20 June 2014
Objection to St James Quarter development
Transform Scotland has submitted its objection to the excessive car parking levels at the proposed St James Quarter development in Edinburgh. The development proposed trebling car parking on the site despite the location being at the centre of Edinburgh's public transport and active travel networks.
I am writing to lodge an objection to this development on behalf of Transform Scotland, the national alliance for sustainable transport.
We are objecting on the grounds that the proposal is in conflict with CEC's parking policies on Off-Street Parking as contained in the CEC Local Transport Strategy 2014-19.
By proposing a trebling of car parking on the site, the proposed development is in direct conflict with the CEC Local Transport Strategy 'Objective' to "minimise the need for car use" (LTS p.15).
Specifically, LTS Policy 'Park6' indicates that CEC will support increases in public off-street parking only where such increases are "explicitly linked to reductions in on street parking provision". We have seen no evidence that this development will lead to reductions in on street parking provision.
Policy 'Park6' also indicates that increases in public off-street parking will be supported where "there is reasonable evidence of a shortfall in parking supply". However, we understand that there is significant under-utilised capacity in the Greenside Place Car Park which is directly attached to the site of the proposed development.
Policy 'Park6' goes on to state that increases in off-street parking will be supported where "the forecast impact of any resulting increases on delays on the road network is acceptable". We have not been party to detailed modelling of the impact of the proposed development on the local road network. However, we would be genuinely amazed if it could be proved that a trebling of car parking on this site did not lead to significant negative impacts on the surrounding road network. Given the importance of the surrounding roads for the city's bus and tram network, we have serious concerns about the impact of this development on the city's public transport services. Furthermore, we would expect a trebling of car parking to be in conflict with CEC's legal responsibility for tackling the significant air quality problems in the near vicinity of the site.
In addition, we would also note and endorse the comments made by Spokes, the Lothian Cycle Campaign, regarding the lack of detail in the application regarding cycle facilities around and through the site. We would refer to their response for further details.
In conclusion, should the proposal be amended in accordance with LTS Policy 'Park6' that an equivalent volume of on-street car parking be removed as a consequence of the proposed increase in off-street parking included in the development proposal then we would be minded to support the overall proposal.
However, as it stands, the proposal runs directly counter to the stated objectives of the Council in its recently-adopted Local Transport Strategy to minimise the need and use of cars, especially in the City Centre.
I would be grateful if you would acknowledge receipt of this objection.
Yours faithfully
Colin Howden
Director, Transform Scotland