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Draft West Edinburgh Planning Framework - Overview of consultation responses

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DRAFT WEST EDINBURGH PLANNING FRAMEWORK

Digest of Responses

Respondent

Summary of Representation

General Issues

The City of Edinburgh Council, East Lothian Council, Dundee City Council, Falkirk Council, West Lothian Council, Glasgow City Council, Renfrewshire Council, South Lanarkshire Council, Stirling Council, Glasgow and Clyde Valley Structure Plan Manager

General support for the strategic aims of the Planning Framework and the vision for managing growth and safeguarding accessibility.

Renfrewshire, Stirling and South Lanarkshire Councils want to see recognition that solutions to West Edinburgh's transport problems cannot simply be found in Lothian and want more consideration of wider economic, land use and transport implications of the Vision.

East Lothian Council welcomes endorsement of the emerging Structure Plan strategy, although considers many of the aims and objectives of the WEPF could be achieved through the more equal distribution of employment land throughout Lothian.

Glasgow City Council argues that brown field business locations already served well by public transport (e.g. Broomielaw) need to be promoted, instead of green field development in areas with identified labour shortages.

Stirling Council and Renfrewshire Council consider that the Framework should be set more clearly within a national context.

Glasgow and the Clyde Valley Structure Plan Manager consider that the vision will induce need for long distance commuting. This will counter efforts to reduce congestion and safeguard accessibility.

Fife Council

Fife Council considers that the issues in west Edinburgh have been considered in isolation from the surrounding council areas. The Framework should address the relationship between the Lothian and other Structure Plans and is therefore in conflict with the proposals contained in the Review of Strategic Planning (which calls for planning at a city region level) and does not represent a co-ordinated approach to planning as intended.

BAA Scottish Airports and BAA Edinburgh

Strongly welcomes the Planning Framework as a way of help protecting the national asset of Edinburgh Airport and the surrounding area. It is also regarded as being an excellent model for taking forward the outcomes of the Aviation White Paper.

Friends of the Earth, Queensferry and District Community Council, Fife Council, Scottish Association for Public Transport (SAPT)

New economic development should be directed to areas outwith Edinburgh where there is greater availability of labour, brownfield land and transport capacity.

Scottish Natural Heritage

SNH would like to see greater linkages and cross referencing to the NPPG series and clarification as to how the WEPF relates to the National Planning Framework.

Edinburgh Green Belt Network

Promotes the more equitable distribution of growth around Scotland and questions the sustainable development credential of meeting demand for economic development wherever it arises, and where it will erode valuable environmental assets.

Is generally concerned that the document is promoting very significant undermining of green belt policy and that uncertainty over the scale and location of green belt release is causing alarm.

AWG Residential, Barratt, CALA, Dundas Estates and Hopetoun Estates, Mactaggart and Mickel, Homes for Scotland, Park Lane Developments, Scottish Council for Development and Industry, Dundas Estate together with Hopetoun Estates interests

Housing land supply should form part of the vision. The Framework will increase long distance commuting in an area of labour supply shortages, which conflicts with national planning policy guidelines and sustainable development objectives.

Homes for Scotland is concerned the geographical and topic focus is too narrow and doesn't consider that the document provides a basis for a sustainable settlement pattern.

The Scottish Council for Development and Industry suggest theta it is crucial to sustain a labour force through the provision of housing, and more strategic direction should be provided on this.

SUSTRANS, Chris Byrne, John Blair-Fish, Eileen Holttum, National Association of Cyclists, EDI, SPOKES, John Glackin, David Leslie

Concerned that the Framework does not recognise or promote walking and cycling use and provision.

West Edinburgh Community Councils, (South Queensferry and district, Kirkliston, Corstorphine, Ratho and District, Currie, Drumbrae, Drylaw/Telford and the Cramond Association)

Would like to see greater recognition given to community needs and local considerations, in particular air and noise pollution, heritage, environment and services.

Scottish Council for Development and Industry

Supports investment in West Edinburgh as a driver for the economic success of Scotland. Recognises that significant investment in transport infrastructure is urgently needed.

Margaret Smith MSP and John Barrett MP

Welcome the strategic approach being adopted in dealing with the big issues affecting the area, although is concerned that no representatives of the thousands of people that live in the area where included on the Stakeholders Advisory Group. Suggests local representation on the Group and on the proposed Travel Plan Organisation.

Generally concerned that there is little mention of social impact further development may have on the area.

Introduction

West Edinburgh Community Councils

Concerned not to have been included in the stakeholders advisory group and would like to see members of the Stakeholders Advisory Group listed.

Premier Property Group Limited

PPG should be considered to be one of the key stakeholders. (map of land in their ownership included).

Edinburgh Green Belt Network

Wants to see some reference in paragraph 2 to the fact there are problems associated with the overheating of the Edinburgh economy.

Dundas Estates together with Hopetoun Estates

As a major landholder in the area, the Group should be included on the Stakeholders Advisory Group.

West Edinburgh - The Place

South Lanarkshire Council

Would like to see the document cover a wider area and deal with the housing market and transport implications for South Lanarkshire.

Ferrymuir Residents

Concerned that South Queensferry has been omitted from the plans, in particular the Ferrymuir Development site (class 4), the impact on the A8000 of this and the Rosyth Continental Ferry Service.

Fife Council, Queensferry and District Community Council

Fife should be more specifically included in the framework, in particular, present and potential links, the Rosyth-Zeebrugge ferry and cross-Forth movements.

Homes for Scotland

Would support a wider area being covered, including Riccarton, South Queensferry and east West Lothian.

CALA Homes Ltd, Mactaggart and Mickel

The study area is too narrow to explore the broad sub-regional issues being considered. It should therefore cover a wider area, including the land to the south at Riccarton and Currie, as well as to the east of West Lothian and south of the Forth Bridge and deal with transport links.

Fife Council

Fife Council wants to see consideration of the cross forth dynamic in transport, labour supply and other strategic land use issues.

Dundas Estates together with Hopetoun Estates (Submitted by PPCA)

Table 1 should be updated to reflect the fact that there is permission on place for a future rail halt at Turnhouse.

Mr Alex Kerr

The Framework needs to be set within a context of a wider central belt strategy (map enclosed).

The Garden History Society

In order to judge the capacity of the landscape to accommodate development the Framework should take into consideration the likelihood of other strategic areas being released for development, in particular the West Lothian Core Development Area/ any new settlement in West Lothian.

The Cockburn Association

The boundary should be extended to include the Heriot-Watt University Campus. Hermiston Gait Business Park could provide a natural escape valve for demands on office space.

West Edinburgh Ltd

West Edinburgh Ltd questions the potential for the former RAF Turnhouse site to be able to support up to 70 000sq m of commercial floorspace, particularly in view of the constraints on the Maybury Junction. Wants to see the main focus of the Framework enhanced to embrace the land around Turnhouse/Turnhouse road in view of its strategic importance for allowing access to the proposed Turnhouse 'Airwest' site and its potential for use class 5 and 6 development.

AWG Residential and Barratt East Scotland Limited

The study area is too narrow to explore broader sub-regional issues and should be expanded to include the West Lothian CDA, encompassing Winchburgh and East Broxburn. This should particularly look at housing land requirements and transport links.

Royal Highland and Agricultural Society of Scotland

Table one should be amended to read 80 into the local economy and 200 into the national economy. Also, The City of Edinburgh Council and SEEL have helped promote the site as 'Scotland's National Showground'.

Light Rail Scotland

Concerned at the lack of progress in transport schemes and that quoted dates appear to be slipping.

Scottish Association for Public Transport

The main focus of the area and tables should be extended to include the Heriot-Watt Campus and an area adjacent to the Edinburgh Bypass as key development sites. The latter to meet demand for housing.

West Edinburgh - A National Asset

David Roberts Associates

The economic potential and importance of west Edinburgh is understated. The Framework should explain the international significance of the area and its linkages with the Scottish economy.

Waterfront Edinburgh confidential

Secondsite (formerly Lattice) Properties Ltd

Considers Edinburgh Waterfront to be a 'national asset' also.

EDI Group Limited

EDI wants to see paragraph 12 expanded to give more emphasis to Ratho as a location of housing development: 'Residential expansion of Ratho is supported to meet the demand for housing on the west side of the city and to provide a valuable base to sustain enhanced social and commercial facilities for the village.'

Edinburgh Green Belt Trust

Wants to see the 'strategic role' of the Green Belt defined (para 15 and elsewhere).

Royal Highland and Agricultural Society of Scotland

RHASS would like to see an additional bullet added at paragraph 15 to recognise the future of the Showground in the national interest: ' need to ensure that the continued operation, and future development of the Royal Highland Centre is not compromised by the allocation or safeguarding of land for other uses'.

The Garden History Society

Framework should identify all environmental assets of national and regional importance - preferably on a map.

Background Issues, Pressures and Constraints

The Cramond Association

Suggests the inclusion of a sentence at the end of paragraph 21 of the framework: Measures to minimise the impact of aircraft movements and related noise on the environment of local communities will also be required

John Watchman

The Planning Framework does not make reference to NPPG 17, Edinburgh Local Transport Strategy or Scotland's Transport: Delivering Improvements.

The Framework should encourage incorporation of the LTS into development plans, in line with NPPG17.

Policy on containing traffic growth and tackling congestion is set out in Scotland's Transport: Delivering Improvements. The Framework would benefit from more explicit cross-referencing to it. Reference should be made to wider strategic transport initiatives including Waverley Station and Central Edinburgh Traffic Management Proposals.

David Roberts Associates

Also, economic demand is not simply based on financial and business services but also includes tourism, retail, culture and technology based businesses.

Growth potential should not simply be based on a sum of current known and anticipated development. Rapid change and global competition have made this assumption outdated.

Scottish Council for Development and Industry

Accepts and agrees with the suggested scale of projected employment growth.

Scottish Association for Public Transport, Glasgow City Council, BAA

Challenges the basis of the Airport Growth predictions being used for the Air Services Consultation Document and their applicability to the Planning Framework and sustainable development objectives.

SEPA

Would like to make further comments in relation to the environmenal issues section (paragraphs 21 and 22)

Flooding - New development should not exacerbate flooding in the Almond and Gogar Burn catchments - a flooding strategy may be required.

Water Quality - Lack of acknowledgement that quality is already adversely affected by development in west Edinburgh. Strategy required to ensure there is no further deterioration in water quality or ecological value of watercources, under provision of the EC Water Framework Directive.

Transport Infrastructure - Second runway etc would result in culverting and the loss of flood plain, increasing the risk of flooding and pollution surface run off which. It is generally SEPAs policy to avoid culverting.

The environmental focus of the vision could be enhanced through some positive support for a landscape framework in advance of development. It could identify areas for protection, areas of habitat creation such as woodland and areas for public access and amenity.

Fife Council

Discussion of environmental and technical constraints is brief and does not seem to recognise the cultural heritage value of the area.

Edinburgh Green Belt Network

Wants to see an environmental/landscape capacity study commissioned to help understand environmental constraints and environmental capacity.

The Vision for West Edinburgh

Edinburgh Green Belt Trust, West Edinburgh Community Councils, Currie Community Council

Generally concerned that the vision is unreasonably skewed in favour of development over environmental protection and enhancement, in particular, natural and cultural heritage, noise and air pollution.

Margaret Smith MSP and John Barrett MP, West Edinburgh Community Councils, Friends of the Earth, New Edinburgh Ltd, Craiglockhart Community Council

There should be no more development committed to west Edinburgh until strategic transport proposals are in place.

The Association for the Protection of Rural Scotland, Currie Community Council

The document to read like a development charter and should be redrafted to avoid development of any non-conforming uses in the green belt.

Moorfield Group Ltd

As owners of a site at Edinburgh Park the Moorfield Group supports the aims and vision contained in the Planning Framework.

Mr Alex Kerr

Concerned that the national interest (paragraph 23) is generally only of local significance.

West Edinburgh Ltd

West Edinburgh Ltd considers that the draft Framework fails to fully grasp the opportunities presented by west Edinburgh.

Scottish Natural Heritage

SNH would like to see the policy objectives in paragraph 23 extended to include a greater commitment to sustainable development, for example, reducing traffic pollution, provision of more sustainable transport modes and protection and enhancement of landscapes and biodiversity.

Royal Highland and Agricultural Society of Scotland

RHASS suggests that bullet point 4 at paragraph 23 be amended to include 'the introduction of rail links to Edinburgh Airport and the Royal Highland Centre to improve accessibility and reduce journey times from other parts of Scotland and the UK'.

RHASS would also like to see an additional bullet added at paragraph 23 to recognise the future of the Showground in the vision: ' continued development of the Royal Highland Centre'.

The Edinburgh Airport Amenity Group

Indicates that there is no policy on aircraft noise and therefore the following paragraph should be added to paragraph 23:

' The effect of aircraft noise (and other effects) on residential amenity (both existing and proposed) will be fully taken into account when deciding all proposals to develop facilities at or in the vicinity of Edinburgh Airport.'

David Roberts Associates

The Vision reads as one where the green belt is sancroscant as if this was the only arbiter of a development strategy. It rationalises proposed developments with Executive civil service timidity and political fear of controversy. It is not creditable to assume that the future will mirror the past, threaten few interests, fit with the Structure Plan and then call that a serious contribution to the National Planning Framework.

Mr R Michael Watson

Mr R Michael Watson sets out a detailed proposal for heavy and light rail

links to the Airport.

Margaret Smith MSP and John Barrett MP

Welcomes the Executive's strategic vision but is concerned that the proposed transport infrastructure should come forward independently of road user charging proposals in Edinburgh.

Scottish Association for Public Transport

The national interest should include the integration of rail and bus networks into land use plans, reduction of congestion by 2006 and priority introduction of road pricing in central and west Edinburgh.

The Planning Framework

Royal Highland and Agricultural Society of Scotland

RHASS submits that the planned growth of Edinburgh Airport should not be allowed to blight the continued expansion and rationalisation of car parking and other support services of the Showground and wider Ingliston area. The Framework should require that the Airport works together with the RHS to provide for non-operational support services related to expanded Airport activity within the wider Ingliston estate.

RHASS supports the reinforcement of the strategic role of the Green Belt through removing the RHS and Airport from it and making the boundaries more recognisable and defensible. This would also reinforce policy support towards their continued development.

Secondsite (formerly Lattice) Properties Ltd

Supportive of improved transport links although would like to see more clarity and certainty over timing and funding arrangements in the finalised version.

Would like to see the scope explored for an extended tram loop from Newbridge to Queensferry and along Queensferry Road to North Edinburgh Tram link.

Keen to see the GB protected until at least 2020, and priority given to core SP development areas.

Strategic Rail Authority

SRA supports Edinburgh Park Railway Station and the provision of heavy rail links to Edinburgh and Glasgow Airports.

Improved access to the rail network from key development sites is supported in principle but this should not compromise the operational efficiency of the railway. The SRA therefore supports more explicit guidance on the role of developer contributions towards providing better links to rail facilities and associated improvements to services and facilities.

Waterfront Edinburgh confidential

Light Rail Scotland

Consider that the WEBS proposal should be abandoned, freeing c10million for immediate investment in the tramway.

The Ingliston P&R should be integrated into light rail proposals.

The City of Edinburgh Council

Stresses the fundamental importance of securing commitment from the Scottish Executive for transport improvements consistent with its own Local Transport Strategy.

Recognises the potential need for improved road links around the Airport and between west Edinburgh and the Waterfront, although accepts that this may need to be resolved after the outcomes from the forthcoming Aviation White Paper are known.

Support the principle of developer contributions to transport infrastructure although considers that the limited amount of development being proposed will not allow for much scope for these.

Supports a statement in the Framework for the promotion of sustainable construction techniques.

Glasgow and the Clyde Valley Structure Plan Manager

Proposal to use GB designation to safeguard a strategic reserve of land is confusing in terms of the stated objectives of the GB, contradicts commitment given to GB elsewhere and could lead to land speculation.

Wants to see a commitment contained in the document towards a balanced development of both Edinburgh and Glasgow Airports.

Scottish Association for Public Transport

Supports the introduction of mode share targets and road pricing to underpin the spatial strategy.

Friends of the Earth

The Framework should also set modal shift targets.

Applications for development should be accompanied by an ecological footprint analysis, including resource use and carbon dioxide emission projections.

Bryant Homes Scotland

Concerned that the national interest in West Edinburgh is being compromised through simply restating existing draft Structure Plan policy. Development in west Edinburgh should be promoted now and not in 20 years time. Bryant Homes considers that the Framework should be clearer on commitments and timescales for transport investment

Housing provision is considered to be essential to the sustainable development of west Edinburgh and considers that the strategy will lead to significant long distance commuting.

Glasgow City Council

There should be an additional heavy rail station, on the Glasgow-Edinburgh line, to provide an interchange with the proposed LRT line at Newbridge for traffic from the west.

West Edinburgh Community Councils

The Community Councils would like to see the location of the proposed 1000 houses at Newbridge/Kirkliston/Ratho being defined more clearly.

Scottish Council for Development and Industry

NPPG 2 sets out the importance of HQ buildings and would like to see more explicit support for confirmed HQ buildings the West Edinburgh in line with the caveats set out in paragraph 24.

Royal Fine Art Commission for Scotland

RFACS submits that safeguarding areas of Green Belt for future development is contrary to the development plan and national planning policy guidelines. RFACS would like to see a more positive commitment to improving the landscape and appearance of the Green Belt/A8 corridor.

Meadowfield Developments Ltd

Concerned that the Planning Framework is a missed opportunity for realising he economic potential of the A8 corridor.

Wants to see Edinburgh Airport designated as a core development area in the event of a second runway being developed and the cross runway being closed.

The forecast floorspace at Turnhouse (table 3) is not considered to be viable

Overall the Planning Framework shows bias towards class 4 uses in spite of demand for class 5 and 6 uses e.g. at Turnhouse.

New Edinburgh Ltd

Supports the principle of fair and reasonable contributions being obtained from developers for public transport improvements.

Premier Property Group Ltd

Disappointed that the framework does not place West Edinburgh in a European context and that development is not promoted before 2020, even in the event of transport links being in place. Overall the Framework is too conservative.

Private investment in improved transport infrastructure may compromise more than a development levy or surcharge although should be based on a partnership approach.

West Lothian Council

Wants to see more detailed costings of transport infrastructure proposals, together with an indication of how they might be funded.

Wants to see the proposed expansion of the Gyle Centre (Table 3) promoted in line with NPPG 8 and the sequential test.

International Business Gateway Scotland

IBG supports the strategic aims of the Framework, although does consider that the potential for further international headquarters buildings is being restricted until at least 2020 and that this will serve to reinforce the gap in Scotland for planned sites, attractive to and capable of accommodating internationally competitive economic development. Supported by a qualitative assessment of land supply for this type of development, IBG would like to see references to 2020 and 2030 removed so that short-term opportunities for headquarters developments are not compromised.

IBG supports the early and sustained step change in levels of transport investment in west Edinburgh are needed and considers that development in the short term can help deliver these.

Would like to see more clarity on transport proposals, including the means and timing of delivery.

IBG considers that the Framework represents an opportunity to promote the environmental and visual appearance of the A8 corridor and Airport.

FSH Airport (Edinburgh) Services Limited

Framework does not provide a clear basis for making decision of individual applications and leads to confusion over a multitude of strategic options.

The Vision should not preclude development beyond the next structure plan period, particularly if the public and private sectors work together to integrate development and transport provision. Would welcome an expanded stakeholders advisory group on an accountable and formal footing to discuss how this might happen.

Mr David Leslie

Land around the airport, especially at Turnhouse, should be safeguarded for light rail infrastructure rather than be swallowed for airport associated uses.

Lothian Buses

Various comments on the schedule of development to 2020

Sighthill/South Gyle: These areas cannot be ignored as an when further developments arise, in preference to further expansion 'out of town'

Edinburgh Park: Area suffers from congestion, illegal parking, lack of traffic regulation/enforcement, regular accidents causing difficulty in maintaining bus timetable. These problems need to be addressed.

The Gyle Centre: Any expansion should not be at the expense of any re-generation of the City Centre. Suffers from congestion problems relating to the Edinburgh Park, especially at the start finish working times of the day. Urgent need for radical improvement to the bus terminus facilities.

Gogarburn Hospital: Opportunity exists at the initial planning stage to ensuring that public transport access is fundamental to the redevelopment of this site. If not, it will contribute to further deterioration and undermine the overall success.

Edinburgh Airport: Urgent need for an improved bus departure point so it is immediately accessible from the public building. Too far away at present.

Royal Highland Showground: This development will undoubtedly be influenced by the decisions regarding the future growth of the airport. Transport strategy should therefore be wholly complimentary to the development and the A8 corridor.

Newbridge: Considerable scope for the regeneration of this area, and the converging motorway system. Transport access issues should not be marginalised in favour of housing developments.

Tram: Disappointed that the benefits to be gained from segregated tram alignment will be at the expense of WEBS. Is not a cost effective way forward and removes any advantage that will have been gained over a private motorist, by taking away the flexibility that only a bus can provide.

AWG Residential confidential

Clerical Medical Investment Group Ltd

Hermiston Gait Retail Park will next year have an excellent transport link with the new Edinburgh Park railway station. Therefore, this area should be given similar treatment in the Planning Framework to the Gyle Centre, as a location that offers significant opportunity for retail expansion in conjunction with planned pubic transport improvements.

Health and Safety Executive

The Framework should make reference to the existence of two high-pressure pipelines in the area. Map included.

Vince Stewart

Disappointed that the document offers little in the way of economic development potential, with the exception of Gogarburn.

It also does little to remove uncertainty over the balance of land uses between the Airport and Showground or serve as a basis for development control. Sites around Eastfield Road are being blighted.

Framework does not set out a requirement for an Airport Showground Masterplan. Does this mean that there is no longer any requirement to prepare this? An adopted LP for the area is unlikely to be in place until 2006

The Cockburn Association, Dundas Estate together with Hopetoun Estates interests

The finalised Framework should clearly define the preferred route of the heavy rail links to the Airport, therefore avoid blight and give certainty.

EDI Group Limited

EDI would like to see reference to the Sighthill and South Gyle development areas in Table 3 expanded to include a requirement that: ' This intensification of development is subject to effective mitigation of adverse transport impacts' in order to be consistent with the reference to Edinburgh Park.

EDI notes the support given to further retail development at the Gyle Shopping Centre in Table 3 but wants to see this made subject to impact on the City Centre, Wester Hailes and other 'town centres'.

Land Securities

Opposes support for further expansion of the Gyle shopping centre in that it appears inconsistent with both stated SE and The City of Edinburgh Council Development Plan policy and would not be subject to sequential testing.

Also states that the Gyle will have expanded to around 36,000 sq.m. after current permission are implemented.

The Cockburn Association

Considers treatment of environmental issues to be the weakest element. The Green Belt plays a critical role in the urban form of Edinburgh, which needs to be recognised. The Framework offers no guidance as to how the greenbelts strategic role can be reinforced. The role of the A8 as a key gateway into the city with prime views needs to be reinforced, for example, planting of trees, landscaping and views are important elements within this.

Would like to see the document set out a modal split targets for airport traffic to 2007 and 2015.

BAA Scottish Airports and BAA Edinburgh

Would like to see the Framework recognise more clearly the development of the Airport as a priority over surrounding land uses.

Considers that early action and investment is needed to address the key challenge of mitigating the transport impact of development already committed.

Considers the key policy priorities to be enhanced global connectivity and improved surface accessibility.

Framework should make reference to the targets in the Transport Delivery Report of reducing congestion by 2021 to 2001 levels. Improved road access to the Airport will be a crucial part in achieving this.

The Framework needs to be more explicit on transport delivery and timing.

The Framework should be more specific in safeguarding future operational requirements, including a third runway.

Would not want to see delivery of improved transport delivery compromised through a commitment to Green Belt protection until 2020. Providing transport is in place first, then the timescale should become irrelevant.

The Royal Highland Showground expansion would severely prejudice the ability of the Airport to acquire and develop the land it needs to grow, thereby limiting its role as a national asset. If the opportunity to set priorities is lost, the value of the Framework is compromised. It is accepted however, that it may be necessary to postpone a decision on this until the outcome of the Aviation White Paper.

Query the basis of Table 3, which appears to constrain airport growth to 15 million passengers per annum by 2020.

The finalised Framework should reflect the findings of the SE/SRA Rail Links Study.

BAA is extremely concerned about road capacity and supported strategic as well as local road improvements, in particular Motorway access and to the cargo terminal at Turnhouse. Road enhancements should be an unconditional requirement of the planning framework (para 23).

The Framework should give support for improved bus services.

Note a transport interchange is proposed on BAA land. This should not compromise the operational efficiency of the Airport and would have to be commercially viable to be operated by BAA.

BAA wonder how the Park and Ride facility at Ingliston relates to the Airport interchange and are concerned it would increase congestion on Eastfield road to the detriment of Airport accessibility

Scottish Natural Heritage

SNH would like to see dates given for the introduction of transport improvements. It also strongly recommends that new transport infrastructure needed to facilitate access to Edinburgh Airport is put in place before growth takes place.

SNH points out that a second runway at Edinburgh Airport would require significant culverting of the River Almond, to the significant detriment of its ecological value. This would need careful considered in the context of NPPG14 and the Water Framework Directive.

SNH considers the implications for the Green Belt to be unclear. It suggests that the Framework be clarified to state that future green belt development should not undermine the strategic role of the green belt (paragraph 30).

SNH would like recognition given to the scope for the Framework to reinforce the strategic role of the Green Belt, for example, through promoting improvement of landscape and biodiversity assets.

Stirling Council

SESTRAN partnership has not been acknowledged in the framework.

Homes for Scotland

Questions the purpose of the framework in that it does not promote any and land release until after 2020.

Distinction between class 4 (of which there seems to be surplus land) and world class economic development is confusing and needs to be clarified.

University Superannuation Scheme Ltd

The framework states that further regeneration and development for the area cannot go ahead until transport improvements are in place. A tangible link between the granting of planning consents for the development in the area and the outworking of transportation improvements would be supported. Scope for these developments to come forward in tandem with transport improvements could be provided through a phased approach to development.

Action Required

Bryant Homes

Bryant Homes is concerned that the 'Action Required' does not set out any clear requirements for the Development Plan and questions the relevance of the Planning Framework to the development planning system.

Scottish Council for Development and Industry

Would like to see the outcome of the Aviation White Paper reflected in the finalised Planning Framework.

Vince Stewart

Framework does not set out a requirement for an Airport Showground Masterplan. Does this mean that there is no longer any requirement to prepare this? An adopted LP for the area is unlikely to be in place until 2006

BAA Scottish Airports and BAA Edinburgh

Action required is not enough to deliver the vision. For example, reference could be made to the action required by the Executive and the Council in delivering transport improvements rail links etc. Other requirements could include developing firm recommendations for managing traffic (based on a comprehensive transport study) and the establishment of a Travel Plan organisation.

Premier Property Group Limited

The Planning Framework should be supplemented with a masterplan for the area, which could serve as a marketing tool for inward investors in Scotland.

Scottish Council for Development and Industry, EDI , SPOKES

The Framework should give more explicit guidance on the use of Section 75 planning agreements as a way of ring fencing contributions towards public transport improvements.

Other suggestions include a dedicated 'fund', including the contributions to maintain and enhance public transport infrastructure in the area.

SEPA

Requires planning authorities to input safeguards to prevent undesirable development in the area, whereas a more proactive approach would require that they start planning the type of environmental framework (similar to a large-scale masterplan) that could be adopted.

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Page updated: Thursday, April 6, 2006