We responded to the Proposed East Lothian Local Development Plan 2016
Para 2.47 and 2.48 Levenhall Links
The Trust welcomes Prop MH18 to continue to manage the land at Levenhall Links to Prestonpans to ‘improve the availability of suitable habitat for qualifying interest for the Firth of Forth SPA’. However the Levenhall site is of a wider wildlife interest than just the qualifying interest of the SPA. This statement seems rather limiting in terms of proposed management. There is potentially valuable grassland habitat for example. We would like to see a broader statement of the management of the site.
The Trust would like to see a commitment to creating a Local Nature Reserve at Levenhall to build on the local interest and support for the site and to enhance and develop the valuable management already carried out at the site by Scottish Power and the Council.
The Main Issues Report (para 6.26) mentioned that there may be opportunities to create a Local Nature Reserve (LNR) at this location. This was supported by the SWT in our comments on the Main Issues Report. It is disappointing to note that this proposal is not carried forward into the LDP
Para 5.24 and 5.25
The Scottish Wildlife Trust welcomes the intention to adopt a Green Network Strategy and notes that the Council ‘will have regard for the Green Network Strategy when assessing planning applications.’
The Trust suggests that the preparation of the Strategy is a priority in light of the considerable extent of the proposed development in the LDP (and development already underway) in order to maximise the opportunities to create and enhance green infrastructure.
The Trust hopes that sufficient resources within the Council are available to prepare the Strategy. There is a risk the pace of development may overtake the preparation of the Strategy.
Para 6.11 Local Nature Conservation Sites, Local Nature Reserve and Country Parks
New Biodiversity Sites. The Trust notes the new Biodiversity Sites and has previously commented on the selection process. We welcome the protection given in policy NH3.
Para 6.14 The East Lothian Biodiversity Action Plan (ELBAP)
The Trust welcomes the proposal to refer to the ELBAP in considering planning applications but notes that the current plan ran out in 2013. The Trust would like to see a commitment to the updating of the plan and some indication of how it will link in the proposed Green Network Strategy.
The Trust welcomes the statements in para 6.16. The Plan has extensive areas of land especially in the west around Musselburgh, committed for development. Whilst the loss of land is regrettable there is an opportunity for habitat creation and enhancement. In this the Green Network Strategy will assist but we hope to see the Council ensuring that landscaping associated with new developments will add value to the environment. The paragraph mentions SNH guidance which we know to be useful. The Trust has also produced guidance for extensive areas under Trust management in Cumbernauld and this may also be useful. http://cumbernauldlivinglandscape.org.uk/docs/083_385__southcumbernauldcga_greennetworkguidance_webversion_1446561841.pdf.
The plan also contains reference to new building at Elphinstone:
2.101 Land at Elphinstone West is allocated for around 80 houses. The encroachment of built development on to the rising land to the north must be minimised where woodland
planting must be provided to expand the existing shelter belt to the east and to contribute to Green Network objectives. There is also scope to accommodate open space to the north of the site and to ensure it connects with the existing open space on Main Street and the adjacent playing field. Provision should also be made within the site for turning and parking areas for the existing playing field to the west of the site in line with PROP CF1.
There may be a need to expand Elphinstone Primary School campus as a result of this development in line with PROP ED4. A Flood Risk Assessment is required. Structural landscape planting will be required to integrate this site with the surroundings.
A local member was worried by the latter and we responded to him and checked with TWIC and they confirmed there were no records of badger setts within 500 metres of the site.
There are no designated sites for wildlife in the vicinity of Elphinstone. The nearest Listed Wildlife Site is Bellyford burn a few fields to the south. One could argue loss of habitat as there are some hedges around the field and perhaps loss of connectivity if the hedges link into others. Apart from the possibility of badgers using the field for foraging it may be problematic to develop a very strong case against the housing based on wildlife on or using the site.
The proposed West Lothian Development Plan was submitted to Scottish Ministers on 28th October 2016. A Reporter will examine the Plan from January 2017 onwards. The Council has indicated that the Trust’s representations have not yet been resolved and so will be considered by the Reporter. While we do not expect that the Reporter will ask the Trust for more information, we have to be ready to provide such information if required.
The proposal by the River Forth Fisheries Trust for improvements to the Bog Burn watercourse has now been submitted as a formal planning application. This is adjacent to, and partly overlaps the Bog Burn LBS. The development will result in much needed habitat improvement in this area and result in an increase in the extent of wetland in the area.
In 2015 we commented on the Draft Midlothian Local Plan and in October 2016 we were informed that the plan was now having its final examination by a Scottish Office Reporter ( normal procedure ‘to deal with unresolved issues/comments from the consultation’) and that (one of?) our unresolved comments would be dealt with during this process – we think this might be our formal proposal that Mavisbank Estate Local Biodiversity Site should be joined with a neighbouring council ranger site and become a (second only in Midlothian after Straiton Pond) council designated Local Nature reserve for people and wildlife.
SES Plan Proposed Strategic Development Plan 2016
The Trust made the following comments on the proposed Strategic Development Plan for Edinburgh and South East Scotland (the 4 Lothian councils, the Borders and Fife – 6 in all, this plan is the second one that replaces the old Lothian Region Structure Plan).
2 Vision: There is a certain amount of read-across between the SES Plan vision, the Vision of the Central Scotland Green Network and that of the Edinburgh Living Landscape , this is welcomed. However, The Trust would like to greater explicit reference to the importance a healthy natural environment. A slight rewording as per the below is suggested:
“Sustainable growth has been achieved by carefully managing those assets that provide the most benefits and by making well designed, successful places where people can thrive. More people are able to afford a home in a place near where they work. A series of cross-boundary transport projects has made travel by public transport easier and more people are cycling and walking to work. The economy continues to grow and the region remains an outstanding place to live, work and visit. Strategic planning of green and blue infrastructure has helped reverse biodiversity decline, reduced the worst impacts of climate change and improved access to nature for all. Communities in the region are healthier and there is less inequality and deprivation.”
The Trust is pleased to see reference to the importance of careful management of assets, it must be made clear throughout the document and to stakeholders expected to deliver the plan that our most important assets are our natural assets. Natural assets should be managed in order to maintain natural function and deliver the wider benefits that society needs such as clean air, water, food, nutrient cycling recreation etc…
2.1 In the Trusts experience developers are very unlikely to pay any attention to “Development should” as opposed to “Development must”. Unfortunately “should” is more often than not applied to green infrastructure / green network guidance regarding development, there needs to be a step change in the way developers are forced to consider green infrastructure in development if we are to realise the multiple developments expected in the Green Network Guidance.
2.2 The Trust considers that green infrastructure should be included within cross boundary infrastructure. There should be a similar level of strategic planning associated with green and blue infrastructure as with traditional “grey” infrastructure.
3.4 The Trust note that land may be released for development this makes the proper weighting for green networks vital. Contribution to the overall green network should be made a material consideration of development. Assessing the “green quality” of a development has been highlighted as an issue by local authorities and by developers, as such the Scottish Wildlife Trust has been developing the “Natural Capital Planning Standard” which aims to give each development an overall rating in terms of the ecosystem services it is delivering. The Trust would be happy to meet with the team to discuss this.
3.6 The trust is supportive of the principles in table 3.2 and emphasises the importance of high quality biodiverse green space to these. The trust can supply additional Green Network Guidance if required.
3.8 The following should be added to the bullet point list: “To act as a buffer to designated sites, such as SSSIs, or locally important wildlife sites”
Table 3.1 See 3.6 comment
3.10 Should make reference to the need to invest properly in natural capital and green infrastructure to achieve sustainable growth
3.13 It should be kept in mind that the land around these settlements in East Lothian is some of the best agricultural land in the UK and certainly in Scotland, given the need to feed expanding populations very careful consideration should be given to the environmental impact and impact one ecosystem services (such as food production) of large scale, low density, housing provision in these areas.
3.16 There could be a slight conflict between growing industry in Leith associated with renewables and the associated rise in HGV traffic with high quality waterfront active travel options, the transport hierarchy should be strictly enforced with priority given to walking and cycling.
3.17 The SES Plan team should be congratulated for taking this plan lead approach, however, green does not just mean active travel considerable thought must be given to biodiversity and connectivity. The Trust thinks that it is essential to see reference to Edinburgh Living Landscape here especially since the City of Edinburgh Council are a founding partner, you can find more information on their website here: http://www.edinburgh.gov.uk/info/20064/parks_and_green_spaces/1160/edinburgh_living_landscape
3.19 Rail networks can form key components of green networks and this trackside habitat should be utilised to deliver maximum benefit. Care should be taken to make sure that rail networks do not become vectors.
3.23 There must be greater reference to the Edinburgh Living Landscape and opportunities around green networks and pollinator networks associated with these links.
3.28 There should be more detail provided regarding the biodiversity elements of the proposed Green Network Priority Areas.
3.34 There should be more detail provided regarding the biodiversity elements of the proposed Green Network Priority Areas.
4.5 The brightest and best entrepreneurial talent are attracted to high quality biodiverse environments, this should be highlighted.
4 Rural Economy There is not enough emphasis on the fundamentally important role that a healthy ecosystem has in the rural economy, this should be addressed. From the Scottish Governments Economic Strategy: “Protecting and enhancing this stock of natural capital, which includes our air, land, water, soil and biodiversity and geological resources is fundamental to a healthy and resilient economy. It also supports sectors such as agriculture, forestry, fisheries, tourism and renewables.”
4.16 Comprehensive environmental liability and compensation must be established by the planning authority, the public purse must not be forced to pay for environmental cleanup.
4.20 The plan should state that it opposes continued peat extraction for horticulture due to the huge biodiversity and climate change impacts.
5.12 The Trust would like to see the following added to the bullet point list: “The proposal actively contributes to green networks and that this will be a material consideration in the planning process”
Enhanced Green Networks The Trust welcome this section and applaud the SES Plan for including it
5.17 The Trust would suggest using the EU/Scottish Government definition here: http://www.gov.scot/resource/doc/362219/0122541.pdf
5.18 The green network does not always have to be a physical connection, in some cases habitat patches can form suitable “islands” for species to use.
Reminder: for Midlothian and East Lothian planning matters affecting wildlife sites please write to Susan Manson email@example.com, or at Castlesteads, Dalkeith, EH22 2NJ, in the first instance.
And for West Lothian write to Dr Cameron Easton firstname.lastname@example.org or write to him at 1 Bellsburn Avenue, Linlithgow, West Lothian, EH49 7LD.
And for Edinburgh wildlife issues please welcome new SWT Edinburgh Planning Representative Alan Templeton and contact him initially on email email@example.com
Dr Tim Duffy
Lothians Group Planning Secretary
Flat 4F2, 34 Warrender Park Terrace, Edinburgh EH9 1ED