Cockburn Response
Background
This PPP application represents one of the largest set piece urban expansion projects in the city for the past 50 years. Coupled with other developments in the immediate vicinity of “West Town”, it amounts to an area of size and significance without parallel this past century.
The Association therefore welcomed the West Edinburgh Strategy and the associated West Edinburgh Place-making Framework as key components of the management of this growth.
However, we remain concerned that the crucial studies such as the SEA, EIA and TIA had not been prepared as separate strategic documents prior to this application coming forward. We indicated as much in our comments on City Plan 2030.
Consultation issues
Given the implications of such a development in this area, we believe strongly that the statutory constraints of consultation periods should be put to one side and that the City Council lead on a wider public engagement with local communities and key stakeholders.
The current PPP application consists of 150+ documents, some of which are complex and need careful study before any reasoned comments can be made. Running to a preset Development Management timeclock is therefore neither reasonable nor democratic in such circumstances.
General
The Association believes that a “total development” approach is required here. This includes the fundamental need for infrastructure of water and waste in addition to net zero and energy generation/conservation initiatives to be given primary consideration first and foremost over developer interests. Indeed the interrelationship of energy, water and waste management are key issues in driving overarching principles of ecology and good environmental standards. These should feature very clearly in this development and should have ambitious environmental targets that go beyond current regulatory requirements. We are not convinced that this is the case.
Similarly, we advise that ambitious environmental targets should be sought for both the creation and ongoing management of this new area of the city. Fundamental to this is demonstration of an ongoing long-term commitment by the developers and any future developers to achieving and maintaining the ambitions aspired to for the development. For example, the developer should be required to the commit to the long-term operation and support of key community infrastructure such as retail and hospitality elements to ensure a liveable 20-minute neighbourhood is achieved and sustained. Too often, provision for such facilities is made but development interests abandon them before the facilities are sustainably embedded in the new community.
In our comments on the West Edinburgh Placemaking Framework, we called for clear statements on delivering very high levels of accessibility including public and active travel routes both to the city, neighbouring communities and to the countryside. Detailed design codes for sub-neighbourhoods are required, which would then form the basis of contracts with developers. These need to be put in place as part of this PPP process to direct any future detailed applications when they come forward.
One good example of a large-scale masterplan incorporating guiding principles of ecology and sustainability can be seen at Hammerby Sjostad in Stockholm. Here, a large c10,000 homes extension to the city was designed and built as a self-contained ecosystem. CaBE wrote it up as a case study in 2006 and this should be available for reference.
A Strategic Approach
This development should be considered not as an extension of Edinburgh but as a new settlement/town. This is due, in urban design terms, to the fact that the area of land is bound by very hard boundaries, not well or easily connected to other areas and very isolated. Therefore, its planning will have to include all the amenities and uses associated with a new settlement/new town and not designed as an extension of Edinburgh which it clearly is not.
The TCPA new settlement network and “Healthy new towns network” may be useful reference points for addition to the WEPF.
Environmental Constraints
There are several significant environmental constraints associated with the framework area key of which are the environmental issues of placing a residential led development adjacent to an international airport. This is not the context of a normal green field site, as aviation pollution and noise can be a health risk and the airport safeguarding requirements can influence the urban design both built form and green spaces.
We are not convinced that these issues have been adequately addressed. Indeed, we have reservations regarding the use of this site for housing in the first place due to its proximity to an international airport.
Connectivity
There are major challenges in forming strategic connections and facilitating public access and linkages to and from the wider context given that the framework area is isolated and bound by hard physical edges including the airport. The difficulties of integrating the tram route with this future development is particularly important as the tram is currently running at capacity. The developers’ assumptions that “there is a tram so everything’s OK” must be fundamentally challenged. The tram system with its fixed capacity will not be able to absorb the levels of patronage that this and other nearby developments will place on it. Similarly, we can see no evidence of a commitment to enhanced bus systems. This needs to be in place from the outset and we would suggest that a legal agreement be required as part of this PPP process requiring the developers (in total) to commit to resourcing this additional capacity for at least a period of 10 years.
Also, critical access travel routes to the Gyle will be essential. The A8/Gogar roundabout poses major barriers in both physical access terms but also in wider integration of facilities. The Gyle remains a key shopping centre for the area. Such edge of development improvements need to designed and assessed by the local authority and legal commitments put in place to ensure that they are delivered.
Heritage and Landscape
There are several historic assets both on and near to the site. The use of the historic assets/environment as a key principle/design tool in the framework is essential. These assets include Castle Gogar (A-listed with its designed landscape), Castle Mains (a scheduled ancient monument) and Milburn Tower (designed landscape).
The design of a strategic blue green network including the possible realignment of the Gogar Burn will be crucial to the success of any major development. The contribution that these make towards positive place-making objectives and climate adaptation is direct. Also, a strategic level approach to other environmental/community facilities is needed including burial grounds, sport and leisure facilities, community growing, play space etc.
Climate Emergency
In general, there does not appear to be sufficient emphasis and weight placed in the application outlining how the development will address the climate emergency. The requirements of NPF4’s emphasis on biodiversity and climate mitigation are not strongly enough articulated.
The concept of embodied/embedded carbon must form a key focus on sustainable construction. The normal palette of concrete and brick materials should be challenged, as these are hugely carbon and energy intensive in production. Net zero should embrace a total development concept, not just operational carbon emissions.
District heating and local energy production should be built into the development aimed at reduction of energy importation into the area. This goes well-beyond passive haus design standards with an expectation that all buildings should aim to be contributors to local grid, not just neutral. For example, all roofs should be solar collectors, extensive use of micro-wind built into the local landscape and linkage with blue networks with ground/water source heat pump distribution technologies.
Place-Making
The Association supported the general thrust of the West Edinburgh Placemaking Framework’s principles, and in particular welcome the ambition to create “a collaborative, multi-disciplinary, master plan led approach to creating a high density, mixed use, urban extension to the city, compact in form with a sense of place and community attractive to residents, workers and visitors.” We appreciate that it is not in scope of this PPP application to address this issue, but we hope that any assessment will require such as masterplan to be produced.
