Network Rail (CLDP063c, CLDP063d) Muckhart Community Council (CLDP174m, CLDP174n) Alloa Community Council (CLDP163d) sportscotland (CLDP083c) Mr & Mrs Tasker (CLDP037) Scottish Government (CLDP070b)
3. Supporting Documents
CD001 Scottish Planning Policy (February 2010) (Paragraphs 176 & 150) [attached] CD047 Clackmannanshire Council Open Space Strategy - Consultation Draft (November 2013) CD049d Clackmannanshire Council Core Paths Plan (September 2010) CD063 Clackmannanshire Council Local Transport Strategy 2009 - 2014 SD37 sportscotland (CLDP083c) - Covering Letter
Page 2 of 7 Issue 22 Transport Development Plan reference: Paragraph 5.53 (Page 46) Paragraph 5.54 (Page 46) Policy SC11 - Transport Networks (Page 51) Policy SC12 - Development Proposals - Access and Transport Requirements (Page 51) Opportunity T10 - Clackmannan Rail Halt (Page 131) Reporter: Body or person(s) submitting a representation raising the issue (including reference number):
Network Rail (CLDP063c, CLDP063d) Muckhart Community Council (CLDP174m, CLDP174n) Alloa Community Council (CLDP163d) sportscotland (CLDP083c) Mr & Mrs Tasker (CLDP037) Scottish Government (CLDP070b)
Provision of the development plan to which the issue relates:
Planning Authoritys summary of the representation(s):
Network Rail (CLDP063c) acknowledge Clackmannanshire Council's aspiration for rail halts at Clackmannan and Cambus and the recognition by the Local Development Plan (LDP) that Transport Scotland have no current plans for such facilities.
The LDP also states that the potential to extend passenger and freight links from Alloa to Rosyth will be explored with neighbouring authorities and key stakeholders. As one of the key stakeholders, Network Rail would welcome any further discussions in terms of the above aspirations and aims at the appropriate stages.
However, it must also be noted that paragraph 176 of Scottish Planning Policy (CD001) is clear that new stations must be very carefully considered and states that "making best use of current rail services and stations to achieve optimum utilisation of the existing rail network should be considered before new services or stations are considered. The case for a new station will be considered where the needs of local communities, workers or visitors are sufficient to generate a high level of demand, and it will be served by feeder rather than existing inter-urban services".
Muckhart Community Council (CLDP174m) welcome the moves to encourage active transport, particularly the plan to extend the Devon Way to Rumbling Bridge.
Network Rail (CLDP063d) supports Policy SC11 and in particular the Page 3 of 7 recognition that development proposals that are likely to create or exacerbate deficiencies in the network and facilities will be expected to provide contributions or overcome deficiencies.
Policy SC11 also supports new freight operations adjacent to the rail line. As one of the key stakeholders, Network Rail would welcome any further discussions with the above aspirations and aims at the appropriate stages.
Policy SC11 should also acknowledge that there are a number of level crossings on the railway within the Clackmannanshire Council area. The safety, reliability and efficiency of the rail infrastructure is of paramount importance to Network Rail and we cannot agree to any proposals which jeopardise these requirements. We are committed to reducing the risk at level crossings where reasonably practicable and will seek to close and/or divert crossings or enhance their safety through the provision of improved safety features or equipment. We will work with local councils to take a holistic approach to reducing level crossing risk and will encourage planning authorities to co-operate in securing level crossing closures or improvements in connection with new developments. Only in exceptional circumstances will we permit new crossings to be introduced onto the network.
Muckhart Community Council (CLDP174n) believes that these Policies are too limited in their scope and will not lead to the development of a low carbon economy.
Alloa Community Council (CLDP163d) feel that as part of the development plan, paths and walks should be encouraged. This would also include making better use of the sea/river front. Alloa was a port in the past. In the past there has been talk of using hydrofoil boats to commute to Leith/Edinburgh and this should be considered, or at the least the option left open.
sportscotland (CLDP083c) requests an amendment to the fourth bullet of Policy SC12 in order to ensure that the policy accords with the provisions of SPP paragraph 150 (CD001) which states that planning authorities should consider access issues and should protect core and other important routes and access rights when preparing development plans and making decisions on planning applications.
Mr & Mrs Tasker (CLDP037) Object to Proposal T10, Clackmannan Rail Halt. It would spoil the view so trees would need to be planted around the car park to screen it. Parking in the streets near the rail halt would need to be reserved for residents to avoid parking conflicts with users of the station.
Scottish Government (CLDP070b) Whilst it is recognised that there are no firm proposals for this station in the plan, it should be recognised that the Scottish Ministers have no current plans for a station at this location. As such, any reference to the station should remain aspirational and no funding commitment should be assumed. The Scottish Government does not require land to be retained in the Plan for the provision of this, or other stations.
Page 4 of 7 The responsibility to demonstrate the need for a new station will continue to lie with the relevant promoter, for example, Local Authorities, Regional Transport Partnerships or developers.
Any proposal for a station would have to be shown to be an appropriate transport solution, through the completion of a properly complete STAG appraisal, which would need to consider any station in the context of alternative solutions that may be developed to address recognised transport issues.
It would also have to be shown to be a viable financial and technical solution, requiring the consideration of such factors as the capital costs of building a station and any associated infrastructure, the ongoing costs that may be associated with operating subsidies, the potential need for additional rolling stock and the impacts of stations on wider rail timetabling.
In terms of this particular proposal, it must also be recognised that this may have the potential to impact on the operation of level crossings that currently exist in the Council area. It is important that Clackmannanshire Council recognise this and discuss any proposals with the appropriate agency, whether associated with a new rail station or not. Network Rail should be contacted for their information and comment, before the Local Development Plan is adopted.
Modifications sought by those submitting representations:
Network Rail (CLDP063c) request recognition of Scottish Planning Policy (CD001) in relation to making best use of existing rail network and stations. It is also worth stating within the text of the LDP that significant investment has already taken place within the area in advance of the electrification of the railway line between Stirling and Alloa which is scheduled to take place by 2018. This will lead to faster, more reliable trains which will also be quieter and cleaner.
Muckhart Community Council (CLDP174m) note that Paragraph 5.54 deals with improvements mainly in the west of Clackmannanshire and would welcome similar developments in the East Ochils. There is a need to improve the quality of the Core Path Network (CD049d) in the Muckhart area and to create a Cycle Path between the Pool and the Yetts of Muckhart and between Muckhart and Dollar along the A91.
Network Rail (CLDP063d) request the inclusion of a policy statement on level crossings and consider that LDP site assessments must take cognisance of the impact of development proposals on level crossings. Transport assessment and developer contributions policy and supplementary guidance must ensure infrastructure risks are identified and mitigation secured.
Muckhart Community Council (CLDP174n) feel there are a number of major issues not covered in this section such as the provision for alternative fuels for low or zero carbon vehicles such as electric cars and hydrogen Page 5 of 7 vehicles. Thought needs to be given to the provision of charging points for electric vehicles and fuelling stations for hydrogen vehicles, etc. Alloa Community Council (CLDP163d) state that paths and walks should be encouraged. This would also include making better use of the sea/river front. Alloa was a port in the past. In the past there has been talk of using hydrofoil boats to commute to Leith/Edinburgh and this should be considered, or at the least the option left open.
sportscotland (CLDP083c) requests that the fourth bullet of Policy SC12 is amended as follows: where the development may adversely affect or result in the permanent loss of an existing Core Path, Right of Way, or any other important route or access right.
Mr & Mrs Tasker (CLDP037) State that they "wish to lodge our rejection to the plans to build a platform...", and it is therefore considered that they object to Opportunity T10 and would wish to see it removed from the Local Development Plan.
Scottish Government (CLDP070b) Rail station proposal at Clackmannan - any reference to the station should remain aspirational and no funding commitment should be assumed. It should be recognised that the Scottish Ministers have no current plans for a station at this location.
Summary of responses (including reasons) by Planning Authority:
Network Rail's (CLDP063c) request for recognition of Scottish Planning Policy (CD001) in relation to making best use of existing rail network and stations is not favoured as it is a repetition of national policy and would add to the length of the LDP. Similarly, stating within the text of the LDP that significant investment has already taken place within the area in advance of the electrification of the railway line between Stirling and Alloa would simply be stating what has already happened. There may be merit in mentioning that the commencement of electrified services on the route is scheduled for 2018, meaning faster, more reliable, quieter and cleaner trains, although this is not really a development plan issues unless there are further infrastructure implications. No changes are therefore sought to the LDP.
Muckhart Community Council (CLDP174m) raise concerns over the quality of the Core Path Network in the Muckhart area, however the Council's Consultation Draft Open Space Strategy (November 2013) (CD047) (paragraph 7.6.6, page 60) notes that "Muckhart has good access to Core Paths, with 1 path classified as Good and the remaining classified as Fair. The cycle path routes are limited and there is scope for improvement to the cycle infrastructure.". This is reflected in the LDP through Proposals T28 and T29 for cycle friendly infrastructure in an around Muckhart. The Open Space Strategy (paragraph 6.18.5, page 45) also notes that "In respect of distribution of Core Paths, the SNH Report: 'National Overview of Core Path Plans and Path Provision' from 2011 notes that Clackmannanshire is the only authority to achieve 100% coverage of a core path within every Datazone in its area..." Page 6 of 7 and that (paragraph 6.18.6, page 45) "Clackmannanshire has a Core Path network that is over twice the length of core paths per person compared to the national average, and good distribution of Core Paths relative to the area's whole population.". No changes are therefore sought to the LDP.
It is considered that Network Rail's (CLDP063d) concerns over level crossings and their request for policy to reflect this are adequately covered, not under Policy SC11, but under Policy SC12 (page 51) where "...Proposals for development will only be supported where they are...capable of being safely and conveniently accessed." Any objections on the grounds of impact on level crossings could be considered under this Policy. In preparing the Proposed LDP, reference was made to the Local Transport Strategy (CD063) to ensure the two documents were complimentary. There is nothing in the Local Transport Strategy (CD063) about level crossings, therefore the LDP has not considered them as a separate piece of transport infrastructure. No changes are therefore sought to the LDP.
Muckhart Community Council's (CLDP174n) suggestion for the consideration of alternative fuel infrastructure was debated during the preparation of the LDP, however it was agreed that it had limited land use planning impact and that it would be addressed through commercial provision and by the Council who have already installed 5 double charging points in car parks in Alloa. No changes are therefore sought to the LDP.
Agree with Alloa Community Council (CLDP163d) that paths and walks should be encouraged and believe that the LDP and Core Paths Plan (CD049d) contribute positively to this. Proposal M02, The Shore, Alloa does identify the opportunity to create recreational access to the River Forth, providing there is no adverse impact on the nature protection area (Firth of Forth SPA). Such access could also service commercial uses, if suitable. Much of the rest of the area adjacent to the River Forth lies next to the area of special protection mentioned above, or within an industrial area, and there are therefore limited opportunities for development focussing on the Forth. Proposals will however be likely to be supported provided they accord with policy and do not have an unacceptable impact on the Firth of Forth SPA. No changes are therefore sought to the LDP.
It is considered that sportscotland's (CLDP083c) requested addition to the fourth bullet of Policy SC12 is too loosely worded and open to interpretation to be included in Policy. It is likely that any existing routes could be claimed to be important by one party, particularly those seeking to use that part of the policy to try to stop development which may be acceptable in all other respects. If there is an "access right", that is likely to be covered under other areas such as Rights of Way or legal agreements. Again, this could be interpreted as an assumed access right or historical access right and so is open to scrutiny and interpretation. No changes are therefore sought to the LDP.
Mr & Mrs Tasker (CLDP037) The principle of a rail halt at Clackmannan has already been established through the Clackmannanshire Adopted Local Plan (December 2004) (CD030). No further certainty in the opportunity can be Page 7 of 7 given until further work is done, but it is considered good Planning to highlight the possibility of a rail halt at this location as an aspiration of the Council. Detailed concerns will be addressed at the detailed design/planning application stage should the opportunity proceed. No changes are therefore sought to the LDP.
Scottish Government (CLDP070b) It was considered that by identifying this as an opportunity rather than a proposal, and stating in the text that the opportunity involved safeguarding the land, rather than delivering the rail halt, that the aspirational nature of the opportunity was made clear. Should further clarity be required through additional wording, the Reporter may be minded to request the addition of further detail.