Democracy Spraffa

Item 7 Appendix 6

West Dunbartonshire Council · 16 November 2022
Back to Planning Committee — 16 November 2022 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Page 1

ITEM 7 - Appendix 6
Green Network and Green Infrastructure – comments received on draft version and Council’s proposed response
Respondent Comment WDC response
The Coal
Authority
Our records indicate that within the West
Dunbartonshire area there are recorded coal mining
features present at surface and shallow depth
including; mine entries, shallow coal workings and
reported surface hazards.  These features pose a
potential risk to surface stability and public safety.  
The Coal Authority’s records also indicate that
surface coal resource is present on the site, although
this should not be taken to imply that mineral
extraction would be economically viable, technically
feasible or environmentally acceptable.   As you will
be aware those authorities with responsibility for
minerals planning and safeguarding will have
identified where they consider minerals of national
importance are present in your area and related
policy considerations.  As part of the planning process
consideration should be given to such advice in
respect of the indicated surface coal resource.
It is noted however that this is a draft SPG on Green
Network and Green Infrastructure and I can confirm
that the Planning team at the Coal Authority have no
specific comments to make on this documents.   
It is noted that the Coal Authority has no specific
comments on this document.
It may however be worth noting that if SUDs are
proposed as part of developments green
infrastructure consideration will need to be given by
These comments, about the design and development
process of SUDs, are more relevant to the Creating
Places Supplementary Guidance and the respondent

Page 2

the developer to the implications of this in relation to
the stability and public safety risks posed by coal
mining legacy.  The developer should seek their own
advice from a technically competent person to ensure
that a proper assessment has been made of the
potential interaction between hydrology, the proposed
drainage system and ground stability, including the
implications this may have for any mine workings
which may be present beneath the site.
has agreed they may be addressed in relation to the
consultation on that draft supplementary guidance.
Glasgow &
Clyde Valley
Green
Network
Partnership
Generally the SG is very good, clear, concise and
focusses on the things we'd want to see delivered
through development.
This support is welcomed.
Page 4: Suggest this text here and in the graphic
below is changed:
Under Greenspace substitute for:
“is any vegetated land or structure, water, path or
geological feature within and on the edges of
settlements.”
Under Green Infrastructure substitute for: “is
greenspace which is designed and/or managed to
provide identified functions.”
Agreed, Figure 1 has been changed to reflect these
comments.
Page 5: Request for wording in the ‘Planning and the
green network and green infrastructure’ section to be
strengthened
Agreed, the phrase “where possible” has been
deleted, which brings the text in the supplementary
guidance in to line with the strategy as written in the
LDP2.
Page 7: Suggested alternative wording in the
‘Embedding the green network and green
infrastructure’ section:
add “providing an overall net gain in provision” to first
bullet point; and
add “which have designed functions for a range of
users” to 4th bullet point.
Agreed, these changed have been made, with a
qualification that net gain can be either qualitative or
quantitative (Page 8).

Page 3

Page 8: In Green infrastructure function: habitat
enhancement section, use the term ‘nature networks’
in line with the draft NPF requirements?
Agreed, the wording has been changed to ‘nature
networks’.
Page 11: Incidental greenspace and landscaping will
not count to towards the quantity standard.
Developers should provide a site plan indicating
which spaces comprise provision
Agreed, this wording has been added.
Page 19 – Appendix 2: Only some of the relevant
LDP policies are cross-referenced in the graphic
Noted, the graphic has been updated with all policy
cross-references.
Historic
Environment
Scotland 
The drafts for our historic environment interests have
been considered , and can confirm that we have no
comments on their content.
It is noted that Historic Environment Scotland has no
specific comments on this document.
Homes for
Scotland
Introduction 
Homes for Scotland (HFS) welcomes the opportunity
to comment on West Dunbartonshire’s Draft
Supplementary Guidance (SG) in relation to Green
Network and Green Infrastructure. 
This submission sets out our representations in
relation to the published draft SG. Firstly though,
there are some general matters of concern to HFS.
Noted
General Concerns 
It is stated within this Guidance that will be adopted
as statutory supplementary guidance, forming part of
Local Development Plan 2 (LDP2). Given LDP2 has
not yet been adopted, and therefore its final form is
not currently known, it is problematic to be publishing
SG to support this. It is not even known whether
LDP2 will in fact ever be adopted. 
General Concerns 
The status of the Supplementary Guidance has been
clarified at the front of the document. The guidance is
intended to be adopted as supplementary guidance to
the Local Development Plan (LDP2) and provides
further detailed guidance on the content thereof, it is
therefore not premature in relation to the emerging
National Planning Framework or Development
Planning Regulations, as the LDP has been prepared

Page 4

LDP2 does not currently form part of the
Development Plan, as it remains unadopted.
Therefore, the lower tier of the Development Plan in
West Dunbartonshire is the West Dunbartonshire
Local Plan (WDLP), adopted in March 2010. The
status of this Plan has been significantly eroded, as it
is now over 7 years out of date. 
The draft SG has also been released just ahead of
the anticipated new Development Management
Regulations and National Planning Framework 4
(NPF4). For these reasons it could be argued that the
revision and delivery of new SG is premature. 
As noted above, it is stated that the Council intends to
adopt the proposed new SG as part of the statutory
Development Plan. However, this statutory status
might only last for a limited period as all such
guidance will at some point have to be non-statutory
under the soon to be published new Regulations and
NPF4. While it is acknowledged that Scottish
Ministers have made provision for a 24 month
‘transitional period’ following publication of the new
Regulations, the draft new SG could end up being
part of the adopted development plan for a limited
period after which the council will require to undertake
a further revision to reflect the non-statutory status
thereafter. 
As we don’t yet know what the new Regulations will
look like and how the transitional period will be
implemented, HFS is of the view that the Council
and will be adopted based on the current Scottish
Planning Policy, and the current Development
Planning Regulations and in line with transitional
arrangements. 
The guidance on transitional arrangements indicates
that Planning Authorities will require to decide if the
content of Supplementary Guidance should move to
planning guidance or be included within local
development plan itself. However the guidance also
indicates that new supplementary guidance can be
prepared and adopted until Section 22 of the 1997
Act is repealed and for a further 24 month period
thereafter.

Page 5

should consider moving straight to publication of non-
statutory SGs as other Local Authorities, including
South Lanarkshire Council, have done.
Regardless, the draft Guidance, in places, appears to
go beyond merely supplementing policies within the
LDP but rather looks to introduce new and more
onerous requirements for developments to meet. This
is not an appropriate use of SG as the principles of
policy have not been properly scrutinised or tested as
part of the LDP examination. 
Planning Circular 6/2013 (Development Planning)
notes that Regulation 27 (2) of The Town and Country
Planning (Development Planning) (Scotland)
Regulations 2008 requires SG to be limited to the
provision of further information or detail in respect of
policies or proposals set out in the SDP or LDP.
There must be a sufficient “hook‟ in the SDP or LDP
policies or proposals to hang the SG on, to give it
statutory weight. 
This matter was reinforced by a letter sent to All
Heads of Planning on 15 January 2015 by The Chief
Planner, which states: 
“For supplementary guidance to be issued in
connection with a local development plan, this means
that the guidance may only deal with the provision of
further information or detail in respect of policies or
proposals set out in the local development plan and
then only provided those are matters which are
expressly identified in a statement contained in the
The Council considers that LDP2 provides sufficient
‘hooks’ for the Green Network and Green
Infrastructure Supplementary Guidance. The
Supplementary Guidance is referenced 16 times in
LDP2, in various sections of the Plan, in both policies
and explanatory text, reflective of the Plan’s green
infrastructure first approach. The Supplementary
Guidance serves the purpose of providing further
information or detail in respect of policies set out in
LDP2.

Page 6

plan as matters which are to be dealt with in
supplementary guidance.” 
We believe specific sections of the draft SG breach
these requirements, as detailed below. 
Any mechanism which may seek to restrict the
deliverability of new homes to meet the housing crisis
which prevails in Scotland must be resisted. As we
move towards the new system under NPF4, the
threshold for what constitutes a “deliverable” site is
greater than previously existed, and it is against this
backdrop that all policies/strategies must now sit.
Affecting the deliverability of sites through the
introduction and requirement of a range of additional
asks must be seriously considered. 
The Scottish Government have indicated in the draft
NPF4 that the Climate and Nature Crises should be
given the highest priority when considering planning
issues. While it is acknowledged that the final NPF
has yet to be published, the Planning Authority
recognises that the Climate Crisis, Nature Crisis and
any housing crisis are all part of the range of issues
which are considered when preparing policy and
guidance and it sits with the Planning Authority to
afford appropriate weight to these and all other
relevant considerations.
Green Infrastructure Delivery in New Development 
The draft Guidance refers to situations where a
developer contribution towards off-site improvements
may be sought. Whilst the principle of this is
supported there should be reference to hybrid
scenarios where a combination of off and on-site
provision/improvements may be appropriate. 
It is agreed that a hybrid approach may be acceptable
where on-site provision cannot be met in full, as
indicated by the Developer’s Flowchart, Appendix 1
and Appendix 3, examples 4 and 5. Further
clarification of this has been added to the guidance
(page 15). However the requirement, and preference,
for on-site provision with a limited number of
exceptions is retained.
Biodiversity Enhancement  Biodiversity Enhancement

Page 7

While HFS does not object to the principle of
‘biodiversity enhancement’, there is currently
insufficient information as to precisely what this will
mean in practice. Draft NPF4 indicates that Scottish
Ministers are still considering this themselves and it
therefore appears likely that there will be further
national guidance on the matter in the final version of
NPF4. It is therefore premature to implement this
requirement for new planning applications.
Policy CP2e requires Habitat Enhancement, and
indicates that, “Development proposals must protect,
restore and enhance biodiversity habitat networks,
and environmental quality within and linking to the
site. Opportunities for improving the conservation
status of priority species and the inclusion of
ecological features within the built environment
should be considered” This policy is within the plan
and has been through examination. It is therefore
disagreed that it is premature to provide further detail
on this policy. No change required.
Open Space – Establishing Need and Opportunity
Table 1 outlines that Open Space provision may be
required for proposals of 10 or more units, in
situations where “need/opportunity identified”. Further
clarification is required here. How is need and
opportunity to be assessed? What specific
assessment processes are in place which would
trigger the requirement for Open Space? There is a
lack of information here, which risks causing
uncertainty, and subsequently viability concerns. 
It is also worth noting that this ambiguous phrasing
also pertains to the potential requirement to deliver
Access Networks, Water Management and Habitat
Networks.
Appendix 1 of the Supplementary Guidance sets out
a flow chart which provides a guide to the
expectations for the provision of open space. The
guidance also states that “The green network
requirements for each individual site will be discussed
and agreed at pre-application stage.” 
Policy CP2 Green Infrastructure and the
Supplementary Guidance set out a green
infrastructure first approach to the provision of access
networks; open space; water management; and
habitat enhancement so as to contribute to the
development and enhancement of a multi-functional
green network. The policy and guidance indicate that
this is best achieved through a design led approach
from the outset. Further guidance on how these
functions can be layered together to provide multiple
benefits for “health, wellbeing, wildlife, as well as,
climate change mitigation and adaptation” are given
in the Creating Places Supplementary Guidance. No
change is required in this regard.

Page 8

Open Space Requirements
The draft SG states:
“All new housing developments should provide
access to 30m2 of publicly useable open space per
person.” 
The Council’s most recent update to the Open Space
Audit was in 2018 and is therefore four years old. It is
not clear, therefore, how the Council has reached the
conclusion that the above volume of Open Space is
required to be provided. It is also recommended that
the Council aligns its Open Space requirements with
many other Local Authorities’ approaches, including
East Lothian Council, by amending the requirement to
be provided on a per dwelling basis, rather than per
person, given the number of dwellings will be known
(and constant), whereas the number of people will
not. 
Based on the 2011 Census the average household
occupancy within West Dunbartonshire is 2.15 people
per household. This data should be used to calculate
the Open Space requirement and potential
contribution rather than extrapolated data based on
the Scottish Household Survey. The Census data is
an accurate snapshot in time. 
The 30m2 per person requirement is established by
the Local Development Plan (LDP2), which has been
through examination. 
The Council considers that basing the open space
calculation on the average household size of different
dwelling sizes provides a more accurate open space
requirement than using a single average household
size figure. This approach has been used by the
Council since 2015 so is a well established approach
in West Dunbartonshire. 
No change is required in this regard.
The draft Guidance seeks to assess proposals
against three key standards – accessibility, quality
and quantity. The quality element of this is based on
the Council’s updated Open Space Audit (2018) and
The Council has now made the scores of its Open
Space Audit available online
(https://westdunbarton.maps.arcgis.com/apps/webap
pviewer/index.html?id=fe102759a63e4dfbb5251b214

Page 9

the guidance notes that a contribution will be required
to upgrade off-site infrastructure where it is below a
threshold score. The Open Space Audit is not public
and the scores are therefore not available. HFS is
concerned that without sharing the evidence, there is
a risk that the Council are not complying with the tests
set out in Planning Circular 3/2012 if there is not full
disclosure when sums are being suggested. 
It is also understood that under the requirements of
the Planning (Scotland) Act 2019 that an Open Space
Strategy must contain an audit of existing Open
Space provision and an assessment of current and
future requirements. East Ayrshire have produced
Green Infrastructure/Open Space Standards
Supplementary Guidance which scores open space
within settlements. A further Council and East
Ayrshire Leisure publication titled Green Infrastructure
and Green Network Strategy Volume 2 then provides
a more detailed qualitative assessment and lists
specific upgrades that are required to specific parks. 
The general direction the Scottish Government
appear to be heading is the prioritisation of brownfield
land. As such, there will likely be a much higher
dependency on brownfield and higher density
development. This being the case, it is likely true that
there will be insufficient land to meet the housing
need if Open Space requirements are not sufficiently
flexible, and evidence of their requirement is
extremely robust. The rigidity of Open Space
requirements and their potential to hinder brownfield
00f058a) and an information note has been added as
an appendix to the Supplementary Guidance. An
updated audit will be undertaken as part of the next
Local Development Plan (LDP3) process. 
The Local Development Plan (LDP2) and this
Supplementary Guidance were prepared under the
provisions of the Planning (Scotland) Act 2006. The
approaches taken by other local authorities are not
binding on West Dunbartonshire Council, but the
Council will continue to investigate and be informed
by best/good practice elsewhere. 
West Dunbartonshire Council have always prioritised
the development of brownfield land and encourage
higher density in urban locations. It is considered
important for provision and consistency that open
space standards are set. The Supplementary
Guidance provides flexibility in allowing a financial
contribution towards the green network to be provided
if sufficient provision cannot be made on site.

Page 10

development from delivering the volume of homes
NPF4 says is required needs to be reviewed. It is also
important to note that brownfield-only development is
unlikely to deliver the volume of homes required, as
well as the Open Space requirements being sought.
General Developer Contributions
The draft SG states:
“The Council will publish a schedule of general and
specific projects that developer contributions will be
used towards. This will be updated annually.” 
This raises significant concerns, and risks affecting
the viability of sites. The presumption appears to be
that developer contributions may not be ring-fenced to
deal with impact of a specific development. This point
requires clarification. 
Any amendment to the contributions required with
regards to Open Space must be informed by an Open
Space Audit. 
It is suggested that a joined-up assessment of
housing need and Open Space requirement be
undertaken, which would lead to the Council to
identifying what is needed and where, and,
accordingly, would necessitate a review of the
allocated land. 
As noted above, any mechanism which would seek to
restrict the supply of deliverable land should be
resisted. It is vital that the housing crisis is addressed,
West Dunbartonshire Council Planning Committee,
approved the process to report and allocate
developer contributions received through the planning
system on 8 June 2022. These are available to view
at https://www.west-
dunbarton.gov.uk/council/strategies-plans-and-
policies/local-development-planning/other-guidance-
and-information/
The allocations document sets out that developer
contributions received will be allocated based on:
proximity to the site the allocation has been received
from; deliverability of the project; and eligible project
types, with some specific projects identified. Through
these criteria, the Council can link projects to deal
with the impact of a specific development. 
Changes to the allocation of land would be a matter
for the next Local Development Plan,

Page 11

and that placemaking policies are suitably adaptable
to factor in viability matters.
Retention Period for Funds
The draft SG seeks a 10-year time period for the
retention of funds. 
HFS objects to this proposed provision on the basis
that a period of 10+ years is excessive. If a
contribution can’t be spent within a shorter timescale
(e.g., 5 years), then it is questionable whether it was
appropriate in the first place and if it meets the
requirements of Planning Circular 3/2012.
It is considered that this retention period is
reasonable considering development timelines for
housing sites or the subsequent delivery of
associated green infrastructure projects. Planning
Circular 3/2012 does not specify a reasonable
timeframe, it therefore sits with the planning authority
to fix one that is reasonable. It is agreed that projects,
associated with a given development, should
delivered before this trigger is met.
NatureScot Overall support this Guidance and appreciate West
Dunbartonshire’s continued commitment to green
networks and green infrastructure. In particular, 
support the strategy of Local Development Plan 2
which underpins the guidance and which ‘seeks to
safeguard the existing green network, and to ensure
new development enhances and expands it by
improving existing green infrastructure assets, the
connections between them and by creating new multi-
functional green and open spaces’ (page 4). We
commend you on being awarded the ‘Building for
Nature Award’ for LDP2, recognising the whole
lifecycle approach to green infrastructure from design,
construction to sustainable management. 
They also support the identified purpose of the
Guidance as outlined on page 3 : ‘to define the green
network in West Dunbartonshire and identify its
assets and opportunities; outline the principles for
embedding the green network at the heart of new
This support is welcomed.

Page 12

development using a green infrastructure first
approach; define open space standards that will be
required of new development and how these
standards will be achieved; and describe how
developer contributions for green infrastructure
associated with new developments will be calculated. 
They acknowledge the recognition given to the role of
the planning system as a key mechanism for
delivering the green network and the role of green
network in delivering outcomes, particularly with
regard to improving health and well-being, meeting
climate change targets, placemaking and securing
positive effects for biodiversity (page 5). 
Part 2 – Green infrastructure delivery in new
development
They  support the requirements for development
proposals set out on page 7, for safeguarding,
enhancing and expanding the green network and
green infrastructure. The requirements encompass
enhancing the functionality and biodiversity value of
existing assets, utilising the site appraisal and design
process to identify opportunities to enhance the value
of existing assets. They welcome the value attributed
to existing assets and consider that this will also help
deliver positive effects for biodiversity. 
Green infrastructure functions (page 7)
Welcome the focus given to the integration of the
green infrastructure functions of water management,
habitat enhancement, access and open space within

Page 13

the design and layout of development as part of the
green infrastructure first approach, ensuring a whole
life approach to green infrastructure provision and
which also links and contributes to the wider green
network. 
Overall, they consider the document to be clear and
well presented, providing useful advice to developers,
including the Developer’s Flowchart, the Green
Infrastructure Checklist and Developer Contribution
Example, contained in the appendices.
Persimmon
Homes
The principle of setting out on and off-site
requirements is welcomed.
This support is welcomed.
Based on the 2011 Census the average household
occupancy within West Dunbartonshire is 2.15 people
per household. This data should be used to calculate
the open space requirement and potential contribution
rather than extrapolated data based on the Scottish
Household Survey. The Census data is an accurate
snapshot in time.
The open space standard per person, and ratio of
household size to dwelling size is established in the
Local Development Plan (LDP2), which has been
through examination. The use of house sizes in
specific developments rather than average household
occupancy is considered to provide a more accurate
open space requirement. No change is required in
this regard.
The draft guidance makes reference to situations
where a developer contribution towards off-site
improvements may be sought. Whilst the principle of
this is supported there should be reference to hybrid
scenarios where a combination of off and on-site
provision/improvements may be appropriate. 
It is agreed that a hybrid approach may be acceptable
where on-site provision cannot be met in full, as
indicated by the Developer’s Flowchart, Appendix 1;
and Appendix 3, examples 5 and 5. Further
clarification of this has been added to the guidance
(page 15. However the requirement, and preference,
for on-site provision with a limited number of
exceptions is retained.
The draft guidance seeks to assess proposals against
three key standards – accessibility, quality and
quantity. The quality element of this is based on the
The Council has now made the scores of its 2018
Open Space Audit available online
(https://westdunbarton.maps.arcgis.com/apps/webap

Page 14

Council’s Open Space Audit that was updated in 2018
and the guidance notes that a contribution will be
required to upgrade off-site infrastructure where it is
below a threshold score. The open space audit is not
public and the scores are therefore not available. We
are concerned that without sharing the evidence,
there is a risk that the Council are not complying with
the tests set out in Circular 3/2012 if there is not full
disclosure when sums are being suggested. The
scale and kind test is of most relevance. It is also
understood that under the requirements of the
Planning (Scotland) Act 2019 that an open space
strategy must contain an audit of existing open space
provision and an assessment of current and future
requirements. East Ayrshire have produced Green
Infrastructure/Open Space Standards supplementary
guidance which scores open space within
settlements. A further Council and East Ayrshire
Leisure publication titled Green Infrastructure and
Green Network Strategy Volume 2 then provides a
more detailed qualitative assessment and lists
specific upgrades that are required to specific parks.
pviewer/index.html?id=fe102759a63e4dfbb5251b214
00f058a) and an information note has been added as
an appendix to the Supplementary Guidance. 
The Local Development Plan (LDP2) and this
Supplementary Guidance were prepared under the
provisions of the Planning (Scotland) Act 2006. The
approaches taken by other local authorities are not
binding on West Dunbartonshire Council, but the
Council will continue to investigate and be informed
by best/good practice elsewhere. 
Scottish
Government
Scottish Planning Policy (SPP) states
at paragraph 232: “In the design of
green infrastructure, consideration
should be given to the qualities of
successful places.” We suggest the SG
should make reference to those
qualities, which are set out in
paragraphs 41-46 of SPP. 
Agreed, reference to the six qualities of successful
places has been added (page 5).

Page 15

In part 4, it is stated that contributions
for green infrastructure will be sought in
line with the circumstances set out in
Policy GI4 of the LDP, and lists those
four circumstances. 
Two of those circumstances are: 
Where a development site is
accessible to open spaces but those
spaces are of a poor quality; and 
Where development sites are
accessible to good quality open spaces
but a contribution to the green network
is required to enhance its provision to
the Central Scotland Green Network. 
It is not clear in the draft SG
(particularly the flowchart in Appendix
1) whether developer contributions
under Policy GI4 will/may be required
in the above two circumstances even if
the development includes sufficient
open space (meeting the relevant
quality and quantity standard) within
the development site. The flowchart in
Appendix 1 implies that such
contributions would be required in such
instances, but Example 1 in Appendix 3
does not. This should be clarified. 
Footnotes have been added to the flowchart to clarify
that: if a residential development meets the quantity
standard through on-site provision, no financial
contribution to the green network is required; and that
an equipped play area is required on a site of 50 units
or more, if there is not an equipped play area within
250m of the site (this highlights a requirement already
included in Part 3 of the guidance).
Page 10, ‘Accessibility standard’
It is stated that the accessibility standard is:
“Everyone will live within a 250m walk of a 0.2 ha
usable and good quality greenspace.” If ‘good quality’
Agreed, a change has been made to clarify this (page
12).

Page 16

is intended to mean that the space meets the ‘quality
standard’ i.e. meets or exceeds the threshold score
set out in Table 2, this should be made clear. 
Pages 10-11, ‘Quality standard’
The draft SG on pages 10-11 refers to a ‘Quality
standard’, and states that the quality of an open
space is an assessment-derived score based on work
undertaken as part of the Open Space Audit carried
out in 2016 and updated in 2018 to reflect changes to
some spaces. 
It is stated that “The quality standard is: All publicly
usable open spaces should meet or exceed the
threshold score set out in Table 2”. Table 2 includes
different “Quality standard threshold scores”
expressed as a percentage for different types of open
spaces. 
However, it is not clear in the draft SG how to
identify/calculate the score of existing or proposed
open spaces, to determine whether they meet or
exceed the threshold score set out in Table 2. This
should be made clear. 
The Council has now made the scores of its 2018
Open Space Audit available online
(https://westdunbarton.maps.arcgis.com/apps/webap
pviewer/index.html?id=fe102759a63e4dfbb5251b214
00f058a) and an information note has been added as
an appendix to the Supplementary Guidance. 
Page 11 ‘Quantity standard’
There is a formatting error on page 11 below the
heading ‘Quantity standard’ – it is assumed that the
text in the box should be below the text in the first
paragraph. 
This formatting error has been corrected.
Page 11 ‘Quantity standard’
It is stated that “Development sites should provide
this quantity of open space [30 m2 per person] as a
minimum where the accessibility standard identifies a
The quantity standard has been amended to clarify
this point.

Page 17

need based on an analysis of open space provision
for the wider area”. 
However this implies that the open space is always
required to be provided within the development site,
which seems to contradict the text in the box, which
refers to “access to” the open space. It also seems to
contradict the text under the heading ‘Accessibility
standard’ which states that the site appraisal/
assessment will inform what type of space, if any is
required within the development or if a financial
contribution to an existing space is more appropriate. 
These apparent contradictions should be addressed. 
Appendix 3: Developer contributions examples 
It would be useful to expand/revise the examples to
show exactly how they follow the process shown in
the flowchart in Appendix 1 (e.g. the application of the
questions regarding the accessibility and quality
standards). 
A Developer’s flowchart analysis has been added to
each example.
Appendix 3: Developer contributions examples –
Example 1 
It would be useful to expand the first example to show
how the ‘site appraisal’ method would be used to
determine the form of open space required to be
provided. 
The purpose of Example 1 is primarily to provide a
simple arithmetic example of calculating the open
space contribution based on the quantity standard.
However, additional information has been added to
explain that the calculated level of open space would
be required on-site in this example as the site is not
within 250m walking distance of an usable open
space.
Appendix 3: Developer contributions examples –
Example 3 
This typo has been corrected to amend the reference
to 250m.

Page 18

The example refers to a financial contribution to
upgrade play equipment in a park less than 400m
walking distance. It is not clear whether/how this is
considered acceptable in relation to the ‘accessibility
standard’ which refers to a 250m walking distance.
This should be clarified. 
Appendix 3: Developer contributions examples –
Example 6, and explanation of Quality standard on
pages 10-11 
The example states that “the first step is to see if it
meets the accessibility standard i.e. is it within 250m
of a 0.2ha amenity greenspace, play space or
natural/semi-natural greenspace?” (emphasis added). 
The example then refers to a “park” within 250m of
the site. It states that “the play area is below the 50%
threshold and requires investment”. However, the
specified ‘Quality standard threshold score’ for ‘Parks
and gardens’ in Table 2 is 69%. It is not clear
whether/why there has to be a play space scoring
over 50% within 250m of the development site, if the
park scores at least 69%. This should be made clear.
Adding an explanation as to how the scoring system
works may help the reader to understand this. 
The appraisal shows that a play area within walking
distance of the site is below the quality threshold,
meaning that it is a valid and eligible project for
developer contribution funding. Additional wording
has been added to provide clarification.
There is no mention of historic environment assets so
suggest adding the following: 
On page 19, ‘Appendix 2: Green infrastructure
checklist’ consideration should be given to an
additional check box that states “identifies historic
environment assets and recognises their significance
in the site design”, within the ‘Site Analysis’ flowchart
Agreed, this change has been made.

Page 19

blue box, under the ‘Site Appraisal’ section. This
would ensure the consideration of gardens and
designed landscapes, scheduled monuments and
The Antonine Wall (FRE) World Heritage Site and
recognise their contribution to green infrastructure.
RSPB
Scotland
. In general,  the guidance is welcomed and the onus
it puts on developers to protect and enhance the
green network and green infrastructure. 
Noted
Page 8 Green infrastructure function: habitat
enhancement
1. Some of the wording of the document might be
interpreted as suggesting that biodiversity protection
and enhancement should be identified and
considered, rather than actually delivered. It is
recommended that this wording be strengthened:
Replace:
“Proposals for new development should consider
whether the site can protect or enhance habitats to
safeguard existing networks or deliver new habitat to
connect fragmented networks.”
With
‘Proposals for new development must protect or
enhance habitats, to safeguard existing networks or
deliver new habitat to connect fragmented networks.’
This would still be valid even when there are no
significant habitat features on site, as the
development can progress whilst they remain
protected. 
A change has been made to ‘Proposals for new
development must consider whether the site….’.
The intention of this part of the supplementary
guidance is to show how the requirement of Policy
CP2e can be met. Policy CP2e does include the
stronger formulation “Development proposals must
protect, restore and enhance biodiversity habitat
networks, and environmental quality within and linking
to the site” and this guidance shows that
consideration of how this can happen as informed by
appropriate surveys. 
2. The document suggests that the Green Network
Blueprint developed by the Glasgow and Clyde Valley
Green Network Partnership should be used to identify
Agreed. This change has been made.

Page 20

whether the site can protect or enhance habitats to
safeguard existing networks or deliver new habitat to
connect fragmented networks. The Blueprint does not
provide sufficient detail to do this and it is
recommended that the following be reworded:
Replace:
“This work should be guided by the Green Network
Blueprint developed by the Glasgow and Clyde Valley
Green Network Partnership, which details existing
habitats critical to the network and where connections
should be made to improve habitat connectivity.”
With
‘This should be informed by appropriate surveys and
assessment. The Green Network Blueprint developed
by the Glasgow and Clyde Valley Green Network
Partnership can provide strategic guidance on
habitats critical to the wider network and where
connections should be made to improve habitat
connectivity.’
Page 9 Table 1
They are concerned that the Matrix suggests that the
provision towards habitat networks is dependent on
whether there is a need or opportunity. It is  felt that
this could lead to confusion, particularly if the
intention of the guidance is that sites should be
enhanced for biodiversity, in which case a ‘need’
should already be established. It is unclear when a
site ‘needs’ to be enhanced and when does it not.
The wording should be amended to add clarity to this.
The matrix has been amended to indicate that habitat
provision/enhancement is required on residential
development sites of 10 or more houses.
Scottish
Environment 
The commitment to a green infrastructure first
approach to development is supported. Welcome the
measures therein to safeguard, enhance and expand
It is noted that Scottish Environmental Protection
Agency has not specific comments on this document
and the support for the green infrastructure first

Page 21

Protection
Agency
existing networks and the connections between them
and support multi-functionality (e.g. by integrating
water management measures such as SuDS).
approach as well as the measures to safeguard,
enhance and expand existing networks are
welcomed.
Sportscotland The guidance and policies referenced within appear
to generally support, protect and improve green
space that (alongside other functions) provide
opportunities to engage in physical activity, sport and
recreation. 
The procedural approach towards green space
provision appears logical. In relation to outdoor sports
facilities specifically – such as pitches, playing fields,
golf courses, bowling greens etc – it‘s not clear how
demand for these will be accounted for when
assessing and providing for green space in new
developments or calculations for developer
contributions. It is understood that the Open Space
Audit 2016 (update 2018) will inform new green space
typology, provision and investment – based on need
and demand. They have not been able to access this
document. The previous Open Space Audit 2011,
which is available online, excluded some spaces for
sport (pitches) in the audit process. It’s not clear
whether this is the case in the revised document. The
planning and provision of places for sport and
recreation should be based on an up-to-date audit of
facilities alongside a strategic assessment of demand
and need for them. 
The 2016 Open Space Audit, like the 2011 audit, did
not include sports pitches (MUGAs were assessed).
Sports pitches are an eligible project for developer
contribution funding, although it is accepted that an
up to date sports pitch strategy would be beneficial in
allocating contributions towards these resources.
Strathclyde
partnership
for Transport
No comments Noted

Page 22

Local
resident  First of all I shall make a comment on the
introduction. 
There are references here to the outstanding natural
environment being shaped by the area’s history,
boasting of our parks, woodland areas, designed
landscapes at Overtoun House, Kilpatrick Hills etc.
However these areas are largely out of bounds to the
local horse riders for various reasons.
Our area as so many others has been shaped by the
use of horses, without them there would be no
industry, no transport, nothing. Without horses
nothing was possible but yet today this has been
forgotten, our canal towpaths are dangerous, our
surfaces are unsuitable and our roads are dangerous.
We owe horses everything but there is seemingly no
place for them in our area, they have been forgotten. 
This council is laying down cobbles on our high
streets but is it even known why there were cobbled
streets in the first place - to stop the cart horses feet
slipping, these horses helped our industries flourish
and made transport possible. They are our heritage
and there should be a special place for our horses
within West Dunbartonshire. 
Look at places like London, public riding arenas in the
parks, bridleways in the parks what does West
Dunbartonshire have? Around half a mile of actual
designated bridleway if that (Auchnacraig estate) and
no parking access for horseboxes so we cant even
Whilst the comments support the benefits of
increasing facilities for horses and horse riding,
unfortunately the guidance document is not
considered to be the appropriate document for the
promotion of horse-riding and horse-riding facilities
that the respondent is seeking.

Page 23

get to use the tiny part of bridleway provided. Our hills
are gated and have unsuitable surfaces, steps and
unsuitable narrow bridges are everywhere, our riding
areas are built upon or inaccessible and to top it all in
our official documents such as this horses are not
even mentioned. 
There are many horse owners in the area, several
livery and private yards. Horse owners have immense
spending power, the equestrian industry is a huge
tourist industry and recreational industry not to
mention one of the most green forms of travel
possible, horses get people out of their houses and
into the outdoors and fresh air, they help with mental
health , it is a scientific fact that being around them
lowers your heart rate. 
We must promote horses and equestrian activity in
our area. We have great places to ride we just need
access to them before its too late and you build
everywhere. Horses can elevate our area from the
socially and economically deprived area it currently is. 
Most if not all horse riders have been involved in a
road traffic incident of some sort, I know I have, we
take our lives in our hands taking our horses out of
their fields and this council does nothing so I hope
you will take on board my comments and we can see
some changes being made.
Benefits of green networks and green infrastructure 
The following are listed as a benefit 
It is acknowledged that horseriding is another
recreational activity and sport that can benefit from
improved access to green infrastructure, however no

Page 24

Off road active travel and recreation routes 
Locations for sport and recreation 
It goes on to say they are made more valuable when
they are multi functional and connected providing off
road routes 
This should be expanded to include reference to
horse related activities and access – not all sport and
recreation is football, walking or cycling. 
Horse riding is much more inclusive than many sports
as men and women compete on equal terms and
together, age and ability is no barrier either. Horses
can allow freedom of movement to those who cannot
have this on their own and horse riding makes places
more accessible than with wheelchairs.
single sport is singled out in this section, so no
change should be made in this regard. 
These comments are also relevant to the Creating
Places Supplementary Guidance and the respondent
has agreed they may be addressed in relation to that
consultation.
When paths are for multi users thought should be
given to all potential users and suitable surfaces
installed, designated bridleways could be installed -
these could be side by side with a “horse lane” or
suitable parking provided for horseboxes. Less use of
steps to allow better access for horses 
These comments are more relevant to the Creating
Places Supplementary Guidance and the respondent
has agreed they may be addressed in relation to that
consultation.
The access priorities mentioned currently have no
mention of equestrian access and access to many of
these places is impossible or limited at best. 
Kilpatrick Hills - gated and keys needed – when I
have enquired before about getting a key, yes I was
given it but I was originally told I had to hand the key
back in after my ride. I did manage to be allowed to
These specific issues raised in relation to equestrian
access are outwith the scope of this consultation.
They have been passed to the relevant service.

Page 25

keep hold of the key however for most people with
less connections than I perhaps have mean the hills
are a no go area. On a rare nice day a horse rider can
not then try to get a key last minute especially when
this is likely to be a weekend, evening or at short
notice so in effect the hills are inaccessible. 
Surfaces of the Kilpatrick Hill paths. The lower
reaches are okay so if you got a key th, however if
you get as far as the Humphrey then the surfaces are
mostly unsuitable unless you try to stick to the grass
edges which is seemingly frowned upon. Rough stone
tracks are not suitable for the modern horse so im not
sure why these surfaces are so widely used. 
The John Muir Way is more or less impassable for
horse riders 
All licensed premises in the area should be contacted
for their opinions on horse access and should be
automatically given keys to gates areas each yr
without fail (if the gate system remains in place) eg
saltings, bowling, overtoun, auchnacraig, forestry
commission (ok hills) 
Bowling harbour - gated in evening and the other
route is unsuitably surfaced. Some paths are too
narrow and unsafe. Tarmacking paths is not always
the answer as more naturalised routes can be more
beneficial to use as a horse rider. Maintenance of all
areas needs looked at, shrubs cut back, fallen trees
removed, paths kept open and usable etc

Page 26

Forth and Clyde canal whilst the surface is suitable is
plagued by illegal quad and motor bikers making it a
volatile route at certain times. Nothing is ever done
about these bikes so although the route along canal
path taking in the saltings and bowling harbour and
beyond to Milton is well surfaced and suitable it is
sometimes unusable due to the dangers. There are
off roads routes running alongside that if maintained
properly (old railway line) could provide a safer option
or if the quad bike situation was policed it could make
the canal path route safer and more suitable.
Unsuitable bridges in certain parts - ie behind Hillview
nursing home – some of our rides are urban and
involve industrial estates as these are safe places in
evenings and weekends but are not often thought
about as such but again we need access as
sometimes these industrial areas have the most
green spaces or provide access to parks. 
Dalmuir park – no horsebox parking, no bridleway,
unsuitable bridges, limited access and unsuitable
surface at the path between park and golf course 
Levengrove park - no horsebox parking, no bridleway 
The Saltings parking is closed off to those with
horseboxes so only walkers and cyclists can use it.
This needs addressed as why have off road routes
when horse riders are effectively banned from its use
if we cant get there to ride. Bridges making shorter
circular routes not in use and seemingly no plans to

Page 27

rectify. Some bridges unsuitable for horses (wooden
one with chevrons and no other crossing next to it is
one example). 
Auchnacraig estate - no suitable parking as locked
and gated cars can get in but not horseboxes.
Unsuitable and broken decking used to cover boggy
areas. Lack of signposting for out of town riders
showing routes to other areas. 
Horse riders have no safe route to Hardgate and the
hills, there is no horse crossing anywhere, there are
no off road routes and cut off by the A82. 
Overtoun estate – gated and locked and steps
everywhere making most of it inaccessible to horse
riders. 
Exxon development - no equestrian access thought of
at all - this could be like mugdock country park but no
nothing about equestrian access anywhere. 
Carless site - excellent opportunity here to link up
many local routes from old Kilpatrick, bowling and
Clydebank - again no mention of equestrian
usage/access 
Hardgate knowes – no equestrian parking or access
as far as im aware but not a place I ride as again I
cant get there so assume no one else can either. 
Whilst  applaud the plans to conserve routes and the
current infrastructure mentioned under KH1, G1I,
The approach set out in the Supplementary Guidance
is based on the Local Development Plan, and

Page 28

ENV1, ENV2, ENV3, ENV4, ENV5, ENV6 and CON3 
need to do more and go further in regards to
enhancing and expanding the green network.
complements and is proportionate to that approach. It
would not be appropriate for the Supplementary
Guidance to go beyond what is included in the Local
Development Plan.
Green infrastructure function –  agree with this which
is mentioned on p8 however there is no mention of
horse access, equestrian facilities or connecting
currently used equestrian routes, do not assume that
because you don’t see horses or know nothing of
them that they are not present and using the area.
The section on access networks relates to all forms
on non-motorised access, whilst not identifying any
specific type. Therefore a specific reference to horse
access, equestrian facilities etc is not considered
appropriate. Reference to multi-user paths have been
added to the guidance.
Contributions could be used more effectively and
certainly should include equestrian access facilities.
You need to be aware of the local equestrian sites
and premises and plan accordingly. The people living
in new homes see horses as a local amenity and
children love to see them riding past or enjoy going to
see them at their fields but if you do not sort out the
correct access and facilities this will be lost.
Contributions made could be used to fund
improvements or to include equestrian access.
Where appropriate the Council will seek to develop or
require multi-user paths that would also be
appropriate for equestrian use. Reference to multi-
user paths have been added to the guidance.
Funding  is the reason our equestrian facilities are
sub standard so this is a chance to rectify it.
Equestrian facilities, as part of multi-user green
network projects, would be an eligible use of
developer contribution funding. However, this
document does not set out eligible projects.
The contributions from developers needs to be
extended to include non residential developments as
these are often on sites used by horse riders and are
the bigger areas giving more opportunity to get
funding for more appropriate paths etc ….Industrial
estates are useful and safe hacking areas at
weekends and evenings and winter nights.
The guidance does not seek developer contributions
from commercial or non-residential development,
where the focus is the provision of green
infrastructure within the development itself. This is
because this type of development is not considered to
increase user demand for the green network outwith
the development site in the same way that residential
development does.

Page 29

The money being returned after 10 yrs if not used is
madness. This needs removed there cannot be some
usage to which the funding could be put – pathway
improvements for one to allow equestrian access –
the bridges at Saltings is another example to which it
could be put. Money should be used not returned.
It is considered that this retention period is
reasonable considering development timelines for
housing sites or the subsequent delivery of
associated green infrastructure projects. The
inclusion of a retention period will also encourage the
Council to make use of funds. Planning Circular
3/2012 does not specify a reasonable timeframe, it
therefore sits with the planning authority to fix one
that is reasonable. It is agreed that projects should be
delivered as associated with a given development
before this trigger is met.
Horses and biodiversity go hand in hand, you can
look at my field and see what the nature is like there.
Horses are not a barrier to nature and wildlife habitats
nor are they a nuisance not when proper access and
riding routes are provided to us. In particular it would
eradicate any perceived nuisance aspects of horse
riding in the area – riders on pavements in Hardgate –
they have no horse crossing nor proper access to
safe off road riding from their yards at Hardgate near
roundabout to the bridleway at Cochno. This could be
addressed by use of developer funding.
The document does not suggest that horses are a
barrier to nature/habitats, nor that they are a
nuisance. 
The purpose of this document is not to set out the
specific projects that developer contributions will be
spent on. However the comments made will be taken
into account when future projects are being scoped
out. 
Maintenance or stewardship is also an issue – grass
needs cut, paths cut into it is a useful feature for
horse access (this does take place at the small park
near golden jubilee hospital and its very useful, one of
the few things that actually helps horse access, there
is also parking here for horseboxes, and there is a 
need more of this elsewhere). 
Verges cut down allows horses to be off the main
parts of track in light of there not being an actual
The guidance includes a section on green
infrastructure stewardship, requiring that maintenance
arrangements are put in place for green infrastructure
associated with new development.

Page 30

horse track installed. Wide verges at side of roads
gets us off the roads too. This enhances safety for all
road and path users and also reduces hay fever
issues which does affect horses as well as people. 
Bridges need fixed or made more suitable (paths can
be created under or beside them in some cases) and
rubbish in particular glass needs removed more
regularly.
There is funding for off road access available from
British Horse Society and horse riders  if they could
get better off road access but funds need diverted to
some equestrian usage so please include it within this
document and future plans.
The supplementary guidance does not to set out
specifics on the types of projects that developer
contributions will be spent on. This information is set
out in the Developer Contributions documents
available on https://www.west-
dunbarton.gov.uk/council/strategies-plans-and-
policies/local-development-planning/other-guidance-
and-information/
Developer payments should be local to the
development and not used out of the area. They
should be of benefit to the people living in and around
that area and should only be used for some kind of
green space or access purpose and percentages
could be split up so its not all going to playparks, it
needs to be equal so it does not just benefit one
group of people. Right now horse riders are a
forgotten part of this so some money should be spent
on that initially to balance things up. Where people
can walk, horses can too, you just need to include the
horse riding aspect, they are not mutually exclusive. 
Where the money should be spent should be more
visible and perhaps up for discussion, more frequent
The Council has approved separate documents
explaining how developer contributions will be
allocated, monitored and reported https://www.west-
dunbarton.gov.uk/council/strategies-plans-and-
policies/local-development-planning/other-guidance-
and-information/

Page 31

updates should be made, annually is not enough. I
can certainly put forward some suggestions that
would immediately assist horse riders in the area and
im willing to be part of any projects or discussions on
this perhaps with the access officer or greenspace
staff. It cant and shouldn’t all go to playparks and
community gardens.
On a wider note developers need to be stopped
pulling down the mature trees on site and replacing
them with tiny saplings, this doesn’t help with climate
change in any way and happens all the time. In one
example a block of flats,  over 300 trees were cut
down and they have been replaced with small shrubs
about 10 of them. These trees were all mature with
many in excess of 50 yrs old. This must be stopped,
developers can keep existing trees around
boundaries which makes the whole site nicer for
residents and better for wildlife but time and time
again everything is cleared and a blank site is the
starting point.The keeping of mature trees must be
enforced even the ones which seemingly are not in
best of health, even an unhealthy tree can live for
hundreds of yrs. I have 2 ancient willows on my
rented field and both grow almost horizontally, they
are still alive, no danger of falling over and are a
beautiful feature. 
Existing trees onsite must be kept and developers
must adhere to this. Climate change is important so
take actions to prevent it worsening.
These comments are more relevant to the Creating
Places Supplementary Guidance and the respondent
has agreed they may be addressed in relation to that
consultation. 
The Council is also intending to prepare planning
guidance (non-statutory) on trees which would cover
these matters.
Balconies are not an acceptable outdoor space,
gardens should be compulsory on all developments
These comments are more relevant to the Creating
Places Supplementary Guidance and the respondent

Page 32

even if it means less buildings on site (no bad thing).
Who uses their balconies,  the ones on the main road
in Clydebank face on to a busy road, who is going to
sit out there with all the fumes from the road. Gardens
are a must not unusable balconies. Do remember that
this council has covered in most of these balconies in
recent years for safety reasons so don’t start putting
them in again instead of actual gardens.
has agreed they may be addressed in relation to that
consultation.