“George Street – First New Town” Proposals

Posted on: March 26, 2021

Our comments on the latest proposals for the future of George Street

Our comments on the latest proposals for the future of George Street

Cockburn Response

The Cockburn has been involved in this project since the outset and has seen the designs evolve and mature.

The Experimental TRO conducted several years ago showed an appetite for change to George Street and its shift from a trafficked street to a destination for civic living.  Key was increased pedestrian space, facilitating the east-west cycle route and generally producing a more amenable place whilst respecting and enhancing the qualities and characteristics of the World Heritage Site.  We endorse all of these objectives and feel that the designs have generally reflected these well.

In addition, we offer these specific comments:

  • Materials need to reflect the recognised palette of stone used throughout the New Town and as articulated in the Street Design Guide.
  • The desire to add the small sections of planters with seating etc should not come at the price of reducing circulation space.  In addition, careful management of street licenses to hospitality venues needs to be put in place with effective and clear guidance so that, again, pedestrian space is not lost.
  • A clear events strategy must be developed and enforced to ensure clarity of use.
  • It is essential that a long-term maintenance strategy is put in place for the street and especially the planters, with dedicated financial resources to ensure a rigorous cleaning and planting regime.

On the subject of trees, we acknowledge the significant public interest in introducing trees into the street.  Indeed, we also acknowledge that throughout the history of the Association, we have been long-standing advocates for street trees, having campaigned for them in the late 18th and early 19th centuries.

Since this time, our understanding of the significance of George Street as one of the centrepieces of the World Heritage Site, inscribed in 1995, has grown hugely.  George Street was not designed as a boulevard but as a set-piece along a strong axis from Charlotte Square to St Andrew’s Square, with the intervisibility of each crucial to its urban form.  The current proposals have evolved to respect this key feature, which we welcome. If trees were to be introduced, it is important that this key element of the street is not undermined.

There are also challenging design issues including a substantial amount of undersurface voids including cellars and service tunnels, which not only introduce planting and technical hurdles but also legal and ownership ones too.  These would need to be fully explored and considered, with additional consultative programmes put in place if it were to advance.

Similarly, not all trees are equal.  There is a very real difference between ornamental species versus “forest” species are considerable, and clarity of thought in this is required.  If underground planting is not possible, and large plant pots required, this would limit the scale of trees possible, which would also limit carbon, biodiversity and other benefits accordingly.  Finally, and as already noted, a long-term management and maintenance regime specific to this street would be required.

Portobello Beach Sauna

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Our comments on proposals to introduce a sauna on Portobello Prom

Our comments on proposals to introduce a sauna on Portobello Prom

Cockburn Response

The Cockburn Association has had the proposed license application for a mobile sauna unit brought to its attention by local civic bodies. Whilst we do not usually comment on licensing applications, this proposal brings forward several issues of amenity and precedent.

Firstly, the location of the proposed mobile sauna unit is at a heavily used, and congested, part of the Portobello Promenade.  Although the hard-standing suggests a suitable area for such a facility, it is in direct conflict with the need for space for people.  It would effectively privatise this small area of public space, which would be larger than the mere footprint of the structure with space for queuing, power, etc.  For this reason alone, it would not be suitable to grant a license for this facility.

Secondly, the proposed use of wood-burning heaters could cause considerable local air pollution.  Other fuel forms might also cause amenity impacts.

Thirdly, placing temporary facilities in this location would create a precedent that would make it harder for the licensing authority to refuse other applications.

For these reasons, the Cockburn feels that this is unsuitable and that the licensing application should NOT be granted.

That said, we appreciate the intention behind the operator of the mobile sauna is to support an increased interest in “wild swimming”, which has become more popular over the past decade or so.  We can understand the merit of the proposal in supporting increased access to the water and the benefits of wild swimming.  Whilst the nearby Portobello Baths provides some support facilities relevant to this interest, they may not be ideally placed for wild swimmers.

This requires a much more strategic approach than this opportunistic application provides. Enhanced beachside facilities would perhaps increase the enjoyment and experience if well-managed and deployed sensitively.

Indeed, there might be other areas along the coastline which could also benefit from such enhancements.  The City Council or its arm’s length organisation Edinburgh Leisure are well-placed to develop a strategic framework to carry this forward.

 

Council Decision: We were contacted by the Council Licensing Dept on 19th May 2021 to inform us that the application had been refused in terms of Paragraph 5(3)(c)(i) of Schedule 1 of the Civic Government (Scotland) Act 1982).

This part of the Act specifies:

Where the licence applied for relates to an activity consisting of or including the use of premises or a vehicle or vessel, those premises are not or, as the case may be, that vehicle or vessel is not suitable or convenient for the conduct of the activity having regard to—

  1. the location, character or condition of the premises or the character or condition of the vehicle or vessel;
  2. the nature and extent of the proposed activity;
  3. the kind of persons likely to be in the premises, vehicle or vessel;
  4. the possibility of undue public nuisance; or
  5. public order or public safety;

 

Phoebe Anna Traquair Murals

Posted on: February 24, 2021

Planning application regarding Phoebe Anna Traquair murals in Sciennes, Edinburgh

Planning application regarding Phoebe Anna Traquair murals in Sciennes, Edinburgh

Cockburn Response

This application will be of concern to anyone with an interest in the artistic heritage of Edinburgh and Scotland. Having carefully reviewed it, the Cockburn Association intends to OBJECT.

Our objection relates to the conditions attached to the original planning permission granted for the redevelopment of the Sick Children’s Hospital site at Sciennes. This was subject to a specific condition that there should be care and protection of the mortuary chapel murals and long-term access by the public.

This new application only ensures the short-term protection of the building and murals and does not ensure the restoration of the murals, nor the long-term management of the building in which they are located nor arrangements for public access.

We believe that there are no current circumstances which would justify the request for the discharge of condition 8 of the original planning permission. This must not be allowed until the restoration of the murals and their future security is assured and arrangement for public access put in place.

Phoebe Anna Traquair was an Edinburgh-based artist who achieved worldwide recognition for her key role in the Arts and Crafts movement in Scotland, as an illustrator, painter and embroiderer. The first woman ever elected to the Royal Scottish Academy, Traquair is justifiably regarded by many experts as the first significant professional female artist of modern Scotland. Her mural painting for The Royal Hospital for Sick Children are among her most famous works.

It is imperative that these murals are saved for Edinburgh and for the Scottish Nation. We welcome the recent intervention made by Sir John Leighton, Director-General of the the National Galleries of Scotland, that re-emphasises the significance of the murals and we therefore call on the planning authority, the City of Edinburgh Council, to take action and enforce Condition 8 of the original planning condition.

You can view the application and post your own official comments at the link below (search for application number: 21/00331/LBC). Closing date: Fri 26 Feb 2021.

New Town North Application

Posted on: February 18, 2021

Location: 34 Fettes Row Planning Application No: 20/03034/FUL Summary: Development comprising demolition of existing buildings and erection of mixed-use development comprising residential, hotel, office and other commercial uses, with associated landscaping / public realm, car parking and access arrangements.

Location: 34 Fettes Row Planning Application No: 20/03034/FUL Summary: Development comprising demolition of existing buildings and erection of mixed-use development comprising residential, hotel, office and other commercial uses, with associated landscaping / public realm, car parking and access arrangements.

Cockburn Response

Following regular, open and constructive engagement with the developers and their professional team, since the project inception to application stage, the Cockburn Association has opted to support this application.

The following represents our views developed as the scheme itself has developed through several iterations.

Overall development concept

First of all, we accept that this is a major development opportunity in the city. We recollect the previous scheme prepared by the Royal Bank of Scotland directly (Michael Laird Partnership) which in its first iteration was overly massive and insensitive to this important site on the northern edge of the World Heritage Site. In our view, it is essential that the opportunity is grasped to prepare a scheme which, in a contemporary and relevant manner, “completes” this north edge and provides a more suitable urban design link into adjoining neighbours such as Stockbridge and Canonmills.

In general, the Cockburn believes that the development team has responded well to this challenge, and has prepared a scheme that has great potential in helping to knit together the various environs, including George V Park.

We note that consideration is being given to the replacement of the hotel, originally proposed as part of this scheme, with further residential accommodation. The Edinburgh Hotel Association reported an oversupply of hotel spaces in March this year, and impact of Covid-19 has created significant uncertainty in the market. We would have no issues with this amendment, and indeed would support it fully.

Scale and Massing

There are two main components to this scheme:

The first are the buildings fronting Fettes Row and Dundas Street. We support the creation of a hard urban edge along Dundas Street; although it was not originally feued as part of the development of the neo-classical city as it spread northwards, establishing a strong urban edge here is appropriate. Turning the corner at Fettes Row is also an appropriate objective of development here and the proposal as last seen by us does this well. We are also very pleased with the direct link created to George V Park.

The second element is the new buildings north of Royal Circus. From the outset these have been a focus of discussion. The overall the scale has reduced, helping mitigate against the visual impact of the views looking down Dundonald Street. Two issues arise – the need to allow the architecture of these buildings to have their own presence and not be diminished to such degree as to not read as part of the urban ensemble. Secondly, the challenges in articulating what areas are public and what is private in a meaningful, clear manner. In both accounts, we feel that the design team has successfully achieved the right balance.

A point of continued discussion, however, is the physical link on the Dundonald axis into the site – specifically, if it should be public or private. We appreciate the desire to have this as a private connection for the flats to be erected here. However, we also believe that an increase in connectivity to George IV Park and the various path networks is highly desirable. That said, the approach taken to address this complex space with its significant height changes and relationships to the emerging proposals is highly creative and potentially very exciting. The interface between the garden spaces and the car parking, however, would benefit from further refinement.

Connectivity, Trees and Landscaping

The Cockburn believes that it is essential for the existing tree cover along Fettes Row to be retained and maintained. We appreciate that this is the intention and welcome it. A detailed landscape methodology should be prepared as part of the consenting process. The loss of trees along Dundas Street was not considered in discussions but we are aware that there is local concern about this. We could see some benefit for a replacement strategy here.

As noted elsewhere in these comments, the enhancement of the pedestrian network and increased connections to George V Park are key requirements in our view. The proposals have met this objective so far. We are particularly supportive of the new link to Dundas Street from the park. The link through the crescent blocks to Dundonald Street/Royal Crescent is more challenging as already noted.

Elevational Treatment and Materiality

From our discussions, it is very clear that the design team has invested considerable energy into the analysis and development of an architectural language for this site which is informed by the surrounding neo-classical buildings on Fettes Row and Royal Crescent but interpreted in a contemporary form. We appreciate that further development of the architecture is underway but we have been impressed with the careful and thoughtful approach, and support the outcome as seen so far.

END

Public Space Management Plan – Pre-consultation Exercise

Posted on: January 20, 2021

The Cockburn Association welcomes the development of a Public Spaces Management Plan, seeking to amalgamate and improve existing policies, plans and guidelines into a single unified document and process. However, we note that the Public Space Management Plan offers no strategic insight or assistance with the controversial issue of the commodification of open space.  Instead, it proposes a set of …

The Cockburn Association welcomes the development of a Public Spaces Management Plan, seeking to amalgamate and improve existing policies, plans and guidelines into a single unified document and process. However, we note that the Public Space Management Plan offers no strategic insight or assistance with the controversial issue of the commodification of open space.  Instead, it proposes a set of …

Cockburn Response

A precis of the issues

It is generally accepted that this is not a management plan for public spaces per se, but an operational guide for the management of events (including filming) in a limited number of Council-controlled public spaces.

This is evidenced by the objective of the plan, which will “set out how we can manage public open spaces (parks, greenspace, roads, plazas, squares under City of Edinburgh Council control) for events, filming and festivals”.  The PSMP continues to assume that the commodification of open space is an acceptable public objective.

The starting point for plan should be a “first principles” review and consideration of the scale and nature of the use of public spaces.  Many if not most events and activities are relatively modest and limited in their impact. An analysis of existing activity would be very useful in preparing the PSMP.

We accept that activities in public spaces can be positive and indeed desirable.  They can contribute to interest and vitality and can support local communities.  They can also be divisive, exclusive/restrictive and anti-community as well introduce disruptive and intrusive activities in places most appreciate for peace and tranquillity. It is this paradigm that the development of the plan should concentrate, and a criteria-based approach developed.  At the moment, it is left to the event organiser to determine how the event is to be delivered.  Whilst this might seem logical from an events management perspective, from a civic perspective, the Council should set criteria to which the operator must adhere to.  For example, a default position against the use of amplified music would mean that any event which wishes it, must justify the need against set criteria (e.g. impact on residents) and outline management and mitigation measures before consent is considered.  Similarly, the closure of streets for filming should be an unreasonable disruption and justification would need to put forward.

The current processes exclude civic engagement.  This should change.  Of course, very small activities over short periods of time could be exempt but some form of public signposting is needed much in the same way as a planning application.

The information that is required to be submitted for event approvals at the moment is very light.  The Cockburn Association has participated in a consultation forum for events in key public spaces such as Calton Hill and has seen just how poor the level of information required to gain consent is.  This Plan provides a very positive opportunity to address this, and we would advocate the creation of a task group to help define what types and levels of information should be required.

Future imperatives

The current premium on open space as a result of Covid-19 isn’t reflected in this paper.  Covid has helped society understand and appreciate the value of open spaces, providing places for well-being activities. Whilst we might question to the implementation of schemes such as Streets for People, the sentiment encouraging greater civic use of streets is a fair one and reflects a changing attitude to civic space and civic amenity.  Commodifying open space is counter to this and the Plan should reflect this.

Various consultation surveys show that the most valued attributes of parks and gardens are their tranquil and green nature (West Princes Street Gardens, for example).  These qualities can be shared and experienced by all visitors, whether residents, workers or tourists.  The default position for the PSMP must be the retention of these qualities.  Commercial events with an element of exclusive ticketing or branding should be avoided or kept to a minimum.  The Summer Session concerts illustrated the conflict between open space as a performance arena and open space as a civic amenity, especially for commercial ventures that require a high degree of exclusivity.  Hoardings, crowd-control gates and threats of street closures to management public safety are all illustrations of the unsuitability of such activities in public parks.

A paper considered by the Policy and Sustainability Committee on 10 January 2021on filming noted that this activity generated less than £250,000 for the city although it highlighted the brand and marketing value. The benefit of allowing public spaces to be used for private ventures should be required to demonstrate a direct benefit to the City. At the moment, there is little in the way of meaningful consultation with residents and civic groups on the impacts of street closures, etc, only noting that local businesses impact may be able to negotiate compensation from filming companies.

This suggests an Activity for Activity’s sake ideology behind the initiative.  A more strategic approach considering the carry capacity of places to absorb events and activities is needed, where civic and amenity requirements are equal to tourist and cultural economic activities.

Need for overarching Strategy

In agreeing with the need for effective operational management of events, there is a need for a more strategic management plan for the wider use of streets and other public spaces and going well-beyond event management.   The impact on public spaces due to construction and development activities can bring significant issues including pedestrian disruption, noise, etc.

It is the nature of many spaces that they are unable to take significant pressures of major events.  The damage to East Princes Street Gardens caused by successive Winter Festivals/Christmas Markets highlights all too well the issue.  In 2019, for the 6 weeks operation of the enhanced market with its large space deck, the gardens were closed for a total of 6 months (including set-up, take down and landscape repair/recovery time). Thus, a civic asset was unavailable for public use as a result of a commercial venture for a significant period of time.  This cannot be acceptable.

A Public Spaces Management Strategy should also include other issues affecting public space, such as street closures facilitating construction work, etc.  These need not be managed through any central department but the criteria for use of civic assets should be set out in a coherent manner.  This should also include spaces not under the control of the City Council but also those under institutional or private management.

Pseudo-public space

Pseudo-public spaces – large squares, parks and thoroughfares that appear to be public but are owned and controlled by developers or private interests are a feature of Edinburgh.  The criteria used for assessing suitability for events or other activities should be applied these spaces as well.  Although they are seemingly accessible to members of the public and have the look and feel of public land, these sites – also known as privately owned public spaces or “Pops” – are not subject to ordinary local authority bylaws but rather governed by restrictions drawn up the landowner and usually enforced by private security companies.  For example, Bristo Square and George Square are owned by the University and host large scale events but would not be covered by the PSMP despite the potential impacts and the perceived civic nature of the space.

Other examples of Pops would be the various New Town gardens.  Charlotte Square has become synonymous with the Book Festival, but its management sits outside the PSMP as it is a private space.  Concern has been expressed over many years about the physical state of the land post the festival, which has visual amenity impact borne by many. As such, its regulation through the PSMP would be beneficial to the city.

Such spaces need to be included in the PSMP because their use as event spaces can have significant impact on public amenity.

Overlap with other consenting regimes

Following on from this point, it is important that the PSMP articulates the wider consenting regime.  The scandal of the space deck being erected in East Princes Street gardens without planning consent illustrates this issue perfectly.  The Cockburn has undertaken a very quick review of other open spaces and has found that major events have operated without planning consent, or so it seems.

Common Goods Land

In 1491, the Scots parliament passed the Common Good Act affirming that the land and property of Scotland’s royal burghs “be obseruit and kepit to the commoune gude of the toune and to be spendit in commoune And necessare thingis of the burgh. From that year until the Burgh Reform Act of 1833, the landowners and the commercial bourgeois class controlled all burghal administration of the common lands and controlled it in such a way that vast areas of common lands were quietly appropriated.

Much of Edinburgh’s public space is Common Good Land.  It is held for the benefit of citizens.  As such, a separate vehicle for oversight should be required as part of the management process.  This might be built into the PSMP and should require special attention to the played.

Summary and Some Cockburn suggestions

The following represents some ideas and thoughts which we feel should be considered as part of this exercise:

  • All events, in all public spaces including streets should be covered by any emerging plan;
  • The remit of the PSMP should include all public spaces, and not be limited CEC owned and/or controlled spaces is too limiting and not acceptable;
  • Common Good Land is not CEC property – this requires a separate process for management and event approval and management;
  • Commercially exclusive events which require restriction of public access for even relatively short period of time should be discouraged;
  • For major events that require ticketing, the assumption should be that most tickets should be free to users, allowing a small percentage of sold tickets for VIP and commercial reasons. As in New York City, the assumption should be use of a public space is for public benefit and enjoyment;
  • Community events and major commercial events require different and bespoke registration and management processes and fee structures;
  • The acceptability of holding major events in public spaces at times of year when access to public spaces are in high demand for informal recreation, rest and well-being should be heavily restricted;
  • The PSMP must have city-wide and community-wide climate mitigation, climate adaptation, biodiversity, tree expansion and sustainability issues at its heart. ISO20121 should be the minimum standard required.
  • Future events in public spaces should be required to clearly express how they will add to or detract from the quality of life in the city as a whole and their host residential communities.
  • All collateral impacts of events in public spaces e.g. noise, pollution, policing costs must be identified, and mitigation frameworks brought forward and incorporated into events approval and management processes. The cost of meeting these and remedying any impact must fall wholly to the event and not the public purse.

The Cockburn Association would be delighted to assist in the development of this ideas and the furtherance of effective management policies for the city’s public and quasi-public open spaces.

Choices for City Plan 2030 – Consultation Response

Posted on: April 20, 2020

As Edinburgh City Council prepares its new Local Development Plan for Edinburgh, called the City Plan 2030, local community groups, organisations and residents have been asked for their input in a consultation called “Choices for City Plan 2030.” After extensive consultation with our members, individuals and affiliates, and members of the Edinburgh Civic Forum, this post contains the Cockburn Association’s …

As Edinburgh City Council prepares its new Local Development Plan for Edinburgh, called the City Plan 2030, local community groups, organisations and residents have been asked for their input in a consultation called “Choices for City Plan 2030.” After extensive consultation with our members, individuals and affiliates, and members of the Edinburgh Civic Forum, this post contains the Cockburn Association’s …

Cockburn Response

General summary of comments

The Cockburn is broadly supportive of the draft policies being proposed in the ‘Choices for City Plan 2030’ document. However, it appears to us that many of the new policies, as proposed, are already within the scope of the city’s existing planning policy and have been the subject of discussion within the land use planning community for many years.

In addition, although many of the new policies being proposed are commendable in themselves, we have significant reservation regarding their deliverability in any meaningful or significant way.  It this context, it would be helpful and appropriate for the City of Edinburgh Council to provide an assessment of the effectiveness of the policies contained within the previous local plan.  Which policies were effective?  Which where not effective? What was this so?  How is this directly addressed by the policy framework now being proposed?

We have reservations about the robustness of the proposals over the extended plan period of up to 10 years,  Whilst this is an outcome of the recent legislative changes, the rapid change of modern society from technological innovations to amending trading patterns suggests that many of the assumptions built into the plan and related plans (such as the City Mobility Plan) will be unfounded in years to come.  For example, the clinical changes to healthcare provision which has driven the consolidation of infrastructure onto major new “campuses” in the past, might revert to the need for more locally-based provision. This would require a potentially significant amended to land-use allocations in existing urban areas to provide sites.

Much of the Plan’s quantitative growth projections are based on projections and extrapolations of data.  It is regrettable that the timing of this document hasn’t allowed for the 2021 Census data to be used.  The implications of Brexit and outward migration of seasonal workers could have a significant impact on housing projections as could any variance to the Higher Education and the need to provide for further student accommodation.  We would therefore advocate that, as a Choice for the City, the Council indicates that it will review the plan in the next few years if emerging data from the census challenges the assumptions built into this plan.

Finally, there is an inbuilt inconsistency in a local development plan predicated on, to a greater or lesser degree, quantitative growth projections and the declared Climate Emergency and the stated political ambition to be carbon neutral by 2030.  A “No Growth” option should be included in this Choices Report to enable a coherent and structured discussion on the major challenges facing the City.  Pretending that this dichotomy doesn’t exist is not a way forward.

 

Specific Comments on Consultation Questions

Choice 1 – Making Edinburgh a sustainable, active and connected city

We support the following proposed changes:

A         We want to create a new policy which will help connect our places, parks and greenspaces together as part of a         multi-functional, local, city-wide, regional, and national green network

B        We want all development (including change of use) to include green and blue infrastructure. Where appropriate this should include trees, living roofs, and nature-based drainage solutions including, ponds, swales, rain gardens and ecosystem services as well as making best use of natural features in the surrounding environment

E        We want to introduce a new ‘extra-large green space standard’ which recognises the need for new communities to have access to green spaces more than 5 hectares, as well as smaller greenspaces. A 5-hectare green space is the equivalent of The Meadows or Saughton Park. At present our policies require new development areas to provide a park of 2 hectares. We want to increase this requirement.

Additional Comment:

We believe that if Edinburgh is to remain an attractive and “liveable” city it is essential that suitable and attractive greenspaces, accessible and well-managed open spaces and green-blue infrastructure are provided for its residents. Such spaces and places are an ever more important component of a positive urban land use policy that enhances biodiversity, boosts public health, creates opportunities to enrich and build communities, assists with adaptation to a changing local climate and provides economic development openings.  Well-connected and appropriately managed urban green and blue spaces are an essential part of making cities work for residents.

This needs to take into account the characteristics of existing places.  Provision for the care and maintenance of what already exists is essential and adding to the list of areas to be managed by an overstretched municipal authority might have unforeseen consequences.  Therefore, a review on the how and what of section 75 planning agreements is necessary and should consider the possibility of long-term maintenance issues.

Choice 2 – Improving the quality and density of development

We support the following proposed changes:

B        We want to revise our policies on density. This is to ensure that we make best use of the limited space in our city and that sites are not under-developed.

  • Across the city, on both urban area and greenfield sites, housing development must achieve a minimum of 65 dwellings per hectare.
  • Where identified in the plan, higher density housing development with a minimum of 100 dwellings per hectare will be required.
  • A vertical mix of uses to support the efficient use of land.

Additional Comment:

Many parts of Edinburgh are already a ‘vertical’ city dominated by traditional tenement dwellings. We believe that densification is acceptable over other parts of the city and we support the development of brownfield sites, in preference to using greenbelt/greenfield land, but only if it is accompanied by an expansion of associated high quality, well-managed and accessible urban greenspace provision. Part of this process should encompass a vertical aggregation of uses as well as a horizontal one.  A prime feature of historic parts of the city is the mix of ground floor retail/commercial use and residential above. Whilst we accept that the traditional pattern might not apply universally (it will in many circumstances) a greater range of uses might be permitted including home-work facilities, small scale industrial/warehousing/manufacturing, etc.

In addition, a re-assessment of current housing quality standards, including space standards, in urgently required to avoid urban residential densification exacerbating the ‘cramped’ living conditions which are so typical of contemporary housing developments across the city.

The number of Edinburgh properties advertised as short term lets has grown tremendously in recent years as have associated concerns that a lack of regulation has exacerbated the housing crisis in the city and threatened the social cohesion of some traditionally residential areas. Achieving a balance in the provision of short-term retails for transient visitors and retails for permanent residents and works is essential.

Choice 3 – Delivering carbon neutral buildings

We do not support the following proposed change:

A        We want to require all buildings and conversions to meet the zero carbon / platinum standards as set out in the current Scottish Building Regulations. We will continue to require at least 50% of the carbon reduction target to be met through low and zero-carbon generating technologies

Additional Comment:

Energy use in buildings in Edinburgh accounts for a significant proportion of all citywide carbon emissions and energy use.  Therefore, minimising the carbon emissions associated with new buildings and conversions, maximising energy efficiency and using renewable energy presents a substantial opportunity to work towards the city’s 2030 carbon reduction target.

However, the proposed change needs to clearly refer to new buildings and to recognise that there may be limitations to the extent to which existing historical fabric can accommodate new energy efficiency interventions without detracting from or damaging existing historical or cultural interest. The term “platinum” standard requires further clarification.

Embodied energy and carbon, the energy used, and carbon emitted in the past: the ‘sunk’ embodied energy and carbon associated with existing buildings is important and should be acknowledged. Replacing a building has significant energy, carbon and cost implications.  The retention of existing building stock is preferable when energy and carbon performance can be improved to reasonable level, in context and with sensitivity with building conservation and sustainability.

 

Choice 4 – Creating Place Briefs and supporting the use of Local Place Plans in our communities

We support the following proposed changes:

A        We want to work with local communities to prepare Place Briefs for areas and sites within City Plan 2030 highlighting the key elements of design, layout, open space, biodiversity net gain and community infrastructure development should deliver

Additional Comment:

We are supportive of Place Plans. However, clarity is required is required on where Place Briefs sit in the hierarchy of strategies, plans and policies. Which have pre-eminence?  In addition, for the meaningful and inclusive delivery of Place Plans considerable support will be required at community level if residents are to play an equal part in the preparation of Place Plans alongside stakeholders from professional communities of interest.

The Plan identifies several areas for the preparation of place briefs, mainly around the proposed sites for new developments.  We recognise the resource and inputs required for the preparation of these plans. We believe, however, there are a number of other communities under pressure, especially in and around the city centre, where place briefs could be a useful tool to engage local communities, manage local pressures and bring an end to excessive commercial development which displaces local populations.

We believe that if the preparation of Place Briefs and support for Place Plans are to have any real relevance or utility within communities of place and communities of interest across the city then existing community engagement processes and activities with community-controlled organisations must be significantly strengthened, fully resourced and professionally supported.  The challenges to the successful delivery of this policy can be overcome.  It may be appropriate to run a number of pilots across the city to establish models of good practice to be rolled out across the city as a whole.

The City of Edinburgh Council and other public bodies must find ways to open up consultation processes and activities to a much wider and fully more representative community-based audience both in general terms and, in particular, when preparing Place Briefs or undertaking place planning activities across the city.

 

Choice 5 – Delivering community infrastructure

We support the following proposed changes:

A        We want City Plan 2030 to direct development to where there is existing infrastructure capacity, including education, healthcare and sustainable transport, or where potential new infrastructure will be accommodated (deliverable within the plan period), encouraging improvements and investment in the services on offer.

Additional Comment:

Successfully delivering community infrastructure needs to be understood within the wider agenda of community wellbeing which can be defined as the “ combination of social, economic, environmental, cultural, and political conditions identified by individuals and their communities as essential for them to flourish and fulfil their potential.

If this policy is to be effective, then it must be taken forward on a starting point of a comprehensive evidence base of the actual, rather than perceived, infrastructure capacity across different communities of the city, which must include the key attributes of connectedness, liveability and equity. This will need to be developed in a co-ordinated way with all council stakeholders. And it should certainly start with a comprehensive understanding   of the infrastructural needs and expectations of established residential communities across the city and an assessment of if and how these needs and expectations are currently being met to an acceptable standard through existing public sector and other infrastructural providers. This will give an insight into what is important to residents in a local community. From the quality of education, housing affordability, and public transport – to the amount of green space and the number of community centres in an area.

Before any further development is directed to existing residential areas there must be community-wide agreement on what needs to be achieved within local communities to meet existing local needs, support existing businesses, promote social cohesion and sustain local accessible greenspace before further development is allocated.  When further development is allocated, this must only be done if coupled with a programme of infrastructural expansion and support to address rather than aggravate any existing infrastructure and services deficits that have been identified.

 

Choice 6 – Creating places for people, not cars

We support the following proposed changes:

A        We want to create a new policy that assesses development against its ability to meet our targets for public transport usage and walking and cycling. These targets will vary according to the current or planned public transport services and high-quality active travel routes.

B        We want to use Place Briefs to set the targets for trips by walking, cycling and public transport based on current and planned transit interventions. This will determine appropriate parking levels to support high use of public transport.

Additional Comment:

We fully support the ambition of the council and its partners to promote the use of public transport and active travel modes. Promoting the use of cycling and walking are particularly important. Not only are they the least carbon intensive transport modes they can contribute to the alleviation of Edinburgh’s significant traffic congestion and car parking demand. In addition, both can also contribute towards community health and fitness.

However, there is a large segment of the population that does not at present have convenient access to public transport.  Greater priority will need to be given to developing routes that serve the whole population, and to the frequency of services throughout the day if public transport is to be an attractive option for people and to enable a significant modal shift. It will require significant policy innovation and expenditure to achieve this,

Also, it is important to acknowledge and make provision for those members of the Edinburgh community, both residents and commuters, who for a variety entirely

legitimate and entirely unavoidable reasons cannot access public transport and active travel modes.  The implementation of this policy must not penalise or discriminate against those community members.

 

Choice 7 – Supporting the reduction in car use in Edinburgh

We support the following proposed changes:

A        We want to determine parking levels in development based on targets for trips by walking, cycling and public transport. These targets could be set by area, development type, or both and will be supported by other measures to control on-street parking.

B        We want to protect against the development of additional car parking in the city centre to support the delivery of the Council’s city centre transformation programme.

C        We want to update our parking policies to control demand and to support parking for bikes, those with disabilities and electric vehicles via charging infrastructure.

D        We want to support the city’s park and ride infrastructure by safeguarding sites for new park and ride at Gilmerton Road and Lasswade Road and extensions to the current sites at Hermiston and Newcraighall. There is also the potential to safeguard an extension to the park and ride at Ingliston as part of the International Business Gateway masterplan. Policies on Park and Rides will be amended to reference these sites and any other sites that are identified in the City Mobility Plan or its action plan.

Additional Comment:

We broadly support the council’s ambition to reduce car use within the city.  This is entirely consistent with the similar action being taken by other major cities across the world who are seeking to prioritise walkable urban development and public transport over car use. However, we do note that Edinburgh has a very high active travel level already, and we need to recognise that the greater impact comes from travel from outside the built-up city rather than within it.

We note that the intention is to address the legitimate needs of car users who require access to a car.  This is a positive move. In addition, the needs of permanent city centre residents must also be protected. The design and management of parking supply could, if it does not address the needs of city centre residents, negatively impacts on the liveability of the city centre for those residents who require regular access to a car and to an affordable car parking space.

We are concerned that building additional parking, for example additional park and ride spaces on the outskirts of the city or elsewhere in the city region, without managing the existing demand for car based commuting could encourage driving, increase the demand for even more parking in the longer term and do little to reduce the environmental and carbon dis-benefits associated with car based travel in general terms.

Where parking space are being lost from the city centre this should, if appropriate, be a local environmental improvement opportunity.   The development of, for example, “pocket parks” in such locations may make a positive contribution towards adapting the city centre and other build-up areas of the city to the anticipated challenges of a changing local climate.

One of Edinburgh’s most pressing challenges for parking will be to find the right balance between supply and demand.

 

Choice 8 – Delivering new walking and cycle routes

We support the following proposed changes:

A        We want to update our policy on the Cycle and Footpath Network to provide criteria for identifying new routes.

B        As part of the City Centre Transformation and other Council and partner projects we want to add strategic routes to our network.

Additional Comment:

We support the council’s ambition to develop new walking and cycling routes across the city.  These will provide many additional benefits for recreational walkers and cyclists alike and for active commuters.

However, these benefits will only be achieved if the existing cycle and footpath network and any additional expansion of the network is properly maintained.  Expansion of the existing network should only be undertaking if and when all parts of the existing network are acknowledge as being maintained to an acceptable standard by user groups, particularly walkers.

We have concerns about the over-engineering of cycle infrastructure in the city centre, and the consequential impacts on space and amenity that results.

Choice 9 – Protecting against the loss of Edinburgh’s homes to other uses

We support the following proposed change:

A        We want to consult on designating Edinburgh, or parts of Edinburgh, as a ‘Short Term Let Control Area’ where planning permission will always be required for the change of use of whole properties for short-term lets.

Additional Comment:

Housing is not only somewhere to live. Affordable, secure and pleasant housing is a fundamental driver of urban regeneration and well-being. The good availability of a range of housing stimulates both physical and economic improvement, and the resulting enhancements in turn fuel new investment and community cohesion. Conversely, a lack of available and affordable houses for non-transient Edinburgh residents and works risks undermining community cohesion and many wider aspects of the civic life of the city.

This policy change recognises the fragility of residential communities across the city and the concerns of residents. The largest and best-documented potential social and economic dis-benefit of the recent expansion of short term lets across cities such as Edinburgh  is the reduced supply of housing and increased cost of housing as property owners move from serving the needs of established local residents to serving the requirements of transient visitors.  Clarity and transparency in the roll out of this policy is essential.

 

Choice 10 – Creating sustainable communities

We support the following proposed changes:

A        We want to revise our policy on purpose-built student housing. We want to ensure that student housing is delivered at the right scale and in the right locations, helps create sustainable communities and looks after student’s wellbeing.

B        We want to create a new policy framework which sets out a requirement for housing on all sites over a certain size coming forward for development.

Additional Comment:

Off-campus student housing developments has grown considerably in recent years across many Edinburgh neighbourhoods.  This has led some communities to express concern over this spread and the potential or actual negative impacts on their neighbourhoods and the local available affordable housing that may, in other  circumstances, have been developed on sites given over to student housing.

We support the proposal to revise policy on student housing. We believe change is much needed in the light of recent growth in student housing which has had significant impact on the character of some neighbourhoods, and the need to give greater priority to housing for Edinburgh residents and those who wish to live and work permanently in the city.

Student housing should be treated as housing for the purposes of social housing provision in the same way that market housing is treated.  There are needs to be a policy barrier to large mono-use student housing developments that can sterilise areas in terms of vitality and vibrancy.  All student developments should have an element of mixed uses therefore, perhaps mixing with social care provision as we have seen in some Dutch developments.

It is unlikely that any single policy intervention will be able to address the many concerns arising from the perceived or actual concentration of students in some established residential communities across Edinburgh. A wide range of stakeholder perspectives is likely to be required to make changes to the existing policy framework successfully. Therefore, it is essential that in developing a revised policy framework, the council works with local communities and a diverse range of relevant stakeholders, which should include the student community, in order to ensure the joined-up delivery of new and workable policy interventions.

The integration of student accommodation with other types of residential and residential supported care accommodation should be encouraged, where appropriate.

 

Choice 11 – Delivering more affordable homes

We support the following proposed changes:

A        We want to amend our policy to increase the provision of affordable housing requirement from 25% to 35%.All development, including conversions, which consist of 12 residential units or more must include provision for affordable housing amounting to 35% of the total units.

B        We want City Plan 2030 to require a mix of housing types and tenures – we want the plan to be prescriptive on the required mix, including the percentage requirement for family housing and support for the Private Rented Sector.

Additional Comment:

Efforts to improve the supply of affordable housing across Edinburgh will need to be informed by new solutions, following international best practice, if a high quality residential environment of affordable housing is to be achieved and sustained in the longer-term  This may mean that it will be necessary to review  the established understanding of  physical housing form – in terms of size, interior space provision, design, materials used, and reuse of existing buildings – and to consider more community-led solutions if the needs of present and future residents of the city are to be met. This specifically includes the affordable housing requirements generated by increasing life expectancy, immigration and the rise in one-person households.

We support the proposal to revise policy on student housing. We believe change is much needed in the light of recent growth in student housing which has had significant impact on the character of some neighbourhoods, and the need to give greater priority to housing for Edinburgh residents and those who wish to live and work permanently in the city.

These proposed changes are to be welcomed but they must be enforced if they are to have any meaningful impact. Exceptions to the revised policy should only be allowed in very exceptional circumstances.  Indeed, it may be that provision for affordable housing amounting to 50% of the total units would be a higher ambition appropriate to the city of Edinburgh.

It is also of concern, that the number of homes that have not been built in the city of Edinburgh area despite receiving planning permission appears to be rising, potentially meaning that sites for thousands of new properties are being left undeveloped.  Research is required to understand why such sites are not being developed across Edinburgh.  Following on from this consideration should be given to a “use it or lose it” approach by the City of Edinburgh Council to prevent developers and landowners leaving sites undeveloped before further permissions for large scale housing developments are awarded.

 

Choice 12 – Building our new homes and infrastructure

We support the following proposed changes:

Option 1        We want our new homes to be delivered by the Council and its partners within the Urban Area.

Option 3 may be acceptable if carefully controlled and strictly limited.

Option 2        Instead of making this change we could use a market-led greenfield approach

Option 3        Instead we could intervene to deliver significantly more housing (11,000 homes) in the existing urban area, as set out in option 1 and release some land (6,600 homes) from the green belt  where it can be supported by the Council, and with viable new infrastructure required to support it.

Additional Comment:

The release of further greenbelt land for housing development should be resisted at this time.  Considerable areas of formerly greenbelt land already has planning permission in place for housing development. In some, perhaps many, instances this approved development has not been progress for many years and shows no indication of being progressed in the near term.  Such “ghost housing” should be developed before any substantial further releases of greenbelt land for housing development are made.

In addition, before new homes are developed, empty or abandoned existing residential properties across the city must be brought back into residential use. The potential of these unused properties to address current and future housing requirements needs to be fully assessed.

Urban brownfield site are often occupied by smaller-scale light industrial and retail uses.  There can have significant utility to the communities within which they are situated, and they can add valuable character to local streetscapes. The residential development of urban brownfield site should, whenever possible, seek to conserve existing industrial and retail functions.

 

Choice 13 – Supporting inclusive growth, innovation, universities, & culture

We broadly support the changes proposed.

Additional Comment:

Edinburgh is a vibrant city with a diversified economic base, and world-leading educational institutions, which is attractive to many people as a place to live and visit.  The plan needs to support economic development across a range of sectors while managing the pressures that can arise from the number of tourist visitors and popular cultural events.

Economic policies should support quality of life in the city, and in particular the quality of life of residents.  This should mean maintaining Edinburgh as an attractive location to visit and for residents.

At the same time, we support policies to encourage innovation and entrepreneurship, and build on the high levels of skills of the city’s workforce and the success of its educational institutions. We believe the plan should commit itself to policies which foster a high value, high pay economy, and create a dynamic and economically successful city.

This means supporting a balance of sectors and opportunities and avoiding undue dependence on sectors such as tourism which may create excessive pressures on the social fabric and infrastructure of the city.

One of the factors that will influence the inclusive growth of Edinburgh will be technological innovation. It is difficult to predict how technology, and particularly emerging technologies, will change city life. Certainly, technology will be increasingly used in the development and running of Edinburgh in the future. Smart planning may harness solar energy for use in housing estates smart mobility technology may alleviate traffic congestion. City Plan 2030 must have a range of policies in place which are sufficiently agile to enable a timely citywide response to the challenges and opportunities of a dynamic technological culture.

The use of environmental technologies which can cool buildings more efficiently or run vehicles that are less polluting will also lead to better future cities. Installing sensors in the homes of ageing seniors living alone can connect them to the community and summon help when they are unwell or hurt.

 

Choice 14 – Delivering West Edinburgh

We do not support the changes proposed.

 

Additional Comment:

We seriously question the wisdom and desirability of further urbanising the area surrounding Edinburgh Airport. The western side of Edinburgh is already heavily developed, and heavily congested, with more housing and associated infrastructure being delivered in the near term. The comparatively undeveloped surroundings of Edinburgh airport provide a contrast to the expanding urban sprawl and an appropriate ‘arrival’ rural setting to the airport for Scotland’s capital city.

Choice 15 – Protecting our city centre, town and local centres

We support the following changes:

       We want to continue to use the national ‘town centre first’ approach. City Plan 2030 will protect and enhance the city centre as the regional core of south east Scotland providing shopping, commercial leisure, and entertainment and tourism activities.

B        We will also support and strengthen our other town and local centres (including any new local centres) by ensuring that new shopping and leisure development is directed to them and only permitted where justified by the Commercial Needs study.  Outwith local centres, small scale proposals will be permitted only in areas where there is evidence of a lack of food shopping within walking distance.

C        We want to review our existing town and local centres including the potential for new identified centres and boundary changes where they support walking and cycling access to local services in outer areas, consistent with the outcomes of the City Mobility Plan.

D        We also want to continue to prepare and update supplementary guidance tailored to the city centre and individual town centres. The use of supplementary guidance allows us to adapt to changing retail patterns and trends over the period of the plan. It also helps us ensure an appropriate balance of uses within our centres to maintain their vitality, viability and deliver good placemaking.

E        We also want to support new hotel provision in local, town, commercial centres and other locations with good public transport access throughout Edinburgh in response to evidence of strong growing visitor demand and reflecting limited availability of sites in the city centre.

Additional Comment:

This policy change is timely. Some of Edinburgh’s traditional shopping centres or “high streets” are in a relatively heathy condition. But many show the tell-tale signs of the ongoing decline which has affected many high street and local shops across the UK in recent years. There is no room for complacency. Neither the local shopping areas of Edinburgh nor the city centre are immune from changing shopping habits, the growth of internet shopping and the ever-expanding offering of out-of-town shopping in the Edinburgh city region.

Some traditional shopping streets, such as Princes Street, are likely to change their character quite radically in short term due to new developments such as the St James Centre. And there is a gradually loss of character in in many local shopping streets as major chains and charity shops become more dominant.

At the same time, in some of the more affluent parts of the city traditional shopping and artisanal retail is holding its own or reviving.

 

Choice 16 (part 1) – Delivering office floorspace

We support the following proposed changes:

A        We want to:

  • Continue to support office use at strategic office locations at Edinburgh Park/ South Gyle, the International Business Gateway, Leith, the city centre, and in town and local centres.
  • Support office development at commercial centres as these also provide accessible locations.
  • Strengthen the requirement within the city centre to provide significant office floorspace within major mixed-use developments.
  • Amend the boundary of the Leith strategic office location to remove areas with residential development consent.
  • Continue to support office development in other accessible locations elsewhere in the urban area.

B        We want to identify sites and locations within Edinburgh with potential for office development.

C        We want to introduce a loss of office policy to retain accessible office accommodation. This would not permit the redevelopment of office buildings other than for office use, unless existing office space is provided as part of denser development. This would apply across the city to recognise that office locations outwith the city centre and strategic office locations are important in are limited sites for future development and demand is likely to continue. meeting the needs of the mid-market.

 

Choice 16 (part 2) – Delivering Business and Industrial Space

We support the following proposed changes:

A        We want to identify proposals for new modern business and industrial sites to provide necessary floorspace.

B        We also want to ensure new business space is provided as part of the redevelopment of urban sites and considered in Place Briefs for greenfield site

B        We also want to continue to protect industrial estates that are designated under our current policy on Employment Sites and Premises (Emp 8).

D        We also want to introduce a policy that provides criteria for locations that we would support city-wide and neighbourhood goods distribution hubs.

 

END

 

Royal Hospital for Sick Children Site Redevelopment

Posted on: July 26, 2018

Our comments on development proposal for former hospital site, registering our opposition to plans to demolish rather than retain or reuse certain buildings on Sylvan Place and Rillbank Crescent.

Our comments on development proposal for former hospital site, registering our opposition to plans to demolish rather than retain or reuse certain buildings on Sylvan Place and Rillbank Crescent.

Cockburn Response

The Cockburn’s Urban Design Group (CUDG) had the opportunity to visit the RHSC site with members of the design team. CUDG commends many aspects of this ambitious project which will bring traditional residential properties back into residential use, repurpose an important heritage building, provide student housing and much-needed affordable housing and open-up new access routes.

However, we would strongly urge consideration of the following points:

We are not convinced that the complete demolition of the A & E unit on Sylvan Place is necessary. We would urge reconsideration of façade retention. If this is not feasible, we would strongly encourage the re-use of key architectural elements from the existing decorative facade in the proposed new-build to create a stronger architectural reference between the proposed new build and the original streetscape and context.

We are disappointed that the existing building at the corner of Sylvan Place and Rillbank Crescent is proposed for demolition. We would again urge consideration of its retention or façade retention and/or the reuse of design features in-situ if at all feasible.

In Rillbank Terrace, CUDG members expressed reservations about the amount of student amenity space and communal garden space/parking space that is proposed. But, CUDG members understand that in terms of landscaping, across the site more generally, this has still to be designed in detail.

The proposed affordable housing will be in one block. We would generally promote the dispersal of social housing across a development site where this is possible.

The re-purposed RHSC facade at Rillbank Terrace, as currently proposed, will have a considerable amount of glass and modern cladding. CUDG members did not feel that this material finishing was sympathetic to the other existing and proposed architectural elements of the street.

CUDG members expressed regret that it has not proved possible to remove parking entirely from the front quadrangle of the RHSC.

Sympathetic landscaping will lessen the visual impact of parking and can create a sense of ‘arrival’ at the entrance to the repurposed RHSC. We would urge consideration of a one-way access/exit to the new parking area. The garden area may be a suitable location of ‘memorials’ relocated from the RHSC.

Finally, we strongly urge the recycling and reuse of stonework that will result from the demolition process.

Grain Silo in Imperial Dock, Leith

Posted on: May 6, 2011

Our considered and detailed objection to the proposed demolition of the listed grain silo building in Leith’s Imperial Dock

Our considered and detailed objection to the proposed demolition of the listed grain silo building in Leith’s Imperial Dock

Cockburn Response

The Association has studied the plans for the above proposals and wishes to make the following comments.

We have commented thoroughly on this building’s owner’s Section 36 Application to build a Renewable Energy Plant on this site under the Electricity Act 1989. The outcome of that application for a ‘deemed planning permission’ under Section 57(2) of the Town and Country Planning (Scotland) Act 1997 (as amended) from the Scottish Ministers is awaited and may be some time off. In the meantime it is uncertain whether the proposed biomass plant will be granted permission and, in a rapidly changing energy market with the impact of subsidy an essential component of all waste energy, whether it will still be economically viable. It is therefore too soon to consider a demolition of this unusual Category ‘B’ listed building citing the proposed biomass plant as a reason for demolition.

Though a distribution building, the grain silo is an important relic from Scotland’s recent industrial past and one of a limited number of survivors of such buildings around the world. It is noted for its intact nature, completeness and vast size. However any scheme to preserve the building would do so from the point of view of its cultural significance for future generations, which can be conveyed to a large extent without conserving the whole building.

Similarly, the argument that the building cannot find a new use and that this warrants not advertising it under the SHEP charter because of its location in a working port, and the limitations imposed by the International Ship and Port Security Code is spurious. Forth Ports has claimed since the early 1980s that this part of the Port of Leith was surplus to commercial requirements and being wound down.

Various masterplans and planning permissions exist relating to the full redevelopment of this area over the coming decades. The grain silo could form a unique and very characterful component of any such redevelopment.

We therefore think that the first priority should be repair and stabilisation of the building to prevent further deterioration, a duty which is implicit on the current owner through the listing procedure.

We are firmly opposed to the granting of permission for the demolition of a listed building such as this which is the last of its type in Scotland, where the clear and agreed procedures for dealing with alternative uses for the building so as to prevent demolition have not been followed.

We therefore wish to object to this application.