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Item 7 Appendix 1 -Supplementary Guidance

West Dunbartonshire Council · 16 November 2022
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ITEM 7 - Appendix 1
Local Development Plan 2
Frontiers of the Roman Empire (Antonine Wall)
World Heritage Site
Supplementary Guidance
November 2022

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This document incorporates amendments following consultation on the draft
Supplementary Guidance in 2022. If/when the associated Local Development
Plan (LDP2) is adopted, this document will be submitted to the Scottish
Government for approval to adopt. Until that time it will be a material
consideration in the determination of planning applications.This document is
also available in other languages, large print and audio format on request.
Please contact Corporate Communications at:
Address: West Dunbartonshire Council, Council Offices, 16 Church Street
Dumbarton, G82 1QL 
Phone: 01389 737527 
Email: Communications@west-dunbarton.gov.uk
Arabic
Hindi
Punjabi
Urdu
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British Sign Language
BSL users can contact us via contactSCOTLAND-BSL, the on-line British
Sign Language interpreting service. 
Find out more on the contactSCOTLAND website

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Frontiers of the Roman Empire (Antonine Wall) World Heritage Site
Supplementary Guidance 
Contents: 
1. Introduction 
1.1 Section 1 Introduction
1.2 Purpose of Supplementary Guidance 
1.3 The Antonine Wall 
1.4 The Frontiers of the Roman Empire World Heritage Site 
1.5 Buffer Zone 
1.6 Protecting the Wall 
2. Application Process 
2.1 Section 2 Introduction
2.2 Site Audit 
2.3 Pre-Application Discussions 
2.4 Environmental Impact Assessment 
2.5 Scheduled Monument Consent 
2.6 Permitted Development and Other Consents 
3. Assessing the Impact of Development 
3.1 Section 3 Introduction
3.2 Physical Impacts 
3.3 Impacts on Setting 
3.4 Cumulative Impacts 
3.5 Adding Value 
3.6 Other Planning Policies and Assessments 
4. Design and Mitigating Impacts 
4.1 Section 4 Introduction
4.2 Design Criteria 
4.3 Mitigation 
4.4 Enforcement 
Appendix 1 - Statement of Outstanding Universal Value 
Appendix 2 - Summary of Key Points 
Appendix 3 - Glossary
Appendix 4 - General Information and Contacts 
Appendix 5 - Map of Antonine Wall and Council Areas
Appendix 6 - The Antonine Wall Then and Now

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1. Introduction
1.1 SECTION 1 INTRODUCTION
1.1.1 This Supplementary Guidance provides advice for developers, decision
makers and the public on managing the impact of development on the
Frontiers of the Roman Empire (Antonine Wall) World Heritage Site
(FRE(AW)WHS) and its setting. The guidance supports the
implementation of the development plan policies agreed by the five
Councils along the Antonine Wall: Falkirk, North Lanarkshire, East
Dunbartonshire, Glasgow City and West Dunbartonshire.
1.1.2 The Guidance will be a material consideration in the assessment and
determination of planning applications affecting the Antonine Wall and
its setting. It will then be progressively adopted as statutory
Supplementary Guidance alongside the emerging Local Development
Plans being prepared by the five local authorities.
1.2  PURPOSE
1.2.1 The purpose of the SG is to:
▪ explain the significance of the Antonine Wall and its status as a
World Heritage Site;
▪ encourage early and effective consultation with Councils and
Historic Environment Scotland;
▪ outline the approach and procedure for assessing development
affecting the World Heritage Site;
▪ set out the criteria which will be applied in determining planning
applications for development along the line of,  and within the
setting and vicinity of the World Heritage Site;
▪ guide decisions on planning appeals and enforcement.
1.3 THE ANTONINE WALL
1.3.1 The Antonine Wall is the most substantial and important Roman
monument in Scotland. Built on the orders of the Emperor Antoninus
Pius in the years following 140 AD, it extends for some 60 kilometres
across central Scotland from Bo’ness on the River Forth to Old
Kilpatrick on the River Clyde and marked the north western frontier of
the Roman Empire.
1.3.2 The Wall functioned both as a frontier control and military defence. It
comprised of a substantial turf rampart built on a solid stone base
fronted to the north by a broad, deep ditch and outer mound. To the
south of the rampart was a road, the Military Way, which permitted the
movement of troops, goods and materials and connected the series of
permanent stone built forts which occur at roughly two mile intervals
along its length. Between some of the forts there are smaller forts, or

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fortlets. Camps used by the troops building the Wall also occur at
regular distances along the frontier. 
1.3.3 The Antonine Wall is of great significance for a number of reasons. It
represents one of many sections of a massive military system which
stretched over 5000 km from northern Britain, through Europe to the
Black Sea, and from there to the Red Sea and across North Africa to
the Atlantic coast. This frontier helped to protect – and define – the
Roman Empire, one of the greatest states ever to have existed. The
Antonine Wall was the most northerly frontier of the Empire, the last of
a series of planned frontiers built in the 2nd Century AD and, at the
time, the most complex ever constructed by the Romans. 
1.3.4 Today around one third of the Antonine Wall is visible above ground, at
places such as Bearsden, Bar Hill and Rough Castle. Around one third
lies in urban areas while the remainder lies in open countryside or open
spaces within urban areas and, though not visible above ground,
survives below ground. Only 2 km of the original 60 kilometres of the
Antonine Wall have been completely lost through quarrying and the
construction of roads, railways and the Forth and Clyde Canal. The
Wall continues to be subject to considerable development pressures
and given its significance it is imperative that the remaining sections –
whether visible on the ground or not – are safeguarded from
inappropriate development. 
1.4 THE FRONTIERS OF THE ROMAN EMPIRE (ANTONINE WALL)
WORLD HERITAGE SITE – FRE(AW)WHS 
1.4.1 In July 2008 the international cultural and archaeological importance of
the Antonine Wall was recognised when the World Heritage Committee
of UNESCO inscribed the site as Scotland’s fifth World Heritage Site
(WHS). The Antonine Wall became an extension of the trans-national
Frontiers of the Roman Empire World Heritage Site which includes
Hadrian’s Wall in England and the Upper Raetian German Limes. The
intention is that the WHS will eventually include all surviving sections of
the frontiers of the Romans in Europe, Africa and the Middle East. 
1.4.2 With World Heritage Site status comes a commitment to protect the
exceptional cultural significance of the Antonine Wall and Outstanding
Universal Values (OUV) for which the site was inscribed. The
Statement of Outstanding Universal Value, provided at Appendix 1, not
only identifies the reasons for the Wall’s inscription as a World Heritage
Site but provides the basis for its effective protection and management. 
1.4.3 It is imperative that development does not compromise the values for
which the Antonine Wall was inscribed as a World Heritage Site, its
authenticity and integrity.

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1.5 BUFFER ZONE 
1.5.1 To protect the important landscape setting of the Antonine Wall a
Buffer Zone has been designated to the north and south of the
monument. The Buffer Zone does not act as an absolute barrier to
development but defines a zone where added protection to the
immediate setting of the World Heritage Site is given.  Development
proposals within the buffer zone will be given careful consideration to
determine whether it is likely to significantly detract from the
Outstanding Universal Value authenticity or integrity of the Antonine
Wall World Heritage Site. 
1.5.2 Section 3 Assessing the Impact of Development provides further
guidance on Buffer Zone and the setting of the Antonine Wall.
The boundaries of the World Heritage Site and the Buffer Zone are
shown in Figure 1, below, as well as on the Proposals Maps of the
relevant local plans/local development plans listed in Appendix 4. 
Figure 1: The Antonine Wall, World Heritage Site and Buffer Zones

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1.6 PROTECTING THE WALL 
1.6.1  World Heritage Site designation does not result in additional direct
legal protection. Nevertheless, the Antonine Wall is protected through
the planning system and in some areas through designation as a
scheduled monument. 
Scottish Planning Policy 
1.6.2 Scottish Planning Policy (SPP) provides a statement of the Scottish
Government’s policy on nationally important land use matters. The
Historic Environment Policy for Scotland (HEPS) sets out the Scottish
Governments policies for the historic environment and provides policy
direction. Paragraph 147 of SPP refers to World Heritage Sites and
states that “Where a development proposal has the potential to affect a
World Heritage Site, or its setting, the planning authority must protect
and preserve its Outstanding Universal Value.” The glossary of SPP
clearly defines the term ‘Outstanding Universal Value’ and emphasises
that the Statement of OUV is the key reference for the future effective
protection and management of the WHS. The glossary also clearly
defines setting.  SPP emphasises that setting is more than simply the
immediate surroundings of a site. It can also relate to how the site was
intended to fit into the landscape, the views from it and how the site is
seen from the surrounding area. Planning Advice Note (PAN) 2/2011:
Planning and Archaeology and the Managing Change in the Scottish
Environment Guidance Notes complete a suite of documents that
together set out the Scottish Ministers’ policies for planning and the
historic environment. Links to all the documents mentioned are listed in
Appendix 4. 
Development Plan Policy 
1.6.3 Decisions on planning applications require to be made in accordance
with the development plan unless material considerations indicate
otherwise. The local development plans of each Council include
policies to protect and enhance the historic environment and
archaeology. National planning policy on the historic environment is
also a material consideration for applications 
1.6.4 Each of the five Councils along the Antonine Wall has also agreed to
include the following specific planning policies on the Antonine Wall
and its buffer zone in their development plans as they are revised and
updated. This document provides additional guidance and information
on the implementation of these policies in the development
management process.

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Antonine Wall Policy 1
There will be a presumption against development which would have an
adverse impact on the Frontiers of the Roman Empire (Antonine Wall)
World Heritage Site as defined on the Proposals Map. 
Antonine Wall Policy 2
There will be a presumption against development within the Frontiers
of the Roman Empire (Antonine Wall) World Heritage Site buffer zones
which would have an adverse impact on the Site and its setting, unless:
▪ mitigating action to the satisfaction of the Council in consultation
with Historic Environment Scotland can be taken to redress the
adverse impact; and
▪ there is no conflict with other Local Development Plan policies. 
1.6.5 In addition to protection under planning legalisation, about two-thirds of
the Wall which has remained unaffected by modern development, is
scheduled as a monument of national importance under the Ancient
Monuments and Archaeological Areas Act 1979. Most works carried
out within the boundaries of the monument require Scheduled
Monument Consent (SMC): the prior written consent of Historic
Environment Scotland. SMC is separate from planning consent and
one can be given without prejudice to the other. Section 2.5 provides
more information. 
KEY POINTS 
▪ This document provides advice for decision makers, developers and
members of the public on managing the impact of development on the
Frontiers of the Roman Empire (Antonine Wall) World Heritage Site
and its setting; 
▪ The Supplementary Guidance is a material consideration in the
assessment and determination of planning applications affecting the
Antonine Wall and its settings and will be adopted as statutory
Supplementary Guidance, which forms part of the  Local Development
Plan; 
▪ The Antonine Wall is of international significance. As a World
Heritage Site its outstanding universal value, authenticity and integrity
must be protected. 
▪ There is a presumption against development which would have an
adverse impact on the Antonine Wall and its setting.

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2. Application Process 
2.1 SECTION 2 INTRODUCTION 
2.1.1 This section provides guidance on key stages in the process of
applying for planning permission where a proposed development may
have an impact on the FRE(AW)WHS or its setting. It also identifies
where other permissions or assessments may be required, for example
scheduled monument consent from Historic Environment Scotland. 
2.2  SITE AUDIT 
2.2.1 Developers considering proposals within the WHS and Buffer Zone
should look carefully at their site to determine whether the development
proposed is likely to have an impact on the fabric or setting of the
Antonine Wall. Table 1 below outlines some of the key information that
will influence whether proposals have an adverse impact, and should
be discussed with the Council at the pre-application stage. Adverse
impacts are examined further in Chapter 3. 
Table 1 – Site Audit; Key Questions 
Factor Key Questions 
Location Is the site in:
• World Heritage Site
• Buffer Zone
• Other designated area
• Scheduled Monument
Site
characteristics
and setting 
Is the site:
• Greenfield
• Previously developed 
What are the key landscape characteristics:
• Topography
• Tree cover
• Enclosed or open 
What is the landscape character of the site and its
setting? 
What is the cultural significance and historic
importance of the existing site characteristics and
setting? 
How will the proposal impact on views to/from the
Antonine Wall? 
Will the proposal affect existing public access to
the World Heritage Site?

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Will the proposal have a direct impact on the
remains of the Antonine Wall and associated
archaeological features? 
Development
Characteristics 
• Size/footprint
• Proposed Use
• Building design  and
materials/scale/height/form/massing
• Landscaping proposals including boundary
treatment 
Development
Plan Policies
What other planning policies and designations
apply to the site? 
2.2.2 It is emphasised that the general principle of new development at any
specific location may be deemed unacceptable because of other
policies in the development plan. For example green belt, open space
and countryside protection policies may rule out the principle of
particular types of development or land use. 
2.3 PRE-APPLICATION DISCUSSIONS 
2.3.1 Developers will be expected, as early as possible, to engage with
the Council in pre-application discussions. Contact details for each
local authority are provided in Appendix 4. 
2.3.2 Early, positive and meaningful engagement will allow unacceptable
proposals to be identified before significant costs are incurred and
allow other projects to move forward more efficiently. Using Table 1
above as a basis, along with any available plans, drawings,
photographs or photomontages and documentation, developers should
aim to provide the Council with as much information as possible
relating to the proposed development and the site. 
2.3.3 With suitable information the Council will be able to make a preliminary
assessment of the proposal, considering relevant development plan
policies and the potential for adverse impacts on the WHS and its
setting. Discussions may also cover: 
▪ any additional information required, for example detailed
archaeological investigations, landscape assessments etc.;
▪ where a proposal might be amended to allow more favourable
consideration (see Section 4);
▪ the Council’s procedure for processing applications, including
key contacts and application fees (including any advertisement
charges);
▪ where wider consultation is required with specialist
archaeological services, statutory organisations and other

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interest groups. This may also involve statutory Pre-Application
Consultation.
▪ advice on other relevant statutory processes, e.g. Listed
Building/ Conservation Area Consents, Scheduled Monument
Consent. 
2.3.4 In many circumstances, only full applications for Planning Permission
will be acceptable for sites within the WHS and Buffer Zone.
Applications for Planning Permission in Principle often cannot provide
sufficient information to enable detailed assessment of impacts on the
WHS or its setting. Where Planning Permission in Principle is sought,
the reasons for this should be discussed with the Council at this pre-
application stage. 
2.3.5 All discussions and pre-application advice is given without prejudice to
the final decision of the Council on any application that may be
submitted. 
2.4 ENVIRONMENTAL IMPACT ASSESSMENT 
2.4.1 Certain types of developments may require Environmental Impact
Assessment (EIA) under the the Town and Country Planning
(Environmental Impact Assessment) (Scotland) Regulations 2017.
Schedule 1 and 2 of the Regulations set out the types of development
to which this applies. This can be discussed during pre-application
discussions and further information is provided at Section 3.7 
2.5 SCHEDULED MONUMENT CONSENT 
2.5.1 Any works directly affecting a designated Scheduled Monument
requires Scheduled Monument Consent (SMC) which is obtained from
Historic Environment Scotland. SMC is required for any works or
operations that would ‘ demolish, destroy, remove, repair, alter or add
to’ those parts of the FRE(AW)WHS designated a scheduled
monument. This includes invasive archaeological investigations.
Applications for SMC are made directly to Historic Environment
Scotland. 
2.5.2 Advice on the SMC process and requirements should be sought at an
early stage from the Heritage Directorate, Historic Environment
Scotland. As in the case of planning applications, early pre-application
contact, this time with Historic Environment Scotland, is strongly
advised. To streamline the process advice on applications for planning
permission and SMC should be sought at the same time. Where both
planning permission and SMC are required, development cannot
proceed without both consents in place. The annex to PAN 2/1011
provides a flowchart outlining the consideration of archaeology in
planning decisions and will be applicable to applications affecting the
Antonine Wall regardless of the need for SMC.

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2.5.3 The presumption of scheduling is that any future works will be the
minimum necessary consistent with the preservation of the monument.
The Historic Environment Scotland website and the HEPS includes
further information on scheduling and SMC and can be used to identify
the location of scheduled monuments: see Appendix 4. 
2.6 PERMITTED DEVELOPMENT & OTHER CONSENTS 
2.6.1 Development that does not require planning permission, for example
householder development within urban areas – where the Wall is
known to have survived under the modern-day ground surface – has
the potential to have adverse impacts without any assessment or
appropriate mitigation. Developers and property owners are strongly
urged to seek advice from the Council before undertaking any works
within the WHS or Buffer Zone to determine whether their proposal is
covered by permitted development rights and to discuss potential
impacts. 
2.6.2 SMC will still be required for permitted development that does fall
within the boundaries of the scheduled monument. 
2.6.3 It is the responsibility of the developer to ensure all necessary
consents, including Building Warrants, Conservation Area Consent and
Listed Building Consent, are obtained. 
KEY POINTS 
▪ Understand your development site: what are the potential impacts of
the proposal on the WHS and its setting? 
▪ Developers are expected to engage with the Council as early as
possible; 
▪ Unconnected to the need for planning permission, Scheduled
Monument Consent is required for works to any part of the
FRE(AW)WHS designated a scheduled monument.

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3.  Assessing the Impact of Development 
3.1 SECTION 3 INTRODUCTION 
3.1.1 This section of the SG provides information on the Council’s approach
to assessing the potential impacts of development on the Antonine
Wall WHS and its setting, including the criteria that will be used. 
3.1.2 Development must not compromise the Outstanding Universal Value
for which the Antonine Wall was inscribed as a WHS. The key
consideration in assessing the impact of development – as outlined in
the development plan – is the presumption against development which
would have an adverse impact on the Antonine Wall and its setting;
that is any impact that would damage the integrity, authenticity,
significance or understanding of the WHS. Examples of what could be
considered adverse include development that: 
▪ destroys or would lead to the damage of archaeological
remains;
▪ interrupts key views to, from, or within the WHS;
▪ changes the character of the landscape in and around the WHS;
▪ reduces people’s appreciation or understanding of the WHS in
its landscape setting;
▪ could negatively affect any of the qualities or significance for
which the WHS was inscribed. 
3.1.3 Impacts may be physical: upon the fabric of the monument; on the
setting of the wall: development that harms the character of the
landscape around the WHS; or cumulative: development that has the
potential to add to the existing negative effects of past or current
developments thereby creating further and possibly greater adverse
effects. This section considers each category of impact in turn and
other factors that will be considered in assessing the impact of
development. 
3.2 PHYSICAL IMPACTS 
3.2.1 Within the FRE(AW)WHS new development of any scale is likely to
have a physical effect on the fabric of the monument and could result in
loss of or damage to significant archaeological remains. Such impacts
intrinsically affect the integrity of the site – one of the reasons for which
it was inscribed as a WHS. Therefore any physical impact on the
surviving fabric of the WHS – whether upstanding or below ground, –
will be considered to be adverse. 
3.2.2 Where sections of the WHS have previously been developed the fabric
of the Antonine Wall may have already been compromised. In these
areas the key consideration in determining if a proposal would have an
adverse physical impact will be whether the new development will
result in additional loss or damage to archaeological remains. As an

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initial guide, the current depth of development on a site sets a sub-
ground limit – known as the Vertical Buffer Zone – below which no
excavation should take place (see Figure 2). The vertical buffer zone
may include complex archaeological deposits, with features relating to
other periods of history, and site investigations to determine the vertical
buffer zone may themselves have adverse impacts. Carefully located
and designed proposals on previously developed sites that do not
extend below the vertical buffer zone may, therefore, be acceptable in
certain circumstances, provided they do not conflict with other planning
policies Pre-application advice should be sought to scope out potential
archaeological impacts of any proposal, particularly those impacts
which may extend beyond the WHS and its associated features. 
FIGURE 2: VERTICAL BUFFER ZONE 
3.2.3 Development should avoid areas of surviving archaeological remains. 
Avoiding the World Heritage Site and, in particular, areas which are
scheduled, will be the best approach.   Even in areas which have
already been developed, the presence, location, depth and sensitivity
of deposits cannot always be predicted.  In many instances it may be
appropriate to carry out an archaeological evaluation to help determine
where Roman deposits lie ahead of making a planning application. 
This may help to design proposals which avoid areas of archaeological
deposits. For smaller developments where surviving Roman deposits
are assessed as being improbable, an archaeological watching brief
and mitigation strategy may be more appropriate – this should be
discussed with the local authority and Historic Environment Scotland at
an early stage.  Moving development outwith the WHS will not
automatically avoid physical impact.  Although not covered by the
WHS, impacts upon archaeological deposits from other periods will not
always be acceptable and should also be considered as part of the
development planning process. 
3.2.4 Proposals should also consider potential long term impacts arising from
development, for example through compression and hydrological
impacts.

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3.2.5 To properly inform the design and assessment process (including pre
application discussions) it is essential that any new development site
overlying the boundaries of the WHS is, at the outset and at the
developer’s expense, the subject of a detailed archaeological
investigation undertaken by a suitably qualified professional. The
Chartered Institute for Archaeologist’ list of Registered Organisations a
good starting point for selecting a consultant. 
Physical Impact within the Buffer Zone 
3.2.6 There may be sub-surface archaeological deposits within or outwith the
defined buffer zone, outwith the line of the World Heritage Site, or
Scheduled areas. This is because the exact line of the Wall is not clear,
and new elements may be discovered during site works. Where known
archaeological remains are present, investigation will be required in
conjunction with new development. Where previously unknown
archaeological deposits are identified during site works the Council
should be informed immediately and further archaeological
investigations may be required. 
KEY POINTS 
▪ Any physical impact on the surviving fabric of the WHS - whether
upstanding or below ground -known or previously unrecognised - will
not be permitted. This refers to both Scheduled Monument and
unscheduled sections of the WHS. 
▪ Proposals on previously developed sites that do not extend below the
vertical buffer zone may be acceptable in certain circumstances. 
▪ Detailed archaeological investigations will be required to accompany
any proposals for development within the boundaries of the WHS. 
▪ Where the extent or presence of archaeological remains is unclear,
pre-determination evaluation will be required. 
3.3 IMPACTS ON SETTING 
3.3.1 The Antonine Wall was not constructed in isolation. It was deliberately
positioned with reference to the surrounding topography, resources and
landscape of central Scotland, notably the southern edge of the valley
formed by the Rivers Kelvin and Carron – a position that offered the
Wall wide-ranging views over the Kilsyth Hills, the Campsie Fells, and
Kilpatrick Hills and meant that it too was widely visible in the landscape.
The setting of the FRE(AW)WHS is predominately well preserved and
readily perceptible and it is this relationship with the landscape that is a
fundamental part of what makes the WHS so significant and
contributes to how it is experienced, understood and appreciated: its
outstanding universal value which must be protected.

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3.3.2 The Buffer Zone has been defined to ensure that all proposals for
development within it are considered carefully as they may have the
potential to affect the WHS; the adjacent environment that it is part of,
and which contributes to the character, significance and
understanding of the Wall. The capacity for new development in the
Buffer Zone varies significantly along the length of the WHS and while
the Council does not seek to prevent all change to the landscape
within the Buffer Zone, it is considered essential that new
development is effectively accommodated within the landscape and is
designed and located to conserve and enhance the setting of the
WHS. This also applies to developments out with the Buffer Zone that
may have an impact by virtue of their scale or visual relationship with
the Antonine Wall. 
Development in the Buffer Zone 
3.3.3 Antonine Wall Policy 2 presumes against development within the
buffer zone which would have an adverse impact on the WHS and its
setting, unless mitigating action to the satisfaction of the Council in
consultation with Historic Environment Scotland can be taken to
redress the adverse impact. Section 4 covers potential mitigation
action, however, it should be noted that in many instances it will not
be possible to mitigate the adverse impact of a proposed
development upon the AW(FRE)WHS. Adverse impacts will be
defined as those which could affect the following criteria: 
▪ a) The authenticity and integrity of the setting, e.g.: 
- Changes to the prominence/dominance of the WHS in the
landscape;
- Obstruction of views to and from the WHS;
- Changes in the overall preservation of the landscape setting. 
▪ b) The significance of the setting, e.g.: 
- How the function and meaning of the WHS relates to the
landscape;
- How the WHS is understood and can be appreciated in the
landscape;
- Relationships between components of the WHS and related
sites. 
▪ c) The character of the landscape in which the WHS sits, including
the contribution the WHS makes to wider landscape character. 
▪ d) The quality of the wider landscape. 
3.3.4 Additional information on the Buffer Zone; how it was defined and its
key characteristics can be found in the Nomination Document and the

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report ‘Definitions of Buffer Zones to the World Heritage Site’. Historic
Environment Scotland has also produced advice on Managing
Change in the Historic Environment (see Appendix 4). These
documents will be a material consideration in the determination of
proposals and their possible impacts. 
Development affecting the wider landscape setting of the World
Heritage Site 
3.3.5 In addition to the defined Buffer Zone it may be necessary to consider
potential impacts of new development outside the Buffer Zone on
longer distance views to and from significant landscape features –
notably the upland edge of the Campsie Fells and Kilpatrick Hills –
which play an important part in the appreciation and significance of
the WHS. Most development beyond the Buffer Zone will not have an
adverse effect on the setting of the WHS or its setting, however, major
development in particular has the potential to detract from or damage
longer distance views to and from the Site. The criteria for judging
whether impacts on wider setting can be considered ‘adverse’ are
broadly the same as those outlined above. 
3.3.6 Within built up areas, parts of the WHS, particularly the scheduled
monument, may also have a setting which will require to be
determined on a site by site basis. 
KEY POINTS 
▪ There will be a presumption against development within the Buffer
Zone which would have an adverse impact on the WHS and its
setting. 
▪ The Criteria set out in paragraph 3.5.3 will be applied in the
assessment of what is an adverse impact on the setting of the
Frontiers of the Roman Empire (Antonine Wall) World Heritage Site. 
3.4 CUMULATIVE IMPACTS 
3.4.1 New development will be assessed on its own merits. However, there
are potential instances where development impacts, acceptable in
isolation, combine to create adverse cumulative impacts on the WHS.
These may be physical – where a series of developments have
resulted in significant losses of archaeological material, or affect the
setting of the WHS – where a sequence of new developments erodes
visual connections with the landscape. Councils will therefore
consider the potential for new development to create, add to or set a
precedent for adverse cumulative impacts. Such consideration will
include:-

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▪ What developments or types of development, in the vicinity of the
proposed site have adversely affected the integrity of the WHS in
the past?
▪ What ongoing activities, developments or natural processes are
affecting its physical condition and survival, and the integrity of its
setting?
▪ What other developments are proposed in the short- to medium-
term that are likely to contribute to adverse effects on the WHS?
▪ Whether the impact of the proposed development is likely to
contribute to cumulative effects generated by the above? 
KEY POINT 
▪ The Council may advise developers to demonstrate they have
given due consideration to the cumulative impact of their
development on the Antonine Wall and its setting. 
3.5   ADDING VALUE 
3.5.1 Where development would not have an adverse impact on the
Antonine Wall and its setting, proposals should seek to make a
positive contribution to the conservation, management and
understanding of the WHS and its setting. Sympathetic, high-quality
design of development can have the potential to add value by
enhancing the character of the WHS and its setting; promoting
improved access, (including by public transport), to, and
interpretation of the site; and contributing to a wider appreciation and
understanding of the WHS in its landscape context. Opportunities
should be identified early in the planning process. Pre-application
discussions with the Council and the archaeology service will assist
in drawing out suitable ideas which can be implemented through the
development process. 
3.6 OTHER PLANNING POLICIES & ASSESSMENTS 
3.6.1 In addition to the impact of proposed development upon the WHS
and its setting, applications for planning permission will also be
considered against relevant policies in the Council’s development
plan, other supplementary guidance and the national policy
framework. Details can be viewed online or can be seen, and
discussed, at the appropriate Council offices. 
3.7 ENVIRONMENTAL IMPACT ASSESSMENT 
3.7.1 Schedules 1 and 2 of the Town and Country Planning (EIA)
(Scotland) Regulations 2017 set out the types of development likely
to have significant impacts on the environment and which are
required to undergo Environmental Impact Assessment. Both
scheduled monuments and World Heritage Sites are defined as
‘sensitive areas’ under the Regulations. Where any proposed

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Schedule 2 development falls within a scheduled monuments or
WHS and is likely to have ‘significant environmental effects,’ an
Environmental Impact Assessment is required (Schedule 1
development always requires EIA). This includes any type of
development that would ordinarily have permitted development
rights, but is located within the sensitive area/is above the thresholds
set out in the Regulations. 
https://www.legislation.gov.uk/ssi/2017/102/contents/made 
3.7.2 EIA development that falls within the Scheduled Area will also
require Scheduled Monument Consent. Planning Circular 1/2017
provides further information on the EIA Regulations. 
http://www.gov.scot/Publications/2017/05/6292

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4.  Design and Mitigating Impacts 
4.1 SECTION 4 INTRODUCTION 
The purpose of this section is to outline the general design principles
for new development within the WHS and Buffer Zone. 
4.1.1 A core principle of the modernised planning system is the focus on the
quality of outcomes, taking account of the sustainable use of land,
good design and the protection and enhancement of the built and
natural environment. The international significance of the Antonine Wall
means good quality design will be vital for any development on or near
the WHS, including within the Buffer Zone and fundamental to the
avoidance of any adverse impact. 
4.2 DESIGN CRITERIA 
4.2.1 In the first instance, there is a presumption against development which
would have an adverse impact on the Frontiers of the Roman Empire
(Antonine Wall) World Heritage Site and its setting. Key to the
avoidance and minimisation of adverse impacts on the WHS will be
good design which takes account of the following principles: 
▪ Careful site selection:
▪ Site selection should avoid the WHS, in particular those
areas which are scheduled; 
▪ Site selection within the Buffer Zone should  avoid the
most sensitive areas and avoid obstructing views to/from,
and limiting existing access to the WHS; 
▪ Prioritise previously developed sites, taking account of
the ‘vertical buffer zone’ and allowing, where possible,
development to fit within existing settlement patterns. 
▪ Well considered development layout:
▪ Proposed development should seek to maximise the
benefit of existing site features, especially topography
and vegetation, to eliminate adverse visual impacts. 
▪ Appropriate building design:
▪ The characteristics of the site, landscape and local
building styles should inform the form, massing, height
and materials of new buildings, generating coherent, high
quality solutions. 
▪ High quality landscape design:
▪ Landscaping – both hard and soft – should be as much
part of the development process as the architecture. Well
planned and executed design may enable development
to be accommodated by the site and wider landscape and

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has the potential to reinforce existing landscape features
and character. Additional landscaping can also impact on
intervisibility between different parts of the WHS and its
setting. It is therefore important that the location and
specification of new landscaping is considered in relation
to impact on the WHS and its setting. 
4.3 MITIGATION 
4.3.1 Antonine Wall Policy 2 states there will be a presumption against
development within the Buffer Zone which would have an adverse
impact on the Site and its setting unless mitigating action to the
satisfaction of the Council, in consultation with Historic Environment
Scotland, can be taken to redress the adverse impact. Mitigation
measures potentially reduce any identified impacts to an acceptable
level. It is emphasised though that not all adverse impacts can be
successfully mitigated. Impacts on the WHS and its setting should
primarily be avoided through positive siting and design decisions in
preference to the use of other mitigation measures. 
4.3.2 Examples of mitigation may include landscaping proposals which are
designed to reflect and strengthen local landscape character and the
visual setting of the Antonine Wall. Mitigation measures however
should not in themselves potentially generate adverse impacts. 
4.3.3 Design matters and the potential for mitigation measures should be
discussed at the pre-application stage, and appropriate reports
submitted in support of any application demonstrating that discussions
have been effectively incorporated in the finalised proposals. In the
event that permission is granted suitable conditions and, if necessary,
planning agreements will ensure the proper implementation of agreed
mitigation measures. 
4.3.4 Conditions will be used to ensure that development does not proceed 
before a programme for appropriate mitigation has been identified,  or
where archaeological recording has taken place. Conditions will ensure
that safeguards are in place to protect important features. When
imposing conditions, planning officers will consult with Historic
Environment Scotland and/or Council’s Archaeologists to ensure that
the proposed measures are proportionate, enforceable and effective in
conserving OUV. Examples of suitable conditions might include
landscaping and/or protective buffer zones around key in-situ sections
of the wall 
KEY POINTS 
All development within the Frontiers of the Roman Empire (Antonine
Wall) World Heritage Site and Buffer Zone will be expected to be of
good design, demonstrating: careful site selection; well considered

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development layout; appropriate building design and materials; high
quality landscape design. 
▪ Mitigating action which redresses the adverse impact of development
within the Buffer Zone may be acceptable but must be discussed in
consultation with – and be to the satisfaction of - the Council and
Historic Environment Scotland. 
▪ Mitigation of adverse impacts will not be possible in all instances. 
4.4 ENFORCEMENT 
4.4.1 The unique trans-national nature of the Frontiers of the Roman Empire
(Antonine Wall) World Heritage Site means that damage to the
Antonine Wall could affect the integrity and significance of the WHS as
a whole – with international implications for Scotland. 
4.4.2 The recognition of the WHS’s Outstanding Universal Value, means the
Antonine Wall requires the highest level of statutory protection. Loss or
damage to upstanding archaeological remains and those buried
beneath the ground will be treated as a particularly serious breach of
regulatory controls. Other impacts of unauthorised development will be
judged against the same guidance for new developments with respect
to the effect on the character, integrity or significance of the World
Heritage Site. Non-compliance with planning conditions or agreements
may also result in significant adverse impacts. 
4.4.3 Breaches of planning control will be investigated and, if appropriate,
enforced by the Council, or in consultation with Historic Environment
Scotland. In all cases it will be required that ongoing work cease with
immediate effect, to allow a proper assessment of the impacts and
prevent damage or loss once it is established that there is or has been
a breach. In particular it may be considered appropriate to issue a
temporary stop notice requiring an immediate halt to activity and
allowing time for further enforcement action to be put in place to protect
the site or archaeological remains. Full details of the enforcement
powers available to planning authorities are set out in Planning Circular
10/2009: Planning Enforcement. Remedying the breach will take
account of particular circumstances, but can include full site
reinstatement. Non-compliance with enforcement or stop notices can
also be prosecuted at the Sherriff Court. 
4.4.4 Any person carrying out unauthorised works or allowing unauthorised
works to be carried out on a Scheduled Monument without consent are
guilty of an offence. Works are defined as: anything resulting in the
demolition or destruction of a scheduled monument; any works for the
purpose of removing or repairing a scheduled monument; or any
flooding or tipping operations. The Historic Environment
(Amendment)(Scotland) act 2014 introduced new powers to enable
Scottish Ministers to serve scheduled monument enforcement notices,

Page 23

complemented by temporary stop notices where unauthorised works
are taking place on a scheduled monument. Further information on this
is available on Historic Environment Scotland's website 
https://www.historicenvironment.scot/advice-and-support/applying-for-
consents/scheduled-monument-consent/compliance/ 
KEY POINTS 
▪ The Council will seek to protect the Outstanding Universal Value of the
World Heritage Site through a robust approach to unauthorised
development. The Statement of Outstanding Universal Value is located
here: http://www.antoninewall.org/world-heritage/nomination-and-
inscription/souv 
▪ ICOMOS have prepared guidance on the process of commissioning
HERITAGE IMPACT ASSESSMENTS (HIAs)  for World Heritage (WH)
properties in order to evaluate effectively the impact of potential
development on the Outstanding Universal Value (OUV) of properties.
This is located here : http://www.icomos-uk.org/world-heritage/

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APPENDIX 1: STATEMENT OF OUTSTANDING UNIVERSAL VALUES 
The Statement of Outstanding Universal Value for the Frontiers of the Roman
Empire (Antonine Wall) World Heritage Site as contained in the decision
notice of the World
Heritage Committee outlines the exceptional cultural significance of the
Antonine Wall: 
“The Antonine Wall fully illustrates the effort of building the Limes on the
frontiers of the Roman Empire, at the time of its apogee and greatest
extension in the British Isles and worldwide (middle of the 2nd century AD). It
embodies a high degree of expertise in the technical mastery of earthen
defensive constructions, in the construction of a strategic system of forts and
camps, and in the general military organisation of the Limes. The Antonine
Wall also demonstrates the diffusion of the military and civil engineering of the
Roman civilisation to the whole of Europe and the Mediterranean world.” 
The Antonine Wall meets three of the selection criteria for inscription as a
World Heritage Site, (ii), (iii) and (iv): 
(ii) The Antonine Wall is one of the significant elements of the Roman Limes
present in Europe, The Middle East and North Africa. It exhibits important
interchanges of human and cultural values at the time of the apogee of the
Roman Empire; 
(iii) The Antonine Wall bears testimony to the maximum extension of the
Roman Empire, by the consolidation of its frontiers in the north of the British
Isles, in the middle of the 2nd Century AD. The property illustrates the Roman
Empire’s ambition to dominate the world in order to establish its law and way
of life there in a long-term perspective; 
(iv) The Antonine Wall is an outstanding example of the technological
development of Roman military architecture and frontier defence

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APPENDIX 2: KEY POINTS 
• The Antonine Wall is of international significance. As a World Heritage
Site (WHS) its outstanding universal value, authenticity and integrity
must be protected.
• There is a presumption against development which would have an
adverse impact on the Antonine Wall and its setting.
• Developers are expected to engage with the Council as early as
possible.
• Any physical impact on the surviving fabric of the WHS – whether
upstanding or below ground, known or previously unrecognised – will
only be permitted in exceptional circumstances ;
• All development within the WHS and Buffer Zone will be expected to be
of good design, demonstrating: careful site selection; well considered
development layout; sympathetic, high-quality building and landscape
design and materials.
• Mitigating action which redresses the adverse impact of development
within the Buffer Zone may be acceptable but must be discussed in
consultation with – and be to the satisfaction of – the Council and
Historic Environment Scotland.
• The Council and Historic Environment Scotland will seek to protect the
Outstanding Universal Value of the WHS through a robust approach to
unauthorised development.

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APPENDIX 3: GLOSSARY 
Antonine Wall
The Roman Empire frontier system running across central Scotland from the
Firth of Forth to the Clyde Estuary, constructed c AD 142 on the orders of the
Emperor Antoninus Pius. Inscribed as part of the Frontiers of the Roman
Empire World Heritage Site in July 2008. 
Authenticity
Depending on the type of cultural heritage, and its cultural context, properties
may be understood to meet the conditions of authenticity if their cultural
values (as recognised in the nomination criteria proposed) are truthfully and
credibly expressed through a variety of attributes including: form and design;
materials and substance; use and function; traditions, techniques and
management systems; location and setting; language, and other forms of
intangible heritage; spirit and feeling; and other internal and external factors. 
Buffer Zone
For the purposes of effective protection of the nominated property, a buffer
zone is an area
surrounding the nominated property which has complementary legal and/or
customary restrictions placed on its use and development to give an added
layer of protection to the property. This should include the immediate setting
of the nominated property,
important views and other areas or attributes that are functionally important as
a support to the property and its protection. The area constituting the buffer
zone should be determined in each case through appropriate mechanisms. 
Environmental Impact Assessment (EIA): Environmental Impact
Assessment (EIA) is the process of assessing the likely environmental
impacts of a proposal and identifying options to minimise environmental
damage. 
Frontiers of the Roman Empire: World Heritage Site composed of three
walls in different parts of Europe- Antonine Wall, Hadrian’s Wall, German
Limes forming part of the frontiers of the Roman Empire. 
The Historic Environment Policy for Scotland: sets out how Historic
Environment Scotland fulfils its regulatory and advisory roles and how it
expects others to interpret and implement Scottish Planning Policy. It is a
material consideration in the Scottish planning system. 
Integrity
Integrity is a measure of the wholeness and intactness of the natural and/or
cultural heritage and its attributes. Examining the conditions of integrity,
therefore requires assessing the extent to which the property: includes all
elements necessary to express its Outstanding Universal Value; is of
adequate size to ensure the complete representation of the features and
processes which convey the property’s significance; suffers from adverse
effects of development and/or neglect.

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Scheduled Monument: A nationally significant monument, building or site
included in the Schedule of Monuments maintained by Historic Environment
Scotland. 
Setting:  the way the surroundings of a historic asset or place contribute to
how it is understood, appreciated and experienced. 
World Heritage Site: World Heritage Sites are cultural and/or natural sites
considered to be of ‘Outstanding Universal Value’, which have been inscribed
on the World Heritage List by the World Heritage Committee. 
Outstanding Universal Value: Outstanding Universal Value means cultural
and/or natural significance which is so exceptional as to transcend national
boundaries and to be of common importance for present and future
generations of all humanity. As such, the permanent protection of this heritage
is of the highest importance to the international community as a whole. At the
time of inscription of a property on the World Heritage List, the World Heritage
Committee adopts a Statement of Outstanding Universal Value which will be
the key reference for the future effective protection and management of the
property.

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APPENDIX 4: GENERAL INFORMATION AND CONTACTS 
Antonine Wall World Heritage Site website: 
http://www.antoninewall.org/ 
Antonine Wall Management Plan:
https://www.historicenvironment.scot/archives-and-
research/publications/publication/?publicationId=f477ec1e-8366-4295-ac10-
a5c900aab488 
Antonine Wall nomination document
http://www.antoninewall.org/sites/default/files/Antonine%20Wall%20Nominatio
n%20doc.pdf 
Historic Environment Scotland: 
www.historicenvironment.scot 
Data Services:
https://portal.historicenvironment.scot/spatialdownloads 
Scheduled monuments:
https://www.historicenvironment.scot/advice-and-support/listing-scheduling-
and-designations/scheduled-monuments/ 
Chartered Institute for Archaeologists (CIfA):
http://www.archaeologists.net/ 
Historic Environment Scotland) Act 2014
http://www.legislation.gov.uk/asp/2011/3/pdfs/asp_20110003_en.pdf 
Planning Advice Note (PAN) 2/2011: Planning and Archaeology
http://www.gov.scot/Publications/2011/08/04132003/0 
Definitions of Buffer Zones to the World Heritage Site (Land Use Consultants
report for Historic Environment Scotland, July 2006) – available on request 
Managing Change in the Historic Environment (Historic Environment
Scotland) World Heritage Sites: 
https://www.historicenvironment.scot/archives-and-
research/publications/publication/?publicationid=89d391d9-9be2-4267-919f-
a678009ab9df 
Managing Change in the Historic Environment (Historic Environment
Scotland)
Setting: https://www.historicenvironment.scot/archives-and-
research/publications/publication/?publicationId=80b7c0a0-584b-4625-b1fd-
a60b009c2549 
Scheduled Monument Consent:
https://www.historicenvironment.scot/archives-and-

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research/publications/publication/?publicationId=515c06f2-d8b0-40f9-919f-
a88000d44a5b 
LOCAL DEVELOPMENT PLANS 
Falkirk Local Development Plan 2:
https://www.falkirk.gov.uk/services/planning-building/planning-policy/ 
North Lanarkshire Local Development Plan:
https://www.northlanarkshire.gov.uk/your-council/council-strategies-and-
plans/local-development-plan 
East Dunbartonshire Local Development Plan 2:
https://www.eastdunbarton.gov.uk/residents/planning-and-building-
standards/planning-policy
Glasgow City Development Plan
https://www.glasgow.gov.uk/index.aspx?articleid=16184 
West Dunbartonshire Local Development Plan:
https://www.west-dunbarton.gov.uk/council/strategies-plans-and-
policies/local-development-planning/ 
CONTACTS 
East Dunbartonshire Council
Development Applications Team, Southbank House, 1 Strathkelvin Place
Kirkintilloch, G66 1XQ
Tel: 0300 123 4510
Email: planning@eastdunbarton.gov.uk 
Falkirk Council
Planning & Environment, Development Services, Abbotsford House, David’s
Loan, Falkirk, FK2 7YZ
Tel: 01324 504950
Email: planenv@falkirk.gov.uk 
Glasgow City Council
Development and Regeneration Services, 229 George Street, Glasgow, G1
1QU
Tel: 0141 287 8555 
Email: developmentplan@glasgow.gov.uk 
North Lanarkshire Council
Development Management, Planning and Development, Fleming House, 2
Tryst Road, Cumbernauld, G67 1JW
Tel: 01236 632500
Email: ESEnquiries@northlan.gov.uk 
West Dunbartonshire Council
Development Management Section, 16 Church Street, Clydebank, G81 1TG

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Tel: 01389 738575
Email: buildingandplanning@west-dunbarton.gov.uk 
Historic Environment Scotland - Planning, Consents & Advice Service,
Longmore House, Salisbury Place, Edinburgh, EH9 1SH.
Tel: 0131 668 8716
Email:  HMconsultations@hes.scot

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APPENDIX 5: MAP OF ANTONINE WALL AND COUNCIL AREAS

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APPENDIX 6: THE ANTONINE WALL THEN AND NOW