Visitor Levy for Edinburgh

Posted on: December 9, 2024

We believe that the main objective of the levy is to improve the City of Edinburgh for its resident population, mitigating the impacts of mass tourism in the city. The funds should be aligned to enhance those attributes which entice visitors to the city, namely its heritage and landscape qualities as well as improve the amenity of public assets such as greenspaces and cultural attractions, which would benefit visitors and residents alike.

We believe that the main objective of the levy is to improve the City of Edinburgh for its resident population, mitigating the impacts of mass tourism in the city. The funds should be aligned to enhance those attributes which entice visitors to the city, namely its heritage and landscape qualities as well as improve the amenity of public assets such as greenspaces and cultural attractions, which would benefit visitors and residents alike.

Cockburn Response

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Draft Climate Ready Edinburgh Plan 2024-2030

Posted on: May 3, 2024

Monitoring and Evaluation  is essential for ensuring that actions are effective, efficient, and accountable

Monitoring and Evaluation  is essential for ensuring that actions are effective, efficient, and accountable

Cockburn Response

Consultation Comments

Background

Over the past twenty years or so the City of Edinburgh Council, in conjunction with many formal and informal partners, has brought forward or enacted many sustainable development  and climate change related strategies, policies, action plans and initiatives.  These all built upon similar strategies prepared by the former District Council and Lothian Regional Council, notably including  the Agenda 21 initiative, the Rio Declaration on Environment and Development adopted by more than 178 Governments at the United Nations Conference on Environment and Development (UNCED) held in Rio de Janeiro, Brazil, 3 to 14 June 1992.

Many of these earlier strategies and plans, including the recent 2016 to 2020 Edinburgh Adapts Plan, have addressed climate change adaptation to a greater or lesser extent.  It would have been helpful and instructive if this latest Draft Climate Ready Edinburgh Plan 2024-2030 had clearly illustrated how it intends to build on the success of previous adaptation  plans and initiatives and how it will work to rectify any past failures and so ensure  a positive and effective contribution to citywide adaptation going forward.

The Draft Climate Ready Edinburgh Plan 2024-2030 signposts to some other citywide strategies and plans that as relevant to climate adaptation. However, the city has many economic, social, and environmental strategies, plans and action plans which have some relevance to citywide climate adaptation. In view of this complex policy landscape, the draft Climate Ready Edinburgh Plan 2024 requires a much clearer indication of where  it sits in  relation the city’s policy hierarchy and what authority it has in relation to other approved plans. This must  include local and national land use planning policies and guidance that can serve as aa exchange for climate related mitigation, adaptation, and sustainable development objectives.  We agree, for  example, with RIBA’s an ICE’s recent policy position that demolition of existing building should not be allowed in all but the most extreme circumstances. This represents a considerable saving in terms of embedded carbon but may require careful and considered adaptation interventions thereafter to ensure climate resilience in retained buildings.

Edinburgh’s 2030 Climate Strategy,  which sets out a city-wide approach to reducing greenhouse gases in Edinburgh,  to deliver a net zero, climate ready city by 2030 is mentioned. However, it is important to note that mitigation initiatives aimed at reducing carbon emissions can also have additional climate resilience benefits. Mitigation and adaptation strategies should be complementary to maximise their climate change impact. Therefore, it is important that they are integrated to avoid wasteful and unnecessary policy conflicts and make the best use of all available resources.  More clarity on how the 2030 Climate Strategy and the Draft Climate Ready Edinburgh Plan 2024-2030 complement each other would be helpful.

As the IPCC made clear in a recent report: “Many adaptation and mitigation options can help address climate change, but no single option is sufficient by itself. Effective implementation depends on policies and cooperation at all scales and can be enhanced through integrated responses that link mitigation and adaptation.”

In addition, community-based climate activities have built momentum in relation to practical adaptation actions over an extended period.  The draft Climate Ready Edinburgh Plan 2024 should acknowledge this invaluable contribution to adapting Edinburgh to a changing climate. The Edinburgh Adapts Partnership has an opportunity to engage with and integrate into Edinburgh’s communities of place and of interest to ensure that community interest is at the heart of its decision making and governance processes.

Vision and Priorities

We are supportive of the Vision and Priorities identified in the Draft Climate Ready Edinburgh Plan 2024-2030.  In any case, these have generally  been embedded in many the city’s existing visions, strategies, and action plans  already. However, as previously indicated, although the draft plan signposts to some of the wider policy context in which the plan will operate, it fails to explain how exactly how this plan will be integrate with existing large and diverse range of relevant policies and related activities and whether it has any  authority within this large policy ecosystem. More importantly, it does not articulate what is new and value added in  the draft plan over and above initiatives which are committed elsewhere.

We believe that effective and meaningful monitoring and evaluation are key factors in achieving real climate adaptation and are critical to demonstrate effectiveness and accountability and the best use of resources.  We acknowledge that there are challenges associated with monitoring and evaluation of climate adaptation, related to the long timescales of climate change and its impacts. However, many of the actions listed in the Draft Climate Ready Edinburgh Plan 2024-2030 are clearly suitable  for short-term monitoring and evaluation. This deficit should be rectified before the draft plan is approved.

The Case for Adaptation and Climate Ready Edinburgh

These two sections provide a useful introduction to Edinburgh’s changing climate and  to what needs to be done to successfully adapt to these changes. However, both are too brief.  The Draft Climate Ready Edinburgh Plan 2024-2030 needs to articulate in a more inclusive way what the challenges of Edinburgh’s changing climate might look like. An obvious way to do this would be through the inclusion of case studies based on actual past events and through illustrative projections of what climate risk might look like on the ground across the city in the future.   This section should be a springboard for the rest of the plan and should set out a clear indicative illustration of the key features which Edinburgh should aspire to as a well-adapted city in the future. It simply fails to do this and requires a thorough reworking.

Climate Ready Edinburgh Action Plan and Implementation Plan

At first sight, these plans seem thorough and comprehensive. But a closer reading reveals many points of real concern which beg the question of how real, relevant, and meaningful the content of Action Plan and Implementation Plans is. Some of the proposed actions are so broad and nebulous that they are almost meaningless.

It must be acknowledged that many of the actions listed in Implementation Plan are of value. But an overarching lack of specificity means that almost any activity, large or small, could be counted as addressing the actions listed  here.  A SMART action plan incorporates 5 characteristics of a goal: specific, measurable, attainable, relevant, and time-based.  These characteristics are not comprehensively achieved in the draft.

We would like to see:

  • Specific actions to increase the climate resilience of city-wide built heritage
  • Greater clarity and urgency on what is being done to counter storm events and flooding
  • More specific and tangible action to  the challenges of sea-level rise
  • Specific interventions to address heat and storm event impacts on public transport, road, and active travel
  • More pro-active action to secure a biodiversity-rich future environment for Edinburgh
  • Pro-active selection of more suitable tree species to safeguard the city’s greenspace and streets
  • Early engagement with the increased day-to-day maintenance burden of greenspaces, parks, and street trees
  • Fuller articulation and stakeholder engagement on the impact of climate change on the local economy, both positive and negatively
  • A much greater degree of participation by residents and other stakeholders at an early stage of the detailed design and implementation of the proposed actions
  • An equal role for residents in the proposed review group and in the identification of key indicators of success
  • Greater transparency on which actions are fully funded and committed
  • Greater transparency on how the draft plan adds value to ongoing activities which are not directly driven by a climate adaptation agenda

Meaningful Monitoring and Evaluation

Monitoring and Evaluation is given a passing mention in the Draft Climate Ready Edinburgh Plan 2024-2030   but is essentially  absent.  A draft Monitoring and Evaluation process for comprehensively assessing the performance and effectiveness of the actions contain in the Draft Climate Ready Edinburgh Plan 2024-2030   should have been presented as part of the current consulting  . This process must  require  the collection and objective analysis of the plan’s activities, outputs, outcomes, and impacts to determine whether the desired results have been achieved.

Monitoring and Evaluation  is essential for ensuring that actions are effective, efficient, and accountable. By monitoring and evaluating the Draft Climate Ready Edinburgh Plan 2024-2030, the Edinburgh Adapts Partnership  and citywide stakeholders and funders can identify successes, challenges and failures and so make informed decisions to improve future  plans, outcomes, and impacts.

There is no need to delay the presentation of  Monitoring and Evaluation framework with key measures of success for Draft Climate Ready Edinburgh Plan 2024-2030. This work does not need to originated from scratch.  The largely generic content of the Draft Climate Ready Edinburgh Plan 2024-2030  means that similar plans with approved   Monitoring and Evaluation frameworks can readily form the basis of a suitable framework for the Edinburgh Adapts Partnership.  Presenting such a framework now, before the Draft Climate Ready Edinburgh Plan 2024-2030   is approved is highly desirable and will ensure timely monitoring of the plans process.

Role of Residents

We believe that residents need a much greater involvement in Draft Climate Ready Edinburgh Plan 2024-2030 at all levels, from governance to action on the ground. The plan and the Edinburgh Adapts Partnership should empower residents, communities, and business stakeholders  to identify climate impacts, and to discuss interventions to adapt to them. This will lead  to a better awareness of, engagement with  and preparedness for future climate change events across the city and help build a common understanding and ownership of climate adaptation plans and actions, which is key to their successful delivery. As the Draft Climate Ready Edinburgh Plan 2024-2030 is rolled out, inclusive community engagement should be supported. In part this might be achieved through an online community engagement platform to facilitate the review of ongoing actions and the working up of new actions. However, real world engagement is also required to access traditionally unheard voices and groups. “Think globally, act locally” was a core principle of Local Agenda 21 which aimed to inspire local authorities, their partners, and citizens to work towards sustainable development. The same principle is applicable to the Draft Climate Ready Edinburgh Plan 2024-2030.

 

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Comments on World Heritage Management Plan 2024-2034

Posted on: April 15, 2024

There is a clear need for the final version of the Management Plan and Action Plan to have Key Performance Indicators and specific areas of action with expected outcomes and outputs.

There is a clear need for the final version of the Management Plan and Action Plan to have Key Performance Indicators and specific areas of action with expected outcomes and outputs.

Cockburn Response

The draft Management Plan now covers a period of 10 years versus the previous plan’s 5-year lifespan. We assume that this is to align with City Plan 2030 although there is no specific explanation for this change. It would be helpful if this were explained. A ten-year plan period could mean that there is little scope to respond to changes in policy or circumstance. However, the introduction of a two-year Action Plans is a pragmatic response to allow these concerns to be managed.

The draft Plan appears to be a roll-over of the existing plan. Given the issues and challenges that we set out in our full reponse, we question if this is entirely the right approach.

The Association agrees with and supports the aims of the draft Plan as set out in para. 2.2.  We also support the five themes set out in the Action Plan, being awareness and appreciation; climate emergency; conservation and maintenance; control & guidance; and a sustainable visitor experience.

In accepting the structure of a 10-year main Plan with a 2-year Action Plan, we would expect the latter to have SMART targets embedded in it. We would expect a final version of the Plan and Action Plan to have Key Performance Indicators and specific areas of action with expected outcomes and outputs.

Failed rainwater goods in the WHS.

The Management Plan must drive a data-driven approach to policy formulation and action-setting. This is currently missing in the draft Plans. We appreciate that a State of Conservation Report has been prepared, but its data must be used to inform the plan, influence its approach, and drive activities (with measurable targets).

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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.

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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

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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.

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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

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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.

Further Details Here

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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.

Further Details Here

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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

Further Details Here

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