Customer Ref: 01234 Response Ref: ANON-KU2U-GFJG-5 Supporting Info Name Nicolas Lopez Email [email protected] Response Type Developer / Landowner On behalf of: Defence Infrastructure Organisation Choice 1 A We want to connect our places, parks and green spaces together as part of a city-wide, regional, and national green network. We want new development to connect to, and deliver this network. Do you agree with this? - Select support / don't support Short Response Not Answered Explanation Choice 1 B We want to change our policy to require all development (including change of use) to include green and blue infrastructure. Do you agree with this? - Support / Object Short Response No Explanation The DIO is concerned about the requirement for changes of use to incorporate new blue and green infrastructure. As the Council will be aware, the Redford Barracks site incorporates a number of listed buildings that may be retained and converted to residential accommodation as part of a wider scheme to redevelop the site. It would be challenging to retro-fit new blue/green infrastructure for these buildings and in terms of drainage it would be much less invasive to continue to rely upon existing systems. This policy would also be incompatible with the conversion of buildings with constrained curtilages which have little or no space to install features like swales or rain gardens. These issues will be further compounded for buildings that are listed or within conservation areas where the retro-fitting of blue/green infrastructure on the building itself, such as a green roof, would not be feasible or indeed desirable from a built heritage perspective. The DIO therefore suggests that changes of use should not be subject to this requirement, or any policy should be carefully caveated to ensure that requirements for green/blue infrastructure would take account of site constraints. Customer Ref: 01234 Response Ref: ANON-KU2U-GFJG-5 Supporting Info Name Nicolas Lopez Email [email protected] Response Type Developer / Landowner On behalf of: Defence Infrastructure Organisation Choice 1 C We want to identify areas that can be used for future water management to enable adaptation to climate change. Do you agree with this? - Yes / No Short Response Not Answered Explanation Choice 1 D We want to clearly set out under what circumstances the development of poor quality or underused open space will be considered acceptable. Do you agree with this? - Yes / No Short Response Not Answered Explanation Customer Ref: 01234 Response Ref: ANON-KU2U-GFJG-5 Supporting Info Name Nicolas Lopez Email [email protected] Response Type Developer / Landowner On behalf of: Defence Infrastructure Organisation Choice 1 E We want to introduce a new ‘extra-large green space standard’ which recognises that as we grow communities will need access to green spaces more than 5 hectares. Do you agree with this? - Yes / No Short Response No Explanation The Defence Infrastructure Organisation (DIO), which is part of the Ministry of Defence (MOD), is generally supportive of the aims of the new policy but is concerned that the requirement for new communities to have access to a 5-hectare park is excessive. This requirement may impact upon the deliverability of large development sites and undermine the other aims of City Plan 2030, as set out in Choice 2, regarding higher development densities and the efficient and effective use of land. It is also unclear how the ongoing maintenance of any large new communal spaces created under this policy would be funded. If the cost of maintenance was passed to residents/proprietors of the private sector housing in the development, bearing in mind separate proposals to increase on- site affordable housing requirements, this may create a prohibitive ongoing financial burden that will reduce the attractiveness of new developments to prospective residents. This burden could also be further increased by the cost of maintaining the allotments/food growing areas proposed as part of Choice 1. In this context, it is considered that the existing policy on open space in new development should be maintained. Should City of Edinburgh Council wish to take the 5-hectare requirement forward, the DIO suggests that the policy should only apply to large greenfield urban extensions where providing open space of this this scale is more likely to be feasible. In contrast, if a 5-hectare open space was required to be accommodated within a constrained site within the existing urban envelope, such as at Redford Barracks, this could severely restrict development potential and undermine the future delivery of housing on the site. Choice 1 F We want to identify specific sites for new allotments and food growing, both as part of new development sites and within open space in the urban area. Do you agree with this? - Yes / No Short Response Not Answered Explanation See response to 1E Customer Ref: 01234 Response Ref: ANON-KU2U-GFJG-5 Supporting Info Name Nicolas Lopez Email [email protected] Response Type Developer / Landowner On behalf of: Defence Infrastructure Organisation Choice 1 F We want to identify specific sites for new allotments and food growing, both as part of new development sites and within open space in the urban area. Do you agree with this? - Upload (max size 3mb) Short Response No Explanation Choice 1 G We want to identify space for additional cemetery provision, including the potential for green and woodland burials. Do you agree with this? - Yes / No Short Response Not Answered Explanation Choice 1 H We want to revise our existing policies and green space designations to ensure that new green spaces have long term maintenance and management arrangements in place. Do you agree with this? - Yes/No Short Response Not Answered Explanation Customer Ref: 01234 Response Ref: ANON-KU2U-GFJG-5 Supporting Info Name Nicolas Lopez Email [email protected] Response Type Developer / Landowner On behalf of: Defence Infrastructure Organisation Choice 2 A We want all development (including change of use), through design and access statements, to demonstrate how their design will incorporate measures to tackle and adapt to climate change, their future adaptability and measures to address accessibility for people with varying needs, age and mobility issues as a key part of their layouts. - Yes / No Short Response Not Answered Explanation Choice 2 B We want to revise our policies on density to ensure that we make best use of the limited space in our city and that sites are not under-developed. Do you agree with this? - Yes / No Short Response No Explanation Again, the DIO is supportive of the principles set out in choice 2. However, setting a minimum density requirement for all development in the city would limit the delivery of larger family housing which there is considerable demand for. Sites in suburban or edge of city locations are well placed to meet these demands and the requirement for high density developments in these locations may push demand outside the city, to potentially less sustainable locations, and undermine housing delivery. It may also result in development that is out of context with its surroundings and which compromises the character and setting of built heritage assets including conservation areas and listed buildings. Furthermore, site constraints, and the green space requirement set out in choice 1, may make the target of 65 units per hectare difficult to achieve in some locations. In that regard it is welcomed that the ‘Housing Strategy’ paper that accompanies ‘Choices for City Plan 2030’ has proposed a site-specific density for Redford that takes account of the special characteristics of the site. However, it is suggested that this site-specific approach to housing density should not be limited to Redford, but rather should continue to be applied across the city as is done presently. Customer Ref: 01234 Response Ref: ANON-KU2U-GFJG-5 Supporting Info Name Nicolas Lopez Email [email protected] Response Type Developer / Landowner On behalf of: Defence Infrastructure Organisation Choice 2 C We want to revise our design and layout policies to achieve ensure their layouts deliver active travel and connectivity links. Do you agree with this? - Yes / No Short Response Not Answered Explanation Choice 2 D We want all development, including student housing, to deliver quality open space and public realm, useable for a range of activities, including drying space, without losing densities. Do you agree with this? - Yes / No Short Response Not Answered Explanation Customer Ref: 01234 Response Ref: ANON-KU2U-GFJG-5 Supporting Info Name Nicolas Lopez Email [email protected] Response Type Developer / Landowner On behalf of: Defence Infrastructure Organisation Choice 3 A We want all buildings and conversions to meet the zero carbon / platinum standards as set out in the current Scottish Building Regulations. Instead we could require new development to meet the bronze, silver or gold standard. Which standard should new development in Edinburgh meet? - Which standard? Short Response Not Answered Explanation Section 7 of the Building Standards Technical Handbook expressly excludes conversions and, given this, careful consideration should be given to the ramifications of requiring conversions to meet any of the standards, let alone the most stringent Platinum standard. The Platinum standard currently only covers carbon dioxide emissions and to meet it net emissions from new buildings requires to be zero. This would be extremely difficult to achieve for conversions, particularly for listed buildings where a conflict between requirements under this policy, and requirements under built heritage policies, is almost inevitable. These changes would also have a detrimental impact on the viability of conversion schemes which already tend to be more costly than new builds due to requirement for the use of traditional materials, specialist skills and the VAT that is applicable on building work and materials.