Appendix 1(b) – Edinburgh City Local Plan Consultation Responses from Organisations by Topic Local Plan in General (Organisations) Organisation Comment Response (to follow) Architecture Brevity of plan and structure, giving prominence to design and conservation matters, are commended. +Design Scotland Arts and Business Suggests specific thought be given to culture when preparing the Plan and should feature through the plan sections. Scotland City Site Estates Proposals Map: include Osborne House at 1 - 5 Osbourne Terrace within designated Central Area. Commission for ECLP requires a race equality impact assessment. Racial Equality in Scotland Corstorphine Concern over inconsistencies e.g. urbanisation and care for the environment; discouraging car use and promoting Community Council shopping areas. Craiglockhart Word changes to ensure policy is not challenged. Community Centre Cramond Provide policy on light pollution, require applications for lighting proposals. Community Council Zoning areas for specific functions e.g. business/industrial use (other than open space) is not good for promoting diverse, interesting and sustainable city development. Concern regarding increasing use of developer contributions - applications granted for the wrong reasons. Clarify in Local Plan how to address public opinion, neighbour notification and consultation process. Cultural Partnership Include reference to cultural spaces and "spaces to learn and be inspired" alongside "places to live/work/shop". Include reference to attracting creative professionals, and the challenge of Edinburgh growing as a creative city. Falkirk Council No comment. Forth Ports plc Promote an alternative approach (to the Local Plan): designate Leith Waterfront as a "special planning area" in which city-wide policies would apply, but site-specific ones would not. Refer to the Waterfront Partnership in the plan. Grange Association Concern regarding shift in emphasis with presumption to permit development benefits developers too much. Plan must be flexible to adapt to changes in demographics. GVA Grimley Welcomes redesignation of the Seafield Road area as "white land". Health & Safety Suggests the inclusion of paragraph(s) explaining the Planning Authorities position with regard to handling notifiable Executive substances. An example is supplied. Suggests a presumption is made against significant developments (in particular high density developments) near major hazard installations and pipelines. Proposals Map: Show locations of the notifiable installations consistent with SPP1. Historic Scotland Concern that there is little cross referencing between heritage policies and other policies. Edinburgh City Local Plan – Consultation Draft -i – Consultation Responses by Topic Local Plan in General (Organisations) Organisation Comment Response (to follow) Iain Gotts Regrets the omission of the Rural West into the ECLP. Associates Malcolm Fraser There is a nice balance between caution and encouragement; its aspirational tone is to be commended. Architects Mountgrange Caltongate should be identified as a Development Opportunity for a mix of uses. Caltongate Ltd NHS Lothian Endorse the importance of the enforcement of policies. Old Town Cross refer between policies. ECLP provides diluted version of the existing Local Plan and glosses over issues. As Community Council there is a presumption in planning legislation to allow development, it is more appropriate for policies to indicate where support will be given where it adheres to specific criteria. Add policies promoting community engagement/community planning. Requests that additional policies re sustainability and community facilities are drafted in consultation with community councils, the sustainability development unit and the community planning team, to ensure the policy development is an exemplar of good practice and community engagement. Queensferry and Policy wording is general, consider expressing policy as law courts with the use of precedents. District Community Council Royal Society for Concern raised with regard the timing of the SEA. Appropriate assessment required. the Protection of Birds Shawfair Support in general for the Local Plan as it stands, which will facilitate delivery of the Shawfair Master Plan proposals Developments in Midlothian. Smith Scott Mullan Policies need to be supported by a range of neighbourhood plans that provide details. Associates South Lanarkshire No comment. Council Southside Concern about building on floodplains in South East Wedge. Community Council Include Nicolson and St Patrick Squares as green space in the Proposals Map. Support for demolition of high rise blocks. Concern regarding property numbering. Stewart Milne Extend boundary to include area covered by Edinburgh West Local Plan. Holdings Stockbridge Define and rationalise community identities, and give new identities to newly developing Community Council destinations/stations/interchanges. Plan's vision lacks conviction - just a tool for development control. Public realm improvements appear arbitrary rather than planned as spaces with purpose. Edinburgh City Local Plan – Consultation Draft -ii – Consultation Responses by Topic Local Plan in General (Organisations) Organisation Comment Response (to follow) SWT Lothians Concern regarding impact of shoreline development on the SPAs. Transform Scotland Welcomes emphasis given to sustainable development and social inclusion throughout plan. University of The University has an Estates Strategy which covers the period 2005 - 2015, supports the Council's corporate Edinburgh strategies and welcomes preparation of city-wide local plan. Waterfront Plan fails to convey economic, especially tourism potential of Granton, and compares badly with previous draft West Edinburgh Edinburgh Local Plan. Foreword (Organisations) Organisation Comment Response (to follow) BL Developments Omit reference to Edinburgh Standards of Housing as having to be met for planning permission to be granted, as Ltd this is contrary to concept of the planning system is based on establishing material harm. Waterfront Re-word to state that 'Edinburgh Standards' may be a material consideration, but not one that 'must' be met if Edinburgh permission is to be granted. Chapter 1 – Introduction (Organisations) Organisation Comment Response (to follow) Communities Reference should be made to Local Housing Strategy in paragraph 1.18. Scotland Currie Community Amend wording to strengthen policy. Council Forth Ports plc Clarify role of paragraphs 1.23 to 1.26. Highlight status of Leith Docks Development Framework as supplementary guidance. Royal Society for Requires reference to the Edinburgh LBAP. the Protection of Birds Scottish Enterprise Introduction and Strategy chapters should provide a more specific and ambitious vision for the city, drawing out Edinburgh and short and long term challenges, positioning capital in regional and international context. There should be a clearer Lothians emphasis and priority to commercial development in the city centre. Scottish Include in paragraph 1.12 the need for appropriate assessment as well as SEA. Environment Protection Agency Scottish Executive Include a small indicative map to show boundaries of this and related local plan areas. Development Re-word paragraph 1.5 for grammatical reasons. Department Planning Division Edinburgh City Local Plan – Consultation Draft -iii – Consultation Responses by Topic Chapter 1 – Introduction (Organisations) Organisation Comment Response (to follow) Re-word paragraph 1.9 to remove 'this that'. Scottish Natural Concern raised with regard the timing of the SEA. Heritage Waterfront SEA should have been prepared with draft Plan to comply with regulations. Edinburgh Include reference to flooding in paragraph 1.16. Include reference to Granton Harbour as an Area of Major Change in paragraph 1.21. Chapter 2 – Strategy (Organisations) Organisation Comment Response (to follow) Central Edinburgh Plan requires stronger vision - propose underpass for vehicles along Princes' St to regenerate city retailing and New Town environmental improvements. Association Cockburn Plan should include an explicit 'shared space' policy. Association Include reference to the residential character of city centre in first sentence of paragraph 2.8. Re-word last sentence in first paragraph to read: 'Edinburgh has attributes that enhanced, will continue to support its successful role in the European context'. The strategy does not address climate change issues in an Edinburgh context, such as possible effect of sea level rises in relation to waterfront developments. Communities Mention should be made in paragraph 2.8 of residential uses in city centre. Scotland Consortium of Objects to lack of reference to possible effects of climate change in Strategy and Chapter 5. Local Voluntary Organisations in Colinton Cramond The vision should be more realistic. Association Currie Community Concern that there is no mention of how affordable housing is to be provided across the city. Council Concern that extension of green network is associated with new development (paragraph 2.12). Concern that there is no mention of implication of global climate change on waterfront development. Gyle Shopping Emphasise the importance of town and major centres - not just City Centres - in paragraph 2.8. Centre General Partner Limited Hallam Land Specific reference should be made to the allocation of greenfield and Green Belt sites under Chapter 7 in paragraph Management 2.6. Edinburgh City Local Plan –