Appendix 2 - CRAIGMILLAR URBAN DESIGN FRAMEWORK DRAFT CONSULTATION (10.01.05 - 09.04.05) RESPONSES Item Organisation No. Scotways 1 2 Date of Response 1711105 The Craigmillar 1811 1104 (received Partnership Topics Council Response Comments/Suggestions ~~ Rights of Way Sent map with rights of way in area. a) Boundary of UDF Although it is understood that the Joint Venture Company’s Business Plan is limited to the JV’s operational area, reference should also be more strongly made to the wider planning area. Issues of tenure mix, density, transportation etc should be set within the wider context, including areas such as Newcraighall, the Jewel, Cleekims, and similar neighbourhoods to the east. The recent consent for the Brewery site on Peffermill Road will introduce a further 240 one- and two-bedroomed flats into the area. b) Densities of Housing Serious concerns raised over the urban form proposed, the design, the density and the mix of the housing proposals. These were highlighted in earlier responses in Accepted. Already on Council Records. Noted. Framework should be adjusted to improve reference to wider context. Noted and accepted. Framework is too prescriptive and detailed in this regard. This asDect will be re-examined. 1 2001 and to the Craigmillar Interim Planning Framework on 12 May 2003. The case for four-storey flats the length of Niddrie Mains and Greendykes Roads is not acceptable. Buildings of that height may be acceptable at corners and occasional points but not uniformly along these lengthy roads. Three storey should be the maximum height in redeveloping Craigmillar. The existing housing and other buildings on the south side of Niddrie Mains Road, and on the east (Niddrie Marischal-side) of Greendykes Road are already less than four-storey. To line the other sides of these roads with uniform four-storey housing would not provide balance. Noted. Not accepted. Framework states that four storeys is maximum height. The Town Centre could accommodate four storeys and this may reduce eastwards of town centre. Will not be uniformly four storeys. Highest densities are most appropriate for places near major public transport corridors and therefore this usually means ‘main streets’ such as Niddrie Mains Road. Similarly, the ratio of flats to houses is Noted. high. Agreement was reached with the JV The Framework is a guide and is for the needs of the present community to flexible, but is overly prescriptive be met first, and the clear local preference on this point. This reference to be is for the form of housing currently in place omitted. at the Hays to extend westward throughout Niddrie Mains. Other, more flatted, developments with higher densities may take place later in the programme, after the needs of the local community have been met in Niddrie Mains and Greendykes. 2 The current planning application for developing the Peffermill Primary School site proposes a mix of houses and flats, two- and three-story, with an overall density of 50 units per hectare. This is a more appropriate design and density for Craigmillar and should be reflected in the UDF. Noted. The Framework allows opportunities for similar densities as redevelopment progresses. The South East Local Plan as modified refers to the need for higher densities in relation to the Greendykes allocation (HSGI) the new land to the south of Greendykes. HSGI referred to 810 houses in 20 hectares, a density of 40.5 (since modified to 30 hectares). HSG 2, the existing Greendykes site had a capacity of 362 on 16 hectares, a density of 22.6. HSG 4 (Niddrie Mains) has a capacity of 1,230 on 25.8 hectares, a density of 47.6. These may change slightly with the passage of time, but still fall well short of the density of 80 per hectare proposed in the UDF. Again, the new development adjacent to the Green Belt may sustain higher densities still, but these are not appropriate in the existing neighbourhoods of Niddrie Mains and Greendykes. Partly accepted. Framework needs to be consistent with SEELP. Reference to 80ha density will be removed from Framework and replaced with appropriate text. But it should be noted that densities in SEELP are only a guide of minimum densities, not a maximum figure. The needs of displaced residents who have the Right-to-Return must be met. Noted. Not a Plannina matter. This is 3 ~~ This requires a further review of the number and type of housing necessary to meet these needs. An increase in the proportion of family housing may be necessary. Housing Department or PARC responsibility. Reference to be removed from Framework. Provision should be made for some larger Accepted. family housing to sustain the new schools. Framework to be revised. A range and balanced mix of housing types should be sought to cater for the needs of different population groups, including people with restricted or impaired mobility (as in Modification SEELP 18: Policy H8 Housing Diversity). The new social housing must meet the Noted. housing needs of those people with a Not a Planning matter. right-to-return and members of the wider community. (Tenure Balance) c) The means by which to ensure the best quality of architecture and design. - Community Facilities The ultimate tenure balance of 50% private and 50% rented housing is approved. Commitment to delivering best quality in design and architecture welcomed but the aspiration for the harder “urban form” and high-density building not accepted. The design and layout should meet the early needs of the local community, with a more traditional mixture of housing and layout as seen in the New Housing Partnership developments in CraigmiIlar. Higher densities and urban form may Noted. Noted. This is the form of development required to meet current design standards and provide sufficient accommodation for the target population. Framework allows for a variety of forms. 4 become more acceptable and relevant in later phases which turn towards the parkland and “new Meadows” to the south of Greendykes. d) The proper location of the secondary school in relation to the “town centre” and means by which the “town centre” and local centre might be strengthened. Concerns continue to be raised over proposals for shared gardens and communal back greens - past experience has shown that these arrangements often lead to disputes, problems of management and general dereliction of the area. The JVC must convince the community that this would not happen again. Safety, security and general amenity demand the provision of proper front gardens for houses around 3.5 metres. Noted. PARC have been asked to provid more thinking on future management of spaces. Detailec arrangements will be addressed t planning application stage. No change proposed for front garder size, as this is fundamental to the basic design concept. There is a pressing need for early agreement between the community and Council on the siting of the new community high school with a clear programme and timetable. Current proposals have departed from the previous idea of a “community campus”, with a range of facilities close by. Concerns about playing fields apart from the school, shared parking with a supermarket, and fewer facilities within the school. Earlier proposals had the school in a main street position, contributing to the town centre. The former idea is considered superior. Noted. Further views sought from Education. In any case detailed design could address some of these concerns, e.g. frontage along Niddrie Mains Road and location of library. 5 e) The provision of community facilities the land on which tc build them and the timing of their provision. Agreed that community facilities can be attached to the new school(s) However, some experience of schools delivered under PPP have led to doubts over affordable and reasonable access being available. Also need to maintain a range of facilities throughout the area, including at the Jack Kane Centre. It is not only the schools which should be provided but other community facilities too. Explicit recognition of this should be made. Noted. Text of Framework can be amended (e.g. “...schools and community facilities at the same time.. .”) f) The provision of parks and green space Whilst recognising that housing and other developments will take place on greenfield sites to the south of Greendykes, the community values its open space. The new parkland before the new Bio-Medi Park is welcomed, and the JV must reflect the letter and spirit of the existing policies for preserving and improving (and replacing) open space and environmental amenity. Comment welcomed and noted. Framework to be revised to incorporate more on open space, and include the parkland within th Framework boundary. g) The means by which home zones might be encourage on a wide scale and the dominance of th car reduced, particularly on Niddrie Mains Road Home zones welcome in asserting the primacy of residents over cars in Craigmillar. Quality bus corridors and Tram Line 3 also welcomed to reduce carbased transport in favour of improved and affordable public transport. However, existing stresses on Niddrie Mains Road are unacceptable and continue to worsen. We are disappointed Support welcomed. Further views obtained from Transport and text to be adjusted in Framework. 6 that no major proposals to relieve the congestion on Niddrie Mains Road. h) The linkages of Craigmillar to the wider city The Partnership continues to favour improving links with the rest of Edinburgh. Need to integrate transport proposals within the South East Local Plan, South East Wedge and related developments. Specific reference must be made to the proposals relating to the extension of Fort Kinnaird The JV has always made assurances that it would exceed all established Council policies, and the Partnership welcomes these assurances. Adherence to these established policies should be the minimum standard set in the Framework. i) The alignment of the Framework with the broad spectrum of established Council policies from energy efficiency and waste reduction to the provision of cycle routes and allotments. Timetabling / Phasing Timetabling of the regeneration (and Business Plan if necessary) must meet the needs of the existing community. If there are to be early demolitions in the rest of Niddrie Mains then the provision of rented housing should be brought forward to cater for the needs of those whose homes are demolished. Noted. All appropriate reference will be added. Noted. All planning applications must consider Local Plan Policy and supplementary planning guidelines. Noted. Not a Planning matter. Comment passed to PARC and Housing Department. ~ Economic Development Document says little about economic development and business issues. Noted. Framework provisions are in line 7 with current predicti Identifying sufficient land for business demand for busines space, especially workshops, is crucial to encourage business growth in the area. The existing business area around Peffer Place should be retained and expanded. Office development should follow the Town Centre, should it move eastwards. Greater attention must be paid to promoting economic development locally as well as linking to the wider opportunities around CraigmiIlar. 3 SEPA 9/3/05 Consultation & Regeneration Whilst welcoming the consultation period, the Partnership hopes that the Council is able to expedite redevelopment. Many families have been displaced for over a year, some for several years already, with no current prospect of returning to a new house. We must ensure that our community benefit, and soon, from the regeneration. Noted. Comments passed General Good overview for the potential to develop this area balancing new development with open space, recreation, landscaping including the rehabilitation of the Niddrie Burn in a new wildlife corridor through the site. Positioning of the school sites should not encroach on the river corridor. The land earmarked for the school sites is squeezing the corridor width, which is not Noted. Schools Figure 2.4 Noted and agreed. Accepted. Framework to be ac 8 ~ Community Facili Recycling FaciIiti( Waste Minimisatii during constructic Parks & Green Space in keeping with the principle to retain a natural corridor width of a minimum 40 metres. It is recommended that these school sites are pulled back so that the development does not encroach on the river corridor. Provision of community facilities in terms of waste recycling facilities. The provision of Community recycling facilities should be adequately addressed by identifying suitable areas of the site for such facilities, and give an indication of the nature of the facilities to be provided in line with the Council’s strategy on this matter. Recycling facilities lend themselves to be positioned in areas where people regularly go, such as schools, libraries, health and community centres. The framework should also reflect the need to integrate waste recycling facilities into the new development itself (as in current Plannina Policv). Waste minimisation has three main benefits for Industry and Customers detailed comments attached. The Niddrie Burn diversion and associated river corridor should be kept free from development encroachment. Noted. Text change proposed tc Council policy on waste facilities. Noted. Suggestion welc Add text to Framework. existing Council Policies Noted. Reference to be added. Noted. Not Planning issues. AcceptedIAgreed. 9 Parks & Open Spacc SEPA supports the intention to provide a new open hver corridor with flood storage capacity built into the design of 'Meadow Park' but it is important that this does not include the creation of on line ponds as part of the river channel. Noted. Details being fed into Niddrie Burr Project design. Niddrie Burn It is SEPA's understanding that the Niddrie Burn will be diverted into a single new channel through the Biomedical Park to meet the proposed route of the Burn through the Meadow Park. This should be reflected in figures 7.3 and 9.2 as currently they show the Biomedical Park development on the proposed Burn corridor. Noted. Diagrams to be amended. Design requirements of the Niddrie Burn Waterside Park supported (section 7.6.1) however the word "soft" should be added in front of engineering. Accepted. Text to be adjusted. ' 3 Bullet point - extensive areas of woodland planting may be appropriate from an ecological point of view and should not be ruled out at this stage. Noted. This provision must recognise requirements of river corridor design. Provision and appropriate location of ponds - detailed comments. Noted. Further consideration to be given to SUDS guidance and included in Framework. SUDS 10 ~ The approach in figure 9.1 in terms of the Surface Water Management Train is supported but concerns about ‘swales’. SEPA would request further opportunity to comment on SUDS relating to the scheme as a whole. Noted. Framework to be amended accordingly. SEPA to be kept informed. Foul Drainage - SEPA emphasises that connection to the public foul sewer is the only acceptable option for dealing with foul drainage from the proposed development. This should be acknowledged in the document with a statement form Scottish Water that a sewer connection will be possible. If it transpires that there are sewer capacity restrictions, sewer infrastructure will need to be provided possibly through developer contributions and in which case, planning agreements would need to be in place to ensure that public sewerage infrastructure is provided before development proceeds on site. Noted. PARC has been asked for further comments. Transport Provision of an adequate public transport system, limitation on private parking areas, and good access to public facilities such as schools by walking and cycle ways would all ensure less reliance on the car. Noted. Framework aims to achieve this. Further adjustments to be made. Movement Provision of an integrated transport system Noted. should be a key element, and system As above. being in place to serve new development Infrastructure & Drainage 11 as it comes forward. Limitation on private parking and good access to the town centre, community facilities and schools by walking and cycle ways would ensure less reliance on the car. ~~ 4 Kintry Housing Partnership (representing Canmore, Castle Rock, Edinvar and Link Housing Associations) 22/3/05 General Welcomed. Endorse the principle of a co-ordinated approach to the regeneration of Craigmillar. ~ Welcome the publication of and consultation on the UDF. However, concerns of possible adverse impacts on the regeneration programme if there are disagreements and protracted discussions over the UDF. Noted. In last seven years the associations and their partners have developed 830 new homes: 530 for affordable rent and 300 for low cost home ownership. Noted. In second half of 2004, for the first time in that seven year period, there were no new build projects on site in Craigmillar. Amendment and approval of the UDF should be speeded up to facilitate further Noted. 12 progress with the regeneration of Craigmillar. ____~ Note of detail Page 25, third paragraph: Link has been omitted from the list of housing associations. Accepted. Text to be amended. Boundaries Content with the boundaries. Some consideration has to be taken of Craigmillar’s surroundings and linkages. E.g. south east wedge, medipark, Queen Margaret University college relocation and expansion of retail facilities at Cameron Toll and Fort Kinnaird. Noted. Additional references to be included. Densities The associations have largely developed low rise terraced housing with a majority 01 front and back doors and defensible space. There is a clear local preference for this type of development, and a resistance to common stairs and gardens of which residents have negative experience. Noted. Concerns that the proposed densities are driven by the desire (or need) to maximise land values, rather than how a sustainable community can best be arrived at. Noted. Densities reflect national plannin guidance and need to create a sustainable population in CraigmiI lar. Noted. Further consideration to be giver to guidance on sizes of residenti In particular, if there are to be three schools in the Niddrie Mains area then these would be best served by being 13 located within an area of predominantly family housing rather than one or two bedroom flats. units. Such designs would fit better with the new schools, the recently built housing developments, and the heritage buildings which remain in the area (Richmond Church, the former Craigmillar Primary School, and the Community Centre). To attract people to move to Craigmillar something extra is required. In the wider Edinburgh context, there is a shortage of affordable family housing (both for rent and sale) and there would be benefits in developments aimed at this market rather than a preponderance of flats aimed at first time buyers and renters. E.g. consideration could be given to the needs of key workers at the hospital and medipark. Noted. Additional planning guidance on affordable housing to be included. We do not oppose higher density or higher storey developments. There will be a place for these, but the balance should be in favour of family housing, some of which could be town houses, rather than flats. Noted. Text should be adjusted to be less prescriptive. Link have planning approval for developing Noted. the Peffermill Primary School site, with a As above. mix of two and three storey houses and 14 ~~ flats, overall density of 50 units per hectare. This is a more appropriate design and density for Craigmillar and should be reflected in the UDF. Architecture & Design Quality Location of The associations are committed to meeting the needs of displaced residents who have the Right-to-Return. We believe there should be several hundred more properties for social rent to help tackle Edinburgh’s housing shortage. Noted. Not a Planning issue. Comments passed to Housing and PARC. We are content with the proposed ultimate tenure balance of 50% owner occupied and 50% rented housing. However, we understand that the best estimate is that there would be 3,692 (57.7%) owner occupier properties and 2,817 social rented properties. On this basis there is clearly some scope to increase the proportion of properties available for affordable rent. Noted. Tenure is not a Planning issue and Framework will be adjusted accordingIy . We support the aspiration to have high quality buildings in a high quality environment. There is a benefit in undertaking larger developments through partnering agreements, rather than competitively tendering smaller developments, and we would endorse this approach. The associations welcome the emphasis Welcomed. Detailed implementation arrangements are not a Planning matter. Comments passed to PARC. Welcomed and noted. 15 secondary school in town centre and means by which the town centre and local centres might be strengthened on improving local schools. Quick progress on these would send a positive message about the overall regeneration programme. There is an urgent need for early agreement on the site and general form of the proposed new community high school. This would help create confidence in the school becoming a reality, but would also allow housing developments around the school to be sympathetic towards it and supportive of it. Generally support for a “community campus”, in a central location close to Niddrie Mains Road. Community Facilities, the land on which to build them and the timing of their provision The “community facilities” it plans to deliver are largely those that meet the needs of the local authority viz schools and library. The associations would welcome a broader approach, and an early indication of what more other and/or more local facilities are planned. If these are not embedded in the original proposals they will not happen. Noted. Framework makes provision for proposals for community facilities should these come forward. This is considered adequate. We welcome the proposed “new heart for Craigmillar”, but are concerned about deterioration of the current shopping parade on Niddrie Mains Road. Immediate action needs to be taken to retain adequate shopping provision in a reasonable environment. Noted. Comments passed to PARC who propose to improve shopping environment in the short term. Parks and Green Space Welcome the proposals for high quality green spaces in and around Craigmillar. Would urge that sustainable and effective management and maintenance arrangements are agreed and implemented at the earliest possible time. Noted. Further consideration to be given to this. Detailed management of private space will be dealt with at planning application stage. Support for home zones, but there is a significant degree of car ownership and a preference by car owners to have cars parked close to home. Proposals for car parks on the boundary of home zones may be problematic, and should be addressed. Our experience of developments in Craigmillar is that eliminating routes through residential areas, and traffic calming measures at junctions, has worked well in reducing the hazard and nuisance caused by cars to residents. Noted. Further consideration to be given to this. We welcome the proposed tram route, but are increasing concerned about the area that will be taken up by the road and tramway. In particular there will be a large sterile area along both Greendykes Road and Niddrie Mains Road for almost a decade before any trams run on it. Noted. Further consideration to be given to this point. Niddrie Mains Road divides Craigmillar. Concerns expressed by community members over safety and pollution. Whilst Noted. Further views obtained from Transport and text mav be 17 3e8te 22/3/05 we understand the constraints, we are disappointed that the UDF contains no major proposals to relieve the congestion on Niddrie Mains Road. adjusted. Linkages of Craigmillar to the wider city The associations are convinced of the need to improve links with the rest of Edinburgh, and to re-integrate Craigmillar into the city. Need to integrate transport proposals within the South East Local Plan, South East edge and related developments. Specific reference must be made to the proposals relating to the extension of Fort Kinnaird. Noted. Text to be adjusted to make this clearer. Alignment of the Framework with the broad spectrum of established Council policies from energy efficiency and waste reduction to the provision of cycle routes and allotments We welcome assurances from CJVC that it Noted. will exceed all established Council policies, Text in Framework should be amended to incorporate reference and believe that adherence to these to (other) Council policies. established policies should be the minimum standard set in the Framework. Business Areas (concerns) We and the Craigmillar District Business Association (CDBA) are concerned about lack of protection of existing business areas in the Framework, and lack of control over land outwith CEC ownership. Noted. Framework is in line with local plan policies. No change proposed. Not sufficient land set aside in the UDF for Noted. 18 business space, hence stifling business growth in the area. Framework provisions are in line with current predictions on demand for business space. The existing business area in and off Peffer Place should be retained and expanded, not reduced. Noted. As above. Only office development has been considered in the Framework. Noted. References in Framework will be amended. There is no mention in that plan of workshop space, for which there is a proven high demand. The Framework allocates enough space to satisfy small business development. Replacement accommodation needs to be put in place for "fall out" from the Blindcraft site, and from Holyrood Business Park should theses sites be redeveloped. It is understood Blindcraft will remain in its existing location. The Framework allocates enough space to satisfy small business development . Transport links to north and south to be retained and improved - Craigmillar Castle Road must be retained, improved or replaced. Framework makes no comment on this. Existing traders to have priority in purchase or lease of retail units in any redevelopment of Centre or District Centres. Not relevant - not a Planning matter. Business Areas (welcome) Accept. Document seeks to achic See comments above re workshop space. Suggestion of balanced community where people can not only live but a percentage will work locally in the commercial property to be constructed including much needed workshop space. ~~ Office space being created in the Town Centre. The proposal to build good quality office space close to the Town Centre as possibly to allow staff to shop and use the facilities in Town Centre. If the Town Centre moves east so should the Offices. Accepted. To be considered further Keep Niddrie Mains Road open with traffic calming measures and not create a pedestrianised Town Centre. Accepted. Framework makes provi: this. Changing the priority of Niddrie Mains Road and turning the main road south into Greendykes. Welcomed. The creation of District Centres Welcomed. The suggestions for improved public transport including the tram (now in jeopardy) and rail stops. Welcomed. The improvements to access around the roads of Craigmillar. Welcomed. The suggestion of a small to medium sized Supermarket to allow a good mix of Welcomed. Reflected in Framework. 20 other local traders to include individual Post Office, Pharmacy, Bank, Newsagent etc. Craigmillar Econc Development Strategy Completion of Peffer Industrial Estate to include redevelopment on the site of the CraigmiIlar Hearts club, after relocation, further phases of workshop units beyond last phase constructed in 2001. Noted and accepted. Cre8te forecast a requirement for a minimum of 4645 square metres (50,000 sq ft) of small workshop space in next 1015 years. Noted. Consideration to be given to this Castlebrae Business Centre should be replaced by 3716 square metres (40,000 ft) of new economic rent business space, or as a listed building be completely refurbished. Noted. Further consideration being give to this. Within PARC’s plans for the new Town Centre are proposals for office suites over shops. This is presently being quantified and will add a further supply of office accommodation to the area as well as business activity in the Centre. Noted. The above business space requirement is in addition to the figures assumed in the Framework. Noted. Further consideration to be giver to this. 21 ~ 0t her relevant matters: There is an error in Fig 7.4. Density & Community The assumption that a Community High School is desired by the community is High School driving the plans for 17,000 population which in turn requires a high density of housing in a suburban setting. The community appear to be saying that they would prefer a lower density even if the school had to be sacrificed. Viable Community Craigmillar Books for Babies 29/3/05 New landmark library location & design - its Accepted. Plan to be adjusted. Noted. Framework is based on reestablishing the target population in Craigmillar to create a sustainable community. Not enough focus on making Craigmillar a Noted. viable community where residents can live, This is a planning document to be used as supplementary planning work and play. a uidance. Noted. Particularly interested in the plans for a new landmark library in Craigmillar as part of the regeneration of the area. Over the last two years library membership Noted. among under threes at Craigmillar Library Comments passed to PARC for has increased from 11 in 2002 to 51 in consideration in detailed design. 2004. One of our priorities is to see this trend continue. Designs for a new landmark library in Craigmillar must take into account this ever-growing group of library users. Regular events and activities at the library contribute to the belief that the library is a safe, enjoyable and accessible environment for families with young children. 22 Proposed plans for new landmark library We welcome the inclusion of the library with our other community services in a common and centrally located area, within reach of all members of the community. But we have concerns over the proximity of the high school and the implications that this may have in terms of shared access and ownership of the library. Noted. Concerns to be dealt with at detailed design stage. Comments passed to PARC. Pedestrian crossings e.g. from the medical Noted. centre to the library, free parking facilities, All these concerns will be dealt with at detailed design and accessibility for prams and wheelchairs, planning application stage. and public transport links. NB: All Council buildings have to be fully accessible by wheelchair and to conform with DDA Act. Several comments about detailed design requirements. 7 CraigmiI lar Communiversity 16/3/05 Consultation 1. An extension to the consultation process and to widen the consultation in Craigmillar. That the UDF should seek for a real partnership rather than a limited consultation with the residents. Welcomed. Passed to PARC for consideration in library design brief. Noted. This is not the first consultation in the process. Fortnightly stakeholders' meetings were held in preparing the Framework. In any case, consultation was already extended to 3 months (I0 Jan - 9 April 2005). Community representations were involved in the development of draft Framework. 23 ____ 2. That every household in Craigmillar should receive a simplified version of the document that details the proposals. Should this prove too complicated to do then at the very least a letter of intent and where plans and model can be viewed and groups that can be contacted. Partly accepted. This is a planning document and has to be written with this purpose in mind. However, a summary could be produced in simpler, clearer style of English. Open Space 3. That Cairntows is not built upon. Noted. Framework makes it clear that it should only be built on in certain circumstances. More text to be added to explain the process. Consultation 4.To go back and reconstruct the UDF which would be based on participation and not just a limited consultation. With the same level of participation as The COMPREHENSIVE PLAN FOR ACTION (1976) published by Craigmillar Festival Society. Not possible. Regeneration needs to start soon to : - to meet local needs; & - to meet 15 year lifetime of PARC Consultation/model 5. We request that a model is made and that this model display in Craigmillar Library and various venues for six months so people can be add there opinions. In particular using sticky labels, so people can add comments to the model. The model is a standard practice in many planning community processes worldwide. PARC already has a model, but it would be inappropriate for this type of participatory exercise at this stage of the regeneration process. 24 6. That planning workshops are created, not just consultation meetings. These planning workshops are half day, evening and weekend events are constructed that allow residents to develop own concepts and ideas with developers, professionals etc. Workshops took place at the public meetings and Craigmillar Community Council organised a Participatory Appraisal process. 7. That the current document does not reflect the social caring and social action history of the area. The document is a physical planning document. It will facilitate other actions through physical regeneration. 8. That the current document should reflect the artistic tradition of Craigmillar which is highly regarded world wide. Noted, but there appear to be no planning implications arising from this. 9. That Art should be at heart of the consultation and the framework. That Art should be central in the regeneration process. This was currently stated in The Scottish Parliament Enterprise and Culture committee report into “Arts and Community” where it stated that “Art should be at the heart of Community planning”. Noted. There are examples of Art in the community and their will be opportunities over the regeneration lifespan to include Art - e.g. Niddrie Burn. IO. That an artist be employed to help Noted. This is a planning document to be used as supplementary planning guidance.. Noted. refocus this document. 11. That a per cent for Art scheme 25 8 Mrs P CI: 29/3/05 introduced. That 1% of regeneration budget be allocated to Arts. This is similar to current regeneration projects in UK. However, not Council Framework to make r planning guidance on 12. That there should be a visual identity for the area that is rooted and supported a’ grassroots level. Noted. This is a challenge foi liaison with the comm 13. That the Communiversity submit its own blueprint which is based on Craigmillar’s cultural and social caring t radition. Noted. Attended the workshops last June run by Llewelyn Davies - impression was that Framework was already agreed. Noted. Attended public meetinglworkshop in Richmond Church March 2005 - did little to inform, was rushed and people left early. Noted. This was the first me€ Subsequent meetings these concerns. Density The proposed close proximity of homes to each other together with the uniformity of the 4 storey blocks, do not allow for personal space or privacy. This seems more like a transient camp than a community. Noted. Density reflects currei guidance. But more t included in the Frame open space and parki than a density figure. Schools There is no need to move the high school. Close proximity to shopping centre not advisable during break periods. Noted. Community High Schc component in regenei Consultation 26 centre. Town Centre The shops on the main road are adequate and the supermarket is already in situ on the main road allowing for passing trade as well as local trade. Noted. But Framework has to provide facilities for a future enlarged population. Town Centre/Transport The main road should be made more free flowing with more thought given to the public service vehicles. Noted. Bus lanes proposed. Business/Home Zones Units for small shops and community facilities would be placed in the Home Zone areas. Noted. Home Zones are for residential only areas. Business/lndustrial area The Industrial Estate is growing and Cameron Toll and Fort Kinnaird offer job opportunities in plenty. Accepted. No change needed. River Restoration/Schools The proximity of a burn to two primary schools is ill conceived an accident waiting to happen “should be enclosed”. Noted. Comments to be addressed in Niddrie Burn project. Open Space Cairntows Park is used by dog walkers golfers and football teams and is a nice entrance to Craigmillar. The demand for office suites is not so great and park should be retained. Noted. Cairntows Park will only be built on if there is no other space for offices and if the football pitch and open space can be reprovided. Additional text to be added. Housing/Buildings The recent new buildings are pleasant and the remaining space should be developed Noted. The aim of the Framework is for 27 in a similar way. Craigmillar to work as a cohesive whole, but with some areas of higher density to secure the desired target population. ~ ~ Lothian and Borders Police 4/4/05 Framework/Business Plan/consuItat ion The framework seems to be motivated by Profit. The regeneration vehicle is through PARC and this cannot be changed. CraigmiIlar/ Framework/Housing Craigmillar could be a nice residential suburb of Edinburgh, a Town it is not and the contents of the framework do not makf it so. Noted. Comments as above. Housing/ Communities To secure quality, sustainable places where people choose to live. More emphasis needs to be placed on the design and on the need to encourage higher standards. Designing for community safety is a central part of this. Noted. Housing/Buildings Recommend the adoption of “Secured by Design” criteria for all new and refurbishec developments. Detailed comments included about relevant criteria. Accepted. This should be part of detailed planning application stage. Framework should cross-refer to Planning Guideline on Community Safety and make reference to “Secured by Design”. Lighting Lighting is a vital feature of Community Safety. This should meet the requirements of BS 5489-1:2003. Higher Accepted. Statement to be included in Framework. 28 crime risks require higher levels of lighting, and this has been a proven crime reduction tool. Also, whiter light provides a clearer colour definition for colour CCTV cameras, compared to sodium lamps, and is proven to increase the public perception of safety. Parking The initiative “Safer Parking Award” exists in tandem with “Secured by Design” offering similar design guides that have proved successful in reducing auto-crime, and improving public fears of crime. For example, underground car parking facilities are useful and can provide a suitable safe storage area, but there are some drawbacks in relation to security. Noted/ Details to be considered for inclusion. Local Parks A park should be a safe place for all people to use, but actual crime or fear of crime can reduce the use of any area. The various problems/crimes associated with parks are: anti-social behaviour; thefts; assaults; indecencies; and vandalism. Comments noted. To be addressed in detailed design. Text in Framework to be adjusted accordingly. There is a problem with youths riding motorcycles around the Jack Kane Centre/Hunters Hall area and other footpaths within the Craigmillar area. I would recommend that the public parks be enclosed with suitable fencing/walling or Comments noted. To be addressed in detailed design. 29 other barriers to prevent the unauthorised entry of motor vehicles. The footpath entrances must have suitable barriers installed to prevent motorcycles gaining entry. ~ Local Parks/Play Areas Local “play areas” within the housing developments need careful consideration regarding the provision of suitable robust play equipment, appropriate [to the]? age group of children that the play area is intended for. These areas should be enclosed by a fence, high enough to keep out dogs, etc but low enough to maintain natural surveillance. Noted. Comments to be addressed in detailed design. Dwelling Security Building design should be kept as simple as possible to eliminate areas that may assist the criminal. A number of detailed comments included. Comments noted. To be addressed in detailed design. Building layout Boundaries between private and public space should be clearly marked. Wherever possible, a strip of defensible space should be incorporated to provide some separation. Landscaping can help here. Accepted. Text in Framework to be added. Landscaping Detailed comments on design of landscaping. Comments noted. To be addressed in detailed design. 30 10 Framework/General In general, SNH are supportive of this document and its objectives, in particular its aims for parkland and openspace, and improved access and recreation. Support welcomed. Niddrie Burn We support the principle of the Niddrie Burn river restoration proposals as well as the principle of the new parkland. However it is noted that although the river restoration is included in the phasing of thc works, there is no mention of the parkland and its implementation. The status of the park proposals should therefore be clarified within the framework. Support welcomed. Comments accepted. Framework to be amer Framew0rk/generaI The production of this long needed development framework is welcomed. Noted. Natural Heritage 11 The Cockburn Association 7/4/05 Local CentredNiddrie The Association strongly supports the three centre development concept, and the Mains Road redesign of the junction of Niddrie Mains Road and Greendykes Road in favour of local traffic and the development of the proposed Greendykes Centre. Views to Arthur’s Seat The report correctly stresses the importance of maintaining the views towards Arthur’s Seat from within the framework boundaries, but omits to mention the obverse - namely the great need to study the composition of the whole framework area laid out in prospect from Noted. Noted. Accepted. Some further work beir out on this. 31 the high ground of Dunsapie and the eastern flanks of Arthur's Seat Edinburgh's earliest sites of settlement. Landscape Inonsidering this landscape, the variation in topography(from the lowest ground west of the Royal Infirmary up to the crown of Edmonstone Ridge and northward over the whole of Craigmillar) is of critical importance. We therefore ask that all the master and phasing plans in their next reprinting should have the contours marked on them so that the proposals as they are worked up in detail, may be carefully checked against the flow of the landform. Noted. Further consideration will be give to this, but it may be inapproprial We stress the importance of maintaining the broad sweep of round crowned oakdominated native woodland along the whole East to West length of the South East Wedge, as achieved by Olmstead in his Boston Emerald Necklace. Noted. Appropriate reference to be included in the Framework. We assume the arboretum proposed would exclude coniferous species. On the Edmonstone Ridge these will look out of place. Noted. Comments passed to PARC for inclusion at detailed design stagc Treatment of the three North to South corridors across the green wedge at Craigmillar Castle Road, the tramway Noted. Appropriate reference to be included in the Framework. 32 leave and the Wisp will need particularly careful treatment to maintain effective East to West open space connections. We strongly recommend the framing and adoption of strict resident proindivisio shared responsibilities for all local open space within each of the proposed housing enclaves in order to ensure high standards of design and maintenance. ~~ NHS Lothian Primary and Community Division South East Edinburgh LHCC (Locality Health Care Co-operative) Received 12/4/05 Noted. Comments passed to PARC a Department of Culture and Leisure. ~ We note that there is no mention of future rail connections with Craigmillar along the North boundary of the framework area. We suggest consideration be given to safeguarding North to South pedestrian movement to such connections and also to the means of reducing the present dangerous trespass over the railway line to Bingham and The Jewel. Accepted. More text to be added. Health Impact Assessment A Health Impact Assessment (HIA) has been carried out for Craigmillar. An executive summary of the draft findings as well as recommendations arising from this submitted. Noted. Key points of the In terms of health and social car service AcceDted. 33 assessment planning there is an urgent need for representatives from Parc, NHS Lothian, the City of Edinburgh Council and community health and social care groups to identify what will be needed in future years. The Framework mentions potential for a branch GP surgery in Greendykes and options for accommodating community projects. The detail of these proposals needs to be addressed. We also have similar concerns about the lack of provision for under 5s day care. Further input on details can still be provided in time to be incorporated into the Framework. More details requested. Our main concern relates to potential for increased health inequality between the socially excluded community in Craigmillar and the incoming population. We have concerns the problems associated with the vulnerable population already living in Craigmillar may not improve but will be masked or distilled within the larger population. We would encourage Parc and the city council to ensure that adequate community resources are in place as development progresses and that health improvement policies receive continued support. Noted. Comments passed to PARC for further discussion with NHS Lothian. The Framework is a welcome development as are the sustainable development principles. Investment in schools, public transport, employment, open space and Welcomed. Report awaited. Working arrangements to be considered further. 34 neighbourhood design as well as provision of good quality, energy efficient homes are all good for population health. Support for the ongoing redevelopment. As the LHCC transforms into a Community Health Partnership, we look forward to a productive working relationship with Parc and the city council planning team to ensure the success of redevelopment in Craigmillar. A detailed report is being finalised about the health impacts of the UDF. Tie 28/2/05 Linkages Meetings with PARC regarding the integration of the tram in the CUDF proposals are continuing. Discussions are concentrating on the alignment on Greendykes Road, in the vicinity of the Thistle Foundation, and near Wauchope Square. Account should be taken of the work to date. Noted. The Framework in Outline (plan). The tram route should be identified as running to Newcraighall, and it should show as interfacing with the heavy rail cross-city link. There are also proposals to link this line to the south (The Waverley Route). There should also be two tram stops identified as being in the vicinity of the ERI - one at the eastern end, and one to serve Moredun to the west. Accepted. Framework to be amended. 35 Town Centre Fig 2.3. Design Concept. It is disappointing that the Town Centre has not been designed to be within a 5 minute walk of the Craigmillar Tram stop, althoug this is identified as relating well to the Community Centre. Density The tram offers a high capacity transport system, and would support a dense level of development. It is suggested that it would support a greater level of development than the two storey properties seen elsewhere in Craigmillar. Not accepted. Town Centre moved as close as it could be to Tram stop. ~~ ____ Noted. Already addressed in Framework. ____ Lighting Lighting should be integrated wherever possible with poles supporting overhead wires for Tram. Noted. Detailed design matter. Town Centre/ Niddrie Mains Road It is important that any junction realignment at this location is undertaken with a check that it will still work for the tram alignment. Noted. Detailed design matter Fig 4.8 This figure should only represent the section to the west of the GreendykedNiddrie Mains Road junction. This arrangement will not work for the trar alignment. Accepted. Boulevards Figures 4.9 and 4.10 are not achievable, particularly with regard to the tree plantinc Noted. Further discussions to resolve this ____~ 36 which is too close to the track. Detailed comments, but support in principle for boulevards. design matter. Framework to be adjusted accordingly. Parking The provision of the tram - a high quality capacity transport mode - should enable general parking provision in the area to be reduced. Tie would support the provision of some limited parking around the tram stops for tram users. Noted. Discussions ongoing about appropriate parking provision. Town Centre Noted. Missed opportunity in the masterplanning But Framework represents a process not to move the proposed town realistic and practical compromise. centre closer to the tram stop. As shown on the plan, the Craigmillar stop will be just outside the 5 minute walk from the proposed centre. As the text notes it is important to move the centre of gravity eastwards to serve more of the local population, but this does not seem to have been carried through into Fig 5.3. There is a significant risk that the population to the east of the area in Niddrie will find Fort Kinnaird a more convenient location. Also, by keeping the centre away from the Niddrie Mains Road/ Greendykes junction as identified in 5.3 means that it does not connect well to the significant development area to the south at the RIE and bio-medi park - another missed opportunity. Meadow Park and The tram would run throuah Dart of the Agreed. 37 Tram route Meadow Park. The text makes reference to footpaths and cycleways which will circulate through the park however the tram will cross the park too. Reference to this should perhaps be made, noting the opportunity to integrate alignments and the requirement to identify crossing points. Framework to be amended. Tram Stop 7.6.2 refers to “the main central tram stop”. Is this stop going to be any different in style or function to either Greendykes or any of the other stops to the east? This supports the suggestion above that if this is the centre of the redevelopment area, then it is where the town centre should be located. Noted. Text to be tidied up for consistency. Tram Design The Craigmillar Framework should make reference to and defer to the tram Design Manual with respect to the design of the tram system. Accepted. Text to be adjusted. Timescales Of major concern is that the Design Framework is coming forward, before the detailed study and recommendations from the Niddrie Burn River Restoration Project. The conclusions from this Study are critical in establishing the precise areas for development purposes as well as informing the more detailed design parameters. In effect the Urban Design Framework is premature. This is Noted. The Niddrie Burn is part of Craigmillar regeneration. The Framework sets out the development framework, includir context for the restoration of the Niddrie Burn. It is important to have clear strategic principles. But the amount of detail will be reduced. ~ 14 . Halliday Fraser 8/4/05 Munro Planning Submitted on behalf of Persimmon Homes (East Scotland) Limited 38 particularly applicable in terms of road layout, number of river crossings, service provision, primary school location, and the requirements for open space. ___ Policy Status The Framework states that it should “provide for choice in the future”and “must allow for changes in how things are done, and the order in which they are done”. It should also be flexible and allow for choices to be made in future years (Paragraph 1.14). However, it is of particular concern that it is the Council’s intention to adopt the Framework as supplementary planning guidance and will therefore constitute a material consideration in the assessment of planning applications. This will inevitably result in the Framework being less flexible in its application. Noted. The Framework will be flexible. Supplementary planning guidance is guidance and thus it can be flexible too. This could perhaps be made clearer. Further clarification and justification is required with regard to the relationship between the stated design principles of distinctiveness; sociability, peopleoriented; sustainability and quality (Paragraph 2.3) and the components of the design and layout which are being promoted within Chapters 3 to IO. Accepted. Text to be adjusted accordingly. Of particular concern is the proposed form of the develoDment lavout and desian Noted. Framework proposals conform - Housing Layout and Design 39 templates, with flatted development, townhouses and perimeter blocks being promoted. It is noted that this approach takes its model from inner city schemesfor example Crown Street in Glasgow. The extension to the Greendykes area is however an ‘edge of city’ location and therefore differs significantly in that it has limited public transport arrangements currently in place and very few social or community services which are necessary in order to support this proposed urban form. with CEC’s Urban Design Standards, which base its principles on national policy. Public transport routes will extenc into Greendykes (public transpor link and tram) and Niddrie Mains Road is already a busy public transport route. Block form is considered sufficiently flexible. Family Housing In addition, there is general agreement that Edinburgh seriously lacks mainstream family housing, witness the exodus to Fife and the Lothians. Indeed, it was noted at the Committee meeting in December 2004 that only 20% of residential properties within Edinburgh have children, significantly below the national average. This is surely an untenable situation that needs addressing by release for additional family units. Noted. Block layout can accommodate family housing, e.g. terraces. Framework could be adjusted to include target figure for family housing. Flats/ Houses Ratic The proposed development for the whole of Craigmillar, with two-thirds flatted units and the remainder as townhouses, will in no way address this problem. Together with the City’s other major development area, the Waterfront, this will seriously Accepted. This is too prescriptive. Framework to be amended to be more flexible. ~ 40 overload provision for this sector of the market and will inevitably lead to the current “unbalanced housing mix” which the Framework proposes to address. It is also of some significance that the Framework considers that its proposals will “give awide range of choice of type of home”. Flatted accommodation does not appeal to or meet the needs of the majority of families and consequently the population will be heavily skewed towards smaller households. Limited choice of housing will inevitably lead to an area which will not produce the mixed, balanced community to which the Council aspires. Noted. Text to be adjusted to focus 01 quality of residential environml rather than proportion of flats : houses. All parties are in agreement that the Craigmillar area is in need of major investment and an image ‘make-over’. If however the Greendykes site cannot be marketed because of limited housing types, or is indeed slow to develop because of lack of demand, the investment required to contribute to the wider area will not be available and the Council’s aims will not be achieved. Noted. See above - Framework has t sufficiently flexible to adapt to changes over a 15 year regeneration period. The Council is attempting to restrict the use of private transport and to this end is proposing a car parking ratio of 100% Noted. Not accurate. Some parking v be permissible in courtyards. - Parking Standards 41 ~ within the area; moreover it is proposed that this should all be on-street. This principle, however, does not sit happily with one of the Framework’s general principles of street design that “it is important that vehicles are not allowed to dominate the public realm. Underground parking will also be encouraged. Off-street parking is acceptable in Home Zones. Parking standards to be reexamined here. In addition, proposed parking provision does not address demand. The City has countless examples of areas where on street parking has created severe difficulties for residents within high density developments, Marchmont and Bruntsfield to name but two. If an acceptable form of parking is to be achieved, and one which takes account of the preferences of future home occupiers, there must be provision for off-street parking. Partly accepted. Framework to be adjusted to address more fully the design issues relating to parking and open space. The lack of alternative transport, particularly a railway station, the uncertainty surrounding the feasibility of the proposed tram line, distance from the city centre and the current concentration of employment opportunities to the north and west of the city all increase the probability that car use will be higher than anticipated by the Framework. Greater provision will have to be made for secure, additional parking areas in close proximity to new housing. Noted. Framework to be adjusted to make reference to railway station. Other comments as above. ” ~ 42 15 sportscotland 19/4/05 Conclusion To conclude, Persimmon Homes (East Scotland) Limited is a key stakeholder in the regeneration of the area but currently has major concerns as to the deliverability of new housing on a key part of the site within the current guideline parameters. Noted. Concerns being address through ongoing discuss Jack Kane CentreIHunter’s Hall football training centre - community facilties In relation to sport, the most significant development proposal for Craigmillar is the proposed indoor football training centre and velodrome at Hunter’s Hall. This development is supported by sportscotland and the Scottish Executive as part of the National and Regional Sports Facility Strategy. Welcomed. Framework to be adjuste reference to this. In addition to the new indoor facilities, the playing fields at Hunters Hall will be upgraded. Although there may be a reduction in the number of sports pitches on the site, this should be more than compensated by an improvement in the quality of the pitches, including the provision of indoor and outdoor synthetic grass pitches. Noted and welcomed. The proposed new football centre will serve a regional function for Edinburgh and beyond, as well as providing access for the local community. It will not serve the same function as the existing Jack Noted and accepted. (Same as CEC policy on open space.) Further discussions takin with Culture & Leisure to - 43 Kane centre. The needs of the local community for sports pitches should be fully taken into account when allocating land for sport and recreation. The southwest corner of the existing playing fields is allocated for housing development in the Urban Design Framework, which will reduce the number of pitches which can be provided. The South East Local Plan states that the inclusion of part of Hunters Hall public park within the housing allocation is conditional on its replacement with in the retained Green Belt. The existing pitch at Cairntows is also proposed for redevelopment, although there is a separate proposal to replace this at Castlebrae. sportscotland strongly advises that the need for formal sports is fully taken into account when considering the design of the replacement open space. The findings of the Edinburgh Sports Pitch Strategy should also be relevant. revisions to the Framework. Should the Jack Kane Centre be redeveloped, there will be a need to provide a replacement sports hall to serve Craigmillar. The scope to incorporate a swimming pool in any new facility should also be considered. A sensible solution would be to provide enhanced sports facilities in the proposed new secondary school to serve both school and Noted. Partly accepted. Further consideration and discussions with Culture & Leisure and PARC taking place. 44 community use. The Urban Design Framework should allocate sufficient site area for the new school to accommodate such facilities. The nature and scale of new sports facilities should be influenced by the level of population increase which will result from the new housing development. 16 Midlothian Council 15/4/05 South East Wedge sportscotland supports the concept of creating a linked network of attractive green spaces which will encourage higher levels of physical activity in the form of walking, cycling and informal play. Welcomed. General - scope and content for areas in South East Wedge in line with SEW Masterplan. Detailed proposals for the Wedge element of design framework should feed into the final document. This would be consistent with other sections of the Masterplan. Noted. This could be considered if timescales permit. Document will have to reflect post inquiry SEELP Mods. High density development at 80 dpha may conflict with objectives for quality environment/quality and amount of public space in urban areas. High ratio of houses to flats may restrict socioeconomic mix and stability of regenerated community. Accepted. Already agreed that text will be adjusted to take account of the Modified Plan. 45 Drainage Drainage - concern that foul drainage not mentioned despite known issues with capacity of Eastern Interceptor Sewer and Seafield treatment works. Noted. PARC giving further consider: to these constraints. Framewc to be adjusted accordingly. Housing House numbers - not clear what will be built in each zonelsector. Need to relate numbers to local plan sites and indicate on indicative layouts. Accepted. Framework to be adjusted to include more on the implementation. Densities Densities - Densities in Greendykes area roughly 30 dwellings per hectare above that suggested in SEW Masterplan. This may increase the overall numbers for HSGI above the 810 allocation in the local plan or would reflect a more compact development pattern due to ground condition and landscape screening constraints. Clarification needed on this. Accepted. Amend Framework once more detail is known. Retail Retail - Would not want to see the amount of local retail in Greendykes go beyond the 1 or 2 corner shop type operators as suggested. Also would not want more than local provision within the revamped town centre area due to potential impact on Shawfair town centre development prospects. Accepted. Local centres may include othc facilities such as community/ health. Unlikely to be a clustei shops and likely to be 1 or 2 IC corner shops. Listed Buildings Some of the buildings in the Framework area which have statutory protection are identified. In addition to those identified in Accepted. Framework to be amended. ~~ Historic Scotland 14/5/04 46 Figure 2.2, Historic Scotland suggests that in the interests of clarity the following should also be detailed: A and B -listed Buildings at Thistle Foundation: A-listed Robin Chapel and B-listed - 11 & 14-18 Queen’s Walk 1 19 Chapel Court, 1-23 West Court Scheduled Ancient Monument and Blisted: Wauchope Tomb near Niddrie House Drive Scheduled Ancient Monument: Craigmillar Castle Inventory of gardens and Design Landscapes: Craigmillar Castle Non-statutory C-listed: Burial Ground, Greendykes Road Non-statutory C-listed: Ice house, Hunter’s Hall Public Park The Framework document should discuss in some detail the positive contribution these features make to the area, and the importance of their setting. It should actively encourage their retention and integration into any proposals for the area, in line with local and national policy. For instance, Historic Scotland is aware, through informal discussions, that is hoped to conserve and find a new use for the White House, however, no mention of this is made in the Framework document. Accepted. Framework text to be amended. 47 The prominent location of the Craigmillar area means that any proposals for the site should take careful account of important views across the city. The significance of this wider context could perhaps be discussed in greater in detail, in order to ensure any views and vistas are not compromised. ~ Mr & Mrs Duffield ~~~ Received 12/4/05 Accepted. Reflected in draft Framework but more text to be added on context and views. Partly accepted. We note the proposal to extend the built up area to the South onto what is currently The principle of development in Green Belt in this area is already farmland. Historic Scotland has agreed in SEELP. Area commented in the past on such proposals and would advise that, as an erosion of the immediately adjacent to rural character of this area, this will have a Craigmillar Castle will not see housing development. But the detrimental impact on the setting of Craigmillar Castle. NPPG5 states that principle of protecting the setting “Development which would have an of the Castle should be adverse impact on scheduled monuments highlighted. or the integrity of their setting should not be permitted unless there are exceptional circumstances”. We would therefore recommend that this element of the proposals should be abandoned. Housing Strong objection to the building of 3000 houses in Niddrie and Craigmillar. We have enough problems with traffic and vandalism without adding to it. Noted. Not accepted. The principle of housing on this scale has already been agreed in the Local Plan and in the setting up of PARC. 48 Wildlife Craigmillar Castle 15/4/05 We have a wealth of wildlife in the area and to destroy this would be a sin. I Noted. Policies are in place to prevent this. The principle of housing on this scale has already been agreed in the Local Plan and in the setting up of PARC. Generallhousing Go build somewhere else. Cairntows Park Serious concerns have been raised at recent meetings of the Craigmillar Castle Regeneration Group (CCRG) regarding the proposals within the Craigmillar Urban Design Framework to build on Cairntows Park. This park is a well used and very popular local amenity, and residents are worried that as the Park has few direct ‘neighbours’, the local community will not get an opportunity to raise their concerns when a detailed planning application is lodged. Noted. Such a proposal will be contrary to the Development Plan and any planning application for this proposal will be advertised and available for viewing on the Planning Portal (www.edinburgh.gov.uk) and at CEC offices. Comments can be made once the planning application has been registered. This is a particular concern of the CCRG, but we have also contributed to the detailed response submitted by the Community Regeneration Forum, and would like this letter to support that response. Noted. The Niddrie Marischal Neighbourhood Association (NMNA) has made a contribution to the response produced by the Community Regeneration Forum Noted. ~ 20 Niddrie Marischal Neighbourhood 14/4/05 Response - see CRF 49 (CRF). Association Noted. This issue will be reassessed ir relation to open space needs generally within Craigmillar and the Framework adjusted accordingly. Library - existing CraigmiIlar Library site One issue we feel so strongly about we have decided to make a separate response. Part of the plan of the Joint Venture Company (JVC) is to build a new library in the Craigmillar area to replace the one currently situated off Niddrie Marischal Gardens. This would ultimately free land occupied by the present library. There is very little spare land in the Niddrie Marischal area, and a distinct lack of facilities for all but the very youngest children. The library plot should be left free so that a play area for older children (7 - 15 yr olds) can be put on this site. The final draft of the Urban Design Framework has this site designated as housing. Community Facilities (for older children) The NMNA has been involved in producing Noted. a Neighbourhood Agreement on Antisocial Further detailed input would be Behaviour with the Council and other local welcome. landlords. This Agreement deals mainly with the symptoms of such behaviour and can do little to tackle the causes. One of the main causes is older children with little or nothing to occupy their minds, and hands. The Association, in recognition of this, is very keen to find a way to provide some facilities for these older children and improve the quality of life for all in the 50 ~ neighbourhood. CraigmiIlar Regeneration Forum (CRF) Received 15/4/05 Introduction The Community Regeneration Forum is an umbrella group of 10 neighbourhood associations in the greater Craigmillar area. A group of 22 residents volunteered to critique this document on behalf of the Community Regeneration Forum. This group were divided in to three groups, each meeting on 3 occasions for up to 3 hours per meeting where the CUDF was evaluated on a page-by-page basis. A further joint meeting was held of the three groups to agree a report to the CRF. Noted and welcomed. Representative from Planning attended meeting in support of this. Summary (Housing - mixed tenure & affordable) The Community Regeneration Forum welcomes the regeneration of Craigmillar and is generally supportive of many strands in the Framework. In particular we think the mixed tenure approach to housing is essential to create a mixed and sustainable community. The proposals for ‘affordable’ housing do not guarantee that this will remain affordable as the programme progresses, e.g. market forces may push prices up faster than anticipated and result in houses for sale in Craigmillar not being any more affordable than the rest of Edinburgh. We would like to see opportunities for other models to deliver affordable housing e.g. more houses for rent or possible shared ownership Welcomed. Framework should be adjusted to provide greater clarity on affordable housing but needs to focus on planning aspects. More detailed suggestions passed to Housing Department. 51 schemes. Schools The proposals for new schools are welcome, although this appears to take up a large proportion of the budget. Would like to see more financial input from the Education department of the Council. Welcomed. It is understood that the CJVC, no the PARC regeneration company, is responsible for funding the school. Not a planning matter. Framework progress & consultation The CRF recognises that this is not a detailed planning application and that each phase will be consulted as the framework progresses. It is essential that this consultation is carried out in a meaningful way, with discussion with neighbourhood groups at the heart of the process. In particular the proposal regarding Cairntows Park should have extensive consultation beyond neighbour notification. Noted. Comments passed to PARC for further consideration. Any proposal for development at Cairntows Park will be subject of a planning application which will be advertised (contrary to Development Plan). Implementation Care should be taken to ensure a coordinated approach to develop and install infrastructure e.g. telephone poles removed sooner rather than later so that any requirements for underground cables can all be laid at one time. Concern was also expressed about ensuring that the use of existing infrastructure will meet the future demands put upon it. Noted. Ongoing discussion with PARC re infrastructure. Comments passed to PARC to consider further. The CRF welcome plans for the community parkland and arboretum, but there are concerns that these will precede Noted. Timing issue, but it is likely that housing will commence first. From ~ ~~ I Open space - park & arboretum 52 Movementnraffic housing development. This would be seen as sending a negative message to the existing community on where the priorities lie. It is also essential that no plans are progressed on this without proper consideration as to how they will be maintained to a standard that will keep them as safe, secure and free from vandalism as possible. a planning perspective it is important that open space and landscaping progress at the san time as housing. Although there are some plans to improve traffic and movement for Craigmillar, there are doubts about whether full consideration has been given to the impact that will be made on the extended development of Fort Kinnaird, Queen Margaret College being sited just beyond Newcraighall, the development of 5000 houses in the South East Wedge (Shawfair) and a doubling of the Craigmillar population (potentially at least double the cars). This could be further exacerbated if the park and ride facility at Newcraighall is not sufficient for future demand. It is recognised that a by-pass is not currently being considered, but results of any traffic impact assessment should be shown to have considered all of the above before coming to a conclusion. Agreed. These matters are relevant Planning guidance for related sites. Further consideration to b given to cross-references to that guidance and other text revision As part of this regeneration programme, a ‘community chest’ should be established to Innovative suggestion. Noted and ideas passed to PAR ___ Community Facilities 53 help pay for community benefit e.g. revenue costs for community facilities, developing future schemes etc for the advantage of Craigmillar. This should be well thought out to ensure that it is sustainable and at least partially implemented as plans progress, to allow maximum opportunity for the community to take ownership of developments. for further consideration. Views of Department of Culture & Leisure also being sought. This is not clear in some of the diagrams and assurances are needed that this action will not result in flooding in the future. It was also noted that this work would probably go ahead anyway (irrespective of a UDF for Craigmillar) and there were concerns that this project may hold up the progress of other work e.g. the PSV road to the ERI. If this work is seen as part of a bigger strategy then funding should not be required from the JVC business plan. Partly accepted. All development in Craigmillar cannot, under national planning policy guidance, contribute to flooding. The brief for Niddrie Burn Project ensures that account will be taken of flood risk. The Burn and public transport link to be designed compatibly. Text needs to make this clear. The replacement for this facility seems to be in the middle of nowhere. It must be located in an area that people can access informally and should not have to be booked prior to use. There are concerns that a like for like replacement is not what is being offered (currently Cairntows Park attracts a lot of informal use and is well overlooked giving a sense of safety). The Noted. Any replacement should be subject of community consultation. Text to be adjusted to make this clear and comments passed to PARC for action as and when appropriate. 54 proposed facility will not be well overlooked and is likely to need revenue funding therefore making it unlikely that it will able to be used informally and at no cost to the community. Noted. Building height not necessarily 4 storey maximum. Framework suggests these should be nonhousing uses. Landmark Fe; What will these be used for? They should not be any higher than 4 storeys and should have a purpose. There is no recognition of existing ‘landmark buildings’. A review of all existing and proposed landmark buildings should take place and some clarity is needed for the rationale of how a ‘landmark’ building is required and decided upon. Town Centre: This would be better if it were given a Accepted. name as the town centre is generally taken Text to be adjusted to refer to to mean Princes Street. “Craigmillar Centre” or similar. The proposed car parking for the town centre is mostly within the car park for the Supermarket and this is also used to meet the needs of the schools. We need to know how many car parking spaces there are and the estimated need for each of these elements. The proposal needs clarity on how many public parking spaces are free for general use and how many are allocated. Noted. Proposal will have to comply wit1 current parking requirements of the Council. Details will only be provided at planning application stage. Other questions do not appear to be Noted. 55 answered within the document e.g. will the existing shops be upgraded and when will this work be carried out? Why is there no provision for public toilets in the town centre? Can the Hearts Club be accommodated in the town centre? It was agreed that existing businesses should be encouraged to stay and be developed as progress on the Town Centre is made. Further discussions taking place with PARC and Framework will be updated with as full information a5 possible. Existing Planning Applications/ Proposals (out-with the JVC): These do not seem to be taken in account, e.g. Historic Scotland have proposals for a car park for 100 cars in Craigmillar Jubilee Park, and the ex Craigmillar Primary School development of a 'social' enterprise centre & arts centre. There is also a proposed Care Home on the ex .Greendykes Primary school site. In addition there is a development of over 240 flats for sale on the ex Brewery site and a substantial development of flats and houses for sale by Castlerock/Lothian Homes on the ex Peffermill Primary School site. The Thistle Foundation is also undergoing major regeneration that includes a significant number of new build flats. There is also a major change in road layout intended as part of the Kinnaird Park extension. Accepted. It is not always appropriate to include details of all recently approved applications but Framework will be updated to make reference to most of these proposals. Local Centres: There is no clarity on how these will be made up and what purpose they have. Is it Accepted. Likely to be 1 or 2 corner shops 56 Office Development: just one shop or several shops or a shop and a small community centre? What needs do they meet and are all the needs being properly addressed? and some community facilities. Additional text to be included. The CRF feel that an additional ‘local centre’ is needed in Niddrie Mains to serve the neighbourhood, enterprise centre and primary schools. Noted. Framework already makes sufficient provision for local shops. There is a long-standing desire, which has been expressed by local neighbourhood groups for some years, to develop buildings for community use within each local neighbourhood. To build a successful, sustainable community, new community members need somewhere local to meet the existing community. It is crucial that new local centres are developed at the same time as the housing and where possible existing centres are upgraded. Noted. Framework makes provision for these, but as yet there are no firm proposals. It is not clear whether there is a proposal for one office development or several smaller office developments. Will it include enough car parking spaces or will it require using the central supermarketkchook car park? The CRF generally welcome the concept of a new office development but would like to see a sound justification for the need to use the Cairntows Park Noted. One office block proposed - only on Cairntows Park if no other town centre site available. More detail as appropriate will be added. See comments as above, on Cairntows Park. 57 proposal. Sustainability: Maps: The CUDF does not go far enough. Therc is more to sustainability than SUDS -we would like to see proposals for the use of sustainable building materials and ensure that good quality soundproofing and insulation is used throughout the development. Provision of recycling bank in every area and innovative ways of encouraging their use e.g. some underground, a variety of types (glass, fabric, metals etc.). Accepted. There is existing CEC supplementary planning guidar which covers much of these iss and all developers should cons them. Cross reference to be included. There is also an absence of drying space: especially for flats, which will therefore require the use of tumble dryers. As this i not energy efficient, gardens etc should bc big enough for this kind of use. Noted. Accepted. Appropriate text to be added. There is a need for larger family homes to allow for a natural progression for families to grow without moving out of the area, and to sustain the schools, the proposal for at least 213 of the homes to be flats does not meet this need. Accepted. Framework is flexible and coulc accommodate more family housing. Target figure to be added. Several of the maps used are inaccurate e.g. neighbourhoods are not sufficiently defined e.g. Niddrie Mill does not include The Hays; Niddrie Marischal does not include Niddrie House and Peffermill is Accepted. Framework to be amended. 58 actually the Peffers. Movement: What are the long-term plans for Craigmillar Castle Road? Proposals for Niddrie Mains Road do not show what impact the increase in population i.e. double over the next 15years will have. It does not take in to account the proposals to increase Fort Kinnaird, Queen Margaret College moving to the other side of Newcraighall, the Shawfair development in the South East Wedge and the Public Service Vehicle (PSV) road being opened up to the RIE. When is work on this road going to start? Do we know what the projected traffic flows in and out of Greendykes will be once the development has been completed? Is there a danger of rat runs developing e.g. to avoid the junction at Niddrie Mains Road and Greendykes Road. Noted. Concerns raised with Transport. Text to be added about requirements for transport improvements which will be linked to planning applications. Third tramline -what contingency plans are in place? When will a decision be made on whether or not land should be reserved for a tramline? Is there any other contingency e.g. guided bus lanes in place of the tramline? What impact does the immediate loss of the tramline have on the UDF? If the tramline is to go ahead in the future, the necessary infrastructure needed should be in place as soon as Land is already safeguarded for Tram Line 3. Bus lanes proposed for Niddrie Mains Road. There is no proposal to ‘lose’ this Tramline. Other matters noted but too detailed at this stage. 59 possible to minimise future disruption for residents. There are concerns that the PSV road/ tramline/SSR could result in some neighbourhoods e.g. Greendykes becoming a very big car park i.e. residents could lose parking to commuters. Are there any plans to have the area policed/traffic wardens? South Suburban Railway (SSR) opening to passengers - this should be encouraged and would assist in alleviating some of the expected congestion, but car parks would have to be built now, so as to avoid residents ‘losing’ car parking space to commuters. ~~ Welcomed. Premature to build station car parks just now as exact station locations not confirmed yet. But points being discussed with Transport. ~ There does not appear to be enough Accepted. priority given to cycle ways. Is it possible to Framework to be amended. show on a larger scale diagram where the cycle ways linkages are? Is it possible to show a diagram large enough to show the priorities etc on roads? This should also show whether or not traffic could enter home zones from a boulevard, which would reduce the safety of home zones. Crossings for all roads should be shown in more detail e.g. the width/ frequency/design along a road. Noted but not accepted. Detailed elements of design not appropriate for Framework. ~~ The proposals for a new road layout along Noted. 60 Newcraighall Rd and at the Wisp should be shown in the UDF. Further consideration will be given to these in relevant part of Framework. It would be good to consider bus/tram/train Not a matter for the Framework. Already an aspiration of Tram tickets that are interchangeable/ proposals. transferable. Communities Neighbourhoods & Housing: I The City of Edinburgh Council has already identified the need for 10,000 affordable homes over the next ten years and intends to demolish and replace a further 4,000. Craigmillar could meet a sizeable proportion of that need, but the CRF are concerned that there is still a greater need for sociaVaffordable housing within the area than is expressed within the CUDF. The CUDF does not take in to account plans for housing for sale already identified in other planning applications, making the final split of social housing/housing for sale even greater, probably more in the region of 14.5%:85.5%. Noted. Accepted that Framework is not clear about Affordable Housing. Text to be adjusted to set planning position out clearly and say less about Housing issues. A general concern is that the ratios of houses: flats do not meet the aspirations of the existing community i.e. the Greendykes and Niddrie Mains communities have already been in negotiations for some time and their understanding is that more houses than flats will be built for social rent. Noted. Framework is too prescriptive on this. Text to be adjusted accordingly. 61 There is also anxiety that the number of social houses being built will not allow for a natural extension of the community who live in social housing i.e. children leaving home to set up their own homes and being able to choose to live in social housing within the Craigmillar area where there is family support. Noted. Amount of social housing not a planning matter. Comments passed to Housing to consider. There is also a fear that social houses will be lost as part of the right-to-buy programme, which is retained by existing tenants. Not a planning matter. Housing responsibility and comments passed to Housing Department. It would be useful if the UDF showed what the density of an existing area is e.g. Niddrie Marischal so that people have a better opportunity of understanding what the figures mean. Accepted. Text to be adjusted to include figure. ~~ There is real concern about thenumber of Framework is flexible and will 4 storey blocks that are proposed and a permit variation over time to reflect feeling that more of a mix of lower rise demand. Issues relating to RTR housing would give greater confidence that and overcrowding are a Housing this proposal could work (past experience responsibility and these comments of tenements in Craigmillar is that they passed to Housing Department. haven’t worked). Detailed comments about the right-to-return (RTR). There are already some families living in overcrowded conditions under other social landlords that have no prospect of moving 62 because their landlords do not have suitable houses to offer them. Community Facilities Community facilities should be grouped according to usehsers to aid identifying gaps in provision. There is a strong feeling that schools are not necessarily community facilities that are available to the community without expensive costs being incurred and/or at times that suit. All ‘community assets’ should be reviewed and appraised as to their suitability in terms of accessibility, both physical and denominational (non religious). The role of the Framework is tc out physical development in a ordinated way. It will identify si for the buildings, but there are I proposals at present. These comments passed to PARC for action. The Niddrie Marischal Neighbourhood Association has identified the existing library site as a potential site for developing a youth facility e.g. a kickabout area once the current library has relocated. Currently facilities for children and youths in the area are confined to a couple of play-parks suitable for children up to 8 yeas old. The CUDF has reserved this area for 4 storey blocks of flats. It is felt that re-allocation of this land would meet an identified need in the area Already addressed above. To be considered as part of the open space needs work. There are several anomalies in figure 6.3 e.g. there are two no.5’~. Several existing facilities are not listed e.g. the proposed new Niddrie Mission and existing shops in Accepted. Framework to be amended accordingly. 63 ~ Niddrie Marischal, Niddrie House and Niddrie Mill. The proposed Care Home on the ex Greendykes Primary School site as well as community space planned for Hunters Hall Housing Co-op are also omitted. House height & diagrams It is essential that community facilities should be built in conjunction with the housing developments and consideration should be given to the need to develop the sense of ownership required to make them successful. Each neighbourhood has its own requirements and it is essential that these should be identified through consultation with the communities involved, and care taken to ensure that these are delivered. Noted and agreed. Comments passed to PARC for considerat ion. A central, modern and dedicated purposebuilt Community Centre is required and it should not be seen as acceptable to ‘bolton’ community use to other facilities. Noted. It is understood this would be par of the function of the Community High School. The keys in some of the diagrams are Noted. ambiguous - 2/3 storey and 3/4 storey These diagrams although this is ambiguous, and could result in more indicative could be considered 4 storey than would be acceptable. A either too prescriptive or definite height should be specified for each misleading. This aspect of the block, and it would be good if numbers of Framework should be simplified. units for each block/phase of development could be shown etc. 64 __ Parking It is not clear how the parking regime would work to ensure that every home has at least one parking space. Also what arrangements are there for visitor parking? Clearly unless the allocated car parking space for each unit is within the garden there could be a tension if families have more than one car and/or visitors use an allocated parking space. How would resident only parking be policed? Are there plans for contingency e.g. could the communal spaces at the rear of blocks be used? Noted. Proposed parking is in line with current Council requirements. Home Zones Home zones are a good idea and there should be more of them throughout including the possibility of introducing them in some of the existing areas. Noted. Communal Space Communal space should be designed in a variety of shapes and sizes and parks should have a purpose that is clear so that people know what the park will/can be used for. Suggestion welcomed. More thought is being given to this. Gardens Consideration should be given to offering alternative ‘gardens’ i.e. paved areas for those people who have no wish for a garden but may still require a ground floor flat or a house. Noted. This is a matter for detailed desic stage. 65 The Morrison Partnership (Edinburgh Office) 19/4/05 Greendykes Multis The result of the feasibility study for the high-rise blocks in Greendykes is not yet known and, if the decision is to demolish them, there is a possibility that additional housing will be needed to accommodate residents. Housing responsibility. Framework should be sufficiently flexible to be able to deal with thi: issue should it emerge. Show People Site There is no provision for the relocation of the Show Peoples site currently owned by the Taylor family despite it being shown as retail/housing as part of the Town Centre. Noted. Discussions are ongoing. If any conclusion, this will be incorporated into the Framework. Relocation of Families There are currently 26 families that need to be relocated within Craigmillar. These families are seen as part of the Craigmillar community and their needs must be addressed This is a Housing matter not a planning matter. Overview Population Numbers of residents is obviously a key factor in the sustainability of local and community services. There has been a very substantial reduction in the local population over recent years. From conversations with local businesses that reduction in population has had a desperate impact on the viability of their business. There will need to be a substantial increase in the population if the terminal decline in local business is to be avoided. Beyond that I suggest that local serviceslbusinesses should be concentrated in one area to reinforce that Noted and accepted. The current version of the Framework already addresses this. Hence strengthening of tow1 centre and business concentratio in Peffer Place. 66 enterprise dimension but focusing customers into one area where they can find a diversity of services and choice. Overview Interaction Overview Environmental Improvements This area is no more isolated or remote from the City than many other areas. Many of those areas having been derived from earlier villages which were subsequently absorbed into the City still retain a sense of self-identity. Craigmillar should be no different. Noted. In speaking with many locals there is a very clear sense of local identity. If there is any sense of isolation it is more likely to be within the wider City and possibly be derived from the perception or reputation of Craigmillar. That being the case challenge is to change the perception of the area within the wider City. Noted. This is one of the aims of PARC in the regeneration of Craigmillar. There is already a strong sense of community and a strong sense of place. Many attempts over the years to improve the environment have failed due to lack of care by individuals and/or vandalism. Until such time as there is an overwhelming dominant sense of care for the green spaces then added provision could be counter productive in a variety of ways. Noted. Framework should be adjusted to address maintenance and management of open space. Discussions ongoing on this issue. From our knowledae of other areas we Noted. 67 have seen how over-provision of green space can result in those spaces dominating the residential spaces, large groupings of youths (well intentioned or otherwise) take over the open spaces and potentially give rise to control or intimidation within the area. It is important that the dominant elements at all times are the residential areas and that they are arranged in small groupings that make self policing inevitable and effective. Comments passed to PARC for further considerat ion. The suggestion is that redevelopment sites Noted. The Framework seeks to address should include open spaces plus roads, this. footpaths and cycle ways to connect with existing networks. As stated above self policing of areas is imperative if residents are to have any chance of creating and maintaining a sense of identity, community and lawfulness. Development must therefore be designed in a way that helps achieve those goals. Make reference to the design parameters set out in "Secured by Design" standards applied by the Police. Accepted. More text to be added to Framework about Secured By Design and safety. Large open spaces and a proliferation of through routes can cause problems. Layouts where housing dominates and controls are more successful therefore avoid large open spaces and Noted. Home Zones do not need to be through routes. Strategic links, e.g. footpaths and cycle ways are important connections to the city/ 68 other part of city/ neighbouring area. interconnecting routes. ~ We have heard residents express unhappiness about having been movec from now demolished flats into terrace houses. The impression given was tha they still wish to live in an upper floor fl; for greater security and personal safety within the home. Noted. It is clear having inspected many housc in the area that personal safety is an is: Noted. More text to be added about s a issues in Framework. A high population figure is important on sustainable, economic and social grour It is also important in helping to instil a greater sense of self-policing which in t helps to improve and generally help perception of the area. Welcomed and noted. The existing linear arrangement of this road is alien to what appears to be the future philosophy of development groul and presumably micro communities. Surely a more meandering line for this road would help to reduce traffic speed and create different points of focus alor its route allowing the residents to beco dominant. Eastern part of Greendykes Roi is to be a major public transport route - linking into the new link RIE and in future for Tram. Therefore, width and straight a1ignment required. I 69 1 - Framework Proposals to create yet another shopping centre in the area will serve only to dilute the market and compromise both the existing and future commercial fabric of the area. There has to be some inherent and viable commercial framework for the commercial sector to survive and grow. Surely the best chance for survival is to create a single commercial centre. Anything less results in low grade, unsustainable services offering little or no choice. Framework proposes to strengthen the Town Centre which has well used and good provision of basic goods. Local centres would be based on a corner shop. Text to be adjusted to make this clear. To create a traffic bypass of Craigmillar would exacerbate any sense, either within Craigmillar community or outwith that community, that is connected to and an integral part of the City. Through traffic is important in maintaining that sense of a link and interaction with the wider city. It may also help to create an added sense of security along the arterial routes simly by the fact that there are more people around - many of whom have no connection with or any involvement with daily events within raigmillar. If the commercial area of Craigmillar continues to be grouped around the main arterial route through Craigmillar there may be the secondary benefit of passing trade. Agreed. I Craigmillar local I The suggestion is that many of the corner Noted. 70 Centre - Local P shops are closing due to redevelopmeni Another suggestion is that they are closi due to their being uneconomic - in part because they cannot offer selection or competitive pricing. As stated previousl> the commercial centre needs to be developed and enhanced to create sufficient critical mass to encourage a stronger attraction to customers. Only I: increasing and maintaining that strong customer base will the commercial centi be successful and from that will follow increased investment, diversity, sustainability and employment. See comments on previous page. Framework Any re-provision of open space must rethink the whole format of such a facility. doing so it must be of a scale that is not too large - better compact areas that loc busy and vibrant. That perceived succe attracts people and heightens security. contrast large open spaces with the saw number of people present will look relatively deserted and therefore less attractive. In addition open empty spacc the dominant element and with it a diminished sense of safetykecurity whic results in fewer people using the space, which in turn gives rise to unacceptable gatherings which can result in antisocial behaviour. Noted and agreed. Further work being undertake and additional text to be added. 71 In Conclusion From experience of the area, personal safety both out of doors and while in the house, is obviously a major issue. All aspects of redevelopment within the area must therefore see this as a primary objective if there are to be improvements in so many other areas of the community and its wider public perception. Until those goals are achieved then surely regeneration and development of the area as a natural self-fulfilling process will not happen. Welcomed. See comments above. More text to be added regarding security in redevelopment. 23 Hunters Hall Housing Co-op Ltd 18/4/05 Housing Noted. Petition of 110 signatures of TenantdMembers of Hunters Hall Housing This is a detailed proposal in the Co-op strongly objecting to the proposal to Framework. To be reassessed in build new houses in the park to the South the light of these comments and wider open space needs. of Niddrie House Avenue. “We value the open space and the view and we use the park frequently for e.g. dog-walking, playing football, our Gala Day.” 24 Rt Hon Gavin Strang MP 14/4/05 Housing Concerned about the density levels being proposed, the high percentage of flats compared to low-rise traditional housing, and also the imbalance in favour of private houses for sale over rented accommodation. The minimum house prices proposed at €85,000 may be affordable at Edinburgh prices, but certainly not for local Craigmillar people, where 64% of the population live in - Noted. However the regeneration model adopted for Craigmillar requires reliance on private house sales. Framework to be refocused on planning and design matters. 72 25 Edinburgh Sustainable Development PartnershiD 29/4/05 Parklands Strongly opposed to the proposals for commercial office development on Cairntows Park, and housing developments on Huntershall Park near the Jack Kane centre. Over the last few years, there has been a gradual erosion of publicly accessible open space in the Craigmillar area in favour of house building and I believe that it is now time to reverse this trend. Noted. Cairntows Park would only be proposed for office development if no other town centre location available. There will be an opportunity to object to proposals at planning application stage. Proposals for development at Hunters Hall Park are however set out in Local Plan and must be reflect in the Framework. Community Facilities The Framework document is very vague on what actual community facilities will be provided as part of the overall plan, for example, no youth facilities or centres for the elderly seem to be included. I propose that a proper range of community facilities, should be included in the plan, fully costed and funded. Surely we do not want to repeat the mistakes of the past in building thousands of houses and precious little community facilities. UDF offers suggestions as to where community facilities could be located. As a planning document it cannot make suggestions for such facilities in the absence of proposals. Council Policies The ESDP would ask you to bear in mind the Council’s commitment to developing a sustainable city as detailed in “Edinburgh’s City vision: Building A Better Edinburgh” Noted. These strategic principles are implicit within current document but additional text to be included. 73 and Sustainable Design Guide Handbook. This vision is as follows: By 2015 Edinburgh will: Lead the most successful and sustainable city region in Northern Europe 0 Sustain the highest quality of life of any UK city competing with the best in the world 0 Keep and attract the people needed to drive it’s talent and knowledge economy and provide every citizen with the best personal opportunities for work, education and development 0 Be a safe and tolerant, creative and connected city, promoting the wellbeing of both people and place. (ESDP) Consultation With regards to this specific proposal we are pleased to note the efforts which have been made in involving the local community and wider range of stakeholders in the development process to date. We are particularly appreciative of the people-first “pedestrian” focus of the proposals and would be interested in your plans to maintain and build upon this as the development process evolves. Welcomed. Council Policies recommendations of the Sustainable How do you plan to utilise and incorporate the recommendations of the recently launched ~.Sustainable - Design Guide Noted. Consideration to be given to incorporat-appropriate - ~ ~ ~ I 74 Design Guide 16/5/05 Landscape structurallwoodlands (Hedgerows) published by the Council. 1 additional text. The Council has been making great efforts to ensure that the new Council HQ building is developed in as sustainable a manner as possible and we would be keen to see this replicated in wider developments across the city. The scale of this development is such that it could exert significant positive influence on a wide range of supply chains involved to encourage increased sustainability of design, manufacture, supply, etc. Noted. As a Council development greater control could be exercised over this. Comments to be passed to PARC for further consideration. Concern that hedgerows all appear to be for the chop in the UDF. Although it’s something that I raised at previous Urban Design meetings with everyone, including the landscape architects and CEC planners, I got the impression they didn’t take my comments seriously. There is a network of hedges, particularly in the Greendykes area of Craigmillar, [i.e. Greendykes Road - from Castlebrae School to the bottom of the hill, Thistle hedgerow - along Greendykes Avenue, the trees and shrubs along the Niddrie Burn (just before it gets to the built-up area), and the hedges between the high rise flats and the Jack Kane park. They’re all quite mature and mostly made up of native species (lots of Hawthorn, some Noted. Framework should be adjusted to take account of historical landscape issues. 75 Elder and Wych Elm, with numerous species of ground flora). The amount of birdlife these hedgerows support is really significant . At least one of the hedgerows has local historical value - the rather tatty Greendykes Road hedgerow was once known as the Skinny Woods, where kids used to play. Admittedly, these days it‘s more likely to be used as a dumping ground - but this is an issue of maintenance. Landscape All the pictures of the lovely ‘new’ Craigmillar have an abundance of mature trees and plants, which we all associate with nice, healthy places to live. In this case, it would seem a crying shame to get rid of the mature vegetation that’s there, along with the wildlife that it supports, especially as it seems to be increasingly difficult to establish new plantings in the new-build areas, due to vandalism. Noted. As above. Landscape structL There seems to be very little provision of greenery filtering into the neighbourhood (the emphasis currently being on the parks at the periphery of the development). As the whole urban design framework appears to be founded upon the doctrine of ‘New Urbanism’, this lack of greenery also doesn’t reallv bear out the central Noted. As above. 76 tenet of the ‘urban-to-rural transect’. Therefore, keeping the hedgerows and doing them up would be a good way to rectify this. 27 Rhona Cleland 12/4/05 Hedgerows The distinct presence of Hawthorn hedges along many borders between the built environment and the current green belt around Craigmillar/Newcraighall seems to be one of the marked characteristics of the area. Maintaining these would be a good way of preserving the character and pastoral feel of the area keeping a link with the past use of the land. Noted. As above. Consultation Disappointed when the UDF meeting at Bristo Church was cancelled. Unable to make meeting on gthApril. We feel we have not been given enough opportunity to voice our views on what the UDF have planned for Craigmillar and urge you to address this situation. Noted. Cancellation of this meeting was regrettable, but 4 other public meetings were held. Cairntows Park I would like to raise my concerns about Cairntows Park, I would hate to see it built on, it would be a huge loss to our community, we need more green areas not less. Noted. Cairntows Park would only be developed for office if no other town centre site available. Any planning application will be advertised and there will be an opportunity for further comment at that stage. In any case, replacement open space to meet 77 local needs would be required. Craigmillar Community Council May 05 Boundary The Framework should redraw the boundary to reflect the ward boundary which will include Fort Kinnaird Retail Park and the high proportion of existing private housing to the East of Niddrie Mill Crossroads. Noted. Reference to these adjacent areas should be included in more detail, but boundary of framework should remain focused on Craigmillar. Housing The Framework should: Ensure that at least 1/3 of new housing be for rent Schedule 100 new homes for rent per year Reduce the number of new flats built to 1/3 of total new homes Include 20% of private homes as low cost, locally affordable Limit average density to not more than 60 houses per hectare Explicitly address housing needs for older people and those with disabilities Discard the central concept of ‘Homezones’ and ‘Perimeter Blocks’ in favour of traditional and locallyconsistent design. Noted. Framework should be amended to: remove references to tenure mix as this is not a planning matter remove references to ratio of flats to houses as this is too prescriptive Include more detail on planning aspects of affordable housing focus on design matters to be addressed rather than density figures. Council policy is to promote the Home Zone concept (Movement and Development p 35, para 7.81) and reintroduce perimeter blocks (Edinburgh Standards for Urban Design, p 26 and 27) Other matters are housing matters not olannina issues. 78 Transport Noted. The Framework should: Framework should be amended to: Ensure that bus lanes and/or guided say more about bus lanes/ bus ways be introduced along the public transport corridor along length of Niddrie Mains Road, through Niddrie Mains Road (reference to Newcraighall and the new Queen already included) Margaret University campus make reference to the detailed Prioritise traffic on Niddrie Main Road design issues to be addressed and scrap the proposed junction at at Greendykes Road/ Niddrie Greendykes Road Mains Road junction Ensure integration with the planned make reference to link with road improvements at Fort Kinnaird Fort Kinnaird proposals Instruct a traffic impact study to identify South East Edinburgh the potential for a bypass to the north Transport Study did carry out or south (or both) of Craigmillar. initial work, but this was terminated due to lack of resources. In the absence of this, the Framework will make reference to the need for proposals to address Transport impacts. Community Facilities The Framework should: 0 Retain or suitably replace existing facilities at the Jack Kane Centre 0 Include facilities for young people 0 Provide a new neighbourhood centre for the Niddrie House and Greendykes areas Retain and refurbish the White House Pub as an unlicensed community facility ~ Noted. Framework should be amended to: 0 make reference to proposals at Jack Kane Centre (input to come from Culture and Leisure Department) 0 adjust text regarding the White House to allow for a range of possibilities. Other comments requesting 79 0 Retain existing under-5’s provision and provision of specific community facilities have been passed to expand as the population rises PARC for their consideration in tt Ensure all proposed community facilities are properly accommodated in Business Plan. the business plan. Town Centre The Framework should: Redevelop the town centre on its existing site Prioritise refurbishment of the existing homes and businesses within the town centre Instruct a full consultation process with regard to the siting of the new Community High School. Parks & Environment The Framework should: 0 Explicitly protect existing parks and green spaces -with no commercial or housing developments on them 0 Give more attention to the creation of green spaces within Craigmillar - as opposed to outlying areas on the periphery of residential areas. Noted. Town Centre should move to a more central location, but further consideration to be given to what is achievable in practical terms. Other comments are for PARC tc consider further. Children & Families Department has already completed a consultation proces! on school location. Consultation of the principle of moving the High School to town centre location took place in 200: and was favourable received. A statutory consultation will need tc take place by Children and Families Department. Partly accepted. Agreed that more attention to be given to open space needs for existing and new communities ar should be met. Framework will be adjusted to tal account of this. However, existin open spaces may need to chang as a result of that work. Until the 80 they are protected by Local Plan Policy. And those open space changes contained in the Local Plan need to be implemented in accordance with the provisions o the Plan. ~~~ Tony Clapham 10/4/05 Noted and welcomed. Redevelopment Understands the necessity of redevelopment. Applauds the breadth of the Framework in identifying a wide range of different topics of concern. Believes that significant improvement can take place in the community through the proposed redevelopment process. Looking forward to seeing: the improved parkland and botanical gardens; the improvements to the waterway running through Craigmillar; the improvements to housing quality; the new amenities, businesses and social resources being brought into the area. Concerns Consultation Disappointed at the low numbers of people Noted. who attended the public meetings. Few Consider these points in any futL folk had the opportunity to read through consultation exercises. the consultation document. Presentation of the meetings - a great assumption was placed upon residents having an awareness of the content of the framework prior to the meetings, if there was to be much expectation for them to be able to engage with the consultation meaningfully.. 81 For many, it was the first time they had opportunity to see more of the detail of the proposed redevelopment plans, and a 2hour discussive exercise is simply far too short a time to possibly gain insight into the breadth of the document’s purview Density Noted. To propose a new average density of 80 Agreed that Framework too homes per hectare without giving consideration to the population density that prescriptive and detailed in tk may result is extremely misleading and led regard. Framework to be to ambiguity simply because the proposed amended. population was not clarified: there is a vast difference between a density of 160 people living in a hectare (2-person homes versus 5-person homes), and the different mix of social amenities required to sustain these two extremes. Lessons to be learned from the history of Niddrie and Craigmillar. To pack families together like sardines -whether in houses or flats -without providing amenities and resources for children, particularly Primary 4-7 year-olds, would be a great mistake. This underlies concern at the proposed housing densities. Look forward to seeing detail in the final draft to show these genuine and legitimate concerns are unfounded and the fears behind them groundless. 82 Housing I understand the aim is for a final community housing ratio of bought to rented houses close to 50:50 once the development is completed, and welcome the economic and social stability that this is designed to bring to the area. However, given that Edinburgh’s market economies are creating a significant affordability problem, building a greater number of houses for rent, maybe as many as 250 more than currently planned, would be appropriate. Suggest partnership with the proposed Edinburgh Housing Association in providing this. The economic argument used by PARC for justifying the delay in building RSL homes in favour of building a greater proportion of private houses first is artificial, as all the houses need to be bought, whether by private home-owners or by RSLs, and the finances would still be raised either way. No compelling reason why more RSL homes cannot be built sooner. Maybe 2 or 3 housing developments would be taking place at any one time in different parts of the Craigmillar community, and a proportionate mix of right-to-return homes could be built as part of those developments. Ian said at a public meeting that right-to-return homes could be spread out throughout the community Noted. Comments already with Housing Dept. Also passed to PARC for consideration. 1 and be indistinguishable from any other homes. It must be possible to fulfil these criterion whilst at the same time building more righl to-return homes sooner than suggested in the CUDF proposals. The first 5 years could cause significant unrest and illfeeling Planners should consider revising the development plan to provide a buildinc schedule more favourable to providing homes for right-to-return and decanted families, as they already have links with the area. Additionally, a number in Greendykes are living in intolerable conditions. Requiring them to wait as long as 10 -12 years for a settled and goodquality home is unreasonable in the circumstances. Little attention given to the significant transport problem. It seems certain that, without a more coherent and radical overall transport strategy to divert nonlocal traffic from using Niddrie Mains Roac the proposals contained in the CUDF will only serve to ensure almost perpetual gridlock along Niddrie Mains Road. While an overall transport strategy is muct bigger than the purview of the CUDF, a meaningful reference to a more widereaching transport strategy, and the way it Noted. Framework to be amended to address this point, making reference to a commitment to reducing congestion on Niddrie Mains Road and ensuring that individual applications address fully the transport impacts. 84 plan, should be made in the CUDF. Concern to local residents that Niddrie Mains road is already completely saturated and grid-locked at times due both to the popularity of Fort Kinnaird Shopping Centre and to commuter through-traffic morning and evening, in spite of the fact that car ownership in Craigmillar is currently among the lowest in Edinburgh. A significantly expanding Fort Kinnaird and the intention to attract more homeowners to live in the community will increase the proportion of car ownership in the community and to attract more cars from outwith the area. Noted. Commitment to tram Line Improved public transport services will be 3 remains, but comments being welcomed. In the absence of any commitment to Tram Line 3, a commitment given further consideration. to considering guided bus-ways as an attainable and feasible alternative to a tram-link would be useful, as the tram-link corridor has already been set aside and would be most effectively used as a guided bus-way. This would remove the need for dedicated bus lanes along Niddrie Mains Road that, if implemented, would only serve to aggravate the local transport problem. Flooding and 5 A co-ordinated approach to improving local Noted/Accepted. Agreed that flood defences is welcomed. Concerned chapter on SUDS requires some 85 Play Facilities to see on Fig 9.2 (pl15) what appears to be two drainage “holding ponds” to the north of the picture adjacent to the heavy rail freight line. More thought should be given before this section on SUDS is adopted. additional work to address this i other issues. Niddrie Marischal currently has a poor lac of provision of play facilities for older children in the area. Little within CUDF to suggest that children’s play facilities will definitely be improved in the new developments. Keen to see conditions being placed on contracts awarded to developers that would ensure that play facilities would be provided for older children (Primary 4-7) as well as for toddlers and young children. Particular attention should be placed on play faciltie: being local to where children stay: parent: would not welcome “centralised” facilities that would require children travelling unreasonable distances from their homes in order to get to play facilties, and thi sis the main problem concerning the play facilities at the Jack Kane Centre. Noted. Framework to be revise1 after further work completed on open space needs. All planning applications will have to comply with current planning guideline ( “Open Space and Ancillary Facilities in New Developments’ The CUDF has earmarked the existing Craigmillar library site for housing development. Given that CEC allowed various developers to build in Niddrie Marischal usina an uncoordinated Noted. This issue should be reassessed in relation to open space needs generally within Craigmillar and the framework adjusted accordingly. 86 I “piecemeal” approach in the past few years, the result has seen lamentably few play facilities being built for older children; the resulting high boredom levels of children has led to frequent instances of juvenile anti-social behaviour and vandaIism. The library site, once the Library has been relocated, would be the last remaining site where a meaningful older children’s play and kick-around area could be located in the area. Serious consideration should be given to seeing if such a facility could be provided, instead of building more houses here. 87
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