Our response to the City Plan 2030 Consultation

Today marks the final day for comments on the final version of City Plan 2030, the City of Edinburgh Council’s proposed replacement for its current Local Development Plan, approved in 2016. Read our full submitted comments to the consultation here.

In terms of the amenity of the city and the protection of its unique architectural and landscape heritage, the importance of City Plan 2030 to the short, medium and long-term future of the city cannot be understated.

The various Town and Country Planning Acts make it clear that “in dealing with such an application the authority shall have regard to the provisions of the development plan, so far as material to the application, and to any other material considerations.[i]”  Thus, City Plan 2030 sets down the rules, so to speak, for any land-use changes or development projects in Edinburgh.

Is 10-years too many?

However, there are many caveats to this.  Firstly, recent changes to the planning system made by the Scottish Government mean that the development plan is no longer a 5-year plan but a 10-year one.  Secondly, there are many developments that are not considered “development” so are therefore exempt from planning.  For example, statutory undertakers like power companies may be exempt from planning control, as is the local authority in terms of its functions as road authority.

Nevertheless, City Plan 2030 is very important and in general, the Association welcomes it and sees much to commend in its approach.  Many policies are laudable and supportable.  Favouring development on “brownfield” sites rather than sprawling into the Green Belt is excellent (although our experience suggests that this is less clear-cut).  The suite of environment and sustainability policies are comprehensive and generally coherent.

But there will be issues, and serious ones to boot.

The Big Three – where are they?

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 weaken the Plan’s robustness and resilience especially in the later years of its life.

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.  Given the world we live in, and the speed of change we experience, a static plan relevant for 2022 will probably not be relevant for 2032.  A continual process of updating and renewal will be needed.

Carbon Today, Carbon Tomorrow?

The plan’s aspirations, outcomes and policies need to be in the language and aspiration of tomorrow not just in the language of today.

For example, the demolition of existing buildings to facilitate new development is increasingly considered unacceptable.  Organisations like the Royal Institute of British Architects (RIBA) and Institute for Chartered Engineers (ICE) now state that there should be a presumption against demolition and that developers should be more considerate and should be obliged to refurbish.

Thus, we found ourselves both supporting and objecting to a new policy in City Plan 2030.  We welcome the new Policy Env 7 Sustainable Developments that requires the embodied energy and 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.  So far so good.  However, 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.  We know of no developer who could not justify their development on the grounds that it provides additional floorspace or houses. Inevitably, a whole industry of consultants will spring up with detailed calculations justifying redevelopment as the only way forward.  Will the City Council also tool up with experts in the Planning Department as well?  It is on this level of detail that the plan will work.

Heritage and Environment

Positively, we found the various environment policies to be well considered and comprehensive.  The commitment in City Plan 2030 to the city’s historic buildings and spaces, and to its special landscape qualities is encouraging. It will be the application of these policies by the planners and the Planning Committee that the real proof of pudding will lie.  Inevitably, there will be policy conflicts – for example, the proposed allocation of Broughton Market just off Barony Street as a housing site for 41 units fails to consider that the Market is a listed building within a conservation area, suggesting demolition is objectionable in policy terms – is a case in point.

Well-being and planning

Covid has made public health and wider well-being issues the top public policy area not just in Edinburgh but world-wide. 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 has asked for much greater clarity and depth of initiatives to be set out here, so that policies can be judged against this most important objective.

And speaking of 20 Minutes!  The current fashion in planning and urban design circles is the 20-minute neighbourhood.  Essentially, it means that the services required to meet one’s needs should be found within a 10-minute to and 10-minute back journey (approximately half a mile distance).  Think Stockbridge or Morningside or Portobello and you can begin to see what this looks like.  But think of the new housing estates being erected or areas recently redeveloped like parts of Edinburgh’s Waterfront, and the challenges become apparent.  What mechanisms will be required to delivery this policy objective?  They remain obscure and with changing patterns in everything from retail to healthcare provision, delivering this attractive initiative is not straightforward.

Further work

City Plan 2030 still has some way to go before it becomes the adopted Development Plan for Edinburgh.  Comments and objections received through this final consultation phase will be considered by the Planning Committee and amendments considered.  Ultimately, it is highly likely that an Examination in Public will be held (the appeal process for local plans) before anything is finally adopted.

The Cockburn will continue to participate in this process, which so far has been relatively positive.

 

[i] s37(2) of the Town & Country Planning (Scotland) Act 1997