Issue 13 New Urban Housing Proposals

Issue 13 New Urban Area Housing Proposals

HSG 28 Ellen’s Glen Road Reporter: HSG 30 Moredunvale Development plan HSG 31 Curriemuirend reference: GS10 Curriemuirend

Body or person(s) submitting a representation raising the issue (including reference number): 31 individuals seeking removal of HSG 0494 Eleanor Burns 28 Ellen’s Glen Road (see Issue 13 0833 Roseann Ferguson Appendix A) 1064 Malbet and Yewlands Residents Association 109 individuals seeking removal of 1127 G Watson HSG 30 Moredunvale (see Issue 13 1213 Friends of Currimuirend Park Appendix B) 1221 Moredun 4 Multis Residents Association 719 individuals seeking removal of 1213 Friends of Currimuirend Park HSG 31 Curriemuirend (see Issue 13 1226 Goodtrees Neighbourhood Appendix C) Centre 1554 Wester Hailes Community 58 individuals seeking removal of HSG Council 31 and GS10 (see Issue 13 Appendix 1638 Juniper Green/Baberton Mains D) Community Council 1755 Cairn Housing Association Organisations, elected representatives 1849 Roy Brown and individuals other than those in 2006 Liberton & District Community Appendices A, B and C Council 2126 Cockburn Association 0020 Allan Millar 2133 R MacKay 0046 Dorothy Curr 2189 Currie Community Council 0124 sportscotland 2195 W Blair 0145 Douglas Webb 2199 S Blair 0155 Catherine Webb 2233 E Beevers 0161 Mary Sandilands 2237 Cliff Beevers 0170 Balerno Community Council 2256 and Lothian’s Health 0184 Curriemuirend Park Allotment Foundation Association 2494 Lisa Browning 0305 Colinton Amenity Association 2502 Neil Thomson 0321 Ratho & District Community 2662 Ian Murray MP Council 2697 Scottish Natural Heritage 0370 Malcolm Stewart 2699 Scottish Environment Protection 0391 Mr & Mrs Holman Agency 0418 John Smith 2706 Juniper Green Community 0448 Roy McCluskey Council 0475 Tim Kingwell 2716 NHS National Services 0480 Currie East Neighbourhood Watch

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Provision of the These provisions of the Plan deal with the proposals for development plan to new urban housing allocations (HSG 28 Ellen’s Glen which the issue Road, HSG 30 Moredunvale, HSG 31 Curriemuiend relates: Park) and greenspace proposal GS10 Curriemuirend. Plannin g authorit y’s summar y of the representation (s):

CONTEXT

The Main Issues Report in Question 7 sought views on four proposals for housing on areas of Council-owned green space to be accompanied by reduced but better quality green space. The first Proposed Plan included proposals on two of these sites – at Moredunvale Road and Curriemuirend, with indicative capacities.

The Second Proposed Plan retains these two proposals, with updated capacity estimates. It also allocates a new site, at Ellen’s Glen Road, which involves loss of open space.

Representations seeking removal of HSG 28 Ellens Glen Road

Seek removal of HSG 28 on the grounds of one or more of the reasons listed below: • Principle – representations object on the grounds of loss of green space, agricultural land and biodiversity at Stenhouse Market Gardens. Object on the grounds of pressure on existing open space which residents of Malbet Park maintain. Object on the grounds of impact on the ‘Mount Alvernia’ (85 Lasswade Road and 1-8 (Inclusive Nos.) former Convent of the Poor Clares Collettines boundary wall and trees. • Transport infrastructure – representations object on the grounds of traffic congestion, access arrangements, including the proposed access off Malbet Wynd. Object on the grounds that access through Liberton hos pital is speculative; access should be provided off Lasswade Road and access off Malbet Park is already a bottleneck. Object to the proposed new cycle path because of anti-social behaviour. • School infrastructure – representation s object on the grounds of the impact on schools capacity, and identify the need for a new school. • Community Facilities - representations object on the grounds of the impact on GP surgeries. • Flooding, sewage, subs idence and residential amenity – representations object on the grounds of that the developmen t will make these problems more frequent. Object on the grounds of amenity dayligh t and privacy, overlooking and loss of view, environmental health issues, pollution and street lighting. • Cottage Flats – object on the grounds that this is not defined in the glossary.

(1 064 Malbet and Yewlands Residents Association; 2006 Liberton & District Community Council; 2126 Cockburn Association; 2662 Ian M urray MP; and individuals listed in Appendix A)

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Representations opposed to HSG 28 Ellen’s Glen Road in current form and seeking its removal and/or change:

• Proposes re-examination is necessary in relation to the potential density of the site and parking and traffic movements generated from the development (0494 Eleanor Burns) • Objects on the grounds that the scale of development is not in-keeping with the existing housing density (1127 G Watson) • The mix of housing to be provided should be dictated by the market at the time of the planning application. Table 4 should show an indicative maximum capacity for HSG 28 Ellen's Glen Road to allow the market to dictate density (2716 NHS National Services Scotland) • Objects on the grounds of pollution, impact on wildlife, impact on biodiversity and traffic congestion. Concerned over potentia l damage to trees and ‘Mount Alvernia’ (85 Lassw ade Road and 1-8 (Inclusive Nos.) - former Convent of the Poor Clares Collettines boundary wall. (249 4 Lisa Browning; 2502 Neil Thomson)

Support the allocation of HSG 28 Ellen’s Glen Road

• Welcomes the allocation of proposal HSG 28 Ellen's Glen Road and has no objection to the development principles. Th e open space portion of the site at Stenhouse Market Gardens is effective (2256 Edinburgh and Lothian’s Health Foundation) • Supports the allocation of HSG 28 Ellen’s Glen Road ( 0448 Roy McCluskey)

Representations seeking removal of HSG 30 Moredunvale

Seek removal of HSG 30 on the grounds of one or more of the reasons listed below:

• Site selection – loss of open space / green space and the resulting pressure on the existing open space and impact on health. • Transport infrastructure – additional housing will mean that the surrounding roads will not be able to cope. • School infrastructure –impact on schools capacity and requ est a new school. • Community Facilities - GP surgeries and dentists. • Flooding, sewerage, subsidence and imp act on residential amenity including the impact on neighbours, daylight, overshadowing, and loss o f privacy including a loss of view.

(1221 Moredun 4 Multis Residents Association; 1226 Goodtrees Neighbourhood Centre and individuals appendix B)

Representations opposed to HSG 30 in current form and seeking its removal and/or change

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• Objects on the grounds of the previous loss of a car park at Goodtree Terrace (0020 Allan Millar) • From the aerial imagery it appears that the site includes a grass football pitch with goals, while it is not clear what size this pitch is it may be appropriate to include reference to the need to reprovide a sports pitch . (0124 sportscotland) • Objects on the grounds of above, suggests housing could be built at the Edinburgh BioQuarter instead. (0475 Tim Kingwell) • Objects on the grounds of lack of information on whether the proposal impacts on open space provision. (2126 Cockburn Association) • Welcome the provision for HSG 30 Mo redunvale include “opportunity to create links to the wider green network”, but more links should be created to the south (2697 Scottish Natural Heritage) • This proposed site is located within functional flood plain or an area of known flood risk. As such, a flood risk assessment will be required to assess the risk from the Niddrie Burn. The northern perimeter of the site lies within the Areas of Importance for Flood Control and Fluvial Flood Risk Area (2699 Scottish Environment Protection Agency)

Representations seeking removal of HSG 31 Curriemuirend

Seek removal of HSG 31 on the grounds of one or more of the reasons listed below:

• Principle - representations object on the grouds of greenfield development, loss of agricultural land, that the proposa l is contrary to SDP’s Spatial Strategy, and coalescence between communities. • Open space and biodiversity - representations object to the loss of op en space, millennium woodland and amenity space. Representations are concerned about why is there a need to upgrade the football pitch; open space improvements at Clovenstone can not be considered cre dible and do not justify the loss of millennium woodland. Representations suppor t the provision of an off road cycle track. • Feasibility study - representations query the viability of the development based on a feasibility study carried out by the Council in regards to the site. • Transport Infrastructure – representations object to the impact of the development on traffic congestion at Gillespie Crossroads and Lanark Road as well as response times of emergency services. References appeal decision for site in Balerno wh ich referred to Gillespie Crossroads (reference PPA – 230 – 2112). Representations object to the Development Principles with regards to the opportunity in the to reduce Wester Hailes Road to one carriageway. Concerned over road safety along Wester Hailes Road if the development creates an active frontage; the speed limit should be reduced from 40 to 20mph to compensate. • School infrastructure – representations object on the basis that local schools do not have sufficient capacity for extra children. • Community facilities – representations object in regards to the impact on GP surgeries

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(0170 Balerno Community Council; 0184 Curriemuirend Park Allotment Association; 0305 Colinton Amenity Association; 0321 Ratho & District Community Council; 1213 Friends of Currimuirend Park; 1554 Wester Hailes Community Council; 1638 Juniper Green / Baberton Mains Community Council; 1755 Cairn Housing Association; 2126 Cockburn Association; 2189 Currie Community Council; and individuals in Appendix C)

Representations opposed to HSG 31 Curriemuirend in current form and seeking its removal and/or change

• Objects to proposal and suggests developing other sites such as East of Millburn Tower (0046 Dorothy Curr; 2133 R MacKay; 2195 W Blair; 2199 S Blair) Edinburgh Park (0145 Douglas Webb; 0155 Catherine Webb; 0161 Mary Sandilands) or The Gyle (0391 Holman) • The cumulative impact of 800 houses with the Juniper Green / Currie / Balerno area, inclusing HSG31 Curriemuirend Park would need additional traffic infrastructure on Calder Road. The Currie/Balerno bypass safeguard (T7) in the Rural We st Edinburgh Local Plan should be re-instated. (0480 Currie East Neighbourhood Watch) • Objects on the grounds of site layout and use of a cul-de-sac, access from one entry point, environmental impact, loss of open space and impact on biodiversity. Concerned over football pitch provisions (1849 Roy Brown) • Notes incorrect referencing of GS10 and HSG29, incorrect ass essment of Curriemuirend as a play park, not a wildlife park and considers it should be graded as high quality on that basis (1213 Friends of Currimuirend Park). • Provides comments on HSG 31 site brief in relation to pedestrian and cycle links. Reference to representation on terms used in paragraphs 46 and 280 of Scottish Planning Policy. (2697 Scot tish Natural Heritage)

Representations opposed to GS10 Curriemuirend in current form and seeking its removal and/or change

• Objects on the grounds of loss of woodland and impact on biodiversity. Concerned that local residents will not benefit from new play area and details of upgrading of footba ll pitch have not been detailed (0370 Malcolm Stewart) • Objects on the grounds of loss of natural play space and enhancement of facilities is not guaranteed (418 John Smith) • Objects on the grounds of environmental impact, in particular th e loss of trees (0833 Roseann Ferguson) • Objects on the grounds of whether the existing facilities will be enhanced and there are no clear deta ils of proposed changes (2233 E Beevers) • Objects on the grounds of there are no guarantees that the facilities will be enhanced and adequate detailed information is not available (2237 Clif f Beevers)

Representations seeking removal of HSG 31 Curriemurend Park and GS10 Curriemuirend

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Seek removal of HSG 31 and GS 10 on the grounds of one or more of the reasons listed below:

• Open space and biodiversity Representations object to the loss of open space, millennium woodland and am enity space. Representations are concerned about why is there a need to upgrade the football pitch; open space improvements at Clovenstone can not be considered credible and do not justify the loss of millennium woodland. Representations support the provision of an off road cycle track. • Transport Infrastructure – representations object to the impact of the development on traffic congestion at Gillespie Crossroads and Lanark Road as w ell as response times of emergency services. References appeal decision for site in Balerno which referred to Gillespie Crossroads (reference PPA – 230 – 2112). Representations object to the Develop ment Principles with regards to the opportunity in the to reduce Wester Hailes Road to one carriageway. Conc erned over road safety along Wester Hailes Road if the development creates an active frontage; the speed limit s hould be reduced from 40 to 20mph to compensate.

(1638 Juniper Green/Baberton Mains Community Council, 2706 Juniper Green Community Council and individuals in Appendix D)

Modifications sou ght b y those submittin g representations:

Representations seeking removal of HSG29 Ellen’s Glen Road

• Remove proposal from the Plan,

(1064 Malbet and Yewlands Residents Association; 2006 Liberton & District Community Council; 2126 Cockburn Association ; 2662 Ian Mu rray and individuals in appendix A)

Representations opposed to HSG29 Ellen’s Glen Road in current form and seeking its removal and/or change

• Re-examine proposal in relation to the potentia l density of the site and parking and traffic movements generated from the development. Infrastructure actions need to be identified and be in place to accommodate the development (494 Eleanor Burns) • N umber of houses should be reduced to be in-keeping with existing development ( 1127 G Watson) • Development Principles should be re-worded to state 'a mix of family style housing in the context of the locale'. Table 4 should read 'indicative maximum capacity of 260 units' (2716 NHS National Services Scotland) • Seeks clarity that there is no impe diment to develop land at Stenhouse Market Gardens which falls under the Ellen's Glen Road site brief in advance of the larger site (2256 Edinburgh and Lothians Health Foundation) • Remove land behind the fo rmer ‘Mount Alvernia’ (85 Lasswade Road and 1-8 (Inclusive Nos.) former Convent of the Poor Clares Collettines from the Issue 13 Page 6 of 19

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Plan (2494 Lisa Browning; 2502 Neil Thomson)

Representations seeking removal of HSG30 Moredunvale

• Remove proposal from plan (1221 Moredun 4 Multis Residents Association; 1226 Goodtrees Neighbourhood Centre; 2126 Cockburn Association and individuals in Appendix B)

Representations opposed to HSG30 Moredunvale in current form and seek ing its removal and/or change

• Remove housing proposal and build a new car park (0020 Allan Millar) • Insert new bullet point to HSG 31 Moredunvale "reprovision of sports pitch" (0124 sportscotland) • Suggests housing could be built at the Edinburgh BioQuarter instead. (0475 Tim Kingwell) • Applicants should explore opportunities to link south beyond the pro posed allotments. Without this link the proposed development appears likely to decrease accessibility to greenspace for adjacent communities to the south (2697 Scottish Natural Heritage) • Amend Table 4 and the Development Principles on page 67 to refer to the requirement for a flood risk assessment to be carried out to inform the design and layout of the finalised scheme. The assessment would need to consider any bridges adjacent and downstream of th e site and any work downstream at Greendykes (2699 Scottish Environment Protection Agency)

Representations seeking removal of HSG31 Curriemuirend

• Remove proposal from the Plan.

(170 Balerno Community Council; 184 Curriemuirend Park Allotment Association; 305 Colinton Amenity Association; 321 Ratho & District Community Council; 1150 Bill Henderson; 1213 Friends of Currimuirend Park; 1554 Wester Hailes Community Council; 1638 Juniper Green/Baberton Mains Communit y Council; 2706 Juniper Green Community Council and individuals in Appendix C)

Representations opposed to HSG31 Curriemuirend in current form and seeking its removal and/or change

• Suggests developing other sites such as East of Milburn Tower (0046 Dorothy Curr; 2133 R MacKay; 21 95 W Blair; 2199 S Blair) Edinburgh Park (0145 Douglas Webb; 0155 Catherine Webb; 0161 Mary Sandilands) and The Gyle (0391 Holman) • Table 9 should include a reference to transport improvements in the Juniper Green / Currie / Balerno area to ensure the existing road network and safety related issues are significantly improved before any additional housing is permitted. Asks that the Currie/Balerno bypass safeguard (Safeguar d T7 ) in the Rural West Edinburgh Local Plan be re-instated in

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the Plan. No new housing development ahould be allo wed until the bypass is built. (480 Currie East Neighbourhood Watch) • Notes incorrect referencing of GS1 0 and HSG29 in the Plan. Curriemuirend Park should be assessed as a wildlife park rather than a play park in the Open Space Audit. It should be graded as a high qua lity wildlife park. (1213 Friends of Currimuirend Park) • Remove proposal from plan, the ite layout and use of a cul-de-sac, acces s from one entry point is contrary to policy (1849 Roy Brown) • Recommends that the site brief shows an indicative path route t hrough the allotments linking to Clovenstone Drive. Bullet poi nt 4 should clarify what 'better pedestrian cycle access' is. Sggest that this is phrased in the terms used in paragraphs 46 and 280 of Scottish Planning Policy. (2697 Scottis h Natural Heritage)

Representations seeking removal of GS 10 Curriemuirend

• Remove proposal from the Plan.

(0370 Malcolm Stewart; 0418 John Smith; 0833 Roseann Fergu son; 2233 E Beevers; 2237 Cliff Beevers)

Representations seeking removal of Hsg 31 and GS 10 Curriemuirend

• Remove proposal from the Plan.

(1638 Juniper Green/Baberton Mains Community Council and Individuals in Appendix D)

Summar y of responses (includin g reasons ) by plannin g authorit y:

Representations seeking removal of HSG 28 Ellen’s Glen Road

• Principle. The site has been allocated in the Plan to establish the principle of a co-ordinated housing development across two adjoining sites, one of which involves the loss of open space. These two sections of the site were identified by a representation to the first Proposed Plan regarding development on the open space, and through the LDP Housing Land Study (June 2014), which identified brownfield land p otentially available for development (see page 13). The open space is ident ified as such in the Open Space Audit (2009,referenc e ‘NAT 35’). The loss of currently inaccessible semi-natural green spac e would not be detrimental to the wider network open space and the value of established trees to biodiversity, local character and amenity would be assessed against Policies Des 3 and Env 12. The Develop ment Principles on Page 66 of the Plan require the alternative provision of open space to be provide d as part of the development in the form of a new local greenspace to meet the Council’s Local Greenspace Standard (Open Space Strategy pages 12-13) • Transport infrastructure . As part of the Local Development Plan process, the Council has carried out a Transport Appraisal. (Volumes 1 and 2 , 2013, Addendum, 2014) Page 44 of the Addendum summarises the findin gs for

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this site. The TA identifies improvements to transport infrastructure to deal with the net impact of new housing proposals in South East Edinburgh. The transport actions for HSG 28 are set out in the Council’s Proposed Action Programme on Page 32 and include upgrading bus stops on Lasswade Road and Gilmerton Road and new pedestrian and cycleway access. The detail of these actions is being established through transport asse ssments required at the planning application stage. In terms of access points, the development principles indicate two access points for HSG 28 to allow for HSG 28 to come forward for development in advance of Liberton Hospital. HSG 28 is to make provision for an access to be taken off Lasswade Road if the Liberton Hospital was to come forward for development. A proposed new cycle / footpath is proposed to increase the modal share of walking and cycling. All relevant proposals will be required to make approp riate contributions to new and improved infrastructure in line with relevant policies and guidance. • School infrastructure. As part of the Plan process, the Council has prepared a Revised Education Appraisal June 2014 (corrected Sept ember 2014) which identifies the improvements to school infrastructure to deal with the net impact of new housing proposals in South East Edin burgh. Ellen’s Glen Road has been assessed within the Liberton and Gilmert on Contribution Zone, pages 16-20. For HSG29 Ellen’s Glen Road a ratio of 60:40 flats to house has been assumed to reflect the surrounding area and nature of the site. The type of development and pupil generation will be monitored as planning applications are received and, if necessary, any required changes will be reflected in the Action Programme. • Community facilities. The Plan in paragraph 72 acknowledges that housing proposals will have implications for the provision of primary healthcare and other community health services. Policy Hou 10 Communit y Facilities seeks to ensure that where practical and reasonable a range of community facilities is provided with new housing development.

The Plan identifies where non-residential units should be provided in new housing sites which could provide potential premises for new health practices. Paragraph 130 of the Plan states that developer contributions to measures intended to mitigate the net effects of development, other than actions identified in the Action Programme, may also be required.

The Council has discussed all growth allocations with the relevant part of the NHS Lothian. This has assessed the need for new and expanded general practitioner practices to accommodate the planned housing grow th set out in the Second Proposed Plan No specific actions have been included in the Action Programme at this time, however when suitable and specific actions are iden tified these will be included in future iterations of the Action Programme. Where these are needed to address demand arising from new development, financial contributions towards the cos t may be sought in line with relevant policies and guidance. • Drainage and flood risk . In preparing a Local Development Plan, the Council must consider the impact of development on flood risk. The new Local Development Plan proposals have been assessed strategically for flood risk using a fluvial flood risk map showing areas at medium-to-high

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te r incorporation of sustainable urban drainage systems, as required by Plan Policy Des 6. Policy Env 21 provides further measures against the risk of flooding to new development. • Impact on listed buildings and trees. At masterplan and planning application stage development in would be assessed against its impact upon the existing listed buildings and their curtilage at ‘Mount Alve rnia’ (85 Lasswade Road and 1-8 (Inclusive Nos.) -former Convent of the Poor Clares Collettines, including gatepiers and boundary walls). Notwithstanding historic environment considerations, Policy Des 4 on Development Design – Impact on Setting would apply. The development principles also provide for tree retention on site to be determined in accordance with Policy Env 12 – Trees. • Cottage Flats – it is acknowledged that the term ‘cottage flats’ is not commonly used or widely know. If the Reporter was minded, the Co uncil would see merit it its omission from the Ellen’s Glen Road Road Development Principles on Page 66.

No mo dification proposed.

(1064 Malbet and Yewlands Residents Association; 2006 Liberton & Distric t Community Council; 2126 Cockburn Association ; 2662 Ian Murray and in dividuals in appendix A)

Repres entations opposed to HSG28 Ellen’s Glen Road in current form and seekin g its removal and/or change

• The density assumption at HSG 28 Ellen’s Glen Road h as been based on the Council’s Housing Land Study (June 2014). The study on Page 12 identifies a range of densities for sites over 1ha based on the surroundi ng area. For Ellen’s Glen Road this has been set at 65 dwellings per hectare based on a mix of houses and flats similar to the recent ‘Evolution’ development at Gracemount which has similar accessibility characteristics . The capacity range in Table 4 therefore identifies a range of 220 – 260 on a 4 hectare site. The actual number and type of units will be determined at the planning application stage. No modification proposed. (494 Eleanor Burns, 1127 G Watson, 2716 NHS National Services Scotland) • In order to establish a principle of a co-ordinated housing development which involves the loss of some open space, the whole site has been allocated as a h ousing proposal in the Plan. It is proposed to allocate the area of open space at Stenhouse Market Gardens (Malbet Wynd) for housing as part of a wider housing allocation on the adjacent land which is currently occupied by the blood transfusion centre at Liberton Hospital. The blood transfusion centre is to relocate to Riccarton Campus. This remo ves the open space policy impediment on the land at Stenhouse M arket Gardens. No modification proposed. (2256 Edinburgh and Lothians Health Foundation; 2494 Lisa Browning; 2502 Neil Thomson)

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Representations seeking removal of HSG 30 Mor edunvale

• Principle. The Council’s regeneration priorities are to ensure that peo ple live in well designed, resilient, supportive and safe communities with access to services and amenities. To help deliver these, the Cou ncil in preparing this Plan has sought potentia l investment opportunities for new housing and environmental improvements on Council-owned land. These included four potentia l sites for new housing development on existing open space. These were presented in the Main Issues Report (page 21 and Question 7) as opportunities for new housing and smaller but better quality areas of open space. Views were sought on the principle of allocation in the Plan, or continued alloc ation of the sites as open space with potential for any proposals to be considered as planning applications. This approach is consistent with advice on local authority interest development. Where a local authority intends to pursue or support particular development projects such as housing on Council owned land, particularly green space, they ought to be proposed, consulted on and agreed through the Local Development Plan. This ensures that the authority’s intentions are clearly known from the outset, allowing for any necessary public debate and scrutiny of local authority proposals as part of the wider considerations of the future planning of the area. Planning Advice Note 82 paragraphs 12-14 and Scottish Planning Policy paragraphs 230-231 are relevant. The responses are set out in the Summary of Responses to the Main Issues Report, April 2012 (pages 80-84). They included qualified support for the Council’s proposals.

The Development Principles on Page 67 of the Plan identify the loss of h alf of the site for housing development, and to improve the quality of the remaining open space. The Open Space Audit (2009, reference ‘AM 72’) identifies the site as a publicly accessible residential amenity space of ‘fair’ quality. The Plan proposes that the development provides better quality play space, allotments and growing spaces as greenspace improvements to the area. In addition, there are other areas of open space in the vicinity of the site which are to be upgraded or provided through the Open Spac e Strategy including Gilmerton Park located to the South and the South E ast Wedge parklands to the east. In this way, the proposal would result in provision of smaller but better greenspace which wou ld provide a higher quality of provision to local residents. Impact on residential amenity of adjacent housing arising from effects on daylight, privacy and sunlight is a matter of detailed design and would be addressed at the masterplan and planning application stage. • Feasibility study and site layout. As Moredunvale Road is Council- owned and to ensure that site can be made effective during the relevant time period, in this case up to 2024, the Council commissioned feasibility work. This feasibility study took one option for the design, layout, height type of properties for feasibility assessment only. The detailed design and layout will be addressed at the masterplanning and and planning application stage. • Transport infrastructure. As part of the Local Development Plan process ,

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the Council has carried out a Transport Appraisal. (Volumes 1 and 2, 2013, Addendum, 2014) This appraised the cumulative impact of the new developments proposed in the Plan, taking account of other factors. This identifies improvements to transport infrastructure to deal with the net impact of new housing proposals in South East Edinburgh, including this site. These transport actions are set out in the Council’s Proposed Action Programme on Page 36. For HSG 30 Moredunvale, the actions include improving pedestrian and cycle facilities within the area. The detail of this action will be established through transport assessments required at the planning application stage. All relevant proposals will be required to make appropriate contributions to new and improved infrastructure in line wit h relevant policies and guidance. • School infrastructure. As p art of the Plan process, the Council has prepared a Revised Education Appraisal June 2014 (corrected September 2014) which identifies the improvements to school infrastructure to deal with the net impact of new housing proposals in West Edinburgh. Thes e Education actions are set out within the Council’s Proposed Action Programme. For HSG 30 Moredunvale these actions are set out on pages 24-27 of the accompanying proposed Action Programme. They include a contribution requirement towards additional capacity within both the non- denominational and denominational primary and high school estate. This includes two new primary schools at Broomhills (ND) primary school (SCH 8) and New Gilmerton South (ND) primary school (SCH 7) and an extension to either Liberton or . All proposals will be required to make appropriate contributions to new and improved infrastructure in line with relevant polic ies and guidance. • Community facilities. The Plan in paragraph 72 acknowledges that housing proposals will have implications for the provision of primary healthcare and other community health services. Policy Hou 10 Community Facilities seeks to ensure that where practical and reasonable a range of community facilities is provided with new housing development.

The Plan identifies where non-residential units should be provided in new housing sites which could provide potential premises for new health practices. Paragraph 130 of the Plan states that developer contributions to measures intended to mitigate the net effects of development, oth er than actions identified in the Action Programme, may also be required.

The Council has discussed all growth allocations with the relevant part of the NHS Lothian. This has assessed the need for new and expanded general practitioner practices to accommodate the planned housing growt h set out in the Second Proposed Plan No specific actions have been included in the Action Programme at this time, however when suitable and specific actions are identified these will be included in future iterations of the Action Programme. Where these are needed to address demand arising from new development, financial contributions towards the cost ma y be sought in line with relevant policies and guidance. • Flooding, sewerage, subsidence and impact on residential amenity In preparing a Local Development Plan, the Council must consider the impa ct of development on flood risk. The new Local Development Plan proposals

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have been assessed strategically for flood risk using a fluvial flood risk map showing areas at medium-to-high risk (i.e. a 1-in-200 year event) (Fig ure 3 of the Environmental Report Volume 1, page 21 and Volume 2 page 52) The portion of the site which is at risk from fluival flooding is the northern corner, which is not identified for development in the Development Principles on page 67. The issue of flood risk for all developments, n ot just Plan proposals is addressed through Policy Env 2. Sewage, subsidence and other environmental issues including the impact on residential amenit y is addressed through Policy Env22. The Moredunvale Development Principles on Page 67 identify that remediation work may be required to develop the site due to the history of coal and limestone mining.

No modification proposed.

(1221 Moredun 4 Multis Residents Association; 1226 Good trees Neighbourhood Centre; 2126 Cockburn Association and individuals in Appendix B)

Representations opposed to HSG30 Moredunvale in current form and seeking its removal and/or change

• It is not considered that previous changing to parking provision are an is sue for this Development Plan. (0020 Allan Millar) • F ormal sports pitch provision is identified in the Open Space Audit (2009). It identifies those pitches which are maintained as such for communities schools and sportsclub use. This is not such a location, and no formal sports pitch is recorded. Goodtrees Playing Field lies to the west of the site and Goodtrees Neighbourhood Centre. Requirements for new playing fields are set out in the Council’s Physical Activity and Sport Strategy (2014) No modification proposed. (0124 sportscotland) • Approved Supplementary Guidance for the Edinburgh BioQuarter and South East Wedge Parkland allows for residential development provided that it helps to develop a “mixed use, urban quarter”, an aim of the SG. An y residential development should contribute to the overall aims for density, mixed uses and urban form and should not take place on isolated sites. No modification proposed. (0475 Tim Kingwell) • There are substantial changes in level across the land to the south of the site. Any masterplan submitted, would be assessed against the requirements of Policy Des 7 – Layout Design, in terms of the comprehensive approach to the layout of built form, streets, paths and open spaces. This is further illustrated on pp 27-30 of the Edinburgh Design Guidance. This should not result in a detriment al effect on access to greenspace for communities to the south of Moredun Park Road. No modification proposed. (2697 Scottish Natural Heritage) • In preparing a Local Development Plan, the Council must consider the impact of development on flood risk. The new Local Development Plan proposals have been assessed strategically for flood risk using a fluvial flood risk map showing areas at medium-to-high risk (i.e. a 1-in-200 year event) (Figure 3 of the Environmental Report Volume 1, page 21 and Volume 2 page 52) The portion of the site which is at risk from fluival flooding is the northern corner, which is not identified for developme nt in Issue 13 Page 13 of 19

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the Development Principles on page 67. The issue of flood risk for all developments, not just Plan proposals is addressed through Policy Env 2 . Sewage, subsidence and other environmental issues including the impact on residential amenity is addressed through Policy Env 22. The Moredunvale Development Principles on Page 67 identify that remediatio n work may be required to develop the site due to the history of coa l and limestone mining. • ( 2699 Scottish Environment Protection Agency)

Principle - HSG31 Curriemuirend and GS10 Curriemuirend • The Council’s regeneration priorities are to ensure that people liv e in well designed, resilient, supportive and safe communities with access to services and amenities. To help deliver these, the Council in preparing this Plan has sought potential investment opportunities for new housing and environmental improvements on Council-owned land. These included four potential sites for new housing development on existing open space. These were presented in the Main Issues Report (page 21 and Question 7) as opportunities for new housing and smaller but better quality areas of open space. Views were sought on the principle of al location in the Plan, or continued allocation of the sites as open space with potential for any proposals to be considered as planning applications. This approach is consistent with advice on local authority interest development. Where a local authority intends to pursue or support particular development projects such as housing on Council owned land, particularly green space, they ought to be proposed, consulted on and agreed through the Local Development Plan. This ensures that the authority’s intentions are clearly known from the outset, al lowing for any necessary public debate and scrutiny of local authority proposals as pa rt of the wider considerations of the future planning of the area. Planning Advice Note 82 paragraphs 12-14 and Scottish Planning Policy paragraphs 230-231 are relevant.

The responses are set out in the Summary of Responses to the Main Issues Report, April 2012 (pages 80-84). They included qualified support for the Council’s proposals.

The Development Principles on Page 69 of the Plan require a comprehensive approach to both HSG 31 Curriemuirend and GS10 Curriemuirend to deliver proposed allotments and greenspace improvements in connection with new housing development. The Open Space Audit (2009, references ‘PG 64’ and ‘PG 63) identifies Curriemuirend Park as a publicly accessible community par k of ‘fair’ quality, and GS 10 as an unclassified park with no quality score. The Open Space Audit (2010) includes as an action the improvement of Curriemuirend Park to ‘good’ standard to meet Local and Large Greenspace Standards. As one of the Council’s parks, it has been a priority for maintenance. However, the potential of Curriemuirend Park to be a safe and pleasant place is fundamentally constrained by its lack o f natural surveillance, the barriers presented by major roads to its west and north-east and the reliance on unwelcoming underpasses for active travel through-routes. These constraints are a legacy of the original design o r Issue 13 Page 14 of 19

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greenspace and road engineering and cannot be readily overcome by further investment in Curriemuirend Park. The greenspace at Clovenstone Drive is more overlooked, has existing well-used and more welco ming through-routes, and therefore has greater potential to benefit from investment as a park.

The LDP proposals are for the inherent design problems of Curriemuirend Park to be addressed by its partial development for h ousing incorporating smaller, better greenspace, and for a major improvement in the greenspace at Clovenstone Drive (Proposal GS 10) to mitigate the overall reducation in quantity of greenspace.

The land is not green belt and does not have a role in preventing coalescence between different settlements. Loss of woodland would be required to be offset in accordance with Scottish Government’s Control of Woodland Removal Policy, including through street tree planting within the site, parkland trees at Clovenstone Drive and supplementary planting within the wider network of public open space. Enhancements to the existing open space at Clovenstone Drive will be required to demonstrate their value to conservation of natural features, wild fauna and flora, in lin e with the Council’s Park’s Quality Assessment. In additi on to the proposed allotments, new development should incorporate features to enhan ce biodiversity, in line with Des 3 Development Design – Incorporation and Enhancing Existing and Potential Features e.g. provision of nest boxes.

Repres entations seeking removal of HSG 31 Curriemuirend

• Feasibility study As Curriemuirend Park is Council owned and to ensure that site can be made effective during the relevant time period, in this case up to 2024, the Council commissioned feasibility work. The study concluded that the site was technical feasible to develop for housing, but th at the scheme in the study would not be financially viable at this point in time due to site constraints, risks, and planning principles associated w ith the development of this site. However, the financial appraisal does not an d cannot provide a view on the future viability of the site throughout the Local Development Plan period. Future viability will be dependent on economic circumstances, market conditions, the actual scheme a developer wishes to take forward and other factors which cannot be predicted at this time. Therefore the study does not rule out the viability and hence effective ness of the site over the next ten years, but it has confirmed the tech nical feasibility and potential capacity of the site. As a consequence , the Council has more information about the technical and economic feasibility of specific options for these two sites than about any other sites in the P lan. This is more than is needed for the approval of a Plan allocating those two sites. • Transport infrastructure - As part of the Local Development Plan process, the Council has carried out a Transport Appraisal. (Volumes 1 and 2, 2013, Addendum, 2014) This appraised the cumulative impact of the new developments proposed in the Plan, taking account of other factors. This identifies improvements to transport infrastructure to deal with

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the net impact of new housing proposals in South West Edinburgh. Thes e transport actions are set out in the Council’s Proposed Action Programm e on Page 42. For HSG 31 Curriemuirend, the actions include improvements to Gillespie Crossroads and Hermiston Park and Ride. Details will be established through transport assessments required at the planning application stage. All re levant proposals will be required to make appropriate contributions to new and improved infrastructure in line with relevant policies and guidance. These are actions in the Action Programme and will be updated as they progress. It is not necessary to add these to the Transport proposals in Table 9.

A number of representations refer to P lanning Appeal PPA – 230 – 2112 which considered the impact of developments in South West Edinburgh on Gillespie Crossroads. The appeal reporter’s findings relate to the appeal site and the decision before him. It was not within his remit or pow ers to carry out or request a cumulative transport assessment for the appeal sit e looking at the impact and potential mitigation at the Gillespie Crossroads. He saw the Council’s evidence that such a study had not been done for the appeal proposal. For his purposes, there was no ready solution. In response to this appeal the Council’s appeal statement highlighted on page 2 that the cumulative traffic impact of potential development in the Lanark Road corridor needs to be assessed as part of the Plan process.

The Development Principles make reference to the opportunity to redu ce Wester Hailes Road to one carriageway; this was identified in the brief to allow for more attractive, safe environment for pedestrians and to create an active frontage. The opportunity to reduce the Wester Hailes Road will be considered at the mastreplanning and planning applica tion stage and will need to be addressed by a Transport Appraisal to be submitted by the applicant. • School infrastructure. As part of the Plan process, the Council has prepared a Revised Education Appraisal June 2014 (corrected Se ptember 2014) which identifies the required improvements to school infrastructure t o deal with the net impact of new housing proposals across Edinburgh. Where required these Education actions are set out within the Council’s Proposed Action Programme. HSG 31 Curriemuirend lies in the catchment and due to there being no capacity within its catchment school, Juniper Green Primary, it is proposed to make a catchment change to transfer the site to the adjacent Clovenstone Primary School and Wester Hailes Education Centre catchments. There is spare capacity at both of these schools to accommodate the proposed development. • Community facilities. The Plan in paragraph 72 acknowledges that housing proposals will have implications for the provision of primary healthcare and other community health services. Policy Hou 10 Community Facilities seeks to ensure that where practical and reasonable a range of commu nity facilities is provided with new housing development.

The Plan identifies where non-residential units should be provided in new housing sites which could provide potential premises for new health practices. Paragraph 130 of the Plan states that developer contributions to Issue 13 Page 16 of 19

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measures intended to mitigate the net effects of development, other than actions identified in the Action Programme, may also be required.

The Council has discussed all growth allocations with the relevant part of the NHS Lothian. This has assessed the need for new and expanded general practitioner practices to accommodate the planned housing growth set out in the Second Proposed Plan No specific actions have been included in the Action Programme at this time, however when suitabl e and specific actions are identified these will be included in future iterati ons of the Action Programme. Where these are needed to address demand arising from new development, financial contributions towards the cost may be sought in line with relevant policies and guidance. • Drainage and flood risk . In preparin g a Local Development Plan, the Council must consider the impact of development on flood risk. The new Local Development Plan proposals have been assessed strategically for flood risk using a fluvial flood risk map showing areas at medium-to-high risk (i.e. a 1-in-200 year event) (Figure 3 of the Environmental Report Volume 1, page 21 and Volume 2 page 157) Appropriate licensing of suc h works would be required. The issue of flood risk for all developments, not just Plan proposals is addressed through Policy Env 2.

No modification proposed.

(170 Balerno Community Council; 184 Curriemuirend Park Allotment Association; 305 Colinton Amenity Association; 321 Ratho & District Community Council; 1150 Bill Henderson; 1213 Friends of Currimuirend Park; 1554 Wester Hailes Community Council; 1638 Juniper Green/Baberton Mains Community Council; 2706 Juniper Green Comm unity Council and individuals in Appendix C)

Repres entations opposed to HSG31 Curriemuirend in current form and seeking its rem oval and/or change

• Representations have identified other sites as an alternative to HSG 31 . However be cause of the increased housing requirement for Edinburgh, these are in addition to HSG 31, not alternatives. This includes Edinburgh Park (0145 Douglas Webb; 0155 Catherine Webb; 0161 Mary Sandilands) and The Gyle (0391 Holman). Other suggested sites within Edinburgh are not considered appropriate for the reasons set out in the Revised Environmental Report June 2014. This includes East of Milbu rn Tower site (0046 Dorothy Curr; 2133 R MacKay; 2195 W Blair; 2199 S Blair) No modification proposed. • The Currie Bypass was a safeguard in the Rural West Edinburgh Loc al Plan (Transport Safeguard T7). However, it is no longer appropriate or necessary in terms of the principles and priorities in the Local Transport Strategy nor is it justified by the LDP Transport Appraisal Addendum. No modification proposed. (480 Currie East Neighbourhood Watch ) • It is acknowledg ed that changing the name of proposal GS10 Curriemuirend would be appropriate. Should the Reporter be so minded, the Council would see merit in an amendment to Table1 to refer to GS 10

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Clovenstone Drive. Curriemuirend Park is identified within the Open S pace Audit on Page 28 as a Community Park and of fair quality. It makes no further reference. No modification proposed. (1213 Friends of Currimuirend Park) • Whilst Policy Des 5 of the plan states that cul-de-sac and single access re sidential layouts and gated communities should be avoided to help the integration of new development into the wider neighbourhood, it is accepted that developments of up to 200 units normally utilise one access point. The design and layout of the proposed development will need to comply with the Edinburgh Design Guidance and this will be assessed at the masterplan and planning application stage. No modification proposed. (01849 Roy Brown) • The site brief on page 69 of the Second Proposed Plan June 2014, id entifies the principal access points in terms of pedestrian/cycle access and the Development Principles require these to connect with the allotments and Clovenstone Park. Any masterplan submitted, would be assessed against these requirements and Policy Des 7 – Layout Desig n, in terms of the comprehensive approach to the layout of built form, streets, paths and open spaces. This is further illustrated on pp 27-30 of the Edinburgh Design Guidance. No modification proposed (2697 Scottish Natural Heritage)

Repres entations seeking removal of GS 10 Curriemuirend

• The Development Principles on Page 69 of the Plan require a comprehensive approach to both HSG 31 Curriemuirend and GS10 Curriemuirend to ensure that the proposed allotments and Greenspace improvements are delivered. No modification proposed. (0370 Malcolm Stewart; 0418 John Smith; 0833 Roseann Ferguson; 2233 E Beevers; 2237 Cliff Beevers 0418) • Loss of woodland would be required to be offset in accordance with Scottish Government’s Control of Woodland Removal Policy, including through street tree planting within the site, parkland tree s at Clovenstone Drive and supplementary planting within the wider network of public open space. Enhancemen ts to the existing open space at Clovenstone Drive will be required to demonstrate their value to conservation of natural features, wild fauna and flora, in line with the Council’s Park’s Quality Assessm ent. In addition to the proposed allotments, new development should incorporate features to enhance biodiversity, in line with Policy Des 3 Development Design – Incorporation and Enhancing Existin g and Potential Features e.g. provision of nest boxes. No modification proposed . (0370 Malcolm Stewart; 0833 Roseann Ferguson)

Representations seeking removal of HSG 31 Curriemuirend and GS 10 Curriemuirend

• The Council’s response and reasoning regarding issues relating to site selection and transport infrastructure is set out for each site individually above.

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No modification proposed.

(1638 Juniper Green/Baberton Mains Community Council and Individuals i n Appendix D)

Reporter’s conclusions:

Reporter’s recommendations:

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