As you know, the Friends of Craighouse discovered that the Council were quietly trying to remove a nature conservation designation from large portions of the Craighouse site where the developer wants to build in the proposed new Local Plan. There was no consultation or or notes on this change – and it was extremely difficult to spot on their reduced-size map.
Thank you to everyone who wrote in to the planning department and the Councillors about this – your support is hugely appreciated and your letters have obviously made a big impact. We must push on to get this reversed.
Most of the Councillors have widely circulated a generic response saying that amenity grass and buildings are not normally covered by this designation and the site had merely been updated in line with new criteria. But there is no details of any assessment that was made, no evidence of how this decision was made, by whom or whether any sort of assessment was undertaken.
A methodology document has also been circulated. We have checked the methodology document and found it does not say that amenity grass and buildings should be taken out – in fact the methodology gives more reasons why such areas SHOULD be included on important wildlife sites like Craighouse.
Lack of Transparency and Evidence
The methodology document that has been circulated refers at length to the process for site assessment. According to this document, information should be properly publicly available through a full Local Biodiversity Site register which is supposed to show a definitive list of all sites assessed and site statements, including:
– Site summary describing the site and its interest
– Site map showing the boundary
– Date of assessment
– Assessment notes (these include decision on boundaries)
– Previous status relating to site
– List of notable biodiversity features
We can find no evidence of any of this in the public domain. We have asked for this information to be made properly available to the public but have so far received nothing.
The Great “Amenity Grass” debate
The Council is trying to maintain that “amenity grass” is not included in Biodiversity designation. It seems to have defined all the green areas at Craighouse that aren’t the LNR – including the entire orchard/lawn areas and other areas of green space – as “amenity grass” and are trying to justify their removal that way.
However, this is contrary to the evidence of biodiversity value contained in all the publicly available audits and reports which show these areas are extensively used by a wide variety of wildlife, including Red List birds and protected species such as bats.
This should have been clear to the Council if they had undertaken the proper assessment procedure as outlined above.
Not only this, but we have studied other sites in the city and discovered that Craighouse has been treated inconsistently with other designated sites.
Inconsistent with Treatment of Other Sites across the City
Let’s look at some other sites.
The Observatory buildings and carpark on Blackford Hill are covered by the designation. The whole of the Old Town is covered in the designation. The “amenity grass” at Lochend Park is covered by the designation. The “amenity grass” and tennis courts of Regents Gardens (a less important wildlife site than Craighouse) are covered by the designation. The large modern building at the entrance to the Botanical Gardens apparently has a Biodiversity site designation. And – most bizarrely – a large chunk of Waverley Station is also covered by the designation.
Tennis courts, modern buildings and carparks are covered by this designation on other sites all across the city – yet not the orchard, parkland and green spaces of Craighouse despite being an important wildlife site and those areas having been proved to be used by protected species!
Indeed, the majority of these green areas at Craighouse have actually been carefully and quietly removed from this important nature designation when they were previously protected.
No one can tell us how or why this was done.
Who decided to de-designate the site and what input did the Craighouse Partnership have?
Craighouse is important to wildlife because it contains a “mosaic of habitats” that are “exceptional within the city environment according to the Conservation Area Character Appraisal.
Woodland, open parkland, water (at nearby Craiglockhart pond) and old buildings provides the perfect habitat for protected species like bats for example. And the orchard/lawn are known feeding grounds for these European protected species. (We will go into more detail on this subject in our next article.)
You cannot just protect where an animal feeds but destroy where it sleeps, or vice versa. And you cannot cut the habitats off from one another -which is why Local Biodiversity Sites are usually designated in full. At Craighouse there is a wealth of established habitats linked together which is why it is so important for wildlife. There is no justification for the removal of the parkland as “amenity grass” – indeed the parkland, including orchard, is specifically mentioned in reports and audits as an area where not just bats, but birds feed – including Red Listed birds who like to feed on the fruit trees, such as the Fieldfare and Redwing.
Serious Questions to be Answered
We would like to know why this decision appears to fly in the face of all the evidence contained in the publicly available Biodiversity Audits and Reports.
Where is the assessment and evidence of any process followed to come to this decision and how and why was such an unjustifiable decision made on such an important site?
We would like to know what input the Craighouse Partnership may have had into this decision. And we want answers as to why a Biodiversity designation seems to have been carefully removed from large areas in the proposed New Local Plan from a site that is the subject of one of the most controversial development applications in Edinburgh’s history – when there is no evidence that the site has changed in terms of its very special wildlife value and when it is described as an important mosaic of habitats “exceptional within the city environment”. (Conservation Area Character Appraisal).
The Council has some serious questions to answer. We look forward to hearing their response.