Pump track, skate park, basketball court, cafe building, changing rooms in the woods?

You have limited time to comment. Objections on planning grounds are more likely to be heeded, but you can also question the need for this sort of development, not just where it is.

The proposal appears to be contrary to the current development plan on Natural Heritage grounds and the protection of green spaces, and seems to fly in the face of a supposed nature emergency and a new national policy framework that prioritises positive biodiversity impacts.

This proposal does nothing of the sort. And as far as the climate emergency is concerned:

This proposal says nothing about sustainability, apart from the dubious addition of solar panels.

The area has planning consent (20/00110/PM) as a quiet play area for very young children and as informal open space, with a small kickabout area. Work on this commenced, with soil mounded and signficant areas fenced off, restricting public access to this open space.  

The current consent for a football pitch, forsees an unmarked area without infrastructure, that would be contained in the wetter corner of the site away from the concrete road and away from Lochend Cottage. The current consented pitch seems to include an adequate run off or safety area, a notion which the new proposal neglects entirely.

The new proposal (which has been kicking around largely without great publicity since last summer) appears to push the pitch proposal southwards down to the road boundary, which is also wet, because the concrete road has inadequate drainage.  The access track is private and delivery vehicles regularly get stuck in the verge as there are no formal passing places. The pitch is now proposed right next to the only habitation, and only meters away from the track, with no safety buffer. Another full size professional marked pitch is proposed, without any evidence of need or demand.

The current consented development has an unimaginative so-called woodland play area, but to its credit has some modest plantings designed to screen the kickabout pitch and so-called wildflower meadow areas all around. Nota Bene: Elsewhere on the Lochend estate such recent plantings almost always fail to thrive, with 50% of saplings dying in the first year and never replaced (and although replacements are a condition of planning consent, I have never seen the condition enforced). Arguably, this area is too secluded for a playpark and too far removed from the existing housing to be of practical use. The facilities seem to be designed for the children of the lower school, which is some distance away.

The new proposal would see playpark area shrink, and most of the landscaping proposals reversed entirely, the woodland plantings, the meadow and the landscaping. The area will instead be dominated by an excessively large and intrusive facility, that by any objective standard sits incongrously in the otherwise secluded and quiet setting almost rural setting, surrounded by peaceful woods. The mounding and tree screening will be removed entirely, at additional environmental cost. Further mounding or its removal, and the proposed earthworks for skate and pump tracks (the drawings suggest 1-2m of earth will be removed and deep drainage somehow installed), will have consequences for local drainage, which is insufficiently described and locally not understood.

In perspective, there is no objective shortage of facilities for sport (in excess of 24 individual pitches and courts in Dunbar, excluding unmarked kickabout pitches) and play facilities (47). Dunbar and West Barns clearly has no shortage of sports facilities. Recent surveys for the Local Place Plan show very high levels of satisfaction with current sport and play provision and muted demand for new ones. Moreover, the present utilisation rate of existing play and sports facilities has never been measured, but any bystander would be able to see it is very low. It is questionable therefore whether any additional supply is required. If you add to the figures above, private sport facilities, gyms and golf, the areas used for sport exceeds that dedicated to nature area several times over (in the Dunbar CC area). While the principle of a new facility is not in question, the detail, sensitive location and the scale very much is questionable. The balance is wrong, as many more people enjoy quiet recreation in countryside settings than participate in sport.

This is a quiet and secluded area and a viable remnant of the old policy woodlands that were established in the grounds of the Lochend estate in the 18th C and perhaps before. The open area was more recently farmed as recetnly as 2012. Before that it was woodland (replanted in 1945 OTA) and the neighbouring western block, now planted, was open farmland. The woodland blocks have been replanted at intervals over time and would need to be managed in the very near future, which would include removing some of the more mature non native species. In the community council area of Dunbar this is possibly one of the last, perhaps the last, vaguely semi-natural open spaces close to the town centre. Everything else that is classed as open or green space is better described as recreational, in other words intensively managed, low cut and biodiversity impoverished green sward.

While the ecological interest of the open area area may be unremarkable, at an East Lothian level, it is nonetheless locally very important, in part because of the proximity and connectivity to the Dunbar Community Woodlands, a Local Wildlife Site and immediately adjacent. The area is an integral part of the whole woodland indeed mapped as woodland in the Ancient Woodland Inventory, which indicates that not only has the habitat has flourished there for centuries, but is perfectly suited for woodland expansion as one of the last remaining hotspots in the community council area. The integrity and connectivity will be diminished by fragmenting the woodland blocks, removing browsing areas and the coarse grassland habitat, which has established itself in the last 12 years, which is likely to be increasingly rich in invertebrates and reptiles and a modest soil carbon store.

Given that the local countryside is so poorly accessible locally to those without a car, this small area provides an invaluable local resource, which enhances the area’s biodiversity, is visually appealing and connects legibly to Lochend’s historical past (the rides, the listed buildings, the traditional walling, the gatepiers).

The open area is an important fragment and an integral part of the fabric of the former designed landscape of Lochend estate, and today almost entirely isolated from modern intrusions, the old concrete road and electricity wires are unobstrusive in this respect (features of most rural areas). There are to the untrained eye attractive mature woodlands in all directions, even though they are unmanaged.

An entomological, reptile and bird survey, alongside a hydrological study to examine the relationship between this area and the wet woodlands, surely should have be done. Although past drainage attempts have mostly broken down, the neglect of drainage has created an effective wetland habitat to the south which is likely tyo be an important local carbon sink / store. This could be jeopardised by an insensitive development, which inevitably will need to have an effective drainage system to operate (although it has not been specified how the drains will work in practice).

The roads and informal paths through the site more or less follow the position of the original rides and access tracks. If the proposal goes ahead, the feeling of naturalness will be lost entirely and this will no longer be an attractive or quiet short cut. It will be transformed utterly.

Given how few nature recovery options are left in Dunbar, and fewer still near where people live, surely this area should be reprioritised for nature conservation and restoration. The orginal developer’s independently commissioned report had argued it should remain as an open seminatural wild with semi managed parkland elements, a few specimen trees. Tht report also stated that this is what the community it had consulted wanted.

The development of skatepark, pump track, basket ball and formal pitch and buildings will damage the environmental and landscape setting irrevocably. The proposers have no plan to mitigate these impacts, other than a vague promise to produce of a woodland management plan, without identifying any details. The DCDHT seem to have little or no ecological or heritage management interest and have shown little inclination to support the environment over the years, leaving the woodlands to be managed by volunteers. ELC should insist that DCDHT they seek professional advice to undertake a comprehensive assessment of the environmental and social importance of the location as it is today, along with a thorough impact assessment of the proposals and a cosnideration of all the alternative locations that were assessed.

The proposal is lacking models of the visual impact, but this can easily be left to the imagination. It will be deleterious, and over time will get worse, as the Sports Centre has a record of aggressively removing all seminatural vegetation, letting the old walls fall into disrepair and then adding fences, astroturfing, advertising hoardings and by and large implementing biodiversity unfriendly prescriptions, often retrospectively. Notably, the sports facilities have very intrusive lighting schemes, which can be seen from a great distance.

Residual archaeology is likely to be present (Iron Age cists and brooches have been found nearby) and the location within the the second Dunbar Battlefield site, but again there is no mention of the potential nor the intention to evaluate it first.

The proposal could also be rejected on other grounds such as safety. It will almost certainly attract unwelcome visitors, generating additional unnecessary traffic, regardless of what the proponents argue. It is a fact that numerous cars park on the school entrance illegally (in the passing places, grass and hammerhead turning point next to the school even during minor practice matches when there is a facility at Hallhill are only a few yards away.) The proposal moreover argues that existing facilities at the School will be used (sic!), but there are none, which are publicly available. It is inconceivable that in this day and age people will not travel from far and wide to try out the new facilities, for a day out, even if they never return.

This facility has the hallmarks of a hubristic vanity project for Hallhill Sports Centre, designed by an older generation for young people that they don’t really understand (the old trope that the kids have nothing to do really doesn’t add up). At best it will be under-utilised facility and fall rapidly into decline, like so many in Dunbar. At worst it will act as a bad neighbour for the local residents (who alreay complain of fires and ASB in the woods). Thousands of current users who pass through and enjoy it just as it is, for quiet leisure, would be perfectly happy with the status quo.

From a practical point of view, there are too many problems. The bin store is 100m or so from any road. There are no lighting proposals, which in reality would be required, and which would necessitate an ecological assessment. The site is not in any sense practically designed, with all the pitches and tracks quite literally squeezed in without a buffer or prescribed audience areas. Even before high fences are installed, which will come next, this is an inadequate proposal.

The site cannot be serviced easily (power, water, drains and sewerage) and access for emergency services would be difficult. The site construction proposed via the school access road is totally impractical. It is also overly optimistic given that the narrow path winds through tall mature trees and the proposers state uniquivocally that no trees will be removed. There is no clear access or fire safety access in the context of an area that regularly suffers call outs for ASB and arson – ie. not a secure area for a facility ostensibly dedicated to young people, supervised or not.

No assessment has been made of which services (above or underground) may be affected by the development.

The current proposals are even thinner on practical details, such as the proposed operational hours, or a prediction of the number of users. It is unclear what the level of supervision is anticipated. Is it even feasible in today’s financial climate to run such a facility?

Safeguarding this community asset as a wild site should have precedence over a facility that will only be used by a very small number of interested individuals (leisure sports like skate are steady decline).

There is a nature emergency of course to take into account, which the application is also silent about.

And only when woodlands are felled to make room for native species, will the full landscape impacts of this development be clear, magnifying the negative visual impact.

Furthermore, the path is claimed to be being built by ELC, yet this is not on their prioritised list of path developments. And if ELC were to create such a path it would need to be lit, yet there are ecological grounds (insects, birds and bats) that would restrict any such proposal. Anyway the current track, although well used as a short cut, doesn’t connect coherently to the existing path network at all and is not even safe existing as it does near the school entrance. The path proposal seems to be designed at 3m, the very minimum for cyclists to pass each other, but only at very low volumes and if not shared with pedestrians. At peak times the width would be wholly inadequate. In design terms the path is at also too close to the proposed buildings, which will create a problem for the facility users and leaves little of no segregation for people who are simply passing through. It is moot whether a shared use path could be accomodated safely in such a setting, once additional allowances are made for creating the sub base and drainage.

Different mapping and plans presented in the application documents show post a wire fence, a different positions and sizes for the football pitches (which deviates from the standard 1:1.5) and other presentational errors, such as the fine lining of the main drawing, that make it difficult to critically examine the proposals. The geometrically and planimentrically correct drawings produced by Velo solutions don’t match the imprecise Blueprint drawings. If the applicant wanted it to be vague and difficult to read, they have been successful. It is a surprise that the application was even validated.

Twenty two documents are submitted in support of the application, but the most interesting ones which could inform a decision are absent:

• a feasibility study, outlining the costs and benefits of the proposals
• an options appraisal (which alternative sites and facilities were explored?)
• background and financial stability and governance of the proposing organisation/s, membership of said bodies
• an ecological and environmental impact assessment
• a hydrological survey
• an archaeological survey
• results of an independently run wider public engagement (a)
• an assessment of the development in terms of current planning policy and heritage policies and NPF4 in particular
• an assessment of how net biodiversity gain will be achieved
• a carbon impact statement

(a) political canvassing and design studies should be excluded for obvious reasons

(b) we can safely assume that by simply owning the woodlands and a management plan for the site is too imprecise and an unfunded promise of net gain – in reality the gain has already been given a financial worth of £1, in other words the woods were a costly liability for the developer

In summary, DCDHT would appear to be going against their own constitution by putting forward such a proposal for a sensitive location and should start looking now for an alternative location on their existing very extensive estate.

Planning officers should recommend the committee reject it outright.

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