Representation on the draft LDP by Catherine Macdonald, Birkhill, Pool of Muckhart,

FK14 7JW
[1720 words]
I thank Clackmannanshire Council for the opportunity to comment on the LDP and
associated documents, and for the extension of period of consultation, to allow us to read the
thousands of pages of materials. We moved to Clackmannanshire after the preparation of the
Main Issues Report, so had no opportunity to comment on it (I also note that family members
in previous generations lived, worked and studied here).
The LDP documents cover complex, intertwining matters, several outwith the Councils
remit. The policies, plans and actions from those policies affect the countys current and
future stakeholders residents, workers, businesses and other organisations, flora and fauna.
This LDP draft is based on NPF2. The LDP is impressive, and its preparation clearly
includes long, careful and caring consultation with residents and businesses. As a result, the
final draft has been issued some months after a draft NPF3 has already gone to parliament for
discussion.

Climate change: identifying and addressing the consequences
The LDP is generally excellent in its low-carbon awareness and policies for achieving low-
carbon transport and energy-efficient buildings. However, the plan is far from systematic and
rigorous in (a) identifying the consequences of climate change, direct and indirect and (b)
considering the implications for the county.

The LDP speaks of an increase in more extreme and unpredictable weather events (Section
7.02, p80), but does no more to identify the main direct consequences of climate change. The
global and local consequences of climate change have major implications for us all, globally
and locally, and therefore must be considered as a matter of urgency by all policy-makers,
now. These consequences include increased rainfall, increased drought, and increased
variability (and extremes of variability) in weather patterns, globally, in the UK and in
Scotland. In turn, one of the major indirect consequences is substantial decrease in food
production, both in sudden shocks and gradual shifts, and this will have profound
implications for Scotland (and also opportunities). The Food and Agriculture Organisation
(FAO) and other bodies (including the US government) have noted in multiple reports that
initially global warming is likely to mean a slight increase in crop production overall, but that
after 2030 it is very likely that we will face major shortages of food. Recent weather
extremes around the world and in the UK are already now wreaking havoc on agricultural
production, and I expect to see revised, more pessimistic near-term forecasts from the FAO
and others about threats to food production and food security. Lower or even lost crop yields
in the USA, Canada, Bangladesh, India etc mean lower exports of food to us; the same
applies to UK/Scottish crop/agricultural production.

We must take these factors into account, regularly, and before building on land which is
currently used for agriculture or which could be used for agriculture. I welcome the
Councils promotion of allotments, but would like to see more active steps to engage
residents in allotments, and orchard growing. This could be an opportunity to involve
jobseekers, provide training, and develop knowledge and skills. While the LDP specifically
mentions developers on numerous occasions, and while it does refer occasionally to
agriculture, it does not mention farmers or the farming sector, nor does it consider larger-
scale agricultural needs arising from the consequences of climate change. These needs are
likely to conflict with the scale of housing development specified on the basis of the NRS
2010 projections and related policy. I cannot see how development can be sustainable, unless
it takes account of the factors highlighted in this representation.

Given these major indirect consequences of climate change, apparently accelerating, it is
surely all the more important to stop and review the population growth projections and the
plans and policies relating to use of land and spatial strategy, before allowing building on
land assets which will be very difficult to recover.

The LDP in general expresses concern for nature, frequently mentioning habitat and
biodiversity, but the strategic objectives (SO1, SO3) and environmental policies are not
strong enough in this regard, and often stated in the context of development. Pollution,
habitat loss, climate change are destroying the flora and fauna around us. Species decline and
loss result in the destruction of ecosystems, which support the food we grow and the
environment around us. An example is the steep and rapid decline in bee population.
Without bees, pollination will be severely affected, with catastrophic results for food
production and our environment. I ask the Council to consider the findings and
recommendations of the State of Nature 2013 report on the state of nature in the UK, and in
Scotland, which tells us that of more than 6,000 species .. assessed using .. Red List criteria,
more than one in ten are thought to be under threat of extinction in the UK. The work with
The Central Scotland Green Network (7.05) is commendable. However, much more is
needed to preserve habitat and protect the ecosystems which support us.

Economic activity, education & training, population growth, house-
building

In my representation on the draft Action Plan, I ask that the Council delay the implementation
of the housing developments. Under the current draft Action Plan, half (2,787) of the total
5,615 new homes are to be built in the first five years of the plan. There are extreme strains
on the environment in Scotland, the UK and world-wide, caused by habitat loss, climate
change, and other factors which affect the environment. Building on green fields and green
spaces causes irreparable damage which we the inhabitants people, fauna, flora, today and
tomorrow can no longer afford.
Moreover, however, there are high levels of unemployment in the county, with an
unconvincing strategy to address this (see below).
The current draft is based on NPF2; the draft NPF3 takes more account of pressures on the
environment. I ask that a substantial proportion of the building programme for the first five
years be delayed, pending review of the LDP, to take account of the desperately urgent needs
to preserve our environment, but also to focus energies on fostering economic activity with a
solid, cogent, realistic plan in which the Council believes, to drive business, support job
creation and eradicate joblessness. In turn this will further the Councils work and vision for
healthy residents, old and young.

Clackmannanshire Councils 2014/2015 Budget Summary reports that the county has
around 5,000 workless households, that is, 22% of the 22,950 households in the county. It
also reports the highest proportion in Scotland of 16-24 year olds claiming Jobseekers
Allowance for over 12 months. The Budget Summary states that the Council is urgently
seeking cost savings and states that it needs to save 25 million over the next five years.
The Councils primary focus in the LDP should be on fostering the countys economy and
economic activity and helping jobseekers and the jobless find work, with a solid, focused
plan. The plan for developing economic activity is vague. Moreover, although the LDP draft
is coy about the timing of the housing building, the Action Plan shows that half of the
housing increase prescribed for the 20-year period is to be built in the first five years of the
plan. This is not where the Councils primary focus should be. The draft LDP does not set
out the financial impact of this additional housing building on the countys finances, in the
near or medium term. It does not adequately justify why the house-building will be an
economic benefit to the countys residents or businesses.

The county needs a strong, solid economic strategy. The strategy in this draft lacks detail and
speaks in general terms building business parks helping retail .. The LDP talks of
bringing in more high-value jobs but what sectors are these in? how? The presence of
supermarkets and superstores is all well and good for a consumer society, consuming
products brought in from outside, but what is their role in the countys economic strategy?
Where does the LDP include digital information technology and capabilities in its strategy?
Digital information infrastructure and capabilities are far more than pipes The Internet is
having a huge impact on business, including retail business. Shops in town centres struggle,
having to compete with supermarkets, out of-town malls, and online shopping. How is the
LDP going to help in this respect? On the other hand, shops can use digital technology (in
particular enabled by geospatial capabilities) to advertise, identify, bring in customers. While
stressing education, the LDP provides minimal detail, and no mention of skills development
in this regard, including outside primary, secondary education. Computer science, digital
literacy is fundamental to a huge proportion of business (and also learning), creativity and
design. Skills development, in particular a basic understanding of the fundamentals of
computing and information technology, would give Clackmannanshire a very, very strong
competitive edge, which it could achieve within a short time, just a few years. (Digital
infrastructure in information technology terms is one of our areas of expertise, we have
advised government and multilateral bodies, including the European Commission, on e-
infrastructures, policy and roadmaps, and we would be happy to contribute thoughts.)

Special Landscape Area (SLA) designations and timings
The LDP reflects a great feeling for and knowledge of the Ochils and describes the SLA for
the eastern Ochils. However, I believe that SLA designations are to be reviewed soon. The
views from the Ochils over east Clackmannanshire are very beautiful. Modern developments
are highly visible, invariably ugly houses squeezed together, large areas of concrete and
fail to fit harmoniously into the landscape. Developers make more money by selling more
houses, so the smaller the plot, the more houses they can build .. but that means small
gardens. The LDP proposes considerable development in east Clackmannanshire, before the
SLA reviews. This is yet another reason why the LDP Action Plan should delay early large-
scale development.

Renewable energy, wind energy
I am concerned that the Council should take into account upcoming improvements in
technology in wind energy capture in particular. We are aware of new types of wind energy
capture which are very much more productive (over 10 times more productive, with a
fraction of the intermittency of current turbines) than the current mast designs; they have a
very different footprint and do not involve masts towering into the air.
C. Macdonald, February 2014