City Plan 2030 Consultation

Posted on: December 20, 2021

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

Cockburn Response

General

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.

Regional Issues

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.

City Plan Outcomes

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.

Place-based Policies

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.

Environment and Design Policies

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.

Housing Policies

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.

Infrastructure Policies

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.

Economy

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.

Retail Policies

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.

Events and Filming in Public Space Consultation

Posted on: December 13, 2021

Our formal response to this Local Authority consultation on events and filming activities that take place in public spaces

Our formal response to this Local Authority consultation on events and filming activities that take place in public spaces

Cockburn Response

The Cockburn participated in a Stakeholders Forum organised by the Council and chaired by Councillor Donald Wilson, Convenor of the Culture and Communities Committee.  It included event and filming organisers, community councils, residents’ groups, business groups, friends’ groups, Council officers and interested individuals, and collaboratively engaged in an exercise to develop and recommend key principles for the use of public open space.

The current consultation is on these principles, and will inform the preparation of a Management Plan which will set out how Edinburgh will manage public open spaces (parks, greenspace, roads, plazas, squares under Council control) for events and filming.

The following is the Association’s response to the online consultation exercise.

Recommended Key Principle:

The Application and Approval for events and filming will be based on the scale of the activity, the impact it will have, both short and long term.

Q3. To what extent do you agree that decisions on events and filming should be based on the impact they will have on people and places?

Cockburn’s response – AGREE

Q4. Please Offer comments

This open-ended question makes giving a coherent and helpful comments difficult.  The Cockburn agrees that the approval of events and filming applications should be based on its impact first and foremost to the wider amenity of the city.

Fundamental to this should be the principle that the public have an absolute right of access to public land (parks, gardens, civic squares, streets) and any impact or dilution of this by events or filming activity must be considered carefully and cumulatively.

Scale of the event is only one contributor to impact and whilst the general thinking that smaller events have smaller impacts may hold true, this may not always be the case.  Similarly, a large-scale event, such the Edinburgh Marathon, due to how it operates, may not.

Nevertheless, an impact-based approach is welcome.

We would add a particular caveat on public spaces held on the Common Goods Register.  These spaces should also be framed in a wider public benefit principle, whereby access to these spaces by commercial events should start from the principle of no loss of access or enjoyment.  Thus, if a commercial event requires exclusive access or has specific safety requirements suggesting that access rights should be suspended, even temporarily, then the default position is that space is unsuitable for that event.

It is essential that the application process builds into it a proportionate and clear enforcement dimension.  Conditions attached to events must be monitored and adhered to in all circumstances.  There should be a presumption against relaxation of standards for temporary activities, and mitigating requirements should be put in place as part of any consents issued.  For example, permanent hospitality businesses with amplified music are required to have sound monitors and comply with strict conditions, including processes that cut power if agreed levels are exceeded.  Similar conditions with appropriate enforcement measures should be in place for public spaces.

Recommended Key Principles:

Events and filming deliver beneficial social value and support a lasting positive legacy for Edinburgh. Events and filming provide net positive economic, social and community benefits.

Q5. For Edinburgh – for an individual event or filming, what do you feel is important? Please select the level of importance for each of the below.

Financial benefit – not important

Social Benefit – important

Community Benefit – Very Important

Q6. For your local area – for an individual event or filming, what do you feel is important? Please select the level of importance for each of the below.

Financial Benefit – not important

Social Benefit – very important

Community Benefit – very important

Q7. Please use the space below for any comments or suggestions on the above.

Firstly, the assumption that events bring positive and lasting benefits needs to quantified and in many cases, challenged.  Very little analysis of the negative impact of filming and events has been undertaken.  Assertions of positive value can derive from untested or incomplete information that may overstate positive values and understate negative ones.  For example, a paper considered by the Policy and Sustainability Committee on 10 January 2021 on filming noted that a specific event generated less than £250,000 in income for the city but was required to be spent on the variety of traffic regulation and management, meaning the actual value of the filming was cost neutral. The paper highlighted the brand and marketing value but ignored the fact that the vast majority of tourists come to Edinburgh because of its historic architecture and townscape.  No analysis of the derivate added-value was undertaken.

The benefit of allowing public spaces to be used for private ventures should be required to demonstrate a direct benefit to the City.

Economically, the direct value to the City may be small in comparison to the value extracted by event operators.  For example, the Council’s published price list for holding events in Princes Street Gardens states a price of only £2,820 per day for a major event.  Gross ticket sales might be in excess of £250,000 for each day, and given no net profit information is available for study, it seems clear that use of public spaces is heavily discounted in comparison to the value of the use of that space to operators.  There are no published data sets that outline how much value from an event stays within the city.  It is entirely possible that the net value is quite small.

Many events are locally organised for local people.  These are a direct public benefit and are supportable.  However, it is important to differentiate between local and city-wide benefits, and to ensure that an event that might have wider positive value does not occur at a negative or disproportionate scale for those local neighbourhoods who might need to bare the most immediate impacts.

Recommended Key Principle:

The use of council-owned or public good sites for commercial events should be framed within a Community wealth building approach.

Q8. To what extent do you agree that ‘The use of council-owned or public good sites for commercial events should be framed within a Community wealth building approach.’?

Cockburn’s response – AGREE

Q9. Please use the space below for any comments or suggestions on the above.

In principle, we welcome this approach.

The Council should seek in all instances to ensure that any use of public space should be to the benefit of the public.

Recommended Key Principle:

Information on events and filming will be as open and transparent as confidentiality allows and proportionate to the scale of the activity and the impact it will have. It will be provided at the earliest opportunity, to all those who may be interested in it, in appropriate and accessible formats.

Q10. At what stage would you like to have information on events and filming?

Cockburn’s response – When a full application is made

Q11. Please use the space below for any comments or suggestions on the above.

Whilst we would encourage as open and transparent a process as possible, this may not be possible in all instances.   The use of public space for commercial events or filming should not be seen as a right.  Indeed the emerging Management Plan should make clear that using public assets for private commercial benefit is a privilege.  Therefore, we believe that confidentiality should be a secondary consideration to whether information is made available. Certainly, proportionality is accepted, but any attempt to conceal information on the scale or impact under the vail of confidentiality should be avoided at all costs.  This should be made clear in any application process.

Recommended Key Principle:

Area Conditions will have information available on the area including stakeholders, facilities, capacity, toilets, key contacts.

Q12. What’s important for you, that you feel organisers should have local information on when they are planning an event or filming in your area? (select all that apply)

Key people to contact (e.g. local suppliers, community / friends groups) ✅

Local facilities (e.g. toilets, electricity and water supply, storage)

Capacity (number of people who can attend at one time) ✅

Local suppliers and trades

Parking arrangements

Public transport

Access for deliveries

Access for care and health services

School activities and routes to schools

Q13. Please use the space below for any comments or suggestions on the above.

We appreciate that each area or site will have particular conditions are issues that are special to it, as well as wider more common conditions.  We would advocate that the Council, working with local groups, civic organisations and event representatives work together to determine those core conditions and information for each site as a useful guide for local and organisers alike.

Missing from this list is the carrying capacity of the public space to able to host a particular event.  Soft landscaped areas may be unsuitable for heavy infrastructure activities and could damage the public space to such an extent as to limit public access post-event.  An analysis of specific site conditions including tree and root systems, ground conditions, etc would be valuable in determining the acceptability or otherwise of a particular event at a particular site.

Common Good Land should appear as a separate condition.  If a public space is included on the Common Goods Register and is therefore a Common Goods Asset, this constraint should feature as local information.

Finally, when activities take place in parks or gardens, it is essential that the area conditions emphasis that the greenspace is the predominant characteristic to be considered.  These areas should not be considered venues within a landscaped setting, but are landscapes where events might be tolerated.

Recommended Key Principle:

A digital platform will hold:

  • an events and filming calendar
  • planned disruption to an area such as road works or construction
  • Area conditions
  • an application template with a guide to what’s required for a successful application, including notification of stakeholders likely to be impacted.
  • record and communicate the positive benefits events and filming provide, as well as the negative impacts, to ensure balanced analysis. 

Q14. How useful to you would be being able to see information on events and filming, both proposals and approved, on a web platform?

Cockburn’s response – Very Useful

Q16. Please use the space below for any comments or suggestions on the above.

We would welcome a new digital platform for events and filming in the city.

Access restrictions should be included under Area Conditions, especially if the Council promotes a section 11 exclusion under the Land Reform Act effectively extinguishing the public’s legal right of access to public land.

The cumulative impact of repeated activities is an important issue that should be addressed here.  In many circumstances, it is not a single activity that causes an impact but repeated events in a single space – for example, damage to soft surfaced areas like lawns.  A digital platform should be able to reflect changing circumstances that might reflect the suitability of use, or otherwise, of a site capability to host an event.

Recommended Key Principle:

Organisers must demonstrate that events and filming respect and contribute to the city’s cultural identity, reputation and quality of life for residents. They will be expected to join with Edinburgh residents in taking responsibility for the good appearance of the city.

Q16. To what extent do you agree that events and filming organisers should respect and contribute to the city’s cultural identity, reputation and quality of life for residents?

Cockburn’s response – strongly agree.

Q17. Please use the space below for any comments or suggestions on the above.

We would support the second aspiration of the principle, namely sharing with residents (and other sectors too) responsibility for the appearance of the city.  Therefore, there should be a requirement for events and filming operations to articulate their specific positive contribution to this principle including an aspiration/expectation that public spaces are left in at least the same if not better condition than when the event took place. For significant activities, this might mean a condition survey is undertaken prior to approval to set a benchmark for management and reinstatement, if needed.

With the first element, we would support this.  Guidance will be necessary to help organisers understand what is expected of them, including expections of local residents for their amenity.  We would advocate that the Council improves its Environmental Health monitoring and enforcement systems, controls and capacity, providing a simple portal for any concerns regarding impacts on the quality of life.

Clear and unambiguous guidance on noise and access/travel disruption is needed.  Similarly, organisers must ensure that they adhere to other regulatory frameworks, policies and guidelines.  For example, in many instances operators have undertaken significant events without the necessary planning consents in place.  Clear information on when consents are required is necessary including timescales for the appropriate consideration of information or applications.  We believe that the core environment policies in the Local Development Plan should be made clear to organisers as a set of agreed principles for spatial management in the city.  This would include information at the point of application on whether planning consent is required.  In this regard, a more integrated, joined-up Council service will be required.

Recommended Key Principle:

Events and filming must comply with Edinburgh’s Sustainability Approach to be ‘net zero’ by 2030 and events with the principles of ISO 20121.

Q18. How important for you is it to have information on the carbon impact of events and filming?

Cockburn response – Very important

Q19. How important for you is it to have information on what organisers of events and filming are doing to reduce their overall carbon impact?

Cockburn response – Very important

Recommended Key Principle:

Applications will be expected to follow the principles and guidelines. In exceptional circumstances an applicant may seek modification or departure from these principles but will be required to present their case, including mitigations, to impacted stakeholders and for scrutiny by the Council. The Council, after due consideration and taking account of comments, will not be obliged to grant the exception.

Q20. In exceptional circumstances, do you think it would be OK for an event or filming to deviate from these principles, where it would have a clear positive benefit for Edinburgh?

Cockburn response – Yes

Q21. Please use the space below for any comments or suggestions on the above.

The nature of “exceptional” and “clear positive benefit” will need to be defined.  Any decision-making process needs to have proportionate and transparent mechanism for such exceptions.

We would suggest that the request to extinguish access rights under section 11 of the Land Reform Act be considered an exceptional circumstance by definition.  Only in the most significant applications should denying access to public space be considered acceptable.  If a commercial event requires such exclusivity, then it is mostly likely an unsuitable event.

Edinburgh Short-Term Let Control Area Consultation

Posted on: November 2, 2021

Our statement of support for the City of Edinburgh Council’s proposed city-wide Short-term Let Control Area

Our statement of support for the City of Edinburgh Council’s proposed city-wide Short-term Let Control Area

Cockburn Response

We fully support the City of Edinburgh Council’s Short-term let Control Area (STLCA) proposals.

The purpose of the STLCA as set down in section 17 of the Planning (Scotland) Act 2019 is to allow local planning authorities to manage short-term letting if “the use of a dwellinghouse for the purpose of providing short-term lets is deemed to involve a material change of use of the dwellinghouse” and provided the property is not a Private Residential Tenancy or the property in whole or in part is the only or principal residence of the landlord or occupier.

The proposed Control Area covers the entire City Council area.  Both the “Short-term Let Control Area – Statement of Reasons” and the associated “Background Report” set out comprehensively why such a designation is necessary.  These explain the three objectives underpinning the STLCA proposal:

  1. to help manage high concentrations of secondary letting which affects the availability of residential housing and the character to neighbourhoods.
  2. to restrict short-term lets in places or types of buildings where it is not appropriate; and
  3. to help ensure that homes are used to best effect.

The Cockburn supports all these objectives and welcomes the city-wide approach. Our response to the consultation is simple and straightforward.

When asked if we agree with the proposed designation, we said:

The Cockburn Association agrees with the reasons as set out in the Council’s Short-term let control area for Edinburgh; Statements of Reasons, which provides a comprehensive set of arguments in support of the designation of a STL Control Area. There is no question that Edinburgh has one of the greatest densities of STL in Scotland, with over 30% of all Airbnbs listed being in the city. In relative terms, it also has one of the highest densities of any city.

When asked if we support the city-wide approach, we said:

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

Licensing of short-term lets – Scottish Parliament Consultation

Posted on: October 5, 2021

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

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

Cockburn Response

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

Cockburn Answer: Strongly support

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

Cockburn Answer

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

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

Cockburn Answer:

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

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

Cockburn Answer:

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

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

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

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

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

Cockburn Answer:

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

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

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

2030 Climate Strategy – City of Edinburgh Council Consultation

Posted on: September 10, 2021

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

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

Cockburn Response

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

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

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

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

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

Community engagement

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

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

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

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

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

Implementation plan

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

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

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

Missing Emissions

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

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

Adaptation

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

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

Download and read a PDF of our full detailed response here

Low Emission Zone consultation – 2021

Posted on: August 26, 2021

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

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

Cockburn Response

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

Regretfully, we are unable to support these proposals.

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

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

Context

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

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

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

Current proposals – discussion

The proposal is for a city-centre zone only.

Boundary

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

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

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

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

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

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

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

Grace Period and Exclusions

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

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

Summary

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

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

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

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

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

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

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

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

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

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

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

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

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

Low Traffic Neighbourhoods Proposals in Corstorphine and Leith

Posted on: July 8, 2021

Our response to the City of Edinburgh Council’s consultation on two low traffic neighbourhoods in the city

Our response to the City of Edinburgh Council’s consultation on two low traffic neighbourhoods in the city

Cockburn Response

We welcome this CEC initiative to address the desire of local residents in Corstorphine and Leith for safer walking, cycling and wheeling spaces and for improved crossing points.

We would like to take the opportunity to stress the need to proactively monitor these temporary schemes and the importance of ongoing and meaningful engagement with local communities at all stages of this scheme.

Henderson Place Lane Development

Posted on:

Our initial response to developer about their plans to demolish existing buildings in Henderson Place Lane and build new apartments

Our initial response to developer about their plans to demolish existing buildings in Henderson Place Lane and build new apartments

Cockburn Response

We welcome the redevelopment of this site for housing. But clarification of the justification for the demolition of this relatively modern building rather than its repurposing is required. This would appear to be a more sustainable option in a part of the city dominated by heritage designations. In addition, and importantly, renovation and repurposing of usable buildings must be an essential first consideration if the City of Edinburgh is to reach its stated target carbon neutrality by 2030. conversion.

The original Silvermills masterplan restricted the scale and density of development in this area. Clarification should be given be on whether and how the current redevelopment proposal is consisted with original masterplan’s aims.

Further information is also required on the proposed housing mix, tenure types and social rented housing component is also required.

Winter Festival Consultation

Posted on: May 19, 2021

Our response to a Council consultation on the future of Edinburgh’s Festive Festivals

Our response to a Council consultation on the future of Edinburgh’s Festive Festivals

Cockburn Response

The Cockburn Association appreciates the popularity of the Winter Festivals.  We have stated repeatedly over the past number of years that it adds vibrancy and vitality to the City.  Edinburgh’s Hogmanay is now a global icon that, at the turn of each year, markets the city to a global audience on par with Melbourne and New York City to name a few.

However, both the Christmas Market and the various Hogmanay events are major commercial events rather than cultural festivities.  The Xmas market has moved considerably from the German market that once occupied the Mound with largely authentic products and produce to such a scale that it now modifies the Princes Street Gardens to suit its purposes rather than sits respectfully within them.

Now, these festive events impose significant restrictions on residents and those working in the city.  Both are now geared to the tourist market rather than the local, with 2018 official figures indicating that less than half attendees of the Xmas market were local residents, which falls even further to just 20% for Hogmanay.

Pre-Covid, the Winter Festivals have been an increasing cause of concern for residents and civic organisations through the city.  The erection of a massive space deck in East Princes Street Gardens by the Council’s contractor Underbelly, together with other issues regarding the operation of Edinburgh’s Hogmanay events (such as attempts to exclude local residents from the city centre) were merely the straw that broke the back of civic interest. The City Council’s response to these issues was less than satisfactory and highlighted the conflicted interests that it has in such matters.

These issues prompted a joint response by the Cockburn and the five City Centre Community Councils prompted by the City of Edinburgh Council’s Policy and Sustainability Committee (Thursday 20th August 2020).

Current Consultation

The Cockburn welcomes the consultation on the future of the Winter Festival.  This was promised as a response to the unsatisfactory management and governance of recent festivals.

However, we are concerned with some of the information provided in the on-line consultation.  For example, figures are put in the introduction with no links to the actual reports or data, which has been relatively unchallenged.  Commercial confidentiality means that key information is unavailable for scrutiny.

Some issues were unexplored (environmental and carbon impacts), and others would benefit from further discussion and consultation.  In this regard, we hope that the various stakeholder groups convened by the consultants would be re-established to receive the report from this consultation and have a chance to consider and discuss the findings.

Covid and Covid-secure challenges

The current uncertainty of restrictions and the general acceptance that we will be living with Covid and Covid-variants for some time needs to be reflected in any event post 2021.

An enhanced (and not just “adequate”) security and people management ?? policy for all aspects of the Winter Festivals will be an absolute priority with respect to public protection.  It is clear that for years to come, the implications of Covid and the management requirements caused by Covid will continue.  The Winter Festivals should have the high levels of management to prevent overcrowding, protect public health and ensure social distancing.

For this reason, together with concerns about previous Winter Festivals, suggests the need for a carefully considered attendee dispersal strategy post-2021.  Bigger isn’t necessarily better.

It is our view that the Christmas Market, Hogmanay and associated events should not be held in East Princes Street Gardens or at least reduced to the extent that only the upper terrace is used.  No space structure such as that erected on 2019 should be permitted.

Key Principles for the Winter Festivals post 2021

The principle of free access must underpin the Winter Festivals offer, especially for those activities that occupy public space.  We accept that there will be some ticketed events (such as the Hogmanay Street Party) but these should be limited with a default position of no exclusive access to public areas.

No public or quasi-public areas with soft landscaped surfaces should be used for activities that require substantial infrastructure that might cause damage to those areas.  For the Cockburn, it is unacceptable for a public space like east Princes Street Gardens to be unavailable for 6 months of the year to facilitate a commercial Christmas Market that operates for 6 weeks.  There are other places and solutions available, such as integrating Waverley Bridge into the market, and using corporate sponsorship to fund entertainment activities.

There should be no loss of public circulation space resulting from measures put in place for these events. For the avoidance of doubt, such management and social distancing measures must not be a Trojan horse for increased commodification of public spaces including streets.

There must be a direct commitment from the Winter Festival management to contribute to Edinburgh’s carbon reduction targets. All contracts should explicitly reference to ISO 20121 on sustainable events as a benchmark for management.  Travel to the events by attendees (including a full breakdown of EH postcodes) should be included in any carbon counting exercise in order to assess, and therefore manage, the full carbon impact of the Festivals.

It is vital that absolute priority is given to supporting existing local businesses and micro-businesses including local social enterprises (Edinburgh Social Enterprise is the most appropriate source of assistance) through all aspects of the events. The aim to create an Edinburgh Christmas Makers’ Market is welcome but important details will need to be developed.

Public interest and protection will be best served by scaling down the market.  In 2019 67% of outlets in 2019 were non-local. There were also too many “repeat” stalls – i.e. stalls owned by the same retailer selling the same products, in many cases products available in traditional High Street shops.   Clear reductions are needed in the number, as well as the proportion, of non-local exhibitors.

In particular, there should be no pop-up bars and food outlets, especially as these create direct competition, not additionality, to local all-year round businesses such as bars and cafes.

Dispersal of activities

A significant problem with the Winter Festivals pre-Covid was the desire of operators to concentrate activity is a small area.  With the Xmas Market, this meant East Princes Street Gardens which were unable and unsuitable to cope with an ever-increasing activity.

Planning applications submitted in early 2020 proposed locating market stalls on High Street and George Street with possible other facilities located in streets will clearly have an impact on local residents for more than two months. We therefore ask that residents on all affected streets are consulted for a period of at least two weeks, before a decision is taken about where the market stalls will be located on the City Trail.

The Cockburn strongly advocates the creation of a Christmas City Centre Trail using sites across the City Centre in various locations for markets which could bring additional benefits to those areas. This should include existing markets, such as those in Stockbridge, Castle Terrace Car Park and the Grassmarket, as part of this trail.  The maps below shows a comparison of relative distances between Munich’s famous Xmas market locations and suggested locations in Edinburgh.  Edinburgh’s Festival Square and Conference Square provide an excellent location for the Winter Festivals which could be coupled with The Mound/Waverley Bridge and the possibly the High Street to form an excellent offer.

   

Summary

The 2019 Winter Festivals were a watershed moment where public concerns about the impact of the Christmas Market and the restrictions and impositions placed upon local residents and businesses for the Hogmanay events reached a tipping point.

This consultation is a direct result of the public disquiet at the approach taken by the Council in managing (or undermanaging) the impacts and the ambivalence of Underbelly, the City’s contracted partner for the delivery of the Winter Festivals to these issues.  The damage caused to East Princes Street Gardens, effectively removing public access for half a year directly caused by the Christmas Market and its space deck erected without proper consents was a low point in history of the Festivals.

Fundamental to any event that happens post-2021 is the need for the City Council so show leadership in managing the special place and unique qualities of the city. The Council must no longer simply hand over control of significant parts of the public realm to a commercial operator because it is expedient to do so.

The Cockburn would welcome the return of the Winter Festivals but only if past failures are rectified.  No soft surfaced public space should be used for infrastructure.  East Princes Street Gardens should be largely off-limits for use, but a more creative and dispersed approach could yield significant benefits for the city in a way that does not overwhelm more fragile neighbourhoods and localities.

Other cities in the world operate just such events in much more sustainable ways without the negative impact of the repeated damage caused here.  There is no reason why Edinburgh cannot follow suit.

Spaces for People

Posted on: April 2, 2021

Our response to the City of Edinburgh’s “Spaces for People” public consultation

Our response to the City of Edinburgh’s “Spaces for People” public consultation

Cockburn Response

General Comments

The Cockburn Association welcomes this opportunity to comment on the Spaces for People scheme. However, as this scheme consists of many on the ground projects with directly impacts on the lives and amenity of local residents in a variety of ways. In respect of the current consultation on the Spaces for People scheme we are unable to comment on points of detail or on the local merits or otherwise of individual initiatives within the overall programme.

We offer the following comments as a contribution to the lively ongoing debate within the city on the merits of the programme. But we are disappointed that the current consultation does not provide an opportunity to discuss and comment on the wider transport, planning and place policy issues which are relevant to the Spaces for People scheme.  It is to be hoped that further consultation on the Spaces for People scheme will allow a debate on relevant issues within this wider policy environment.

The recently approved City Mobility Plan 2030 as well as initiatives such as the Central Edinburgh Transformation ProjectGeorge Street proposals and the Meadows to George Street Cycleway project All signal a shift in emphasis and desire to move away from automotive strategies into more civic-based ones.  The Cockburn supports this approach in principle but will scrutinise the content of actual proposals as they are published for consultation and comment.

Better facilities to encourage walking, wheeling, and cycling are required to making Edinburgh the great walkable city that it should be. But they must be the right initiatives in the right place and be consistent with the needs and wishes of residents and local businesses.

Challenges and Issues

The Spaces for People was a rapid rollout scheme that benefited from huge displacements of traditional road traffic due to the Stay at Home regulations of the Scottish Government.  As normal activity resumes over the coming weeks and months, competing pressures of road and civic space will result.  Any assumptions of success or impact will need to be reassessed, in some cases from first principles, before any temporary schemes can be deemed workable, appropriate or relevant to the everyday experiences and needs of residents and businesses post-pandemic.

The increase in on-line retail was an stablish and growing trend before the pandemic has been significantly accelerated by the lockdown.  The shift from People moving to the Shop to the Shop moving to the People will continue, meaning an increase in delivery traffic through the city and all times of the day.  A particular feature of this shift is the requirement for localised loading bays for delivery vehicles in all parts of the city, but particularly on residential streets.  Any Street for People initiative must be able to accommodate this trend.

Design and Place Emphasis

The Cockburn argues that Spaces for People must prioritise making places for people.  Its focus should be place led, not transport led.   The introduction of safer cycling facilities is important but in many instances is a traffic management issue. An while it may be possible to reach a balance between the competing needs of pedestrians, cyclists and motorists, this will not always be the case. In addition, the specific requirements of facilitating efficient deliveries to local business and deliveries and services to residents must also be fully integrated into an acceptable, workable, permanent version of the Spaces for People scheme.

A wider, more inclusive urban design approach through a focused agenda of quality design inputs will yield more appropriate results in many places.  In this, we also emphasise the need to enhance the DESTINATION element of local centres in order to support local businesses post-Covid, noting the important role that they have played in supporting their neighbourhoods during and before the pandemic. Such an approach will also anticipate and address the potential unintended negative consequences of local Spaces for People infrastructure such as creation of new local ‘rat runs’.

Narrative and Discussion

Spaces for People in Edinburgh was initiated to put in place several measures that specifically try to:

  • help parents/carers and children to physically distance near schools;
  • help people to physically distance while using high streets, some city centre streets, and while exercising; and
  • provide protected cycle lanes on main roads, so that people can consider cycling for trips that they might otherwise make by public transport.

It is the Cockburn’s View that the Council has an opportunity, in terms of transport and travel, to make sure that residents and business owners can move about the city more safely and more efficiently, with a reduced impact on the local environment, than was the case before the pandemic.

However, any Spaces for People schemes that become permanent must:

  • be acceptable to residents and businesses;
  • improve the streetscape;
  • be safe for all users (particularly vulnerable residents).
  • improve accessibility for all users (particularly vulnerable residents).;
  • be efficient and effective;
  • be environmentally acceptable;
  • provide for walking, cycling and public transport consistent with the Transport Hierarchy.

The Spaces for People projects which have already been put in place or are in the process of being put in place, across the city may be fit for purpose and relevant to the needs of residents, businesses, and local communities.

However, the restrictions on movement during the pandemic certainly present challenges and uncertainties in forming a complete picture of the needs and requirements of residents and established businesses post-pandemic.

What is certain is that all schemes which are to become permanent should only become so if they conform to the Transport Hierarchy. If they do not conform, they should not become permanent or should only do so after significant modification.

Emphasising the Transport Hierarchy

The Scottish  Government’s Transport Hierarchy strategy places the needs and requirements of pedestrians at the top (including the access requirements of people with disabilities), followed by cyclists, then public transport, then shared transport with private ­car users last. The aim of the hierarchy is to ensure that the movement needs of the most vulnerable groups are fully considered in all new transport and mobility schemes. This does not necessarily give priority to pedestrians and cyclists in every location.  This will depend on local circumstances.

Anecdotal evidence seems to suggest that the current Space for People projects have the potential to affect hard-to-reach or vulnerable groups disproportionally and adversely, such as those with mobility issues.  We note and agree with the concerns expressed by the Edinburgh Access Panel.  Our own stakeholders have raised very similar concerns relating to pedestrians safely at ‘floating bus stops’ and in any situation where pedestrians are forced to cross a cycle lane to get to their bus or their parked car.

A particular concern is any proposed loss of parking provision for blue badge holders caused by the roll-out of cycle lanes. Of necessity, blue badge holders must be allowed to park close to their destination.  This is not a question about the total number of blue badge parking bays in the city.  But it is it a question about having blue badge parking bays where they need to be to meet the requirements of blue badge holders. In some situations, it may not be possible to meet the competing requirements of blue badge holders and, for example, cyclists. In such circumstances the legitimate needs of blue badge holders cannot and must not be compromised.

Local businesses will also have their own unique concerns. The Council’s transport teams need to engage effectively with local businesses and their representative beyond the passive and somewhat leading digital consultation portal. Information should be disseminated and presented locally in a way likely to be accessible and useful to the various local stakeholders with a substantial interest in the changes being put in place. Local businesses will only be able to survive and thrive post-pandemic if they have safe and secure access for incoming and outgoing deliveries to and from their places of businesses.  At this point, it is not clear to us that this have been established in all the temporary Spaces for People schemes currently in place or proposed. The economic sustainability of local businesses is dependant on the Spaces for People programme being fit for purpose in this respect. This is more than a simple decision about the number and location of loading bays, important as they are.

A related point, it the facilitation of deliveries and services to local residents. The point has already been made that the ongoing growth in online shopping has led to an increase in deliveries to residents, at all times of the day.  The Spaces for People programme must accommodate this need and the related needs of the many service providers that are used on a regular basis by residents throughout the city.

The Need for a Place Hierarchy

Missing from the Spaces for People initiative is an understanding of the needs of the particular place or local neighbourhood into which the interventions are being located.

Much of central Edinburgh is covered by Conservation Area designations, each of which has its own Conservation Area Character Appraisal that sets out those characteristics that need to be preserved or enhanced.   We acknowledge that traffic interventions are technically excluded from Conservation Area Management by Class 30 of the General Development Order (Work by the local authority) but we argue that there is a duty of care by all sections of the local authority to ensure the highest design standards in a Conservation Area.

Any interventions should reinforce the particular character and functions of that place. For example, if a street acts as a local neighbourhood centre (a parade of shops, pubs, cafes, etc), the priority is to enhance the pedestrian environment with gathering spaces to support these places as local destinations.  It should be explicit that if in achieving this, the ability to insert a segregated cycleway is curtailed, that should be accepted.

Maintenance

A point which we have raised in previous consultations such as that for the City Mobility Plan 2030 is the issue of ongoing maintenance. An example is the condition of some of the city’s pre-pandemic cycling infrastructure of painted on-road cycling lanes and on-road waiting areas.  In many instances, these have not been maintained although some have now been overlain by Spaces for People infrastructure. The Council has not yet made it clear if and how future resources will be provided to maintain permanent Spaces for People projects in a safe and appropriate condition to secure the needs of those walking, wheeling, and cycling. Put simply, funding appears to be available for capital works. But will funding be available to secure the adequate maintenance of completed projects in the future?

Consultations and the Consultation process

A recent opinion piece in the Evening News declared that implementation is not consultation.  We agree with that sentiment.  At the height of the pandemic, normal consultation requirements were set aside for the necessary infrastructure to be put in place as quickly as possible whilst the pandemic was at its peak. This meant that some residents had controversially little, or no notification of planned Spaces for People changes and only found out when the implementation works started.

Now, the Council is considering whether to keep some Spaces for People measures in place, either on a trial basis or more permanently. Before deciding whether to go through the legal processes necessary to keep projects in place, the Council want to hear residents’ and businesses’ views. The current process is an online consultation. It is not one based on the ground, in local communities, talking face-to-face with residents and local businesses. Whilst we appreciate that many schemes will be advanced under a temporary or experimental basis, it can be assumed that permanent retention is an objective.

As the pandemic restrictions ease, the Council must take the opportunity to expand and extend its consultation process to capture a full range of views from stakeholders affected by the Spaces for People projects. An opportunity to discuss and comment on the wider transport, planning and place policy issues which are relevant to the Spaces for People scheme should also be provided. The Cockburn Association would certainly strongly encourage the Council to search out and take up all further consultation opportunities as they become possible.

It is also essential that the Council recognises that the views and lived experience of stakeholders may change as pandemic restrictions are eased and the city fills up again with traffic, visitors, and events. It is a sad reality that as commercial life returns to community ‘High Streets’ across the city, the local streetscape of shops and businesses, the way people shop, use services and meet friends and neighbours may have all have undergone significant change.  Locals may have discovered new ways of using their local streets and neighbourhoods and the Spaces for People initiative will need to support and facilitate local community vitality post pandemic and not hinder it.

The Council’s consultation processes will need to be agile enough to capture this changing reality. Indeed, as the city moves back to ‘normal’ life the results of the Council’s current consultation, given the unique circumstances under which it is being carried out, may come to be quite irrelevant to the reality of life in only a few months’ time. And, of course, the views of residents, business, services providers and utility companies may be quite different and may need bespoke consultation processes.

Summary

We would encourage all local residents, businesses and stakeholders to participate in the Council’s current consultation.  But we believe that this should not be the end but rather the start of a more significant and locally engaging consultation exercise or series of consultations.