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
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
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.
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.
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.
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.
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.
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.
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.
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.
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.
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
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
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.
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
Our response to the Scottish Government consultation on its NPF4 draft document
Our response to the Scottish Government consultation on its NPF4 draft document
(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.
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.
View our full submission by clicking the box below.
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.
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:
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.
Our detailed response to City of Edinburgh Council’s consultation on CityPlan 2030
Our detailed response to City of Edinburgh Council’s consultation on CityPlan 2030
Whilst there are many aspects of City Plan 2030 that we welcome and support, we find that it is weakest in those areas of greatest importance, namely Climate impact and preparedness, Covid and post-Covid resilience and Brexit where the implications of leaving the EU over the plan period are not considered and the implications to economic prosperity with a probable change in relative importance of certain sectors and approaches.
These omissions seriously weaken the Plan’s robustness and resilience especially in the later years of its life. The Cockburn therefore calls for meaningful revisions and policy statements on how the LDP will tackle these most significant of issues facing the city.
Edinburgh needs a City Plan which is fit for purpose not just at the beginning- period of the plan but also at its end-period. Therefore, the plan’s aspirations, outcomes and policies need to be in the language and aspiration of tomorrow not just in the language of today.
Sustainable Carbon Neutral city (paras 2.28 – 2.32)
Further to our general comments, we believe that the framework for this policy subject is narrow and lacks any serious credibility. Land-use policy will need to change radically if net-zero carbon targets are to be met, including presumptions of growth and regional support and development.
The Cockburn calls for an examination and explanation of how this plan and its policies will directly influence this objective rather than a discussion on other legislative or statutory frameworks.
Well-being and Equalities
The unsubstantiated comments here on how the plan improves well-being is a strategic weakness of it. There is no strong indication of how public health and land-use planning will be framed in this plan, with unclear statements of the roll of 20minute neighbourhoods as a mechanism for achieving this. The Cockburn asks for much greater clarity and depth of initiatives to be set out here, so that policies can be judged against this most important objective.
In general, we welcome the proposed outcomes outlined in City Plan 2030. However, in many sections, there is no clear statement of outcome which undermines the usefulness of this section and weakens a focussed delivery of the plan. We offer some comments and observations below.
Built Environment (2.45-46)
No outcome statement is offered. The Cockburn suggests that a commitment be given that Edinburgh’s unique urban landscape will be improved through active conservation policies and innovative design policies so that the qualities of the city are improved by the end of the plan period.
World Heritage Site (2.47-48)
We recommend that commitment be given that the Management Plan for the WHS will be a material consideration (not “may”).
Listed Buildings, Conservation Areas, Archaeology, etc
We welcome the statements made here in City Plan 2030. Again, we would advocate a firm outcome statement to the effect that the city heritage assets will form a key part of the delivery of the plans economic and environment policies and the Plan commits to improvements to all assets where possible.
We would also advocate that an outcome statement makes clear that proposals affecting heritage assets and Conservations Areas considered by non-planning mechanisms such as Traffic Regulation Orders will be required by City Plan to meet the policy objects set out within it.
Green Belt (2.58-60)
The Cockburn welcomes the commitment to no new Green Belt releases in this plan period.
Countryside (2.61) and Blue-Green Network (2.62-64)
The Cockburn has concerns with some of the land removed from Countryside Policy where it pursues development proposals on the western approach corridors. In terms of meeting its net-zero carbon strategy, the loss of any green space should be avoided, and the policy commitment to protecting countryside land needs to be strengthened.
To this end, the Climate Change Risk Assessment referred to in 2.64 is crucial. The Cockburn supports the wider ambitions to develop and reinforce the Blue-Green network across the city. To this end, a new policy advocating protection of private green spaces such as the large, treed gardens in the inner suburbs should be established, enhancing existing policies.
Housing
Our comments will be covered under consideration of specific policies. We note the quantitative analyse of housing need and suggest that the narrative around growth and operational carbon requirements needs to expand to include embedded carbon and wider sustainability issues.
Qualitative assessment and outcomes for housing are largely missing, however. The Cockburn believes that the spatial standards for new housing must improve if the city is to build resilience into a post-Covid recovery city, where more and more home-working if likely to feature. The UK has some of the meanest space standards in Europe. We therefore advocate additional policies to be developed to enhance the existing array including the better minimum spatial standards and increased outdoor space for well-being and active family environments.
Sustainable Energy (2.129-129)
The Cockburn believes that it is essential if we are to meet the net-zero Caron Strategy by 2030 that we move beyond a simple operational carbon/energy perspective of development and shift to a total carbon/energy assessment, taking into account life cycle costing and embodied energy in materials.
We also believe that new building including mass housing should include renewable generation technologies within the fabric, evidenced at the point of consent. Thus, the Cockburn advocates additional policies on the sustainability of building materials and building technologies as well as a policy on renewable energy generation in all new developments.
The Cockburn offers comments on some but not all place-based policies.
PLACE 1 – City Centre and Waverley Valley
The Cockburn is broadly supportive of the Ciy Centre transformation project and its various proposals. We do have concerns with renewal of the Ross Bandstand and other facilities in West Princes Street, and do not support the radical redevelopment vision of the Ross Development Trust to create a 4-6,000 seat venue in the heart of West Princes Street Gardens. A number of ENV policies are relevant so this policy should be amended to include reference to other policy objectives such as protecting the special characteristics and outstanding universal values.
PLACE 2 – Fountainbridge
We are broadly supportive of the policy here, although we would strongly recommend an additional statement supporting the vertical integration of uses in each development area. Large, mono-use blocks should be avoided. The policy should therefore be amended to encourage this.
PLACE 3 – Astley Ainsley
In general, we are supportive. However, the first bullet point should be amended from “respects the mature landscape setting of the site” to “preserves the mature landscape setting of the site”. This is to ensure that any development starts from the objective of conserving the character of the site.
PLACE 4 – Edinburgh Waterfront
We are increasingly concerned with the quality and quantity of development that is being placed in this policy area. To this end, we do not support the first bullet point “comprehensively designed proposals which maximise the development potential of the area” in that maximising the development potential should not be a policy objective. Instead, this might be merged with the second point – “provision of a series of mixed-use sustainable neighbourhoods that connect to the waterfront, with each other and with nearby neighbourhoods” – to emphasise that the delivery of sustainable neighbourhoods is the primary objective and one consistent with the 20 minute neighbourhood ambition.
Western Harbour and Central Leith Harbour policy areas need to fully explore the impact of rising sea levels on the suitability and feasibility of development. This should not be considered as a remote possibility but integrated into a revised set of land-use allocations that actively plan for increased storm surges and sea-based flooding. The statement carry out a flood risk appraisal to inform the design and layout of development proposals is wholly inadequate in this regard and objectionable as a result.
Granton and Granton Waterfront – we are broadly in agreement with the principles, subject to the above comment on sea levels. We welcome the development principle to create a new Coastal Park, but concerns with the principle Some small pavilion buildings and a larger focal building could be accommodated within the coastal park to provide places to meet, eat and enjoy activities, as these may eroded the positive values of the park in the first place. Also, it would be likely that these would displace activity better directed towards existing businesses. We therefore ask that this be amended.
PLACE 5 – Crewe Road South
This represents a significant development opportunity within the city. We welcome the statement to Make iterative use of Townscape and Visual Impact Assessment to identify footprint, height and massing of built form, respecting existing townscape, landscape and conservation area setting and surrounding residential character. We feel that this might be strengthened to ensure that the TVIA precedes any development proposal of scale coming forward with the aim of ensuring the deliver of this element.
Existing trees should be protected as a matter of principle. We would also advocate the removal of large areas of hardstanding where not required and their return to green space. Substantial levels of new tree planting should form part of any development masterplan.
PLACE 7 – Stead’s Place & Jane Street
We welcome the commitment to retain the 2-storey building at 105 Leith Walk. The plan does not reflect the proposed extension of the Leith Conservation Areas which proposes to add the former railway embankment and bridge abutments into the area, which we support. We would strongly advocate a unified urban design framework be prepared to ensure the architectural and streetscape coordination of any new development coming forward. The haphazard approach of allowing developments to come forward without an integrated vision is apparent in the nearby area.
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.
PLACE 17 – Edinburgh Airport
As with PLACE 16, we have concerns regarding the expansion of development in the airport area. Clarification of the mitigation measures which will address the negative environmental impacts identified in the Strategic Environmental Assessment Environmental Report is required before this policy should be adopted.
PLACE 30 – Redford Barracks
Overall, we welcome the general principles for the repurposing of this site. However, all existing green spaces should be retained and enhanced for public and climate mitigation benefit and all existing trees should be protected as a matter of principle. We would also advocate the removal of large areas of hardstanding where not required and their return to green space. Substantial levels of new tree planting should form part of any development masterplan.
In general terms, the Cockburn supports the policies as set out in this section of City Plan 2030. We offer a number of specific comments on individual policies, as indicated below.
ENV2 Co-ordinated Development – Whilst we support this policy, it should be amended to not just ‘encourage’ but ‘require’ conformity to this objective. Thus, advocate a rewording to “The Council requires a comprehensive approach to redevelopment and regeneration wherever possible, and the preparation of development frameworks, master plans, Development Briefs or Place Briefs to identify the full design potential for creating successful places.”
ENV5 Alterations, Extensions and Domestic Outbuildings – this policy should include an explicit indication against the development of front gardens for private car parking on the grounds that it damages character and affects streetscape.
ENV7 Sustainable Developments – We welcome the new policy requirement assess the embodied energy and life-cycle analysis of construction. However, we object to the caveat for proposals involving the replacement of existing buildings the proposals should be accompanied by a carbon assessment setting out the ‘whole-life’ carbon footprint of the proposed development compared to the option of re-using the existing building to accommodate the proposed use. Where this comparative assessment fails to show an overall lower carbon footprint then it must be set out why the developer considers the proposal justified, for example because the new development provides additional floorspace and/or dwellings compared to the existing building. The reasons for possible justification are spurious and unacceptable in the context of the purposes of the policy and would largely negate the reason for carrying out a carbon assessment in the first place.
ENV 5 – Alterations, Extensions and Domestic Outbuildings
This policy should include an explicit indication against the development of front gardens for private car parking on the grounds that it damages character and affects streetscape.
ENV 7 – Sustainable Developments
We object to the caveat for proposals involving the replacement of existing buildings* the proposals should be accompanied by a carbon assessment setting out the ‘whole-life’ carbon footprint of the proposed development compared to the option of re-using the existing building to accommodate the proposed use**. Where this comparative assessment fails to show an overall lower carbon footprint then it must be set out why the developer considers the proposal justified, for example because the new development provides additional floorspace and/or dwellings compared to the existing building.
The reasons for possible justification are spurious and unacceptable in the context of the purposes of the policy and would largely negate the reason for carrying out a carbon assessment in the first place.
ENV8 New Sustainable Buildings – We support this policy but ask for clarification of the linkages between this policy and other policies within the plan which support and promote environment, social and economic sustainability.
ENV 9 – World Heritage Sites – We support this policy but advocate an amendment to the wording of para 3.108 requiring reference to the Management Plans in place rather than merely suggesting they should be referred to. The purpose is to ensure awareness and compliance in all developments affecting WHSs in the city.
ENV13 Conservation Areas – Demolition of Buildings – We continue to support this policy. However we are concerned with the subtle dilution of it in comparison to the current LDP policy, which makes indicates that where a building is proposed for demolition and it makes a positive contribution to the character or appearance, Policy ENV10 Listed Buildings – Demolition applies. This adds clarity to the policy and grounds the assessment in national policy. We strongly advocate this change.
HOU1 Housing Development – In some instances, the sites allocated are not genuine effective housing sites as constraints may mitigate against development. We would therefore advocate that the policy makes clear that in addition to the statement “Development should accord with the Place
Polices and development principles set out in Place 1-Place 36 and Appendix D” that development should also be accordance with the other policies as set out in the plan. This is remove any doubt.
HOU 2 Affordable Housing – In supporting this policy, we suggest the deletion in para 3.193 of the phrase “or as far as possible” which refers to providing 35% affordable housing for developments over 12 units in scale. The need for affordable housing over the plan period is very clear and should not be delighted by caveats that suggest otherwise.
HOU 4 Housing Land Supply – We do not support this policy as the wording suggests that it may be used as a ‘trojan horse’ for development of greenbelt land. The allocation of housing numbers includes a 20% Generosity Allowance over and above that required. No further allocations should be accepted.
HOU 6 Student Accommodation – The Cockburn is unsure about this policy. Whilst we accept that there is some need for additional accommodation, the policy provides no position on over-provision in areas of existing concentrations of student housing. We would therefore advocate a return at a threshold policy as used to exist in previous LDPs.
We also query the suitability of a area-based threshold in the context of housing and affordable housing provision. A threshold based on numbers and density might be better. The design of student accommodation should be capable of adaption to mainstream housing in order to ensure long-term carbon benefits and greater flexibility in changing circumstances. This should be built into this policy. Finally, we ask for clarification of the criteria with will be used to determine no adverse impact on established character of an area.
HOU 7 Loss of Housing – We welcome and support this policy. However, we would advocate a policy statement in enforcement in areas of significant STL concentrations which have no consent. Also, the policy should include the proposed STL Control Area currently under consideration and outline a policy-basis for considering Change of Use applications associated with it.
Hou 8 Inappropriate Uses in Residential Areas – We welcome this policy and its stated intention. However, we would advocate the retention of the policy in the existing LDP HOU7 which states, “the intention of the policy is firstly, to preclude the introduction or intensification of non-residential uses incompatible with predominantly residential areas and secondly, to prevent any further deterioration in living conditions in more mixed-use areas which nevertheless have important residential functions. “ This provides greater clarity for decision-making and reinforces the need to support housing in mixed-use areas.
INF1 Access to community facilities – Whilst we support this policy, the facilities and infrastructure referred to in para 3.203 needs to be considered in separate guidance and open to public consultation.
INF5 Location of Major Travel Generating Development – We support this policy but ask that clarification of what criteria to be used to determine ‘very good accessibility by sustainable transport’ be included in the plan.
INF9 City Centre Public Parking – Further clarification of provision for accessible parking is required.
Econ 1 Supporting inclusive Growth, innovation and culture – We support the intention of this policy subject to inclusion of a reference to lifelong learning. We particularly welcome the requirement that “Developers will have to demonstrate that proposals are not just associated with the five key criterion but meet other relevant LDP policies such as heritage and environmental policies.”
Econ 6 Hotel Development – We do not support his policy. Clarification is required on the relationship between the objectives of Econ 6 and those of Econ 2 for which seeks to ‘create sustainable communities, maximise opportunities for housing and avoid large mono use developments”. We also note that in February 2020, the Edinburgh Hotel Association reported an oversupply of bedspaces in the city. This does not align to the suggestion in para.3.253 noting that “it is unclear at this time what the long-term implications will be” in a post-Covid city.
RE9 Entertainment, Leisure and café/restaurant Developments (Preferred locations) – We support this policy and in particular the caveats that proposals must be integrated satisfactorily into its surroundings to a high quality of design that safeguards existing character and will not lead to a
significant increase in noise, disturbance and on-street activity at unsocial hours
to the detriment of living conditions for nearby residents. We would advocate that suitable criteria be set down in guidance for added clarity.
RE 10 Entertainment, Leisure and café/restaurant Developments (Other Locations) – As with RE9, Clarification of the criteria for determining “a significant increase in noise, disturbance and on-street activity at unsocial hours to the detriment of living conditions for nearby residents” will be required.
RE 11 Food and Drink Establishments – Clear criteria for determining ‘an unacceptable increase in noise, disturbance, on-street activity or anti-social behaviour to the detriment of living conditions for nearby residents’ will be required.
