to the standards and amounts required by NLC Play Services, Amendments will be required
to the Indicative Strategic Framework document to the satisfaction of the planning authority to
identify alternative locations for play areas requiring play areas to be located nearer to each
development phase and away from the currently proposed locations of the main open space
play areas close to overhead pylon lines. 
Developer contributions can be addressed by planning conditions or, in the case of educational
contributions, by legal agreement. Subject to implementation of the above infrastructure
contributions and implementation of the physical infrastructure measures required by SEPA,
Network Rail and Strathclyde Partnership for Transport. Therefore, the application proposal
could comply with Policy C1 Contributions to Infrastructure. 
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10.44 EDQ Policies (Environment and Design Quality) 
EDQ Policies aim to ensure that developments create new or enhance existing places and that
they integrate with the local area by taking into account human-influenced and natural
elements of the site and avoid harm to neighbouring amenity through successful design.
Additionally, the polices aim to ensure proposals address issues of climate change, promote
biodiversity and consider potential valued habitats, infrastructure provision and promote
sustainable transport. These policies have similar objectives to many of the NPF4 policies.   
10.45 EDQ1 - Site Appraisal 
Policy EDQ1 requires the application proposal to address matters such as design, massing
and finishing materials of buildings, site topography, public services available, street lighting
and street design, road and path layouts and a number of other elements of good site design. 
10.46 Policy Assessment 
As this is an application for Planning Permission in Principle the application satisfies the level
of detail required although the proposal for significant groundworks and soil cutting and filling
raises concerns regarding the impact on the overall landform of the site and how this would
impact visually and in terms of water movement and flood risk prevention. Further assessment
of these design details and changes to landform would be required at each phase of
development and could be addressed by planning conditions. However, the current PPP
application complies with the principles of Policy EDQ1 in as much as sufficient detail has been
provided to allow assessment.   
10.47 EDQ 2 Specific Features for Consideration 
Policy EDQ 2 addressed development in areas subject to hazards and the presence of future
planning of utilities infrastructure such as pipelines and overhead transmission wires. 
10.48 Policy Assessment 
The applicant has responded to the level required for a PPP application in terms of matters of
flood risk, contaminated land and ground instability and regarding current and future utilities
infrastructure requirements. The relevant council and external agencies (SEPA, NLC Pollution
Control, the Coal Authority and utility providers) have provided planning conditions which
would require more detailed investigation and analysis of these matters therefore the
application complies with policy EDQ2 at a Planning Permission in Principle level. 
10.49 EDQ 3 Quality of Development 
EDQ3 advises that only development where high standards of site planning and sustainable
design can be achieved, and planning applications have to demonstrate that development
takes account of the site appraisal. Matters to be considered include clear design principles in
terms of siting, layout, density and other built environment matters; adaptability for climate
change, green networks, transition to a low carbon economy, internet and other fibre
interconnectivity, mitigation of potential adverse noise or air quality, protection of existing site
features of value including those of a biodiversity and historic or cultural nature and other
matters. 
10.50 Policy Assessment 
Again, it is not possible confirm in detail the final design and other measures relevant to policy
EDQ3 at a PPP application level including protection of the designated biodiversity asset at
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Croy Spinney SINC. However. the application has provided sufficient information to assess
the application at a strategic level. The main area of concern is the level of impact on the green
belt and that other measures proposed will be implemented to a sufficient degree to
compensate for losses. However, these matters would be addressed by various planning
conditions should an In Principle planning permission be granted and would then be assessed
in detail when MSC applications for individual development phases are submitted.   
Development Plan: Conclusion 
10.51 With regards to NPF4 and the North Lanarkshire Local Development Plan there is considered
to be no sufficient justification at this time to release this green belt site for residential purposes
and to do so would represent a significant departure from the development plan and its spatial
strategy 
Other Material Considerations 
10.52 Section 25 of the Town and Country Planning (Scotland) Act 1997 states that planning
decisions must be made in accordance with the development plan unless material
considerations indicate otherwise. 
• Development Plan –This is covered above in detail including the Chief Planner/Scottish
Government updated guidance ‘Planning for Housing’ letter dated 26th June 2024. In
addition, in a further letter sent on 20th September 2024 the Chief Planner advised
among other work streams that this year’s Programme for Government recognises the
importance of planning and sets out their intentions to: 
• ensure the planning system responds to the housing emergency. This includes
supporting planning authorities to allocate a pipeline of land for new homes as local
development plans come forward and promoting consistent monitoring of its delivery. 
In this regard, as indicated above we are already moving towards allocating a pipeline of
land for new homes. 
With regards to NPF4 and the North Lanarkshire Local Development Plan there is
considered to be no sufficient justification at this time to release this green belt site for
residential purposes and to do so would represent a significant departure from the
development plan and its spatial strategy. 
• Representations – these are covered in Section 9 above. 
• Consultations covered above in Section 8.  Apart from the Community Councils, there
have been no objections from consultees, however this development would represent a
significant departure from the development plan and for this reason the planning service
is not supportive of it, so whilst not indicating support for the proposal, where comments
from consultees could be addressed by planning conditions, should planning permission
be granted, this has been highlighted. 
• Statement of Community benefit & Golf Club Development Plan these are discussed
in the following sections below 
Statement of Community Benefit 
10.53 NPF 4 introduced the requirement for development proposals of 50 or more houses to prepare
a Statement of Community Benefit. 
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Policy 16 b) of the NPF outlines that these Statements will explain the contribution of the
proposed development to 
• meeting local housing requirements including affordable homes,
• providing or enhancing local infrastructure, facilities and services,
• improving the residential amenity of the surrounding area. 
10.54 Dealing with these in turn, the first two bullet points have been covered at length above. With
regards to explaining the wider community benefit the applicant has provided two statements
on what the applicant perceives to be the benefits arising from the proposed development. 
These are discussed in the following paragraphs.       
Applicant’s Agent Stantec’s Statement on Community Benefits (dated Nov 2023)
Golf Course Improvement Plan 
10.55 The applicant advises that the proposed development will deliver vital financial investment to
Dullatur Golf Club, enhancing existing facilities and ensuring its long-term survival. The
proposed development responds to the economic challenges facing golf clubs across Scotland
and ensures that this community facility is retained and upgraded to serve a wider
demographic. 
Comment: No detailed financial information has been provided by the applicants agent
Stantec on the state of the golf club’s accounts or its current financial viability. Nor has the
planning authority had any information on the nature of the agreement between Hallam Land
and the golf club in terms of financial benefit. It is considered that if the club was in a dire
financial state more information on these matters would have perhaps been
provided/volunteered. Also not detailed is whether golf club members may benefit individually
from this development – although this is not a matter that is relevant to the planning
assessment.
10.56 With regards to specific plans, the applicant advises that improvements to the golf club are
stated as including the following: 
• The redevelopment of the Antonine Course to create a new nine-hole golf course alongside
the existing 18-hole course and allowing the opportunity for shorter play; 
Comment: this could equally be achieved by the club without the need for any planning
permission without the proposed housing development. Whilst this may benefit the club the
wider community benefits of this are limited  
• Development of a new Indoor Tennis Dome and facilities, allowing for year-round play; 
Comment: Planning permission already exists for this (planning application reference
19/01240/FUL) and the development has commenced. The permission was obtained by a
private individual and not the club, albeit planning permissions run with the land. Again, this
would be a facility at a private club so wider community benefits would be limited
• Enhancement of Junior Play and Youth Development;
• The income received would allow for future refurbishment of the Clubhouse and additional
tenant space to enhance the current offering. There are currently five other uses such as
yoga, beauty salon, golf professional and a restaurant; 
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Comment: noted, both are aspirational aims.
• New Practice Area, Driving Range and Short Game area;
• An additional Trackman studio – a golf simulator – which can be hired on an hourly basis
by both members and non-members and have proven to be attractive to younger golfers.
This forms a key part of the investment into youth development at the club for coaching
and training. 
Comment: Noted and will in the main only benefit members of the club albeit it may be more
attractive to new members. It may be the case that this along with a shorter 9 hole course may
appeal more to junior members.
• Creation of jobs through clubhouse improvements;
• Carbon Footprint improvements and energy saving upgrades, including the potential
installation of Photovoltaics on the greenkeeper’s shed roof to meet the power
requirements for the shed and clubhouse, and electrical charging points in the car park;
• Further green infrastructure enhancements including increased tree restorations and
planting; 
Comment: noted 
10.57 In conclusion, when considered in the round the proposed projects within the Golf Course
Improvement Plan are not sufficient to justify a favourable recommendation for the
development.  Many of these improvements could take place without the need for planning
permission (reducing course to nine holes, photovoltaics, trackman etc).  Nevertheless, it is
noted that as the golf club are joint applicants. If the planning authority were minded to approve
the development it may be possible to require an improvement plan detailing the physical
works and a timetable for their implementation and to control implementation of the
improvement plan by tying the completion of these works to the housing development e.g.no
more than 100 houses will be built within the site until the works detailed in the improvement
plan have been implemented in full. 
Improvements to the Residential Amenity of the Surrounding Area
10.58 The applicant advises that the proposed development will deliver an attractive, modern and
energy efficient residential development of between 600 and 650 new homes, including 25%
affordable housing, equating to up to 163 homes. Furthermore, the proposed development will
include the opportunity for a new community facility, and an extensive landscape framework
within a highly sustainable location. The level of affordable homes at 25% is an increase of 5%
above the current statutory requirement within the adopted North Lanarkshire Local
Development Plan 2022. The tenure for the affordable homes would be set by North
Lanarkshire Council and would be secured by a Section 75 Legal Agreement. 
Comment: The requirements or need for additional affordable housing is covered elsewhere
in the report, suffice to say there is no justifiable need for the release of this green belt site for
residential development at this time 
10.59 The applicant states that the proposed development will create benefits for the surrounding
community by: 
• Delivering significant financial investment into Dullatur Golf Club, thereby securing the
long-term financial future of the Golf Club to maintain a modern golf facility for the local
area; 
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Comment: The wider community benefits of maintaining a private club are limited and as
indicated above, the financial justification that has been provided is short on detail and is not
sufficient to justify the release of this green belt site for residential purposes. Other stated
community benefits by the applicants are:
• Identification of land for a new community facility such as a GP surgery or retail facilities,
providing a focal point and improving local service provision at the site and surrounding
area. The land is located at the site entrance on Constrarry Road so would be accessible
by the wider local community;  
• A range of economic benefits associated with the reuse of the site, job creation through
construction activity, supply chain jobs and expenditure in the local area by new residents. 
Comment: noted but these benefits are not sufficient in isolation, or in addition to other stated
benefits to warrant support for a development that is not needed and is such a significant
departure from the development plan 
• Financial contributions to the local school infrastructure to ensure that there is adequate
capacity for local catchment areas arising from the development, secured by Section 75
legal agreement;
• A scheme of road improvements at Craiglinn Roundabout to accommodate the
development, whilst also providing a net benefit for road users by minimising traffic
congestion and improve traffic flows. 
Comment: these are not additional benefits but are contributions and improvements that would
be required in any case which are only required to mitigate the impacts of the proposed
development. There may be some wider benefits of improved traffic flow for all users of the
Craiglinn Roundabout. 
• Provision of a variety of house types and sizes that gives choice for families seeking a new
home in the area, including affordable homes; 
Comment: as stated earlier in this report there is no identified gaps in provision nor is there a
need for additional housing land
• Creation of a green network, comprising of a variety of maintained open green spaces,
planting and tree planting. Such open spaces would be managed by property factoring
agreements;
• Retention and improvement of existing trees and watercourses, and creating of green blue
networks to strengthen boundaries;
• Provision of equipped play areas, creating a range of recreation opportunities across all
age groups;
• Creation of green-blue network enhancements as part of the identified drainage solution
and further enhancement of the biodiversity qualities of the site including the improvement
of the SINC within the site. 
• An extensive improved pedestrian and cycle network, providing upgrades of existing core
paths, encouraging active travel across the site with the ability of safely connecting cycling
from other residential areas of Cumbernauld to Croy Station 
Comment: this is a golf course in the green belt so is already a significant green network
resource.  The measures indicated above would be in mitigation for the development if it were
to proceed.
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The Landscape Strategy Plan
10.60 The applicant indicates this will deliver a range of formal and informal recreation opportunities
for new and existing residents of the area, whilst retaining and enhancing a significant
proportion of the existing open space offering. The existing function of the site will continue to
deliver a green corridor and footpath connections between neighbourhoods which surround
the site. Although, as a result of the proposed development the site land will cease to operate
as part of the golf course, it will continue to deliver green network connections and access to
core path linkages. Indeed, in comparison with the current use as a functioning golf course,
the landscape framework to be delivered through the proposed development will facilitate a
wider range of outdoor recreation opportunities for all and enhanced permeability 
Comment: The applicant’s statement recreational and landscape opportunities are only as a
result of and in mitigation of the development if it were to proceed. 
Economic benefits 
10.61 The applicant indicates the proposed development will provide significant economic benefits
to the local area thorough the following: 
• During the construction phase benefits will include the creation of jobs and use of local
supply chains;
• This will include 263 direct and 309 indirect employment opportunities 
• In terms of Gross Value Added (GVA), it is projected that the proposed development will
deliver £94.5m directly, £117.2m indirectly, and in total £211.7m GVA during the
construction phase; 
• Once the proposed development is occupied, it will deliver an increase of 1,443 residents
to the area, resulting in £33.8m GVA per annum and £646m in employment; and
• Retail and leisure expenditure is expected to be £12.4m per annum, with council tax
opportunities of over £1.1m per annum. 
Comment: These projected benefits are noted but there is currently no justifiable need at this
time for the release of this green belt site for residential development. 
Dullatur Golf Club – Proposed Golf Course Improvement and Development Plan
Statement  
10.62 This statement was undated but was submitted with the application so received by the Planning
service on 6th Sept 2021. In view of the time that has elapsed an update was requested and
this was received on 9th October 2024 
10.63 Dullatur Golf Club (DGC) advise that the proposed residential development will assist in the
cross-funding of the Golf Course Development Plan proposals detailed below. When DGC
identified the need for funding, they appointed a property agent to market the area for 600+
homes. Hallam Land Management purchased the area of land which was marketed. The
purchase has provided DGC with an initial payment with further payment to be received if
planning permission for residential development is granted and the sale of the surplus land at
the Antonine Course to a future housebuilder or housebuilders is achieved. The initial payment
has allowed the club to begin some short- term projects, However, a further payment will be
required to achieve the medium-to-long term projects and provide financial security for the
long-term future of the club.   
10.64 In 2021 the applicant advised that their proposals will include the following: 
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Short to Medium Term Projects:
• Indoor Tennis Facilities
• Improved Car Parking 
• New Footpath and planting 
• Lawn Bowls 
• Tree Restoration and Strategic Planting 
• Modernisation and Refurbishment of the Clubhouse – Phase 1 
• Investment in Marketing and Community Reach 
• Youth Development Phase 1 
• Carbon Footprint Improvements – Phase 1 
Medium to Long Term Projects – 5 – 10 years:
• Modernisation and Refurbishment of the Clubhouse – Phase 2 
• Youth Development – Phase 2 
• Carbon Footprint Improvements – Phase 2 
• New 9 Hole Antonine Golf Course 
• Sale of Remaining Land at the Antonine Course 
10.65 DGB advise that the club has been a long-established local recreational facility within the
community for 125 years. The types of financial challenges which Dullatur Golf Club has
experienced in recent years have severely and adversely affected many golf courses, a
number of which have not survived. In 2019 Scottish Golf had lost approximately 47,000 (21%)
of members between 2007-2017, and if clubs continue to lose memberships, through aging
membership there is not a enough younger members to sustain golf clubs. 
10.66 The club has suffered from this trend and whilst 2020 saw some new memberships, driven by
the immediate impact of COVID, however the Club and wider golfing community expect
membership numbers to continue to decline. 
10.66 Whilst figures are not provided the club assert that, using 2012 as a starting point, their income
has fallen year on year with the exception of an upward spike in 2020 following Covid. No
information has been provided beyond 2020. 
10.67 The banking sector are no longer tolerant of clubs that move from cash positive to debt and
funders generally do not consider golf clubs as stable for investment and return. However, the
club decided in 2018 to pursue two strategic land sales both of which provided financial stability
to the club in the short term. The club believe that the long-term future can only be achieved
with a robust business model for future operation 
Comment: whilst these financial challenges are appreciated, this alone is not sufficient
justification to allow development on a site that is allocated as green belt and which there is no
other justification at present. The release of the site for housing is not currently needed and to
grant permission at this time would represent a significant departure from the development
plan and its spatial strategy.  There are many golf clubs within North Lanarkshire who are
presumably facing similar issues and to grant permission for this application could be perceived
as setting a precedent. 
The Planning service has been supportive of the club previously, in 2008/2009 granting
permissions for the redevelopment and replacement of the bowling and greenskeepers
facilities for 18 houses developed by CALA homes and in 2019 a plotted development along
Glen Douglas Drive (a total of 8 plots). Despite local opposition and objections, and unlike the
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current proposal, these developments were assessed as complying with the policies within the
development plan.    
10.68 The club provided information on their membership over the period (2012 – 2020). The majority
of members are seniors (65 and above) and indicate an ageing membership which does not
provide a solid future for golf clubs. DGC has considered ways to increase their golfing
membership and broaden the demographic of golfers, but they have also considered other
avenues of income including opportunities within the clubhouse and facilities for other sports
that can be provided on but require capital expenditure for these.  
10.69 Updated membership information was provided in October 2024. Whilst not providing
commentary on the age profile, overall membership numbers show a membership of 725 in
2014 rising to 956 in 2024. In commenting on this the club advises: 
• The decline, and unsustainable level, of membership numbers in the period 2014 to
2018 precipitated the Club’s decision in August 2018 to seek a purchaser for part of the
Antonine Course with a view to achieving a sustainable future for the Club in the short,
medium and longer term. 
• The upturn in membership numbers in 2021, the ‘Covid effect’, was experienced by
most golf clubs. 
• A further upturn in membership was achieved in 2023 following the clubhouse
refurbishment and having secured a catering franchise partner. 
• In the period 2021 to 2024 the Club was successful in securing a higher, ‘Intermediate
plus Junior’ membership in support of a strategy for attracting younger golfers to the
club 
Comment: In terms of membership numbers, it would seem clear that the club are in a better
position than they were in 2014 and this has been achieved without the more significant
financial benefits that the club may accrue if this planning permission in principle application
were to be successful.   
Proposed projects – 2024 update
Short to Medium Term Projects and Initiatives 
10.70 The October 2024 updated information was provided on works that have been
commenced/completed. 
• Indoor Tennis Facilities - The substructure works for a tennis dome facility, on the existing
tennis courts, together with the construction of the entrance building, has progressed
during 2024. The dome structure for the 4 court padel tennis* facility is currently under
fabrication The dome installer has programmed the handover of the tennis dome to the
operator on 14th November 2024. The operator proposes to open the tennis dome to the
general public in December 2024 and will launch a website soon to promote the facility. 
(*Padel tennis has a smaller court, lower net and is played with a solid paddle instead of
stringed racket). 
Comment: In its initial submission the club acknowledged this is being delivered by Total
Tennis under a lease agreement not by the club itself 
• Improved Car Parking - The reconfiguration and construction of the improved car parking
at the Club was completed in August 2021. 
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Comment: This ‘improvement’ is a direct result of the car park being reconfigured to allow the
club to sell a series of plots on Glen Douglas Drive for housing.
• New Footpath and planting this is to allow walkers to access the club car park without
the need to walk between the brick piers, which can be a busy junction where vehicles
access and exit the Club car park. The new footpath and planting, entrance, was
substantially completed in October 2022 
Comment: This was a requirement of reinstatement works to restore the temporary car park
that was put in place as a short-term facility when the works to reconfigure the car park and
develop the plots were ongoing. 
• Lawn Bowls – the club advise there are currently 40 Lawn Bowls members.  It is an
essential part of the sports facilities on offer at the Club and safeguarding its future through
the financial security of the Club is crucial. The golf course greenkeeping staff maintain the
playing surface, irrigation and power is provided from the clubhouse. The facility would not
be able to operate without the golf club operational.
Comment: the wider community benefits of the bowling club are clearly limited.
• Tree restoration/strategic planting – the club advise they established an on-site nursery,
with 420 native species saplings planted in November 2021, which will support wildlife with
a rolling 3 year investment of wildlife and hedging plants to maintain the integrity of the tree
buffer at the margins of the courses and to provide feeding and nesting for native birds.
The club advise that a robust tree belt between the Club and the neighbouring houses is
advantageous as it provides a buffer between the two uses and can help to stop stray balls
entering gardens. A survey by the club to identify areas where the tree belt can be
enhanced, and a proposal has been put in place to plant new trees to restore and enhance
the buffer zones at locations. This planting requires short to medium term investment and
is a project the club will pursue. There will then be ongoing maintenance to ensure the
trees grow and mature successfully 
Comment: Whilst this is commended in terms of landscape and wildlife benefits that may arise
this could be considered part and parcel of managing and maintaining the land that the club
own. 
• Modernisation & Refurbishment of Clubhouse – The GC advises it has been very
proactive in terms of identifying areas of potential income generation within the facility they
have at the Clubhouse. The Club now lease rooms to three different wholly financially
independent local businesses who provide services to the wider community; Cumbernauld
Education Centre (after school hours tuition), a hairdressers and physiotherapy and sports
injury clinic. It is very important for the golf club to continue to offer (and potentially expand)
facilities available to local businesses and they are currently exploring additional areas
which can be made available for this and ongoing improvement works to the existing facility.   
• Modernisation and Refurbishment of Clubhouse (Phase 1) – Following completion
of the refurbishment of the Restaurant, Kitchen and Toilet facilities at the First Floor
level of the clubhouse Dullatur Golf Club welcomed the introduction of Nonna’s Kitchen
as our catering franchise partner for the provision of food and drink at the Club, in
September 2022. The Club thereafter progressed the refurbishment of the Lounge
which opened in December 2022 
• Yoxa Fit Studios – In June 2022 Dullatur Golf Club welcomed Yoxa Fit Studios to
operate a Yoga, dance and fitness studio at the former gymnasium within the clubhouse 
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• Youth Development (Phase 1) – In February 2022 Dullatur Golf Club completed the
installation of a second Trackman facility at the clubhouse. The golf simulator is utilised
extensively by the Junior Coach which has been instrumental in increasing the Junior
Membership numbers at the Club 
The club advise that the aforesaid changes have largely financed by the initial financial
investment provided by Hallam Land and has resulted in the Club having completed the
refurbishment of 40% of the clubhouse building. The refurbishment of the remainder of the
clubhouse; the Ground Floor, 3 unused rooms and the Common Areas will be progressed
when funds are available. In addition, and in recognition of the fact that the clubhouse
building is 28 years old, future refurbishment works will need to include upgrading or
replacement of the mechanical and electrical systems at the building which have largely
exceeded their design life.
It is anticipated that the replacement energy systems will embrace harnessing solar and
wind energy with a view to satisfying the clubhouse, and greenkeepers shed, energy
requirements whilst also providing electrical charging points within the car park 
Comment: the diversification of the club facility is noted but the wider community benefits
of what is after all still a private members club is limited. As indicated above some of these
works have been a direct requirement of other development opportunities that the club
have been successful in pursuing in particular the recent sale of 8 housing plots on Glen
Douglas Drive.  We are not party to the nature of the deal between the club and Hallam
Land so are unable to comment on how much of the additional work above has been
funded by this deal rather than through the sale of the plots.   
Medium to Long Term Projects
10.71 The club advise that the following projects will be undertaken: 
• 9 Hole Course (Redevelopment of the Antonine Course) 
• Sale of Land on Receipt of Planning Consent 
The club advise that both courses are currently available to non-members and will continue to
be so, as an 18 hole + 9-hole arrangement. The income from non-members and visiting parties
of non-members is an integral part of the Club’s annual income. The investment on the courses
and in the clubhouse is considered to be fundamental in supporting the Club’s aspiration of
being the destination of choice for visitors at an affordable price point. The 9-hole offering
allows the Club to provide 9-hole medal competitions, which neither the Antonine nor
Carrickstone Courses currently accommodate readily as the 9th hole, on both courses, is a
considerable distance from the clubhouse. In addition, a 9 hole course will allow the Club to
target other markets; those who are new to golf, families, juniors, and those who simply don’t
have time to commit to a 4 hour round of golf on a 18 hole course. It will also allow Dullatur
GC to pitch at a much lower price-point making the game accessible to those who would
previously have considered the sport to be cost prohibitive
Comment: Noted. However, these changes to the course and club offer could be achieved
simply by taking holes out of play without the related housing development. It is considered
that reducing the course to 9 holes in itself would achieve savings on the likes of maintenance,
grass cutting etc.
10.72 Investment in Marketing Community Reach - The club advises that Marketing and
Community reach is in the early stages of development. Dullatur GC has appointed TB Digital
to act on the Club’s behalf in relation to their presence on Social Network platforms. This
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objective is to increase awareness of what is on offer at the Club by targeting a variety of
different people who may use the wider range of facilities on offer. The Club are also very keen
to engage with the community through these platforms to inform and educate them on the
projects which will be undertaken in relation to the wildflower mix planting, tree planting etc 
Comment: Noted. This would seem a sensible thing for any private business to do.   
10.73 Youth Development - DGC advise that they understand the importance of youth development
within golf and the need to welcome junior players to the club. They indicate that they have
already invested heavily into this and have a commitment to continue and grow this investment.
The Club professional, currently coaches a large number of youth players from throughout the
region. His assistant professional, who is currently taking the PGA course and is local to
Dullatur, is a beneficiary of Dullatur’s longstanding commitment to developing youth players.
He was the club’s youngest ever Club Champion, and has had a fine amateur career, before
turning professional.  He is currently working on the ‘My Pathway2Golf’ programme by Golphin,
for young golfers and has over fifty players are attending weekly courses, which will run
throughout the year. He also runs summer camps for youngsters throughout the summer
months. The objective will be to continue this excellent engagement with young players but
also to grow this with the inward investment from the potential housing development. At present
the existing practice facilities are not well suited to junior coaching and development, however
with the right investment the Club expect to attract and grow the number of Junior participants
and members. Key to the investment will be an additional Trackman for coaching and training,
a 9-hole course which is much more manageable and playable for younger golfers, a driving
range facility for coaching and practice as well as a short game area. All of these will be key
to increase the engagement and development of youth players. The proposals are significant
and require investment to be able to progress and take forward 
Comment: Noted.  Investment in attracting younger players/future members to the club is a
sensible approach and DGC are not alone in adopting this approach. Again the 9 hole course
could be delivered now simply by taking holes out of play.     
Conclusion on Community Benefits/Golf Course development plan 
10.74 With regards to this matter, it is concluded that the indicated benefits (both to the wider
community and with regards to the golf club in particular) are not considered to be sufficient
either in isolation or in conjunction with the other justifications advanced by the applicant to
justify an approval of this development.  It is considered that the proposal represents a
significant and unjustified departure from the development plan.   
11.  Conclusions 
11.1 The application for residential development seeks to planning permission in principle to
develop up to 650 dwellings on green belt land. The applicant states that the site should not
have been designated as green belt in the Local Development Plan and is required as to
address a national housing crisis (Scottish Government Housing Emergency). The applicant
also states that there is insufficient delivery of housing on allocated LDP sites within North
Lanarkshire and therefore as allowed by NPF4 Policy 16. In addition, the applicant has
indicated a range of community benefits that would arise if the development were to proceed
(economic, community benefits and securing the long term future of the golf club). 
11.2 The application has been carefully assessed against the development plan taking all material
considerations into account and, when this is done, it is concluded that there is nothing to
justify such a significant departure to the development plan and for this reason planning
permission in principle should be refused.   
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11.3 Should the Council be minded to approve planning permission in principle then the permission
would not be released until such times as a legal agreement had been concluded to secure
the required developer contributions that would be required to mitigate the impacts of the
development. 
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North Lanarkshire Council
Report
Council 
Does this report require to be approved? ☐ Yes   ☒ No
Ref    EK Date 27/11/24 
Finance Update 
From  Elaine Kemp, Chief Officer (Finance)  
E-mail KempE@northlan.gov.uk Telephone 07939 280601 
Executive Summary
In line with the framework outlined in the Revenue Budget Strategy, the Council’s Medium
Term Financial Plan (MTFP), approved by Policy and Strategy Committee on 5 June 2024,
identified an envisaged three-year budget gap of £61.976 million, with an estimated
shortfall of £21.561 million in 2025/26.   
On 30 October 2024, the Chancellor of the Exchequer presented her Autumn Statement
to the UK Parliament and announced significant increases in UK public spending,
confirming an increase in Scottish Block Grant funding through Barnett consequentials
across 2024/25 and 2025/26. 
This report aims to summarise the potential impacts of this announcement on the Scottish
Government’s and North Lanarkshire’s budgets and to update on other key movements on
the MTFP since its approval.  The financial outlook will continue to be reviewed and
updated until the 2025/26 is set in February 2025, which will also reflect the Local
Government Finance Settlement announcements expected in December 2024. 
After adjusting for anticipated changes, the latest Financial Outlook shows an estimated
net increase in the 2025/26 budget gap of £3.541 million and £4.661 million over the three-
year planning period.  This results in a forecast gap of £25.102 million in 2025/26 and a
gap of £66.637 million over the three years. 
Council is reminded that in setting the Revenue Budget in February 2024 it was recognised
that this Council has one of the lowest levels of Council Tax in Scotland. Therefore,
reflecting on the forecast challenging financial environment in which the Council operates,
the Chief Officer (Finance) was instructed to undertake an analysis of options in relation to
a future Council Tax Strategy to explore opportunities to protect vital public services valued
by local communities given past, present and future financial forecasts for public sector
funding.  Therefore, a Council Tax Strategy report will be presented to Policy and Strategy
Committee on 5 December 2024, which will present options for consideration.  In line with
the approach taken for the 2024/25 budget the S95 Officer will outline the income
generation potential from Council Tax increases, and the impact on the revenue budget
gap or other potential opportunities linked to the Community Investment Fund Programme
and the Council’s Programme of Work. 
Council officers will work with Elected Members to ensure a number of potential solutions
are presented to enable the Council to address the budget gap and to meet its legal
Item 3
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1. Background
1.1. The statutory requirements in relation to budget setting are contained within Section 93
of the Local Government Finance Act 1992.  This is reinforced by CIPFA’s guidance
which requires that total estimated expenses for the year can be funded by the income
estimated from grants, Council Tax and other income. Failure to meet these
requirements would result in serious consequences for Council operations and
individual members. Section 102 of the Local Government (Scotland) Act 1973 sets out
specific processes for the Controller of Audit to report to the Accounts Commission on
the failure to set a budget.  The Commission can recommend that Scottish Ministers
direct the Council to rectify this. 
2.  Report 
UK Government Autumn Statement
2.1. On 30 October 2024 the Chancellor of the Exchequer presented her Autumn Statement
to Parliament, taking cognisance of the Office for Budget Responsibility (OBR)
published Economic and Fiscal Outlook. In July 2024 the UK Government published
an audit of public spending, which set out £22 billion of in-year pressures, the vast
majority recurring in future years. 
2.2. The Chancellor announced significant increases in UK public spending of around £70
billion per year and confirmed Block Grant funding totals for devolved administrations 
2.3. As a result, the Scottish Government is set to receive an additional £3.4 billion from
Barnett consequentials in cash terms across 2024/25 and 2025/26. In 2024/25,
resource funding increased by around £1.4 billion in cash terms and capital increased
by around £70 million. In 2025/26 resource funding increased by around £1.4 billion
(3.4% relative to 2024/25), and capital funding increased by around £600 million
(12.3%).
obligation to set a balanced budget.  A suite of solutions will be presented including income
generation from potential Council Tax increases, savings options and prudent use of
balances in line with the Council’s Reserves Policy. 
Recommendations
It is recommended that Council: 
(1) Acknowledges the potential impact of the UK Government Autumn Statement.
(2) Recognises the key movements on financial planning assumptions and the
impact on the forecast position for 2025/26 financial year and the three-year
planning to 2027/28.
(3) Acknowledges that a suite of solutions to manage the position and ensure that
the Council meets its statutory requirement to set a balanced budget will be
presented for members consideration.   
The Plan for North Lanarkshire
Priority  Improve North Lanarkshire's resource base
Ambition statement (25) Ensure intelligent use of data and information to support fully
evidence based decision making and future planning
Programme of Work Statutory / corporate / service requirement
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2.4. The Scottish Government will determine how the additional funding will be allocated
and in line with its priorities and the impact on Local Government will become clearer
following the Scottish Budget on 4 December 2024. However, based on the sizeable
increase in funding, with a significant amount directed to Local Government in England,
it may be reasonable for Local Government in Scotland to expect to see an increased
settlement from 2024/25. 
2.5. The Chancellor also increased the rate and starting point at which employers pay
National insurance contributions. Employer National Insurance contributions (eNICs)
will increase from 13.8% to 15% from April 2025. In addition, the threshold at which
businesses start paying National Insurance will be lowered from £9,100 to £5,000. It is
understood that Public Bodies will receive funding to support this additional cost
pressure and that any funding will be additional to the £3.4 billion consequentials
previously noted. HM Treasury has confirmed that funding will be provided at the UK
Main Estimate in Spring 2025. 
2.6. It has been widely recognised that the public sector in Scotland is larger than UK as a
whole and is relatively better paid and, as a result, there is risk that funding provided
through Barnett consequentials may not be sufficient to fully cover this cost in Scotland. 
Financial Outlook 2025/26 to 2027/28 Update 
2.7. In line with the framework outlined in the Revenue Budget Strategy, the Council’s
Medium Term Financial Plan (MTFP), approved by Policy and Strategy Committee on
5 June 2024, identified an envisaged three-year budget gap of £61.976 million, with an
estimated shortfall of £21.561 million in 2025/26.    
2.8. Appendix 1 highlights the main movements across financial years 2025/26 to 2027/28
since the MTFP was approved in June 2024. 
Net Budget Impact 
2.9. The overall net financial impact of changes are as follows:   
Employee costs
2.9.1. The 2024/25 pay award for teachers and single status employees which is
currently being implemented is estimated to cost an additional £8.400 million in
2025/26 (exc. adult health and social care [AHSC]), with an additional cost of
£0.300 million anticipated to 2027/28 as a result of the higher baseline position. 
Additional Scottish Government funding of £7.240 million (exc. AHSC) has been
agreed to partially offset the increased cost, resulting in a net increased cost of
£1.160 million in 2025/26 and £1.460 million over the three year period.  
2.9.2. Following changes to employer National Insurance Contributions (eNIC)
announced as part of the UK Government’s Budget on 30 October and
highlighted above, it is estimated that this will cost the general revenue budget
an additional £11.000 million.  The current planning assumption is that Local
Government in Scotland will be fully compensated for this change, representing
a net nil impact.  COSLA has advised that HM Treasury have confirmed that the
additional funding announced in the budget for Scotland of £3.4 billion does not
include the funding to compensate public sector for such increases and it is
understood that the UK Government are working through the impact, with
additional support expected in the spring supplementary estimates in February
2025. However, Scottish Parliament Information Centre (SPICe) notes that due
to the relatively larger size of the public sector in Scotland, a Barnett related
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share of funding is insufficient to fully cover this extra cost.  Future updates will
report on any additional impact as the position becomes clearer. 
2.9.3. Similarly, the financial forecast still assumes that the increased cost of employer
contributions to teacher pensions, estimated at £6.000 million, will be fully
funded, representing a net nil impact. Therefore, any shortfall in this funding will
have a financial impact. Clarity on this position is awaited. 
Contract Inflation
2.9.4. The Office for Budget Responsibility (OBR) published its latest Economic and
Fiscal Outlook alongside the UK Government’s budget, which indicates that
CPI/ RPI inflation is anticipated to remain higher for longer than previously
expected.  Therefore, it is deemed prudent to update the forecast to reflect the
impact on contract inflationary pressures.  This change is estimated to cost an
additional of £1.400 million in 2025/26, and a further £0.820 million to 20207/28. 
However, given the volatility in forecasts it is proposed that this remains under
review, with a further update provided in a future financial outlook. 
Current Service Provision & Other Cost Pressures
2.9.5. There is currently a budget burden in 2024/25 in relation to the Council’s
insurance premiums, which is being managed through one-off use of reserves. 
Following recent contract renewals it has now been confirmed that a recurring
shortfall in budget of £0.873 million needs to be managed.   
2.9.6. Following the Scottish Local Authority Remuneration Committee’s
recommendations on councillor remuneration from July 2024, an additional cost
pressure of £0.310 million has been provided for in this update.  Also, the
Council’s external audit fee has been increasing over the years, which is now
causing a recurring budget burden to be managed of £0.115 million. 
2.9.7. In addition, the Council’s liability for non-domestic rates (NDR) has increased
materially in 2024/25 mainly as a result of a revaluation of all NDR properties
by the Assessors, and the impact of tapering transitional reliefs introduced to
reduce the impact for businesses.  This has resulted in a recurring budget
shortfall to be managed of £1.380 million, after accounting for increased
inflationary pressures. 
2.9.8. Other less material updates include a requirement to manage a £0.204 million
recurring reduction in the 2024/25 general revenue grant in respect of final
adjustments to the settlement, which were confirmed after the 2024/25 budget
had been approved.  Also, increased internal recharges to the capital
programme for of £0.197 million in respect of work for City Deal has had a
positive impact on the position. 
Approved/ Proposed/ Potential Action
2.9.9. There is a trend in recent years of increased recovery of overpayments on rent
rebates and allowances, which is currently unbudgeted.  Therefore, it is deemed
prudent to create a £0.200 million recurring income budget to recognise this. 
2.9.10. The Environment and Climate Change Committee on 30 October 2024
approved the proposal to introduce a charge of £40 per annum for the uplift of
garden waste, which is estimated to generate net income of £1.504 million. 
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2.9.11. The MTFP in June 2024 reflects previous indications of a flat cash
settlement for Local Government in 2025/26. However, it should be
acknowledged that the UK Government Budget on 30 October 2024
confirmed an additional £3.400 billion in consequentials for Scotland over
2024/25 and 2025/26.  COSLA has advised that just under £1.400 billion
is in respect of revenue resources for 2025/26.  Part of the consequentials
are driven by a material increase in funding for Local Government in
England, therefore is does not seem unreasonable that there may be a
more positive settlement for Local Government in Scotland than had been
previously anticipated.  This of course is very much dependent on the
Scottish Government’s priorities and how they choose to allocate the
funding.  Therefore, whilst not currently reflected in this update it should
be noted that a 1% increase general revenue grant equates to more than
£8.000 million. The Council will only have more certainty on this position
following the provisional Local Government Finance Settlement to be
issued in December 2024. 
Budget Gap
2.10. As indicated in the updated Financial Outlook provided in Appendix 1, the changes
outlined above are estimated to increase the 2025/26 budget gap by £3.541 million and
£4.661 million over the three-year planning period.  This results in a forecast gap of
£25.102 million in 2025/26 and a gap of £66.637 million over the three years. 
Addressing the Budget Gap 
2.11. A Council Tax Strategy report will be presented to Policy and Strategy Committee on 5
December 2024, which will present options for members consideration.  In line with the
approach taken last year the Section 95 Officer will outline the income generation
potential from Council Tax increases, and the impact on the revenue budget gap or
other potential opportunities linked to the Community Investment Fund Programme and
the Council’s Programme of Work. 
2.12. Finally, Members may have to consider approving savings. Therefore, a refreshed
Savings Options pack will be distributed to senior politicians of all political groups on
28 November 2024 to inform budget deliberations. 
2.13. Council officers will work with Elected Members to ensure a number of potential
solutions are presented to enable the Council to address the budget gap in each
financial year and to meet its legal obligation to set a balanced budget.  Solutions
around income generation from potential Council Tax increases, savings and prudent
use of balances in line with the Council’s Reserves Policy will be considered. 
2.14. In line with the approach taken for the 2024/25 budget, the Section 95 Officer will
consider recommending a strategy to members to ensure a robust, deliverable and
sustainable budget is set. 
Areas of Risk and Uncertainty 
2.15. In preparing the Updated Financial Outlook, a number of volatile assumptions have
been made.  Therefore, it should be noted that estimates including those for pay, non-
pay inflation, energy, and future local government finance settlements, present
significant risk and uncertainty to the position reported.  Thus, the position remains
under continuous review and any material changes will be reported in future outlooks. 
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2.16. It is envisaged that any manageable unbudgeted pressures arising after the budget is
set in February 2025, will be managed on a one-off basis from reserves set aside to
support future budget challenges, with any recurring impact addressed in future
Medium Term Financial Plan, when there is greater certainty of impact. 
2.17. In addition, the grant settlement received by the Council may be subject to change as
the Finance Budget Bill progresses through Parliament.  Therefore, the current
planning assumption is that should further undirected funds be received on a recurring
basis as a result of this process, they will be held in reserves on a one-off basis to
mitigate against budget risks and challenges and to mitigate future budget gaps. This
is in line with previous years’ practices. 
3. Measures of success 
3.1. Ensuring that the Council sets a balanced budget for 2025/26.   
4. Supporting documentation 
Appendix 1 Updated Financial Outlook 
Elaine Kemp
Chief Officer (Finance) 
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty 
Does the report contain information that has an impact as a result of the Public
Sector Equality Duty and/or Fairer Scotland Duty? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
If Yes, has an assessment been carried out and published on the council’s
website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality-
and-fairer-scotland-duty-impact-assessments 
Yes ☐ No ☐
5.2 Financial impact 
Does the report contain any financial impacts? 
Yes ☒ No ☐ 
If Yes, have all relevant financial impacts been discussed and agreed with
Finance? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the impact?
The financial impacts are detailed in the report.
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant HR impacts been discussed and agreed with People
Resources? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.4 Legal impact 
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)? 
Yes ☐ No ☒ 
If Yes, have all relevant legal impacts been discussed and agreed with Legal and
Democratic? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal
data?   
Yes ☐ No ☒ 
If Yes, is the processing of this personal data likely to result in a high risk to the
data subject? 
Yes ☐ No ☐ 
If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e-
mailed to dataprotection@northlan.gov.uk 
Yes ☐ No ☐
5.6 Technology / Digital impact 
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management,
or connectivity / broadband / Wi-Fi? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact?
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Where the impact identifies a requirement for significant technology change, has
an assessment been carried out (or is scheduled to be carried out) by the
Enterprise Architecture Governance Group (EAGG)? 
Yes ☐ No ☐
5.7 Environmental / Carbon impact 
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.8 Communications impact 
Does the report contain any information that has an impact on the council’s
communications activities? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.9 Risk impact 
Is there a risk impact? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the key risks and potential impacts,
highlighting where the risk(s) are assessed and recorded (e.g. Corporate or
Service or Project Risk Registers), and how they are managed? 
The production of the annual budget report, annual updates to the Medium Term
Financial Plan and regular updates to the Council’s Financial Outlook presented to
Elected Members all support the Council in managing the risk of ongoing financial
sustainability which is a key corporate risk. The delivery of recurring savings and
sustainable use of reserves mitigate against risks to the Council’s financial
sustainability. 
5.10 Armed Forces Covenant Duty 
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e.
does it relate to healthcare, housing, or education services for in-Service or ex-
Service personnel, or their families, or widow(er)s)? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the provision which has been made to
ensure there has been appropriate consideration of the particular needs of the
Armed Forces community to make sure that they do not face disadvantage
compared to other citizens in the provision of public services. 
5.11 Children’s rights and wellbeing impact 
Does the report contain any information regarding any council activity, service
delivery, policy, or plan that has an impact on children and young people up to the
age of 18, or on a specific group of these? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact and the provision that has
been made to ensure there has been appropriate consideration of the relevant
Articles from the United Nations Convention on the Rights of the Child (UNCRC). 
If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been
carried out? 
Yes ☐ No ☐ 
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Appendix 1
2025/26
£000
2026/27
£000
2027/28
£000
Total
£000
Gap per approved MTFP June 2024 21,561 21,320 19,095 61,976
Updated assumptions Nov 2024
24/25 Pay Award - increased cost (exc IJB) 6,700 100 200 7,000
25/26 Pay Award - rebaseline & increased teachers impact 1,700 1,700
24/25 Pay Award increased SG Funding (net of IJB) (7,240) (7,240)
Change to Employers National Insurance Contributions (eNIC) 11,000 11,000
Assumed Funding for increased eNIC (11,000) (11,000)
Increased Teacher Pension Costs 6,000 6,000
Estimated Funding for Increased Teacher Pension Costs (6,000) (6,000)
Contract Inflation 1,400 680 140 2,220
CSPs; Audit Fee, Insurance Premiums, Cllr Salaries 1,298 1,298
Other Net Cost Pressures; NDR, GRG, City Deal 1,387 1,387
Net impact of changes 5,245 780 340 6,365
Revised Gap Nov 2024 26,806 22,100 19,435 68,341
Approved/ Proposed Action
Base Budget Adjustments; 0
Introduction of charges for green waste (1,504) (1,504)
Trend in recovery of rent allowance/ rebates (200) (200)
Revised MTFP Gap 25,102 22,100 19,435 66,637
Movement 3,541 780 340 4,661
Updated Financial Outlook
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