City Plan 2030 Consultation
Posted on: December 20, 2021
Our detailed response to City of Edinburgh Council’s consultation on CityPlan 2030
Public Consultation By:
City Plan 2030 sets out locations for new homes and businesses, where new infrastructure and facilities are required and how the Council will protect places of value. It provides policies which will be used to determine future planning applications.
This consultation is your last chance to comment on the content of City Plan.
Opened for comments:
Whilst there are many aspects of City Plan 2030 that we welcome and support, we find that it is weakest in those areas of greatest importance, namely Climate impact and preparedness, Covid and post-Covid resilience and Brexit where the implications of leaving the EU over the plan period are not considered and the implications to economic prosperity with a probable change in relative importance of certain sectors and approaches.
These omissions seriously weaken the Plan’s robustness and resilience especially in the later years of its life. The Cockburn therefore calls for meaningful revisions and policy statements on how the LDP will tackle these most significant of issues facing the city.
Edinburgh needs a City Plan which is fit for purpose not just at the beginning- period of the plan but also at its end-period. Therefore, the plan’s aspirations, outcomes and policies need to be in the language and aspiration of tomorrow not just in the language of today.
Sustainable Carbon Neutral city (paras 2.28 – 2.32)
Further to our general comments, we believe that the framework for this policy subject is narrow and lacks any serious credibility. Land-use policy will need to change radically if net-zero carbon targets are to be met, including presumptions of growth and regional support and development.
The Cockburn calls for an examination and explanation of how this plan and its policies will directly influence this objective rather than a discussion on other legislative or statutory frameworks.
Well-being and Equalities
The unsubstantiated comments here on how the plan improves well-being is a strategic weakness of it. There is no strong indication of how public health and land-use planning will be framed in this plan, with unclear statements of the roll of 20minute neighbourhoods as a mechanism for achieving this. The Cockburn asks for much greater clarity and depth of initiatives to be set out here, so that policies can be judged against this most important objective.
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.
Our comments will be covered under consideration of specific policies. We note the quantitative analyse of housing need and suggest that the narrative around growth and operational carbon requirements needs to expand to include embedded carbon and wider sustainability issues.
Qualitative assessment and outcomes for housing are largely missing, however. The Cockburn believes that the spatial standards for new housing must improve if the city is to build resilience into a post-Covid recovery city, where more and more home-working if likely to feature. The UK has some of the meanest space standards in Europe. We therefore advocate additional policies to be developed to enhance the existing array including the better minimum spatial standards and increased outdoor space for well-being and active family environments.
Sustainable Energy (2.129-129)
The Cockburn believes that it is essential if we are to meet the net-zero Caron Strategy by 2030 that we move beyond a simple operational carbon/energy perspective of development and shift to a total carbon/energy assessment, taking into account life cycle costing and embodied energy in materials.
We also believe that new building including mass housing should include renewable generation technologies within the fabric, evidenced at the point of consent. Thus, the Cockburn advocates additional policies on the sustainability of building materials and building technologies as well as a policy on renewable energy generation in all new developments.
The Cockburn offers comments on some but not all place-based policies.
PLACE 1 – City Centre and Waverley Valley
The Cockburn is broadly supportive of the Ciy Centre transformation project and its various proposals. We do have concerns with renewal of the Ross Bandstand and other facilities in West Princes Street, and do not support the radical redevelopment vision of the Ross Development Trust to create a 4-6,000 seat venue in the heart of West Princes Street Gardens. A number of ENV policies are relevant so this policy should be amended to include reference to other policy objectives such as protecting the special characteristics and outstanding universal values.
PLACE 2 – Fountainbridge
We are broadly supportive of the policy here, although we would strongly recommend an additional statement supporting the vertical integration of uses in each development area. Large, mono-use blocks should be avoided. The policy should therefore be amended to encourage this.
PLACE 3 – Astley Ainsley
In general, we are supportive. However, the first bullet point should be amended from “respects the mature landscape setting of the site” to “preserves the mature landscape setting of the site”. This is to ensure that any development starts from the objective of conserving the character of the site.
PLACE 4 – Edinburgh Waterfront
We are increasingly concerned with the quality and quantity of development that is being placed in this policy area. To this end, we do not support the first bullet point “comprehensively designed proposals which maximise the development potential of the area” in that maximising the development potential should not be a policy objective. Instead, this might be merged with the second point – “provision of a series of mixed-use sustainable neighbourhoods that connect to the waterfront, with each other and with nearby neighbourhoods” – to emphasise that the delivery of sustainable neighbourhoods is the primary objective and one consistent with the 20 minute neighbourhood ambition.
Western Harbour and Central Leith Harbour policy areas need to fully explore the impact of rising sea levels on the suitability and feasibility of development. This should not be considered as a remote possibility but integrated into a revised set of land-use allocations that actively plan for increased storm surges and sea-based flooding. The statement carry out a flood risk appraisal to inform the design and layout of development proposals is wholly inadequate in this regard and objectionable as a result.
Granton and Granton Waterfront – we are broadly in agreement with the principles, subject to the above comment on sea levels. We welcome the development principle to create a new Coastal Park, but concerns with the principle Some small pavilion buildings and a larger focal building could be accommodated within the coastal park to provide places to meet, eat and enjoy activities, as these may eroded the positive values of the park in the first place. Also, it would be likely that these would displace activity better directed towards existing businesses. We therefore ask that this be amended.
PLACE 5 – Crewe Road South
This represents a significant development opportunity within the city. We welcome the statement to Make iterative use of Townscape and Visual Impact Assessment to identify footprint, height and massing of built form, respecting existing townscape, landscape and conservation area setting and surrounding residential character. We feel that this might be strengthened to ensure that the TVIA precedes any development proposal of scale coming forward with the aim of ensuring the deliver of this element.
Existing trees should be protected as a matter of principle. We would also advocate the removal of large areas of hardstanding where not required and their return to green space. Substantial levels of new tree planting should form part of any development masterplan.
PLACE 7 – Stead’s Place & Jane Street
We welcome the commitment to retain the 2-storey building at 105 Leith Walk. The plan does not reflect the proposed extension of the Leith Conservation Areas which proposes to add the former railway embankment and bridge abutments into the area, which we support. We would strongly advocate a unified urban design framework be prepared to ensure the architectural and streetscape coordination of any new development coming forward. The haphazard approach of allowing developments to come forward without an integrated vision is apparent in the nearby area.
PLACE 16 – West Edinburgh
We are concerned with the growth strategies for West Edinburgh and therefore require clarification of the mitigation measures which will address the negative environmental impacts identified in the Strategic Environmental Assessment Environmental Report related to this development expansion.
PLACE 17 – Edinburgh Airport
As with PLACE 16, we have concerns regarding the expansion of development in the airport area. Clarification of the mitigation measures which will address the negative environmental impacts identified in the Strategic Environmental Assessment Environmental Report is required before this policy should be adopted.
PLACE 30 – Redford Barracks
Overall, we welcome the general principles for the repurposing of this site. However, all existing green spaces should be retained and enhanced for public and climate mitigation benefit and all existing trees should be protected as a matter of principle. We would also advocate the removal of large areas of hardstanding where not required and their return to green space. Substantial levels of new tree planting should form part of any development masterplan.
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.
HOU1 Housing Development – In some instances, the sites allocated are not genuine effective housing sites as constraints may mitigate against development. We would therefore advocate that the policy makes clear that in addition to the statement “Development should accord with the Place
Polices and development principles set out in Place 1-Place 36 and Appendix D” that development should also be accordance with the other policies as set out in the plan. This is remove any doubt.
HOU 2 Affordable Housing – In supporting this policy, we suggest the deletion in para 3.193 of the phrase “or as far as possible” which refers to providing 35% affordable housing for developments over 12 units in scale. The need for affordable housing over the plan period is very clear and should not be delighted by caveats that suggest otherwise.
HOU 4 Housing Land Supply – We do not support this policy as the wording suggests that it may be used as a ‘trojan horse’ for development of greenbelt land. The allocation of housing numbers includes a 20% Generosity Allowance over and above that required. No further allocations should be accepted.
HOU 6 Student Accommodation – The Cockburn is unsure about this policy. Whilst we accept that there is some need for additional accommodation, the policy provides no position on over-provision in areas of existing concentrations of student housing. We would therefore advocate a return at a threshold policy as used to exist in previous LDPs.
We also query the suitability of a area-based threshold in the context of housing and affordable housing provision. A threshold based on numbers and density might be better. The design of student accommodation should be capable of adaption to mainstream housing in order to ensure long-term carbon benefits and greater flexibility in changing circumstances. This should be built into this policy. Finally, we ask for clarification of the criteria with will be used to determine no adverse impact on established character of an area.
HOU 7 Loss of Housing – We welcome and support this policy. However, we would advocate a policy statement in enforcement in areas of significant STL concentrations which have no consent. Also, the policy should include the proposed STL Control Area currently under consideration and outline a policy-basis for considering Change of Use applications associated with it.
Hou 8 Inappropriate Uses in Residential Areas – We welcome this policy and its stated intention. However, we would advocate the retention of the policy in the existing LDP HOU7 which states, “the intention of the policy is firstly, to preclude the introduction or intensification of non-residential uses incompatible with predominantly residential areas and secondly, to prevent any further deterioration in living conditions in more mixed-use areas which nevertheless have important residential functions. “ This provides greater clarity for decision-making and reinforces the need to support housing in mixed-use areas.
INF1 Access to community facilities – Whilst we support this policy, the facilities and infrastructure referred to in para 3.203 needs to be considered in separate guidance and open to public consultation.
INF5 Location of Major Travel Generating Development – We support this policy but ask that clarification of what criteria to be used to determine ‘very good accessibility by sustainable transport’ be included in the plan.
INF9 City Centre Public Parking – Further clarification of provision for accessible parking is required.
Econ 1 Supporting inclusive Growth, innovation and culture – We support the intention of this policy subject to inclusion of a reference to lifelong learning. We particularly welcome the requirement that “Developers will have to demonstrate that proposals are not just associated with the five key criterion but meet other relevant LDP policies such as heritage and environmental policies.”
Econ 6 Hotel Development – We do not support his policy. Clarification is required on the relationship between the objectives of Econ 6 and those of Econ 2 for which seeks to ‘create sustainable communities, maximise opportunities for housing and avoid large mono use developments”. We also note that in February 2020, the Edinburgh Hotel Association reported an oversupply of bedspaces in the city. This does not align to the suggestion in para.3.253 noting that “it is unclear at this time what the long-term implications will be” in a post-Covid city.
RE9 Entertainment, Leisure and café/restaurant Developments (Preferred locations) – We support this policy and in particular the caveats that proposals must be integrated satisfactorily into its surroundings to a high quality of design that safeguards existing character and will not lead to a
significant increase in noise, disturbance and on-street activity at unsocial hours
to the detriment of living conditions for nearby residents. We would advocate that suitable criteria be set down in guidance for added clarity.
RE 10 Entertainment, Leisure and café/restaurant Developments (Other Locations) – As with RE9, Clarification of the criteria for determining “a significant increase in noise, disturbance and on-street activity at unsocial hours to the detriment of living conditions for nearby residents” will be required.
RE 11 Food and Drink Establishments – Clear criteria for determining ‘an unacceptable increase in noise, disturbance, on-street activity or anti-social behaviour to the detriment of living conditions for nearby residents’ will be required.