LDP Response, CAM

Changes sought
Review of the Action Programme in light of climate change considerations, economic
strategy points raised in LDP representation

Representation: LDP draft Action Programme
I thank Clackmannanshire Council for the opportunity to comment on the LDP and
associated Action Programme, 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).


Properly addressing climate change consequences need to delay
Action Programme
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 cannot see how
development can be sustainable, unless it takes account of the factors highlighted in my LDP
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.

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.

The Action Programme 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.

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. The LDP proposes
considerable development in east Clackmannanshire, before the SLA reviews. This is
another reason why the LDP Action Plan should delay early large-scale development.