This also formed the basis of the decision by the Council to dispose of the land and conformation to this guidance was alluded to by your Convenor in a letter to Dr. Lyons on 30 July 2007.  In a letter dated 13 April 2007, your Director informed Ms Godman MSP that the actual need hadn’t been quantified at that time.

There has been rather unnecessary debate as to whether the council could impose legal restrictions on the type of resident (your Mr McLiraith referred to it as well.) As Head of Property Services confirmed to Councillor Nicolson as long as 29 November 2005, specifying the design and size of the houses could be used to ensure the Council's requirements. Clearly if residental units are properly designed for the elderly and socially disadvandaged they will not be attractive for other social groups. Moreover, by involving a Housing Association "affordable homes" could be provided.

We have carried out our own study on the need for homes for elderly people on this site (we attach a copy as relevant information).   We conclude that:

We note that the applicant submitted an application which is materially different from the specified type and number of units described in the said Development Requirements and as a consequence materially different to that certified by the Council to the Scottish Ministers in the matter of our Application pursuant to The Land Reform (Scotland) Act 2003.  We are pleased that Mr. McIlraith indicated that you had suggested to the applicant that he should reduce the number and size of the units.

It is in respect of this that we refer to “justifying need”.  In our opinion the Council has made it clear as to what would in their opinion amount to “strong justification” to develop this open space for residential purposes and at the same time satisfy the need to assess the benefits of change of use against the criteria set down in Policy L4.  Whilst we accept that you may be acting in good faith, we do not believe that legislation requires you to enter into a process of elimination with the applicant until he arrives at a proposal which you can say is strongly justified as an alternative to the one you certified in September 2005.

We are pleased to learn from Mr. McIlraith that the Council has been relatively firm about the size of the units, but we understand that the design or the need to have a Housing Association involved has not been emphasised.  What also gives us concern is that we understand that it may have been suggested to the applicant that 30 units would be acceptable.  If this is so we believe that would imply that the Council has determined the actual need at 30 and that it is not an arbitrary or maximum figure.  Of course, the work in hand in April may well have been completed and reached that conclusion.  But any new study wasn’t referred to at the Board meetings in June – it could be that you intend to refer to it in your report, but it should be a public document for members of the public to take account of.  We would be obliged if you would confirm whether such a conclusion has been reached and why.

The Director of Planning’s Report to the Planning and Economic Development Policy Board held on 5 June 2007, under the sub-heading “Community Plan Implications”, reports that social inclusion will be achieved because “part of the site will require to be developed for smaller housing units suitable for purchase for the elderly”.   This is in line with the Development Requirements – the southern part of the site being said to be for   “20 – 30 residential units to 1 or 2 bedroom units designed primarily to meet the needs of the retired, the elderly or those with special needs”. 

Fifth Representation  24 January 2008

We would like to thank your Mr McIlraith for the courtesy and time he extended to us when we visited on Tuesday afternoon.  His explanation of the Applicant’s revised layout was useful.  He also explained your insistence that the Application be further revised in keeping with the Development Brief, clearly showing an intent to keep firm to the Council’s guidance for this site.  We also noted that you have asked the Applicant to complete Certificate 2 and correctly identify and notify the Owner. 

Whilst we do not agree with the procedure you have adopted, we accept that Mr. McIlraith acted in good faith in believing that the Applicant had actually acquired ownership from the Council, he accepts that otherwise he would not have registered the Application.  Moreover, provided that you required the Applicant to include justification of the development in a Planning Statement (and not justified by yourself) we were prepared to accept that at the end of the day the process had a chance of being seen not to have seriously breached the integrity of the planning system.   We reported this back to members on Tuesday evening.   

The current position 

Members have asked that we reiterate and emphasise that we object to any development of the land other than for open space purposes.   

However, in the interest of cooperating with you and without prejudice to our overall objections and previous representations, we make the following comments: 

• The Applicant’s revised proposals make no provision for Open Space in accordance with Policy L5.  We draw your attention to the fact that this land provides valued Open Space (defined by you as under Policy L4) for the adjoining and existing developments and if it was to be developed for purposes other than open space, alternative provisions would have to be made.
  
• We are extremely concerned that you should be considering any new development before Scottish Water provides additional sewerage capacity to serve Houston.  This may be addressed in the Applicant’s drainage impact assessment.
  
• We welcome and agree with your suggestion that any SUDS pond should be underground.
  
• We agree that safe pedestrian access would be required.
  
• We agree that minimum distance between units should be maintained, including that with existing properties.
  
• We are pleased to see that you are insisting on a tree survey and protection of the “ash” tree.  We would expect you also to deal with protected species.
  
• We are pleased to see that you are protecting the existing stone walls.  Could you require the developer to repair and maintain them?
  
• We are pleased to see that you are insisting that the Applicant should greatly reduce the number units proposed on the southern site and that they should not exceed two stories and two bedrooms.  However, we are concerned that you are not seeking to place tighter control on the use of the units.  Your explanation that you cannot make the nature of occupancy legally binding raises the possibility that the houses could be occupied by families.  Many of our members are concerned that this will affect the number of children attempting to gain places at local schools and that this has not been addressed.  We also believe that you could exercise control by insisting on the involvement of a body that habitually provides the sort of accommodation described in the Development Requirements.
  
• We are concerned that Applicant’s revised proposals still do not give details of the proposals for the northern part of the site.  Nor, have you asked for them.  We see no reason why the Applicant shouldn’t give details if development of that part of the site is to be included in the Application which goes before the Board.  Our members are very clear that the details of any development on this part of the site must be open to full public scrutiny and approval.  For the avoidance of doubt, this part of the site is in a prominent position and any houses built there would be seen as landmarks.  It is simply unthinkable that the Council should not insist that the developer’s detailed proposals are made public.
  
• We suggest that the Applicant is required to give consideration to pollution and dust control, noise and hours of working during the construction phase.  Any development will be close to existing properties and strict conditions should be applied. 
  
• We note that the Applicant has extended his Site Investigation.  We suggest that the results of his investigation are made public.
  
• We note that the Application is lodged on your web site. We assume that if you consider information received from the Applicant constitutes a revision to the Application that you will post it on the web site.
  
• We note that Mr McIlraith considers the Council’s Estate’s Department to be the Owner and that the Owner has not made representations. 
  
• We note that you only permit the public to see representations from “consultees”.  Shouldn’t representations from “neighbours” and community bodies like ours be included in the public file?

Going forward 

However, a number of circumstances have arisen since our visit which leads us to believe that you must clarify the process you are adopting.   

You will be aware that in response to an initiative from Gryffe Action Group interested people have been contacting Councillors, we assume with the intention that draw attention to the wider policy issues involved.  The responses from Councillors imply that there is no set down framework in which Councillors respond to such contacts. 

Councillor Eileen McCartin expresses an opinion that could be construed as saying that it would be illegal for any Councillor to have any form of discussion touching on the application with a member of the Planning Board.   The Councillor’s comments suggest that Councillors are legally inhibited in making representations either on their own behalf or on their constituents’ behalf. Councillor Carol Puthucheary has announced that the Council is to hold an “Inquiry” into the application, suggesting that a decision has been made by the Council.  We also understand that Councillor Nicolson has asked the Chairman of the Community Council to chair a meeting between the Council and other bodies with an invited collection of people who have expressed written objection to the application. 

There is clearly a danger that these statements may cause individuals who would have otherwise have expressed an objection to the Application to question the need to.  Moreover, limiting a meeting to those who have already formed an opinion appears to ignore the fact that a public meeting may help individuals to decide whether or not to object.  However small the number is of people who are contacted by Councillors this way, could the responses be seen to be prejudicial to the integrity of the planning system? 

Would the meeting proposed by Councillor Nicolson be held to present an Application which the Council has agreed with the Applicant merits acceptance?  It is clear from your letters of 20 December 2007 and 18 January 2008 to the Applicant that you consider that his Application as submitted and revised merits refusal.  We consider that the Council has to be careful with this.  Could it be seen that the Council is promoting the Application?  And, as the Council has a financial interest in the outcome of the Application, could be this be said to breach the integrity of the correct procedure for considering an application in such a circumstance? 

For the same reason we suggest that the Council should be careful not to be seen to justify the Application.  It is up to the Applicant to justify the “need” for the development.  He should set out persuasive reasons why the location, spatial layout and topography is suitable for the development.  He should also demonstrate that there is no other alternative site which would better meet the need (if there is one).  We believe that your report to the Board should critically review and address the Applicant’s justification.   Is it the intention that your report is presented to the meeting proposed by Councillor Nicolson?  If so would it be before or after members of the Board have received and decided on it? 

Will the Council explain its strategy for the provision of Open Space in Houston at such a meeting?  We note for example that there is a paucity of provision in areas such as Crosslee. 

Under what authority will an Inquiry be held and will it take place after the meeting or before?  Is Councillor Puthuceary referring to the fact that if you are minded to recommend acceptance you will first have to refer the matter to the Scottish Ministers?  Have they already indicated that they would wish to hold an Inquiry? 

Will the Applicant be in attendance at the meeting and will he be required to justify the development? 

With respect it appears that the process you have adopted in good faith has become muddled and unclear.  We suggest that for the sake of transparency and to vouchsafe the integrity of the planning process that you ask the Applicant to submit (under time restraints) one more final revision (without further input from you), fully justified by him and with all the required detailed assessments in place.  Thereafter, it would be helpful if you instigated a public meeting where the Applicant can explain and justify his Application to the public at large.   You may then allow time for those who have made representation to make further representation, always giving assurances that you will preserve previous representations for you to deal with in your report to the Board. 

We are aware that existing legislation does not set out such a procedure; however, we are also aware that there is disquiet that the prescribed procedure for advertising applications is not satisfactory.  May we suggest that you ask the local press to publish the timetable and agenda and that you ask Gryffe Action Group and ourselves to circulate the information?   

We trust that you accept this representation in the spirit of cooperation that is intended and that it is strictly without prejudice to our rights and the individual rights of our members to object to and make representations on the Application. 

Fourth Letter of Representation – Site Investigation.   21 December 2007

We note that Site Investigation was carried out on Friday 18 January 2008 – we understand that it was instructed by Mactaggart & Mickel.  Was it carried with your knowledge and permission and if so did you agree a scope of assessment with the Applicant before the investigation started? 

We have a record of where 5 shallow trial pits were excavated to the sites western side and two on the southern side.  Another was located on the elevated west side of the site adjacent to the quarry.  We observed an in-rush of groundwater into that trial pit when it was being excavated. 

The applicant also installed two number 4 inch diameter boreholes, which were sleeved and capped.  These were located in the southwest corner of the site and on the high point to the south of the site. 

We also have photographic evidence of the excessive damage done to the field by these works.  The damage was avoidable if the Applicant had carried out the work at less inclement times.  We expect that you will be instructing them to restore the site forthwith and look forward to you being able to report successful completion of restoration works to the Community Council within the next 14 days.  

We also note that the works exposed an area of soft ground and subsidence on the high ground to the south of the site.  We understand from historical mapping that this may have been the site of a substantial structure in the past.  In which case we suggest that further investigation may be required in that area to ascertain whether it is the site of an uncapped well or similar excavation 
 

Third Representation  21 December 2007

We are also aware that your Environmental Health Department has raised concerns over the adjacent disused quarry being a possible source of contamination risk.  We have only superficially investigated this matter.  Anecdotal evidence is that the quarry was used to extract limestone; that operations ceased in the 1940’s and that it has been backfilled with agricultural waste without the control of a site license regime.   

The solid geology consists of formations of the Carboniferous age.  The quarry is likely to be situated the Strathclyde Group: Lawmuir Formation that comprises sandstones, siltstones, mudstones and seatrocks; a few coal seams and marine limestones. Much sandstone, commonly pebbly, in lower part; cyclic sequences predominate in upper part.  The "Hollybush Limestone (HHL)" is present as a band approximately 50m wide in the southern half of the site and in the land to the east of the site.  We presume that this is the limestone that was worked in the quarry. The HHL is cut off to the south by a fault. We have sketched the HHL and the fault on a copy of the attached plan.  Site observation shows that Neuk Crescent is also situated on the same formation as could any part of development which lies on the face of the slope. 

It is likely that there are pathways from the quarry which could transport methane gas and any soluble contaminants present in any filling that has taken place.  Whilst it may be that the waste deposited in the quarry will not be generating significant amounts of gas at this time, there is a significant possibility that there are deposits of gas which have not degraded or dispersed to atmosphere.  These pockets could be dormant at some distance from the quarry.  Rotting vegetation could generate some gases, but this in itself should not be significant.  Other contaminants common in agricultural waste could have been transported from the quarry by pathways in the shattered rock and could be present in surrounding areas. 

Rock formations as described above will be the source of ground water manifestation in localised areas.  Development could cause disruption to these.  Visual inspection of the banks to the River Gryffe shows that despite the fault there is continuity in a southerly direction.  The “bog land” in the south west of the application site is more than likely caused by water flowing along the shattered rock.  There is mapping evidence of a water course which coincides with a piped outlet into the River Gryffe adjacent to Lee Burn Gardens.  The “bog land” area can be seen from old mapping to be the possible “source” of that water course which is more than likely fed by water flowing through the rock strata and the fault.  We are unable to assess what effect the faulting would have on foundation design. 

None of this is conclusive and may not be reason to give rise to concern unless the status-quo is disturbed.  But we are inclined to concur with your Environmental Health Department’s opinion that the matter should not be ignored.  These matters should form part of an Environmental Impact Assessment, which in any event should be required by the Council for a development of this size.  You may also confirm whether the old quarry has been identified as a Contaminated Site by the Council and if so on what basis. 
 

Second Representation

We refer you to the attached detailed representation which inter alia sets out the case for the Application to be REFUSED on the basis that the development proposed does not justify development which does not relate to open space.

Your Chief Executive has given us what we believe are firm assurances that granting of planning permission, if granted, will not be influenced by the capital receipt that would accrue thereby.  In so far as the question of need is concerned, when considering the Application you have therefore only to consider whether there is a strong justification on the basis of need for residential development of the type and scale proposed by the Applicant.  It has long been established (since at least 1960) that residential development should not be permitted on green open space unless there is a special need.  Moreover, there is no convention which supports an argument that need is unquestionably established by the market.  Hence the Local Plan and Housing Strategy have to clearly set out the need for residential development and how it is to be satisfied.  In the case of open space such need as there is has to have special merits described as “strong justification”. 

Pursuant to current guidance, justification must include evidence that the development will not result in a deficit of open space provision of that type within the locality and that alternative sites and any community concerns have been properly considered.  Where, exceptionally, it is proposed to grant permission for development which would result in or exacerbate such a deficit, current guidance requires that replacement open space of appropriate type, quantity, accessibility and quality must be provided.

    We are not aware of the Council having drawn up an Open Space Strategy.  In the absence of which it would be premature for the Application Site or any other open space to be developed for purposes unrelated to open space.

Recent correspondence with your Council has not clearly confirmed the Council’s requirements for the type of development.  There is a widely held impression that the Application is for homes for the elderly and socially disadvantaged, very much as described in the Development Requirements included in the Enquiry given to bidders for the Land.  With some people the impression is that permission can only be granted for such a development.  You are aware that we do believe that this is the intention of the Application.   

For the purposes of transparency it would be helpful if the Council could make its position clear on this matter so that members of the public may have an accurate understanding of what they are entitled to make representations on before you prepare your recommendation on this application. 

You will see that we have made it clear on our letterhead that you should reply to this letter to the undersigned acting in his capacity of Chairman of Houston Amenity Land Limited.  We understand that despite having made this clear to you in its opening paragraph you incorrectly acknowledged our previous representation dated 12 November 2007.  Please acknowledge both letters of representation. 
 

First Representation 12 November 2007

Executive Summary

This representation refers to the need for there to be justification for any development on open space which does not relate to open space.

It adds to any other representation made by HALL.

It takes account of correspondence received by HALL since its first letter of representation and the most recent guidlelines published by the Scottish Government.

It includes submissions on:

• Getting Best Value when developing sustainability.
• The facts to be taken account of.
• The Scottish Government’s Policy on Open Space.
• The Local Plan Context
• Expert’s Report
• Detailed Representation

HALL submits that: 

The Application is not justified it and it should be refused. 

Getting Best Value when developing sustainability.

Environmental issues are high on the agenda of people and bodies in all walks of life.  It is said that the Stern Report marked a watershed in the debate on climate change, setting out the economic case for cutting carbon emissions.  It is recognised that there has to be a root and branch review by society as a whole on how we protect our environment.  The best use of natural resources is a key global, national and local consideration in the fight to achieve carbon targets in a sustainable and most affordable manner.  The creation and maintenance of policies and strategies which preserve green open space, on whatever scale, is seen by most Governments, including the Scottish Government, as being at the fore front of that fight.

These policies have wide public support.  For example a recent Henley Centre study found that 26% of UK consumers will boycott companies who damage the environment.  This comes as no surprise as the public recognise the potential cost of not acting to stabilise CO_2.  The Stern Review puts the cost at some 5%-20% of global GDP per annum.  In terms of Scotland, the nett receipts from the sale of the Application Site are insignificant when measured against Scotland’s £85bn GDP or even against the spending by Renfrewshire Council.  Obtaining “Best Value” has to balance a loss of a sum which represents less that half a percent of Renfrewshire Council’s budget against the contribution retaining the land as open space has to make towards the fight for environmental stability.

The facts to be taken account of.

The facts are these. 

• Potential sales proceeds have prompted the proposed development of this land.
• It is admitted by Renfrewshire Council that the land is categorised as Open Space.
• Renfrewshire Council have not referred to a Strategic Open Space Plan or Audit.
• There is a presumption against development on open space.
• Renfrewshire Council actively manage the land well as open space.  
• The site can be described as high quality open space. The open space is valued and used by local people. 
• It is the location of valuable biodiversity. 
• It is well located at the centre of three separate communities which make up Houston.
• It is accessible, distinctive and adaptable.
• It is safe, pleasant and welcoming.
• Its loss could not be replaced.

In what follows HALL makes and supports the case:

• Developing the Land for residential purposes in contrary to Scottish Government policy;
• Developing the Land for residential purposes in contrary to the Local Plan;
• The Land should be a key element of an Open Space Strategy for Houston;
• There is no justification, strong or otherwise to develop the Application Site for purposes not related to open space.
• Planning Application No. 07/1084/PP should be refused.

The Scottish Government’s Policy on Open Space ¹

A key objective of the Scottish Government is to protect and enhance open space.  Open spaces and sports facilities enrich our quality of life and our environments. Access to good quality open spaces and facilities which encourage people to play sports and to walk, run, cycle or ride horses are an essential component in the drive to get more of the population physically active and can contribute to The Scottish Government's objective of a Healthier Scotland. Physical activity can improve mental health and well-being and the presence of tranquil green spaces close to where people live and work can encourage relaxation.

Providing play space and other opportunities for children and young people to play freely, explore, discover and initiate their own activities can support their wellbeing and development. Open space can also provide a rich and accessible resource for education.  Civic open spaces, whether providing pleasant places to meet or through enhancing the streetscene, can help to create well designed places for people. An environment which contains good quality, well-maintained open space is more attractive to investors, helping create a Wealthier and Fairer Scotland. Improving the open spaces within a community can help reverse patterns of decline, generate civic pride and help to establish cultural identity, all contributing towards a Safer and Stronger Scotland.

Open space can help create a Greener Scotland. Open space can provide habitats for wildlife, and linking them in a green network is of particular importance to biodiversity objectives. Open space can also help counteract climate change. Areas of green open space have the potential to provide carbon sinks and can offer areas of shade and shelter. They can incorporate sustainable drainage systems and some can have a role in flood management. Networks of quality open space can encourage more sustainable forms of transport such as walking and cycling.

Local authorities are required to take a strategic, long term approach to managing the open space within their areas, objectively assessing both current and future needs and protecting all spaces which can help to meet those needs.  In urban areas, networks of linked, good quality greenspace are important for their positive visual impact, as well as their role in nature conservation, biodiversity, recreation, education, physical activity and outdoor access.  

Open spaces can be important components of habitat networks. Green networks can provide safe tranquil off-road access opportunities from the doorstep to play space, sports facilities, town centres, local amenities, path networks and the wider countryside. Planning authorities should give due weight to connectivity and consider the need to avoid fragmentation of open space, in particular areas of woodland and other important habitats identified, for example, in Local Biodiversity Action Plans.

Planning authorities should seek to identify opportunities to create and enhance links between open space as an integral part of development. For large land releases and regeneration areas, masterplanning can play a key role in the strategic provision of open space across wider areas and land ownerships

In order to deal strategically with open space provision, local authorities must have an accurate understanding of the current open space resource in settlements within their area. Local authorities should assess how well the needs of communities are being met and identify any changes needed to improve access to quality open spaces. To assist in this process, local authorities must undertake a comprehensive open space audit.

The community's needs and aspirations are at the heart of any open space strategy and they should have an opportunity to contribute to both the audit and strategy. All parts of the community, including voluntary groups and sports clubs, should be involved, as should the community planning partnership and other relevant local and national bodies.

The Scottish Government encourages good design and networks of high quality open spaces. These should be safe, welcoming, appealing, distinctive, well connected environments, in line with the qualities for successful places set out in Designing Places. It is important that open spaces should be viewed in their context, as their quality often directly relates to the quality of the buildings and spaces surrounding them. The design of open spaces can be as important to the townscape of a settlement as the design of buildings and should be treated with as much care. Factors to be taken into account when considering the quality of open space may include whether it is:

• fit for purpose
• well located and connected
• easily accessible
• inclusive
• distinctive
• of high quality design  
• pleasant and welcoming
• safe
• adaptable
• well maintained and actively managed

There is a presumption against development on open spaces which are valued and functional, or which are capable of being brought into functional use to meet a need identified in the open space strategy. Local development plans will identify and protect such open spaces, in line with the findings of the open space audit and strategy. The strategy may not cover every open space but may instead focus on larger and more important spaces. Where there is other open space which is not identified in the strategy but which is valued and functional or which contributes to local amenity, biodiversity or other planning policy objectives, this should also be protected in the development plan.

Only where there is strong justification should open space protected by the development plan be developed either partly or fully for a purpose unrelated to use as open space. Justification must include evidence from the open space audit that the development will not result in a deficit of open space provision of that type within the locality and that alternative sites and any community concerns have been properly considered. Where, exceptionally, it is proposed to grant permission for development which would result in or exacerbate such a deficit, replacement open space of appropriate type, quantity, accessibility and quality must be provided.

Development by local authorities is subject to normal planning considerations, including the policy advice in SPP 11, and local authorities should seek to protect and enhance open space in their ownership. 

Note 1 – Source SPP 11 

The Local Plan Context 

The Local Plan context is founded in paragraph 11.3 of the Local Plan.  Therein the averred policy is to take a robust approach towards giving protection to open spaces against pressures to develop them for other purposes.  The policy statement goes on to assert that the “Most important formal and informal open spaces, are identified on the Proposals Map and given a high level of protection.  The level of protection of lesser open spaces will be dependent on the characteristics of the individual areas”. 

The Application Site is categorised by the Council as “Lesser Open Space”.  In relation to which the natural meaning of the policy is that the amount of protection it is entitled to depends on its merits.  It may be intended to be a higher level of protection than that proffered for formal or informal open space, it may be less.  Whatever, HALL submits that in this context protection means defend against – stop, prevent, disallow or refuse. 

Policy L4  : Protection of Lesser Open Space and Recreational Facilities informs that: 

“The Council will assess proposals for development and recreational facilities not identified on the Proposals Map in terms of: 

1. the amenity value of the site to the surrounding area;
   
2. the value of the site or facility in recreational terms to the surrounding population.

Paragraph 11.12 confirms that the Council is accepting that the policies accord with national planning guidance.  Consequently they should be read alongside current national planning guidance which in the case of ambiguity will take preference. 

Paragraph 11.13 confirms that “it is important to give protection to those lesser sites which make a valuable contribution but which are not of a scale to be shown on the Proposal maps.”  There is no explanation of this statement of policy, but the natural meaning would be that “scale” refers to the plan area of the site in relation to its surroundings. 

Paragraph 10.2 asserts that the Local Plan policies are intended to protect and enhance a high quality of natural environment.   

Paragraph 10.15 confirms that appropriate protection is to be provided to the wider nature conservation resource outside formally designated areas. 

Paragraph 10.20 confirms the requirement to recognise “the importance of wider natural heritage, in particular the vital network features that support the coherence of designated sites by acting as stepping stones or linear corridors forming links from one habitat to another.” 

Expert’s Report 

Attached to this representation is a copy of a report on the Application Site prepared by Ms. Nikki Dayton, BSc Hon’s Environmental Science, Senior Ecologist at Quadrat Scotland.  

Inter alia the report Ms. Dayton concludes: 

“The site is most important for its position as a green link cutting between the old and new parts of Houston Village (See Appendix 1).  This field provides a corridor between the mature woodlands around Houston House and the woodland around the cemetery and connects to the Gryfe valley along the old road.  This will be used by a number of protected species including bats and birds to access feeding grounds and for dispersal.  Any proposals for this site should recognise and retain this link, preferably enhancing it with new planting of indigenous trees and herbs and providing nest boxes for bats and birds. 

This site is also an important recreation area for local residents who use the site for dog walking, strolling and other pursuits.  It is understood that they would be in favour of supporting a green link through this site, both to retain the area of green space for leisure activities and to provide additional habitat and local interpretation of the wildlife in this area.” 

Detailed Representation