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Comments by Jon Grounsell Midlothian Local Development Plan

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Comments by Jon Grounsell Midlothian Local Development Plan Comments by Jon Grounsell Midlothian Local Development Plan MIR consultation. I am a town planner and architect with 30years practical experience. Although currently residing in Edinburgh I have interests in Midlothian as developer of a brownfield housing site in the conservation village of Lasswade and as owner of Uttershill Castle a Scheduled Ancient Monument on the south side of the conservation area of Penicuik, which I have planning permission to restore as my home. I am also a member of the Cockburn Association and sit on their Council and was their Cases Committee Convenor from 2009-13 during which time I was heavily involved in their responses to the SESplan and its MIR, though the views expressed here are my own and nothing to do with the Cockburn Association. I have many comments to make across inter-related subjects. I do not think it would be practical or coherent to fragment the comments and repeat them at each policy question as it arises in the MIR and related Technical Notes as the points would be re-stated over and over again and require complex referencing. There are a number of themes to the comments I wish to make which I will summarise as follows:- 1. At the Vision level, there is no recognition of Midlothian’s special qualities in terms of what the objectives of the LDR need to be and those which are given are generic and applicable to any council. 2. The assessment of landscape character is flawed, has major omissions and gives the wrong policy direction. In particular there is no understanding of key views. 3. There appears to be no consistent policy on the historic environment, it doesn’t warrant a Technical Note of its own and the topic is covered haphazardly across various sections. 4. The Town Centres and Retailing Technical Note is in fact only about retailing and offers no input or direction on town centres other than as retail destinations. This appears to indicate a policy vacuum. It is significant that no alternatives are proposed for retail policy and in fact new ideas are not welcome, which rather defeats the purpose of a MIR consultation. 5. Green Belt policy is primarily concerned with Edinburgh’s coalescence with Midlothian towns rather than also being a policy applicable to Midlothian and its small towns. It therefore does not appear to meet Midlothian’s needs. 6. Tourism does not appear to have been given any great significance and there are no policies put forward for this key aspect of the Scottish economy. 7. Various policies are proposed without their spatial impacts being fully considered or acknowledged, such as the A701 re-alignment and policies on rural housing. Within these seven topics there are overlaps which I will try and address. The nature of my comments is primarily district-wide, but I do have comments on subjects where I have a vested interest as a landowner. I will be specific about these in theme 8:- 8. Matters affecting the setting of Uttershill Castle and 7-9 Elm Row, Lasswade. I have illustrated my comments with site photographs. As these might cause the file size to be excessive I will submit these separately. 1. At the Vision level, there is no recognition of Midlothian’s special qualities in terms of what the objectives of the LDR need to be and those which are given are generic and applicable to any council. The special quality of Midlothian, compared to Fife, East and West Lothians and the Borders is that the county has an outstanding natural landscape quality within close proximity of the City of Edinburgh. It is possible to travel no more than ten miles from Edinburgh City Centre and be in completely wild landscape above Gladsmuir and Loganlee Reservoirs, a quality that is unique in the UK and with which there are few comparable city regions in Europe. Midlothian itself is amply endowed with beautiful landscape (including townscape) settings which have been handed down by good fortune with the decline of mining and mill industries and a general lack of speculative housing development in the county during the period 1970-2000. The challenges that face the county during the lifetime of this proposed plan therefore are without precedent and focus on how to protect this inheritance whilst also meeting the needs of SESplan. The Vision, and much of the MIR document fails both to identify and explain this special quality and put it in a regional, national and European context. Without an understanding of the opportunities and threats which the county faces it is impossible to measure how the planning objectives are being met. Within the Vision the only reference is to the natural environment “providing inspiration”, an objective which can neither be monitored, assessed, measured or delivered. The challenges faced by Midlothian are inevitably different to those experienced in other SESplan areas like the Borders and Fife, and this needs to be demonstrated. Aspirations for prosperity, quality of life and the numerous other benefits which might ensue from good planning policies all follow from having key objectives which match the situation and local need. As such, this overview is missing throughout the document and when it comes to the detail it means the key considerations are not addressed. The challenge is to make the changes required by SESplan with the minimal amount of negative impact. Furthermore, proper recognition needs to be given to the opportunities which the outstanding landscape and character could provide to tourism, employment and the wider economy. 2. The assessment of landscape character is flawed, has major omissions and gives the wrong policy direction. In particular there is no understanding of key views. Technical Note Landscape has been prepared largely on the evidence-base from previous Local Plans, though it is labelled a review of landscape character. In fact it only assesses land in or adjacent to existing designations. This is not appropriate and does not match the challenges the county faces. There are some serious flaws in this approach, inherited from those plans. The first, I would contest, is that the landscape quality of the existing AGLV at Gladhouse Reservoir & Moorfoot Escarpment and Carrington Farmland is not any ‘better’ than that in neighbouring parts of the county particularly around Mount Lothian and the routes of the A6094 and B7026 which despite their designation are major arteries into the city from the South. I would suggest that rather than being special the landscape character here is significantly worse. Furthermore, the landscape assessment is meant to take account of scenic quality, i.e. views, yet there has been no study undertaken of the key views in the county similar to that of Edinburgh’s Skyline Study. I would illustrate this as follows using numbers in brackets to refer to my photographs. There are major viewpoints and in some cases almost continuous viewpoints to the West from the A6094 (1302-1307,1309-1310) and the B7026 (1428-1429) with a public bench to indicate it. These views of the Pentland range are outstanding by any measure and would be treasured in many counties of England. They offer pronounced undulating landscape in the foreground (1375-1379) – possibly drumlins – mixed farmland with stone dyke field boundaries, stone vernacular buildings (1314-1315) varied woodland next to open fields and the prospect of falling ground towards the West which combined with the higher peaks and jagged outline of the hills makes them seem higher than they really are. There are distant views of the Ochils (1311) and Arthurs Seat (1306 & 1307). Even the Municipal Dump has a superb setting and viewpoint (1336-1339). By contrast the view to the East from these points is obscured by rising ground and is unexceptional (1308, 1320, 1340). The equivalent area near the Moorfoot Hills designated as ‘special’ is flat (1341- 1345, 1348-1349), without hedgerows and stone dyke enclosures, with poor quality local buildings of no vernacular interest (1370 & 1372). The main built environment feature is windfarm turbines on the skyline (1345). There is little natural tree cover (1356-63) and the escarpment seems low and flat in profile because of the rising foreground (1567). Native trees struggle in the exposed setting (1366), are of limited height and are generally confined to indentations in the ground (1350-51). Commercial single-species conifer plantations of limited wildlife value are the main feature (1362- 63). From here even the Pentlands are merely a low feature on the horizon, due to distance (1368-69). Gladhouse Reservoir is deemed to be a key feature of the area. However, even very close up it is an unrecognisable feature with limited landscape impact until one is on the higher ground of the Moorfoots (1364). The MIR states that the designation of Special Landscape Areas has to be robust and capable of standing up to scrutiny. I don’t see how it can be argued that this designation can be. It may be that Midlothian has so much good landscape that it is impossible to deem one area ‘special’ over the many others, but if that is the case it should be stated. NPPG14 intends such areas to have clearly defined boundaries, but here they do not. The particular landscape quality of the area, high moorland associated with the watershed lands between the Forth and Tweed catchment areas occurs in many places outwith the proposed SLAs, such as on the Carlops Road from Penicuik and along the edge of the Pentland Regional Park (1412-1416, 1419); it is by no means unique. These designations are very important as they act as material considerations in the selection of sites for future housing.
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