encourage greater emphasis on pedestrian use of the city centre whilst supporting public transport investment and policies to secure a modal shift to sustainable transport modes. The role of sub-regional centres should be strengthened.

Q16 Local plans best placed to deal with policy issues although there is merit in an overall structure plan strategy to ensure a true mix of uses in town centres.. Colinton Amenity Q15 Structure plan should support draft Edinburgh City Local Plan Policy Retl. Strongly support that plan’s statements about the Association need to safeguard and improve the historic environment of central Edinburgh. Agree that it would be helpful for the roles of regional and sub-regional centres to be more clearly defined.

Q16 Structure plan must support both town and local centres. Policy must resist the loss of commerciaMndustriaI sites in existing local centres by resisting change of use to housing. Smaller offices should be encouraged to locate in local centres. Short-stay street parking should be improved in local centres. Without direct and positive discriminatory action, many small shops will not survive. Retail Impact Assessments must be impartial and take full account of the impact of supermarkets on local businesses. Supermarket operators should make specific contributions to sustain the viability of local centres. Craiglockhart Q15 Additional off street parking will retain custom, otherwise this will transfer to out of town centres. Community Council Q16 Make it easy and convenient for customers Cramond Association Q15 Given the state of Princes Street shop-fronts, strict standards should be established and enforced.

Q16 Difficult task - quality establishments must be encouraged to stay or set up by good parking and pleasant street-scape. Damhead Community Q15 Consider town centres the best place for retail development. Council Q16 Concentrate on improving quality of shopping facilities in city centres and easier parking. No more out of town shopping centres. Forth Ports PIC The consultation paper is insufficiently transparent about retail capacity across the Lothians and fails to explain the relevance of EARNS to retail capacity conclusions.

Retail capacity distribution should continue to focus on the City Centre and on sustainable and accessible locations. Ocean Terminal should be recognised as a key location to accommodate significant retail and leisure development and that review must properly reflect this position. Go reb ridge Q15 Preserve and strengthen the uniqueness of Edinburgh city centre. With a more insightful vision the city can face any Community Council competition with confidence, and that competition should be encouraged as a stimulus to development.

Q16 Maintain and improve town centre environments, with a more sensitive taxation regime for small businesses. Grange Association Q15 A greater degree of pedestrianisation might enhance the city centre. Plan should make it clear that regional and sub-regional

63 centres should be lively, self-contained entities with a range of amenities, and not dormitory towns.

Q16 A policy of mixed business and retail development would ensure that districts do not become ‘ghost towns’ after office hours. Cumulative imDact of a series of develoDments must be assessed. DeveloDment should include oDen Dublic mace. I, Greenhill & Church Hill Q15 Combine’ with existing pedestrianisation and expand park & ride. Amenity Association Q16 Introduce special city centre retail premises business rates Gyle Shopping Centre Q15 Recognises the importance of retaining Edinburgh city centre as the primary retailing destination within Edinburgh & The General Partner Ltd Lothians. Requests that the review includes a policy specifically related to out-of-town centres, defining their role and providing policy support for their enhancement and sustainable expansion. This would include centres such as the Gyle

Q16 Considers that review should contain a specific policy aimed at securing the long-term future of town centres. This would define what would be considered as a town centre and the types of acceptable uses. The policy should recognise that centres such as the Gyle can fulfil the function of a traditional town and local centre. Henderson Global Seek clarification as to the position of all the Structure Plan authorities on the Edinburgh Area Retail Needs Study (EARNS). Investors Concern that the consultation paper does not properly and transparently address the EARNS findings of a surplus of non-food retail spending and the distribution of this shortfall across the Lothians to 201 5. If review process based on EARNS then that study and its assumptions must receive full and transparent scrutiny - at what stage is this scrutiny appropriate?

New retail floorspace should be prioritised in the City Centre, sub-regional Livingston town centre and other town centres as first choice, and thereafter only other major shopping centres of strategic importance.

Supportive of the structure plan’s focus on Edinburgh City Centre as the first choice for major retail development. Express concern that the performance of the Almondvale Centre in Livingston and the growth of Fort Kinnaird are to the detriment of the regional function of the City Centre. A full review of retail policy is required to ensure that the primacy of the City Centre is not undermined and that retail expansion outwith there is focussed on the most accessible and sustainable locations. Hercules Unit Trust Critical of the apparent reliance on EARNS which they regard as a flawed study. It should not be a justification for policy.

In respect of town centres, the planning authority should enter into innovative partnerships with developers, landowners and retailers to deliver larger and more modern “floorplates” necessary for retail investment in the city centre. Planning authorities should recognise that in due course major shopping facilities may fulfil all the town centre functions for their particular area of the city. Significant differences in the characteristics of major shopping centres should be recognised in policy. Submit that NewcraighalVThe Jewel is effectively functioning as a town centre. John Lewis Q15 Success of Edinburah Citv Centre in manv fields is not reDlicated in terms of retail success as the dace to ao to in comDarison

64 Partnership with competitors. Need policies that sustain the City Centre as a living centre, eg mixed tenure affordable housing and a strong leisure and entertainment culture. City centre should be given priority over out of town areas in view of its accessibility. Structure plan should make a definitive statement of intent indicating no support for further out of town and retail park development in order to sustain the City Centre. It should also explicitly state that the City Centre is the Regional Shopping Centre for the Lothians. Left unchecked, development on sites such as Ocean Terminal could undermine the sustainability of the City Centre, while edge of town retail parks will put additional pressure on transport and local roads.

Q16 The plan should note the renaissance of Glasgow and Newcastle and recognise the strategic importance of developments at the East End of Edinburgh. It should reiterate the premier role of the City Centre as the Regional shopping centre and recognise and ensure a mix of activity. It should ensure that any proposals for car parking and traffic management were not deleterious to the commercial viability of John Lewis Partnership, given that the private car is the most used mode of customer transport. There should be a specific section in the plan about how to grow the City Centre and the infrastructure required.

Kniahtd Frank LLP Object to the assumption that no further retail development is needed in view of increasing per capita retail expenditure figures. Land Securities Q15 Consider that the current structure plan’s retail policies remain valid. Little need to more clearly define the respective roles of Edinburgh city centre, as the regional centre, and Livingston town centre, as a sub-regional centre.

Submit that Edinburgh city centre’s comparison shopping role has been far more affected by retail development at the Gyle, Cameron Toll, Ocean Terminal, Fort Kinnaird and Straiton than by the Almondvale Centre in Livingston. Lasswade District Q16 Potential for adverse impact on existing town centres of any proposed retail development should be evaluated independently Civic Society and professionally. The business tax regime should be reviewed. Liberton Association Q15 Role of Edinburgh City Centre must be maintained and enhanced. Clear definition of roles desirable.

Q16 Make clear provision for small retailers Loanhead and District The traditional town or village centre has all but vanished in place of the convenience of shopping complexes such as Straiton Park. Community Council Given the policy of car restrictions and poor parking, the City Centre will continue to decline other than in highly specialised areas. Shopping policy should focus on building up the city’s uniqueness rather than trying to compete with out of town centres. Lyndon, R F The car must be given higher priority in order to encourage commercial activity in the city centre. The idea that public transport reduces congestion is a dubious one. Continued commercial viability of the city centre will depend on its attractiveness to shoppers and businesses. Department stores will always be a major attraction but they must be reasonably accessible (ie parking nearby). Merchiston Community Q15 Deplore the continuing decline of Princes Street. Attractions such as the Gardens, Castle, etc must not be obstructed by Council buses and trams that could be accommodated in a tunnel below street level. Major reappraisal of north side of Princes Street required.

Q16 The local authority, local property owners and tenants should set standards for each central street, with power to penalise nonconformity with increased rates.

65 Midlothian Council Believe that supporting and enhancing Edinburgh City Centre requires a more imaginative approach that simply trying to curb the role of other major shopping centres. The City Centre needs to be more accessible, competitive and offer a different shopping experience to sustain its long-term health.

Midlothian Council continues to express concern at the scale of leakage from Midlothian of expenditure on comparison goods (87% in 1999). Consideration must be given to improving the public transport accessibility of Straiton Retail Park. Murrayfield Particularly concerned about the extremely poor quality of the centre of Edinburgh. Princes Street still a busy, noisy transport route Community Council making shopping and socialising an unpleasant experience. The public realm must be brought up to the best international standards. Musselburgh Q15 Plan should facilitate appropriate development and ensure fast and frequent public transport services are available into the Conservation Society city centre from all locations. Musselburgh & Q15 Plan should facilitate appropriate development and ensure fast and frequent public transport services are available into the lnveresk Community city centre from all locations. Council National Grid Property Supports continued backing for the key role played by Edinburgh City Centre and agree that it should remain the focus for major Ltd retail development. Peel Developments Not unreasonable for development plans to identify appropriate town centre retail opportunities in conjunction with stakeholders. Ltd Plan should support a network of centres with their respective roles and functions identified. Plan should continue to include a similar policy framework to structure plan RET5 Penicuik & District Q15 Query why this question is being posed since the obvious answers will be ignored, ie placing a veto on further development at Community Council The Gyle, Ocean Terminal and Fort Kinnaird.

Q16 Solution is a complete halt on all out-of-town and edge-of -town developments. However, note that major retailers will now

only open branches in retail parks. Also concerned about the ownership of town centres and high- rents, leading to a desert of mass-produced, poor quality chain stores and empty shop fronts Performance Retail Seek clarification as to the position of all the Structure Plan authorities on the Edinburgh Area Retail Needs Study (EARNS). Limited Partnership Concern that the consultation paper does not properly and transparently address the EARNS findings of a surplus of non-food retail spending and the distribution of this shortfall across the Lothians to 201 5. If review process based on EARNS then that study and its assumptions must receive full and transparent scrutiny - at what stage is this scrutiny appropriate?

New retail floorspace should be prioritised in the City Centre, sub-regional Livingston town centre and other town centres as first choice, and thereafter only other major shopping centres of strategic importance.

Supportive of the structure plan’s focus on Edinburgh City Centre as the first choice for major retail development. Express concern

66 that the performance of the Almondvale Centre in Livingston and the growth of Fort Kinnaird are to the detriment of the regional function of the City Centre. A full review of retail policy is required to ensure that the primacy of the City Centre is not undermined and that retail expansion outwith there is focussed on the most accessible and sustainable locations. The review must recognise the importance of Cameron Toll and its ability to accommodate a significant share of available expenditure capacity. Poltonhall & District Q15 Town and city centres are in decline and large companies want to site their stores where they can have large units and ample Community Council free parking. Shopping complexes are used by the public to provide for their needs at one site. This trend spells the end of the small shopkeeper in the high street.

Support for the expansion of the Gyle and Fort, but opposed to expansion of Straiton and McArthur Glen. Any development of Edinburgh towards a world class city should not be at the expense of surrounding towns.

Q16 ImDrove facilities and accessibilitv to meet needs of those who visit town centres for occasional needs. Rosewell & District Q15 Yes Community Council Q16 Stop allowing unnecessary expansion of retail parks RBS Q15 Substantial policy support in current structure plan but financial support required to improve the public realm, shift transport modes and secure the highest quality tram system for Edinburgh. Transport proposals need to underscore the accessibility of the city centre.

Q16 Support for continued primacy of city centre and other town centres, including encouragement of high density residential development and consideration of their role as destinations with some form of park and ride linked to them. RHASS Q15 The model for 2040 needs to be embraced more clearly

Q16 Sole traders should be offered incentives in town centres and the ‘big shed’ operators set in semi-industriaVpark sites Scottish Borders Q15 Support maintenance and enhancement of identified town centres Council Scottish Enterprise Q15 Would welcome additional support for the development and redevelopment of sites in and around Princes Street for additional Edinburgh and Lothian high quality retail floorspace. Revised plan should give highest priority to directing new retail development to Edinburgh City Centre and carefully manage the growth of sub-regional and out of town shopping. Structure plan should support increased investment in the public realm and the provision of improved event space in the City Centre.

Q16 Consider that scope should be provided within all town centres for significant growth of high quality retail and compatible town centre developments. Wherever possible, commit to a town centre action plan, high quality development and resources for town centre management. SEPA Q15 Promote more significant investment opportunities in the city centre whilst preserving its special built and natural environment

67 as far as possible. Locate new development to maximise sustainable transport modes. Provide a framework for urban design, briefs and masterplans. Clearly define role of regional and sub-reqional centres.

Q16 Discourage unsustainable out of town development and advocate use of the sequential approach to enhance the viability of town centres. Ensure good public transport accessibility. Taylor Woodrow Q15 The structure plan should support and if possible enhance the City Centre’s role. There is a need for further clarification of the Developments respective roles of regional and sub-regional centres. Ltd/AWG Properties Ltd Q16 The plan needs to encourage the expansion and development of retail centres. Developer contributions should be sought from retailers for necessary upgrades to services/infrastructure. Taylor Wood row Q15 The plan should place emphasis on Edinburgh becoming the most successful and sustainable city in northern Europe. A clear Developments definition of the roles of regional and sub-regional centres is required.

Q16 A comprehensive review of the structure plan must be undertaken that comprises a long-term development strategy dealing with these issues. Tesco Stores Ltd Q15 The term ‘sub-regional centre’ needs explanation. Agree that the role of the city centre should be more clearly defined: its many roles cause conflicts and constraints. The city centre does not lend itself to major new shopping development and a balance is needed between investment in it and in other important centres that meet people’s needs. The complementary roles that the various centres in Edinburgh and the Lothians have in meeting retail needs should be recognised. City-centre types of retail development should be directed to the city centre while developments that have a more localised role should be directed to the other centres in the city where they will be readily accessible to those who need to use them.

Q16 The structure plan should support not just defined town centres but also the other centres which meet retail needs. Most town centres in Edinburgh and the Lothians are physically constrained. The plan should promote the complementary roles of the defined town centres and the other centres so that each centre exploits its potential and has a role to play within an overall strategy/hierarchy. The plan should promote development in centres that have a realistic prospect of implementation. Thomson, Walter Q15 Current balance between city centre and out-of-centre shopping sites is about right.

Q16 Adequate car parking is the key. Suggests that it would not be technically difficult to provide multi-storey underground car parking in the city centre. Tie Q15 Existing plan gives adequate policy support: it is financial support that is now needed, eg, to upgrade the public realm, ensure radical shifts in mode of transport and ensure delivery of the full network and highest quality setting of tram network for Edinburgh.

Q16 The plan’s support for the primacy of the City Centre and other Town Centres should be continued. Encouragement of high density residential development will also help support town centres. The key link between town centres as destinations and the

68 provision of transport interchanges should be recognised and developed. TRANSform Scotland Q15 The plan should endorse the City of Edinburgh Council proposals for public transport investment and policies aimed at achieving road traffic reduction and modal shift. Turner, Barry Q15 Plan should facilitate appropriate development and ensure fast and frequent public transport services are available into the city centre from all locations. Wester Hailes Q16 Wester Hailes should be elevated to ‘town centre’ status as it embodies the key characteristics and functions that define a Shopping Centre Ltd ‘town centre’. Its vitality and viability should be sustained and enhanced. Policy should direct new retail and other key town centre uses to these locations in the first instance. The structure plan should identify a network of centres and set out their differing roles.

There is no explicit reference to the Edinburgh Area Retail Needs Assessment: if policy is to be based on this then that study must have full scrutiny and public debate. Clarification required as to the stage in the ELSP review process at which this scrutiny is

LOOKING FORWARD (Questions 17 to 19)

AWG Ltd & Taylor Acknowledges SP concerns about environmental damage and lack of community infrastructure as constraints to development. Woodrow However considers it possible to protect landscape as part of growth strategy. Infrastructure more difficult to resolve - suggest Development Ltd establishing an ‘infrastructure working group’ of key stakeholders. (Turley Associates) Supports the ‘concentrated’ model of longer term City Region growth. Need to consider locations close to Edinburgh, either physically, or through good transport links, specifically rail and tram. Exception to this is Blindwells, which is supported by the I submission. BAA Edinburgh Fully agree that the Edinburgh City Region should plan for significant growth 2020 - 2040 - national economy depends on continuing growth in this region.

Support the 2040 Vision of radial development corridors based on public transport routes together with network of strategic green wedges. Traditional Green Belt is outdated. Support CEC attempt to consider innovative solutions to manage urban growth and considerable development pressures particularly in west Edinburgh Carrie, Johanna Q17 Plan should be flexible to allow growth when and if needed.

Q18 Reluctantly support concentration rather than dispersal.

Q19 Supports concentrating development along corridors. Need for improved public transport. Affordable housing should be close to employment. Scope to move employment to outer towns like Penicuik. Also consider decentralised energy provision. Clippens Support higher levels of growth and dispersing some growth around wider City Region. Dispersal is more sustainable; important to

69 Developments Ltd get balance right. Growth should be spread between City and surrounding centres with appropriate infrastructure, or capacity for (Andrew McCafferty enhancement of infrastructure. Scale and setting of Edinburgh can be maintained whilst benefits of growth spread. Spread of Associates housing and jobs will ensure long distance commuting is contained. City of Edinburgh Responses to Qs 17 to 19 set out in document “A Vision for Capital Growth”. CEC believes we should plan for significant economic Council and population growth beyond 2020, and that this growth should primarily be directed into a number of growth corridors radiating out from the core city. These corridors should be based upon and supported by existing or potential high quality public transport routes. This development pattern would entail reconfiguring the green belt into green wedges with a focus on landscape and recreational enhancement and public access, and with strict controls on new development. Cockbu rn Association Welcomes opening of debate. Expected rats of growth may not happen, and in meantime emphasis should be on protecting resources. Doesn’t necessarily accept that economic success requires population growth. The Vision may threaten the liveability of the city: protection of the character of the city centre should be built into any long-term strategy. Suggests more intensive use of suburban areas as a policy option. Does not dismiss development corridor approach subject to caveats. Audit required of existing green belt and open spaces. Colinton Amenity Q17 Edinburgh is already one of most successful cities in Europe. Quality of life is widely appreciated by community, Association environmental & business interests & is principal attractor for present growth. The components of quality of life must not be damaged by excessive growth.

Due to importance of growth question all households in the City Region should be included in consultation, in line with ‘Modernising the Planning System’ requirement for more effective and meaningful involvement of communities.

Support strongly the case for lower levels of growth, but these still need to be determined and based on sustainability principles, to avoid damage to environment and quality of life.

Do not support case for higher levels of growth - 0 Scottish Executive should determine distribution of growth amongst city regions/ Scotland as a whole; 0 Critical of methodology of St Andrew’s scenario planning exercise and Experian study due to skewed samples and questions; 0 Do not consider there is a strong link between growth and increase in GDP (& prosperity or community happiness); 0 Do not take account of real possibility of damage to Edinburgh’s quality of life; 0 Do not consider enough research carried out into reasons for commuting, feasibility of eliminating commuting, adverse impacts upon landscape of reducing commuting (caused by development along transport corridors).

Q18 Suggest a combination of concentrating development in some locations near settlements within Edinburgh Green Belt where minimal adverse effects would occur (refer to Q19) and dispersing development elsewhere in City Region or around Scotland.

Q19 Onlv essential arowth should be Dlanned for - need accurate assessments of future arowth. Outer edaes of settlements/

70 countryside (Green Belt) are important for setting, recreation and quality of life. Need to carry out environmental audit of capacity of Green Belt & edge of settlement green spaces to accommodate growth without damage - lead to identification of areas for growth and green spaces to protect. The latter should be given long term protection against development (as per SPP21). All areas for growth should have development of good design, well integrated into landscapes. Craiglockhart Q17 Should plan for significant growth between 2020 and 2040. Community Council Q18 On balance development should concentrate around Edinburgh. May not be able to determine how dispersed development will be due to influence of market forces. Very concerned about loss of parts of Green Belt, which has been protected for many years. Opportunity for huge planning gains - should be captured for benefit of city and its people.

Q19 Need to assess planning applications for sustainability; closer collaboration needed between Planning and Building Control. Cramond Association Q17 Possibly plan for significant growth, however must consider possibility of any economic down-turn or melt-down.

Q18 Support dispersal. Current SP has emphasis on flatted dwellings for single/ double occupancy. Need to provide choice for those wanting dwellings with gardens. Example of current large numbers of commuters from Fife, EastlMidNVest Lothian.

Q19 Careful study of planning applications; maintain high standards of design; apply environmental assessment. Currie Community Q17 Support the case for lower levels of growth. Do not consider there is a need to plan for significant growth- do we want to Council grow? Should have discussed what are the implications of not growing? Suspect there will be a need to consolidate rather than expand. Maintain flexibility by restraint at this time.

Global and European trends - questions the likelihood of early expansion of working population through later retirement (resistance from population); need to take serious note of impact of climate change/ rising sea levels, by not placing development near sea front.

Edinburgh should not be seen as engine of growth - should not consider its needs at expense of other communities and regions. Technology may diminish need to meet labour needs locally.

Q18 Support brownfield development. Do not support concentration, as wedges will ultimately become developed, as per previous experience of growth of city. Support dispersal - regenerate/ revitalise existing communities; create jobs to reduce commuting; improve infrastructure; restore balance. More attention should be paid to potential of other regions (Fife, Galashiels).

Q19 Locate more local industries in communities other than Edinburgh - already local infrastructure; reduce dependence on travel; avoid need to despoil a country that depends on its beauty and tourist industry; bring life and decision-making back to local level. Dalmahoy Estate Q17 Supports the case for significant growth 2020-2040. -will assist the development of sustainable communities & provide

71 (Strutt & Parker) certainty to service and infrastructure providers for their funding programmes.

Supports a development corridor along the lines of the Calder/ Currie corridor in the 2040 Vision, including land within the Dalmahoy Estate -would generate developer contributions to High Speed Glasgow link and Shotts Line upgrade.

Q18 Supports concentration of development around Edinburgh, along strategic public transport corridors, along with strategic green wedges. Dalmeny Estate Q17 Supports the case for significant growth 2020-2040. -will assist the development of sustainable communities & provide (Strutt & Parker) certainty to service and infrastructure providers for their funding programmes.

Supports a development corridor along the lines of the Calder/ Currie corridor in the 2040 Vision- would generate developer contributions to High Speed Glasgow link and Shotts Line upgrade.

Q18 Supports concentration of development around Edinburgh, at existing islands of urban development and along strategic public transport corridors, along with strategic green wedges. Damhead Community Q17 No - should not plan for significant growth 2020-2040 -there has been tremendous development in recent years. Council Q18 Should concentrate development on brownfield sites where possible.

Q19 Maintain the Green Belt and avoid coalescence at all costs, to prevent sprawling development from Edinburgh. Dunalastair Estates Q17 It is appropriate to plan for significant growth 2020 - 2040. Adopting a longterm vision for development will support (Derek Scott Planning) investment in infrastructure, which will be important for growth and economic prosperity of the city.

Q18 Supports dispersal of future growth to areas which are easily accessible to main centres of population and employment through choice of modes of travel. Sites suggested meeting this criteria at Wallyford and Kirknewton, as suitable for housing. ED1 Group Cannot postpone decision on level and distribution of growth, due to problems of plan preparation slippage.

Supports higher levels of growth - could support planned investment in improving transportation in the city. Long distance commuting might be reduced if demand & supply for housing was better balanced in city.

Concentrate growth on main public transport links in city and immediate hinterland rather than dispersal further afield in Lothian and beyond. Example of location on edge of city well served by public transport - Brunstane/ Newcraighall - should support family housing.

Support 2040 City Vision development corridor approach - should be developed for long-term settlement strategy. SPP 21 needs

72 to be addressed through SP Review. Esk Valley Trust Q17 Edinburgh is about an optimum size at present. The GROS(S) statistics provide some justifiable support. Edinburgh is naturally constrained by the Pentland Hills & the Forth. Need to avoid pressures to allocate increasing levels of housing (as in Southern England) which would result in ‘wall-to-wall’ concrete. Believes encouraging in-migration leads to continuing spiral of pressure for more housing; requiring more jobs, etc, ultimately leading to over-stressed population and forever loss of greenspace.

Q18 Alarmed at prospect of ‘Finger Plan’ development & abandonment of Green Belt. Supports principles behind SPP 21 (subject to para 13 not being treated as a capitulation), rather than 2040 City Vision.

Easier to defend a well defined ‘Belt’ rather than growth corridors that would have greatly extended perimeter boundaries which would be easier to erode surreptitiously. Loss of a Green Belt is fraught with irreversibly risk.

Coalescence of identifiable communities is disastrous - it leads to loss of civic pride, youth disengagement, vandalism, etc.

Any future expansion should firstly consider City brownfield, and then small self-sufficient satellite towns, mainly in the Borders (refer Waverley Rail Line).

Q19 Professional testing, includin Environmental Impact Statements, of planning applications. Concerned about lack of appeal rights for (often knowledgeable) 3r2 parties. . Onus on Councils to assess applications, identify compensating infrastructure, monitor development and enforce planning conditions. Fairm ilehead Q17 Require a 2020-2040 plan or vision, but needs to be capable of alteration according to future situation. Significant growth may Association not happen; transport costs may soar.

Q18 Neither vision for growth should be regarded as absolute. Impact of ‘Blue Belt’ development not certain; future development should make greatest use of brownfield sites within region.

Consider Green Belt areas within the City (eg Colinton Polo fields, Liberton Drive, Midmar Field) under pressure from developers, but valued by communities. Whereas some arable land in Green Belt lacks biodiversity (due to lack of hedges/ trees and crop spraying) which could be made available for development in the future, whilst safeguarding the GB areas within the Bypass.

Q19 Important that full environmental impact assessed and mitigated according to future circumstances. Development needs to be as sustainable as possible. Fife Council If present trends continue then it is likely that growth will be sustained in the long term and it is therefore important to plan for this in a sustainable way. In this respect Fife Council is committed to working closely with the Lothian authorities in response to the new strategic planning arrangements being proposed by the Scottish Executive.

73 FM Developments Ltd Q17 As CEC has indicated it wishes to promote growth in its 2040 City Vision, need to plan for and mechanisms set in place to deliver future growth - substantial lead in times for infrastructure. Cannot await City Region Plan. Certainty is required in development plans to enable ’joined-up’ approach for infrastructure provision. Developers/ housebuilders, and other bodies such as Scottish Water need a degree of certainty beyond Structure Plan - need land allocations/ safeguarding, planning consents/ Section 75 Agreements. Need to set strategy, including Green Belt review, to 2028.

Q18 Need to create a sustainable pattern of development responding to market forces and economic trends. Need macro growth within Edinburgh and local growth in core development areas in individual local authorities. If sustainable development is the aim, there needs to be substantial development including greefield land releases on periphery of Edinburgh up to City Bypass, including land in Midlothian & East Lothian. In support of 2040 City Vision suggest inclusion of land at East Hermiston, Currie and Dovecot, Haddington.

Q19 Promote a development strategy which follows SPP3 guidance on sustainable development. Carry out a Strategic Environmental Assessment of the Structure Plan. Considers suggested land allocations represent sustainable development and accord with current development strategy of approved SP. Forth Ports PLC Supportive of growth. Concerned to create an effective city-region-wide political structure to oversee strategic decisions. Priority should be development of previously-developed land within Edinburgh. The capacity of this won’t be known until a detailed assessment done. Development must be in parallel with investment in infrastructure. Scope to reclaim more land from the sea. Finger plan worth exploring further, especially West Edinburgh. The candidate corridors should be prioritised. Friends of the Consider Green Belt should be a priority for preservation. Support retention of green wedges (including Hermitage of Braid LNR). Hermitage of Braid Need to retain Green Belt around south of City, as a natural counterpart to seashore to north. and Blackford Hill Green Belt should not be ‘broken up’ (reference to SPP 21) - consider it is acceptable to have housing & industry spilling over outside city, provided reasonable transport links to Edinburgh available. Expansion in city should be principally on brownfield where practicable. Go reb ridge Q17 Authorities should be ready to take advantage of opportunities for growth as they arise. However should not consider that Community Council growth is inevitable - ‘economic reality has a habit of confounding expectation’.

Q18 Do not agree with reference to ‘city region’ - ‘structure plan area’ remains the relevant reference. Housing dispersal should be accompanied by economic development. Successful communities need successful economic conditions, sustainable environments, and social & community facilities.

Q19 Respect the Green Belt. Grange Association Q17 If indicators support the case, agree to plan for significant growth. Recognise that there are uncertainties in projections, but need to be ‘ahead of the game’.

74 Q18 Support the concept of development corridors and green wedges for future development. Growth should include all amenities to support independent communities along the corridors & avoid unnecessary travel.

Q19 Adhere to highest building standards - above national levels. Limit hard landscaping; include open space, apply energy efficiency standards. Establish guidelines on sustainable development - limit population density, building height, builthatural environments. Management of natural environment should be area-wide to avoid piecemeal development. Greenhill & Church Hill Q17 Seeks definition of “significant”. Would not support if result in large increases in commuter traffic by car from outside region. Amenity Association Q18 Favour dispersal to other less favoured regions of Scotland.

Q19 Business expansion should be brought more into line with local new entrants to workforce. Hallhill Developments Acknowledges SP concerns about environmental damage and lack of community infrastructure as constraints to development. &Taylor Woodrow However considers it possible to protect landscape as part of growth strategy. Infrastructure more difficult to resolve - suggest (Turley Associates) establishing an ‘infrastructure working group’ of key stakeholders.

Supports the ‘concentrated’ model of longer term City Region growth. Need to consider locations close to Edinburgh, either physically, or through good transport links, specifically rail and tram. In this regard Dunbar is well placed having frequent train service and is supported by the submission. Hart Estates Ltd Q17 It is appropriate to plan for significant growth 2020 - 2040. Adopting a long-term vision for development will support (Derek Scott Planning) investment in infrastructure, which will be important for growth and economic prosperity of the city. Councils need to adopt a proactive attitude to development.

Q18 Supports dispersal of future growth to areas with unmet demand for new housing and which are easily accessible to main centres of population and employment through choice of modes of travel. Sites suggested meeting these criteria at Philpstoun, Gilmerton, Gullane & Old Craighall, as suitable for housing. Heller. Martin Considers that introducing Green Fingers would inevitably lead to breaking up and destruction of Green Belt. It would contribute to urban sprawl and ribbon development. Continuing demand for greenfield land will lead to creeping pressures on land further out - communities will be absorbed and lose identities, eg as has happened at Colinton, Stockbridge. Concerned about implications for Hermiston village.

Development of land between the ‘fingers’ will increase traffic congestion in City. Need efficient, cheap and regular public transport, especially from East and West Lothian & the Borders. Borders rail line should be able to take freight.

Why do we need more housing when population is declining?

75 Homes for Scotland Q17 Current development plan framework and land supply does not meet Lothian’s needs at present, let alone 2020-2040. Advocates a 20-year strategic plan which would include part of the 2020-2040 period. Considers 2040 City Vision articulates well the issues facing the area.

Q18 Focus of demand & economic activity is Edinburgh. Outmoded view of Green Belt has resulted in land allocations being constrained in & close to Edinburgh. Consequence is unsustainable pattern of development. Outmigration being encouraged through land allocations in pursuit of growth in areas beyond the Lothians. Comments on Lothian Councils lack of comment on Fife Structure Plan’s overt aspirations to attract growth from Lothians.

Agree a new approach needed based on corridors and green wedges. Higher level of development needed in & close to Edinburgh & only way to be achieved is through corridor/ wedge approach. Corridors support infrastructure, transport patronage & flexibility. Allows for retention of genuinely valuable areas of open space potential for better access to these. Orbital transport provision, as referred to in 2040 Vision, will provide links between peripheral employment areas and residential areas.

Q19 Current strategy and patterns of development & movement are moving away from a sustainable approach. 2040 City Vision approach moves towards a more sustainable pattern of development. Sustainability on the ground needs discussion through master plans, site briefs & the EIA procedure. Recommend discussion/ partnership with stakeholders. Ian Gotts Associates Q17 Support planning for significant growth, as otherwise consequences for Scotland would be extremely worrying. To compete on national, UK & international basis targets for growth must be set. Policies on housing & affordable housing are needed to retain & attract people to City region.

Q18 A balance is needed. Development needs to be shared between City and rest. To achieve sustainable form of development, City has to grow. This will support provision of major strategic infrastructure, eg Trams, & support Airport expansion. Green Belt strategy and boundaries should be reviewed - identify areas that can be developed most sustainably - locate housing, public transport that relate to employment with least impact on areas of high landscape value.

Q19 Planning authorities need to be well resourced & officers & members appropriately trained to ensure understanding of possible impacts, alternatives & mitigation measures to ensure delivery of sustainable development. John Lewis Q17 Considers there is overwhelming evidence to support growth. There is a current mismatch in the city region between labour Partnership supply and growing urban sector, resulting in workers being ‘sucked in’ to the capital from rest of city region & beyond, resulting in pressure on transportation systems & unsustainable commuter travel. Therefore need to invest in infrastructure to support growth, need to protect green wedges.

Q18 Growth should be based around infrastructure (transportation). Prefer City of Edinburgh to be main area for growth as, on retail front, this would be a means to address competition from Glasgow, Newcastle & others in City centre retailing.

76 Q19 Emphasise planned development should be infrastructure led. Re retailing city centre can utilise & develop exiting transport strategies. Lasswade District Q17 Economic development should be encouraged where possible to locate elsewhere in Scotland - reduce longstanding Civic Society excessive pressure & adverse impact on Edinburgh & Lothians; spread benefits more widely.

Q18 Nevertheless growth is inevitable; jobs & housing should be co-located to minimise commuting. Suggest establishing another large new settlement, not necessarily within region. Considers any strategy based on green wedges could only be considered if major expansion of region supported, but decision would need to be taken at a national rather than regional level. Continuing growth would destroy the region’s assets, already process could be considered to have gone far enough.

Q19 All Structure Plan and Local Plans protections be maintained through consistent decision-making/ enforcement. Leith Central Q17 Concerned that focus is on growth rather than on ensuring good quality of life and prosperity for all its citizens. Growth can Community Council herald decline for established communities such as Leith, Marchmont, etc. Considers risk of over estimating population growth. Need to consider the impact of changing working environments. Improved rail links, ferry links across Forth - opportunities for good access from established communities could redress labour demand/ supply mismatch.

Q18 Considers finger approach could have a negative impact on existing areas of City. More family non-flatted properties need to be developed in the City - refers to difficulties in selling flats in Waterfront area. If more attractive housing is available in ‘fingers’ there could be a drift of the economically active to these areas - Edinburgh will become more socially segregated than it currently is. Concerned at closure/ transfer of facilities (university/ leisure/ educational/ hospital) to periphery of city - could result in residents in the ‘fingers’ not having to come to City to access facilities. City centre may be sustained by tourism, the Parliament & City Council HQ. Travel may concentrate on movement between fingers, rather than finger-City centre. Need to concentrate on providing housing, employment & services for all ages within the City.

Q19 If Copenhagen ‘finger’ model is adopted, may be preferable to replace local government structure by one authority. Concerned that once areas for development established & Green Belt breached these areas will be attractive to develop, even if economic growth does not occur - need safeguards. Liberton Association Q17 Unclear as to meaning of “significant growth”. It is important to maintain the scale & setting of the city.

Q18 Development should be dispersed around city region. It is unreasonable for city to bear full weight of development.

Q19 Publish an Open Space Audit - assess landscape value, accessibility, biodiversity of open spaces; defend these valuable assets. Loanhead & District Strong views on this section; ideas seem to be “Edinburgh centric”; whatever growth options it appears outlying areas are there for

77 Community Council the city’s convenience. Would oppose any planned growth that would encourage coalescence, loss of local identity/ character/ history/ community aspirations, and transformation into dormitories for Edinburgh. Would welcome improvements to infrastructure, particularly across-region access, and decentralised employment opportunities. Although not agree with slant on advantages/ disadvantages listed, would favour “dispersal of growth” option. Lothian and Borders Calculate that the estimates could result in 6% growth in population. This will have implications for police resources. As growth will Police be contrary to decline elsewhere, this needs to be recognised, and there will be a need for additional funding to cope. With the growth, along with other police pressures resulting from Edinburgh’s various roles (Parliament, universities, Festival), resourcing will be an issue. Concern that the City draws a lot of police resources and this has an impact on policing in outlying divisions. Emphasises the need to design out crime in any developments. Lothian Park Ltd Q17 Significant growth should be planned for as the City of Edinburgh Council has indicated it wants to promote growth in 2040 (RPS) Vision. This will need substantial lead-in times to co-ordinate & deliver infrastructure. Cannot await City Region Plan. Must include jobs as well as homes. Certainty in development plans is required to support joined up approach to infrastructure provision. Need to review the Green Belt. Suggest Craighall would be suitable for further development.

Q18 Support local growth in each core development areas, and macro growth within Edinburgh. If aim is for sustainable development, scale of growth should be substantial/ include greenfield land releases on periphery up to City Bypass, including land in Midlothian & East Lothian. Craighall in East Lothian is suitable for further economic land (10 ha) -suited to a prestigious headquarters; located in transport corridor/ well served for public transport; within Eastern Growth Corridor promoted in 2040 Vision.

Q19 Development strategy should adhere to guidance in SPP3, and the Alteration should be subject to Strategic Environmental Assessment. Proposals promoted by Lothian Park will improve sustainability of approved development plan. Lyndon, RF Radial development is, or will be perceived as, ribbon development. The city will appear larger because it is spread out further into countryside. Radial development runs risk of suburbs with no commercial heart. Suggests it is possible to develop multiple centres around Edinburgh without losing their identity, eg Colinton, Morningside. Their identity being the focus of local amenities/ distinct character. Considers the fingers of green space will benefit fewer people than enclosed green spaces within a larger City. Merchiston Community Q17 Planning for growth should be viewed in terms of impact on environment, housing costs, congestion, infrastructure burden & Council quality of life.

Q18 Modern technology could allow effective business development in areas at a distance, eg Galashiels & Hawick, currently deprived full employment.

Q19 Produce a positive & creative Masterplan once Review complete.

78 Midlothian Council Keen to sustain economic growth, which will need housing to support such growth. Require investment in physical and social infrastructure. Environment and quality of life must be protected. Must avoid coalescence of communities. Scale of growth in Midlothian resulting from planned developments will result in new households equivalent to one third of current total households - need time for this scale of growth to be absorbed.

Investment in transport infrastructure required to support current planned development, as well as for post 2015 growth.

Current 2015SP signals Council’s intention to consider a further phase of proposed new settlement at Redheugh/Prestonholm, along with further development at Shawfair. Reopening Waverley route could allow central Borders to contribute to Lothian housing requirements. Any high growth housing scenario for the Waverley rail line must be accompanied by economic development. Economic growth could not be met in West Edinburgh.

One option for growth which should be evaluated is the development of a new settlement, rather than relying on further major expansion of existing settlements, resulting in ‘creeping coalescence’.

A substantive review of the Green Belt will be required to address SPP21, & needs to consider deletions and additions; and the views of Midlothian’s communities.

In addition the Council generally supports the comments made by those Midlothian Community Councils who made submissions. These included, the need to maintain a strong Green Belt & other measures to prevent coalescence; need to avoid Midlothian communities becoming dormitories; the need for a Green Belt review; concern that the Finger approach would lead to ribbon development; significant growth of the city region would detract form the region’s desirability; encourage use of brownfield sites; need to disperse economic development/ co-locate jobs and housing to minimise commuting; Scottish Borders could accommodate development; a large new settlement, not necessarily in Midlothian, should be considered; and the need for co-operation between authorities. Miller Homes Acknowledges SP concerns about environmental damage and lack of community infrastructure as constraints to development. (Turley Associates) However considers it possible to protect landscape as part of growth strategy. Infrastructure more difficult to resolve - suggest establishing an ‘infrastructure working group’ of key stakeholders.

Supports the ‘concentrated’ model of longer term City Region growth. Need to consider locations close to Edinburgh, either physically, or through good transport links, specifically rail and tram. In this regard Gorebridge is well placed being located on the path of the proposed Borders Rail and is supported by the submission. Similarly North Berwick is supported having a frequent train service. Ministry of Defence/ Seeks a meeting to discuss MOD land interests. Significant property interests - does not always agree with nor accepts all Defence Estates proposed designations for its land. Wish to reserve potential development rights in & around its major land holdings.

79 Musselburgh Should be considering now how growth to be managed post 2020. Prefer a balance between the two options, based upon quality Conservation Society public transport. Development on edge of city and in corridors close to city planned around new tram routes and quality bus corridors. Straiton/ Penicuik corridor is good example without impinging too much on Green Belt. Surprised SP has not given more emphasis to this location. Further away there should be development around rail stations with fast frequent services.

Comprehensive sustainability appraisals should be carried out of Structure Plan and Local Plans, supplemented by appraisals of individual developments. Involve local people in this process. Musselburgh & Should be considering now how growth to be managed post 2020. Prefer a balance between the two options, based upon quality lnveresk Community public transport. Development on edge of city and in corridors close to city planned around new tram routes and quality bus Council corridors. Straiton/ Penicuik corridor is good example without impinging too much on Green Belt. Surprised SP has not given more emphasis to this location. Further away there should be development around rail stations with fast frequent services.

Comprehensive sustainability appraisals should be carried out of Structure Plan and Local Plans, supplemented by appraisals of individual developments. Involve local people in this process. Old Road Securities Q17 Should concentrate on requirement for development up to 2020 and address further requirements to 2040 in a coherent & plc & Arniston Estates conjoined manner at an appropriate time. (Montagu Evans) Q18 Post 2020 growth should be located in sustainable & appropriate locations throughout the SP area.

Q19 Developments should be properly assessed through development plan process and planning applications. Penicuik & District Q17 Does not support term ‘Edinburgh City Region’ Should not plan for significant growth - no certainty as to what levels of Community Council growth will be needed in 34 years time. Planning for 10-15 years is enough.

Q18 REFER TO GOREBRIDGE CC RESPONSE The Borders is in need of development, due to decline in traditional industries. No benefit to mismatch in economic activity between overheating in Lothians and ‘chill’ in Borders. Waverley Line should be viewed as means of opening up the Borders to commercial investment, rather than for commuting. Edinburgh is continuing to inflict growth on three hinterland councils.

Q19 Site developments as close to work locations to reduce commuting. Aim to generate energy for new developments on site. Reassess the Green Belt - maintain some sort of ring around Edinburgh, but increasingly important maintain rings around other towns. Avoid coalescence.. Reaching a point where Edinburgh’s paranoid obsession with its growth will have to stop. Persimmon Homes Q17 Significant growth should be planned for as the City of Edinburgh Council has indicated it wants to promote growth in 2040 (RPS) Vision. This will need substantial lead-in times to co-ordinate & deliver infrastructure. Cannot await City Region Plan. Certainty in development plans is required to support joined up approach to infrastructure provision. Need to review the Green Belt. Suggest Craighall would be suitable for further development.

80 Q18 Support local growth in each core development areas, and macro growth within Edinburgh. If aim is for sustainable development, scale of growth should be substantial/ include greenfield land releases on periphery up to City Bypass, including land in Midlothian & East Lothian. Potential for Craighall in East Lothian to part of a sustainable, long term development strategy; making case for Eastern Growth Corridor Core Development Area, as promoted in 2040 Vision. Includes an indicative masterplan, as promoted by SPP21 - 2000 houses, including affordable homes and indoor concert arena.

Q19 Development strategy should adhere to guidance in SPP3, and the Alteration should be subject to Strategic Environmental Assessment. SP should promote the principles of sustainability. Poltonhall & District Q17 Essential to plan for the future, but need to evolve as events unfold. Community Council Q18 Develop brownfield sites in the City. As Capital grows commuting and rising property prices will continue. City workers should not take priority for affordable facilities over local residents. Shawfair and similar new developments needed, but care required to ensure full service facilities with transport and roads/ avoid ‘choking’ existing suburbs.

Q19 East of Scotland pleasant place to live, with access to countryside/ seaside. Copenhagen finger plan would be a recipe for disaster - lead to coalescence and encroachment into Green Belt areas. Must protect greenfield areas, as once such amenities lost, lost forever. Portobello Amenity Q18 The Green Belt should be protected as a single entity. Against the idea of development corridors cutting through the Green Society Belt. This would result in significant growth of Edinburgh to detriment of its character, heritage & beauty. Premier Property Acknowledges SP concerns about environmental damage and lack of community infrastructure as constraints to development. Group Ltd However considers it possible to protect landscape as part of growth strategy. Infrastructure more difficult to resolve - suggest (Turley Associates) establishing an ‘infrastructure working group’ of key stakeholders.

Long term vision needed rather than incremental planning. Supports the ‘concentrated’ model of longer term City Region growth. Reduces need to travel. Spokes/ wedges approach reflects SPP21. New woodland parks and recreational land could be located in wedges. Inadequate supply of new family/ executive housing. Well located development along public transport corridors would be highly attractive to developers & potential occupiers. Suggesting land at Baberton, Gogar, Ratho Station would be suitable for growth. Rosewell & District Q17 Should not plan for significant growth, as the population is decreasing. Community Council Q18 Prefer concentrating development around Edinburgh.

Q19 Failed up to now to deliver sustainable development. Suggest slow development rate and concentrate on delivering quality rather than quantity.

81 Royal Bank of Q17 Edinburgh’s growth should be encouraged and provision made. Hard to predict pace of growth - ensure flexibility - consider Scotland contingency scenarios to address different rates of growth.

Q18 Pattern of future strategic growth needs to ensure integration between housing & economic development. Need to protect Edinburgh’s existing assets, particularly greenspaces as contribute to quality of life & image. Good strategic links of western area of City (around airport & M8/M9) - should be safeguarded for possible future economic development. Position recognised in West Edinburgh Planning Framework - needs to be reflected in SP Alteration.

Q19 Assume SEA will be required - will help identify environmental impacts & how these should be addressed. Need to ensure design and quality of new development is high. Aim for long life development rather than cheap poorly designed which won’t stand test of time. Royal Highland & Q17 More housing should be in the regions. Edinburgh should be encouraged to redevelop the 1940-1960s developments. Agricultural Society of Scotland Q18 Support dispersal to radiating fingers.

Q19 Deliver the plan in time assumed & simplify the planning process. Scottish Association Q17 Depends on definition of significant/ strategies for sustainable growth for Central belt. Plans should allow for a range of for Public Transport development & how this might influence the character & phasing of transport programmes. Emphasis on policies/ programmes compatible with sustainable growth/ that achieve reduction in carbon fuels/ minimise climate change.

Q18 Favours concentration in & around Edinburgh, but with element of dispersal, so long as discourages longer-distance car use (encourage use of public transport).

Q19 Depend on strong Scot Exec lead on transport, land use, energy & environmental issues, reinforced by strong team for regional plan preparation, approval & delivery. May require change from rather weak SESTRAN to a regional authority with strengthened land use/ transport responsibilities plus closer links with Health Boards & Enterprise Agencies. Scottish Borders Consultation provides some useful input to deliberations of the 6 Councils proposed to be charged with preparation of Strategic Council Development Plan. However, deliberations will require more detailed analysis in advance of putting options out for public debate. Need to consider potential role of each council area in respect of its future strategic planning. Scottish Natural Q17 Planning for long term has advantages in ensuring development is as sustainable as possible. Identifying now the likely points Heritage of growth & supporting infrastructure required for committed developments should help identify areas likely to be developed in future. Plans should be adaptable to cater for different levels of growth. Need to plan longer term, including taking account of alternative sources of energy, flooding, reducing journeys. Need to accept that city region is likely to have a finite capacity for sustainable growth.

82 Q18 Likely to be a mix of concentration around Edinburgh and dispersal across city region. Certain areas of Lothian will be able to accommodate well managed concentrated growth; others dispersed growth will be more appropriate. Must be well planned with respect to transport, landscape and environmental capacity, positive management adjacent to Green Belt.

Q19 Need to undertake baseline capacity studies, including landscape, ecological sensitivity, recreational value (current/ potential). Also long term infrastructure needs must be identified (transport, sewerage) & infrastructure put in place before planning consent. Need to introduce Lothian-wide requirements for sustainable design & construction. Recommend requirement through local plans to incorporate target (eg 10%) renewable energy production in new developments. Seek minimum standards of open space in new developments. Scottish Wildlife Trust Notes that current SP covers period to 201 5 and review document suggests only slight alteration/ extension to 2020 in preparation of city region plan. Notes the key issues are high or low growth/ where growth be sited, but does not suggest Green Belt should be abandoned. Considers that historic character of Edinburgh and other towns and precious natural environments are under pressure due to current prosperous growth, and won’t be limited to impact of future growth. Urban greenspace, habitats in countryside (open water/ native woods, river valleys) are being lost. Scottish Enterprise Prefer to consider the strategic growth options for Edinburgh & Lothians in the context of the wider City-region agenda. Supports Edinburgh and .othian “metro-Edinburgh” aspiring to become one of Europe’s major growth regions. Market forces alone will not deliver a prosperous future. Edinburgh city region compares favourable with other UK city regions, but not with some other, larger north European cities. Consider need to plan for growth immediately to overcome labour supply shortages and long lead in times for infrastructure. Considerable threat to Edinburgh & Scotland’s economic future if Edinburgh does not continue to prosper & gain competitive advantag e.

There is likely to be a need for a combination of concentrated and dispersed growth. However consider concentrated growth, including planned Green Belt releases & reuse of brownfield/ Waterfront, will be required to promote sustainable commuting patterns; compact city model; efficient use of land. Consider accessible sites around existing & Proposed nodes of transport should be safeguarded exclusively for high value employment uses, eg Airport/ A8 corridor. Would be particularly concerned at relying on establishing new settlements beyond Green Belt, due to commercial viability/ costs/ lead-in times. SEPA Q17 SEPA recommends that Lothian authorities take lead from National Planning Framework II, which will be published in 2008. This will provide strategy for sustainable development of Scotland to 2028. Stronger context for development planning. Expect NPFll to support cities as drivers of economy & to provide policy on matters of national importance -which will need to be addressed in development plans.

Q18 Risks to both options, ie concentration and dispersal. SEPA tentatively supports dispersal as this would alleviate pressure on city (congestion/ historic fabric/ infrastructure/ air quality/ quality of life). Dispersal adheres to principles of integrated transport & land use. Concerned that development wedges will fragment the Green Belt - seem to be at odds with aim of Edinburgh Biodiversity Action Plan to protect habitats. A full SEA would be required for forthcoming strategies & plans related to capital

83 growth. Need to consider cumulative impact of high density development in city centre and elsewhere. Recent medium-high density devts resulted in increase in road traffic/ congestion/ air pollution.

Q19 SEA provides mechanism for assessing / monitoring significant environmental effects of plans, etc to assist delivery of sustainable outcomes. Also EIA process of individual projects - need to be sufficiently detailed/ consult key agencies. Planning Bill requires planning authorities to carry out development planning with objective of contributing to sustainable development. Also for agencies to co-operate in preparation of development plans. South East Acknowledges SP concerns about environmental damage and lack of community infrastructure as constraints to development. Development However considers it possible to protect landscape as part of growth strategy. Infrastructure more difficult to resolve. Company (Turley Associates) Supports the ‘concentrated’ model of longer term City Region growth. Need to consider locations close to Edinburgh, along high capacity transport arteries, specifically rail and tram. Green Belt spokes & wedges approach in 2040 vision reflects guidance in SPP21, & this approach could enable provision of new woodland parks. Ned to prioritise ‘spokes’; produce development briefs & infrastructure investment/ implementation schedules to guide development.

Insufficient family/ executive housing in Edinburgh. Suggests the Drum at Gilmerton could provide for expansion of city - within City Bypass/ close to Borders Rail Line. Spokes Supports concentrated/ dense development in Edinburgh, with commuting from fingers of development. Do not in general support commuting from dispersed development beyond Green Belt. Development outside Green Belt should provide employment & housing opportunities in close proximity to reduce need to travel. Taylor Woodrow Q17 Significant growth should be planned for as the City of Edinburgh Council has indicated it wants to promote growth in 2040 Developments/ AWG Vision. This will need substantial lead-in times to co-ordinate & deliver infrastructure. Cannot await City Region Plan. Certainty in (RPS) development plans is required to support joined up approach to infrastructure provision. Need to review the Green Belt.

Q18 Support local growth in each core development areas, and macro growth within Edinburgh. If aim is for sustainable development, scale of growth should be substantial/ include greenfield land releases on periphery up to City Bypass, including land in Midlothian & East Lothian. South Queensferry should be allowed to expand as a gateway development & consideration of a new village in Rural West Edinburgh. Scale of growth needs to be set/ tested against existing infrastructure/ options & costs identified. Clear signals that limited demand for flatted development/ cannot be met by Waterfront/ demand for family housing, which is being met outwith Edinburgh. Edinburgh needs to decide how much of the family market it wants to retain within City or upto Bypass. Suggest need for at leasr 500 family homes per year, including affordable homes. Suggest need for greenfield housing sites in Edinburgh for 6,500 homes for period 201 6 to 2028.

Concerned about loss of jobs from traditional locations in city through redevelopment for housing, & businesses moving out to City Bypass. Need to plan for more economic land releases from Green Belt, ie need further lOOha at strategic locations around City

84 Bypass and A8 corridor (201 5 to 2028).

Q19 Development strategy should adhere to guidance in SPP3, and the Alteration should be subject to Strategic Environmental Assessment. SP should promote the principles of sustainability through locating houses nearer to jobs. Taylor Woodrow Acknowledges SP concerns about environmental damage and lack of community infrastructure as constraints to development. Devtelopments However considers it possible to protect landscape as part of growth strategy. Infrastructure more difficult to resolve - suggest (Turley Associates) establishing an ‘infrastructure working group’ of key stakeholders.

Supports the ‘concentrated’ model of longer term City Region growth. Need to consider locations close to Edinburgh, either physically, or through good transport links. In this regard Bonnyrigg is well placed. Taylor Wood row Q17 Timeframe for SP Review should be 2008-2028. Need a long term development strategy, providing confidence & commitment Developments to delivery of essential infrastructure/ nurturing potential development in future. (Turley Associates) Q18 Review of Green Belt, taking into account provisions of SPP21 should form fundamental part of long-term development strategy & this SP Review. Supports the concentrated model of growth (around City and along public transport corridors), but also suggests, due to potential scale of demand, some further growth should be sought in sustainable locations across the Lothians. 2040 Vision provides a good basis for discussion, but is still based on current Core Development Areas. SEA will require consideration of a series of alternative options.

Q19 SP should provide context for sustainable dvelopment. Impact of policies should be assessed through SEA/ Sustainability Assessment processes. Apply best practice through Building Regulations. Thomson, Walter Q17 Should not plan for significant growth. Edinburgh will lose its unique close knit small town feel if it grows much more.

Q18 Questions the need for growth/ new houses/ new jobs, given shrinking population. Do not agree that without major growth Edinburgh will die; too much expansion will change nature of city - becoming no longer attractive as a place to stay/ work.

Q19 Control growth at macro level; use local plan policies to control maximum housing densities & minimum private open space in new developments. TIE Q17 No reason not to assume Edinburgh City Region will continue to grow. Key is need to carefully consider phasing of such (Dundas &Wilson) growth & link development with infrastructure to ensure maximum flexibility.

Q18 Most effective pattern of growth would be mixed use based on transport nodes, rather than transport corridors. Nodes should be rail halts, tram stops, transport interchanges. Need to integrate land use and development planning with transport planning & delivery programmes. Higher density should be encouraged around City centre. Commuter settlements should be mixed use, and linked to city by fast efficient transport infrastructure.

85 Q19 Timely delivery of transport improvements; reduce distances to destination through proximity or fast efficient transport links. Achieve high density development close to city centre & around transport facilities - so encouraging public transport use & emission reduction. Transform Scotland Q17 Not convinced that steps should be taken to seek major expansion in geographical or population size of city. However if it is necessary for city to grow, eg to meet housing or labour market shortages, the Structure Plan should master plan for growth. Not opposed to growth in principle. However believe discussions needed to consider contribution other parts of Central Belt can make, eg Greater Glasgow. Comparing Edinburgh with Stockholm, Helsinki, Oslo is not appropriate, as they are largest cities in their countries, while none have a large conurbation such as Glasgow within forty minutes.

Q18 If growth is necessary, support ‘concentration’ along lines of Copenhagen ‘Finger Plan’. However public transport investment needs to be accompanied by demand management measures to discourage car use/ encourage pedestrian/ bicycles and reinforce traditional city core.

Q19 Welcome commitment to tackling environmental impact of future development. Consider the best way is to introduce road user charging. Turner, Barry Agree need to consider how growth is to managed post 2020. Prefer a balance between the two options, based on quality public transport provision. Support development on the edge of the city & in corridors close to city, planned around new tram routes & quality bus corridors. Consider Straiton/ Penicuik corridor is good example offering much potential without impinging too much on Green Belt. Could utilise a disused rail line. Surprised SP has not given more emphasis to this area. Farther from city, development should be located around rail stations with fast, frequent services to & across Edinburgh.

Development must be public transport orientated, which will make it more sustainable. Comprehensive sustainability appraisals need to be undertaken of Structure and Local Plans, supplemented by appraisals of individual developments. Waterfront Edinburgh The Waterfront needs to be seen as making a contribution to the international stature of the City. The Waterfront provides an Ltd opportunity for complementing the historic core of the City for tourism development, along with housing/ employment/ mixed uses.

Wemyss & March Supports the Eastern Growth Corridor included in the 2040 Vision report, which is based around the East Coast Main Line/ North Estates Management Berwick Line upgrade. Haddington has excellent locational advantages being situated immediately adjacent to the A1 trunk road, & Co Ltd short distance form Longniddry where rail services to Edinburgh, Dunbar, etc (Farningham McCreadie Partnership) Wigglesworth Cllr Q18 Reauests that arowth is disDersed.

86 (CEC) George Wimpey East Endorse the principles in 2040 Vision for a strategic plan, including new thinking on location and scale of development to create of Scotland Ltd prosperous city region communities. Support concentrated growth around the city, including land at Cauldcoats, as this is (Halcrow) considered to be sustainable. Fully endorse ‘draft’ SPP21 - should not preclude development on urban fringe so long as proposals are sustainable and realistic. Endorse a new policy direction which allows innovative approaches to future growth and capable of being implemented in a cost effective manner.

Keen to participate in further investigation into growth corridors, but consider Cauldcoats is excellently positioned to take advantage of committed and proposed transport links, park & ride, infrastructure improvements and tram links, including the Waverley Line.

The strategy will assist key sectors and institutions as part of knowledge economy; will increase supply of attractive high quality housing to serve labour market; assist in facilitating economic growth particularly in health, bioscience & technology sectors. Implementation and phasing is critical. George Wimpey Q17 Should concentrate on requirement between 2015 - 2020, as well as beyond that between 2020-2040. Strategic Land Ltd (Montagu Evans) Q18 Potential growth post 2020 should continue to be located in sustainable and appropriate locations throughout the structure plan period.

Q19 Developments should be properly assessed through development plan process and development control.

EAST LOTHIAN SPECIFIC COMMENTS

Dunalastair Estates An additional 400 houses should be allocated to Wallyford, in addition to the 1000 proposed in the Finalised East Lothian Local Plan Group 2005. Hart Estates Ltd Seek structure plan support for the identification of Gullane as an appropriate location for future residential development. Wish to promote two areas of land on the eastern side of the village, north and south of the A1 98, for a total of 80 houses.

Seek structure plan support for the identification of Old Craighall as an appropriate location for future residential development. Wish to promote a 2.5 hectare site on the south east side of the village for housing, noting that the land is currently in the Green belt. FM Developments Submit that further western expansion of Haddington is possible without an adverse impact on the town. Support development of up to 450 houses at Dovecot, adjacent to Letham Mains.

Lothian Park Ltd The structure plan review needs to address the requirement to identify Craighall in East Lothian as a sustainable location for further strategic development as part of a new Core Development Area.

87 The review also needs to direct the requirement for at least 5.3 hectares of land at Old Craighall, East Lothian, for future economic development capable of accommodating up to 500 jobs. Miller Homes Submit that North Berwick has the potential to grow in an efficient and sustainable manner, and that the planned growth of the settlement should be to the west. Provision should be made for a new link road to connect the A1 98 Dirleton Road and the B1347 Haddington Road to serve a south-western expansion of the town. There is a longer-term opportunity to provide a rail halt. Land at Ferrygate, on the west side of North Berwick, is well placed to provide for this growth. Persimmon Homes Highlight the potential of the Craighall area to contribute to future strategic growth by providing a long term sustainable settlement Ltd pattern on the periphery of Edinburgh. Consider that the area can accommodate up to 2,000 family houses, including affordable housing, and promote a leisure theme as a mixed development. An indoor concert arena is proposed, subject to feasibility studies. Argue that this should be part of a new East Edinburgh Core Development Area that would also encompass Shawfair, Danderhall and Millerhill in Midlothian and Edmonstone and Newcraighall in Edinburgh. Consider that a review of Green Belt boundaries is required in this area and that the City Bypass should define its boundary in east Edinburgh. Taylor Wood row Highlight locations for future growth in Haddington (250 houses) and note that villages such as Ormiston and Pencaitland can Developments accommodate further growth without adverse impact on the local environment or services. Ltd/AWG Properties Ltd The approved structure plan’s limited land release at Blindwells is inherently flawed by discouraging a long-term view of the planning of all the facilities that will combine to create the future community. Submit that a larger area should be identified for development, based upon the entire site of the former open-cast workings and accessed from a new junction on the Al. The creation of a sustainable community will require approximately 4000 to 5000 houses, including the 1600 already proposed for allocation. Taylor Woodrow Submit that Dunbar is a suitable and sustainable location for further growth. Propose that a longer-term approach be adopted for Developments Ltd & the strategic planning of infrastructure, education, services, etc for the continued development of the town. Seek to promote a Hallhill Developments sustainable town expansion westwards from Hallhill on land between the A1 and the east coast main line. Ltd Wemyss and March Haddington should be identified as a sustainable strategic location for future growth. Land to the east of the town at Amisfield Estates Management provides an opportunity for a phased sustainable residential development . Co Ltd Longniddry should be identified as a sustainable strategic location for future growth. Land to the south of Longniddry provides an opportunity for a phased sustainable mixed use development including residential.

EDINBURGH SPECIFIC COMMENTS

Park Lane Consider the importance of the A8 Corridor should be identified both in the period from 2020 up until 2040 but also in the context of DeveloDments the Structure Plan review in the Deriod UD to 2020. This will Drovide the certaintv bv which C)roDosals in the area can be considered

88 and which can be promoted also in the context of the West Edinburgh Planning Framework. Premier Property Land to the east of Ratho Station should be identified for expansion of the community. Group (Turley) Land at Ratho Station, Proposes land at Riccarton Mains Road, Baberton for new housing. Riccarton Mains Road and Gogar and Land at GogadEastfield Road for business uses. Eastfield Road Scottish Association Two major projects require re-evaluation, these being: for Public Transport Edinburgh Airport Access In the shorter term, Phase 1 of a revised EARL (using an enhanced Edinburgh tram service for access to the airport from interchanges at Gogar and Edinburgh Park) could bring a significant improvement in the business case for the tram line and facilitate completion by 201 0 while also allowing larger investments in airport access to be delayed until further studies had been completed. This would also minimise requirements for extra spending on approach roads to a crossing at a different location and contribute to lowered traffic levels in west Edinburgh.

Forth Crossing Require either major renewals of the present bridge (possibly involving a period of closure but raising capacity to 3 lanes each way with one each way being reserved for public transport) a new crossing with modest added capacity and allowing a refurbished existing bridge to concentrate on public transport and local traffic. Prefers the first option.

Sees a case within the period to 2020 for greater levels of bus segregation on key corridors plus extension of the tram network on corrdors into south and east Edinburgh plus a spur from Edinburgh Park to Curriehill via the Heriot-Watt campus and land released for housing. SAPT also has a preference for the Newbridge tram spur to be an extension from Edinburgh Airport, rather than a separate spur. South East Land at the Drum should be considered for an urban expansion (planned residential community similar to Shawfair). Councils Development should prioritise policies to direct development to such locations. Close to Borders Rail Line and other committed development. Company (Turley) Drum Estate Stewart Milne Holdings Supports Ratho as a sustainable, strategic location for future growth (for period up to 2020 and beyond). Specifically affords the (Farningham opportunity to provide for an innovative and phased future residential development in accordance with Government policy, guidance McCreadie) and advice relating to issues of quality, design and sustainability. Taylor Woodrow Wishes to highlight following opportunities as contributing to future strategic growth: Developments Ltd/AWG Properties South Queensferrv: Ferrvmuir - develoDment of final Dhase. Land release for mixed use develoDment to create maior aatewav into

89 Ltd (RPS) the city.

Maybury, West Edinburgh- continued expansion to provide family housing close to location of major economic growth.

Rosewell and District Feel the development that will come forward through the current Midlothian Local represents gross over development of a small Community Council village environment. The settlement will be commuter belt for Edinburgh. Taylor Wood row Promotes land on the south western boundary of the Hopefield extension of Bonnyrigg, and the safeguarded route of the Developments Ltd per Bonnyrigg-Dalkeith distributor road. Turley Associates "Concentrated" model for city region growth has much to commend it with emphasis placed locations close physically or by transport links to Edinburgh. Bonnyrigg is well placed in this respect given its distance to Edinburgh, bus services and proposed rail halt at Eskbank.

Reference is made to preference in national guidance of accessible settlements and some of the benefits of settlement extension.

Considers the location to be appropriate as; south of the green belt, would allow further planned expansion up to the defensible boundary of the new distributor road and can help meet structure plan requirements and housing shortfalls. George Wimpey East Response relates to land at Cauldcoats Farm in the south east wedge and the requirement for additional housing in the wedge and of Scotland Ltd per a green belt policy review in relation to the wider area. Halcrow A full review of the structure plan to 2020 and possibly beyond is required. Correct quantity and mix of housing in locations responsive to the market that can support economic growth and transport and infrastructure provision are required.

These factors should be considered as part of a long term settlement strategy. Cauldcoats Farm is an appropriate site that should be considered as part of this review.

Would welcome being able to advise the Council of how this land can assist in the development of the south east wedge. Knight Frank Requests Straiton continue to be identified as a core development area, particularly along the A701 corridor.

Object to the assumption that no further retail space is required.

Requests land between the A701 and realigned A701 be removed from the green belt. This can be justified on the basis of the consented park and ride scheme and the need to for retail development to retain retail expenditure in the structure plan area.

90 Straiton has the ability to accommodate major retail development in Midlothian given the inability of Dalkeith, Bonnyrigg and Penicuik centres to accommodate modern retail floor space. If modern floor space is not available, retail expenditure will flow out of the structure plan area. Miller Homes per Promotes land at Gowkshill, Gorebridge. Turley Associates Gowkshill is preferable to Redheugh. Unlikely for technical, financial and population reasons that a station could be provided at Redheugh.

Gowkshill is more sustainable as it has immediate connections to services in existing settlements. Redheugh will be more car reliant in the early phases of development.

Gowkshill is in line with national guidance and accords with principles of sustainable development. It would build incrementally on an existing settlement and is better placed for the Waverley line and extended bus services.

Gowkshill would make full use of planned infrastructure for Newtongrange and Gorebridge and have less impact on matters of historic and cultural importance.

Growth of Redheugh beyond that envisaged in the Finalised MLP would have a severe and direct impact on these matters of importance.

Redheugh breaks the traditional urban growth pattern of Gorebridge, coalesces with Newtongrange and is highly visible from the main road and the Waverley line. Murrayfield Properties Promoting land at Tynehead Village. Control 323 ha (800 acres) but can bring further land into control if required. Located on Ltd per Colliers CRE Waverley Rail Line. Historically village had a rail station. Potential for housing growth based on re-opening of rail station; could contribute to construction costs of rail line.

Settlement could be sustainable; a park & ride could help remove traffic from A68. Persimmon Homes per Promoting land around Craighall. RPS Consultants Further development can be accommodated between the A7 and AI, up to the City Bypass. Location accords approved development strategy, Eastern Growth Corridor and CEC's Vision for capital Growth.

Promotes changes to the green belt boundaries around eastern Edinburgh.

91 WEST LOTHIAN SPECIFIC COMMENTS

Cemex UK Materials Ltd

A site at Falkirk Road, west of Linlithgow, is promoted for residential development. The respondent argues that while it could potentially make an important contribution as a “windfall” housing site, it would be more appropriate and would provide greater certainty if it was identified as part of the strategic housing allocation.

It is stated that the current list of strategic allocations have failed to deliver, manly due to infrastructure constraints, and that the list therefore needs to be augmented to allow for greater flexibility.

Cemex also queries the soundness of the increase in output from strategic housing allocations from the 2015 Structure Plan of 18,200 commitment to the anticipated output of 33,600 new homes in the period to 2020. It is argued that the inclusion of their site will assist in meeting this target.

It is argued that the site is appropriate for housing on account of it lying adjacent to existing residential development and its accessibility to the M9.

It is acknowledged that there are infrastructure constraints but it is concluded that by allocating the site these stand a better chance of being addressed.

Hart Estates Ltd A site at Philipstoun, east of Linlithgow, is promoted for residential development and the respondent argues that it is appropriate because: a) it represents a logical and natural extension the existing settlement and is contained within well defined mature landscaped boundaries; b) the site can be developed without having an adverse impact on the amenity of existing neighbours; c) it will increase housing choice and will reduce reliance on meeting Structure Plan Housing Requirements from larger sites which are notoriously slow to deliver; d) the site benefits from its strategic location in relation to the motorway network; e) it will result in significant benefits to the existing community by helping to sustain local schools, shops and other services; and f) the proposed development offers an opportunity to enhance the recreational potential of the woodland.

92 OTHER RESPONSES

Architecture & Design (Q.19- Other) The 6 qualities spelt out in the Policy Statement for Scotland “Designing Places” as being at the heart of good design Scotland for urban & rural development can, by reinforcing the life expectancy of areas, make an important contribution to the sustainability of new development. Forestry Commission (Other) Woodlands have crucial role to play in the future of Edinburgh and the Lothians by improving landscape setting, Scotland environment and recreational opportunities offered in new housing areas. They also offer one element of the high quality environment required in those areas that are not development. Currently developing a Forest Habitat Network. Poltonhall & District Topics addressed were those identified where provisions for the future were needed. It is ongoing and other needs will arise in Community Council future.

Present plans were designed to meet projected future needs. Unless circumstances change so radically that existing plans are no longer relevant they should be adjusted to suit needs and requirements. Scottish Enterprise Notes that consultation exercise does not take full account of relationships between Edinburgh and Lothians and wider city -region. Edinburgh and Lothian While recognise that review will be an interim document until strategic development plans prepared, SEEL would welcome ,with (SEEL) input from other parts of Enterprise Network, early discussions on how this work may be taken forward.

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