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

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.

Further Details Here

Back to Listings

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

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.

Further Details Here

Back to Listings

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

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.

Further Details Here

Back to Listings

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

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.

Further Details Here

Back to Listings

Winter Festival Consultation

Posted on: May 19, 2021

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 20^th 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.

Further Details Here

Back to Listings

Spaces for People

Posted on: April 2, 2021

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 Project, George 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.

Further Details Here

Back to Listings

“George Street – First New Town” Proposals

Posted on: March 26, 2021

Our comments on the latest proposals for the future of George Street

Cockburn Response

The Cockburn has been involved in this project since the outset and has seen the designs evolve and mature.

The Experimental TRO conducted several years ago showed an appetite for change to George Street and its shift from a trafficked street to a destination for civic living. Key was increased pedestrian space, facilitating the east-west cycle route and generally producing a more amenable place whilst respecting and enhancing the qualities and characteristics of the World Heritage Site. We endorse all of these objectives and feel that the designs have generally reflected these well.

In addition, we offer these specific comments:

Materials need to reflect the recognised palette of stone used throughout the New Town and as articulated in the Street Design Guide.
The desire to add the small sections of planters with seating etc should not come at the price of reducing circulation space. In addition, careful management of street licenses to hospitality venues needs to be put in place with effective and clear guidance so that, again, pedestrian space is not lost.
A clear events strategy must be developed and enforced to ensure clarity of use.
It is essential that a long-term maintenance strategy is put in place for the street and especially the planters, with dedicated financial resources to ensure a rigorous cleaning and planting regime.

On the subject of trees, we acknowledge the significant public interest in introducing trees into the street. Indeed, we also acknowledge that throughout the history of the Association, we have been long-standing advocates for street trees, having campaigned for them in the late 18^th and early 19^th centuries.

Since this time, our understanding of the significance of George Street as one of the centrepieces of the World Heritage Site, inscribed in 1995, has grown hugely. George Street was not designed as a boulevard but as a set-piece along a strong axis from Charlotte Square to St Andrew’s Square, with the intervisibility of each crucial to its urban form. The current proposals have evolved to respect this key feature, which we welcome. If trees were to be introduced, it is important that this key element of the street is not undermined.

There are also challenging design issues including a substantial amount of undersurface voids including cellars and service tunnels, which not only introduce planting and technical hurdles but also legal and ownership ones too. These would need to be fully explored and considered, with additional consultative programmes put in place if it were to advance.

Similarly, not all trees are equal. There is a very real difference between ornamental species versus “forest” species are considerable, and clarity of thought in this is required. If underground planting is not possible, and large plant pots required, this would limit the scale of trees possible, which would also limit carbon, biodiversity and other benefits accordingly. Finally, and as already noted, a long-term management and maintenance regime specific to this street would be required.

Further Details Here

Back to Listings

Portobello Beach Sauna

Posted on:

Our comments on proposals to introduce a sauna on Portobello Prom

Cockburn Response

The Cockburn Association has had the proposed license application for a mobile sauna unit brought to its attention by local civic bodies. Whilst we do not usually comment on licensing applications, this proposal brings forward several issues of amenity and precedent.

Firstly, the location of the proposed mobile sauna unit is at a heavily used, and congested, part of the Portobello Promenade. Although the hard-standing suggests a suitable area for such a facility, it is in direct conflict with the need for space for people. It would effectively privatise this small area of public space, which would be larger than the mere footprint of the structure with space for queuing, power, etc. For this reason alone, it would not be suitable to grant a license for this facility.

Secondly, the proposed use of wood-burning heaters could cause considerable local air pollution. Other fuel forms might also cause amenity impacts.

Thirdly, placing temporary facilities in this location would create a precedent that would make it harder for the licensing authority to refuse other applications.

For these reasons, the Cockburn feels that this is unsuitable and that the licensing application should NOT be granted.

That said, we appreciate the intention behind the operator of the mobile sauna is to support an increased interest in “wild swimming”, which has become more popular over the past decade or so. We can understand the merit of the proposal in supporting increased access to the water and the benefits of wild swimming. Whilst the nearby Portobello Baths provides some support facilities relevant to this interest, they may not be ideally placed for wild swimmers.

This requires a much more strategic approach than this opportunistic application provides. Enhanced beachside facilities would perhaps increase the enjoyment and experience if well-managed and deployed sensitively.

Indeed, there might be other areas along the coastline which could also benefit from such enhancements. The City Council or its arm’s length organisation Edinburgh Leisure are well-placed to develop a strategic framework to carry this forward.

Council Decision: We were contacted by the Council Licensing Dept on 19th May 2021 to inform us that the application had been refused in terms of Paragraph 5(3)(c)(i) of Schedule 1 of the Civic Government (Scotland) Act 1982).

This part of the Act specifies:

Where the licence applied for relates to an activity consisting of or including the use of premises or a vehicle or vessel, those premises are not or, as the case may be, that vehicle or vessel is not suitable or convenient for the conduct of the activity having regard to—

the location, character or condition of the premises or the character or condition of the vehicle or vessel;
the nature and extent of the proposed activity;
the kind of persons likely to be in the premises, vehicle or vessel;
the possibility of undue public nuisance; or
public order or public safety;

Further Details Here

Back to Listings

Edinburgh City-wide Parking Phase 2 Consultation

Posted on:

Our comments on the Council proposals for controlled parking in parts of the city.

Cockburn Response

Our concerns mainly focus on managing the amenity and environmental impacts of these proposed parking controlled zones.

Residential gardens form a major part of Edinburgh’s streetscapes, helping to improve air quality, support biodiversity, improve health and wellbeing, and enhance the traditional sense of place of communities across the city. They are also important because they help surface water management as garden vegetation acts as a “sponge” by soaking up rainfall and filtering pollution. This fact will become increasingly important as out local climate changes in the years to come.

However, many gardens across Edinburgh have already been covered by hard paving by residents to create off-street parking. Replacing natural vegetation with impermeable surfaces reduces the amount of rainfall that can infiltrate naturally into the ground and increases the rate and volume of runoff flowing to the city’s drainage systems. During storm events, this can cause the system to become overwhelmed and lead to localised flooding and storm events are expected to become much more common in the future.

The further expansion of on-street parking may encourage the further conversion of gardens to driveways. It is entirely understandable why householders would seek to repurpose their front gardens in this way, especially to avoid parking permit costs when including within a Parking Control Zone. However, this represents the semi-privatisation of adjacent public streets with new dropped curbs and potentially more roadside restrictions preventing the new driveway from being blocked by street parking. In most places, this will result in a significant further reduction in on-street parking, exacerbating the problem of supply rather than alleviating it. It is also important to flag up that that a proliferation of dropped kerbs can present addition problems for pedestrians and wheelers, especially those with mobility or sight issues and with young children.

Without urban planning controls and design guidance, further restrictions to on-street parking run the risk of promoting more unsustainable garden to driveway conversions. If Parking Control Areas are being expanded and the associated increased pressure to form private drives in increasing. Then it is essential that the City of Edinburgh’s guidance for parking in front gardens is up-to-date and fit for purpose. It also needs be consistent with other Council traffic and transport policies and initiatives.

Further Details Here

Back to Listings

Public Space Management Plan – Pre-consultation Exercise

Posted on: January 20, 2021

The Cockburn Association welcomes the development of a Public Spaces Management Plan, seeking to amalgamate and improve existing policies, plans and guidelines into a single unified document and process. However, we note that the Public Space Management Plan offers no strategic insight or assistance with the controversial issue of the commodification of open space. Instead, it proposes a set of …

Cockburn Response

A precis of the issues

It is generally accepted that this is not a management plan for public spaces per se, but an operational guide for the management of events (including filming) in a limited number of Council-controlled public spaces.

This is evidenced by the objective of the plan, which will “set out how we can manage public open spaces (parks, greenspace, roads, plazas, squares under City of Edinburgh Council control) for events, filming and festivals”. The PSMP continues to assume that the commodification of open space is an acceptable public objective.

The starting point for plan should be a “first principles” review and consideration of the scale and nature of the use of public spaces. Many if not most events and activities are relatively modest and limited in their impact. An analysis of existing activity would be very useful in preparing the PSMP.

We accept that activities in public spaces can be positive and indeed desirable. They can contribute to interest and vitality and can support local communities. They can also be divisive, exclusive/restrictive and anti-community as well introduce disruptive and intrusive activities in places most appreciate for peace and tranquillity. It is this paradigm that the development of the plan should concentrate, and a criteria-based approach developed. At the moment, it is left to the event organiser to determine how the event is to be delivered. Whilst this might seem logical from an events management perspective, from a civic perspective, the Council should set criteria to which the operator must adhere to. For example, a default position against the use of amplified music would mean that any event which wishes it, must justify the need against set criteria (e.g. impact on residents) and outline management and mitigation measures before consent is considered. Similarly, the closure of streets for filming should be an unreasonable disruption and justification would need to put forward.

The current processes exclude civic engagement. This should change. Of course, very small activities over short periods of time could be exempt but some form of public signposting is needed much in the same way as a planning application.

The information that is required to be submitted for event approvals at the moment is very light. The Cockburn Association has participated in a consultation forum for events in key public spaces such as Calton Hill and has seen just how poor the level of information required to gain consent is. This Plan provides a very positive opportunity to address this, and we would advocate the creation of a task group to help define what types and levels of information should be required.

Future imperatives

The current premium on open space as a result of Covid-19 isn’t reflected in this paper. Covid has helped society understand and appreciate the value of open spaces, providing places for well-being activities. Whilst we might question to the implementation of schemes such as Streets for People, the sentiment encouraging greater civic use of streets is a fair one and reflects a changing attitude to civic space and civic amenity. Commodifying open space is counter to this and the Plan should reflect this.

Various consultation surveys show that the most valued attributes of parks and gardens are their tranquil and green nature (West Princes Street Gardens, for example). These qualities can be shared and experienced by all visitors, whether residents, workers or tourists. The default position for the PSMP must be the retention of these qualities. Commercial events with an element of exclusive ticketing or branding should be avoided or kept to a minimum. The Summer Session concerts illustrated the conflict between open space as a performance arena and open space as a civic amenity, especially for commercial ventures that require a high degree of exclusivity. Hoardings, crowd-control gates and threats of street closures to management public safety are all illustrations of the unsuitability of such activities in public parks.

A paper considered by the Policy and Sustainability Committee on 10 January 2021on filming noted that this activity generated less than £250,000 for the city although it highlighted the brand and marketing value. The benefit of allowing public spaces to be used for private ventures should be required to demonstrate a direct benefit to the City. At the moment, there is little in the way of meaningful consultation with residents and civic groups on the impacts of street closures, etc, only noting that local businesses impact may be able to negotiate compensation from filming companies.

This suggests an Activity for Activity’s sake ideology behind the initiative. A more strategic approach considering the carry capacity of places to absorb events and activities is needed, where civic and amenity requirements are equal to tourist and cultural economic activities.

Need for overarching Strategy

In agreeing with the need for effective operational management of events, there is a need for a more strategic management plan for the wider use of streets and other public spaces and going well-beyond event management. The impact on public spaces due to construction and development activities can bring significant issues including pedestrian disruption, noise, etc.

It is the nature of many spaces that they are unable to take significant pressures of major events. The damage to East Princes Street Gardens caused by successive Winter Festivals/Christmas Markets highlights all too well the issue. In 2019, for the 6 weeks operation of the enhanced market with its large space deck, the gardens were closed for a total of 6 months (including set-up, take down and landscape repair/recovery time). Thus, a civic asset was unavailable for public use as a result of a commercial venture for a significant period of time. This cannot be acceptable.

A Public Spaces Management Strategy should also include other issues affecting public space, such as street closures facilitating construction work, etc. These need not be managed through any central department but the criteria for use of civic assets should be set out in a coherent manner. This should also include spaces not under the control of the City Council but also those under institutional or private management.

Pseudo-public space

Pseudo-public spaces – large squares, parks and thoroughfares that appear to be public but are owned and controlled by developers or private interests are a feature of Edinburgh. The criteria used for assessing suitability for events or other activities should be applied these spaces as well. Although they are seemingly accessible to members of the public and have the look and feel of public land, these sites – also known as privately owned public spaces or “Pops” – are not subject to ordinary local authority bylaws but rather governed by restrictions drawn up the landowner and usually enforced by private security companies. For example, Bristo Square and George Square are owned by the University and host large scale events but would not be covered by the PSMP despite the potential impacts and the perceived civic nature of the space.

Other examples of Pops would be the various New Town gardens. Charlotte Square has become synonymous with the Book Festival, but its management sits outside the PSMP as it is a private space. Concern has been expressed over many years about the physical state of the land post the festival, which has visual amenity impact borne by many. As such, its regulation through the PSMP would be beneficial to the city.

Such spaces need to be included in the PSMP because their use as event spaces can have significant impact on public amenity.

Overlap with other consenting regimes

Following on from this point, it is important that the PSMP articulates the wider consenting regime. The scandal of the space deck being erected in East Princes Street gardens without planning consent illustrates this issue perfectly. The Cockburn has undertaken a very quick review of other open spaces and has found that major events have operated without planning consent, or so it seems.

Common Goods Land

In 1491, the Scots parliament passed the Common Good Act affirming that the land and property of Scotland’s royal burghs “be obseruit and kepit to the commoune gude of the toune and to be spendit in commoune And necessare thingis of the burgh. From that year until the Burgh Reform Act of 1833, the landowners and the commercial bourgeois class controlled all burghal administration of the common lands and controlled it in such a way that vast areas of common lands were quietly appropriated.

Much of Edinburgh’s public space is Common Good Land. It is held for the benefit of citizens. As such, a separate vehicle for oversight should be required as part of the management process. This might be built into the PSMP and should require special attention to the played.

Summary and Some Cockburn suggestions

The following represents some ideas and thoughts which we feel should be considered as part of this exercise:

All events, in all public spaces including streets should be covered by any emerging plan;
The remit of the PSMP should include all public spaces, and not be limited CEC owned and/or controlled spaces is too limiting and not acceptable;
Common Good Land is not CEC property – this requires a separate process for management and event approval and management;
Commercially exclusive events which require restriction of public access for even relatively short period of time should be discouraged;
For major events that require ticketing, the assumption should be that most tickets should be free to users, allowing a small percentage of sold tickets for VIP and commercial reasons. As in New York City, the assumption should be use of a public space is for public benefit and enjoyment;
Community events and major commercial events require different and bespoke registration and management processes and fee structures;
The acceptability of holding major events in public spaces at times of year when access to public spaces are in high demand for informal recreation, rest and well-being should be heavily restricted;
The PSMP must have city-wide and community-wide climate mitigation, climate adaptation, biodiversity, tree expansion and sustainability issues at its heart. ISO20121 should be the minimum standard required.
Future events in public spaces should be required to clearly express how they will add to or detract from the quality of life in the city as a whole and their host residential communities.
All collateral impacts of events in public spaces e.g. noise, pollution, policing costs must be identified, and mitigation frameworks brought forward and incorporated into events approval and management processes. The cost of meeting these and remedying any impact must fall wholly to the event and not the public purse.

The Cockburn Association would be delighted to assist in the development of this ideas and the furtherance of effective management policies for the city’s public and quasi-public open spaces.

Back to Listings