Agenda pack
North Lanarkshire Council · 15 December 2022
Back to Council — 15 December 2022 and its agenda
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Our Ref: Your Ref: Contact: Tel: Fax: E-Mail: Date: Mark Hamill 07811294702 hamillm@northlan.gov.uk 6 Dec 2022 Members of the Council Chief Executive’s Office Archie Aitken Head of Legal & Democratic Solutions Civic Centre, Windmillhill Street Motherwell ML1 1AB DX 571701, Motherwell 2 www.northlanarkshire.gov.uk Notice is given that a Special Meeting of the COUNCIL is to be held within the Council Chamber, Civic Centre, Motherwell on Thursday, 15 December 2022 at 2:15 pm or immediately following the conclusion of the Planning Hearings Committee, which you are requested to attend. The agenda of business is attached. Chief Executive Members : Councillors: 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, 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 Linden, J Logue, H Loughran, F MacGregor, A Magowan, A Masterton, M McBride, B McCluskey, B McCulloch, M McCulloch, P McDade, F McKay, R McKendrick, J McLaren, C McManus, F McNally, M McPake, J McPhilemy, A McVey, L Mitchell, L Nolan, P Patton, J Reddin, L Roarty, D Robb, G Robinson, N Shevlin, W Shields, A Smith, K Stevenson, A Stubbs, L Stubbs, R Sullivan, A Thomas, J Toner, S Watson, C Williams, N Wilson and G Woods. Page 1 of 58
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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 21/00273/FUL - Rail Freight Terminal, Distribution Centre and Office with Ancillary Buildings, Cranes and Associated Landscaping and Infrastructure Land Adjacent To Wishaw Deviation Railway Line, Site Of Former Ravenscraig Steelworks (page 5 - 58) Submit report by the Head of Planning and Regeneration on an application for planning permission by John G Russell (Transport) Limited (copy herewith) Page 3 of 58
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North Lanarkshire Council Planning Applications for consideration of Planning Committee Committee Date: 15-12-2022 Ordnance Survey maps reproduced from Ordnance Survey with permission of HMSO Crown Copyright reserved AGENDA ITEM 2 Page 5 of 58
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APPLICATIONS FOR PLANNING COMMITTEE 15th December 2022 Page No Application No Applicant Development/Site Recommendation 7-58 21/00273/FUL John G Russell (Transport) Limited Rail Freight Terminal, Distribution Centre and Office with Ancillary Buildings, Cranes and Associated Landscaping and Infrastructure Land Adjacent To Wishaw Deviation Railway Line, Site Of Former Ravenscraig Steelworks Access Via Ravenscraig Spine Road (A721), Motherwell Refuse Page 6 of 58
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Application No: 21/00273/FUL Proposed Development: Rail Freight Terminal, Distribution Centre and Office with Ancillary Buildings, Cranes and associated Landscaping and Infrastructure Site Address: Land Adjacent To Wishaw Deviation Railway Line Site Of Former Ravenscraig Steelworks Access Via Ravenscraig Spine Road (A721) Motherwell Date Registered: 15th March 2021 Applicant: John G Russell (Transport) Limited Deanside Road Hillington Glasgow G52 4XB Agent: GL Hearn Limited Broadhurst, The Tootal Buildings 56 Oxford Street Manchester M1 6EU Application Level: National Application Contrary to Development Plan: Yes Ward: 19 Motherwell South East And Ravenscraig Kenneth Duffy, Agnes Magowan, Nathan Wilson, David Robb Representations: 697 letters of representation received from 687 parties. Recommendation: Refuse Reasoned Justification: Whilst rail freight as a form of development receives support, it is not identified for such use at this location. There are no material considerations that would outweigh the adverse impacts that are considered to arise from the proposal, and it is therefore considered to constitute a significant unacceptable departure from the Development Plan. Page 7 of 58
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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: 21/00273/FUL Name (of applicant): John G Russell (Transport) Limited Site Address: Land Adjacent To Wishaw Deviation Railway Line, Site Of Former Ravenscraig Steelworks - Access Via Ravenscraig Spine Road (A721), Motherwell Development: Rail Freight Terminal, Distribution Centre and Office with Ancillary Buildings, Cranes and associated Landscaping and Infrastructure Page 8 of 58
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Recommendation: Refuse for the Following Reasons:- 1. The proposed development does not accord with the spatial vision at every level of the Development Plan hierarchy: National Planning Framework 3 (NPF3), Clydeplan Strategic Development Plan (CSDP), and North Lanarkshire Local Development Plan (NLLDP) due to development of this form not being supported at this location. In addition, the impacts of the phase one development are considered unacceptable in terms of its known visual impacts, and the losses of housing land, green belt, habitat and woodland, and an acceptable form of access to, and peaceful enjoyment of greenspace, and are considered to undermine the ability to deliver the Ravenscraig Masterplan objectives in becoming a sustainable community. 2. Insufficient information has been submitted for phase one to clearly demonstrate all aspects of its visual impact and the impact of the development on the road network, road and pedestrian access and safety, noise, and air quality. As noise and air quality form part of the Environmental Impact Assessment (EIA), the EIA is also considered to be inadequate. 3. In the absence of confirmed cut and fill levels for phase one, and a detailed layout for phases two and three, it would be wholly inappropriate at this stage to sanction the entire loss of habitat within the phase two and three areas which would occur during enabling works for which permission is sought under this application. Enabling works involve site clearance, earthworks to provide material in support of platforming phase one to final design levels, and drainage. There is potential that some habitat could remain once cut and fill levels are confirmed, and under a redevelopment scheme for phases two and three. As this habitat includes ancient woodland in particular, an irreplaceable precious resource, it should be protected until such time as the exact impact is known and can be given full consideration. Page 9 of 58
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Background Papers: External consultees Letter from Scottish Environment Protection Agency received 23rd September 2021 Letters from Nature Scot received 1st April 2021, 12th April 2021, 14th April 2021, and 25th November 2021 Letters from Transport Scotland received 23rd March 2021 and 7th April 2021 Letter from Scottish Water received 18th March 2021 Letter from Historic Environment Scotland received 14th April 2021 Letters from Network Rail received 30th April 2021, 29th October 2021, and 21st October 2022 Letter from Strathclyde Partnership For Transport received 2nd December 2021 Letters from Scottish Gas Network received 31st March 2021, 7th May 2021, and 24th November 2021 Letters from Scottish Power Environmental Planning received 16th March 2021 and 7th December 2021 Letters from The Coal Authority received 29th March 2021, 22nd April 2021, 30th September 2021, 10th December 2021, and 15th February 2022 Letters from the Health And Safety Executive received 18th March 2021, 24th March 2021, 18th November 2021, and 1st December 2021. Letters from Scottish Forestry received 20th April 2021 and 22nd November 2021 Internal consultees Letter from the Archaeology Service received 19th March 2021 Memos from Protective Services received 16th June 2021, 29th June 2021, 12th October 2021, 11th November 2021, 24th November 2021, 26th November 2021, 9th December 2021, 13th December 2021, 14th December 2021, 14th December 2021, 11th October 2022, and 28th October 2022 Memos from Transportation received 1st July 2021, and 8th December 2021, and 4th November 2022 Memos from Greenspace received 13th April 2021, and 30th November 2021 Memos from Arbor received 26th November 2021 and 7th December 2021 Memo from Education received 30th November 2021 Contact Information: Any person wishing to inspect these documents should contact Mrs Joanne Delaney at 01236 632500. Report Date: 2nd December 2022 Page 10 of 58
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APPLICATION NO. 21/00273/FUL EXECUTIVE SUMMARY I. Site and Proposal Ii. The site measures approximately 95 hectares and is located within Ravenscraig in Motherwell where it lies half a mile remote from the main spine road on Ravenscraig’s eastern side. (Refer to appendix 1) The Wishaw Deviation Line (WDL) railway splits the site in two lengthwise creating an eastern and western development parcel. The South Calder Water (SCW) bounds the site on its northern edge and returns just beyond its eastern edge. Meadowhead Road housing and Wishaw Golf course lie near the southern boundary, whilst there is no physical demarcation of the east and west site edges. The site has lain undeveloped since the steelworks days and has naturally regenerated as a variety of habitats which complement the existing mature woodland. Iii. In phase one, the eastern parcel is proposed to create a rail freight terminal to be operated by the applicant Russell Transport Ltd. The terminal will operate 24 hours a day seven days a week and will comprise four track sidings measuring approximately 800 metres long, two cranes, a 27,870 square metre distribution warehouse measuring up to 36 metres in height, along with an office with training academy and other ancillary buildings, separate lorry and car parking, landscaping and SUDS ponds. The western parcel will create a new habitat area named the ‘green lung’ where the public will be encouraged to enter and be served by a visitor parking area. Access will be taken via a fourth arm to be created on the roundabout of New Craig Road with Plantation Road on the main spine road (adjacent to the former British Research Establishment (BRE) site) which will lead in an arc towards the WDL where it will pass under to reach the eastern parcel. To mitigate noise, barriers will be placed in and around the terminal and green lung areas ranging from 2-12 metres high. In addition, a 5.5 metre high barrier will run the length of the access road near to its limit with the roundabout on New Craig Road, passing under the WDL and terminating near to the terminal’s office building and internal roundabout. The application was accompanied by an Environmental Impact Assessment (EIA), the applicant having determined that it be restricted to addressing effects on noise, air quality, and ecology. (Refer to appendix 2) Iiii. Development is proposed over three phases. This current application seeks detailed permission for phase one for the works described above, as well as enabling works of site clearance, engineering works, and drainage for phases two and three. If this current application is approved and developer interest justifies it, detailed applications for planning permission will be submitted for phases two and three at a future date. Meantime however, early discussions indicate that two warehouses measuring 46,451 square metres each will be developed on these phases. The applicant hopes that that the phase one works would become operational in 2027. Iiv. The new facility at Ravenscraig is considered to form an upgraded replacement of the applicant’s existing operations at Gartsherrie allowing the terminal railhead to close freight operations entirely at that location and the land to be offered to the market for a potential mixed use redevelopment scheme of residential and open air sports facilities. The applicant estimates that 190 Gartsherrie employees would relocate to the new Ravenscraig facility, and between 50-75 new posts would be created under phase one. Discussions with interested parties for phases two and three anticipate 1700-2000 full time employees in total created across all three phases of the hub campus and approximately 800-1000 of which would be new jobs. Iv. It is important to note that the indicative information on phases two and three including job creation, can be given little or no weight in determining this application. This is because these further phases would of themselves, require (EIA), and because there are no firm details of the proposals. II. Consultations IIi. The majority of consultees raised no objections and of these, planning conditions can adequately address any outstanding requests for further information in the event Committee are minded to approve the development. However, NLC Transportation and NLC Protective Services consider that the extent and nature of likely impacts have not been clearly demonstrated on the road network, access and pedestrian safety, and air quality and noise, and of these, it would not be appropriate to attach planning Page 11 of 58
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conditions especially regarding noise and air quality which are considered under EIA and should have been clarified to enable a fully informed decision on the development. In addition, NLC Greenspace, and Arbor Sections consider that insufficient compensation has been provided for the loss of ancient woodland in particular and other forms of habitat. III. Representations IIIi. 697 letters of representation were received from 687 parties including Monica Lennon MSP, Marion Fellows MP, and Ravenscraig Community Action Group (RCAG) all objecting to the development. Concerns were raised that the proposals did not accord with the development plan nor Ravenscraig Revised Masterplan and would raise adverse impacts on noise; air quality; light pollution; road network; access, and safety; ecology and environment; landscape/visual; residential amenity; health and wellbeing; ability to deliver the Masterplan objectives; and property values where residents were not made aware of the proposals at the time of purchase. Concerns were also raised that the pre-application consultation was only online and carried out during the pandemic limiting the public’s involvement in the process. IIIii. As current landowner, Ravenscraig Ltd confirmed their support for the proposals noting that the development will positively contribute to regeneration of a large area of Ravenscraig and offer beneficial employment opportunities. They consider that due to the site occupying a discrete parcel of land, it will not undermine the long held objectives of creating a mixed use scheme in the overall Ravenscraig site where the Council will retain all the necessary controls to ensure the desired outputs are delivered. They submitted an indicative revised Masterplan layout detailing how the design may potentially be re-worked in the event that the railhead proposal is approved. This involves retaining two road junctions onto the terminal’s access road at ‘Ravenscraig Square’ and fronting a range of residential and non-residential community buildings towards the green lung to embrace it as an asset. (Refer to appendix 5) IV. Assessment Summary Development Plan National Planning Framework 3 2014 (NPF3) IVi. NPF3 sets out the national spatial strategy by providing a framework for flexible sustainable growth and development. Ravenscraig is identified in NPF3 as a sustainable place for growth and is accorded National Development status where it benefits from additional impetus to secure further investment. It notes that the master-planned redevelopment of Ravenscraig will transform one of Europe’s largest areas of vacant and derelict land into a new sustainable community. It is considered that the application meets the spatial development priorities in terms of reducing carbon emissions and improving rail freight connectivity, but it is not supported at this location due to it not having been included as part of the master-planned approach for Ravenscraig in its most recent revised form approved in 2020, and for reasons discussed later in the report, the proposal is considered to create adverse impacts. It is considered therefore, that the proposals do not accord with the national spatial strategy set out in NPF3. Clydeplan Strategic Development Plan 2017 (CSDP) IVii. The CSDP similarly finds fault in the proposal as it is not located on one of the seven sites it identifies for rail freight development in its spatial strategy. Adverse impacts are also considered to arise when considered under its placemaking, housing, green network, forestry, green belt, and freight policies such that overall, it is considered that the proposals do not accord with the principles set out in the CSDP nor is it considered an acceptable departure. North Lanarkshire Local Development Plan 2022 (NLLDP) IViii. The NLLDP zones the application site broadly in accordance with the Revised Ravenscraig Masterplan as: - • PROM LOC 1 – Regeneration Priorities: Ravenscraig; • PROM LOC 3 - Housing Development Sites; • PP3/AD3 – General Urban Area; • PP4/AD4 – Green Belt; and Page 12 of 58
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• PROT A– Site of Importance for Nature Conservation (SINC). Again, the proposals are not supported by the NLLDP due to rail freight development not forming part of the approved land uses, and adverse impacts are considered to arise with respect to its known visual impacts, and the losses of housing land, green belt, habitat and woodland, and an acceptable form of access to, and peaceful enjoyment of greenspace, and are considered to undermine the ability to deliver the Ravenscraig Masterplan objectives. In addition, insufficient information has been submitted for phase one to clearly demonstrate all aspects of its visual impact and the impact of the development on the road network, road and pedestrian access and safety, noise, and air quality. Collectively, the form of development proposed is supported due to the carbon reduction benefits and increased rail freight connectivity it would provide but is not supported at this location where it is considered to give rise to adverse effects. The proposal is not considered to accord with the Development Plan and should therefore be refused unless material considerations indicate otherwise. Furthermore, in the absence of full demonstration of the impacts on noise and air quality which form part of the Environmental Impact Assessment (EIA), the EIA is also considered to be inadequate and the application should be refused on these grounds. Material Considerations Scottish Planning Policy 2014 (SPP) IViv. SPP sits alongside NPF3 by providing general principles by which Scottish planning policy and other land use matters should be assessed. Throughout the SPP, there is a focus on economic development within a framework for sustainability and place-making, with a presumption in favour of development considered as sustainable development. In terms of assessment, the primacy of the development plan remains unaltered and the presumption in favour of sustainable development is a material consideration. As noted earlier, it is considered that the promised economic benefits in terms of job creation arising from phases two and three should be given little or no weight under this application. In addition, whilst the applicant provided information on the economic benefits which may arise from re-development of the Gartsherrie site, this too can be given little or no weight as this would require detailed consideration of the proposals under any separate planning application which may be forthcoming for that site. It is accepted however, that the relocation of the business from Gartsherrie could afford other benefits to the local community through the removal of a ‘bad neighbour’ noise producing development and large volume of HGVs from local roads. It is noted however, that phase one is estimated to create between 50-75 new full-time jobs. It can also be considered that many temporary jobs would also be created during the construction phase. As well as jobs, the ability to accommodate 775 metre length trains then affords opportunity to access international markets and the Scottish Government is keen to increase opportunities in this regard. The applicant has demonstrated specific locational need as this particular location benefits from being able to provide direct connections north and south without requiring deviating on routes, loop around, reverse, shunt or split trains. Whilst resulting in greater efficiency of handling goods, it also has the added benefit of freeing up precious capacity on the rail network which is currently constrained. Lastly, adjacent land at this location can support large warehouses and access the strategic road network reasonably quickly. For all these reasons, the proposals are considered to accord with SPP. However, SPP states that the planning system should support economically, environmentally and socially sustainable places by enabling development that balances the costs and benefits of a proposal over the longer term. Due to the adverse impacts noted earlier, it is considered that the economic and locational benefits of this proposal do not outweigh these concerns such that on balance, the development is not considered to accord with SPP. Revised Ravenscraig Masterplan 18/00463/PPP IVv. This application was approved on 18th November 2020. The application site is intended to be developed mainly as housing plots, with the north and east edges forming part of the proposed community nature park, whilst land at the south edge and adjacent to the roundabout access position, are allocated as other woodland/landscaped areas. An access road forming a fourth arm to the roundabout adjacent to the former BRE site and arcing round past the railway to the eastern parcel was also proposed in the Page 13 of 58
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Masterplan in roughly the same location as the rail freight access road, but was to serve residential plots with new junctions leading from it. It is also noted that directly north of the access roundabout, lies the site for the new school. (Refer to appendices 3 and 4) It is considered that the impacts arising from the development can most fully be assessed by considering the existing built context as well as that to be built out under the Masterplan and in doing so within the main body of the report, several of the individual technical aspects are deferred for assessment to the Masterplan heading found in Material Considerations. Meantime, though, it is considered that the same adverse impacts as discussed under the NLLDP perpetuate when considered under the Masterplan land allocations. National Planning Framework 4 Consultative Draft 2022 (NPF4) IVvi. NPF 4 was laid before the Scottish Parliament as a revised Draft for approval on 8th November 2022, meaning that it is now a material consideration in the assessment of planning applications. It sets out the Scottish Government's current view on delivering sustainable, liveable and productive places through the application of spatial principles. The weight to be given to it prior to its adoption is a matter for the decision maker. Under the Draft. it should be noted that Ravenscraig is no longer accorded national development status, however, it is referred to as “a long standing post-industrial site where new development, including improved transport connectivity, can bring new models of low carbon living at scale”. The applicant considers that the development accords with the Draft due to beneficially re-using brownfield land, stimulating development on this particular part of Ravenscraig which has lain undeveloped since the steelworks closed, supports improvements in the transport and distribution sector, and will bring much needed jobs for local people to help counteract inequality and deprivation. It is agreed that these are supported under the Draft, however, its spatial principles require that future places work for everyone. Rather than compromises or trade-offs between environmental, social, and economic objectives, it is an integrated strategy to bring together cross-cutting priorities and achieve sustainable development. IVvii. Until it is formally adopted, it is considered that little weight should be accorded to NPF 4. The reason for this is that it still has to be considered and approved by the Scottish Government. In addition, NPF 4 places additional requirements on the applicant which have not been requested thus far during the processing of the application due to the late stage of these requirements now being introduced. Notwithstanding this, it is noted that the proposal conflicts with the Development Plan’s spatial strategy due to not being identified for this use at this location. In terms of material considerations, it is accepted there would be economic and operational benefits to the rail sector, however, these are considered to be greatly outweighed by the adverse impacts considered to arise in terms of environmental and social objectives sought under the Ravenscraig Masterplan. A strong theme coming through in the Draft is the greater emphasis requiring to be given to the assessment of health and wellbeing impacts from developments. In this case, the resultant development would be visually intrusive, would create an environment that would feel neither safe nor welcoming and would lie within an area that was intended to provide many new homes and beyond this, a greenspace resource for residents and the wider community to retreat to and engage with nature. Instead, significant areas of housing, woodland, and other habitat would be lost, and acceptable access to, and peaceful enjoyment of greenspace, would not be possible. All of these factors would not support the health and wellbeing of residents and visitors. It has also not been demonstrated that effects from noise, air quality, access and safety would be within acceptable standards or physically achievable. As such, the development is not considered to accord with NPF 4. V. Conclusion Vi. It is considered that whilst rail freight as a form of development receives support, it is not identified for such use at this location. There are no material considerations that would outweigh the adverse impacts that are considered to arise from the proposal, and it is considered to constitute a significant unacceptable departure from the Development Plan supported by an inadequate EIA. It is therefore recommended that planning permission be refused. Page 14 of 58
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Abbreviations AOD – Above Ordnance Datum APB – Area Planning Brief AQIA – Air Quality Impact Assessment BRE – British Research Establishment CNP – Community Nature Park CSDP – Clydeplan Strategic Development Plan EIA – Environmental Impact Assessment Regulations 2017 ES – Environmental Statement HES – Historic Environment Scotland HLS – Housing Land Supply HSMA - Housing Sub-Market Area LEPO – Long Established Plantation Origin LVIA – Landscape and Visual Impact Assessment NIA – Noise Impact Assessment NLLDP – North Lanarkshire Local Development Plan NPF 3 – National Planning Framework 3 NPF 4 – National Planning Framework 4 NR – Network Rail NSR – Noise Sensitive Receptor PPiP – Planning Permission in Principle RCAG – Ravenscraig Community Action Group RSF – Regional Sports Facility SCW – South Calder Water SEIL - Strategic Economic Investment Location SEPA – Scottish Environment Protection Agency SFTH - Strategic Freight Transport Hubs SPP – Scottish Planning Policy SPT – Strathclyde Partnership for Transport TP – Travel Plan TS – Transport Statement WDL – Wishaw Deviation Line (railway) Page 15 of 58
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Structure of Report 1. Site Description 2. Proposed Development 3. Applicants Supporting Information 4. Site History 5. Development Plan - The National Planning Framework 3 2014 (NPF3) - Clydeplan Strategic Development Plan 2017 (CSDP) - North Lanarkshire Local Development Plan 2022 (NLLDP) 6. Consultations - External Consultees - Internal/NLC Services 7. Representations 8. Assessment - Development Plan Policy (NPF3, CSDP, NLLDP) 9. Other Material Considerations - Scottish Planning Policy 2014 (SPP) - Revised Ravenscraig Masterplan 18/00463/PPP approved 18th November 2020 - The National Planning Framework 4 Consultative Draft 2022 (NPF 4) 10. Assessment of Consultation Responses 11. Assessment of Representation Comments 12. Conclusions Appendices 1. Comparison of the rail application site boundary relative to the overall Ravenscraig Masterplan boundary 2. Rail Application Site Layout 3. Ravenscraig Masterplan Land Uses 4. Ravenscraig Masterplan Plot Layout 5. Ravenscraig Ltd Suggested Masterplan Changes Page 16 of 58
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APPLICATION NO. 21/00273/FUL REPORT 1. Site Description 1.1 The site is located within the eastern part of Ravenscraig in Motherwell (refer to appendix 1). The site is predominantly rectangular in shape arranged north-south but is appended by a slender crescent which extends like an arm to the northwest until it meets the roundabout on New Craig Road adjacent to the former Building Research Establishment (BRE) site where consent has been granted in 2022 for new build Council housing. The Wishaw Deviation Line (WDL) railway splits the site in two lengthwise, creating an eastern parcel amounting to approximately three quarters of the overall area, and the western portion comprising the remaining quarter. The northern boundary is defined by the South Calder Water (SCW), and the site runs fully to the limit of Ravenscraig’s southern boundary which is defined by existing house boundaries on Meadowhead Road and a remote track, whilst the east and west edges have no physical demarcation. 1.2 The application site measures approximately 95 hectares in total and within the rectangular area, is 1500 metres at its longest stretch equivalent to almost a mile, and 657 metres wide. Ground levels vary considerably within the general area with the SCW sitting in a deep gorge, the WDL crossing the Water by viaduct and thereafter accommodating railway underbridges at its northern and southern limits made possible by its continuing elevated position which is largely adjoined in common by the eastern parcel, but which sit approximately 8 metres above the western parcel at the greatest extreme. Within the wider Ravenscraig site, levels generally continue to fall at a gentle gradient east to west, and north to south. 1.3 Since the closure of the steelworks, the site has lain dormant having allowed nature to largely re-claim it and form grassland interspersed with trees and shrubs which complement dense broadleaved woodland, including large areas designated as ancient woodland of long established plantation origin (LEPO). These link with further woodlands forming a riparian corridor to the SCW which meanders along the northern boundary before returning southward beyond the eastern edge of the site where thereafter Dalziel Park estate, BOC plant, and Glen/Knowenoble estates lie as pockets within the wider countryside in the distance. Beyond the site’s western edge, lies more intervening vegetation with areas of mounding being legacy stockpiled material from the steelwork operations, along with various other remnant areas of hardstanding, the odd building, and roadway, before meeting the Regional Sports Facility (RSF) and new public park towards the northern end, with the main Ravenscraig spine road thereafter. Within the vicinity of the crescent shaped area, lie Ravenscraig’s new Barratt and Taylor Wimpey estates, Ravenscliff pub/restaurant with hotel, and Prospecthill. Within the vicinity of the site’s southern edge lies Meadowhead Road housing with the new Keepmoat Homes estate further west, whilst to the south-east lies the pump track, Wishaw Golf Course, the listed Coach House and remnants of the former Wishaw House. At a wider distance lie Carfin to the north, Cleland and Wishaw to the east, Craigneuk to the south, and Motherwell to the west. 2. Proposed Development 2.1 Planning permission is sought for the construction of a rail freight terminal by Russell Transport Ltd which they will operate 24 hours a day seven days a week and will comprise four sidings with two entry/exit points, two cranes, a distribution centre, office and ancillary buildings, and associated infrastructure and landscaping including a new habitat area termed the ‘green lung’. Works are intended to take place over three phases with this current application seeking detailed permission for phase one and enabling works only for phases two and three. (Refer to appendix 2) 2.2 Built development is to take place on the eastern parcel whilst the green lung is to be formed over the entirety of the western parcel. The first phase comprises the following development:- On the eastern parcel amounting to approximately 30 hectares: • A four-track intermodal terminal served by two entry/exit points and two overhead cranes, including formation of the full-length crane roadway. Each track measures approximately 800 metres long giving an overall total of 3200 metres; • Two conjoined distribution warehouses comprising a high bay of 36 metres in height and a low bay 9 metres high and giving a combined footprint of 27,870 square metres; Page 17 of 58
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• A two storey office forming the applicant’s new HQ with integrated training academy and innovation hub, a separate vehicle maintenance workshop with adjoining driver welfare accommodation; • A three-arm roundabout to segregate access for cars and HGVs; • Trailer parking for vehicles moving goods to and from the site by road, car parking for staff, and a container storage area; • Ancillary landscaping with walkways and SUDS ponds; • To mitigate noise, barriers measuring 2, 5, and 5.5 metres high will be placed in and around the terminal; and • Due to the requirement for a continuous noise barrier on the western side of the railway which will block an existing lineside access for Network Rail (NR), the access will require to be relocated to the eastern parcel in a location still to be agreed with NR. On the western parcel amounting to approximately 20 hectares: • Compensatory habitat creation in the green lung including planting and ponds; • Sculpted mounds and meandering walkways linking with the wider network of paths to be created; • A visitor parking area at its northern end; and • To mitigate noise, a continuous acoustic barrier measuring 8 metres high will be sited nearby to the west of the WDL running the majority of the length of the site before transitioning down to 4.5 metres high at the site’s southern extreme adjacent to houses on Meadowhead Road. Overlapping arced barriers measuring mainly 9 metres high but transitioning to 12 metres high at its northern extreme, will run the entire length of the green lung’s western boundary adjacent to the Ravenscraig Masterplan’s future housing plots. On the crescent area amounting to approximately 7 hectares: • Remote vehicular access to the site will be taken by forming a 4th arm to the roundabout on New Craig Road with Plantation Road adjacent to the former BRE site some 800 metres (half a mile) distant from the WDL, where the SCW passes into culvert enabling the access road to head south before arcing round to the east following where the SCW lies in open channel, then picking up the route of remnant roadway and passing under the WDL to the eastern parcel; • A 2 metres wide footway with 2 metres wide verge will adjoin the new 7.3 metres wide carriageway on its northern side only until it passes under the WDL whereafter it will transition down to a 2 metres wide footway with no intervening verge separating it from the carriageway; and • To mitigate noise, an acoustic barrier measuring 5.5 metres high will be sited on both sides of the access road. On the northern side, it will sited behind the footway and run from nearby to the roundabout on New Craig Road, passing under the WDL and terminating near to the terminal’s office building and internal three-arm roundabout. On the southern side, it will sit on the verge and again run from adjacent to the New Craig Road roundabout until it meets the green lung where it will return in an arc to overlap the 12 metres high barrier discussed above. On the enabling works area for phases two and three amounting to approximately 38 hectares: • Forming a continued access road to the limit of where phase one connects to the phase 2 area; • Site clearance and earth works to provide material for creating finished design platform levels on phase one; and • installation of drainage infrastructure. 2.3 By nature of the operational requirement for the four new sidings to connect to the rail network, these will be formed at the same ground level as the WDL. The exact final design ground levels and extent of cut/fill will be informed by further intrusive site investigation, however current best estimates are that the eastern parcel will be engineered where required, to a similar level just slightly lower than the WDL over its entire extent to form a largely flat slab for ease of goods handling, and the western parcel will remain at a lower ground level. The phase one works amount to approximately 27% of the overall area to be developed on the eastern parcel and are located towards its northern end due to the vehicular access location. The applicant notes that the capability of the railhead to accommodate trains is dictated by track length which in this case at 3200 metres, results in a maximum of 15 trains. For phase one, initially 6-7 trains are anticipated to arrive and depart per day and if demand increases, this will rise to 10 trains per day, this being the maximum handling capacity of phase one due to the available site area and Page 18 of 58
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range of accommodation. Trains will be destined for Inverness, Aberdeen, Blackford, and Daventry Raft International Freight Terminal (DRIFT). In turn, this equates to approximately 840 heavy goods vehicle (HGV), and 294 staff car movements per day. The development will enable the relocation of 190 posts from the applicant’s existing facilities at Gartsherrie and the creation of 50-75 new jobs in phase one in warehousing, IT, picking, and the apprenticeship training academy. There will also be many jobs created during the construction of the facility. It is envisaged that the phase one site will become operational in 2027. 2.4 The applicant’s expansion needs will be met under the phase one accommodation. Phases two and three will therefore not be taken forward by them but the land will instead be offered to other operators. Discussions with two interested parties indicate the potential for there being a requirement for an additional 46,451 square metres distribution building on each phase which the applicant estimates will provide 1700-2000 full time employees in total created across all three phases of the hub campus and approximately 800-1000 of which would be new jobs with a net £62m annual GVA to the North Lanarkshire economy. These figures are those submitted by the applicant in support of the application but have not been verified by the Planning Service. Again, there would be further jobs created during construction. If this current application is approved for phase one, detailed applications for planning permission for phases two and three will be submitted at a future date. It is expected that the remaining 5 train handling capability of the railhead will be taken up by phases two and three thereby exercising full use of the facility. 3. Applicant’s Supporting Information 3.1 The applicant (John G Russell Transport Ltd) explained that their aspirations for expansion and upgrade are driven by a desire to accommodate 775 metre length trains which then affords opportunity to access international markets, however this cannot be achieved at their existing facilities at Gartsherrie. Having investigated 14 other existing freight locations, the applicant considers that there are also none that offer direct connections north and south, avoid the need to circulate or deviate on routes, nor any that avoid a need to shunt, loop around, reverse, or split trains. The Ravenscraig site therefore benefits greatly from being able to cater for all these rail needs thereby increasing efficiency of movement but also freeing up capacity on the rail network which is currently constrained, whilst also offering substantial landholdings for expanding warehousing, and also being relatively accessible to the strategic road network. In respect of the latter, significant improvements will occur in the near future once the dual carriageway is constructed between the RSF and Windmillhill Street, along with the dualling upgrades of the A723 and Airbles Road which collectively will provide direct links between Ravenscraig and the M8 to the north and M74 to the south, all of which are still currently programmed to be operational ahead of the freight terminal. 3.2 Ravenscraig Ltd as current landowner, have confirmed their support for the proposals noting that the development will positively contribute to regeneration of a large area of Ravenscraig and offer beneficial employment opportunities. They consider that due to the site occupying a discrete parcel of land, it will not undermine the long held objectives of creating a mixed use scheme in the overall Ravenscraig site where the Council will retain all the necessary controls to ensure the desired outputs are delivered. They submitted an indicative revised Masterplan layout (refer to appendix 5) detailing how the design may potentially be re-worked in the event that the railhead proposal is approved. Network Rail also confirmed their broad support for the development at a high level but that the specifics of design were still to be worked through. Transport Scotland noted that they wished to promote and facilitate the development of rail terminals of this character, but acknowledged that this particular site was not allocated for this form of development on the Ravenscraig Masterplan. 3.3 Given the significant scale and nature of the works compared against the context of the site and surrounding area attributes, environmental impact assessment (EIA) becomes a consideration. In most cases, the applicant requests a ‘screening opinion’ from the Planning Authority to determine whether EIA is required, and if it is, they also seek a ‘scoping opinion’ which determines the matters which must be assessed in the EIA as informed by responses from statutory consultees. In an uncommon approach also permitted under the EIA Regulations 2017, the applicant alternatively advised that they would not be seeking a screening or scoping opinion, but that they would be submitting an EIA and they would consult with the relevant bodies. In light of this approach, the applicant was advised that the first opportunity the Planning Authority would have to confirm the adequacy of the EIA would be upon receipt of all consultations undertaken during the formal planning application process which may cause delays Page 19 of 58
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to be incurred if further matters are deemed to need assessed. The planning application was duly accompanied by an EIA, the applicant having determined that the scope of the EIA be restricted to addressing effects on noise, air quality, and ecology. The application was also supported by supplementary information on the following matters: • Pre-Application Consultation Report • Design and Access Statement • Site Investigation for Contaminants • Coal Mining Risk Assessment • Flood Risk Assessment • Drainage Impact Assessment • Landscape and Visual Impact Assessment • Lighting Strategy • Transport Statement • Archaeology and Cultural Heritage • Population and Human Health • Climate Change • Major Accidents and Natural Disasters • Economic Assessment • Energy/sustainability statement • The Case for a Rail Terminal at Ravenscraig • EIA Regulation 19 Notification and Consultation • Green Lung Woodland Creation • Planning Statement • Non-technical Summary • Construction Dust Management Plan • Ravenscraig Ltd’s Report on Potential Changes to the Masterplan • Applicant response to Representation Comments 3.4 The Pre-Application Consultation report summarised online events which were held over two sessions on 25th November 2020 and 9th December 2020 between the hours of 1600-1930 hours and was publicised in the Wishaw Press and Motherwell Times beforehand. For those unable to access online information or attend on those dates, a contact telephone number and address was provided to enable discussion and any requests for hard copies of information to be posted as well as comments to be returned. 4000 targeted leaflets were distributed locally within Ravenscraig and surrounding neighbourhoods, a Facebook page was held on Craigneuk Community Council’s site and wider press releases were printed in local and national publications to raise awareness. In addition to the consultation proposed under the Proposal of Application Notice (PAN) as noted above, a third online event was also held on 16th December 2020 in response to feedback from the public and discussions with the council. Again notification was sent ahead of this date. The Planning Service was aware of and approved the proposed consultation package and confirmed that it accorded with the (then) approved regulations for Pre-Application Consultation which was in effect during the pandemic. 4. Site History 4.1 As noted above in Section 1, no physical development has taken place on this particular part of Ravenscraig since the closure of the steelworks in 1992. However, the site has been earmarked for development since approval of the original Ravenscraig Masterplan in 2005, planning application reference 01/00758/OUT (Mixed Use Development Comprising Residential Areas, Primary Schools/Community Uses, Business and Employment Uses, Open Space, a New Town Centre Including Retail, Leisure, Business, Housing and Hotel, and Associated Transport Infrastructure) which expected the entire Ravenscraig site re-development to take some 20 years to complete. Under this Masterplan, the application site itself was proposed to be mainly redeveloped for housing, but the north and east edges were to become part of a wider community nature park, a sliver of the southern boundary to be retained as woodland, whilst the middle portion straddling the WDL comprised part of the town centre Page 20 of 58
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with proposed train station. However, progress on the overall site was slower than anticipated, due in part to the recession of 2008 and in part to significant changes affecting the retail and commercial sectors. This resulted in the proposed nature and scale of the development approved under the terms of this planning consent to be considered unfeasible in the form originally proposed and approved. 4.2 Having undertaken a review, Ravenscraig Ltd submitted a Revised Masterplan (refer to appendices 3 and 4), planning application reference 18/00463/PPP (Revision of Mixed Use Development Approved under Planning Permission Ref: 01/00758/OUT Comprising Residential Areas, Educational/Community Facilities, Business and Employment Uses, Open Space including Town Park, Hotels, a New Town Centre including Retail, Leisure, Business and Housing with associated Transport Infrastructure) which was approved on 18th November 2020. Under this Masterplan, the community nature park designation remains unchanged, but the southern woodland area has been slightly enlarged. The town centre area has been reduced and relocated slightly further west, whilst any specific proposals for the rail station have been removed at this time such that these former allocations where they fall within the application site, have now been given over for additional residential development. The statutory bodies with the responsibility for transport infrastructure (Transport Scotland and SPT) concluded that the rail station would not prove viable (at this time), the preference being for improved public transport linkages (a circular bus service) to existing rail stations at Motherwell, Carfin and Shieldmuir. Should there be a desire to bring forward development of a rail station on the WDL in the future, this current application would preclude the possibility of it being on its originally intended location, and the only other un- developed land adjacent to the WDL within Ravenscraig lies on the proposed housing site west of BOC, and part of the community nature park south of BOC. 4.3 To date, Ravenscraig has seen the following developments take place: - • The dual carriageway spine road from Carfin to Craigneuk; • Phase one of the employment land spine road; • Approximately 900 houses and flats completed; • New College Lanarkshire Campus; • Ravenscraig Regional Sports Facility; • Public playpark; • Active Travel Route connecting Craigneuk with the RSF; • Marston’s Family Pub/Restaurant; • Hotel accommodation (40 bed) adjacent to Marston’s; and • Building Research Establishment Innovation Park (now demolished). 5. Development Plan 5.1 This application raises issues of a national, strategic, and local nature and therefore must be considered in terms of the National Planning Framework (NPF3), the Strategic Development Plan, and the Local Development Plan. National Planning Framework 3 (2014) 5.2 The third National Planning Framework (NPF3) provides a long-term strategy for planning in Scotland. It provides the spatial expression of the Governments economic strategy and its plans for delivery of development and investment in infrastructure. 5.3 NPF3 sets out the Scottish Governments view on how it can deliver a successful, sustainable place and the key projects that will contribute to this. The key drivers for change and priorities for investment in infrastructure, include major cities, a number of enterprise areas and 14 “National Developments”. Ravenscraig appears as one of the latter and, as such is seen as important to the delivery of the Governments spatial strategy. 5.4 NPF3 identifies Ravenscraig as one of the largest areas of vacant and derelict land in Europe. It repeats the aim of giving the project renewed impetus, encouraging redevelopment of the site for a range of uses through a master-planned approach. It is noted that the Scottish Government expects the outcome to be a sustainable settlement with a new town centre, jobs, facilities, and homes along with sustainable transport connections. Page 21 of 58
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Clydeplan Strategic Development Plan (2017) 5.5 The Clydeplan Strategic Development Plan (CSDP) sets out the spatial development strategy (SDS) for the city region to 2029. The strategy supports the presumption in favour of sustainable development leading to economic growth. Maximising the use/reuse of development land and existing infrastructure is seen as fundamental to the success of the SDS. Ravenscraig appears as one of the four priorities within Diagram 2 key spatial priorities of the CSDP. In line with NPF3 it is noted as a national priority project having a strategic role in the delivery of the long term regeneration and restructuring of the southern part of North Lanarkshire. Notably, Ravenscraig is not listed as one of the seven sites CSDP identifies for rail freight development in its spatial strategy. 5.6 Due to the scale and nature of the proposed development, it is considered that the application requires to be assessed against Policies 1, 4, 5, 6, 8, 12, 13, 14, 17, and 18 of the CSDP. Diagrams 10 of the CSDP sets out how development proposals are to be assessed against the provisions of the SDP. North Lanarkshire Local Development Plan (NLLDP) (2022) 5.7 The NLLDP was adopted in July 2022. PROM LOC 1: Regeneration Priorities identifies Ravenscraig as a priority area where the North Lanarkshire Local Development Plan (NLLDP) seeks to achieve regeneration and sustainable growth through delivering the right amount of development in the right places, developed to the right quality, and for the benefit of the communities they affect. The NLLDP shows the application site allocated for a range of uses broadly in line with the Revised Ravenscraig Masterplan as discussed above in section 4, where the following zonings apply: - • PROM LOC 3 - Housing Development Sites; • PP3/AD3 – General Urban Area; • PP4/AD4 – Green Belt; and • PROT A– Site of Importance for Nature Conservation (SINC). 5.8 Due to the application constituting a national development and significant departure from the Development Plan, it must be considered by the Planning Hearings committee. 6. Consultations 6.1 Health and Safety Executive raised no concerns in respect of the proximity of the site to the high pressure gas pipeline which is classified as a Major Accident Hazard Pipeline and which runs partly parallel to the railway line and South Calder Water. 6.2 Scottish Gas Networks withdrew their objection to the proposed development on the basis that further discussions are undertaken to ensure that the pipeline and integrity of the servitude or easement area are not compromised. The applicant submitted an amended layout detailing re-alignment of the access road and note that it is proposed to install a protection slab where the road crosses the gas main. SGN confirmed they were satisfied with the protective measures proposed. 6.3 Scottish Power raised no objections but noted they had underground cabling and overhead lines within the vicinity. 6.4 Scottish Water raised no objections and noted that capacity existed within their network to provide water and wastewater facilities to the site. 6.5 SEPA noted that whilst not replacing like for like, they commended the provision of the green lung planting scheme. They agreed that flood risk to the site from the South Calder Water was low, that air quality would be addressed by NLC Protective Services, and that the handling of any invasive non- native species (INNS) or groundwater effects from any mine grouting would be handled under their separate environmental legislation. 6.6 Transport Scotland raised no objection to the proposed development and noted their broad support for rail freight development as a modal change but acknowledged that the application site is not allocated for this form of development. 6.7 Strathclyde Partnership for Transport (SPT) commented specifically on staff access to the site noting that the Transport Statement makes the assumption that all staff access to the site will be by car and shift patterns have been designed to avoid peak times drawing experience from travel demand and shift Page 22 of 58
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patterns at the existing Gartsherrie site where staff will relocate from to the Ravenscraig site. SPT considers the relocation provides opportunity to influence and change travel behaviour. The site access should be designed and lit to encourage walking/cycling and link with routes in the wider Ravenscraig area but it is noted that the site is outwith 400 metres of existing bus stops with limited service provision at the nearest stop adjacent to the RSF. A new bus service is expected to operate in Spring 2023 connecting Ravenscraig with Motherwell train station routing along the main spine road, but bus stops would still be outwith 400 metres. SPT would be happy to engage with applicant and the Council to explore means to enhance provision to support sustainable access to the site and this should be considered further through development of a Travel Plan prior to the site becoming operational. SPT welcomed the applicants’ commitment to provision of disabled and cycle parking spaces but noted that electric vehicle charging points should also be provided. 6.8 Historic Environment Scotland consider that the proposals would not have any significant impacts on heritage assets within their remit. 6.9 Nature Scot advised that the proposals are unlikely to have a significant effect on any legally protected sites or species either directly or indirectly. In addition, the implementation of all the proposed mitigation measures relevant to the natural heritage interests must be followed thoroughly in order to ensure that disturbance to wildlife is kept to a minimum and should include pre-construction protected species surveys and integration of the further mitigation measures. Furthermore, they welcomed the plans to control invasive species, the creation of the Green Lung and the commitment to ongoing maintenance of the existing and new habitats. 6.10 The Coal Authority removed their objection following the receipt of further information and considered that the imposition of conditions requiring intrusive site investigation to confirm the location of mine entries, their subsequent remediation and certification as such would adequately cover matters. 6.11 Scottish Forestry were pleased to note an uplift in the scale of replacement broadleaved woodland in the green lung above that being lost. They noted that compensatory planting should also be provided for the loss of grassland and short ephemeral vegetation. 6.12 Network Rail broadly confirmed support for the development but could not confirm any of the detailed proposed operational aspects as these would be articulated during the design and build contract following planning permission. As such they could not confirm the capacity number of trains that could operate per day, this being a matter for the applicant as they would know how quickly they could load/unload goods etc. but they did note that there is line capacity for at least 15 trains over the three phases. Also, they could not confirm pathway slots or crossover locations to determine whether trains would require to stop off-site and idle with associated noise implications. They did however confirm that they had no objections in principle to the proposed noise barriers subject to detailed design and maintenance arrangements, and required the applicant to continue discussions regarding the need to relocate the lineside access point given that the continuous noise barrier closes off the existing access. 6.13 NLC Archaeology Service noted that information submitted in this respect was limited but there was possibility for there to be a range of archaeological remains within the site and surrounding environs. To ensure matters had been adequately assessed, they requested a planning condition be attached if the development is approved, requiring the implementation of a programme of archaeological work in accordance with a Written Scheme of Investigation. 6.14 NLC Greenspace require the submission of updated protected species surveys given the time which has elapsed since the undertaking of the original surveys. They welcomed the proposed ‘green lung’ habitat creation however they did not consider it adequate to compensate for the loss of ancient woodland in particular, and the further loss of wider habitat such as semi-natural grassland. They also noted that the new habitat would take a significant time to become established and will have a lot lower benefit for biodiversity. 6.15 NLC Arbor were broadly satisfied with the compensatory proposals for the loss of woodland but would require more details in terms of delivery mechanisms and short/medium term management given the challenges which can occur in trying to establish an urban woodland. However, they noted their agreement with Greenspace that insufficient compensatory measures were being proposed for wider habitat loss. Page 23 of 58
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6.16 NLC Protective Services raised no concerns over light pollution and were satisfied that site investigation could be adequately covered by condition. However, they consider insufficient information had been submitted to demonstrate the full impacts of the development on noise and air quality. 6.17 NLC Transportation similarly advised that they considered insufficient information had been submitted to demonstrate the impact on the road network, road safety, physical ability to construct the required standard of carriageway with segregated footway and cycleway and sightlines exiting the green lung parking area. 6.18 NLC Education note that active travel routes are important to ensure that the service can promote active travel to the school site. It is noted that the current proposed site for the new school is surrounded by roads. As such, increase in traffic movement is not viewed as a positive influence when assessed in relation to active travel. The introduction of large vehicles and a significant increase of traffic around the proposed school site would be a negative influence from both a safety and an air quality perspective. It is further suggested that, if the freight terminal was already on the plan before the school site was allocated, the council would likely have requested other options for a school site from Ravenscraig Ltd. 7. Representations 7.1 Following neighbour notification and press advertisement in the Motherwell Times, Wishaw Press, and Edinburgh Gazette, 697 letters of representation were received from 687 parties including Monica Lennon MSP, Marion Fellows MP, and Ravenscraig Community Action Group (RCAG), all objecting to the development. Concerns raised related to the following: 7.2 Policy • The proposed development is contrary to Development Plan, NPF3 and NPF4 and the North Lanarkshire Local Development Plan. The plan designates the site for primarily housing and is not allocated for a rail freight facility. • The proposed development is contrary to and was not part of the original or revised Ravenscraig Masterplan. The Masterplan designates the area for housing with the area opposite the Regional Sports Facility designated for industrial and business uses. • The proposals would compromise future developments within the Ravenscraig masterplan. • The proposed development is contrary to Green Belt policy and the proposed Rail Freight Terminal eats into a large expanse of Green Belt land and completely goes against the designated purpose and use of the land in this area. • The proposals go against the Council’s strategic priorities set out in the Carbon Management Plan 2019-2022 to improve the health and wellbeing of its communities. • The Council’s Best Value Assurance Report notes that to achieve its economic regeneration ambition the Council plans to provide 5,000 new homes by 2034 requiring a significant increase in new homes with a key part being the Tower Strategy to replace all 48 blocks with approx. 4,000 new homes. The removal of the Meadowhead Residential Site within the Ravenscraig Masterplan is strategically significant to achieving the number of new houses required and would go against the Council’s strategic priority to improve economic opportunities and outcomes for all. • The economic benefits are not considered sufficient to outweigh the significant environmental impacts with the first phase creating little additional jobs but re-locating existing ones to the site. • The proposals are contrary to recent policy regarding investment in net zero carbon projects. • There are alternative sites more suitable for this type of development for example Eurocentral, Gartcosh, Bellshill and Livingston and it is unclear which alternative sites were considered for the proposals. • Concerns that the proposals will displace existing North Lanarkshire Jobs and will compete against existing rail freight sites. • The proposal is incompatible with Scotland's recently adopted UN Convention on the Rights of the Child – GIRFEC (Getting it Right for Every Child) • Concerns that most residents were sold property under the idea that the future of the Ravenscraig area would fit the masterplan which was approved back in 2019 and raises serious issues of trust with North Lanarkshire Council and its residents and concerns that residents have been mis-sold properties. Page 24 of 58
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7.3 Noise • Detrimental impact on amenity of surrounding receptors due to noise pollution from the proposed facility – including movement of containers and vehicle movements from operations within the facility and 24hr operations. • Concerns regarding noise and vibration from the increased rail freight and rail freight at night. • Concerns regarding noise from increased HGV movements and noise from the access road which will require additional soundproofing or be re-located away from residential properties. • There are no adequate means to enforce the working methods suggested in the noise assessment. 7.4 Transportation • Road Safety concerns regarding the number of vehicle movements (1000 vehicle movements per day) and suitability of the proposed access given its close-proximity to the proposed new school and busy residential area. • SPP in relation to 'appropriate location' would consider that increased HGV traffic would come off Motorways via as short a distance as possible preferably a slip road rather than to drive through large numbers of built up residential areas. This development will encourage HGVs into the heart of an urban area that would otherwise be able to remain on Trunk Routes. • Impact on the pedestrian safety of children and college students in the area and will make safe routes to school impossible. • Concerns that the roads are already extremely busy and not suitable / will be unable to sustain the additional volume of traffic/HGV’s that the facility will generate. • The proposals have the potential to cause accidents/near misses given the proximity to the school entrance. • Concerns that the public road network will deteriorate due to the volume of heavy traffic and increasing the risk to damage of residential cars. • Detrimental impact on the wider road network and road safety in terms of Airbles Road / Windmillhill Street to the south and A723 to the North. The road network leading to the M80 is unsuitable for the proposed volume of traffic that would be created. • The proposals will cause congestion on the M8 and M74. • The development is considered to incorporate inadequate parking, loading and turning facilities. • The proposals will require significant changes/upgrades to surrounding footpaths within Ravenscraig to increase pedestrian safety. • Concerns that HGV’s will rest up on local streets to the detriment of road safety. 7.5 Ecology • Detrimental impact on ecology and habitats. • Impact on wildlife. • Impact on fauna. • Concerns regarding the destruction / loss of Greenspace – removal of 60 acres of greenbelt once part of the Wishaw House estate. • Loss of trees and impact on Ancient Woodland. • Concerns regarding the inadequacy of the applicants’ assessment in terms of ornithological interests within the area. 7.6 Environmental Impact • Concerns regarding the negative environmental impact of the proposed development. • Concerns regarding increased air pollution due to harmful emissions from the proposals and increase in HGV movements and the subsequent impact on health of surrounding residents and adjacent school facilities due to air pollution from emissions. • Proposals are incompatible with the surrounding community facilities such as the civic park. • Concerns regarding light pollution from the site. • Concerns the proposal will have a detrimental impact on the carbon footprint. • Impact of construction within the site over a number of years including noise from construction works taking place from 08:00 to 19:00 every day. • Concerns regarding water pollution from the development and operation of the site. 7.7 Landscape / Visual • The proposals will have a detrimental visual impact on the Ravenscraig area and will dominate the Page 25 of 58
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skyline being approximately 7 times the size of the Regional Sports Facility. • The proposals will not fit in with the landscape of the area given the proposed scale, massing, layout, density of building design, appearance, and materials. • Concerns that the building will overshadow properties. 7.8 Residential Amenity / Health and Wellbeing • Detrimental impact on the physical and mental wellbeing of residents. • A major industrial development will create a large, out of place visual barrier. Even if pathways were to be provided, locals will have to travel quite some distance to be free of noise or visual intrusion. • Detrimental impact on the standard of living of surrounding residents. • Impact on the residents should be a key consideration in the assessment of this proposal given its proximity to the current surrounding residential properties. • The development will have a detrimental social and economic impact on the residents of the area. • This proposal will be detrimental to all families and homes which reside in the Ravenscraig site and the development has zero positive impact for the residents of Ravenscraig. • The developer's current facility at Gartsherrie is not only noisy, polluting and a visual intrusion, but the access route towards it from the A8 is constantly obstructed by parked HGVs awaiting their slot to arrive at the terminal. The same applies to the DB Cargo UK facility at Euroterminal. Not only do vehicles have an allotted time to arrive, but the clearance facilities at the gate take time, and vehicles are regularly idling and awaiting access at all hours. • Fear of crime. 7.9 Additional Matters Raised • If approved the development will be challenged by a great many people and organisations. • Proposals will ruin the area and is contrary to what was promised to home buyers buying into the area e.g residential area with schools and shopping and not an industrial estate. • The size and impact of the proposals were not disclosed at the time we purchased our property. • Detrimental impact on surrounding property values and will make the area less desirable. • The location is inappropriate given the plans for schools, retail, leisure and housing and a strong freight presence is not desired or safe. • Proposals do not align with the Ravenscraig community vision and developers might re-consider their investment if the proposals go ahead. • Concern that the proposals are about money and do not consider the impact that the proposals would have on the local community. • Concern regarding the timing of the PAN process and that the pre-application consultation was poorly managed with public consultation meetings being held during a worldwide pandemic and only online – with barely any consultation or notice for residents and completely alienating those that don't have internet access. • The development would result in the loss of a major community resource as it has become a major community resource, providing residents with easy access to the Coltness Woodlands and South Calder Valley. • Site should be utilised for new build and affordable housing for new families. • The applicants are already ignoring local residents who have already voiced significant concerns by submitting this very application and seeking planning permission. • Concerns that the proposed facility cannot fit with the existing cycling and pedestrian movements and proximity to the park. • Concern that residential developers will stop building in the area. • It seems as work has already begun that this is going ahead regardless which is absolutely ridiculous. • Why invest lots of money in regeneration only to revert back to a heavy industrial use. • £1.9m of annual council tax lost - enough to fund 72 new teachers; 80 home care workers; re-open Kilbowie and restore Christmas lights. 7.10 As current landowner, Ravenscraig Ltd confirmed their support for the proposals noting that the development will positively contribute to regeneration of a large area of Ravenscraig and offer beneficial employment opportunities. They consider that due to the site occupying a discrete parcel of land, it will not undermine the long held objectives of creating a mixed use scheme in the overall Ravenscraig site where the Council will retain all the necessary controls to ensure the desired outputs are delivered. They submitted an indicative revised Masterplan layout detailing how the design may potentially be re-worked in the event that the railhead proposal is approved. This involves retaining two road junctions onto the Page 26 of 58
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terminal’s access road at ‘Ravenscraig Square’ and fronting a range of residential and non-residential community buildings towards the green lung to embrace it as an asset. 8. Planning Assessment 8.1 Section 25 of the Town and Country Planning (Scotland) Act 1997, requires that planning decisions must be made in accordance with the development plan unless material considerations indicate otherwise. 8.2 The assessment is ordered as follows: Development Plan - The National Planning Framework 2014 (NPF3); - Clydeplan Strategic Development Plan 2017 (CSDP); and - North Lanarkshire Local Development Plan 2022 (NLLDP). Material Considerations - Scottish Planning Policy 2014 (SPP); - Revised Ravenscraig Masterplan 18/00463/PPP; - The National Planning Framework Consultative Draft 2022 (NPF 4); and - Assessment of Consultation Responses and Representation Comments. 8.3 As discussed in Section 3, the applicant did not seek an EIA screening or scoping opinion from the Council but instead confirmed that EIA would be undertaken and that the applicant determined following contact with the relevant consultation bodies, that (in their opinion) it must consider the impacts from noise, air quality, and ecology. The applicant was advised that this approach meant that it would not be possible for the Planning Authority to comment on the adequacy of the EIA until such time as consultee responses had been received during the formal planning application stage. Having reviewed the Environmental Statement (ES) and the application supporting information and consultee responses, it is confirmed that these three topics are correctly identified as requiring to have been assessed under EIA. However, as will be discussed in detail later, it is considered that insufficient information has been submitted to demonstrate the full impacts of the development on noise and air quality and in these respects, the EIA is considered to be inadequate and planning permission should be refused. National Planning Framework 3 2014 (NPF3) 8.4 The National Planning Framework 3 (NPF3) sets out the Scottish Government’s spatial development priorities for the next 20 to 30 years, including plans for development and investment in infrastructure. The national spatial strategy set out in the NPF3 shows where there are opportunities for growth and regeneration, investment in low carbon economy, environmental enhancement, and improved connections across the country. The spatial strategy provides a flexible framework for sustainable growth and development which reflects the varied assets of our many distinct places, including the cities networks, towns and villages, rural area, and coast and islands. It is highlighted that the cities network would continue to be a focus for investment, becoming models of low carbon living, supporting growth, addressing regeneration, and improving connection. It is noted that many of Scotland’s largest and vibrant towns are located close to cities. In respect to the application, the site is located in close proximity to the towns of Motherwell and Wishaw. 8.5 NPF3 goes on to set out a vision for Scotland which is based upon the planning outcomes detailed in the Scottish Government Economic Strategy which consist of: a successful, sustainable place, a low carbon place, a natural, resilient place, and a connected place. The application is considered in terms of each outcome below. 8.6 A Successful Sustainable Place: The national spatial strategy sets out opportunities for Scotland’s city regions to develop as successful, sustainable places. It is noted that challenges and opportunities vary across the region but in according the Ravenscraig site itself National Development status, it will benefit Page 27 of 58
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from additional impetus to secure further investment. It notes that the master-planned redevelopment of Ravenscraig will transform one of Europe’s largest areas of vacant and derelict land into a new sustainable community. As will be discussed in greater detail under section 9, the revised Ravenscraig Masterplan does not include the incorporation of a rail freight terminal at this location, and it is considered that the application does not accord with this aspect of the spatial strategy. 8.7 Low Carbon Place: NPF3 considers that planning has a key role in delivering national targets of low carbon emissions. While the Scottish Government has set out the energy sector as the primary focus to achieve low carbon targets, it is also recognised that the low carbon sector is fast moving and will continue to be shaped by technological innovation and a changing environment. The applicant highlights that the proposal would contribute to lower carbon emissions through modal shift from road to rail freight, thus reducing the number of HGV movements. It is considered that the application is in line with this aspect of the spatial strategy. 8.8 A Natural Resilient Place: This aspect of the vision states and encourages respect to enhance and make responsible use of our natural and cultural assets. The spatial strategy highlights that natural and cultural assets in around urban areas have a key role to play in supporting sustainable growth, marinating distinctiveness, and promoting quality of life. It is noted that a planned approach to development helps to strike the right balance in safeguarding assets which are irreplaceable, and facilitating change in a sustainable way, whilst creating better connections for people with the natural world. This development will remove a significant area of broadleaved woodland, a large part of which is ancient woodland, and other habitat such as semi-natural grassland. As will be discussed in greater detail in Section 9, taking cognisance of the compensatory habitat proposed under this application in the green lung area, alongside consideration of the reduction in habitat that may occur in any case by virtue of approval for housing in a large part of this area under the revised Ravenscraig Masterplan, against comparison of the differing quality and character types that the proposed habitat areas are likely to present following housing or rail freight development, it is considered that on balance, the proposal represents a net adverse effect which is not in line with this aspect of the spatial strategy. 8.9 A Connected Place: NPF3 sets out that Scotland will maintain and develop good internal and global connections, with particular regard to road and rail infrastructure improvements. In order to facilitate improved connections, spatial priorities for change highlight road improvement works at the M8/M73/M74 motorway network and focus on the critical importance of rail freight networks to Scotland’s economy which are likely to become increasingly important as Scotland’s export potential grows alongside the transition to a low carbon economy. Mossend, Gartsherrie–Coatbridge, and Grangemouth are identified in NPF3 as important freight interchanges. The spatial strategy highlights the Scottish Government’s intention to work with the rail freight sector to develop a more strategic view of future development priorities for rail freight within the broader operational context. In light of this position, it is considered that the rail freight operations have the potential to support this national spatial priority. 8.10 Delivery: There are 14 national developments identified to deliver the spatial strategy, of which Ravenscraig is one, but as noted above, rail freight development does not form part of the vision for the site. 8.11 Taking all of the above into account, it is considered that NPF3 supports rail freight as a form of development, due to its positive benefits in reducing carbon emissions, but does not support it at this location due to it not having been included as part of the master-planned approach for Ravenscraig in its most recent revised form, and for reasons discussed later in the report, the proposal is considered to create adverse impacts. It is considered therefore, that the proposals do not accord with the national spatial strategy set out in NPF3. Clydeplan Strategic Development Plan (CSDP) 2017 Policy 1 Placemaking 8.12 This policy states that new developments should contribute towards the creation of high quality places across the city region. In support of the Vision and Spatial Development Strategy, new development proposals should take account of the Placemaking Principle set out in Table 1, which provides a range of criteria under the six qualities of a place set out in ‘Creating Places 2013’ and ‘Place Standard for Scotland 2015’ as being Distinctive, Safe and Pleasant, Easy to Move Around, Welcoming, Adaptable, and Resource Efficient. Page 28 of 58
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8.13 The Safe and Pleasant/Distinctive/Welcoming qualities require developments to reflect local character and strengthen community identity. The application site and extensive surrounding land to the north and east present a natural character and appearance of dense riparian woodland which beyond the site, open into meadows with woodland and hedgerows beyond the South Calder Water (SCW). However, under the Revised Ravenscraig Masterplan, it is proposed that this natural setting only be retained and enhanced over the Community Nature Park area along the north and east boundaries and that the majority of the application site be redeveloped for housing. In accepting that the principle of physical development can occur over most of the application site, the resulting environment from the rail freight terminal must be considered in this context. 8.14 The phase one site has been laid out to maximise the efficiency of goods handling between the railway, HGVs, and the distribution warehouse. Whilst visually imposing at 36 metres high, the scale and rudimentary design of the high bay storage and distribution building is informed by its functional spatial requirement associated with delivery, sorting, storage, product retrieval, packaging, and distribution where the storage and packaging elements are undertaken by an automated system 33 metres high within the building. The ‘big box’ as it’s being termed by the applicant, will be clad in differing coloured panels to soften its façade and has been recessed further east with the low bay measuring 9 metres high having been handed to its western side to extend the views further from it, together with the low bay providing a degree of screening, which the applicant considers will help to reduce its visual impact. The two storey office building with training academy comprises a cutting edge design with cantilevered upper level and is presented as the arrival building to the front site entrance to the north and will be set among landscaped areas with SUDS ponds. The Vehicle Workshop and driver welfare facilities buildings are located along the eastern boundary where they will provide ease of access for drivers from the lorry park. It is considered that the development will not only provide a state of the art facility, but will also provide a modern, pleasant, working environment for staff within an enviable woodland setting in accordance with the Placemaking quality. 8.15 As part of the proposals, it is intended to encourage the public in, and around the facility in the creation of the green lung habitat and via access links through the riparian woodlands. The discussion here will therefore consider the visual impacts as viewed from a distance or at close quarters. The impacts of the visitor experience in terms of the quality of the habitat environment created by the green lung development and access links through the riparian woodlands are discussed under section 9 heading ‘Community Nature Park’. It is noted that the site lies approximately half a mile remote from the main spine road through Ravenscraig. Given this, on initial consideration it may be reasonable to expect that at this distance, the development would create minimal visual impact within the surrounding area. However, with the exception of the RSF, new public playpark, and active travel route between Craigneuk and the RSF, the intervening land between the spine road and the site is undeveloped other than remnants from the old steelwork days and regenerated vegetation. Topography also plays a large part in the available views towards the site. The RSF, playpark, active travel route, and land within the close vicinity of the spine road all sit roughly around 85 metres above ordnance datum (AOD). Approximately 50 metres from the playpark’s eastern edge, the land rises in bunding by a further 5 metres (equivalent to the eaves/gutter height of a two storey building) to 90 metres AOD and stretches north and south at a gentle rising grade over a considerable plateau to the east until approximately 50 metres from the WDL, it hits steep banking rising to around 102 metres AOD at the railway line. Despite requests for existing and proposed site levels and cross sections over the entirety of the application site, only confirmed details were submitted for the phase one freight terminal area on the eastern side of the railway line which will sit slightly below it at around 101 metres AOD. The phase two and three enabling works areas cannot be fully confirmed in terms of ground levels and cut/fill until intrusive ground investigation has been undertaken. With regards to the green lung area on the western side of the railway towards the wider Ravenscraig site, only one cross section was submitted but cannot be wholly relied upon as it does not correctly detail the width of the green lung nor provide AOD levels. However, in extrapolating the confirmed level of the railway and warehouse building, it appears that existing ground levels of roughly 92 metres AOD at its western edge will be maintained in the green lung, and the visual impact from the development has been considered on this basis. Design elements of greatest stature to be considered in terms of visual impact comprise the low and high bay warehouses and noise barriers measuring between 2-12 metres high. The low bay reaches 9 metres high, whilst at 36 metres in height, the high bay is equivalent to around a 13 storey building with pitched roof. As noted above, the warehouses are to sit at around 101 AOD so that in comparable terms, the siting of the high bay 16 metres above the ground level of the spine road and RSF etc. raises it by another 6 storeys to equivalent Page 29 of 58
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19 storeys or 52 metres high. As will be discussed later in the report, the full noise impact of the development was not demonstrated. Several noise queries and alterations to the road/footway configuration required to be clarified with further noise modelling being undertaken to confirm whether the noise barriers would need to be increased in height, relocated, or extended in length. In the absence of full demonstration of the noise impacts, in turn, the visual impacts of the barriers cannot be fully articulated with assessment only being possible based on the current information of barriers measuring between 2-12 metres high at their current locations detailed in the noise impact assessment. In addition, as is normal practice and usually subject to a planning condition, no details have been confirmed on the construction specification of the noise barriers as they can comprise either fences/walls or bunding or a combination of both. The one cross section provided gives the example that half the height will be achieved through landscaped bunding, with the upper half formed by a fence or wall. As the specification is not confirmed, again the visual assessment can only consider the impacts from the heights of the barriers. 8.16 The Landscape and Visual Impact Assessment (LVIA) considered several vantage points internal and external to the site including opposite the M74 near Larkhall and at three points around Cleland including one off Wishaw Low Road and another at the Townhead area near Newarthill both of which enjoy long views across the SCW valley towards Motherwell. From here, the foreground is characterised by sloping meadow which then rises in dense woodland around the SCW, above which the urban area of Motherwell of flatted tower blocks and Dalzell Steelworks are visible. The development would be viewed in the context of the urban setting given that it sits beyond the SCW from these angles, but because of the high bay’s greater height coupled with its broader massing due to its closer proximity, it exerts a definite dominance over the towers and steelworks such that it would be clearly perceived as a visual intrusion from these viewpoints. From within Ravenscraig, even with the intervening SCW woodland, the high bay would still tower above the treetops and be visible from the housing estates to the north. Views would also be available towards the site at the junction exiting the pub/restaurant, from the vicinity of the RSF, playpark, and land stretching southward, and from the redundant arm of the college roundabout used for parking by dog walkers etc. Where there are breaks in the structural planting aligning the main spine road, views would also be possible from this road to the north and south. Due to the existence of the bund beyond the play park, it is considered that this will largely truncate the view eastward to the immediate foreground such that the green lung area will not be visible, however at the equivalent rise of 19 storeys, the high bay will be visible. Given that several of these vantage points represent destination facilities, visitors will come from far and wide to access these amenities and thereby constitute a high degree of surveillance. It is further noted that the road configuration at the pub and RSF junctions also positions the site within the direct line of vision. It is accepted that drivers will gain transient views, due to their main focus being on oncoming traffic to enable safe entry to the road network. However, given there will be patrons of the pub, it is reasonable to expect a high number of visitors on foot whose gaze can be held for longer periods towards the site. It is accepted that those accessing the RSF may quickly continue their journey into the building but those visiting the park will occupy this external space for potentially long periods. There is also regular use of the active travel links along the main spine road by students accessing the college, by the public for general exercise and by dog walkers. Given all these factors, there will be a large audience and perceived adverse visual intrusion from the high bay even at this remote distance viewed centrally within the Ravenscraig site where it will appear out of place within the landscaped backdrop. 8.17 The first phase of a new active travel route was opened in summer 2022 providing a direct link between Craigneuk via the Keepmoat Castings Estate, over the Meadowhead Bridge and on toward the RSF passing the park enroute. As use intensifies along this route, together with increased visitors to the park, visitors may start to spill out from these features onto the adjoining land and scramble up the nearby banking to the large gently graded plateau area. Other recreational users (dog walkers, joggers etc.) may also currently access this area as a more peaceful alternative to the main spine road. Upon immediate arrival atop the bank, the view eastwards is partially obscured by nearby mounds of remnant materials from the steelwork days which have now greened over. However, once atop these mounds, the view opens up entirely all the way to the WDL where the intervening land is characterised by pockets of self-seeded trees and shrubs and remnant roadways. From here, with the exception of planting pockets which will offer partial screening, most of the built components of the scheme will be exposed in a tiered effect, starting at the bottom will be the 9 and 12 metres high overlapping arced noise barriers of the green lung running its full length as one consolidated defence, sitting atop the railway banking will be the 8 metres high railside barrier running from the WDL’s northern underbridge to the rear garden boundary of houses on Meadowhead Road, behind which the high bay will be clearly visible. To the Page 30 of 58
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north, the 5.5 metres high roadside barriers will also be visible. The railside barrier will screen the low bay warehouse and 2 metres high noise barrier proposed along the phase one site southern boundary. However, due to lack of ground levels information for the phase two and three areas, it is not possible to assess whether the 5 metres high barrier running down the western edge of these phases will be visible. A 4.5 metres high barrier is proposed to run adjacent to the gable boundary of the end house on Meadowhead Road but again no ground levels information has been provided to demonstrate the visual impact. In time, the intervening land may be built out as intended house plots screening off the roadside barriers from this vantage point, and/or softened with more mature landscaping within and around the green lung area. However, what is known at this stage is that at this intermediate distance, glimpses of the green lung defences will still be available whilst the upper rail barrier and high bay warehouse will be clearly visible and will appear in stark contrast and at odds with the natural landscape backdrop. 8.18 Furthermore, the public are to be encouraged into the green lung area, and the woodlands around the SCW via linked paths in the Community Nature Park accessed either via the southern end of the site behind the Meadowhead Road houses or via the new access road. The LVIA did not consider the impact of the acoustic barriers along the access road, but these will be visible from the main spine road on approach from the north due to them being sited just short of the roundabout adjacent to the BRE site, and from the existing houses on Ravenscliff Road and Roedeer Drive, and in time, the new build Council housing site on the former BRE site. The site will be screened from the immediate southern approach by intervening structural planting aligning the spine road at this point. As noted above, the roadside barriers will also be currently visible from the remnant mounds atop the raised plateau where it will lead the eye all the way to the facility. For those travelling along the access road, there will be a 5.5 metre high noise barrier on both sides. Although the submitted site layout does not reflect it (currently the drawing details a 2 metres verge with 2 metres footway on the north side and 1-2 metres verge on the south side), roads requirements dictate that a 2 metres verge with 5 metres wide segregated footway/cycleway be provided on the northern side and the noise barrier would sit behind this and continue under the WDL stopping at the freight terminal’s internal roundabout. On the south side, the barrier would require to sit fully behind a 2 metres wide verge and will return into the green lung. Despite requests, the drawings were not updated to this layout nor was it demonstrated that the WDL bridge support span or height can accommodate the road requirements and noise barriers, nor was it demonstrated what the effect on the noise barrier height, location, and extent may be as a result of requiring to relocate them to the correct roads layout configuration. Again, full assessment of the visual impacts cannot be made and instead consideration can only be given to the current information and in doing so, assume that the roads requirements can be met and by relocating the barriers to the correct position, no changes are required to their height or extent. 8.19 Due to the steep banking to the SCW Gorge, travellers on the north side are less likely to come off the formalised path and skirt round it at the roundabout to access through the SCW woodland and will likely therefore be corralled close to the carriageway and experience a definite separation from the woodland until they reach past the WDL some half mile along, where the barrier stops beyond at the internal roundabout and the access opens up to the woodland. On the south side, there is no footway and the road barrier runs continuous until it reaches the green lung still a considerable distance away. It is acknowledged that some able bodied travellers may skirt behind the southern barrier near the roundabout as access can be gained into the green lung from here due to breaks in the overlapping arced barriers, were this not the case, the only other way to access the green lung from this side of the barrier would be via the distant southern route behind houses on Meadowhead Road in Craigneuk. However, it is reasonable to consider that the public would expect to be provided with a formalised, properly surfaced and lit route to these amenity greenspaces to afford access for all abilities and age groups for walking, cycling, and wheeling, and indeed the revised Ravenscraig Masterplan details the provision of an access road in this location leading to the housing plots and Community Nature Park. In turn, it is reasonable to expect that most pedestrian traffic will use the formalised route where it should be noted that a HGV is estimated to pass just under every two minutes, Whist the roadside barriers may truncate the view to a degree, at the intermediate and near positions to the facility, the tiering of visual effect will be evident due to the varying barrier heights and ground levels culminating in the emphasised stature of the high bay given its raised position. The facility will be viewed in the context of a natural backdrop of woodland where the high bay will breach the horizon towering above the treetops and appear at complete odds as an incongruous feature on the landscape. Where the view is truncated to the road corridor, the traveller is also likely to experience an oppressive fortress- like sense of enclosure for a considerable distance passing along this route due to the barrier heights being equivalent to just above the eaves/gutter line of a two storey building, and in turn, a heightened perception of close Page 31 of 58
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proximity to HGVs passing regularly. While the site may be distinctive, it is likely to be so for negative reasons creating an environment that is likely to feel neither, safe, welcoming, nor pleasant and may deter the public from accessing the greenspaces. 8.20 In considering, the visual impacts of the rail freight proposal, it is important to remember that the Revised Ravenscraig Masterplan also proposes business/industrial development, town centre uses, and housing, and the potential effects from those should also be considered in comparison. Development on the employment land area has not been brought forward as yet and a marketing exercise only commenced in autumn 2021. Nevertheless, it is noted that the employment land is located directly west of the RSF and park opposite New Craig Road and that the first phase of creating its spine road is now complete. Ground engineering in this area is challenging as the land falls sharply after leaving New Craig Road and sits approximately 8 metres below. It is also noted that the parameters plan suggests a building height of 7-15 metres which would coincide with the range usually built out on industrial buildings. In this context, the employment land development is likely to fit comfortably on the streetscene and in complement with the stature of the RSF. Within the town centre area south and south-east of the park, the ground is fairly level to the south, but again sits at the lower level to the south-east. Here buildings are expected to be 9-25 metres high taking cognisance of the higher density, mix of uses and variety of design likely to result in a town centre setting. The application proposal constitutes double the height envisaged in the Masterplan over any use taking into account its raised position, within a location where houses were expected to be up to 12 metres high and set within the backdrop of the woodland representing departure from the urbanised area of the town centre and employment land and transition towards the Community Nature Park. For all the reasons discussed above, the proposal is not considered to accord with the Safe and Pleasant, Distinctive, and Welcoming qualities of Placemaking policy. 8.21 The Easy to Move Around quality supports developments concentrated along transport corridors in close proximity to public transport stops. In terms of movement of HGVs in distributing goods from the railhead, it is assumed that traffic will split 50/50 north to the M8 or south to the M74. Access to Ravenscraig is due to be upgraded shortly in the form of dualling the A723 north to the M8 (currently estimated to be operational by early 2026), creation of a new dual carriageway southward between the RSF and Windmillhill Street (currently estimated to be operational by the end of 2025 and where works have now started on the underbridge to the railway), and completion of the Airbles Road dualling (also by the end of 2025) both of which will provide a direct route south to the M74. In terms of all these road improvements, they pre-date the applicant’s estimated start of operational use for phase one in 2027 if all goes to plan on all fronts and would provide the site with excellent transport links and in this respect is considered to accord with the Easy to Move Around quality. 8.22 In terms of staff access to the site, it is noted that 190 staff will be relocating from the applicant’s existing site at Gartsherrie and that 50-75 new posts will be created. The Transport Statement (TS) notes that existing staff live near and far from the site around the central belt and the TS has presumed a worst case scenario that all staff will access the site by private car and shift patterns will be kept outwith peak traffic times to avoid adverse impact from the predicted 294 cars arriving/departing per day. Alternatively, a Travel Plan (TP) is to be created to investigate opportunities for modal transfer from private car to other means. This may involve cycle parking, car sharing schemes, or more use of homeworking with remote online meetings with incentives to do so. A breakdown of staff numbers has not been provided but it is considered likely that the latter is most likely to apply to office staff given that drivers, crane and warehouse operators would require to be on site to carry out their duties. However if some staff were to try to use public transport, it is important to assess what facilities may be available. Currently, there is an existing bus stop at the RSF, but this only operates once an hour between 1900- 2300 hours and links Ravenscraig with Harthill Services. Outwith the site there is a bus stop on Merry Street and one to the south on the A721 Craigneuk Street. These offer increased frequency and destinations in and around Motherwell or to Glasgow but lie much further away at a 30 minute walk from the site. However, SPT advise that a bus service linking Motherwell Rail Station with Ravenscraig is expected to become operational in Spring 2023. This will operate a circular route via Plantation Road, New Craig Road, and Robberhall Road. SPT expect it to be unlikely that the bus will divert away from this route where it will take in the future town centre, and particularly if the housing plots around the WDL are now removed under the railhead proposal. This would mean that a bus stop would still be in excess of the recommended maximum of 400 metres, and 800 metres for rail access given that even just the distance from the access roundabout to the WDL is approximately 800 metres itself and the facility will lie further east. Again considering what might have happened under the Masterplan, it is Page 32 of 58
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noted that the phasing of housing plots under the footprint of the facility on the eastern side of the WDL were phased for 2035-2045. By this time, with the build out of housing plots on the western side ahead of this, it may be reasonable to assume that the bus route may have been extended to take in the new estates and thereby provide access to bus stops within 400 metres. In considering all these matters, the proposals do not accord with this aspect of the Easy to Move Around quality. 8.23 In terms of active travel, Ravenscraig is well served and provides a segregated cycle/footway on the eastern side of New Craig Road, while solely pedestrian routes align its western side. As noted earlier, a new active travel route of shared cycle/footway arrangement will link the community of Craigneuk to the site via the Meadowhead Bridge north to the RSF and also west to the College, with the first phase having been completed in summer 2022. Again as noted earlier, whilst the submitted site layout does not detail the required segregated footway/cycleway configuration, the applicant has noted willingness to provide this and had requested this matter form a condition if the application is approved. However, it has not been demonstrated that it is possible to physically construct to the required design in order to render such a condition reasonable and enforceable. A condition is also not considered appropriate in this instance given that the correct layout requires to be detailed to inform the location of the roadside barriers which would require the noise model to be re-run to determine if the barriers require to be altered in any way. In addition, for those on foot travelling from the north-east seeking to access the sports, pub/restaurant, college amenities to the south, or for those on foot from the south-east seeking to access in time, the new school to the north, they would require to cross the railhead access road. NLC Transportation were not satisfied that the safety and suitability of pedestrian movements around and across the roundabout and new access road had been demonstrated. In all these respects, the development is considered to contravene the Easy to Move Around Quality. However, it is also noted that informal paths will be provided through the green lung linking with surrounding green spaces and existing paths in the Community Nature Park and these are considered to offer a positive contribution to the Easy to Move Around quality in terms of their provision, but as will be discussed later, they will lie within an area that is likely to offer a low quality of environment and visitor experience. 8.24 Adaptable/Resource Efficient qualities require developments to contribute towards the delivery of the Glasgow and the Clyde Valley Green Network. (GCVGN); optimise existing infrastructure and give priority to brownfield locations. The site is brownfield but as will be discussed later, encroaches in part, on the Green Belt which is an area proposed as part of the new Community Nature Park (CNP) and which also forms part of the Green Network. Notwithstanding this, it is considered that the proposals otherwise accord with these qualities by creating a development which will make maximum use of the land and rail connection opportunities in an operationally efficient manner, and by locating development near to the CNP, it has the potential to bring forward its enhancement proposals earlier than the Masterplan phasing which shows links into the woodland from 2035 onwards coinciding with the development of housing plots W1-5. Policy 4 Network of Strategic Centres 8.25 Policy 4 identifies a network of strategic centres and related schedule 2 identifies Ravenscraig as one such centre. Strategic centres are to be protected and enhanced as the focus for investment in commercial and community facilities and investment in their long term future is supported. Schedule 2 also sets out the role/function of each centre with Ravenscraig the key identified factors are regeneration, retail, education, leisure and employment uses. As noted above in section 4 Site History, the original Masterplan identifies part of the site as falling within the town centre. However with the Revised Masterplan moving the now reduced town centre further west outwith the site, and the zonings in the adopted NLLDP are derived from here, there are no concerns considered to arise from the development under Policy 4. Policy 5 Strategic Economic Investment Locations (SEILs) 8.26 The Spatial Development Strategy identifies 22 SEILs of which Ravenscraig is one, which will support the long term vision of a rebalanced low carbon economy, boosting competitiveness and tackling inequality. Access to wider UK, European and global markets is essential to support the city region’s economy and development of the SEILs. Local Authorities are to safeguard and promote investment in the SEILs to support their dominant role and function which Schedule 3 identifies for Ravenscraig as being business and financial services/construction/manufacturing/engineering/further and higher education. Storage and distribution use is not identified as part of its dominant function and the SEIL boundary was recently altered under the Revised Masterplan and does not encompass the application site. Notwithstanding these, it is considered that the SEIL in Ravenscraig and elsewhere would not be Page 33 of 58
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adversely affected and on that basis would have a neutral impact in accord with Policy 5. Policy 6 Strategic Freight Transport Hubs (SFTHs) 8.27 The sustainable transportation of goods is essential to the long term growth of a low carbon economy. In order to achieve this it is important to promote a modal shift from road to rail and sea. Clydeplan identifies seven locations for freight development which are to be safeguarded and promoted for investment. Ancillary land allocations adjacent to SFTHs are also to be safeguarded for the purposes of freight activity. The seven SFTHs are selected because they maximise access to ports, rail networks and airports. Within North Lanarkshire, SFTHs for the transfer of freight from road to rail are identified at Eurocentral/Mossend and the applicant’s current facility at Gartsherrie. In terms of their current site, Clydeplan notes that this site has limited expansion opportunities and poor accessibility to wider road networks and that City Deal investment offers potential to improve road access to the site. The Council’s City Deal Team investigated matters in partnership with SPT who were carrying out a number of regional freight studies where it was concluded that there was sufficient capacity at the site to meet demand in the short-medium term. In the longer term, an upgraded road link which could potentially be made possible via a new road from Gartcosh Business Park to the site with associated improvements to M73 Junction 2A, would remove traffic from residential roads as is currently the case, and in turn reduce noise and air pollution. However, design characteristics of rail terminals need to achieve the quickest time and lowest cost for transfer which the site doesn’t offer in its present form due to having to split and shunt trains and would likely struggle to compete in the rail freight sector. Costly requirement for the replacement of aged rail mounted gantries also constrains the site. If Committee are minded to refuse the development, the applicant has advised that they will reconsider replacing the overhead cranes at the Gartsherrie site as well as other potential upgrades at their Hillington site. It should also be noted that the Council was also minded to grant planning permission for a significant rail freight proposal at the Kilgarth site (application reference: 08/01036/OUT) this being located between the Gartcosh Business Park and the applicant’s current site at Gartsherrie. The necessary legal agreement was never concluded and the application was subsequently withdrawn. On this basis, the City Deal Team considered there was no case for intervention and limited project need. Notwithstanding the difficulties at the applicant’s current site, Ravenscraig is not identified or safeguarded through Clydeplan as a location for SFTH development and the proposals are therefore considered to contravene Policy 6. However, this document dates from 2017 and things have since moved on with the Scottish Government being more supportive of additional rail freight facilities outwith the identified locations in Clydeplan but where it is demonstrated that the development can be accommodated without adverse impact and is compatible with the surrounding built context. Policy 8 Housing Land Requirement 8.28 This Policy confirms the need for Councils to maintain a five year effective housing land supply. It notes that local authorities should take steps to remedy any shortfalls in the five-year supply of effective housing land through the granting of planning permission for housing developments on greenfield or brownfield sites, subject to satisfying each of five criteria. Where there is deemed to be insufficient land in the supply, this is a factor in considering planning applications for new sites for building houses that do not benefit from being identified for such development in the Development Plan. It is considered that removal of housing plots on the application site, coupled with the rail freight facility as a neighbour to adjacent housing plots, may also threaten their viability and bear a significant adverse effect on the Council’s ability to maintain its housing land supply. These matters are deferred to Section 9 Material Considerations where they can be discussed more fully under the context of the Ravenscraig Masterplan. Meantime, it is considered that the development does not accord with this Policy. Policy 12 Green Network and Green Infrastructure & Policy 13 Forestry and Woodland 8.29 Policy 12 notes that in support of the Green Network, these areas are to be identified, protected, promoted, and enhanced, and developments should integrate and prioritise their delivery from the outset within the Strategic Delivery Areas of which Ravenscraig forms part. Policy 13 notes that development proposals should support the retention and expansion of forestry and woodland and that the planning system has a responsibility to protect ancient semi-natural woodlands, native or long established woods, and whenever appropriate, planning permissions should make adequate provision for the preservation or compensatory planting of trees. The impact of the development on the area identified for the Community Nature Park which forms part of the Green Network, and the loss of trees within the site would require to be considered under these policies. Again these matters are deferred for fuller consideration under the Masterplan in Section 9. Meantime, it is considered that the development does not accord with this Policy. Page 34 of 58
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Policy 14 Green Belt 8.30 A section of the site forms part of the Greenbelt under the SDP due to part of its current zoning as such within the adopted Local Development Plan. The Spatial Vision highlights that the Green Belt is an important strategic tool with a significant role to play in achieving key environmental objectives. Policy 14 Green Belt considers that the review of Green Belt boundaries should be a priority of Local Development Plans so as to ensure those key environmental objectives are achieved. It is noted that the recently adopted Local Development Plan shows that the Council have chosen to retain the settlement boundary as currently exists at this location which has remained unchanged as an intended Community Nature Park since the original Masterplan of 2005. Excluding the retained woodland areas, the land to be developed under the phase one site encroaches beyond the proposed housing plot allocation and into the green belt by approximately 3.5 hectares. In phases two and three, the enabling works encroach into the green belt by 2.7 hectares, giving a combined total of 6.2 hectares. Whilst the areas are relatively small in the grand scheme of the overall development proposed on the eastern parcel between phase one and the enabling works (68 hectares), of themselves they still constitute a large incursion within the green belt and propose development which is not supported by the Development Plan at this location and are considered to contravene Policy 14. Policy 16 Improving the Water Quality Environment and Managing Flood Risk and Drainage 8.31 This Policy requires development proposals to protect and enhance the water environment by adopting a precautionary approach to flood risk and should safeguard the storage capacity of the functional floodplain. The Flood Risk Assessment noted that whilst the site lies close to the SCW, it sits at a significant depth below the site in a Gorge and thereby it is concluded that there is no flood risk to the site. The Drainage Impact Assessment concluded that sufficient capacity exists in the public network for provision of water and disposal of foul. Provision of two SUDS ponds is deemed sufficient to attenuate surface water run off from the site. SEPA raised no concerns and it is considered that the proposals accord with this Policy. Policy 18 Strategic Walking and Cycling Network 8.32 Development proposals are to maintain and enhance existing networks. As was discussed under the Easy to Move Around quality of Placemaking Policy, Ravenscraig is well served by routes in this regard but it has not been demonstrated that the development can physically provide the required footway design in contravention of this policy. Whilst the informal paths proposed in and around the green lung and Community Nature Park areas are held to accord with this Policy in respect of their provision, as will be discussed in Section 9, the quality and visitor experience likely to be witnessed by the public in using these spaces is likely to be very low and in this regard is not considered to accord with this Policy. 8.33 The purpose of Diagram 10 ‘Assessment of Development Proposals’ is to aid consistent application and implementation of the SDP and is to be used by Local Authorities when assessing strategic scale development proposals to determine whether they comply with the policies, schedules, and diagrams of the SDP. Diagram 10: Box 1 poses the question “Does the development proposal support the Vision, Spatial Development Strategy and the Placemaking Policy including having regard to the Glasgow City Centre Joint Strategic Commitment?” Taking account of the preceding paragraphs 8.3-8.32, of the ten policies relevant to this proposal, it is considered to contravene seven. Box 10 confirms that any proposal which fails to meet the relevant criteria will be regarded as a departure from the SDP. Diagram 10: Box 2 allows consideration of departures from the SDP and other material considerations and these are discussed under Section 9. North Lanarkshire Local Development Plan (NLLDP) 2022 8.34 The NLLDP zonings on the site mainly reflect the land use allocations of the revised Ravenscraig Masterplan. Where small differences lie are in areas zoned as General Urban Area on the NLLDP, which on the Masterplan otherwise comprise proposed new access roads, the existing railway line, a sliver of woodland at the southern boundary, and larger footprints for the housing plots, the latter likely to have been shrunk on the NLLDP to allow for the incorporation of buffer areas between the housing and woodland as will be required in Area Planning Briefs for the plots to come. Policies PP3 and AD3 note that General Urban Areas are described as areas either primarily residential in character or have a mixture of recognisably urban uses where additional ancillary developments of appropriate scale can maintain and improve the level of amenities in these areas. For reasons discussed earlier and in more detail later under the Masterplan designations, the scale and nature of this development is not Page 35 of 58
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considered compatible with being located directly adjacent to a primarily proposed residential area, the scheme will result in the loss of the protective buffer areas, and the continuous noise barriers will remove the ability to form junctions onto the site access road where it has not been demonstrated that remaining junctions can cope with expected traffic all in conflict with Policies PP3 and AD3. 8.35 Under Policy PROM LOC 1, Ravenscraig is identified as a key regeneration priority for the Council to promote regeneration and sustainable growth of the community through delivering the right amount of development in the right places, developed to the right quality, and for the benefit of the communities they affect. It is considered that the site’s location to the east, will not affect Ravenscraig’s attractiveness nor viability to attract town centre and employment use development, which when coupled with the existing housing, hotel, pub/restaurant, sports and education facilities, will result in an overall wide and varied mixed use development in accordance with PROM LOC 1. However, for the reasons raised above in the SDP assessment, and which will be discussed further under the context of the revised Masterplan below which placed a greater emphasis on the residential sector as the key land use to enable transformation of the site, it is considered that the loss of housing plots on the application site, coupled with the development affecting the attractiveness and viability of the remaining housing allocations cannot be sustained, and may additionally prevent use of the Community Nature Park from being fully realised and enjoyed and will result in a significant loss of Green Belt land. For these reasons, the proposals are considered to contravene Policies PROM LOC 3 (Housing Development Sites) which seeks to provide a generous supply of housing land; PP4/AD4 – (Green Belt) which seeks to protect the setting of communities, support regeneration by directing growth to urban areas, protect natural assets and provide a high quality environment; and PROT A – (Site of Importance for Nature Conservation (SINC)) which seeks to protect natural places by safeguarding natural heritage assets. 8.36 In addition to the above zonings, the nature of the specific development proposed requires to be assessed against Policies PROM LOC 2 (Business Development Sites) which seeks to support and direct such developments to sites identified in the Plan and Industrial and Business Land Supply, PROM ID1 (Transport Improvements) which seeks to support sustainable multi-modal transport improvements which are identified and delivered through a number of different strategies, and PP2A and AD2A (Strategic Business Centres) encourages large scale business users to locate in these areas and safeguards their character from dilution by other inappropriate forms of development. It is noted that whilst Ravenscraig itself is identified as a Strategic Business Centre on its employment land and town centre areas, the application site is not identified for business/industrial use, nor as a freight location for modal transport improvement. The proposal therefore does not accord with these Policies. 8.37 The development also requires to be assessed against policy C1 (Contributions to Infrastructure) which seeks to secure developer contributions for new developments where they generate a requirement for infrastructure or services, and Environmental and Design Qualities policies EDQ1 (Site Appraisal) which requires developments to relate well to the existing setting and avoid adverse impact on existing or proposed properties , EDQ 2 (Specific Features for Consideration) which requires consideration of constraints which can affect the form or extent of development, and EDQ3 (Quality of Development) which seeks to maintain or improve the quality of environment through requiring high standards of sustainable site planning and design. No infrastructure upgrades were identified as being necessary under the proposal in accord with C1. As will be discussed in greater detail later, the proposal is considered to raise adverse impacts and is held to be contrary to EDQ1. A high pressure gas pipeline lies within the site, however SGN were satisfied with the mitigation measures to re-align the access road and form a protective slab which could be adequately covered by condition in accord with EDQ2. Policy EDQ3 provides a range of assessment criteria which are addressed in turn below: Landscape and Ecology 8.38 Supplementary Planning Guidance (SPG) 01 (Landscaping) recognises that one key element of successful schemes is an attractive well designed landscape whilst SPG 02 (Trees and Development) seeks to ensure that existing planting is retained as an asset to new development, giving instant maturity and retaining natural visual amenity. As discussed under the SDP assessment, it is considered that additional planting in the green lung and around the facility will provide an additional amenity for the public and pleasant outlook for the workforce and setting for the built development. The effects on the wider area resulting from removal of existing planting can be more fully assessed under the context of the revised Masterplan and are deferred to Section 9 below under the Community Nature Park heading. Meantime it is considered that the development raises adverse impacts in this regard. Page 36 of 58
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8.39 In terms of ecology, PROT A5 and SPG 20 (Biodiversity & Development) indicate that development that significantly affects a species protected by law will only be permitted where an appraisal has demonstrated that the protected species would not be compromised. Nature Scot and NLC Greenspace were satisfied that proposed measures would provide adequate protection of species and could be covered by planning conditions if approved. Flooding and Drainage 8.40 SPG 09 (Flooding & Drainage) requires that applicable developments demonstrate any risk and means for mitigation of flooding and detail the measures for treatment of surface water through the use of SUDS principles. As has already been discussed under the SDP, no concerns are considered to arise in these respects in compliance with this SPG. Building Design and Site Layout 8.41 As has been discussed earlier, the built development and site layout have been designed to maximise goods handling and will bear all the hallmarks of an efficient machine. The office building presents a high standard of design with cantilevered upper floor, whilst the warehouse will incorporate cutting edge robotic technology and overall will create a state of the art facility. However, the high bay will be visible for a considerable distance, whilst the necessary measures to mitigate noise in the form of high barriers are considered to detract from the appearance of the wider area and lower the quality of environment, potentially deterring the public from accessing the Community Nature Park. Transportation Considerations 8.42 Despite requests for clarity, NLC Transportation considered insufficient information had been submitted to demonstrate the impact on the road network. The Transport Statement (TS) noted that committed developments and proposed road improvements had been taken into account but no clarity was provided on which developments were considered to ensure a robust analysis had been applied. Similarly, with the requirement for continuous roadside noise barriers along the access road, this removed the ability of junctions to be formed onto this road from the remaining housing plots reducing the roundabout exit junctions from three to two but analysis was not submitted to confirm that those remaining roundabout junctions had sufficient capacity to cope with increased traffic. Clarity was sought on the safety and suitability of pedestrian movements around and across the roundabout and access road especially given that a new school is proposed nearby but again this was not provided. Drawings were requested to demonstrate physical ability to construct the required standard of carriageway with segregated footway and cycleway and sightlines exiting the green lung parking area, and correct standards for manoeuvring of HGVs within the trailer park and around the loading bay, only the latter being considered acceptable to be conditioned. Again these were not provided and collectively in the absence of all this information, the proposals are held to conflict with this criterion. Environmental Considerations: Site Investigation, Mineral Stability, Air Quality, and Noise 8.43 The Coal Authority were satisfied that planning conditions could secure provision of the necessary further information on intrusive site investigation to ensure mineral stability, whilst NLC Protective Services were similarly satisfied that conditions could ensure removal of site contaminants. However, again despite requests, NLC Protective Services considered insufficient information had been submitted to demonstrate the impacts on air quality and noise. Noise is discussed more fully under the revised Masterplan heading in Section 9. In terms of air quality, a clear conflict in reporting of information was highlighted. The air quality assessment takes information derived from the TS which directly informs the resulting air quality impact assessment (AQIA). As noted above, the TS was advised by the applicant to have considered all committed developments and proposed road improvements, however the applicant specifically noted that these had not been considered in the AQIA and therefore leaves doubt that the full impacts have not been assessed with no clarity being provided as to why this was done. In addition, clear justification had not been provided to demonstrate why certain elements were scoped out and on these bases, the proposals are held to conflict with this criterion. As air quality and noise were topics considered under EIA, the EIA is also considered to be inadequate. Low Carbon Economy 8.44 The proposal would contribute to lower carbon emissions through modal shift from road to rail freight, thus reducing the number of HGV movements. It is considered that the application is in line with this criterion. 8.45 Collectively in terms of policy EDQ3, the proposal does not accord with considerations on landscaping, Page 37 of 58
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visual impact, roads impacts, noise and air quality. Drawing together consideration of the North Lanarkshire Local Development Plan generally, it is concluded that the proposal is contrary to policies PROM LOC2, PROM LOC3, PROM ID1, PROT A, PP2A/AD2A, PP3/AD3, PP4/AD4, EDQ1, and EDQ3. Accordingly, given this conclusion and the assessment of NPF3 and the SDP in earlier paragraphs, it is concluded that the proposal is contrary to the Development Plan and must therefore be refused planning permission unless material considerations suggest otherwise. 9. Material Considerations Scottish Planning Policy 2014 (SPP) 9.1 Scottish Planning Policy (SPP) sits alongside NPF3 and sets out national planning policies which reflect priorities for the operation of the planning system and for the development and use of land. The SPP notes a presumption in favour of sustainable development but affirms that this does not change the statutory status of the development plan and that its primacy is maintained, with the SPP and the presumption in favour of development that contributes to sustainable development being material considerations. Policy principles within the SPP state that the planning system should support economically, environmentally, and socially sustainable places by enabling development that balances the costs and benefits of a proposal over the longer term. The SPP sets out principles to guide policies and decisions and in this case the relevant principles are: • Giving due weight to net economic benefit; • Responding to economic issues, challenges and opportunities, as outlined in local economic strategies; • Making efficient use of existing capacities of land, buildings and infrastructure; • Have regard to the principles of sustainable land use; • Supporting delivery of infrastructure, for example transport, education, energy, digital and water; • Supporting climate change mitigation and adaption including taking account of flood risk; and • Improve health and well-being by offering opportunities for social interaction and physical activity, including sport and recreation. 9.2 It is acknowledged that there is widespread support at every level of the Development Plan hierarchy for a shift in freight methods from road to rail in terms of the potential significant environmental benefit it brings in reducing freight’s carbon footprint, as well as supporting economic growth and reducing costs. The applicant also proposes to address climate change by committing to decommissioning of diesel vehicles over the next 10 years and transitioning to electric or hydrogen power. Use of renewable energy in the form of solar panels and air source heating is being investigated. In construction terms, techniques will be employed to increase thermal performance and reduce energy consumption of buildings and make use of recycled materials sourced locally. All these matters are considered to contribute positively to climate change and weigh in favour of the planning application. 9.3 One of the main reasons the application proposal falls down under the Development Plan assessment, is in its fundamental failing to align with the spatial strategies which identify appropriate locations for freight developments of which this site does not form part. Putting the fact that Ravenscraig is not identified for rail freight development to one side, it is also important to consider what benefits developing in this location may offer. Going forward, rail freight networks are likely to become increasing important as export potential grows alongside transition to a low carbon economy and will require improved connectivity to the rest of the UK and Europe. Through the creation of facilities for up to 775 metres length trains, this would comply with international freight standards (longer trains are more likely to transport goods over longer distances i.e to Europe and to the South of England) and incur time efficiencies where trains do not require to be split. The same overhead craneage can be used to load/discharge trains and deliver containers to warehouse loading bays eliminating inland road shunts. Trains can also be received from both the north and south, indeed of all the freight sites, the applicant notes that only Ravenscraig can be addressed from either direction for services to England (via either Wishaw Central or Mossend South Junctions) which provides further resilience when track is being maintained. It also means that trains can serve the terminal without the locomotive being disconnected by operating in a circle (Law Junction, Wishaw, Mossend, Motherwell and returning to Law Junction) further reducing costs and improving asset use. Ravenscraig also has vast land to accommodate large warehouses. In considering the new site by PD Stirling at Bellshill, the applicant notes that it will also create sidings which can accommodate 775 metre trains and accommodate large warehouses, however the site can only be entered from one direction, trains have to be reversed to enter the cargo handling Page 38 of 58
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area from the south. In addition, whilst the existing terminals at Grangemouth, Gartsherrie, and Deutsche Bahn (DB) at Mossend are all able to receive and despatch trains to both the north and south (addressing both relevant market places (North of Scotland and England respectively), the PD Stirling terminal at Mossend can only receive and despatch trains to the south, but only by using the short head- shunt to the north of the terminal (itself a limit on train length). However, the applicant notes that it appears the new PD Stirling terminal does not enjoy that option, therefore forcing trains to either compromise network capacity by locomotive run-round on the main line or finding an alternative route through Glasgow to pass to the south. The applicant notes that operationally, the Ravenscraig site offers several advantages not available for the other terminals and would render the facility highly competitive in the freight industry. 9.4 Even if both the new PD Stirling and Ravenscraig sites were developed, the applicant notes that Network Rail forecasts greater demand in the coming years to 2043 of up to 54 trains per day while cumulatively there would be 43 trains (based on ten in phase one at Ravenscraig) serviced by existing facilities and the new hubs so additional facilities will still be required over and above these sites. The Ravenscraig proposal does not therefore preclude other sites being developed given the recognition for greater demand. In considering the applicant’s current site at Gartsherrie, as discussed under the SDP assessment, this site has poor road access and is recognised as offering little expansion potential due to surrounding residential uses and could not compete in the international freight market (due to having to split trains owing to the substandard siding length and thereby incurring time inefficiencies) to help offset costs required to renew rail gantries and the City Deal Team did not consider there to be a case for intervening to improve road access to the site. The applicant therefore considers the Ravenscraig site to form an upgraded replacement of this facility and the terminal railhead there will close with land offered for redevelopment as residential and open-air sports facilities. The Gartsherrie site is noted to have handling capacity for 13 trains based on overall track length, but as noted above the short sidings require trains to be split. The Ravenscraig proposal is noted as having handling capacity of up to 10 trains in phase one and an overall capacity for 15 trains in future phases, but only phase one can be considered under this application. As this is to replace the Gartsherrie facility, there would be a comparable net reduction of 3 trains, but an overall net reduction of 13 trains, meaning that where there was an overall combined deficit of 11 trains, there would now be 24. However, the improved directional connections and handling efficiencies, coupled with the vast scale of available land within Ravenscraig to enable expansion and accommodation of large distribution buildings, are considered to offer significant benefits to the rail freight industry. 9.5 It is noted that 190 existing Gartsherrie staff will relocate to the Ravenscraig site, whilst it is expected 50-75 new posts will be created in phase one. As explained earlier, estimated posts created in phases two and three can be given little or no weight and likewise for any benefits which may arise from redevelopment of the Gartsherrie facility. Whilst any additional jobs are always greatly welcomed, it is not considered that the number expected under phase one constitute a significant net benefit to the economy. In addition, for the reasons discussed earlier and to be considered in more detail below, the development is not considered to improve health and well-being. Whilst technically access will be improved to the Community Nature Park and further paths created in the green lung, it is considered that the quality of environment within which these will be located will deter the public and reduce opportunities for social interaction and physical activity and recreation. 9.6 Drawing together assessment of the proposal under SPP, it is recognised that there will be significant operational benefits to the freight industry by developing at this location. However, there will still be a large deficit of trains required to meet projected demand especially in light of the intended closure of the Gartsherrie terminal notwithstanding its operational deficiencies, and so several other sites will still have to be found and of these, they may be capable of being accommodated without detriment to the surrounding area. These factors combined with the small number of jobs created do not outweigh nor reconcile the significant adverse effects that are considered to arise from this proposal such that would warrant approval on balance. Revised Ravenscraig Masterplan 18/00463/PPP 9.7 This application was approved on 18th November 2020. The application site is intended to be developed mainly as housing plots, but the north and east edges form part of the proposed community nature park, whilst land at the south edge and adjacent to the roundabout access position, are allocated as other woodland/landscaped areas. It is also noted that directly north of the access roundabout, lies the site for the new school, a second school is also more loosely indicated to the west of the green lung habitat Page 39 of 58
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area. It is considered that the impacts arising from the development can most fully be assessed by considering the existing built context as well as that to be built out under the Masterplan and in so doing within the main body of the report, several of the individual technical aspects have been deferred for assessment to this Section. The following discussion centres on the impacts considered to arise from the proposals on the Masterplan land use allocations. Housing Allocation v Class 6 Storage and Distribution Use 9.8 The Masterplan affords the construction of up to 116,000 square metres industrial floorspace over the Employment Land plots at the western side of Ravenscraig. The phase one building at 27, 870 square metres is just under a quarter of the overall intended allocation for this use Ravenscraig wide. If phase one is approved, and without pre-judging consideration of any application(s) which may be forthcoming for phases two and three, it is clear that one aspect that will need considered is whether there is sufficient merit to support similar development on the remaining land adjacent to the railhead facility to make use of its maximum handling capacity, especially given that suitable sites are rare, and that there will still be a deficit of rail freight facilities under the projected demand beyond that provided at this location. If approval was given for phases two and three, both of which are expected to site 46,451 square metres warehouses each, this would give a combined total of 120,772 square metres and easily exceed that to be built site wide. The railhead warehouses are likely to be single user sites and so the viability of the Employment Land sites are not considered to be adversely affected and will still likely be taken up by a variety of operators keeping this aspect mixed use. However, if phase one is approved, this raises implications for phases two and three as noted above, and instigates the beginnings of a trend towards the return of the predominant industry days of Ravenscraig’s past which over the last 20 years under a Masterplan approach have attempted to make a clean break from towards predominant residential use supported by a new town centre, mixed retail/business/industry with community facilities (school/sports use/nature park) served by improved travel connections to create a truly sustainable community. The loss of housing units coupled with the increased industrial use is therefore considered to be at odds with this approach and undermines the regeneration objectives of Ravenscraig’s Masterplan which has only recently been revised and approved. Traffic Impacts on School Site, Residual Housing Plots, and Access to the Community Nature Park 9.9 A new school is to be sited directly north of the access roundabout to the rail facility on the eastern side of New Craig Road. Another is to be sited towards the southern end nearby to the proposed green lung habitat area but the location for this is more indicative. Of the 900 homes which will soon be completed on Ravenscraig, just over 300 of which (Keepmoat Homes off Meadowhead Road, and Barratt/Taylor Wimpey estates off Prospecthill Road) are located south of the railhead access road. In addition, with the exception of the site west of BOC (237 houses), all other remaining proposed housing plots are also located to the south of the access road. It is considered that those wishing to access the main school site from the north will have the option of taking New Craig Road, or less heavily trafficked routes through the housing estates. For those from the south, (other than the Prospecthill Road estates which would likely take the very short stretch of New Craig Road where the school site is the next exit) the railhead access road would have provided that less trafficked route away from New Craig Road, where all future southern housing plots would have had circulation routes towards. Due to the roadside noise barriers, that pass would be cut off with no option but to travel along the busier route. It also means that travellers from the south not in vehicles, would have to cross the railhead access road where HGVs are expected to arrive/depart under every two minutes. Again recognising that Masterplan approved industrial uses would also route along New Craig Road, as well as an increase in general traffic using the upgraded dual carriageway routes to the M74 and M8, it is noted that these vehicles would pass on a straight course through the junction, are likely to be lower in numbers and thereby less frequent, and only traffic coming from the north would be near to the school for a short period. However, due to the rail freight site being on the eastern side of New Craig Road the same as the school, all traffic manoeuvres would be carried out at close quarters, whether it be right hand turns from traffic from the south, or left hand turns from traffic from the north, queuing of vehicles exiting the rail access, the high volume of traffic and thereby increased frequency all of which would build a greater perception of intrusion from large vehicles upon those accessing the school site whether they had come from the north or south and are likely to lead to increased fears over road safety especially for children which is not considered to accord with the Masterplan principles or ability to provide safe routes to school. NLC Education have raised concerns in this regard. In addition as noted earlier, NLC Transportation do not consider that pedestrian access and safety has been demonstrated for this location. As also noted earlier, wider impacts would also apply to those from the north seeking to access amenities to the south who would also require to Page 40 of 58
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cross this access road. 9.10 Similarly as noted above, due to the continuous noise barriers along the railhead access road, this prevents siting of the previously anticipated junctions off this road to the housing plots on the western side of the WDL and forces all traffic from these to exit to New Craig Road at the potentially busier College and RSF junctions where again NLC Transportation are not satisfied sufficient junction capacity has been demonstrated. Given that this application is only for phase one, and that enabling works of themselves do not preclude housing plots remaining on the phase two and three enabling works areas (plots W2, W4 and W5), siting of the green lung habitat area and rail and green lung noise barriers will also remove the ability to provide the intended additional tunnel link under the WDL from the west to the east parcels which would act as a secondary form of access. This would mean that all traffic to the eastern housing plots would be forced onto the railhead access. A single access for approximately 750 houses, using a road which will be shared with industrial use and significant HGV traffic, which will also have to pass by the facility to access the housing areas, would significantly breach access standards which only allow 200 houses (or an absolute maximum of 300 under special circumstances) off a single access, introduce conflict between the interaction of domestic and industrial traffic raising road safety concerns, and would create an extremely low quality of environment in visual amenity terms for residents on this eastern side. All of these factors would put the viability of developing housing on the eastern side of the WDL in significant jeopardy based on access difficulties. 9.11 In terms of access to the Community Nature Park (CNP), for those in vehicles, this would now only be possible via the railhead access and it is noted that a visitor parking area will be created on its southern side within the green lung, and a layby off the access road on its northern side just beyond the WDL which can accommodate 7 cars. The visitor car park access is approximately 40 metres from the WDL underbridge where again NLC Transportation are not satisfied that adequate sightlines have been demonstrated, whilst the layby is only 20 metres from the internal roundabout where all HGVs for phase one will enter and leave the railhead via the adjacent arm. On both occasions, it is likely that when exiting these areas on foot to access the CNP to the north and east, there will be a heightened perception of close contact with HGVs and sense of danger especially for those exiting the green lung car park who will require to cross the railhead access road where visibility is shortened due to the underbridge and banking, and once they reach the other side, the 5.5 metres high road noise barrier carries on right up to the internal roundabout beyond the WDL which may create a sense of entrapment which would not subside until passage through the underbridge to the eastern parcel where the site opens up fully to access the CNP. For those not accessing by vehicle, as discussed under the SDP Placemaking policy, the siting of noise barriers would force access along the railhead road, except for those wishing to risk routing behind the southern roadside barrier and access via the overlapping arced barriers in the green lung some distance away over unmade ground, or via the alternative access from the southern end near to the Meadowhead Road houses in Craigneuk which is unsurfaced and unlit. Two options to access the CNP are available from the latter, either through the green lung and exiting north with the same concerns as those exiting the visitor car park, or by passing under the other existing railway underbridge and routing past Wishaw Golf Course into the wider countryside area. For those walking/cycling/wheeling along the rail access road, as noted under Placemaking Policy, they would be corralled between 5.5 metres high noise barriers on both sides of the road for half a mile until they reach past the WDL and would be caught in an immediate environment characterised by HGV traffic passing under every two minutes. In addition, noise barriers progressively increase in stature as they close in on the facility such that all built components and traffic would be perceived to be in close proximity, whereas the CNP and woodland would feel distinctly distant and separate. These circumstances are likely to create a heightened sense of danger, urbanisation, and where access to nature is largely shut off. It is unlikely to engender and promote feelings of health and wellbeing and is likely to deter the public from trying to access these areas to realise their full benefit and potential. Noise impact 9.12 The Noise Impact Assessment (NIA) considered six worst case scenarios based on the operational practices intended by the applicant and handling capacity of phase one being ten trains per day. Two daytime scenarios were considered, the first comprising a train leaving whilst one crane was working both at the north side (albeit for health and safety reasons it is unlikely that a crane would work whilst a train is leaving), and the second using the same criteria but from the south side. For night-time, four scenarios were considered in isolation: a train leaving from the north side; a train leaving from the south side; one crane working at the north side; and one crane working at the south side. Bearing in mind that the development proposes four sidings with two cranes and two entry/exit points, it appeared that the Page 41 of 58
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intended operations were overly restrictive in comparison to its physical capabilities. Network Rail (NR) could not confirm any of the detailed matters as these would be borne out during the design and build contract which would follow planning permission if granted. As such, they could not provide verification on the handling capacity of ten trains per day, NR considering this was a matter for the applicant to confirm as they would know how quickly they could load/unload goods but they did confirm that there was line capacity for at least 15 trains to join the rail network. They could not confirm whether they would impose any timetable restriction to prevent a train leaving from the north at the same time as another train leaving from the south nor whether pathway slots would be available to allow direct departure from/return to the sidings from the main track to avoid vehicles having to stop/idle, the highest recorded noise event occurring when trains are in low gear departing; nor crossover locations which allow trains to pass from the main track to the sidings. The applicant confirmed that only one crane would work for health and safety reasons, the second crane being required as a backup in the event of the first crane suffering mechanical failure and that otherwise, they were satisfied that the operational scenarios considered represented their existing and future business requirements. Should committee be minded to approve the application, these prescriptive forms of operation could be controlled by planning condition and the applicant is aware that any departure from these operating terms would require to be subject of a further planning application to consider the impacts. 9.13 In order to render the resultant noise environment acceptable for existing and future noise sensitive receptors (NSRs), noise levels from the operations require to be <5dB above the existing background level. To do so, noise is to be mitigated in the form of acoustic barriers. The 5.5 metres high barriers along the access road are to mitigate traffic noise, whilst a variety of barriers measuring between 2-12 metres high in and around the terminal, railway line, and green lung are to mitigate operational noise from the railhead. The siting of the green lung habitat area also assists in extending the separation distance between the freight facility and proposed housing thereby reducing noise levels further. Collectively these barriers are intended to protect existing and proposed predominantly housing areas, but also the school. Just as earlier discussion noted that the 750 unit W plots on the eastern side of the WDL would require to be discounted from future residential use due to substandard vehicular access, similarly there are no physical means capable of adequately mitigating noise and so these plots would require to be discounted on noise grounds too. The NIA considered 19 other locations around the site and on all occasions the requirement for resulting noise to be <5dB was met. However, the NIA applied an attenuation rating of 13dB for a partially open window whereas NLC’s noise guideline requires 10dB to be applied for industrial noise. Were it as simple as to just add 3dB to the noise results, this would cause a total of 15 locations across the four night-time scenarios to be 5dB or more above background levels and therefore result in an unacceptable noise environment at these locations. However, it is possible that the noise model incorporates more variables and a nuanced method of re-calculating the noise which may retain the noise at acceptable levels of <5dB, or with adjustment to the location and height of the barriers, these may reduce any exceedance back to the target level. However, the position has not been clarified and as it stands it has not been demonstrated that noise will not adversely affect NSRs, nor that it is physically capable of accommodating any increased height or relocation of the barriers particularly the roadside barrier running under the railway bridge, and railside barrier which is already greater in height than its distance to the active main rail track which if it were to topple raises safety concerns albeit NR have raised no objections over the principle of this subject to detailed design. In addition, two other queries remain outstanding: as a result of relocating the roadside barriers to their correct position behind the 7 metres wide active travel route on the north side and 2 metres verge on the south side, will this require any alteration to the barrier and is it capable of being accommodated bearing in mind the railway bridge constraint? It should be noted that changes in the barrier heights/locations does not solely affect noise but would also have a bearing on the visual impact of the development which can also not be fully considered. The other query relates to whether it is realistic for noise modelling to have used a value of one minute for trains to start up. With these queries remaining unanswered, the noise impact from the development has not been fully demonstrated and as noise required to be considered under EIA, the EIA is also considered to be inadequate. Implications for Housing Land Supply (HLS) 9.14 The phase one site including the green lung, and phases two and three enabling works areas take over sites allocated for housing plots in the revised masterplan. As noted above under noise and traffic considerations, whilst the extent of the enabling works on phases two and three would not of themselves preclude housing development on these areas, the very nature of the operational noise produced by the facility would have farther reaching effects than simply removing the phase one landholding from Page 42 of 58
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residential to freight development, but would also render it impossible to mitigate noise to an acceptable level on phases two and three thereby also removing the ability of these areas to remain as housing plots as intended under the revised Masterplan. Along with similar issues being evident in trying to provide vehicular access to these areas, it is apparent that even at this stage by virtue of the phase one effects, if it is approved, there is likely to be more merit in supporting further freight development not only to make maximum use of the rail handling capacity where suitable sites are rare, but also because difficulties may arise in accommodating an alternative use even non-residential, due to vehicular access and noise issues. 9.15 In terms of the Revised Masterplan allocations, the phase one built development area will remove part of housing plots W1 and W3, the green lung area will remove part of housing plots P2-4 and S1, and the enabling works area sits atop housing plots W2, 4 and 5. Information on housing numbers applicable to each area can be taken from the Parameters Plan or the Phasing Plan. The Parameters Plan provides an estimation of unit numbers based on either low density or high density. Site wide a high density development is expected to create 3579 units overall, or 2962 at low density. However, the Phasing Plan indicates an overall capacity of 3115 units. Of the housing plots affected in whole or in part by the works across all three phases (given the noise and vehicle access limitations for residential use), this would result in a reduction of 2017 units if based on high density, 1674 units if based on low density, or if taken from the phasing information, a reduction of 1372 units. In comparing the developable footprint of the Parameters Plan against that of the Phasing Plan, it is noted that the eastern boundary of plots W3 and W4 are recessed on the Phasing Plan. There is no explanation for this but as discussed earlier, it is perhaps because the Masterplan requires Area Planning Briefs for these areas to assign buffer distances from the woodland of the proposed CNP and so the entire area shown for housing on the Parameters Plan would not have physical development on it. Whilst the reason for the boundary reduction nor articulation of the buffer distance provided can be confirmed, it would appear reasonable that the loss of housing unit numbers should be based on the information contained in the Phasing Plan. 9.16 Indeed supporting commentary from the applicant concludes that housing units under the footprint of all three phases would be lost to the freight development and estimates this to amount to approximately 1400 units which again largely concurs with the Phasing Plan which shows this to be 1372 units. As the majority of these are phased from 2035 onwards (plots W1-5 totalling 1042 units) and thereby do not form part of the effective supply, they consider that 330 of the units could be suitably recouped by increasing the density on the remaining housing plots especially around the town centre areas, and that the loss of the 1000+ units would return the overall housing numbers to that of the original Masterplan of 3500 (the Revised Masterplan having added 1000 units). It is accepted that some units could be recouped but whether this would amount to 330 units is in doubt given the land available which would also need to accommodate roads, parking, garden, play or open space areas. In addition, the ability to recoup units would be based on an assumption that there would be market interest for higher density on all remaining house plots, or indeed that there would be market interest at all to develop the remaining plots given that with the exception of the site west of BOC at the northern end of Ravenscraig, all other units would sit directly west of the rail facility which would be in clear view and where noise levels have not been demonstrated as being acceptable. 9.17 The Council have based their housing land programming on the Phasing Plan information of the Masterplan which includes the 1372 units. This programming was subsequently updated following discussions with Homes for Scotland and it remains the position that the majority of units will fall within the non-effective supply. However, the 1372 unit loss represents approximately 10% of the Council’s land supply on a particularly well located brownfield site. The loss of these units would be a significant issue within the Motherwell Housing Sub-Market Area (HSMA) and the Council as a whole where it is not considered that the Council could comfortably recoup the units within the time available. This coupled with the prevailing and emerging National Policy on the reuse of land and non-urban development, would render it extremely difficult to find brownfield land and justify greenfield release in compensation within the Motherwell HSMA where a replacement site(s) would be required. Even if the 330 units could be recouped, the loss of the 1000 units would not only significantly affect the Council’s ability to maintain its Housing Land Supply in the affected future years, but would also detract from the fundamental principle of the Revised Masterplan which sought to re-design the site by changing retail as the key driver of change, to now place greater emphasis on the residential sector as the key land use which would enable transformation of the site. Page 43 of 58
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Community Nature Park Area 9.18 A planned approach to development helps to strike the right balance between safeguarding assets which are irreplaceable and facilitating change in a sustainable way. SPP identifies ancient woodland as one such ‘important and irreplaceable national resource which should be protected and enhanced’. Environmental quality is also considered central to our health and wellbeing and proposals are encouraged to create a walkable place which links open space and wider travel networks thereby making better connections between people and the natural world. Under the Revised Masterplan scheme, it was highlighted that 120.5 Ha (32%) of the overall Ravenscraig site will be retained as open space with a variety of designed and natural environments intended to set development within an accessible and biodiverse landscape setting. Care was taken to integrate new development with existing natural assets such as Ravenscraig Gorge around the South Calder Water (SCW), and Todhole basin with the provision of management plans which seek to encourage public access to these areas while ensuring the protection of both biodiversity and wildlife. Area Planning Briefs (APBs) are also to be prepared for each area and should include the setting of suitable buffers between the natural areas to be protected and those to be developed. Details of the park proposals are to form part of the APB for housing plots P4/5 phased for 2028-2032. Final landscaped links to the woodlands are to be created from 2035. 9.19 The Community Nature Park (CNP) is located on the eastern edge of Ravenscraig, the SCW Gorge forming its north and eastern boundary and proposed housing plots W3-5 running the length of its western side. The CNP area has been defined since the original approval in 2005, having remained unchanged under the Revised Masterplan and is characterised by mainly dense woodland forming a riparian corridor to the SCW but also semi-improved neutral grassland, and ephemeral/short perennial habitats. These habitats, much like the alternate NLLP SINC designation suggests, do not stop at the CNP boundary, but instead carry on stretching westwards over housing plots W3-5, being stopped only by remnant roadway whereafter trees becomes more sporadic and the habitat mainly ephemeral/short perennial until it meets the WDL. As such, it has long been accepted that a large part of the woodland and these other habitats would be lost to housing. However, what has never been articulated thus far, is exactly how much would be lost and where, albeit the earlier discussion above on the Phasing Plan suggests buffer areas may be being applied in the W3-4 plots given these are recessed from the woodlands and in comparing the areas noted in the Parameters Plan (46.8 hectares over plots W1-5 forming all of the eastern parcel) against the Phasing Plan (41.6 hectares) it suggests the land to be developed near to the CNP boundary is 5.2 hectares less, however this would remain unconfirmed until such time as APBs defined the position. What is clear though, is that the entire footprint area of the housing plots (even if taken as the larger area on the Parameters Plan and are what the CNP and Green Belt boundaries are based on), would not be built upon to respect the union between the built and natural environments. It is also worth highlighting that the comparatively small scale of individual house units allows for a more nuanced and organic design to be developed which can be more easily manipulated to recede buildings from areas warranting greater protection such as ancient woodland, and allow projection of new pockets of landscaped open space where they will form a positive relationship with existing planting and create meaningful path links in and around the wider area. 9.20 The application site’s eastern parcel takes over a larger area than that defined for housing plots W3-5 under the masterplan and encroaches into the CNP. Discounting the areas of the site layout not being developed or involving site clearance, the physical development otherwise will encroach into the CNP by approximately 6.2 hectares and is the only area where a definite net loss of woodland is known. This would be in addition to any buffer land that might have been defined by APBs for the intended housing plots which may have been more or less than the 5.2 hectares mentioned above. The applicant proposes 17 hectares of compensatory replacement habitat on the western parcel in the green lung proposal and there is no doubt that this will be an uplift on the likely overall area that would have been lost under housing development. The applicant appreciates that while ancient woodland is irreplaceable, all efforts will be made to translocate other habitat where possible to the green lung giving it a head start, along with planting a majority oak woodland, variety of other native species, mixture of habitats, and wildlife ponds, which will all be beneficial in establishing the new habitat area. 9.21 The phase one facility proposes physical building works, whereas the enabling works for phases two and three are to involve site clearance and earth works to provide material for creating finished design platform levels on phase one, and installation of drainage along the western boundary close to the sidings. The volume of material required from phases two and three cannot be confirmed until such time as intrusive site investigation can be undertaken to inform the cut and fill levels to create phase one Page 44 of 58
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platforms, and this cannot be done until permission is in place and the site is purchased. Whilst all habitat is valued, ancient woodland in particular, is a precious resource which cannot be replaced. It is noted that ancient woodland exists to the north along the SCW and would be outwith the building footprint of phase one and will thereby be retained. There is another large area approximately 6.3 hectares that sits diagonally across phases two and three. Given that site clearance on these phases is only required to supply material on phase one which is currently unconfirmed, there is a high possibility that the required material could be provided from other parts of these phases outwith the ancient woodland areas given that land here extends to approximately 38 hectares. In addition, physical redevelopment of these phases in the future may also be capable of retaining these areas in whole or in part given that they constitute around 75% of the landholding but would only have access to the remaining 5 trains handling capacity of the railhead facility. Therefore, notwithstanding the increased area of compensatory habitat proposed in the green lung, given the importance of ancient woodland and the unconfirmed volume of required material, it is considered that even if it were recommended to approve the proposal, it would still be wholly inappropriate to sanction the wholesale loss of all ancient woodland in phases two and three at this stage which would occur under the site clearance works. 9.22 Whilst it is agreed that the green lung would provide an uplift of compensatory habitat in terms of area, and that the intended planting scheme would support biodiversity, it is also important to consider the quality of environment that would be experienced by visitors using this area given that it is intended to encourage the public into these areas as a natural space for recreation, also compensating the area lost for this purpose in the CNP. The green lung measures approximately 156 metres wide, (roughly 10 metres more than the longest side of the RSF building) and will run for three quarters of a mile. It will be sensitively planted as described above where sculpted mounds will carry the planting and meandering paths will allow access through to create a more natural organic sense of place. However, being sandwiched between the freight facility and residual housing plots, it performs not only a biodiversity role, but also plays an integral part in mitigating noise by extending the separation distance between the conflicting uses, and by hosting the required noise barriers. On its eastern side over its full length, will be sited the 8 metres high barrier to the railway line which also sits 8 metres above the green lung giving a combined height of 16 metres. Beyond that the 36 metres high bay will also be visible on this elevated position. On the western boundary will be arced overlapping barriers measuring 9-12 metres high which runs the length of the green lung. Whilst it is accepted that in time, planting will mature and establish to screen parts of the noise barriers, it will not do so in its entirety and so those using this space, who will be able to discern the barriers on both sides, are likely to experience an oppressive fortress like sense of enclosure at odds with the natural environment upon which they are located. In addition, this area will be subject to noise from the freight operations at close quarters which will interrupt the ability to experience peaceful enjoyment of this new habitat area. Road safety concerns have already been highlighted for those wishing to depart from the green lung and head towards the CNP area via the facility access road. 9.23 Within the northern parts of the CNP the freight impacts will be felt even more acutely as there are no noise mitigation measures proposed here and there will be clear sight of the facility where the public will bear the full force of noise from each of the freight operations ranging from trains moving, cranes lifting and placing containers, and HGVs manoeuvring to uplift goods and depart off site. The applicant considers that due to their development lying close to the CNP where new habitat in the green lung and associated walkways will link the two areas, this will help stimulate and bring forward enhancements to the CNP which otherwise were to form part of the APB for housing plots P4/5 phased for 2028-2032 with final landscaped links to the woodlands not being shown to be created until 2035. It is agreed there is potential for this to happen but it is not clear who would undertake the enhancement works. However, the CNP was intended as one of the few non-urbanised areas within Ravenscraig where people could retreat for peaceful passive recreation and connect with nature. The siting of the facility adjacent to this area, whilst having a specific locational need to be close to the railway, is also where it’s presence will be felt most severely both in visual terms where it will appear as a significant incongruous feature on the natural landscaped character of the area, but also in auditory terms, where the operations will be loudest owing to there being no noise attenuation barriers at this side and where the noise environment created by the facility of bangs and clangs and vehicle movements is likely to out-perform the soothing sounds of nature from moving water and birdsong. For these reasons it is considered that the development will have a significant adverse impact on the resulting environment of the CNP which is likely to deter the public from making use of this area which should have been one of the most prized and valued resources for the Ravenscraig and wider community. Page 45 of 58
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9.24 Diagram 10: Box 2 of the CSDP covers departures from the SDP and requires any development to comply with a range of 7 criteria and taking account of any other material considerations. An assessment of the development against the seven criteria is as follows;- - makes a significant contribution to sustainable development particularly through enabling shift to sustainable travel modes and the contribution to carbon reduction: The carbon reducing impacts from the proposal which enables a modal shift from road to rail would be considered to comply with this criterion; - provides significant net economic benefit including the need to accommodate inward investment that would otherwise be lost to the city region or Scotland: The applicant notes an expected net £62m GVA to the North Lanarkshire economy based on the predicted additional 800 full time jobs created over all three phases. As has been noted earlier, little or no weight can be given to the estimated jobs created in phases two and three as these developments of themselves would require EIA and are not part of the current proposals. In addition, there are no confirmed details of what development might occur on these areas. Little or no weight can be given to Gartsherrie redevelopment impacts either as this would require to be assessed under any application which might be forthcoming. This current application seeks permission for phase one where it is expected 50-75 new jobs will be created. Even by a simple calculation accrediting 10% of the overall GVA expected, this would amount to £6.2m. Whilst not a small sum, it would similarly not be considered to provide a significant net economic benefit (and certainly not enough to counteract negative impacts of the proposal); - responds to economic issues, challenges and opportunities, including the protection of jobs or the creation of a significant number of net additional permanent jobs to the city region: 190 existing jobs from the Gartsherrie facility would relocate to the site. Whilst any additional jobs are always greatly welcomed, the creation of 50-75 new jobs in phase one is not considered to be significant; - Meets a specific locational need: The development is considered to accord with this criterion in meeting competitive requirements for 775 metre length trains with direct connections north and south where no shunting or splitting of trains would be required and pathing would free up network capacity. In addition, adjacent land would be capable of accommodating large warehouses to support the freight operation; - protects, enhances and promotes natural and cultural heritage including green infrastructure, ,landscape and the wider environment: As noted elsewhere in the report, the development involves large scale incursion of the green belt, will remove a large area of ancient woodland and other forms of habitat, and will create a low quality of environment and visitor experience for those accessing the green lung and CNP in contravention of this criterion; - improves health and wellbeing by offering opportunities for social interaction and physical activity, including sport and recreation: Whilst earlier discussions have noted that technically, the development will accord with some Policies due to providing paths around greenspaces, it is considered that the negative environment within which these facilities will be located is likely to deter the public from making use of them and thereby not contribute to improvements in health and wellbeing; and - supports the provision of digital connectivity in new developments and rural areas: The development has a neutral impact on this criterion. On balance, taking account of the above, it is therefore considered an unacceptable departure from the SDP. National Planning Framework (NPF) 4 Consultative Draft 2022 9.25 NPF 4 was laid before the Scottish Parliament as a revised Draft for approval on 8th November 2022, meaning that it is now a material consideration in the assessment of planning applications. Once adopted, it will replace SPP and NPF 3, and remove individual elements of the LDP policies. It sets out the Scottish Government's current view on delivering sustainable, liveable, and productive places through the application of spatial principles. The weight to be given to it prior to its adoption is a matter for the decision maker. Under the Draft. it should be noted that Ravenscraig is no longer accorded national development status, however, it is referred to as “a long standing post-industrial site where new development, including improved transport connectivity, can bring new models of low carbon living at scale”. The applicant considers that the development is in accord with the Draft in terms of bringing much needed significant investment to this particular part of Ravenscraig which has remained Page 46 of 58
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undeveloped since the closure of the steelworks and will provide jobs for local people to help counteract the high levels of inequality and deprivation. It will beneficially re-use brownfield land, support transport and distribution improvements which are nationally important sectors, and assist in the delivery of development in Ravenscraig which is held as a spatial planning priority. It is agreed that these aspects are supported by NPF 4 and that encouragement for modal shift from road to rail in particular, receives continuing focus. However, it is also noted that its spatial principles require that future places work for everyone. Rather than compromises or trade-offs between environmental, social, and economic objectives, it is an integrated strategy to bring together cross-cutting priorities and achieve sustainable development. Indeed, the “How to use this document” section of the Draft states that “The policy sections are for use in the determination of planning applications. The policies should be read as a whole. Planning decisions must be made in accordance with the development plan unless material considerations indicate otherwise. It is for the decision maker to determine what weight to attach to policies on a case by case basis. Where a policy states that development will be supported, it is in principle, and it is for the decision maker to take into account all other relevant policies.” 9.26 Until NPF 4 is formally adopted, it is considered that little weight should be attributed to it. The reason for this is that it still has to be considered and approved by the Scottish Government. In addition, NPF 4 places additional requirements on the applicant which have not been requested thus far during the processing of the application due to the late stage of these requirements now being introduced. Notwithstanding this, it is noted that the proposal conflicts with the Development Plan’s spatial strategy due to not being identified for this use at this location. In terms of material considerations, it is accepted there would be economic and operational benefits to the rail sector, however, these are considered to be greatly outweighed by the adverse impacts considered to arise in terms of environmental and social objectives sought under the Ravenscraig Masterplan. A strong theme coming through in the Draft is the greater emphasis requiring to be given to the assessment of health and wellbeing impacts from developments. In this case, the resultant development would be visually intrusive, would create an environment that would feel neither safe nor welcoming and would lie within an area that was intended to provide many new homes and beyond this, a greenspace resource for residents and the wider community to retreat to and engage with nature. Instead, significant areas of housing, woodland, and other habitat would be lost, and acceptable access to, and peaceful enjoyment of greenspace, would not be possible. All of these factors would not support the health and wellbeing of residents and visitors. It has also not been demonstrated that effects from noise, air quality, access and safety would be within acceptable standards or physically achievable. As such, the development is not considered to accord with NPF 4. 9.27 Drawing together consideration of the relevant Material Considerations, it is noted that there is likely to be significant benefit to the freight industry by developing at this location given the many benefits it would present over other facilities. However, the contribution to train handling capacity in the context of overall projected demand, and the number of jobs created are considered to be low, and these alongside the many varied adverse effects which are likely to arise from the development, results on balance that the benefits do not outweigh the concerns and as such there are no matters that would justify approval of the proposals. 10. Assessment of Consultation Responses 10.1 In terms of the consultation responses received, it is considered that the outstanding matters which have not been covered earlier could be suitably addressed by way of planning conditions or advisory notes in the event permission is approved. 11. Assessment of Representation Comments 11.1 For those concerns not addressed in the discussion above, these can be responded to as follows: • Light pollution can be adequately controlled via planning conditions; • Construction noise is controlled under separate Environmental legislation administered by Protective Services; • HGV’s resting up on local streets to the detriment of road safety cannot be controlled under planning powers however this is considered unlikely to arise given the sheer length of the site access road (800+ metres) where vehicles are more likely to queue awaiting entry to the terminal should this occur and could accommodate over 50 HGVs. There is also a large lorry parking area within the site. Other road safety concerns raised by the development have been discussed earlier; Page 47 of 58
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• Fear of crime would be a matter to be handled by the police; • The size and impact of the proposals were likely not disclosed at the time properties were purchased because the intended development only came into the public domain in November 2020 when the Proposal of Application Notice (PAN) was submitted followed by the planning application in March 2021; • Detrimental impact on surrounding property values is not a material consideration. • Work has not already begun on the development; • Loss of council tax revenue from reduced housing units is noted, other concerns relating to loss of housing have been discussed earlier; • The online pre-application consultation with the community (PAC) exercise accorded with, and exceeded the Regulations in force at the time; and • There are no third party rights of appeal on a planning decision, only on matters of law. 11.2 In terms of Ravenscraig Ltd’s support for the proposal, these have been covered in earlier discussions where adverse impacts are considered to arise from the development. With regard to any re-working of the Masterplan layout, this would require to be considered under any planning application which may be forthcoming in the event the railhead is approved. Meantime it should be noted that the potential retention of two junctions onto the railhead access road around ‘Ravenscraig Square’ would not be possible due to the requirement for a continuous roadside noise barrier. It is considered that necessary changes to the Ravenscraig Masterplan (as a result of this application) would have been best addressed by way of a formal revision to the Masterplan process which would have run concurrent with this application, as it is difficult to understand how such changes could be retrofitted. 12. Conclusions 12.1 Being sited closest to the development, existing and proposed residents, and school users will experience the impacts from the development most acutely. As these constitute the highest sensitivity of receptor, the significance of impact would be even greater. Taking cognisance of the heavily urbanised nature of Motherwell on adjoining land at its western side, compared with the wider countryside setting of Cleland/Wishaw on its eastern side, the approved Ravenscraig Masterplan applies a design logic which complements transition from the busier aspects of employment/town centre/retail/sports uses to the more peaceful areas of housing then community nature park as it moves east. Whilst there is a specific locational need for the railhead to be sited on the eastern side due to operational requirements to connect to the WDL, in doing so, it completely goes against the transitional design principles of the Masterplan layout and locates a 24/7 heavy operation in close proximity to those uses which will occupy the land the most, being residents rather than visitors, where environmental impacts will be felt most severe and where the built development will appear as most incongruous on the visual environment given its elevated position and backcloth of mature woodland within a wider natural character setting and is likely to deter the public from making use of the Community Nature Park as it was intended. 12.2 Undoubtedly, the rail freight facility would bring benefits in reducing carbon emissions and support economic development via access to international markets both of which the Scottish Government is keen to increase, as well as the creation of 50-75 new jobs. However, this cannot reconcile the fact that significant adverse effects are considered to arise from the proposal in terms of its known visual impacts, the losses of housing land, green belt, habitat and woodland, and an acceptable form of access to, and peaceful enjoyment of greenspace thereby creating a low quality of environment. The loss of housing units will be very difficult to recoup, especially trying to find site(s) as sustainable as Ravenscraig, and the railhead facility may have farther reaching impacts affecting the viability of the remaining housing plots to be built out given their proximity to the site, or market interest in other areas affecting the intended objectives of the Masterplan. Insufficient information has been submitted for phase one to clearly demonstrate all aspects of its visual impact and the impact of the development on the road network, road and pedestrian access and safety, noise, and air quality. As noise and air quality form part of the Environmental Impact Assessment (EIA), the EIA is also considered to be inadequate. 12.3 It is considered that whilst rail freight as a form of development receives support, it is not identified for such use at this location. There are no material considerations that would outweigh the adverse impacts that are considered to arise from the proposal, and it is considered to constitute a significant unacceptable departure from the Development Plan. It is therefore recommended that planning permission be refused. Page 48 of 58
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Appendix 1: Comparison of the rail application site boundary relative to the overall Ravenscraig Masterplan boundary Page 49 of 58
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Appendix 2: Rail Application Site Layout Page 50 of 58
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Appendix 3: Ravenscraig Masterplan Land Uses Page 51 of 58
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Appendix 4: Ravenscraig Masterplan Plot Layout Page 52 of 58
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Appendix 5: Ravenscraig Ltd Suggested Masterplan Changes Page 53 of 58
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