HUMBIE, EAST & WEST SALTOUN AND BOLTON COMMUNITY COUNCIL

OUTLINE RESPONSE TO MAIN ISSUES REPORT

This report is set out in two parts: 1. Answers to the questions posed in the Main Issues Report; and 2. Additional comments in relation to policy issues which need a clearer statement.

Question 1: Aims, Objectives and Outcomes – do you have any comments on the aims and objectives for the LDP? (page 31)

It is helpful to recognise the development pressures and the fact that is part of the wider City of region. The LDP must therefore seek to accommodate this pressure in the most sustainable and realistic way.

Question 2: Sustainability and Climate Change – Are there any additional matters related to sustainability and Climate Change mitigation that you think the LDP should seek to address?

In order to deliver these policies it is essential that close attention is paid to transport and building design and construction. Developments that are not serviced by public transport or that use energy intensive technologies should not be permitted.. In addition, these measures should not only focus on new developments – better transport and enhanced energy efficiency are is requirements of existing communities.

Question 3: Development locations – Of the two spatial strategy options, do you support the preferred (compact growth), alternative (dispersed growth) or neither?

The preferred approach is supported. With most people working in Edinburgh, it makes sense to locate housing as close to Edinburgh as possible. Furthermore, transport links are most developed in these locations.

Question 4: Town Centres – Subject to the ability to expand Blindwells, do you support the introduction there of a new town centre? Do you support retention of the current network and hierarchy of existing centres? The intention is to prepare strategies for each town centre, what ideas do you have for improving your town centre?

For Blindwells, we support the creation of retail facilities necessary to support the new development. We do not support wider development of retail activities given the proximity of Fort Kinnaird/Edinburgh and the increase in on-line shopping.

The current network and hierarchy of existing centres is supported.

The area covered by this Community Council is serviced by three main centres: Haddington, Dalkeith as well as Edinburgh. For Haddington, there is no need for 1

additional retail space other than for smaller retailers. Retail facilities in are also readily accessible. Furthermore the growth of on-line shopping means that there is a reduced need for such outlets.

In terms of improvements for Haddington: Traffic management – parking and traffic issues need to be addressed as a matter of urgency. Our rural community is car-dependent. Car parking is therefore essential for accessing local amenities, doctors etc.

More leisure offerings – cinema and other leisure activities particularly for younger members of our community need to be developed as an alternative to a trip into Edinburgh.

Question 5: Planning for Employment – Do you think the review of the employment land supply should be as set out under the preferred approach, alternative approach or neither?

The preferred approach is supported.

In rural areas, there is needs to greater flexibility to change designations between housing and employment land to ensure that small businesses are encouraged. Small businesses in rural areas typically have low and variable incomes and require small and flexible business space. Critical to their development is the ability to access markets. High speed broadband should be a pre-requisite of designating any employment site.

Question 6: Planning for Housing – Should the LDP plan for a longer term settlement strategy to meet the SDP’s housing requirements as well as help contribute to signposted need and demand for housing post 2024 (preferred approach) or should it plan only to meet the SDPO’s confirmed housing requirements to 2019 and 2024 (alternative approach) or neither?

The preferred approach is supported. Growth of communities should occur in a planned manner. This allows consideration to be given the wider needs of the whole community.

It is important that the LDP ensures a gradual expansion of communities to ensure that new and existing communities can be integrated. Large and sudden expansions will threaten the vibrancy of existing communities.

Question 7 – Green Belt – In terms of the approach to Green Belt, do you support the preferred approach, the reasonable alternative, or neither?

The preferred approach is supported.

2

Question 8 – Countryside Around Towns – In terms of the potential to introduce Countryside Around Town designations as a new policy approach, do you support the preferred approach, the reasonable alternative or neither?

The preferred approach is supported. This ensures that communities are distinct.

Question 9 – Central Green Network – In terms of approach to the Central Scotland Green Network in East Lothian, do you support the preferred approach, the reasonable alternative, or neither? What do you think the priorities are for the green network for East Lothian or your local area?

The preferred approach is supported. Green spaces are important for communities, provide space for wildlife and enhance the appearance of a town or village.

There are no priorities in this Community for the green network as most land is designated as agricultural or forestry.

Question 10 – Development in the Countryside and on the Coast – In terms of the approach to managing development in the East Lothian countryside and on the coast, do you support the preferred approach, reasonable alternative, or neither? If you support the alternative approach, do you think a) or b), or a) and b) should be incorporated into policy?

The Reasonable Alternative, both a) - to enable like for like replacement and (b) - where local need for affordable housing can be demonstrated and “very small scale” is defined.

We support the particular policies 5.8.3 to 5.8.7.

We agree that disused buildings regardless of their reason for that disuse, should be allowed to be developed subject to tight conditions on the nature of the redevelopment. The policy should: - enable both housing and business development (where required); - enable architecturally distinct buildings to be created; - create a restriction on the size of the redevelopment to ensure that the existing community is not overwhelmed with new residents and the character of the existing village/hamlet is not altered in an unrecognisable fashion; - recognise the lack of transport and therefore provide adequate parking within any development; and - recognise the nature of accommodation/tenures needed in the vicinity. For example a block flats more commonly found in urban areas would not be appropriate.

This Community Council covers two Cluster areas: and Haddington. We would wish to note that the Cluster areas do not match Ward Boundaries. In our view, these should match thus ensuring that elected Councillors can represent their areas in a clear and transparent way. 3

TRANENT CLUSTER

Question 13 – a) Do you support the preferred approach to new economic development and housing opportunities in the Tranent cluster?

The preferred approach is supported. Special consideration should be given to reviewing Council processes and policies to make them more effective in facilitating economic development in the smaller villages where small start-up businesses struggle to find suitable premises for an affordable rent, and where poor communication between the Council’s planning and building control functions imposes unacceptable and unnecessary delays and costs.

b) Do you think all of the preferred housing sites can be delivered in the anticipated timeframe?

The failure to deliver many of the planned sites in the 2008-13 period should not be taken as an indicator of likely delivery in the period to 2019 given the improvement in the economic climate.

c) Potential options have been identified for how education capacity might be increased in the cluster. How do you think those options could be funded and delivered?

Please see our answer to d)

d) Where might such facilities be located if required?

It is clear from the MIR that a catchment review is required in order to provide sufficient education capacity. This Community Council argues that a catchment review is long overdue and should remove the current anomaly whereby secondary children (except for those in Bolton village, Eaglescairnie, Howden and Bankrugg) are required to attend Ross High. For many, Knox Academy is closer and aligns with family use of other amenities and services. Whilst the numbers of students is very small, it would provide some relief to the capacity problems at Ross High. A more detailed explanation is given under Additional Comments.

Also, please note that the Primary School in East Saltoun is called Saltoun Primary and serves both West and East Saltoun villages.

HADDINGTON CLUSTER

Question 14 - Do you support the preferred approach to new economic development and housing opportunities in the Haddington cluster?

The preferred approach is supported. However, we offer the following observations: 4

 We question why no development is allowed south of the river which is close to Haddington town centre. Haddington has recognised traffic issues that will be compounded by large developments towards Letham because of a lack of car parking. Unless parking issues are resolved, new and existing residents will simply abandon Haddington as centre for shopping and go elsewhere. Fort Kinnaird is a mere 15 miles way.  We suggest that provision is made for a Park and Ride facility at the West side of Haddington. This would remove the need for commuters using the buses to park within the town.  Whilst the site at Clerkington is recognised as another potential site, better access to the A1 must be created before the development proceeds. Current links between the Road and the A198 are unsuitable for high volumes of traffic.  In relation to education, please see the comments to the Tranent Cluster and the Additional Comments.

Question 17 – Blindwells New Settlement

We support the preferred approach to a potential expansion of Blindwells but are concerned at the potential impact on Haddington town centre if Blindwells were to be developed as a retail centre for anything other than its own residents. We do not support large scale retail development anywhere in East Lothian.

Question 19 – Developer Contributions - In terms of the approach to infrastructure and developer contributions do you support the preferred approach, the reasonable alternative, or neither?

The alternative approach is supported. A flat rate (which may have different parts to recognise different development scenarios) is a simpler system and can be easily understood by all. Furthermore it removes the need for lengthy and protracted negotiaions between developers and the Council. The current Section 75 process is not transparent and doesn’t necessarily lead to improvements in the local area. We would recommend that Section 75 contributions are kept in the Cluster area and that communities (through the Area Partnership) should have the final say in how this money is used.

Question 20 – Affordable Housing Quota – In terms of approach to the affordable housing quota do you support the preferred approach, the reasonable alternative, or neither?

The preferred options is supported. However, the allocations should be flexible to meet local demand and local circumstance, and as advised by housing associations and local communities. A housing needs survey might be a useful tool to inform the needs for affordable housing.

5

Question 21 – Affordable Housing Tenure Mix – In terms of approach to the mix of affordable housing tenures do you support the preferred approach, the reasonable alternative or neither?

The preferred approach is supported as it allows the mix to be tailored to the circumstances of each proposed location.

Question 22 – Energy, including Renewable Energy – In terms of approach to energy proposals, including renewable energy proposals, do you support the preferred approach, the reasonable alternative or neither?

The preferred approach is supported. We would recommend that a strategic approach is taken to windfarm development to avoid “windfarm creep” whereby small numbers of wind turbines are added over a period to existing developments.

We also recommend that the Council formally adopt a policy presuming rejection of any windfarm planning application under which the community contributions is less than the minimum per MW of generating capacity recommended by the Scottish Government. Land is a scarce resource and awarding planning permission to a development which short-changes the local community precludes the recommended return to that community on that resource for the following twenty five years.

Question 23 – Use of Low & Zero Carbon Generating Technologies in New Buildings – In terms of the approach to use of L&ZCGT in new buildings do you support the preferred approach, the reasonable alternative or neither?

The Reasonable Alternative is supported. Council policy should assess alternative energy solutions on a whole-life cost basis, i.e. including both installation and running costs. It is always more difficult and more expensive to retro-fit new systems so it is important to install the most efficient system at the construction stage.

Question 24 – Minerals, including Aggregates and Coal – In terms of the approach to minerals, do you support the preferred approach, the reasonable alternative or neither?

The preferred approach is supported. There is no case for opencast coal mining in a sustainable Scotland.

Question 25 – Waste – In terms of the approach to waste, do you support the preferred approach, the reasonable alternative or neither?

The preferred approach is supported.

Question 26 – Minor Policy review & New Policies to be Introduced – The Monitoring statement indicates where and how it is intended to promote the LDP a minor review of existing local plan policies and the introduction of new 6

policies either in the LDP itself or in Supplementary Guidance. Do you have any comments on these proposals?

No

Other Comments

School Catchment Review

There is a major issue facing the rural communities of East and West Saltoun, Humbie and half of Bolton and that is the policy of East Lothian Council in respect of catchment boundaries and, in particular, to maintain secondary school catchment areas that are different to the electoral ward boundaries. It is clear that splitting the rural village of Bolton such that one half of a small rural village belongs to one school catchment and the other half in another is a bizarre situation and one that was, by all accounts, not intended when the Bolton school was closed. Furthermore it makes little economic sense for the Council given that both Yester and Knox school buses pass through the length of the village.

However, the catchment issue is much more far reaching than just the anomaly in Bolton. In particular it is having a severely detrimental effect on the primary school populations in East Saltoun and Humbie as families relocate in order to ensure that their children can secure places in primary schools which feed into our local area of Haddington and Lammermuir, or are forced to consider moving outside of East Lothian. This then has a direct knock-on effect onto the Council’s ability to plan teacher numbers effectively for the school and ultimately resulting in fewer children and therefore composite classes that cover more age groups – a situation that is known to make parents look for alternatives in the private sector or seek to relocate away from the village.

A significant number of families opt to put their children into private education. Whilst it is recognised that these families may choose such an option for secondary education, the uncertainty of catchment areas and fluctuating numbers of school children (and classes) at Saltoun means that they do so earlier than they might do otherwise.. As a direct consequence, parents and children focus their spare time and energy in Edinburgh rather than on participating and contributing to the vibrancy of the local community which is often centred around the activities at the school and in the village hall. The absence of local ties within the Community frequently results in families moving to relocate closer to Edinburgh in order to place their children in private education and avoid the significant daily travel from East Lothian.

A disturbing consequence of East Lothian Council failing to address this issue is that the local rural communities are suffering from these significant barriers to building and sustaining a vibrant community. We firmly believe that once the secondary school catchment is aligned with our ward boundaries of Haddington and Lammermuir and aligned with the local communities centre of existence, that families will stay in the local rural villages, the school populations will be allowed to flourish and the communities will grow and flourish.

7

Feedback from the Council in response to numerous formal letters from residents has been that no catchment review is planned. It is noted that the Main Issues Report has many references to secondary school catchment issues but that in relation to the areas of East and West Saltoun, Humbie and Bolton are not addressed. We strongly recommend that for the reasons given above, that an urgent review is undertaken.

Rural “In-fill” and “brownfield” Sites – as noted in the answer to Question 10, policies are required to ensure that these sites are developed in a manner that is appropriate to the scale, size and nature of the existing community and compatible with the character of the existing village/hamlet. Our comments reflect experiences of planning applications within the Haddington & Lammermuir ward.

 Size of Development – the size of development must be such that it does not dominate the existing community. We suggest that there should be a presumption that planning will be refused for developments which propose to add more than 25% in any one year to the existing stock of housing units in a village. Also where large developments (relative to the existing community) are proposed, a review should be undertaken of the village amenities to ensure that adequate provision is made in relation to other infrastructure (eg broadband, local amenities etc).  Nature of Development – The development must recognise the characteristics of the local village and the needs of families living in a rural area. Car ownership is essential for all households in order to access amenities, schools etc. Adequate parking provision is therefore essential. Cognisance should also be taken of the exposure to climatic conditions. Bolton for example is extremely exposed to the prevailing winds. As a consequence, storage for waste bins, garden equipment, bicycles etc is essential and must be an explicit condition in the planning permission.  Style of Development – the Council must actually implement the guidance in SDP Policy 7 that ‘new development is located in such a way that it respects the character, appearance and amenity of the area, including its settlements and their settings’ .. The appearance of Bolton has been altered by the construction of houses whose style and materials bear little resemblance to their surroundings. Houses that have a predominantly north-facing aspect should not be approved. Consideration should not only be given to green spaces but such provision actually enforced as an integral part of the approval of the planning application. Trees and hedges should be a requirement on the extremities of a development to provide protection from wind and rain. In Bolton, where no hedge or trees have been provided, new built houses are already feeling the effects of the lack of shelter.  Transport – one of the objectives of the LDP is ‘to find locations for new developments that reduce the need for travel and that are well served by a range of transport modes.’ This policy needs to be implemented – it was ignored in the case of Bolton. So was the SPP statement ‘that countryside areas accessible from cities and main towns, such as East Lothian, should be protected against unsustainable growth in car based commuting and the suburbanisation of the countryside’.

8

 Further development after occupancy – tight rules that prohibit further development – for example fences, satellite dishes, garden sheds, chimneys etc should not be overly restrictive and must recognise that families require these additions to their houses in order to make them comfortable. Ideally such “additions” or, potential for, should be considered at the planning application stage. Failure to recognise these requirements merely results in an unhappy and restless community.  Broader community interests – the Scottish Government and the Council’s planning policies prioritise sustainable economic development and the interests of the local community. These policies appear to be frequently ignored, the housing development of Bolton and the grant of planning permission for a house on a site adjacent to the shop in Humbie being local examples. The latter not simply deprived the community of the only potential parking for the shop, thereby compromising its viability, but approved development on a site where the built proportion exceeded the Council’s own guidelines; and where vehicle turning cannot be accommodated without intruding on the public footpath. Such planning decisions, which are overwhelmingly rejected by the resident Community, do not lead to vibrant communities and result in communities questioning their faith in the Council’s policies.

Economic Development in Rural East Lothian – there are few small businesses in our area. This is in part due to the absence of affordable retail/business units. This means that those that do start are either located in inappropriate areas or from the home. In both cases, this restricts the ability for the business to grow and develop.

Broadband & Mobile coverage and mobile – In any age when it is becoming more common for people to work from home (whether this be to manage childcare arrangements or because of the nature of their job) it is essential that there is access to adequate broadband and mobile communities. In our communities – some of which is less than two miles from Haddington, there is an urgent need to ensure that Broadband and mobile communication services are improved. Speeds in much of our area are so poor that many “streaming” services and mobile signals taken for granted elsewhere are impossible. The poor broadband and mobile signals have a detrimental impact on economic growth by restricting the ability for businesses to access markets. Consideration should be given to Broadband capacity for any new development similar to that given to other utilities such as water and sewerage.

‘Job Density’ – we do not consider this a useful concept. The MIR treats East Lothian as part of the broader Edinburgh housing market, but takes a balkanised view of the labour market. East Lothian is part of the Edinburgh Travel-To-Work Area – which means that jobs created in East Lothian may well be filled by a resident of the broader TTWA, Queen Margaret’s campus being the prime example. In an age of flexible work places, working from home etc, the concept of ‘job density’ is economically illiterate.

9