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Stop Development of Brunstane Farmlands Greenbelt, Edinburgh

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FAO: Robert Newton (GVA James Barr, agent for EDI Group Ltd); 

CC: Catriona Reece-Heal (Planning Case Officer, City of Edinburgh Council); David Leslie (Acting Head of Planning and Building Standards, City of Edinburgh Council); City of Edinburgh Council Planning Committee; Board of EDI Group Ltd.

Dear Robert Newton

15/05835/PAN – Land 445 Meters North of 103 Newcraighall Road, Edinburgh

I am writing to register my formal objection to the planning application highlighted above and, in doing so, I would like to put forward the following issues to support the case against this development:

Maintenance of Green Belt and the Prevention of Coalescence

The area of woodland and agricultural land at Brunstane is the only remaining designated Green Belt land between Edinburgh and Musselburgh/East Lothian and acts as a natural boundary, protecting the identity and character of both these settlements, whilst preventing coalescence. 

Transport and Infrastructure

The area of land in question is landlocked and has no existing public transport links.  Creating such links will be hugely expensive and would involve building roads across the John Muir Way, as well as the main East Coast railway line.  This would result in negative impacts on walkers, cyclists and the natural environment, as well as the communities that surround the Brunstane site.  In addition, the road running through Newcraighall Village has houses located close to both sides of the street and is not designed to service the levels of traffic that currently use it.  The development of a further 1300 houses, over and above the 600 units that are already being built in Newcraighall, will completely gridlock the road creating dangerous levels of pollution for residents, as well as children who attend the local primary school.

City Council Planning Officers have estimated that peak hour traffic flows would increase by 63% on the surrounding road network if development is permitted on this site.  This is by far, the largest estimated increase in traffic of all the proposals that are being put forward as part of Edinburgh’s revised Local Development Plan and would result in major congestion and pollution.  These estimated increases in traffic flow also fail to take into consideration the cross-boundary transport impact on Newcraighall Village as a result of developments taking place in East Lothian and Midlothian.  Transport Scotland has been very critical of the City of Edinburgh Council's failure to undertake any proper traffic assessments on the cross-boundary transport implications and have submitted these concerns to the Scottish Government Reporter. 

Historic and Architectural Importance

There are already plans to build 600 houses in and around Newcraighall, a further 1300 will completely engulf the village and destroy the character and heritage of Edinburgh's last remaining mining village.  The proposal to build further units on the site at Brunstane will have a detrimental effect on the landscape settings of the two historically and architecturally important houses in the area, Newhailes and Brunstane House. The settings of both houses have gradually been eroded and diminished by modern developments over recent years and this proposal to build yet more units in the area will further substantially erode the surroundings of both of these significant historic buildings.

Serious Omission of Environmental / Public Safety Information from Edinburgh Local Development Plan

The site contains substantial near surface coal reserves (of up to 18 shallow seams) that have considerable, historic, shallow mine workings associated with them, including numerous mine shafts.  The presence of the near surface coal reserves and historic mine workings results in much of the proposed site being geologically unstable, as identified in a consultant’s report produced in 2006 on behalf of the Council-owned Development Company (EDI Group Limited). 

As a result of near surface coal and associated historic mine workings, development of the site could significantly impact the natural environment and public health and safety within its vicinity, a fact that has led to it being designated as a “High Risk Development Area” by the Coal Authority.  The Coal Authority – in a submission to the City of Edinburgh Council’s consultation on ELDP2 – has stated that its preference is for shallow coal reserves to be removed prior to the development of sites such as Brunstane Farmland, potentially resulting in extensive open-cast mining being undertaken on the land, which would create significant environmental impacts and disturbance.

Discrepancy between site identified in the Second Edinburgh Local Development Plan and the Proposal of Application (PAN)

In the Second Local Development Plan, the proposed Brunstane Farmlands development site's northern boundary is clearly shown as being to the south of the Brunstane Burn (apart from a corridor of land next to Portobello Cemetery where it is proposed a road linking the development with Milton Road East would be built).  The development site identified in the PAN includes a significant area of land to the north of Brunstane Burn, running a considerable length of Daiches Braes.

This would indicate that the actual development site is larger than that represented in the Local Development Plan, and correspondingly this will produce significant impacts upon Brunstane Burn and the land/residents of Daiches Braes.  These factors were not identified, nor consulted on, in the Local Development Plan, potentially raising significant doubts about its accuracy and legality. This is an issue that has been raised with the Scottish Government's Planning Reporter.

 Biodiversity and Natural Habitat

There would be a significant loss to the biodiversity in the area if Brunstane Farm was developed. This land was identified in 2002 as a proposed biodiversity area, a reservoir for some of the 97 priority Scottish wildflowers and 12 key habitats currently threatened with extinction. The Brunstane Burn was furthermore identified in the Development Quality Handbook as an Urban Wildlife Site. The fields here serve as prime agricultural land, and offer an important link between the historic properties of Newhailes House (N.T.S.) and Brunstane House. It has been identified in Local Biodiversity Action Plans that planning authorities should make an important contribution to sustainable biodiversity targets (e.g. NPPG 14 'Natural Heritage' 1999).  A number of protected animal species have also been observed/recorded as being present at the site, including bats, common buzzards and sparrow hawks.

I would like my objections to this application presented to the Board of EDI Group Ltd, and City of Edinburgh Planning Committee and would urge members of the Committee to fully consider the points that I have raised and, as a result, would ask them to reject this, and any other, planning application to develop this site in its entirety.



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