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Portobello schools consultation
I am writing on behalf of Portobello Park Action Group, which represents the views of many people who oppose the development of Portobello Park and Golf Course. Our supporters include local residents, children and parents, golfers, footballers, dog walkers and nature lovers. We have wide support in the community, with around 3,000 people having signed our petition opposing the development of the Park and Golf Course. We call upon the council to conduct a full debate on all the site and funding options, including keeping the land for public recreation.
We welcome the opportunity to participate in the wider community consultation on the sites for the new schools, however, we have a number of questions which have not yet been addressed.
1 We believe Portobello park and Golf Course to be common good land. This is backed up by the legal opinion of Roy Martin, QC, who states: “Whilst the issue is ultimately a matter of fact to be judged by the court, it is my opinion that the Park does form part of the common good of the Council and the Group would have reasonable prospects of obtaining a decision of the Court to that effect. In that situation, there would be limitations upon the entitlement of the Council to alienate the land forming the Park”.
2 We have raised questions about how the consultation will be evaluated and how a conclusion will be reached on the new sites for Portobello High School and St John’s Primary School. Unfortunately we have not had a response to these questions, which I list below:
There is a possibility that the two schools will form one campus; the parallel consultations ignore this. How is this accommodated in the consultation?
You are asking people to make a decision in a vacuum. To give you an example, it has been claimed that if people vote for option C for the High School then the golf course will be saved. This completely ignores the fact that the golf course may come out as the favoured option for St John's. How will the two parallel consultations be dovetailed?
Is there a different weighting applied to the views of parents than to local residents?
Are children's views taken into account? If so, are they given more, less or equal weighting as adults? What is the lower age limit for a child to make a submission?
How will 'votes' for each option be counted when much of the response will be free text?
Do parents get a say through the schools consultation and one through the wider consultation? Parents who currently have children at either of the schools but whose children will not attend the new schools should have no greater weight attached to their comments than other residents.
Is the general consultation restricted to only those living in the catchment area? How will this be proved? Who is the wider community?
How will other sites be assessed if there is a groundswell of support for them?
How will the authenticity of respondents be verified?
I hope you agree that we need answers to these questions for the public to feel confident about the conclusion reached on the consultation.
At the recent public meeting for local residents, it was difficult to raise many of the wider issues concerning people as quite a lot of airtime was spent on subjects such as decants which had already been fully explored at the two previous meetings for parents. This meant that many other issues, such as loss of green space and amenity and questions about the dismissal of brownfield sites from the consultation were not able to be raised in any depth, if at all. The tightly controlled nature of the meeting did not allow for debate and discussion and many questions were taken from parents who had attended previous meetings, instead of giving priority to other members of the public who had not had the chance to have their say. We hope that due consideration will be given to the views of ordinary residents in reaching a conclusion on the consultation.
3 In our deputation to the Council Executive meeting on 12 September we asked for certain brownfield sites to be reconsidered as we believe that the rationale for their dismissal was unclear. We have since asked four times for a site meeting with the council’s consultants to point out some of the misconceptions contained within the feasibility studies, such as the Baileyfield site being shown as extending across Rosefield Park. We are also concerned that the consultants employed to carry out the feasibility studies have not previously been involved in school design. Unfortunately our requests for a meeting have been refused on the grounds that, “there are a number of groups interested in these proposals and it is imperative that they are all treated equally. For the same reasons we are unable to make site visits with one interest group”. We did not ask for an exclusive site visit and would have been quite happy if representatives of other groups had been present. We would still like the opportunity to have a site visit and hope that in the spirit of co-operation you will grant this.
4 We are also concerned that, up until very recently, housing on the Golf Course and Park was to be the funding method for the new schools. The council now appears to be saying that there will be no housing built on the Park or Golf Course to pay for the schools. This appears to be a short term strategy until after next May’s elections. There is no indication from the Scottish Executive that funding will be made available and the council’s intention of raising money for the new schools from capital receipts presumably still stands, so what assets will be sold to pay for the schools? We are concerned that, when it is identified that there is a funding gap for the schools, the housing on the Park and Golf Course will reappear on the agenda. If this happens, can the council give an assurance that consultation will begin again from scratch, including site options. People need to know the implications of their choices - at the moment we are being asked to make decisions in a vacuum.
5 The council agreed to widen the consultation to the general public but has not looked at the wider issues surrounding the replacement of the schools, such as the potential loss of central, accessible green space, loss of amenity, environmental issues and potential increase in traffic in a very congested area with limited access. It has been said that these would be addressed at the time of any planning application but, once again, we are being asked to make choices in a vacuum. It would be more helpful to the whole community to look at the big picture and all contingent issues at the same time.
The Options
We oppose the development of Portobello Park and Golf Course for either schools or housing and therefore we support option A for Portobello High School. Decant issues are being used to put people off this option and the example used at the public meeting of a decant following a fire was inappropriate as a planned decant would be a very different prospect from an emergency decant. The council must consider a decant as a realistic possibility otherwise they would not have commissioned a feasibility study into decant options.
Many parents understandably fear the prospect of a decant but this could be achieved with little disruption to pupils and teachers if a full decant was done, say into temporary buildings on the Figgate park next door. An added and very important benefit would be a quicker build time and this type of decant has been successfully employed for the rebuild of other schools. Other options for a complete decant would be to use the old Holy Rood school, staggering start and finish times to avoid traffic congestion, Meadowbank House, which is standing empty at the moment or Castlebrae School, which has spare capacity. It was considered acceptable to decant children during a rebuild on site when Portobello High School was being considered as part of the PPP2 project - so why has it now become unacceptable?
In addition, Portobello High School can be rebuilt on site alongside the existing building, without a decant, like Holy Rood High. This possibility was acknowledged by the council’s consultants after one of the recent public consultation meetings. The Figgate Park (which is not on a flood plain - an inaccuracy in the consultants’ feasibility studies) or Portobello Park could provide playing fields for Option A, thereby eliminating the need for bussing. We ask you to explore thoroughly the option of a rebuild on site without a decant.
Another point which is interesting to note is that the way the cost of Option A is presented in the report makes it look as though it is much more expensive than the other options, but this is misleading because of course it includes the cost of rebuilding St John’s elsewhere.
The real cost of a rebuild of Portobello High School on site, minus decant costs, would be £42.1M, which compares very favourably with the estimated cost of option C (£41.2M).
The possibility of rebuilding both schools on site, as per the PPP2 feasibility studies, should be revisited. This was considered acceptable at the time and, had the funding been forthcoming, would be going ahead. If this had been funded under PPP2, would there have been a groundswell of opposition to it? Of course not. So why is it not now acceptable?
We support option A for St John’s but we would also like the following brownfield sites to be reconsidered for St John’s, whose school board has publicly stated that it is against a rebuild on a greenfield site:
the former Scottish Power site
the Powerleague site
the Freightliner terminal.
The reasons given in the feasibility studies for the dismissal of these sites is inconsistent, for example, PowerLeague is dismissed as too small for PHS but what about for St John’s? It also allegedly has a “fairly harsh micro climate” but that seems to be tolerable to the pupils of Towerbank Primary School. The three sites listed above are also dismissed as too small for Portobello High School but they are NOT too small for St John’s.
The Freightliner terminal is dismissed on the grounds that it is zoned for industrial use but the Park and Golf Course are zoned as “open space - sport” and they have not been dismissed. We request that you have these options properly assessed, as councillors and officers have said that we could make comment (and have those comments properly considered ) on any site option.
The indicative drawings of the school developments on the Park and Golf Course do not show any new road layouts or access, therefore the amount of space taken up by these options would by necessity be more than that shown.
We have been promised that any green space built on would be replaced but have been told that it would not be as central as the Park and Golf Course. It is disingenuous to say that the redesignation of open farm land as green parkland miles from the heart of the community replaces that which we have now. It is unclear whether the council still intends to move the Golf Course to the site it has acquired at Newcraighall. It had been acknowledged that, if moved, this facility would not be in the community and if the space is not replaced locally then there will have been a loss of green space to the community. Once the green space is built on it will be lost forever.
Planning Issues
Building on the Park and Golf Course would be against the local plan and numerous planning policies which we mentioned in detail in our submission made in the summer. In the draft Edinburgh local plan there is a presumption against the development of this green space. Portobello Park and Golf Course are designated as “open space - sport”. Does this not make a mockery of the local plan before it has even been adopted? If this designation is serious then the proposal should not even get off the starting blocks. It should be noted that, as any planning application to build housing and schools on Portobello Park and Golf Course would be contrary to the local plan and because the council would have an interest in the application, the plan would be called in to a public local inquiry by the Scottish Executive. It has been acknowledged that there is a high risk of not obtaining planning permission, so why is the council persisting with this option when several years down the line it might be refused planning permission, necessitating a return to square one for the replacement of the schools. Surely it makes more sense, for the benefit of the whole community, to pursue an option that would easily obtain planning permission.
There is a general presumption under planning guidelines against the development of green spaces, at an international, national and local level. For example, in the new draft local plan, Planning Policy Guidance NPPG11 is quoted. It states that, "local plans should include policies to protect and enhance existing open space, including public parks and playing fields and other land of recreational, amenity or wildlife value and prevent the piecemeal erosion of playing fields and pitches through a succession of small developments over a long period."
SPP1 (Scottish Planning Policy 1, The Planning System) Nov 2002 states that: "The purpose of the planning system is to ensure that development and changes in land use occur in suitable locations and are sustainable. The planning system must also provide protection from inappropriate development" It goes on to describe sustainable development as, "Promoting the use of previously developed land and minimising greenfield development. Protecting and enhancing areas for recreation and natural heritage" and further into the document: "Sustainable development promotes the right to a healthy and safe environment"
Social justice is high on the list of the planning agenda; it, In other words, the needs and wishes of the whole community, not just the educational community, should be equally and transparently taken into account when deciding where to relocate the schools.
SPP1 highlights the importance of openness and accountability in the planning process: "Planning authorities should be able to demonstrate clearly how the views of local people and local interest were heard and taken into account in policies and decisions"
NPPG11 (National Planning Policy Guidelines) SPORT, PHYSICAL RECREATION AND OPEN SPACE (Scottish Office 1996) includes parks and outdoor sports facilities as suitable open space it states: "In existing built up areas the Council seeks to improve provision and overcome shortages, subject to opportunities being available and expensive land acquisition not being involved. Priority is given to areas of need as measured against the following standards:"
1. A local park of at least 1.5 hectares in extent suitable for informal recreation within 400 m of every home; more extensive facilities, up to 6 hectares in extent, suitable for organised sport within 1200 m of every home. Illustrative Example 2 - Summary of the National Playing Fields Association minimum standard for outdoor playing space recommendations. The National Playing Fields Association recommends a minimum standard for outdoor playing space of 2.43 hectares per 1000 population. This is commonly referred to as the `NPFA 6 Acre Standard'" Will these standards be maintained, if and when Portobello Park is built on, for the 20,000 population of Portobello and surrounding area?
Other recommendations to note are:
Playing Fields & Sports Pitches: "47. There should be a presumption against redevelopment of playing fields or sports pitches, public or private".
Health and Welfare: "5. Opportunities for people to participate in sport and in a wide range of formal and informal recreation should, wherever possible, be available for everyone, including the elderly and those with disabilities for whom access to facilities is especially important." At present, many elderly people can access the Park and golf course without resorting to public or private transport.
Open Space: "34. The Government indicated in the Environment White Paper ‘This Common Inheritance’, the importance which it attaches, to the retention where appropriate, and to the creation, of recreational and amenity open space, particularly in urban areas where demand is concentrated. It is important for physical and mental health that everyone, particularly the disabled, children and the elderly, should have easy access, preferably on foot or by cycle, to public open space. The need for it depends on the type and density of urban housing. Attractive open space, whether or not there is public access to it, may also be important for its contribution to the quality of urban life. It enhances the character of residential areas, Conservation Areas, Listed Buildings and historic landscapes; it can help to attract business and tourism; it is one ingredient of urban regeneration". The Council makes much of its green credentials, of how it has "created green space", in the words of Councillor Perry (Public meeting, St, Marks church on 22 April) from agricultural fields. With the proposal to build on Portobello Park it wants to urbanise a major open green space.
And: "38. Development proposals affecting open space, especially playing fields, must therefore be considered carefully if they would be likely to adversely affect the community value of the open space. Important issues will include whether there is or would be a surplus or deficiency in open space in the area, the contribution that brownfield, contaminated or derelict land could make either to relocate the proposal or to redress the loss of open space, sports pitches or other facilities, and whether the space is to be replaced with alternative provision giving similar community benefits. The consideration should take into account the leisure or sport and recreation strategy for the area, where one has been drawn up, and the needs of future generations, for once built on open space is almost certainly lost to the community forever. In urban areas, over intensification (town cramming) can erode open space provision, especially small informal areas, while simultaneously adding to the demand."
The new draft SPP 11: Physical Activity and Open Space will replace NPPG11. The existing presumption against redevelopment of playing fields or sports pitches is broadened in the draft document to a presumption against "development on existing functional open space or space capable of being brought back in to functional use." This indicates the intention for even greater protection of our precious open spaces.
A summary of the main findings of the policy by the Scottish Executive states: "Ultimately, the long term value and quality of open space depends more on effective management and maintenance, coupled with strong community support, than the planning system. At the same time, the planning system has a vital role to play in protecting existing open spaces from development and ensuring that new developments either include appropriate open spaces or contribute to the development and enhancement of green networks - or both." How will this work with the building on Portobello Park? Will the small piece of retained undeveloped land be the open space for the new properties, if housing ends up being built there?
PAN 65 (Planning and Open Space – 2003)
This Planning advice note gives advice on the role of the planning system in protecting and enhancing existing open spaces. It states that the planning system performs key functions in relation to open space, one being "protecting areas that are valuable and valued". It states that some local authorities are implementing NPPG11: “Meanwhile, valuable spaces, particularly green spaces, continue to be lost to development through a piecemeal approach and, in some cases in pursuit of capital receipts.”
This is what could happen here in Portobello and should not be allowed to proceed. The local council, despite the fact it owns the site, should be applying all the above policies and guidelines, as any other applicant would be made to do. Indeed it has been made clear that the pursuit of a capital receipt is essential to pay for the school. Which other community in Edinburgh is forced to pay through national and local taxes for the provision of schools across the city and, on top of this, come up with their own capital receipt to pay for a school in their area?
We believe that our position is reinforced by the recent announcement that the Scottish Executive has drawn up measures to protect green spaces and civic amenities from being built on. Robin Harper, Green MSP, has said: "It is crucial for their [children’s] health that they have easy access to informal spaces for play and exercise. Ongoing audits and strategies designed to protect open spaces are essential if people are to have a decent quality of life." Portobello Park is such an informal space, which, if built on, would not be replaced by an equally central and accessible green space, as acknowledged by the council.
Council Policies
Building on the Park/Golf Course would not accord with many of the council’s own policies.
For example, the council’s Public Parks and Gardens Strategy identifies that world-class cities have world-class parks and that Edinburgh has fallen behind other cities in terms of its spend on its historic parks. It aims to halt the decline in standards of provision in parks which has fallen over the last 30 years. The strategy uses the findings of a survey to show that parks are of key importance to liveability for the vast majority of people.
The strategy recognises that Edinburgh is spending less than half the average Scottish local authority per head on its parks, and one third of the budget of the top spending council. It acknowledges the importance of empowering communities, of spending in line with the priorities of local communities and park users and states that ”it is essential that communities have the opportunity to help in the planning and redesign of new and existing local parks.”
The strategy intends to create a top quality parks system by renewing existing parks and by creating new parks in areas where provision is poor. The Council lacks a specific policy relating to the designation of public parks and currently parks are treated in planning terms no differently from other protected open space. The strategy sets out five main goals to achieve this:
Goal One: to highlight and interpret aspects of Edinburgh’s heritage located within the city’s parks
Goal Two: to conserve the natural habitat and wildlife
Goal Three: to realise parks’ potential in supporting healthy living
Goal Four: to put parks at the centre of community identity and planning
Goal Five: to improve the landscaping and visual appearance of parks
These goals are supported by a number of objectives including:
Promotion of parks and gardens as an integral part of the renaissance of the city;
Recognition of the role of parks as a positive environmental influence on noise, air quality, flooding and CO2 absorption;
Ensure that there is an equitable distribution of parks so that everyone can have access to them;
Provide a diverse range of open spaces for recreation, relaxation and enjoyment;
Provide opportunities for physical activity in parks;
Foster participation and social inclusion by providing opportunities for voluntary and community activities in the design and care of parks.
The strategy also highlights the role of parks in improving public health, "with the recognition that informal, locally based, free-of-charge facilities can make an important contribution to countering inactivity, and thus help counter the health problems that accompany it, such as obesity." In conclusion the strategy affirms the city’s need to reverse the decline in the parks resource with which it was endowed.
Alongside the Public Parks and Gardens’ Strategy sits the Council’s proposal to establish the Edinburgh Greenspace Partnership. A major objective of the Partnership will be to oversee the implementation of the strategy. This will include establishing a collective, representative voice for parks, woodlands and other green open spaces in the city.
In the Evening News of 17 March 2006, Councillor Anderson is quoted as saying: “We are pleased to be in a position to deliver the greatest investment in parks and green spaces ever achieved in the city. We are making real progress towards delivering high quality parkland for all Edinburgh residents.” Unfortunately, the proposal to build schools and probably housing on Portobello Park and Golf Course appears to fly in the face of these very commendable aims.
Traffic/Transport issues
The promotion of forms of transport other than private motor car such as by bus, cycling or walking is supported in the Council’s policies . By rebuilding on site, the majority of the community can reach both the school and the sports facilities offered on Portobello Park without the need for a motor car. Currently, many people can be seen doing so daily. Moving the golf facilities out of Portobello will mean that access will be overwhelmingly by private car and, unlike now, no-one will walk to the Golf Course or use public transport to get to it.
This point is reinforced by the council’s own Local Transport Strategy 2004-2007 which identifies that, "The Council will seek to maximise people's ability to meet their day to day needs within short distances that can easily be undertaken without the need to use a car.” The proposed development on the Park and Golf Course clearly go against this strategy as access to the ‘new’ golf course could only be achieved by car. It goes on to state that, “The city should develop and grow in a form that reduces the need to travel longer distances, especially by car. Choice should be available for all journeys within the city."
The strategy identifies the increasing use of cars as a significant problem for the city, "if traffic growth continues at the rate that it is growing at present and we continue with our transport developments as they are at the moment, forecasts show that traffic congestion will double by 2016." The proposed development will inevitably encourage a greater dependence on cars as the new golf course will be, realistically, only accessible by car resulting in an increase in traffic.
The proposals of B and C are being considered without a Traffic Impact Analysis being carried out. It is irresponsible to consider these options without the knowledge of what effect the new school(s) would have on road capacity and safety. There would be a huge increase in traffic in the vicinity of Stanley Street, Park Avenue and Milton Road, which is one of the main arterial routes into the city. This would be further compounded by the introduction of Greenways on Milton Road, leading to increased congestion and pollution in the area. If housing developments are reintroduced into the equation, the traffic congestion, with two new major housing developments as well as the new school(s) in the area, coupled with predicted doubling of congestion by 2016, will reach unmanageable proportions.
Every energy study shows that oil production has peaked and we are going to have to learn how to live with dwindling supplies, so it makes sense for facilities to be local and within walking distance. The siting of this golf course goes against this principle and will no doubt exclude people who do not have access to private transport. The Council's own policy is to discourage car use but this development in its totality will generate more traffic.
It is argued that an offset to this increased car use would be made by not needing buses to travel to sports playing fields. Whether sports fields are necessary for physical education is questionable but a well designed rebuild could provide an all weather pitch on site. And what has been so wrong with upgrading the current pitch on Portobello Park for the school’s use? If overuse of this pitch is the worry, how can community use of the proposed school pitches (in the school(s) on the park option) be promised?
In conclusion, we ask you to consider how answers to the following key areas are to be addressed. Without answers to these points, the consultation is being done in a vacuum and could be rendered redundant, especially considering the long timescale of the delivery plan.
The areas are:
1 Common Good land
2 Funding for the schools
3 Planning
4 Community participation and consultation
5 Transport issues
Finally, the decision on the sites is to be made four days before Christmas at the same time as the contentious proposal for the Tramway System. There is a danger of the schools issue being "buried" on the agenda at this time. We therefore request that the council defers consideration of this issue, which is also contentious, until the January 2007 meeting of the full council, when it can be given the full consideration and airtime it deserves. This will not affect overall timescales.
We hope you will give careful consideration to our contribution to this consultation process.
Portobello Park Action Group
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