West Edinburgh Placemaking Framework – Cockburn comments

Posted on: October 18, 2023

West Edinburgh Placemaking Framework support and comments

West Edinburgh Placemaking Framework support and comments

Cockburn Response

Planning background & City Plan 2030

The WEPF specially addresses the City Plan 2030’s Place Policy 16 (PP16)– West Edinburgh.  In our comments on CP2030, we said, “PLACE 16 – West Edinburgh We are concerned with the growth strategies for West Edinburgh and therefore require clarification of the mitigation measures which will address the negative environmental impacts identified in the Strategic Environmental Assessment Environmental Report related to this development expansion.”

NPF4 is currently the primary development plan for Edinburgh until such time as City Plan 2030 is adopted.  The primary objectives of climate change mitigation and biodiversity enhancement in NPF4 need to be fully worked into the proposals.  Our initial reading of the framework suggests some areas of concern resulting from the developments themselves.  This will be addressed below.

Background

The WEPF covers new development proposals in and around Edinburgh Airport and land at West Craigs/Maybury.  It also includes the consented scheme known variously has the “Garden District” or East of Milburn Tower with PPP for 1,350 units.

However, it does not look beyond this or south of the A8.  This framework should be better connected to the wider strategy.  The vision of WEPF should be expanded to include the Gyle and the wider Edinburgh Park Area.  We are aware of proposals to restructure the Gyle Centre akin to proposals at Ocean Terminal.  Also, other western areas of the city are undergoing change on a piecemeal, ad hoc basis.   The WEPF should provide positive connections with these areas, and this will be crucial for its success.

Some approvals and projects in pipeline

Schemes adjacent to WEPF area

Cammo Meadows – 665 homes (approved)

West Craigs – 1,650 homes approved; further extension of NW section (Rosebery estates)for further housing but no application yet.

Edinburgh Garden District/East of Milburn Tower – major Green Belt release with up to 9,000 houses (1,350 consented) with major commercial and office space & up to 1,150 hotel rooms.

SAICA site (aka Maybury Quarter) – Early discussions with presentation to EUDP; no firm scheme but city plan suggests 1,000 houses with new Primary School.

Edinburgh Park (south end) – c.1,750 new homes with commercial and 170bed hotel.

TOTAL – Potential 14,000 new homes

 

WEFP Area (land south and east or Airport bounded by A8 and railway; includes Gogar Designed landscape)

International Business gateway (IBG) phase one – PPP call in with 10000m2 office & 400 homes.

IBG phase 2 or WEST TOWN – shift from mixed-se to  largely residential with no specific housing numbers but can assume c.5000 or so.

Crosswind (Turnhouse runway) – 2500 homes and 43,000m2 commercial with 170-bed hotel.

TOTAL – potentially 7,900 new homes.

 

IBG – Phase one has essentially been granted and includes 400 new homes.  However, the developers have now argued that the wider commercial aspirations of the IBG are no longer viable, so propose a major shift to housing across the later phases.

 

Cockburn Comments

General

The Association believes that a “total development” approach is required, including the fundamental infrastructure of water and waste in addition to net zero and energy generation/conservation. 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 framework document and should have ambitious environmental targets that go beyond current regulatory requirements.

Similarly, it would be good to see ambitious environmental targets being sought through both the creation and ongoing management of this new area of the city. The framework should also have clear statements on delivering very high levels of accessibility including public and active travel routes both to the city and countryside.  Detailed design codes for sub-neighbourhoods are required, which would then form the basis of contracts with developers.

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

The framework and masterplan should be considered as an extension of Edinburgh but as a new settlement/town.  This is due, in urban design terms, by 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.

Connectivity

There are major challenges in forming strategic connections and facilitating public access and linkages to and from the wider context given the framework area is isolated and  bound by hard physical edges including the airport.    The difficulties of integrating the tram route with future development particularly is 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.

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 comparison shopping centre for the area.

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 is insufficient emphasis and weight has been placed in the framework requiring development coming forward to address the climate emergency.  The requirements of NPF4’s emphasis on biodiversity and climate mitigation are not strongly enough articulated in the WEPF.

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.  Nett zero should embrace a total development concept, not just operational.

District heating and local energy production should be built into the WEPF aimed at reduction of energy importation into the area.  This goes well-beyond passivehaus 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

In general, we welcome the importance of establishing clear placemaking guidance.  Greater clarity of the proposed heights and densities is needed as it is unclear in the framework.  More detailed and localised studies and view analyses will be required.  Fundamental to this is the need to ensure a “total development” vision rather than leaving to individual developers and their design teams to determine what is, or is not, acceptable.

We support the general thrust of the place-making 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.”

SUMMARY

There is much to commend in the West Edinburgh Place-making Framework.

The approach to development here should be the creation of a new settlement rather than extension to the existing western fringes of Edinburgh.

A “total development” approach to net zero carbon and energy is required, which includes the embodied energy/carbon of materials rather than just operational targets.  The framework area should aim to be self-sufficient in energy production and generation.  A new baseline for sustainable development needs to be set.

The exploitation of existing heritage and landscape assets to inform development is key, which must also integrate and compliment new blue-green networks.  Increasing biodiversity whilst offering localised climate impact mitigation strategies should also be a strategic objective of development.

Hunter’s Hall Public Park – Common Good Consultation

Posted on: August 9, 2023

A clear community benefit should be identified over and above any improvement to telecoms functionality

A clear community benefit should be identified over and above any improvement to telecoms functionality

Cockburn Response

Picardy Place Central Island design proposals

Posted on: October 5, 2022

We suspect that significant changes will need to be made at key junctions and crossing points

We suspect that significant changes will need to be made at key junctions and crossing points

Cockburn Response

 

 

The Association appreciates the opportunity to examine the developing proposals for the central area of Picardy Place.  We understand that the process is well advanced and the scope for both change and further dialogue is limited.  We are disappointed that this is the case.

We also appreciate that, for the purposes of this specific exercise, the wider context for the central island at Picardy Place is fixed.  The Cockburn is firmly of the view that the current arrangements and disposition of the various movement corridors is significantly deficient, in terms of quality of place and in terms of traffic/movement across the site.

For example, there appear to major congestion issues and modal conflict at the top of Broughton Street, which will only be exacerbated by the opening of the new Trams stop on the north side.  A recent site visit by our Policy & Development Committee counted at least 24 sign poles for traffic regulation.  Similarly, the pedestrian/cycleway conflict at the eastern side by the Playhouse is palpable especially when crowds access and egress the building during performances.

As such, our comments on the central island proposals are in the context of concerns, some very significant, regarding the operation and quality of the wider Picardy Place environment.

Broad concept – a non-civic space

It is inescapable that the environment within which the central island sites is a hostile one.  It remains a heavily trafficked, controlled roundabout designed to cater for high volumes of vehicles with up to four lanes of roadway intervening between the central island and the perimeter footpaths.  Many active travel access points are two-phase crossings.  The new tram stop will introduce sequencing issues for pedestrian and cycle movement (as well as road traffic) which makes access to the area less seamless than needed and more of a barrier.

Although it might be argued that these same characteristics can be found in places like St Andrew’s Square, our view is that the density of traffic and remoteness from active edges suggests that this will not be a successful destination or dwell-space.  Its main function will be to connect active routes across the site to Leith Walk, Leith Street, Broughton Place and York Place.

The central island is a small site, only 0.2ha in area (the size of a large house site).  It is the Cockburn’s view that the central island of Picardy Place does not have the scale or qualities to be destination in its own right.

Looking forward – key objectives

Noting the above constraints, the central island can still provide some positive civic benefits.  The first key objective is the facilitation of effective connections across Picardy Place, especially from the north-west corner across towards the Playhouse and from the tram stop to the main areas of activity especially the St James Quarter and Omni Centre.

Secondly, the provision of cloudburst management and ecosystem services should be the next key objective.  The significant levels of hard ground surfaces in Picardy Place will present problems for water run-off management.  Using the central island to help offset this would be positive.  Relating to this, the provision of planting for both biodiversity and amenity benefits would also be positive.  A link to the planting schemes being developed for the George Street Transformation project could provide some landscape design continuity and might be considered.

Additionally, there are opportunities for space to be used for new statues and cultural displays.  The north-east apex has been earmarked for such, but a recent site visit shows a serious congestion of traffic-control paraphernalia.  Adding to this clutter might not be a good strategy.

Finally, it should be possible to provide some dwell spaces and other opportunities (such as locations for statutes or other cultural edifices) but these will need to be integrated into the access/ecosystem infrastructure as a secondary benefit.

Beyond implementation

In both our assessment of the proposals and the current environs of Picardy Place, we are clear that some potentially significant alterations will be required in the medium term, if not sooner.  As already noted, the junction at York Place/Broughton Street/Picardy Place remains very dangerous in terms of pedestrian and vehicular conflict.  At the same junction, street clutter abounds, with 24 signposts for traffic management clearly visible without taking a single step.

It is our understanding that the space in front of St Mary’s Cathedral encompasses the southern section of Broughton Street and remains usable for vehicles including access for worship, weddings and funerals.  Access to York Lane via Picardy Place is also maintained.  The potential for conflict is considerable and efforts should be made now to add both clarity and safety at his point.  We also think that there is an opportunity to add a new cycle lane at this point, linking the east-west cycleway as it joins Picardy Place to Leith Street/Little King Street running parallel to the road between it and the Paolozzi sculptures.

At Leith Street, the mixture of pedestrian footpaths and cycleways will (does) result in increased conflict between active travel modes.  The narrow footpath outside the Playhouse (the largest capacity venue in the city) results in major congestion at showtimes with crowds spilling over into the cycleway.  There will no doubt be a clear desire line from the tram stop to the Playhouse not catered for in the current layout.  These are some of the issues that will need to be resolved in the future.  The implications for the landscape of central area could be significant, and it might be more effective to consider amendments now rather than later.

Planning Consultation Jock’s Lodge, Edinburgh

POSTED ON September 2, 2022

We acknowledge that this may be a suitable site for student accommodation and that such developments can bring many associated benefits. However, we do not support the current proposals as it stands and, without significant amendments, we are likely to object to the associated planning application when it is lodged.

We acknowledge that this may be a suitable site for student accommodation and that such developments can bring many associated benefits. However, we do not support the current proposals as it stands and, without significant amendments, we are likely to object to the associated planning application when it is lodged.

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Planning Consultation Jock’s Lodge, Edinburgh

Posted on:

We acknowledge that this may be a suitable site for student accommodation and that such developments can bring many associated benefits. However, we do not support the current proposals as it stands and, without significant amendments, we are likely to object to the associated planning application when it is lodged.

We acknowledge that this may be a suitable site for student accommodation and that such developments can bring many associated benefits. However, we do not support the current proposals as it stands and, without significant amendments, we are likely to object to the associated planning application when it is lodged.

Cockburn Response

Short Term Lets 2022 – consultation 2

POSTED ON August 3, 2022

It is essential for the Council in implementing this regime to ensure that adequate resources are made available for its effective operation. Coordination with Police Scotland on enforcement and the reporting of complaints will be an important to the management of the system and should be made open and transparent.

It is essential for the Council in implementing this regime to ensure that adequate resources are made available for its effective operation. Coordination with Police Scotland on enforcement and the reporting of complaints will be an important to the management of the system and should be made open and transparent.

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Short Term Lets 2022 – consultation 2

Posted on:

It is essential for the Council in implementing this regime to ensure that adequate resources are made available for its effective operation. Coordination with Police Scotland on enforcement and the reporting of complaints will be an important to the management of the system and should be made open and transparent.

It is essential for the Council in implementing this regime to ensure that adequate resources are made available for its effective operation. Coordination with Police Scotland on enforcement and the reporting of complaints will be an important to the management of the system and should be made open and transparent.

Cockburn Response

Tenement properties – comments on options proposed

The simplest regulatory approach is option 1, being a universal position of the unsuitability of tenements for commercial uses such as STL. Tenements have many different forms in the city, and it is important to understand that ‘tenement’ refers not to an architectural type but to a form of tenure of vertical ownership (refer Tenement Scotland Act).

We would suggest that for clarity, the policy includes main door flats in tenements as well, as these tend to have direct access to private garden spaces which hold a premium for family accommodation in the city. Given that option 1 allows an owner to challenge a decision, this ensures fairness in the decision-making process. Guidance on what might be accepted as a rebuttal presumption might be helpful.

We do not support option 2 for several reasons. Firstly, there are many properties in the city where all, or almost all, flats are used for STL uses. In these instances, the vested interests of operators would suggest no real independence in terms of policy presumption. Secondly, it is not clear enough to address situations where only one or a minority of owners object to the granting of a licence where other STL operators might support. This would need a clear presumption in favour of residents even if they are in the minority. Thirdly, it might be expected that an applicant would suggest an exemption based on hardship or other personal circumstances which if accepted, results in negative impacts on others. Fourthly, it might result in undo pressure being placed on owners to consent. Fifthly, there are buildings in the city where all the flats are owned/managed by a single operator who would effectively be arguing for their own applications to be approved. Finally, there a consent process might need to be extended to tenants as well, and not just owners, as they would experience any anti-social behaviour that might result from a STL in a common stair

Overall, no specific instance in option 2 cannot be remedied by the rebuttal process suggested in option 1.

Home letting– proposals to set limitations on number of nights

To be consistent with the current planning regulations and temporary uses, a maximum of 4 weeks (28 days) should be set as the limit. However, we accept that there might be instances where home letting for longer periods might be required (eg. an owner has work contract in another location for, say, 3 months, or has a job that requires work a remote location on a regular and timed basis such as a worker on an oil rig. In such instances, rebuttal presumption enabling an applicant to justify why their application should be granted as an exemption to this policy is reasonable where they can demonstrate personal circumstances.

Licensing policy – comments on proposed policy

It is essential for the policy to set out very clear management criteria for STL operations as to what is acceptable and what is not. Notice of Application – there are issues with the current notification process for hospitality businesses in that the posting of an application notice by the applicant “on or near” the premises is too vague. Given the potential impact on neighbouring properties, we believe that adjacent properties should be notified separately much akin to the Neighbour Notification procedures for planning consent, albeit with the responsibility placed on the applicant’s shoulders to ensure the information has been distributed. Evidence of this included in the certificate required (para 4.5).

Temporary exemptions – comments on proposed policy

It is a feature of the events and tourism industry in Edinburgh that large numbers of visitors enter into the city at any given time, whether for a Festivals or sporting events like the Six Nations Rugby. As such, it should not be necessary for many temporary exemptions to be permitted. However, if so, then we agree that they should be subject to the same mandatory and additional conditions as other applications.

Additional licence conditions – comments on proposals

If the licencing regime permits STL in tenements, the issue of density of use and the vertical disposition of rooms becomes an issue. Significant problems arise with STL when communal areas are used as sleeping spaces through the use of sofa beds, etc. This was recognised in the early consultations by the Scottish Government and we feel that this should be something included in the licencing application assessment especially if information such as a layout plan is required (ref para 4.2). This is less of an issue if STL are not permitted in common stairs.

Enforcement – any regulatory/licencing scheme is only as good as the enforcement given to it. The Policy must set out firm and clear guidelines on compliance and enforcement and include provisions when a licence might be revoked due to substantial or continual breaches of regulations. Whilst this is highlighted in para 4.41, threshold criteria should be considered for clarity. For example, a set of guidelines on what might constitute a variation, suspension of revocation of a licence would be helpful to both operators and neighbours alike – something like three complaints for disturbance to the Police would result in an enforcement action.

Enforcement fees – we have no objection to the proposals set out in para 4.38. However, we advocate a sliding fee scale for repeat offenders – other property-based and host – rising with each enforcement action that takes place.

Conditions – Overall, the Cockburn finds the additional conditions sset out in Appendix 2 acceptable. However, we offer the following comments on some specific points.

  • STL 3 suggests that hosts must provide a key-holding service when guests arriving between 9pm and 7am. We understand the reasoning for this, but disruption can occur outside these hours. Also, if tenemental properties are not to be used for STL purposes, then the significant impact of out-or-hour access is obviated.
  • STL5 – we welcome the requirement for hosts to take reasonable steps to deal with anti-social behaviour. Guidance on these ‘reasonable steps’ should be prepared and included in each STL property, setting out some basic requirements for guests. This links to STL 7 as well.
  • STL 6 – Key boxes. Again, if STL are to be permitted in tenements, specific guidance is required. In this instance, consent must be required from all proprietors without exception.
  • STL 7 – In addition to the points made in the conditions, license holders should also be required to ensure that the use of a STL property should not disturb the right of neighbours to enjoy their properties peacefully.
  • STL 11 – We are not clear on the purpose of the condition to insist on carpeting of rooms in secondary lets. If it is for the purposes of sound insulation, acoustic underlay is more important. Again, some guidance and technical specifications for material might be useful.

Additional Comments

It is essential for the Council in implementing this regime to ensure that adequate resources are made available for its effective operation. Coordination with Police Scotland on enforcement and the reporting of complaints will be an important to the management of the system and should be made open and transparent.

Finally, the register of licences STLs should be made public with a searchable archive.

Leith Links Masterplan

Posted on: July 28, 2022

Overall, we welcome the creative thinking and general approach taken. As a Masterplan, we
appreciate that considerable detailed development still needs to take place, and we offer the
following comments to this end.

Overall, we welcome the creative thinking and general approach taken. As a Masterplan, we
appreciate that considerable detailed development still needs to take place, and we offer the
following comments to this end.

Cockburn Response

The Cockburn has taken this opportunity to examine the Leith Links Masterplan and in doing so,
offer our whole-hearted support for the project and its continued development. We note that the
current condition of the Leith Links is less than optimal and that development pressures within Leith
will add future pressures to this important recreational and greenspace. The proposed Masterplan
provides the opportunity to address these issues.

Overall, we welcome the creative thinking and general approach taken. As a Masterplan, we
appreciate that considerable detailed development still needs to take place, and we offer the
following comments to this end.

The summer of 2022 illustrates the critical need to build climate resilience into the design. Climate
adaptation measures will be critical to the longer-term success and must be built into the project at
all stages. For example, the proposed blue zones need to be able to respond to major cloudburst
events as well as provide opportunities to reduce water requirements for operational needs.
Assumptions of "parkland" also need to considered. Whilst playing fields need to be regularly
mown, other grassed areas would benefit from less intrusive management methods – ie a shift from
manicured lawns to more biodiversity-friendly meadows. How this is achieved in the context of
increasing recreational demand will be a challenge.

We also feel that maintenance and repair budgets and approaches requires to be built into the
management plan in the long term, thereby ensuring a rapid response to any damage caused by use
or climate. This would require a firm set of policies for temporary events or heavy infrastructure
activities, which if allowed, require forward planning.

Finally, the curation of the landscape, from a nature perspective as well as a historic one, will be
essential. Innovative ways of interpreting the Links should be explored and go beyond the usual
information boards and plaques, however good these will be.

In summary, the Association welcomes this masterplan and supports its development into the
future.

Fountainbridge

Posted on: July 22, 2022

It is positive to see that a comparatively  high level of greenspace and public space has been included and the proposals seem to work with  their canal-side location

It is positive to see that a comparatively  high level of greenspace and public space has been included and the proposals seem to work with  their canal-side location

Cockburn Response

 

 

This is a  comparatively detailed and well-presented consultation which gives a good idea of proposals underdevelopment for the regeneration of a remaining, major brown field site.

We note that the proposals include a  residential element, shops, social enterprise, and community spaces with high quality public realm as well as a 100,000 square foot office building.

These proposals represent a considerable concentration of development on this site. But it is positive to see that a comparatively  high level of greenspace and public space has been included and the proposals seem to work with  their canal-side location quite positively. And it is also encouraging that the developers  have engaged with community representatives.

We look forward to seeing these proposals in more detail.

Image: Consultation website

Harbour 31

Posted on: July 21, 2022

This project has significant positive aspirations for its impact on Leith. However, the materials provided for this consultation are very not comprehensive or detailed and so are of limited usefulness in facilitating  a meaningful assessment of the current proposals.

This project has significant positive aspirations for its impact on Leith. However, the materials provided for this consultation are very not comprehensive or detailed and so are of limited usefulness in facilitating  a meaningful assessment of the current proposals.

Cockburn Response

This project has significant positive aspirations for its impact on Leith. However, the materials provided for this consultation are very not comprehensive or detailed and so are of limited usefulness in facilitating  a meaningful assessment of the current proposals.

Very little detail is provided relating to design and tenure of proposed residential areas or of  the design of  the proposed non-residential elements of the  development.

Very little detail is provided on the design and character of the proposed greenspace and public space elements including how the location’s foreshore/dockland potential is being actively exploited.  And it is disappointing to see no evidence of the potential being acknowledged for biodiversity improvements on the foreshore and in the docks e.g.  floating islands.

We would also  like to see more  detailed Information relating to proposed new  vehicular routes through the site and to active travel opportunities and connectivity  to and through the new development.

Many large scale developments are planned for Leith or are already under way. Further information is required to understand the actual or potential relationship between Harbour 31 and these developments.

We would also like to understand how this development is responding proactively to  the worsening predications for Edinburgh relating to climate change, particular sea-level rise, and its potential negative impact on this dockland development.

Finally ,in our view a revised masterplan/sustainability strategy for the Leith area is an urgent priority.

Image: Consultation website

National Planning Framework 4

Posted on: March 31, 2022

Our response to the Scottish Government consultation on its NPF4 draft document

Our response to the Scottish Government consultation on its NPF4 draft document

Cockburn Response

(The following is a summary of our response to this consultation, read or download our full submission HERE).

These comments have been developed from substantial debate and deliberation led by the Cockburn’s Policy & Development Committee as well as in discussion and collaboration with the Edinburgh Civic Forum, which is a network organisation of over 100 civic groups, amenity societies, residents’ associations and community councils within the City of Edinburgh Council area.  The Forum is administered by the Cockburn Association.

The Cockburn Association acknowledges the challenges in making a national spatial strategy relevant on a local level.  It believes that the strategy, policies and projects that derive from the Framework will have a direct impact on local decision-making and local place-making.

Our main area of interest is the Central Urban transformation section of NPF4 and other areas of specific interest to Edinburgh – both city and city region.  In addition, we have taken special interest in Part 3 of Framework, covering the National Planning Policy Handbook.  Comments on Part 3 are covered is a separate document.

Overall, the Cockburn Association welcomes the general thrust and overall sentiment of NPF4.

In particular, the strategic ambitions to pioneer low-carbon, resilient urban living; reinvent and future-proof city centres; accelerate urban greening; rediscover urban coasts and waterfronts; reuse land and buildings; invest in net zero housing solutions; grow a wellbeing economy; reimagine development on the urban fringe; and improve urban accessibility are welcome.

Against this support for the generalised strategic thrust of NPF4, we are concerned with the lack of evidential assessment of delivery of NPF3.  Without very clear analysis of the success or otherwise of NPF3, it is very difficult to consider the likelihood of success of NPF4.  Also, whilst the positive rhetoric and narrative is compelling, polices and strategies are generally too caveated in terms of precision and language to give confidence in delivery.

In general terms, there is a lack of clarity on several key issues such as those noted below.

  • Growth model and approach seems incompatible with zero-nett carbon/climate mitigation requirements, community wealth-building and other policy drivers. It is not clear how these potentially conflicting policy drivers are aligned to ensure support rather than conflict.
  • No explanation in spatial or geo-political terms of the emphasis on Edinburgh City Region for population growth and enhanced development proposals, especially housebuilding. Edinburgh City is expected to deliver almost double the number of new houses as Glasgow (41,300 v 21,300) which rises to almost 3.5 times across the Edinburgh City Region (c.75,000). The linkages to infrastructure needs, land-use conflict (eg Urban Edge/Green Belt issues) and sustainable travel are not explored and are, in part, contradictory.
  • Circular economy needs to focus more on Community Well-being and less of waste management. The core principles of “reduce, reuse and repair” are not strongly articulated across all aspects of the Framework.  There is an opportunity to create far better connections between the circular economy, zero waste ambitions and the planning system.  Policies should make more of positive carbon capture and management.
  • Tourism features as an important sector for NPF4 to address. We would advocate that this policy should shift the emphasis towards ‘responsible tourism which amongst other things, seeks to minimise negative economic, environmental and social impacts; and generate greater economic benefits for local people and enhances the well-being of host communities.  In this regard, we find the emphasis on Cruise tourism on the Edinburgh Waterfront national project unsupportable.

Delivery

NPF4 is very light on the “how” as opposed to the “what”.  It is also couched in a language the weakens delivery in terms of policy commitments.  For example, strong statements like “‘We must embrace and deliver radical change so we can tackle and adapt to climate change” are undermined by non-directive words such ‘Encourage’ when referring to low- and zero-carbon design.’  The preparation of a National Action Plan with clear allocation of resources to achieve the strategies and policies contained within NPF4 will be required.

Edinburgh-specific issues

Although we appreciate that NPF4 is a national strategy and not meant to cover the ground occupied by Local Development Plans and strategies, it is a material consideration in planning matters and will have considerable influence.

We welcome that statement in the Framework, “as a capital city with a World Heritage Site at its core, it will be crucial that future development takes into account the capacity of the city [of Edinburgh] itself and its surrounding communities and makes the most of its exceptional heritage assets, places and cultural wealth.”  In making this workable, it is therefore essential that an analysis of what is meant by “capacity” and how it is measured and defined is developed as part of NPF4.  The concept of carrying capacity is embedded in ecosystem analysis but has not been developed as a useful tool for urban management.  There is a very positive opportunity to create such a policy tool here which should be grasped, otherwise this statement will be little more than positive rhetoric.

We have already mentioned concerns about the emphasis of the Edinburgh City Region for population growth and housing building.  The City of Edinburgh is expected over the next 10 years to accommodate an additional 41,300 new houses with the wider City Region taking 75,800.  In comparison, Glasgow City is required under NPF4 to take on 21,300.  There are concerns that this could lead to overdevelopment and might well undermine the delivery of related Scottish Planning Policies such as prevention of loss of prime agricultural land or Policy 29 on Urban edges and Green Belt, which will be subject to consider pressure from the private market-led housebuilders who might exploit this quantitative target as a means of justifying loss of prime land or Green Belt.

Strategic Approaches and Projects

In our internal and external discussion, the Cockburn has articulated these seven areas of strategic land-use or resourcing issues that should have greater emphasis in the framework or needs to be included as a major issue.

Maintenance & Repair as National Strategic project – the need to ensure existing places are fit for purpose and resilient completely missed in NPF4. It has been estimated that 72% of the buildings in the historic centre of Edinburgh are in need of significant repair due to a backlog of neglected maintenance work and the cost of basic road maintenance (potholes) is estimated to now cost £71m.  Keeping our buildings and neighbourhoods in reasonable condition should be a firm objective of this Framework.

Sea Level rise as impact from Climate Change needs to be considered as a strategic land-use constraint in Spatial Strategy.  The recent IPCC Report has suggested that it is now a matter of when, not if, that sea levels will rise.  There is no indication of this significant issue featuring as a major land-use challenge.  In supporting the development of Edinburgh’s Waterfront as a national development, it is essential for this to be factored into it.

Housing (Quality) – concern with emphasis on Built to Rent; no quality initiatives other than bland statements and reliance on Place Standard.  Cost of Living pressures and affordability not addressed.  Need to increase internal space standards and internal/external spaces to cope with emerging blended work patterns.  Over reliance on commercial housebuilding sector to determine market need and land-use determinations suggests need to review definition of effective land supply.

Housing (Quantity) – major concern is concentration on City of Edinburgh/Edinburgh City Region for housing expansion with too great an emphasis on peripheral, suburban housing types.  Weak links to infrastructure first approach.  Lack of regional planning framework to ensure coordination.  Poor link to 20-minute neighbourhood concept.  Need to increase delivery of affordable and social house types in Edinburgh which suggests a different approach to the current market-led model.  Current 25% threshold should not be reduced.

Food Security and Food deserts – Will be a significant issue in plan period; prefer an outright ban from using prime agricultural land for development, which implies fundamental review of spatial strategy within Central Urban Transformation area.  Need to emphasise localism and links to poverty and food.

Energy Security – greater emphasis of integration of “passive house” standards in all housing developments; innovative renewals rollout including PV, micro-wind, etc. Development of Heat Networks as key national project.

Resources to deliver – there is no denying the fact that financial pressures on local authorities will inhibit delivery.  The City of Edinburgh Council is one of the poorest resourced in Scotland, yet it is expected to shoulder significantly higher levels of national developments than others.  Good planning requires adequate resources.  National resources might be allocated to assist in upskilling planning authorities especially in areas of carbon management and climate preparedness.

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Slavery and Colonialisation Review Consultation – Comments 19 January 2022

Posted on: January 19, 2022

Our response to the Council’s Legacy of Slavery and Colonialism consultation exploring Edinburgh’s slavery and colonialism legacy.

Our response to the Council’s Legacy of Slavery and Colonialism consultation exploring Edinburgh’s slavery and colonialism legacy.

Cockburn Response

The Cockburn Association welcomes this review and the work of the review group chaired by Professor Geoff Palmer.

This is a complex and challenging subject and has, in part, been driven by debates on the role of Henry Dundas, Lord Melville played in the abolition of slavery in Scotland and the international Black Lives Matters campaign fuelled by the killing of George Floyd in America.  The events in Bristol with the toppling of the statue of slave trader Edward Colston and subsequent trial has highlighted many issues associated with subject. However, here in Edinburgh, the issues are much wider and more contemporary than the case of Dundas.

Furthermore, we also need to acknowledge that slavery, in all its modern-day forms, continues. British companies and institutions may still be exposed to current slavery practices in their operations and supply chains both at home and abroad, the most common of which in contemporary society are forced labour, child labour and debt bondage.

The Review should aim to set in place a process that fills in gaps in the received history of the city, and in doing so reconciles past and present by recognising the contributions to Edinburgh’s development and prosperity made by people who were enslaved or colonised. Equally, it is important to recover and celebrate the voices of those who contested the institutions and individuals that sustained the injustices. The legacy of slavery and colonialism is multi-faceted and enduring, and the Review should be seen as a way of beginning to engage fully with it.

The Cockburn is also aware of other related challenges in the interpretation of people and events.  The stellar work the Witches in Scotland group highlighting the huge miscarriages of justice, and the writings of Sara Sheridan on the lack of public commemoration of women in Edinburgh are but two.  Therefore, we believe that the Slavery and Colonial Legacy Review should be considered as a catalyst for a new wider and inclusive reflection of the history of the city.

The Cockburn comments in the review consultation will concentrate on the wider principles and processes.  An evidential approach focusing on awareness, communication and education about the history and key issues is the best way forward.   In doing so, we will not address individual or specific issues regarding particular monuments or place names other than to argue that any proposed changes should be subject to a public consultation and education processes supported by a strong evidential basis.

In all of this, the need for recognition of the positive contribution to Edinburgh that many persecuted individuals and groups have made should be an objective. This is a forgotten and hidden history and the lived experience of the many, many individuals who through slavery and colonial oppression were forced to contribute to the development of Edinburgh, and wider Scottish society, remains, for the most part, deeply buried. In fact, the ways in which this forgotten history has been hidden and suppressed, and the reasons for this, are also something worthy of examination and exposure to contemporary scrutiny.

To facilitate this ongoing process, we suggest the following as our contribution to this current consultation:

  • Establish a centre of research and reconciliation supported by CEC and academic institutes to carry the work forward looking not only at major individuals, events, networks and institutions based in the city, but also at ways in which the general public were impacted by slavery and colonialism. An additional role should be to monitor current trends in the city to ensure that all citizens are benefitting from what Edinburgh offers.
  • Create a museum / interpretation centre on the theme of justice, preferably by reusing an existing building that had links with slavery and colonialism, such as the Custom House in Leith. It would highlight slavery and colonial issues, as well as other societal issues such as witchcraft, historic abuse of women and children etc., while also recognising those resisting such practices, and highlighting their relevance today.
  • Work with schools to help learners become aware of these issues.
  • If the current consultation and subsequent Review Report suggests there is a case for changes to monuments and/or place names, views should also be sought from local community and civic groups as well as any other representative or specialist groups, recognising practical issues that might be involved (e.g. changing a street name will have consequences for postal addresses, etc). Similarly, where monuments or buildings have listed or scheduled status, consideration will need to be given to whether that status needs to be reviewed or amended.
  • An interpretation policy using all modern techniques to highlight the issues and injustices should be established. This would need to include a prioritisation system (which is a major challenge).
  • Host an international conference/online event connecting Edinburgh to places overseas that were linked to the city through slavery and colonialism, to better reveal the legacies.

In summary, the Cockburn would encourage the Review to recommend a number of practical steps designed to fill gaps in past understandings of Edinburgh’s history by promoting rigorous research, and to identify ways to share that new understanding widely.