Low Traffic Neighbourhoods Proposals in Corstorphine and Leith

Posted on: July 8, 2021

Our response to the City of Edinburgh Council’s consultation on two low traffic neighbourhoods in the city

Cockburn Response

We welcome this CEC initiative to address the desire of local residents in Corstorphine and Leith for safer walking, cycling and wheeling spaces and for improved crossing points.

We would like to take the opportunity to stress the need to proactively monitor these temporary schemes and the importance of ongoing and meaningful engagement with local communities at all stages of this scheme.

Further Details Here

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Henderson Place Lane Development

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Our initial response to developer about their plans to demolish existing buildings in Henderson Place Lane and build new apartments

Cockburn Response

We welcome the redevelopment of this site for housing. But clarification of the justification for the demolition of this relatively modern building rather than its repurposing is required. This would appear to be a more sustainable option in a part of the city dominated by heritage designations. In addition, and importantly, renovation and repurposing of usable buildings must be an essential first consideration if the City of Edinburgh is to reach its stated target carbon neutrality by 2030. conversion.

The original Silvermills masterplan restricted the scale and density of development in this area. Clarification should be given be on whether and how the current redevelopment proposal is consisted with original masterplan’s aims.

Further information is also required on the proposed housing mix, tenure types and social rented housing component is also required.

Further Details Here

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Old Tynecastle High Redevelopment

Posted on: June 11, 2021

Our comments on a Proposal of Application Notice (PAN) for a development at this significant site in Tynecastle

Cockburn Response

This is a significant, well-connected yet potentially challenging site in relation to its location next to a distillery, stadium, and the Western Approach Road. In particular, the proximity of the distillery and road raises substantial design questions regarding the site’s environmental quality and amenity for future residents. However, the successful redevelopment of this site would bring it back into active use and contribute to the neighbouring community. In such a congested part of the city this is an ideal location for a car free development although the sites potential impact on public and active travel provision will also require assessment. The active interest of the local community in the future of this site is of note.

It is acknowledged that this will be challenging site to develop given the many site constraints. Nevertheless, this is a large site which has the potential to actively engage with the surrounding residential community in several ways. This should not be developed, in any sense, as a gated community. Residents from the surrounding community should be able to access new open space/ greenspace recreational opportunities on the site. The access to green and open spaces is also seen as a priority by many as part of the Covid 19 recovery. The potential to develop the site for a range of land uses and public access to the courtyard and to the site more generally should be advised by local feedback and community aspirations for the site and the city’s 2030 climate change and climate adaptation agenda.

The retention of the B listed main school building is welcomed although the potential demolition of the workshop block, which pre-dates the school and is of some historic significance, and of the janitor’s house is of concern. These demolitions need to be fully justified and should be reconsidered in the context of the historical development of the site and their relevance to the history of the local community past, present and future. The repurposing of retained buildings and any facade alterations should also respect the historical character of the buildings and site.

This may be an appropriate site for student accommodation development. However, the local community’s interest in the potential of the site for multigenerational and co-housing buildings, should also be considered as part of this development. This would energise and diversity the site and contribute to the provision of more local social housing and affordable housing.

In addition, a thorough assessment of the current and consented student developments in the neighbouring locality is required before any further student accommodation can be considered. Over provision of student accommodation in any single locality or community in the city runs a concomitant rise of undermining the social and community fabric of that community. If this development represents over provision of student accommodation in this community, then the opportunity to provide a mix of uses, including business and community use, which could assist with integrating the site into the community should be reassessed.

Further Details Here

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Short Term Let Conversion in Barony Street

Posted on: June 10, 2021

Our comments on the plan to convert another long-term residential home to a short-term commercial property

Cockburn Response

This application has been brought to our attention by a Cockburn stakeholder.

It is our view that the proposed change of use from residential to short term visitor accommodation is not consistent with Policy Hou 2 ‘Housing Mix’ as it would detract from the provision of a mix of local house types and sizes able to meet a range of local housing needs, including those of families, older people and people with special needs, and it does not have regard to the character of the surrounding area.

The proposed change of use is not supportive of either Scottish Government Housing policy on more homes – “everyone has a quality home that they can afford and that meets their needs” or Scottish Planning Policy on “socially sustainable places” and “supporting delivery of accessible housing”.

For these reasons we object to the conversion of this property from long-term residential to short-term commercial use.

Further Details Here

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Festival Fringe Circus Hub in the Meadows

Posted on: June 9, 2021

Our detailed objections to the proposal to temporarily privatise a significant portion of publicly owned greenspace in the heart of Edinburgh

Cockburn Response

The Cockburn Association would wish to offer the following comments on this application.

We do so in the context that we have great sympathy for local businesses who have been hardest hit by the lockdown restrictions and believe it is essential for the local economy get back on its feet and to get the iconic Festivals back in operation. We made this clear in a communication to the City’s Planning Committee on 18 May in the context of the relaxation of planning control encouraged by the Scottish Government has part of the Covid recovery programme of action.

The Cockburn acknowledges the fact that the applicant has erected similar infrastructure on this site having secured a contract from the City Council to do. This displaced the “Lady Boys of Bangkok” who operated from here for several years and who we understand will operate from Festival Square this year. Other events such as the Meadows Festival and Moonwalk use the Meadows, and historically, the 1886 International Exhibition of Industry, Science and Art was sited here where a temporary dispensation to the erection of buildings was allowed.

However, the Cockburn is aware that no planning consent has been sought for their operation in The Meadows despite it being a very clear Change of Use to Class 11 (Assembly and Leisure) and operates for longer than the 28 days in any year. The implications of such a change of use are considerable. It would permit large wholly-commercial developments to use a public open space year-round and would set a dangerous precedent for other open spaces in the city.

As such, the past history of occupation should not be taken as a material consideration in this application or should be given minimal weight. In effect, from a planning perspective, a this is a new application for a development in a public park.

Covid has also demonstrated the critical need to preserve open spaces for well-being, both physical and mental. The enclosure of a sizable part of the Meadows will have a material impact on space available for informal recreation and enjoyment, and should be resisted.

Fundamentally, the Cockburn believes that soft landscaped areas should not be used for events that require heavy infrastructure due to the damage that they cause. The proximity to trees causes further concern due to the potential compaction of root systems leading to long-term decay or even loss. We dispute the assessment by the applicant that no trees are affected by the application. Root systems at both Middle Meadow Walk and Boy’s Brigade Walk will be affected, especially the former with the hospitality elements located adjacent to the existing avenue.

A recent site visit shows that the ground has still to recover fully from events held in 2019. Serious compaction of soil has occurred where previous event infrastructure was located.

We note that the Edinburgh Improvement Act of 1827 expressly stipulates that no buildings may be erected in the Meadows or Bruntsfield Links. The Meadows are also Common Good Assets, requiring the Council to manage them for the benefit of residents. We believe that this development is contrary to the spirit, if not fact, of the 1827 Act and to the use as a enclosed, exclusive event space is not consistent with Common Good land.

The Marchmont, Meadows and Bruntsfield Conservation Area Character Appraisal notes that the Meadows is the largest urban recreational parkland in the city and affords panoramic views to the north and east. It also notes the importance of the recreational open space at Bruntsfield Links and Meadows as one of the premier open spaces in the city. The appraisal indicates that it is designated a Millennium Park, which means that the Council will ensure that the park is protected in perpetuity as community open space. The appraisal also notes the occasional use by festival temporary venues.

There are other sites in the city where would be welcome this event. Festival Square and the related Conference Square provides a hard surfaced area more than capable of hosting this event this year, close to Princes Street and a variety of public transport corridors. Large car parks, such as Meadowbank Retail Park, might also be alternatives.

In addition, we strongly advocate that pop-up food and drink facilities should be deleted from the proposals. It is more important that established, permanent year-round neighbouring pubs and restaurants benefit from any trade associated with this type of use. Almost half the site is given over to its use as a licensed premise. We liken this to be similar to a cruise ship – self-contained with the objective of reducing off-site sales to a minimum. Whilst this might be good for the operator, it does little to support the local economy.

Relevant development plan policies are:

Policy ENV 6 – Conservation Areas (Development) states:

“Development within a conservation area or affecting its setting will be permitted which: a) preserves or enhances the special character or appearance of the conservation area and is consistent with the relevant conservation area character appraisal b) preserves trees, hedges, boundary walls, railings, paving and other features which contribute positively to the character of the area and c) demonstrates high standards of design and utilises materials appropriate to the historic environment.”

Our view – the CACA makes it clear that its character is an open space and its appearance is as an open parkland. The erection of a temporary building to host a commercial event with gated access is not consistent with its special character.

Policy ENV12 Trees states:

“Development will not be permitted if likely to have a damaging impact on a tree protected by a Tree Preservation Order or on any other tree or woodland worthy of retention unless necessary for good arboricultural reasons. Where such permission is granted, replacement planting of appropriate species and numbers will be required to offset the loss to amenity.”

Our view – the develop is likely to have a damaging impact on the root systems of trees along Middle Meadow Walk and is therefore inconsistent with this policy.

Policy ENV18 Open Space Protection states:

“Proposals involving the loss of open space will not be permitted unless it is demonstrated that: a) there will be no significant impact on the quality or character of the local environment and b) the open space is a small part of a larger area or of limited amenity or leisure value and there is a significant over-provision of open space serving the immediate area and c) the loss would not be detrimental to the wider network including its continuity or biodiversity value and either there will be a local benefit in allowing the development in terms of either alternative equivalent provision being made or improvement to an existing public park or other open space or e) the development is for a community purpose and the benefits to the local community outweigh the loss.”

Our view – The proposals will result in the loss of open space due to its restrictive enclosure. We believe that it will have a significant impact on the Meadows overall and will reduce its use for amenity and recreational activity as a result. We also believe that the need for informal recreational open space in the current Covid climate makes this a pre-eminent policy objective.

Policy ENV22 Pollution and Air, Water and Soil Quality states:

“Planning permission will only be granted for development where: a) there will be no significant adverse effects for health, the environment and amenity and either b) there will be no significant adverse effects on: air, and soil quality; the quality of the water environment; or on ground stability c) appropriate mitigation to minimise any adverse effects can be provided.”

Our view – there a substantial negative impact on soil compaction and therefore soil quality. it is clear that the turf is struggling to regenerate over much of the area covered by the application despite no activity in 2020.

The Association is of the view that the proposed development is inconsistent with Local Development Plan policies and with the duties of the local authority to manage these Common Goods Assets for the benefit of the public.

We would therefore wish to formally object to this application.

Should the Committee be minded to approve this, we would strongly advocate that any consent be time limited for this year only and be made personal to the applicant only. The reason for this is to decouple the temporary relaxation of planning control encouraged by the Scottish Government as a Covid recovery initiative and to allow future consideration of the suitableness of this site as part of the Council’s Events and Filming in Public Spaces Management proposals, which are currently in development phase.

Further Details Here

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Grassmarket Short Term Let Application

Posted on: June 8, 2021

Our objection to a plan to convert yet another residential home into a short term let holiday property

Cockburn Response

The Cockburn has studied this application and would wish to lodge a formal objection to it.

We do so in the context that we have great sympathy for local businesses who have been hardest hit by the lockdown restrictions and believe it is essential for the local economy get back on its feet.

It is our view that in this residential shared stair context the proposed change of use is not in accordance with Policy Housing 7 ‘Inappropriate Uses in Residential Areas’ as it would have a materially detrimental effect on the living conditions of other residents of the main door accessed residential stair, and so should not be permitted.

In addition, the proposed change of use is not supportive of either Scottish Government Housing policy on More homes – “everyone has a quality home that they can afford and that meets their needs” or Scottish Planning Policy on “socially sustainable places” and “supporting delivery of accessible housing”.

The Old Town has been subjected to the most intensive pressures of overtourism for some time. It is essential that the city rebalances this pressure. Encouraging the shift from short-term holiday letting to more permanent housing is one way of achieving this.

We note that the applicant places significant importance to a recent appeal decision at Johnston Terrace where an application for change of use to STL was sustained. We believe that the issues are very different in the Grassmarket which retains a substantial residential community. Also, this appeal decision was very much an outlier and not consistent with the many, many cases where appeals have been dismissed due to their impact on neighbours and the wider community.

Further Details Here

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Winter Festival Consultation

Posted on: May 19, 2021

Our response to a Council consultation on the future of Edinburgh’s Festive Festivals

Cockburn Response

The Cockburn Association appreciates the popularity of the Winter Festivals. We have stated repeatedly over the past number of years that it adds vibrancy and vitality to the City. Edinburgh’s Hogmanay is now a global icon that, at the turn of each year, markets the city to a global audience on par with Melbourne and New York City to name a few.

However, both the Christmas Market and the various Hogmanay events are major commercial events rather than cultural festivities. The Xmas market has moved considerably from the German market that once occupied the Mound with largely authentic products and produce to such a scale that it now modifies the Princes Street Gardens to suit its purposes rather than sits respectfully within them.

Now, these festive events impose significant restrictions on residents and those working in the city. Both are now geared to the tourist market rather than the local, with 2018 official figures indicating that less than half attendees of the Xmas market were local residents, which falls even further to just 20% for Hogmanay.

Pre-Covid, the Winter Festivals have been an increasing cause of concern for residents and civic organisations through the city. The erection of a massive space deck in East Princes Street Gardens by the Council’s contractor Underbelly, together with other issues regarding the operation of Edinburgh’s Hogmanay events (such as attempts to exclude local residents from the city centre) were merely the straw that broke the back of civic interest. The City Council’s response to these issues was less than satisfactory and highlighted the conflicted interests that it has in such matters.

These issues prompted a joint response by the Cockburn and the five City Centre Community Councils prompted by the City of Edinburgh Council’s Policy and Sustainability Committee (Thursday 20^th August 2020).

Current Consultation

The Cockburn welcomes the consultation on the future of the Winter Festival. This was promised as a response to the unsatisfactory management and governance of recent festivals.

However, we are concerned with some of the information provided in the on-line consultation. For example, figures are put in the introduction with no links to the actual reports or data, which has been relatively unchallenged. Commercial confidentiality means that key information is unavailable for scrutiny.

Some issues were unexplored (environmental and carbon impacts), and others would benefit from further discussion and consultation. In this regard, we hope that the various stakeholder groups convened by the consultants would be re-established to receive the report from this consultation and have a chance to consider and discuss the findings.

Covid and Covid-secure challenges

The current uncertainty of restrictions and the general acceptance that we will be living with Covid and Covid-variants for some time needs to be reflected in any event post 2021.

An enhanced (and not just “adequate”) security and people management ?? policy for all aspects of the Winter Festivals will be an absolute priority with respect to public protection. It is clear that for years to come, the implications of Covid and the management requirements caused by Covid will continue. The Winter Festivals should have the high levels of management to prevent overcrowding, protect public health and ensure social distancing.

For this reason, together with concerns about previous Winter Festivals, suggests the need for a carefully considered attendee dispersal strategy post-2021. Bigger isn’t necessarily better.

It is our view that the Christmas Market, Hogmanay and associated events should not be held in East Princes Street Gardens or at least reduced to the extent that only the upper terrace is used. No space structure such as that erected on 2019 should be permitted.

Key Principles for the Winter Festivals post 2021

The principle of free access must underpin the Winter Festivals offer, especially for those activities that occupy public space. We accept that there will be some ticketed events (such as the Hogmanay Street Party) but these should be limited with a default position of no exclusive access to public areas.

No public or quasi-public areas with soft landscaped surfaces should be used for activities that require substantial infrastructure that might cause damage to those areas. For the Cockburn, it is unacceptable for a public space like east Princes Street Gardens to be unavailable for 6 months of the year to facilitate a commercial Christmas Market that operates for 6 weeks. There are other places and solutions available, such as integrating Waverley Bridge into the market, and using corporate sponsorship to fund entertainment activities.

There should be no loss of public circulation space resulting from measures put in place for these events. For the avoidance of doubt, such management and social distancing measures must not be a Trojan horse for increased commodification of public spaces including streets.

There must be a direct commitment from the Winter Festival management to contribute to Edinburgh’s carbon reduction targets. All contracts should explicitly reference to ISO 20121 on sustainable events as a benchmark for management. Travel to the events by attendees (including a full breakdown of EH postcodes) should be included in any carbon counting exercise in order to assess, and therefore manage, the full carbon impact of the Festivals.

It is vital that absolute priority is given to supporting existing local businesses and micro-businesses including local social enterprises (Edinburgh Social Enterprise is the most appropriate source of assistance) through all aspects of the events. The aim to create an Edinburgh Christmas Makers’ Market is welcome but important details will need to be developed.

Public interest and protection will be best served by scaling down the market. In 2019 67% of outlets in 2019 were non-local. There were also too many “repeat” stalls – i.e. stalls owned by the same retailer selling the same products, in many cases products available in traditional High Street shops. Clear reductions are needed in the number, as well as the proportion, of non-local exhibitors.

In particular, there should be no pop-up bars and food outlets, especially as these create direct competition, not additionality, to local all-year round businesses such as bars and cafes.

Dispersal of activities

A significant problem with the Winter Festivals pre-Covid was the desire of operators to concentrate activity is a small area. With the Xmas Market, this meant East Princes Street Gardens which were unable and unsuitable to cope with an ever-increasing activity.

Planning applications submitted in early 2020 proposed locating market stalls on High Street and George Street with possible other facilities located in streets will clearly have an impact on local residents for more than two months. We therefore ask that residents on all affected streets are consulted for a period of at least two weeks, before a decision is taken about where the market stalls will be located on the City Trail.

The Cockburn strongly advocates the creation of a Christmas City Centre Trail using sites across the City Centre in various locations for markets which could bring additional benefits to those areas. This should include existing markets, such as those in Stockbridge, Castle Terrace Car Park and the Grassmarket, as part of this trail. The maps below shows a comparison of relative distances between Munich’s famous Xmas market locations and suggested locations in Edinburgh. Edinburgh’s Festival Square and Conference Square provide an excellent location for the Winter Festivals which could be coupled with The Mound/Waverley Bridge and the possibly the High Street to form an excellent offer.

Summary

The 2019 Winter Festivals were a watershed moment where public concerns about the impact of the Christmas Market and the restrictions and impositions placed upon local residents and businesses for the Hogmanay events reached a tipping point.

This consultation is a direct result of the public disquiet at the approach taken by the Council in managing (or undermanaging) the impacts and the ambivalence of Underbelly, the City’s contracted partner for the delivery of the Winter Festivals to these issues. The damage caused to East Princes Street Gardens, effectively removing public access for half a year directly caused by the Christmas Market and its space deck erected without proper consents was a low point in history of the Festivals.

Fundamental to any event that happens post-2021 is the need for the City Council so show leadership in managing the special place and unique qualities of the city. The Council must no longer simply hand over control of significant parts of the public realm to a commercial operator because it is expedient to do so.

The Cockburn would welcome the return of the Winter Festivals but only if past failures are rectified. No soft surfaced public space should be used for infrastructure. East Princes Street Gardens should be largely off-limits for use, but a more creative and dispersed approach could yield significant benefits for the city in a way that does not overwhelm more fragile neighbourhoods and localities.

Other cities in the world operate just such events in much more sustainable ways without the negative impact of the repeated damage caused here. There is no reason why Edinburgh cannot follow suit.

Further Details Here

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Virgin Hotel Roof Terrace

Posted on: April 14, 2021

Our objection to the proposed roof garden on Edinburgh’s new Virgin Hotel

Cockburn Response

The Cockburn Association OBJECTS to this application.

This application has been brought to our attention by Cockburn stakeholders resident in the Grassmarket area.

It is most unfortunate that this proposal was not part of the original planning application for this hotel which would have been the appropriate opportunity to fully scrutinize its potential impact in the context of the development as a whole.

We are particularly concerned that, if approved, the proposed roof garden will generate an unacceptable negative impact on local residential amenity from noise, disturbance and light pollution. And we note that it overlooks both the Edinburgh Central Library and Greyfriars Kirkyard, both relatively quiet and peaceful locations in the heart of the already busy and congested Old Town.

Given the various uses and users proposed for this roof garden. It seems not unlikely that the roof garden will be a potential source of disturbance throughout much of the year, night and day.

Further Details Here

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Demolition of existing buildings and erection of apartments and associated development at 27 Arthur Street

Posted on: April 7, 2021

Our objection to the proposed demolition of a building at 27 Arthur Street, Leith

Cockburn Response

The Cockburn Association OBJECTS to this application.

27 Arthur Street is actively used as an affordable artistic and venue space that demonstrably diversifies and promotes a vibrant cultural identity and cultural activities at local community level outside the confines of the city centre.

Our objection is consistent with our call in the Association’s ‘Our Unique City‘ statement and in recent City of Edinburgh Council consultations to move the concentration of event and cultural activity away from the city centre and to disperse such activity across Edinburgh’s communities, for the amenity and benefit of those communities.

In ‘Our Unique City‘ we have stressed the importance of a holistic view which looks at the functions of buildings as well as the buildings themselves. Such a consideration is even more important now given the City of Edinburgh Council’s interest in and stated commitment to the concept of the 20-minute City.

Further Details Here

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Spaces for People

Posted on: April 2, 2021

Our response to the City of Edinburgh’s “Spaces for People” public consultation

Cockburn Response

General Comments

The Cockburn Association welcomes this opportunity to comment on the Spaces for People scheme. However, as this scheme consists of many on the ground projects with directly impacts on the lives and amenity of local residents in a variety of ways. In respect of the current consultation on the Spaces for People scheme we are unable to comment on points of detail or on the local merits or otherwise of individual initiatives within the overall programme.

We offer the following comments as a contribution to the lively ongoing debate within the city on the merits of the programme. But we are disappointed that the current consultation does not provide an opportunity to discuss and comment on the wider transport, planning and place policy issues which are relevant to the Spaces for People scheme. It is to be hoped that further consultation on the Spaces for People scheme will allow a debate on relevant issues within this wider policy environment.

The recently approved City Mobility Plan 2030 as well as initiatives such as the Central Edinburgh Transformation Project, George Street proposals and the Meadows to George Street Cycleway project All signal a shift in emphasis and desire to move away from automotive strategies into more civic-based ones. The Cockburn supports this approach in principle but will scrutinise the content of actual proposals as they are published for consultation and comment.

Better facilities to encourage walking, wheeling, and cycling are required to making Edinburgh the great walkable city that it should be. But they must be the right initiatives in the right place and be consistent with the needs and wishes of residents and local businesses.

Challenges and Issues

The Spaces for People was a rapid rollout scheme that benefited from huge displacements of traditional road traffic due to the Stay at Home regulations of the Scottish Government. As normal activity resumes over the coming weeks and months, competing pressures of road and civic space will result. Any assumptions of success or impact will need to be reassessed, in some cases from first principles, before any temporary schemes can be deemed workable, appropriate or relevant to the everyday experiences and needs of residents and businesses post-pandemic.

The increase in on-line retail was an stablish and growing trend before the pandemic has been significantly accelerated by the lockdown. The shift from People moving to the Shop to the Shop moving to the People will continue, meaning an increase in delivery traffic through the city and all times of the day. A particular feature of this shift is the requirement for localised loading bays for delivery vehicles in all parts of the city, but particularly on residential streets. Any Street for People initiative must be able to accommodate this trend.

Design and Place Emphasis

The Cockburn argues that Spaces for People must prioritise making places for people. Its focus should be place led, not transport led. The introduction of safer cycling facilities is important but in many instances is a traffic management issue. An while it may be possible to reach a balance between the competing needs of pedestrians, cyclists and motorists, this will not always be the case. In addition, the specific requirements of facilitating efficient deliveries to local business and deliveries and services to residents must also be fully integrated into an acceptable, workable, permanent version of the Spaces for People scheme.

A wider, more inclusive urban design approach through a focused agenda of quality design inputs will yield more appropriate results in many places. In this, we also emphasise the need to enhance the DESTINATION element of local centres in order to support local businesses post-Covid, noting the important role that they have played in supporting their neighbourhoods during and before the pandemic. Such an approach will also anticipate and address the potential unintended negative consequences of local Spaces for People infrastructure such as creation of new local ‘rat runs’.

Narrative and Discussion

Spaces for People in Edinburgh was initiated to put in place several measures that specifically try to:

help parents/carers and children to physically distance near schools;
help people to physically distance while using high streets, some city centre streets, and while exercising; and
provide protected cycle lanes on main roads, so that people can consider cycling for trips that they might otherwise make by public transport.

It is the Cockburn’s View that the Council has an opportunity, in terms of transport and travel, to make sure that residents and business owners can move about the city more safely and more efficiently, with a reduced impact on the local environment, than was the case before the pandemic.

However, any Spaces for People schemes that become permanent must:

be acceptable to residents and businesses;
improve the streetscape;
be safe for all users (particularly vulnerable residents).
improve accessibility for all users (particularly vulnerable residents).;
be efficient and effective;
be environmentally acceptable;
provide for walking, cycling and public transport consistent with the Transport Hierarchy.

The Spaces for People projects which have already been put in place or are in the process of being put in place, across the city may be fit for purpose and relevant to the needs of residents, businesses, and local communities.

However, the restrictions on movement during the pandemic certainly present challenges and uncertainties in forming a complete picture of the needs and requirements of residents and established businesses post-pandemic.

What is certain is that all schemes which are to become permanent should only become so if they conform to the Transport Hierarchy. If they do not conform, they should not become permanent or should only do so after significant modification.

Emphasising the Transport Hierarchy

The Scottish Government’s Transport Hierarchy strategy places the needs and requirements of pedestrians at the top (including the access requirements of people with disabilities), followed by cyclists, then public transport, then shared transport with private car users last. The aim of the hierarchy is to ensure that the movement needs of the most vulnerable groups are fully considered in all new transport and mobility schemes. This does not necessarily give priority to pedestrians and cyclists in every location. This will depend on local circumstances.

Anecdotal evidence seems to suggest that the current Space for People projects have the potential to affect hard-to-reach or vulnerable groups disproportionally and adversely, such as those with mobility issues. We note and agree with the concerns expressed by the Edinburgh Access Panel. Our own stakeholders have raised very similar concerns relating to pedestrians safely at ‘floating bus stops’ and in any situation where pedestrians are forced to cross a cycle lane to get to their bus or their parked car.

A particular concern is any proposed loss of parking provision for blue badge holders caused by the roll-out of cycle lanes. Of necessity, blue badge holders must be allowed to park close to their destination. This is not a question about the total number of blue badge parking bays in the city. But it is it a question about having blue badge parking bays where they need to be to meet the requirements of blue badge holders. In some situations, it may not be possible to meet the competing requirements of blue badge holders and, for example, cyclists. In such circumstances the legitimate needs of blue badge holders cannot and must not be compromised.

Local businesses will also have their own unique concerns. The Council’s transport teams need to engage effectively with local businesses and their representative beyond the passive and somewhat leading digital consultation portal. Information should be disseminated and presented locally in a way likely to be accessible and useful to the various local stakeholders with a substantial interest in the changes being put in place. Local businesses will only be able to survive and thrive post-pandemic if they have safe and secure access for incoming and outgoing deliveries to and from their places of businesses. At this point, it is not clear to us that this have been established in all the temporary Spaces for People schemes currently in place or proposed. The economic sustainability of local businesses is dependant on the Spaces for People programme being fit for purpose in this respect. This is more than a simple decision about the number and location of loading bays, important as they are.

A related point, it the facilitation of deliveries and services to local residents. The point has already been made that the ongoing growth in online shopping has led to an increase in deliveries to residents, at all times of the day. The Spaces for People programme must accommodate this need and the related needs of the many service providers that are used on a regular basis by residents throughout the city.

The Need for a Place Hierarchy

Missing from the Spaces for People initiative is an understanding of the needs of the particular place or local neighbourhood into which the interventions are being located.

Much of central Edinburgh is covered by Conservation Area designations, each of which has its own Conservation Area Character Appraisal that sets out those characteristics that need to be preserved or enhanced. We acknowledge that traffic interventions are technically excluded from Conservation Area Management by Class 30 of the General Development Order (Work by the local authority) but we argue that there is a duty of care by all sections of the local authority to ensure the highest design standards in a Conservation Area.

Any interventions should reinforce the particular character and functions of that place. For example, if a street acts as a local neighbourhood centre (a parade of shops, pubs, cafes, etc), the priority is to enhance the pedestrian environment with gathering spaces to support these places as local destinations. It should be explicit that if in achieving this, the ability to insert a segregated cycleway is curtailed, that should be accepted.

Maintenance

A point which we have raised in previous consultations such as that for the City Mobility Plan 2030 is the issue of ongoing maintenance. An example is the condition of some of the city’s pre-pandemic cycling infrastructure of painted on-road cycling lanes and on-road waiting areas. In many instances, these have not been maintained although some have now been overlain by Spaces for People infrastructure. The Council has not yet made it clear if and how future resources will be provided to maintain permanent Spaces for People projects in a safe and appropriate condition to secure the needs of those walking, wheeling, and cycling. Put simply, funding appears to be available for capital works. But will funding be available to secure the adequate maintenance of completed projects in the future?

Consultations and the Consultation process

A recent opinion piece in the Evening News declared that implementation is not consultation. We agree with that sentiment. At the height of the pandemic, normal consultation requirements were set aside for the necessary infrastructure to be put in place as quickly as possible whilst the pandemic was at its peak. This meant that some residents had controversially little, or no notification of planned Spaces for People changes and only found out when the implementation works started.

Now, the Council is considering whether to keep some Spaces for People measures in place, either on a trial basis or more permanently. Before deciding whether to go through the legal processes necessary to keep projects in place, the Council want to hear residents’ and businesses’ views. The current process is an online consultation. It is not one based on the ground, in local communities, talking face-to-face with residents and local businesses. Whilst we appreciate that many schemes will be advanced under a temporary or experimental basis, it can be assumed that permanent retention is an objective.

As the pandemic restrictions ease, the Council must take the opportunity to expand and extend its consultation process to capture a full range of views from stakeholders affected by the Spaces for People projects. An opportunity to discuss and comment on the wider transport, planning and place policy issues which are relevant to the Spaces for People scheme should also be provided. The Cockburn Association would certainly strongly encourage the Council to search out and take up all further consultation opportunities as they become possible.

It is also essential that the Council recognises that the views and lived experience of stakeholders may change as pandemic restrictions are eased and the city fills up again with traffic, visitors, and events. It is a sad reality that as commercial life returns to community ‘High Streets’ across the city, the local streetscape of shops and businesses, the way people shop, use services and meet friends and neighbours may have all have undergone significant change. Locals may have discovered new ways of using their local streets and neighbourhoods and the Spaces for People initiative will need to support and facilitate local community vitality post pandemic and not hinder it.

The Council’s consultation processes will need to be agile enough to capture this changing reality. Indeed, as the city moves back to ‘normal’ life the results of the Council’s current consultation, given the unique circumstances under which it is being carried out, may come to be quite irrelevant to the reality of life in only a few months’ time. And, of course, the views of residents, business, services providers and utility companies may be quite different and may need bespoke consultation processes.

Summary

We would encourage all local residents, businesses and stakeholders to participate in the Council’s current consultation. But we believe that this should not be the end but rather the start of a more significant and locally engaging consultation exercise or series of consultations.

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