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1.1 We were pleased to be invited to participate in this Hearing, as the proposals have a number of implications for our communities. 1.2 We found the process both interesting and informative, but remain somewhat perturbed by the manner in which Strategic Land Allocations seem to be developed and implemented by Fife Council. The two concepts of ‘restoring balance to Dunfermline’ and ‘reviving the town centre’ are regularly repeated as justification for the huge schemes now planned for the south west and north west of the town. 1.3 ‘Restoring balance’ could mean a ‘Dunfermline West’ expansion to match the nightmare of ‘Dunfermline East’; and while ‘a revived town centre’ is a worthy aspiration, we contend that it is no more likely to happen with a westward expansion than it did with an eastward expansion. The stark truth is that increasing numbers of people shop in retail parks or on the internet, and the struggle for survival of small shops is a nation-wide problem. The fact that Dunfermline is also on a hill, means that, no matter which direction you come from, you face a gradient. No amount of creative thinking can sort that out. What is, however, very clear is that Dunfermline West will be yet another dormitory town for Edinburgh. 1.4 Land availability. Planners are clearly constrained in their ‘grand design’ by availability of willing sellers. The fiasco over the assumptions that had been made over the Logie Estate holdings clearly illustrates this! It is unfortunate for us, and for the prime agricultural (porridge-producing) land that is Broomhall, that this huge parcel of land has a willing seller. 1.5 In view of the challenges alluded to below, that are posed by the timely provision of appropriate infrastructure, we can see merit in releasing other smaller parcels of land where infrastructure is more easily developed. Perhaps the idealism of the grand design should be tempered with reality.

2. Impact and Implications of the Dunfermline South West SLA (DUN84) BROOMHALL for the Transport Network . 2.1 It would appear that a proposed Grange Drive Link Road from Queensferry Road is not scheduled to be in place until at least 2016; and the West Dunfermline Peripheral Road heading west and north looks increasingly uncertain, following withdrawal of the Logie Estate land that previously featured in the SLA west urbanisation plan.

2.2 It is proposed that access to the initial urbanisation scheme of 789 houses will depend on two existing roads - Limekilns Road (B 9156), and Grange Road (unclassified). Even before the first house is built, access to the site will be required by construction traffic. Access along these roads is subject to severe restrictions as described below. 2.3 Access via Limekilns Road. From the north, entry to Limekilns Road is either from the Coal Road, which is unsuitable for large vehicles, or from Nethertown Street and Forth Street, which is narrow with on-street parking. The route is also subject to an 18 tonne weight restriction over the Lyne Burn. 2.4 Access via Grange Road. Access to Grange Road from the North is also from Nethertown Street via Elgin Street, which leads to Grange Road under a height-restricted (11' 6”) railway bridge ( appendix 1). Clearly, neither access route from the north is satisfactory for construction traffic. 2.5 From the south, the access is off the busy A985. The Limekilns Road junction with the A985 is offset with restricted visibility. Access to Grange Road is by way of the narrow twisting Brankholm Brae. Furthermore, the proposed ‘Hilton’ development to the east of Brankholm Brae will cause even more congestion. With justification, Grange Road has been dubbed as one of the most dangerous roads in West Fife and unsuitable for construction traffic (appendix 2). 2.6 There are no cross connections between Limekilns Road and Grange Road between the A985 and Dunfermline. Provision of the Grange Drive Link Road from Queensferry Road, or an alternative access from the south, is essential before construction traffic can safely gain access. A suggestion by the Transport Officer, that a link could be engineered from Limekilns Road through the Elgin Industrial Estate, would not, of course, alleviate the access problems noted above, as the exit onto Elgin Street is on the wrong side of the heightrestricted bridge at the north end of Grange Road. 2.7 The Traffic Assessment for the proposed container terminal suggests that the A985 will be ‘at capacity’ by 2017. Whether it is Forth Road Bridge construction, a proposed Biomass plant, a fish packing factory, a proposed container terminal or residential development at ‘Hilton’, it seems that ‘everyone’ thinks that ‘their’ project won’t make a difference. Our community is very aware of how difficult it already is to join a busy road that is already approaching ‘capacity’. Assessment of cumulative impact is an essential requirement of the Scottish Planning system, and cannot be ignored when it comes to impact on the A985. 2.8 The building of 789 houses and the development of 32.8 hectares of employment land will generate a huge volume of additional traffic on Grange Road and Limekilns Road. There is already considerable congestion at the junction of Elgin Street and Nethertown Street on week days and the suggestion by the Transport Officer at the Hearing that altered phasing of the traffic lights is the solution, would be more likely to back up traffic on the even-busier east-west route along Nethertown Broad Street. 2.9 Grange Road has a bad accident history (appendix 3). Over the years, there have been several proposals to improve safety, initially by restricting its use to cyclists and pedestrians,

then by restricting it to a single track and, recently, using speed restriction measures. The Traffic Officer at the Hearing indicated that, as part of the Broomhall scheme, Grange Road would be upgraded along part of its length to 'Street' grade, the implication being that parts of it might remain as hazardous as it is now. 2.10 While the concept of ‘walkable neighbourhoods’ and pedestrian and cycle access to the town centre is a laudable aspiration, walking from the Broomhall site is not a feasible proposition for most folk – in view of the distance and the gradient. Moreover, fundamental alterations would be needed to make any such venture attractive. For instance, beneath the railway bridge at Elgin Street, large puddles are a hazard to pedestrians and the single pavement is not suitable for both pedestrians and cyclists. A functioning Grange Drive Link Road could alleviate those problems and should be in place before urbanisation of Broomhall. 2.11 It was with dismay that we heard the Transport Officer suggest that traffic congestion provides a means of inducing modal shift. The obvious implication seems to be that walking, cycling, or taking the bus will be the solution to traffic delay. This alternative may not be an option for the elderly and infirm. There will also be implications for emergency vehicles and bus timetables, which will be subject to the same congestion delays as cars.


Boundary of Broomhall SLA. 3.1. We do not have a fundamental problem with the proposal by Stirling Developments to alter the southern boundary, if the additional land can be used to provide greater scope in the master-planning process and in the provision of a corridor of green space and woodland for free movement of both public and wildlife. We are, however, not at all content that this bounty of additional land allocation should tempt Stirling Developments to think that they can accommodate additional housing units which had hitherto been allocated to the Liggars Bridge SLA, or indeed from anywhere else. 3.2. We believe that the existing line of the Limekilns Road is an appropriate western boundary for the development. Freeing Gallowridge from any development would preserve an important vista of historic Dunfermline

4. Proposal for Employment land west of Rosyth 4.1 We totally oppose any allocation of employment land on either side of the A985 west of Rosyth for the following reasons: 4.2 If there were ever a need for additional employment land associated with a possible container terminal there is sufficient brown-field land available inside the Dockyard boundary. 4.3 It would overwhelm the rural settlements of Pattiesmuir and Hilton Farm Steadings.

4.4 It would compromise the distinctiveness of Limekilns.


Green belt east of Limekilns

5.1 We are not satisfied with the reasoning as to why the green belt north of the A985 should not be continued down to the River Forth to separate Limekilns from Rosyth.

6. ‘Consultation’ process 6.1 We repeat our dissatisfaction at our exclusion form effective consultation in the development of the concept of Strategic Land Allocations at the Structure Plan Stage. A clear intention of ‘Modernising the Planning system’ was to enable people and communities to engage with plans at a stage where local opinions and perspectives can be taken into account.

Hearing Closing Statement