Licensing of short-term lets – Scottish Parliament Consultation

Posted on: October 5, 2021

Our response to the Scottish Parliamentary Committee examining pending legislation on the regulation of short-term lets

Our response to the Scottish Parliamentary Committee examining pending legislation on the regulation of short-term lets

Cockburn Response

Q) How would you describe your view of the proposed licensing system for short-term lets?

Cockburn Answer: Strongly support

Q) Why do you think this? (please tick all that apply)

Cockburn Answer

  • It will safeguard the amenity of people living alongside short-term lets.
  • It will protect existing communities in areas with high visitor numbers.
  • It brings short-term lets into line with other tourism businesses.
  • It will ensure short-term lets meet minimum safety and management standards.
  • It protects legitimate short-term let businessesOther reason(s) Please specify in the box below:

Q) Other reason(s) please specify in the box below

Cockburn Answer:

  • It offers the opportunity to rebalance housing provision in Edinburgh.
  • It allows for the effective management on STLs in tenements and areas where shared/community access is prevalent.
  • It will assist in the problem of reducing long-term let accommodation where there has been a displacement from long-term to short-term rentals.
  • It could form part of a toolkit of measures to help manage areas suffering from Overtourism.
  • It will help reduce the level of foreign and non-city investment in residential properties where the purchaser has no intention of living in the property but views it as an investment opportunity.
  • It will help manage direct and indirect impacts such as litter, waste management, anti-social behaviour, etc.

Q) Thinking about your response above, how do you think the proposed licensing system could be improved? Please set out how you think the system could be improved in the box below:

Cockburn Answer:

The key issue missing from the licensing system is the need for effective enforcement.

Firstly, in areas of over-provision such as Edinburgh, there is an urgent need for increased enforcement against unauthorised STL, especially whole-property STLs.

Secondly, the licensing system needs to ensure public confidence that non-compliance will be addressed swiftly and consistently. There are many circumstances where a STL landlord has ignored requests from the local authority to stop trading.

Thirdly, a Licensing system could make other actions such as compliance with tax laws easier as it simplifies data management and data sharing.

Q) Anything else? Is there anything else about the proposed licensing system, or its potential impact, that you would like to mention to the Committee. It would be helpful if you could keep any comments brief and provide evidence to support any claims made. Please set out any further comments in the box below:

Cockburn Answer:

In the City of Edinburgh, the issue isn’t what is coming but what has happened already. The current regulatory and enforcement regime is not fit for purpose. Many individuals and communities suffer from the expansion of STLs in their common stairs and neighbourhoods. The scale of the problem is so great that a substantial proportion of housing in central areas (and across the city too) has been given over to commercial short-term letting resulting in the depopulation of parts of the city.

We appreciate that those businesses and individuals who has operated STL may feel aggrieved but the proposed licensing system. However, their businesses seldom recognise the impact that they are having on individuals and on communities collectively. We accept that many STL businesses have operated for some time and that many have done so responsibly.

It is the total impact that needs to be addressed and we believe that the proposed licensing system will go some ways to dealing with it.

Further Details Here

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Former Tynecastle High School

Posted on: October 1, 2021

Our submission to planning on this significant development at Tynecastle.

Our submission to planning on this significant development at 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, safety 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.

Given that this is not a straightforward site to develop, we understand why its repurposing as student accommodation is considered both a viable and desirable option. If this application is approved, it should be considered the upper limit of what the local residential area can tolerate without seriously undermining its social fabric and cohesion. No further student accommodation proposals should be considered in this community.

If the application is approved. 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 proposed the site. The access to green and open spaces is seen as a priority by many as part of the ongoing recovery from the Covid 19 pandemic. The potential engagement of the charities LOVE Gorgie Farm and People Know as operators for community garden and community facilities on the site, should planning permission be granted, is a positive step in this regard.

Although we welcome the retention of the B listed main school building and janitor’s house.  We do not accept the assessment used to justify the demolition of the workshop block, which pre-dates the school and is of some historic significance and crucial to understanding the site.  These would seem to be ideal for repurposing as community facilities, on-site shops, bikes stores, storage areas or a wide variety of other utility functions associated with the proposed student development.

We are aware of the local community’s interest in the potential of the site for social, multigenerational and co-housing development and of its concern regarding the potential over provision of student accommodation in this community and of the potential dis-benefits associated with this. 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 in consultation with the local community.

Further Details Here

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Dunard Centre in St Andrew Square

Posted on: September 23, 2021

Our statement of support for the revised plans for the proposed Dunard Centre in St Andrew Square

Our statement of support for the revised plans for the proposed Dunard Centre in St Andrew Square

Cockburn Response

The Cockburn Association has studied and discussed this revised application by David Chipperfield Architects).  As with the earlier proposals (2018), we welcome and support these ambitious plans to create Edinburgh’s first purpose-built concert hall in over a century.

This project has potential to make a positive contribution to the artistic life of the city and to act as a transformative catalyst for the economic, social and artistic revitalisation of the streets, lanes and businesses that surround it.

Within the constraints of the available site, the proposed concert hall continues to use the space in a an effective manner.  It provides the opportunity to link the new St James Quarter into not only to St Andrews Square but the wider city centre.

Our comments are predicated on the above support, and we hope that further refinements to the design will continue.

Site and Context

  • The opening of access through the site, including outside the operational hours of the concert hall is an important objective. We believe that it would be appropriate to put in place a legal mechanism to ensure the public permeability through the site is secured in the long term.
  • We remain of the view that it is essential for the floorscape around the new concert hall be integrated with the Registers and wider environment. This should respect the limited palette of paving materials in the New Town and be designed so that the pedestrian environment appears seamless to users who will approach the building from the various access points.  Linkages to St James Quarter should follow this approach if possible.
  • We continue to advocate that access to the several garden areas by the Registers of Scotland be undertaken at the same time (although we appreciate that there seems some reluctance on the RoS to do so). This could be through a discrete new opening in the existing wall (for the Physician’s Garden) and possibly through a new gate in the railings (for the small grassed area to the south).  In essence, there is an opportunity to create a new, interesting and intimate pedestrian quarter, which places the concert hall in the centre of it.
  • The single mature beech tree currently extant on the site is most likely a remnant of the former garden landscape of Dundas House and should be retained.

Building

  • We have been unable to access the site due to neighbouring construction work so have not been able to assess how well the original test panels have weathered (if they are still on site). Our understanding is that the same highly finished concrete panels are proposed.  Based on our discussions with the architects at the time of the first application, we accepted this material given the uniqueness of the proposals and the very high specification of finish proposed.  We would therefore suggest that a suitable condition against any planning consent be applied here to give the Planning Authority long-term control over this.
  • With the original proposals, the elliptical concert hall itself is shown to have a distinctive façade modelling different from the “edge” blocks. We welcomed this as it helped break down the mass of the building and created additional visual interest within what will be an intimate pedestrian environment.  However, as the scheme has contracted and simplified, this juxtaposition has been reduced also, especially at the north-east where the angle is very obtuse.  Greater distinction between the elliptical hall section and the northern “edge” block would be beneficial. As such, this appears unresolved, as does the treatment of window openings and the junction of eaves and ground floor levels.
  • Similarly, the views to the building from the western entrance to the St James Quarter are important. The blank façade with vertical striations from almost top to bottom and virtually not fenestration presents a hostile frontage from this perspective.  Further work is needed to address the massiveness here.

Wider Opportunities and issues

  • Unlike the original scheme, the physical connection with the Category A-listed Dundas House is direct and substantial. Whilst we acknowledge that this doesn’t affect the original 18th Georgian property, it is a more significant impact to the listed fabric.
  • We continue to believe that consideration should be given to the creation of a ‘processional route’ through the current RBS building with the long-term objective being the integration of Dundas House into the centre, providing all the necessary “front of house” facilities required by a modern concert hall.
  • In the wider context of performance venues in the city, we acknowledge that this proposal will not address the needs of the festival and events sectors. The Council have prepared in the past an assessment of need – this should be renewed.
  • The use of the hall once built may generate traffic impacts on neighbouring areas including the residential New Town to the north. Large volumes of private vehicles using these streets after the 6:30pm Zone 2 parking restrictions end could result in negative impacts.

SUMMARY

The Cockburn Association continues to support this proposal.  The creation of a new cultural building is welcome, and we acknowledge the skills of the design team in integrating the sizable building into a very constrained site. We recommend some further revisions and believe especially that the wider floorscape needs to be developed to include the Registers and connections into St James and St Andrews Square, and beyond.

Further Details Here

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2030 Climate Strategy – City of Edinburgh Council Consultation

Posted on: September 10, 2021

Our detailed response to the City of Edinburgh Council’s draft “2030 Climate Strategy” for the city

Our detailed response to the City of Edinburgh Council’s draft “2030 Climate Strategy” for the city

Cockburn Response

A brief summary of our comments (a link to the full document can be found below)

The City of Edinburgh Council’s  draft  2030 Climate Strategy in is the latest in a long line of related vision statements, strategies, action plans and initiatives which the Council and its partners have launched over the last decade or so.

The 2030 Climate Strategy seeks to be more than a carbon reduction plan in that it also attempts to integrate aspects of climate change adaption, sustainable economic development, issues of social equity and well-being, for example. In this it is only partially successful.

There are undoubtedly some positive aspects to the strategy, in particular, the strategy’s ambition to achieve a significant carbon reduction for the city well in advance of the equivalent Scotland-wide target is ambitious.

However, a final judgement on whether the strategy will be able to deliver the necessary projects at scale and at pace to achieve a meaningful citywide carbon reduction by 2030, and accrue additional societal benefits for the city’s citizen, will only be possible when the strategy’s implementation plan is published at the end of 2021. This must have appropriate costings, timescale, project owners and carbon reduction metrics to enable an assessment of the achievability of net zero carbon by 2030.

Community engagement

The City of Edinburgh Council has been supporting and facilitating community discussions and practical actions to address the carbon mitigation and climate adaptation for many years and this activity has undoubtedly intensified in recent years. However, it remains unclear if such activities have influenced, or even reached, most local citizens.  And it is equally unclear if hard to reach groups and minority groups have engaged meaningful in climate change initiatives across the city.

The current Covid-19 pandemic has placed restrictions on the capacity of the council to facilitate face-to-face activities during its consultation of the 2030 Climate Strategy.  However, the relaxation of Covid-19 related restrictions over the summer has allowed some suitably adapted community consultations activities to take place across Scotland.  This being the case, and given the importance of the 2030 Climate Strategy, more effort should have been made on the part of the council and its partners to run face-to-face consultation activities in and with Edinburgh’s communities of place and communities of interest.

The role of citizens and communities going forward will be crucial. However, it remains unclear how citizens are to be given a pro-active role in the implementation of this strategy.

‘Ownership’ at a community level of the strategy’s aims and actions will be required if they are to have value. Worldwide, there are models of excellence in terms of successful, community-based sustainable development and climate action on a citywide scale.

‘Sustainable Seattle’ is a particularly well-established and embedded example of good practice, which we recommend here in Edinburgh.

Implementation plan

An implementation plan for the 2030 Climate Strategy is due out towards the end of this year.  This requires a further consultation exercise before it is approved. This will be a further and necessary opportunity to determine if the actions being brought forward by the climate strategy are likely to achieve a significant impact by 2030.

A thorough and careful assessment of the timing, costing and funding of actions is particularly required since Edinburgh seeks to achieve carbon neutrality by 2030 rather than to align with the Scotland-wide target of 2045. This seems particularly ambitious and final approval for the strategy should be contingent on confirmation that realistic and achievable actions are in place.

Many visions, strategies and plan have been approved in Edinburgh over the last decade or so which seem similar to the 2030 Climate Strategy. There is little evidence that they have achieved anything significant in terms of climate mitigation or adaptation over and above what would have been delivered if such plans had not been in place. The impacts of the strategies actions should be assessed on an ongoing basis against prior approved milestones and performance indicators.

Missing Emissions

The net zero target of the 2030 Climate Strategy is based around the concept of territorial emissions. Arguably this does not include a significant amount of additional carbon emissions which could be attributed to the city and its citizens. It would be more than helpful to understand the city’s net zero target in the context of other emissions such as off-shored emissions.

Of particular interest to the Cockburn is embedded carbon and its relationship to redevelopment and new build. Given the expansion and growth expected for Edinburgh in the near term the emission of embedded carbon from the draft strategy is notable and undesirable.

Adaptation

The need to adapt Edinburgh to the unavoidable impacts of a changing local climate is embedded throughout the strategy. However, consideration of this important action area appears to be entirely subservient to the strategy’s headline net zero target. This is more than unfortunate since adaptation projects are among the quickest and easiest ways of achieving active community engagement and of delivering tangible and immediate benefits at a community level.  It is to be hoped that the anticipated implementation plan offers more clarity in terms of adaptation-related actions.

Missing from this is the recognition that looking after what we have now is a key strategic objective and “adaptive” project. properly maintained buildings, streetscapes and green spaces prevent loss of carbon.  It also provides a long-term bridge to developing sustainable options in the future.  For example, it might not be possible to increase the physical capacity of the City’s run-off sewer systems in even the medium term to deal with increased cloudburst events.  It is possible to increase the maintenance regime to ensure that the existing system is clear and functions to its maximum capacity.

Download and read a PDF of our full detailed response here. 

Further Details Here

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Low Emission Zone consultation – 2021

Posted on: August 26, 2021

Our official response to the latest City of Edinburgh Council consultation on the implementation of Low Emission Zones in the city

Our official response to the latest City of Edinburgh Council consultation on the implementation of Low Emission Zones in the city

Cockburn Response

The Cockburn Association would wish to make these comments on the Low Emission Zone proposals being consulted upon by the City of Edinburgh Council.

Regretfully, we are unable to support these proposals.

This comes in the context of our full support for the initial LEZ proposed by the Council in July 2019. We supported the introduction of both a City-wide and City-centre LEZs accepting the arguments made at the time that only a holistic approach would prevent current “hot spots” being shifted around the city as general traffic sought ways of avoiding any smaller zone.

With the City of Edinburgh Council’s current commitment for a net zero emission on city by 2030, the LEZ is an opportunity to make changes needed across the City of Edinburgh. The city-centre boundary must be expanded city-wide to avoid displacement of pollution into residential streets and to create a cleaner, healthier city for all residents.

Context

It is important to understand the wider movement trends in order to achieve any satisfactory outcome from an LEZ.  The City Mobility Plan 2021-30 sets out the Council’s vision and policies, aimed largely at reducing pollution and increased the modal shift to active travel.  Edinburgh has a very high pedestrian journey to work percentage, where 40% walk to work in the city centre and 18% walk to work citywide.

In contrast, two-thirds of commuter traffic entering into the city comes from outside the city boundary with 70 % of commuters from other local authorities traveling by car. This compares unfavourable to local commuting, where 33% drive to work.  The related issue of traffic-generated pollution is directly linked origin of traffic.

Some of the main “hotspots” for traffic pollution lie outside the city centre and include Corstorphine High Street and parts of Leith. The current proposals will offer no solution to problems here.  Indeed, they might see even higher levels of pollution as a result.

Current proposals – discussion

The proposal is for a city-centre zone only.

Boundary

The proposed zone excludes Queen Street and the Northern New Town but extends to and includes the Meadows, which seems a bit confused given the objectives of the LEZ.  Indeed, the specific boundary suggests the creation of a de facto inner ring route allowing more polluting vehicles to circumnavigate the LEZ.

The implications for increased rat-running across the city is considerable.  This could be greatest in the residential New Town as a result of the LEZ, where traffic seeking to avoid Queen Street could easily displace into residential streets, exacerbating traffic and pollution displacement issues.  This would be very real outcome and a significant objection to the current LEZ proposals.

We strongly advocate that the northern boundary of the LEZ be altered and extended to include Randolph Crescent and the Moray Feu, and the follow the approximate line of the World Heritage Site boundary. Queen Street would be subsumed into this area.  In this, we do have concerns of further potential displacement into Stockbridge and Inverleith.

We also find the implication of the boundary is that the Morrison Street/A700 (Earl Grey Street, Brougham Street, Melville Drive) corridor becomes the main arterial for polluting traffic heading around the LEZ to/from eastern and southern parts of the city.  Similarly, St Leonard’s and The Pleasance would become the eastern flank of this Inner Ring Route causing considerable increases in air pollution along this corridor.  The potential diversion of traffic onto Queen’s Drive and Holyrood Park (subject to a separate consultation by HES) is also deeply concerning.

All this comes from the lack of a city-wide boundary for the LEZ.  The compact, dense nature of Edinburgh will result in negative impacts for communities on the edge of the centre-boundary LEZ.  This cannot be acceptable.

Indeed, in the Transport & Environment Committee report of 16 May 2019 recognised this.  It states in para 4.17, “there is a risk that a city centre boundary alone may displace polluting vehicles to other areas of the city and exacerbate existing air quality problems.”  This remains a very real and significant risk.

The consultation does not explain why the wider urban area has been deleted and only the city centre included.  This needs to be outlined fully as it contradicts the objectives set out in the paper of 16 May 2019.

Grace Period and Exclusions

A grace period of only two years is proposed although one might argue that two years have passed since first mooted.  Given the economic and other challenges that Covid has created, we believe that this may be too short a period to allow residents and businesses to transition to other vehicle types.

The LEZ also includes a list of vehicles exempted from the controls including military and emergency vehicles.  Less clear is why historic vehicles are exempt (manufactured or registered at least 30 years or historically preserved in its original state).  We can see no logic in this given the objectives of the LEZ.

Summary

As stated above, the Cockburn Association is unable to support these proposals.

We call for the dual LEZ proposals as outlined in 2019 to be reinstated, and offer the following suggestions as a way of improving the proposals.

  • High trafficked streets such as Queen Street, Melville Drive, Morrison Street and Picardy Place should be included with in the LEZ city-centre boundary.
  • Further consideration to inclusion of residential New Town Areas (as suggested initially by NTBCC) and especially those sections subject to high volumes of traffic or potential rat-runs through residential areas (e.g., section east of Dundas Street to London Road and Broughton Street).
  • In all this, the avoidance of creating an “inner ring route” must be a guiding principle.
  • We also challenge vehicle exceptions for historic vehicles as they tend to be more polluting.

Addendum: Extract of Cockburn’s previous comments – July 2019

Do you support the proposed boundary for the City Centre LEZ?

Yes, in part. The Cockburn Association accepts the reasoning to expand the zone beyond the current “hot spots” identified in the consultation in order to avoid displacement. In this regard, we believe that the suggestion from the New Town and Broughton Community Council to extend the northern boundary to include most of the residential New Town has some merit and might help prevent some displacement from city centre traffic.

City centre vehicle types in the City Centre LEZ should apply to Buses/coaches, HGVs/LGV/Vans, Taxi/private hire cars, Cars, Motorbikes.

Proposed Grace Periods – The Cockburn supported the following grace periods – 1 year for buses and coaches; 1 year for commercial vehicles; 4 years for private cars; and 5 years for city centre residents with cars.

City-wide LEZ – Do you agree with the proposed boundary for the City-wide LEZ?

Yes in part. Again, there is a logic in a holistic boundary approach which will make it easier to understand and potentially simplify the management and enforcement. As with the City Centre boundary, infrastructure will be required to enforce the zone and we presume that some sort of registration plate recognition system will be put in place. This begs the question of whether Congestion Charging would be a more useful tool rather than a simple in/out zone. Some aspects of the boundary should be revised. Whilst we appreciate the local authority boundary issues, logically, the whole of the City Bypass should be taken as the boundary for the LEZ. This will require the cooperation of East Lothian Council but from a users’ perspective, there is no distinction in Council border in the south-east quarter of the city in travel terms.

City-wide LEZ vehicle types in the city-wide LEZ should apply to Buses/coaches, HGVs/LGV/Vans.  We supported a grace period for this as 3 years for buses and coaches and 3 years for commercial vehicles.

Do you anticipate any unintended consequences from Edinburgh’s LEZ proposals?

Yes. The implications of this for Edinburgh’s hinterland is considerable. Significant investment in sustainable transport systems will be required to ensure that the City Region functions. We see no evidence of this scale of planning in place. Given that almost 70% of commuter journeys from neighbouring local authority areas is by car, simply pulling up the drawbridge (metaphorically speaking) will cause serious issues. Although the period of grace will help, there will be a financial penalty for people who have invested in diesel cars especially. Recent evidence shows that the shift back from diesel has resulted in the first UK increase in CO2 in the past decade. We suggest that the Council invests in a detailed study of how cars are used in the city, segmenting external and internal traffic. We would be happy to discuss this further.

Further Details Here

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Demolition and Replacement of Rosebery House

Posted on: August 25, 2021

Our objection to the demolition and replacement of Rosebery House in Haymarket with a bland, taller and wholly inappropriate new office block

Our objection to the demolition and replacement of Rosebery House in Haymarket with a bland, taller and wholly inappropriate new office block

Cockburn Response

The Cockburn OBJECTS to this application.

It is the Cockburn’s view that the current proposals are too tall, too bulky, bland and inappropriate for its largely residential context on the edge of the city centre.

The absence of any evidence in the application relating to the potential to refurbish rather than demolish an apparently functional office building is unacceptable, particularly in the context of Edinburgh’s high profile carbon neutrality targets. Evidence should be provided that the existing office block cannot be reconfigured to meet modern office working requirements and cannot be brought up to an acceptable energy performance standard so avoiding the significant carbon implications of demolition and rebuild.

Refurbishment must now be the starting point of any significant office redevelopment if Edinburgh’s commitment to tackling the climate emergency and achieving carbon neutrality by 2030 is to have any meaning. Successful refurbishment and reuse may have the potential to deliver some or all of the stimulus to the growth of the local, regional and national economy and  opportunities for employment in Edinburgh which are claimed for this redevelopment.

The developer appears not to have sufficiently considered the scale and setting of their proposed building and appears to be  attempting the maximise the amount of office accommodation that can be crammed onto  limited and constrained development footprint.

The developer’s assertion that the proposed building’s design will enhance the relationship of the site with the New Town Conservation Area and the Old and New Towns of Edinburgh World Heritage Site is, we believe, difficult to justify.  We believe that, for example, the architectural language of the New Town or of the remaining industrial heritage of Haymarket is not, as asserted, significantly evident in the  proposed design.

We are also concerned that the height and mass of the proposed building will create a ‘canyoning’ effect on adjacent approaches to Haymarket Station which will exacerbate existing noise, and particularly, air quality issues.

If the principle if demolition is accepted (and we believe that there is  insufficient evidence to support this) then redevelopment in this location should be limited to around four stories with a sympathetic roof structure in keeping with the surrounding cityscape, rooflines and residential character of much of this area.

The proposed design does improve some aspects of the public realm, particularly in relation to the local trams stops. But on such a constrained site it has clearly proved impossible to provide significant accessible greenspace  at street level.  Moreover, it is our view that the design overall is too tall, too bulky, bland and inappropriate for its largely residential context. As such it will significantly detract from the local area’s public realm and create an incongruous  point of arrival into the Haymarket area and city centre and will negatively impact on views to and from the city centre.

Further Details Here

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Fly Open Air Music Festival in West Princes Street Gardens

Posted on: August 23, 2021

Our response to the Council’s request for comments about another commercial event being held Princes Street Gardens

Our response to the Council’s request for comments about another commercial event being held Princes Street Gardens

Cockburn Response

The Cockburn through its long history has campaigned to protect Edinburgh’s parks and open spaces including West Princes Street Gardens. We appreciate the desire of the hospitality and events sectors to get back into operation following the enforced closure due to Covid. However, Covid as allowed us to reassess the importance of open spaces to the health and well-being of the city for its residents and visitors.

Our view is that West Princes Street Gardens is a public park, not a private events space. We hold no position on the type of activities or events that are or are not appropriate.  The issue is the impact on a public civic space in terms of accessibility, suitability and well-being in the widest sense.  All public attitude surveys since the late 1990s have shown that the two characteristics of West Princes Street Gardens valued the most by the public are its green-ness and its tranquillity.  This event, and others similar to it, are not consistent with these values.

We therefore object to this event (FLY Open Air) on the grounds that it takes over one of the capital’s premier public spaces, barring entry to it for a substantial and significant period (with set up and take down times added to the event itself) to all except those whom a commercial operator decides can gain access.  Ultimately, it is a private event that has at its core the need to offer exclusivity to ticket purchasers at the expense of public access and enjoyment.

In addition to this principle, we have several concerns which we outline below:

  • The use of the central part of WPSG will result in the inability of the public to move across the gardens unimpeded.  The proposals will effectively divide WPSG into two disconnected sections during times of operation.  This should be avoided with the public able to move from one area to another as freely as possible.
  • No times of operation are shown, thereby allowing the operator to restrict access for periods that are unnecessary.
  • The suggestion that concert users will be required to undertake a Lateral Flow test, stationed on King Stables Road suggests significant queuing issues off site, for which no management information is available.
  • The main access points, proposed for Lothian Road, presents substantial congestion issues during peak use.  Lothian Road is a major route with important bus stances beside the proposed main entrance.  Pedestrian congestion could be a safety issue.
  • There is no information on tree management or restoration requirements post the event.  A tick box asking if the applicant is aware of the Council’s policies is wholly inadequate and provides no assurance that these will be enforced given experience elsewhere in the City. Details should be included in the application.
  • We object to the proposed pop-up food and drink facilities.  It is essential that as part of the City’s Covid recovery strategy that we support existing local businesses who operate 365 days a year in the city, and not allow unfair competition from operators who are only tied to this event.
  • The event will be heavy in infrastructure, which will damage the soft landscaping. The site plan also suggests that structures will be placed over tree root systems, causing soil compaction and possible significant damage to the treescape.  This needs to be assessed before any consent can be granted.

Whilst we appreciate that the events sector is keen to hold such events for its customers, the Council should not allow land that is held as a Public Good to be used in this way.

 

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Juniper Green Telecoms Mast Installation Application

Posted on: August 20, 2021

The Cockburn Association supports local stakeholders’ considered objections to the proposed installation of a telephone mast in an Edinburgh Conservation Area

The Cockburn Association supports local stakeholders’ considered objections to the proposed installation of a telephone mast in an Edinburgh Conservation Area

Cockburn Response

The Cockburn OBJECTS to this application.

This application has been brought to the Cockburn’s attention by concerned local stakeholders. The proposed telecommunications equipment would result in excessive visual clutter within the streetscape.

The proposal would have a harmful impact upon the visual quality of the wider street scene and so detract from the amenity and special character of the conservation area as a whole. It is our view that the application is not consistent with Policy Env 6 Conservation Areas – Development as it does not preserve or enhance the special character or appearance of the conservation area.

This application should certainly be refused if it is determined that the benefits of the proposed installation are deemed not to outweigh the harm caused  to the conservation area and if there is insufficient evidence that alternative sites or mast sharing opportunities have been adequately explored.

In consultation with local stakeholders the proposed apparatus should be located in a more inconspicuous location.

 

Further Details Here

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Subdivision and building of a new house in Joppa Terrace

Posted on: August 13, 2021

Our objections to a proposal that will lead to an unacceptable loss of local garden space, local greenspace and community amenity in Joppa

Our objections to a proposal that will lead to an unacceptable loss of local garden space, local greenspace and community amenity in Joppa

Cockburn Response

The Cockburn Association OBJECTS to this application.

Local stakeholders have made contact with the Cockburn Association in relation to this application and we are aware that similar proposals for this site have been refused in the past.

If is our view that this proposal represents an unacceptable loss of local garden space, local greenspace and community amenity and would detract from the distinctive Victorian character of the terrace. The loss of this local urban greenspace would also be incomparable with the Council’s stated aims of increasing tree cover and addressing the Climate Emergency.

In these circumstances Policy Env 18 (Open Space Protection) and Policy Env 6 Conservation Areas – Development should be considered relevant to the application site.

It must also be the case that approval of this application will help to set a precedent for the loss of similar spaces in the neighborhood and across the city.

Further Details Here

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Short-term Let Control Area in Edinburgh

Posted on: August 6, 2021

The Cockburn’s expression of support for the local Planning Authority’s efforts in establishing a short term let control zone in Edinburgh

The Cockburn’s expression of support for the local Planning Authority’s efforts in establishing a short term let control zone in Edinburgh

Cockburn Response

The Planning Act recently passed by the Scottish Parliament allows planning authorities to designate areas as Short Term Let Control Areas, whereby “the use of a dwellinghouse for the purpose of providing short-term lets is deemed to involve a material change of use of the dwellinghouse” provided the property is not a Private Residential Tenancy or the property in whole or in part is the only or principal residence of the landlord or occupier.

The Cockburn Association fully supports the creation of a Short Term Let Control Area (STLCA) in Edinburgh. Furthermore, we strongly support the recommendation that the STLCA should covers the whole city.

Almost no ward has no holiday lets in it, and it is essential that any designation does not simply displace issues with Short-term lets (STLs) from one street onto another.  We can see some merit in several areas being designated (providing whole authority coverage) as there may be different issues that need to be managed.  For example, flats in common stairs present different issues so different policies might be useful for tenement areas, colony developments and for bungalow areas.

Guidance needs to be prepared as a matter of urgency.  The Cockburn suggests that the expected CityPlan 2030 should contain robust policy proposals when it is released for public consultation later this year.

We would advocate that, in addition to individual property regulation, an area-based approach be considered with clear thresholds for STL in defined areas.  A maximum threshold could be imposed for streets (no more that 10% of properties can be used, for example).  This should be considered in the context of other tourist or transient person accommodation including hotels, guest houses and B&Bs.

The Council must put in place adequate enforcement and management resources and processes. We would expect a significant increase in applications for Change of Use to precede the creation of a STLCA as well as a corresponding number of enforcement actions assuming the current approach to refusing consent to flats in common stairs continues.

All registered STLs in a STLCA should also agree to a Code of Conduct seeking to minimise anti-social behaviour.  This might include access to contact details of owners/managers and a framework for addressing complaints including recommended time spans for dealing with them.

We accept that a balance needs to be struck between the right of people enjoying a property and the right of neighbours and others to not have their amenity affected.  A degree of tolerance is needed but currently, the onus of responsibility rests entirely on affected parties to prove a sustained impact on their amenity.  A review of the effectiveness of current powers to deal with anti-social behaviour is therefore recommended as part of this process.

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