Carmunnock Community Council Submission to Local Review Board regarding Busby Road Planning Application ref 21/00040/LOCAL


Both prior applications for this site were soundly refused by the council’s own professional Planning Officers for reasons fully endorsed by the Community Council. We have submitted comments on both previous applications. Our views on this development have not changed and we would respectfully draw the attention of LRB members to our previous comments and to our further submissions that follow below.
In this submission we will attempt to summarise as briefly as possible the strong objections of the Community Council and the local community to development on this site as evidenced by the over 100 objections which were lodged. As LRB members will be aware it is rare for a planning application such as this to generate such a strong response. We will also take issue with the evidence submitted by Certus, Land Agents and Planning Consultants on behalf of the applicant. We are confident that the LRB members will review this evidence critically and assess it accordingly.
In the last few years Carmunnock has for a small community had significant development. Two blocks of luxury flats (36 units yet to be built) at Carnbooth were permitted in the Green Belt, contrary to the Development Plan and requiring the felling of 110 mature trees. In this case and to our disappointment, the LRB appeared to favour the financial interests of the developer rather than make a determination in accordance with the Development Plan legally in force at the time. More recently a development of 56 houses on two Green Belt fields at Cathkin Road is nearing completion. The Busby Road field is within the village boundary and is an integral part of a network of green and open spaces in Carmunnock. The Community Council does not oppose all development but in our view all these spaces are just too important and need to be retained and enhanced. The number of objections received shows that this view is shared by the local community.
Glasgow City Council’s own website extolls the amenity which Carmunnock contributes to Glasgow as a whole by virtue of its status as a Conservation Village and as the last true village within Glasgow surrounded as it is by farmland on all sides. Carmunnock village is characterised by areas of green and open land which are intimately linked with housing. Visually and physically this site connects the heart of the village to the wider landscape and is one of the green spaces which make an indispensable contribution to Carmunnock’s character. As such we believe it should remain as open space.
The need to build more houses is accepted, particularly affordable homes and those for social rent. Carmunnock has a shortage of these and this development proposal would do nothing about that. The contribution that this site can make to Glasgow’s overall housing needs is minimal. The need for more houses should not require that every piece of land should be referred to as a ’gap site’ and be built on. Our view is that the site has more value to Glasgow as an open green space than as a site for housing.
We are aware that the LRB has to decide whether there are other material considerations to be taken into account. Two points may be considered material. The first is that research on Registers of Scotland shows that the current owner of the site was gifted ownership by his father in 2008. The land had been bought for £2750 by the applicant’s father as agricultural land in 1979. The second is that the Community Council is aware of interest within the community in buying the site for
community use. This interest arose after the sudden death in February this year of Roz, the horse that had grazed in the field for the previous 18 years although as far as we are aware no approach has yet been made to the site owner. We support any moves to bring the field into community ownership and use.
The last Green Belt review in 2017 considered this site and rejected it as being unsuitable for housing and kept it within the Green Belt. This decision was taken after due process and consultation. Our view is that any change in the site’s status should be similarly decided at the next Green Belt review.
At our meeting on 25th May 2021 Carmunnock Community Council further considered this planning application. In addition to those mentioned already we have further concerns related to this specific planning proposal:
 It is out of keeping with the spacing of other houses on Busby Road – 4 houses are too tightly spaced compared to other houses in the road.
 All the surrounding houses are built into the natural contours of the land. The current proposal is to level the site by creating a raised platform to alter the existing contours of the land which would be out of keeping with surrounding houses and with the area in general.
 It would create an artificial embankment to the left against 66 Busby Road which would be clearly visible when viewed from Busby Road and a concrete permacrib wall at the rear which would be visually intrusive and unattractive when viewed from Pedmyre Lane.
 The traditional hedgerow to the front should be retained.
The Community Council does not automatically oppose all development; rather each proposal is constructively assessed on its merit. Our comments and suggestions are based on how we believe each proposal would affect our community. In this case we emphasise that our considered judgement is that this particular development proposal should be rejected.
The Certas Letter to Members and the Certas Planning Report are selective in their evidence. We would respectfully draw the LRB members’ attention to the following issues they raise:
 The Certas letter refers to loss of green belt and selectively to the last green belt review. The exact review wording is
“The final zone in this sector, Zone 3.5, lies to the west of Busby Road, to the south west of the village. It comprises some open land and some individual houses on the west side of Busby Road, all of which are currently located in the Green Belt. The land to the west of the houses is steeply sloping, down to a burn which feeds into the Kittoch water to the south. These topographical constraints, and the identification of the land immediately around the burn as a City-wide SINC, means that the site is, generally, considered unsuitable for development. The 2004 CPS had identified the northern part of Zone 3.5, a field between the houses in the Green Belt (to the south) and the houses in the village(to the north), as a small site which may offer some development potential of around 5 units. The site is relatively flat to Busby Road but does slope down quite steeply to the burn within a relatively short distance. Although not designated a Site of Special Landscape Importance, this site is considered to play a valuable landscape role within the village. Given this role, and limited scale of the development opportunity, it is considered that, on balance, this site should remain as Green Belt.”
It is clear that although the development potential of the site was recognised, the review concluded that all the evidence pointed to the greater benefit of the site remaining undeveloped. We make no apology for repeating our view that any change in the site’s status should be as a result of examining all the evidence at the next green belt review.
 Glasgow’s City Development Plan is a 10year plan adopted in 2017. It refers to the importance of the Green Belt in linking the urban area to the wider countryside. This site fulfils this function as a finger of green coming into a built up area. Development would break this link.
 Although the land is poor for agriculture it has significant biodiversity and rewilding potential. The statement that hedgerows and scrub are ‘poor quality’ is unsupported. They are rather to be seen as natural features in the landscape to be retained and allowed to develop naturally.
 The Certus report contains pictures of selected surrounding houses but omits the 2 properties to the left of the site at 66 and 66a Busby Road. The inclusion of these supports the view that 4 houses would be overdevelopment of the site.
 This open land referred to in the Certus report as a ‘gap site’ does not have to be developed but can be left open as amenity land. There are many examples of this in Carmunnock and in other parts of Glasgow city. Building on this site would create ‘ribbon development’ which has been discredited by most professional planners.
 There is a proposed artificial embankment to the left along the boundary with 66 Busby Road. This would be visually intrusive when viewed from that property and from Busby Road. This embankment would not be necessary if any development respected the existing contours of the land as all surrounding properties do. NB It appears that 46 Busby Road sits on an artificial raised platform. It is however originally a 1950’s house built on top of a naturally occurring outcrop of rock so for avoidance of doubt it too respects the existing contours of the land.
 The Scottish Water Ecological Appraisal has not been presented so any conclusions based on this cannot be verified. We would respectfully suggest that LRB members may prefer to rely on the assessment by GCC’s own Biodiversity Team that the site is of significant importance for nature conservation.
In general the developers have looked at how to maximise profit from the site without taking a holistic view of how their development would integrate with existing properties and the surrounding landscape. People living in communities around such proposed development deserve better than this.
We are dismayed at the criticism by Certus, Land Agents and Planning Consultants of the planning officer’s Report of Handling. We fully support the planning officer’s approach in addressing the substantive planning issues and arriving at sound conclusions.
With regard to the applicants appeal we support the planning officer’s original decision. It is our considered view on the evidence available to us that there are no considerations material enough to
outweigh the public benefit to Glasgow of retaining the site as open space. Indeed the only possible outcome from this development would be a detriment to the environment and the local community. Our view is that unless material considerations indicate otherwise, the LRB’s determination must be made in accordance with the Development Plan that is legally in force.
With this submission taken together with our comments on the two previous planning applications and in light of the large number of objections from the local community we respectfully invite the LRB members to conclude that this appeal should be rejected.
Carmunnock Community Council
25.05.2021