Edinburgh Christmas Market 2022 – Comments on planning applications

Cockburn Response

The Cockburn Association has examined the three interconnected applications for a Christmas Market submitted by Underbelly.  We offer the following comments.  In doing so, the Cockburn believes that there are common issues for each, and the separation of what is a single event into three different applications is unhelpful when considering the total impact of the proposals.

General comments

We acknowledge the significant challenges in delivering this year’s Christmas Market.  The failed procurement exercise with Angel Events should be reviewed urgently in the context of previous year’s controversaries with the Winter Festivals.  An independent process should be initiated looking at the failures of the procurement process.  This is essential to prove the public and elected Councillors the necessary insight to determine an appropriate way forward for any future Winter Festivals.

We strongly advocate that given the circumstances now, any approvals should be for one year only.  We acknowledge the challenges that Unique Assembly as a recent substitute contractor have faced in attempting to pick up someone else’s planning applications.

We also note that other cities such as Leeds and Glasgow decided to cancel their Christmas Markets or major holiday celebrations this year.

The Cockburn realises and sympathises with the continuing challenges that local businesses face.  It is therefore essential that any festive activity aims, first and foremost, to increase activity for the brick-and-mortar businesses in the city.  In our discussions with Unique Assembly, we appreciate their ambitions to seek, for example, 65% of stalls to be local traders.  This needs to be fully and properly assessed as part of the overall process.  As such, the Cockburn believes that a local economic study should be required as part of any consent (should it be given) to quantify the level of local economic value and of economic spillage outside the city.

It is essential for the Council, both political and administrative, and operators/applicants to fully appreciate that the winter festivals rely entirely on the use and exploitation of public assets like streets and gardens for their success.  Decisions taken on all accounts, must be open and transparent.

In general, the Cockburn recognises the popularity of the Christmas Market and its contribution to the vibrancy of the city.  However, we also note that they are major commercial events than cultural activities and the Christmas Market has moved from the German Market that occupied the Mound with largely authentic products and produce to a disruptive event that imposed significant restrictions on local residents, targeting the tourism market with 2018 figures indicating that less than 50% of attendees to the Christmas Market were locals (falling to just 20% for Hogmanay).  A fundamental shift in benefit is required – in effect the Christmas Market must serve the city, not the other way round.

In this, we continue to call for a greater dispersal of activities noting that the significant problem with the Winter Festivals pre-Covid was the desire of commercial operators to concentrate activity is a small area.  Although some movement has been made in this regard, further dispersal is required.  The Cockburn 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. We suggest that this should include existing markets, such as those in Stockbridge, Castle Terrace Car Park and the Grassmarket.  Festival Square and Conference Square should be used as well and be well suited for the fairground elements of the market.

We are pleased that the concentration on East Princes Street Gardens alone has changed.

The Cockburn remains concerned with the proposals as they stand, and believe that greater efforts in terms of dispersal, further reduction in use of soft surfaced areas and a greater need to support local businesses is required.  Our assessment is and must be based upon the information in the planning applications as submitted, and not on any discussions we have had, however constructive, with Unique Assembly.

Overall, the Cockburn does not formally object to these applications, nor do we support them.  Our concerns would be lessened slightly if the applications were for this year only.  All three applications have major deficiencies in information and are inaccurate in many instances.  The planning statements do not articulate on any satisfactory way the impacts to heritage assets such as listed buildings, etc.  No detailed locational information is available for disposition of stalls, rides etc and the associated management of crowds.

We appreciate the special circumstances that Unique Assembly as “rescue applicants” find themselves in but there can be no excuses for a failed public procurement process given recent controversary and history of the Winter Festivals.

Specific Application comments

The Cockburn has no objection to the use of George Street for a dedicated ice rink with ancillary functions such as toilets and changing facilities.

However, we cannot support the application as no details of the actual structure to be erected have been submitted with the application.  There is no way of ascertaining the impact on the neighbouring businesses or listed buildings and Conservation Area without them, and strongly advise that no consent be issued until this information has been submitted.  It is essential that any development here respects the qualities of George Street and the World Heritage Site.

No information on the management of support infrastructure is provided.  We are concerned with the impact of generators, etc on the immediate environment.  Similarly, we are also concerned with the lengthy periods required for set up and take down of the temporary structures and the disruption that this will cause for pedestrians and businesses alike.

The site boundary runs up the curb line on both sides of the street.  The current relaxation for outdoor seating has seen many of the hospitality businesses exploit the opportunity with substantial outdoor dining arrangements especially on the north side of the street.  The implication of Underbelly’s application is that these facilities will need to be moved before the erection of the ice rink can begin.  As it seems likely that the relaxation of licensing will continue, this needs to be clarified as a matter of some urgency.  In addition, the potential crowding of restricted pavement space seems likely, and could make crowd management more challenging.

The Cockburn would wish to object to the proposed pop-up bars and retail shacks within the ice rink enclosure.  As already noted in our general comments, we believe that these represent unfair competition to existing businesses who are struggling to recover from the past 20 months of restrictions.  We understand that these views are also shared by the George Street Association which represents a wide of local interests.

We have no specific concerns regarding the use of The Mound for the Christmas Market.  This has been used for several decades now and if properly managed should present no issues.  But we do have concerns with pop-up bars, preferring trade to be given to permanent businesses who operate year-round.

Regarding the upper terrace in East Princes Street Gardens, we would prefer this to be deleted from the proposals and possibly moved to Waverley Bridge.  This would avoid damaging the soft surfaces and permitted other activities such as the remembrance garden greater time to be enjoyed.  It must be said that we have little confidence in either Underbelly or the City Council in restoring the area of ground post-damage or in preventing it in the first place.

Regarding proposals for  West Princes Street Gardens below these were  new in 2021, and our initial assessments based on site visits during its operation suggests that it was, in general terms, reasonably successful as a venue.  However, there were areas of significant deficiency, and these must be addressed, in particular,  the damage done to soft surfaced areas as part of Santa’s Grotto and Christmas maze, as well as damage to the grass on the fringes of the blaise area.

There is little information available to determine the potential negative impacts in these areas.  As a matter of principle, all soft surfaced areas should be avoided with all development contained in areas of hard surface.

The application suggests that the upper terrace will form part of the site but there are few details to explain how it will be used in the application. We have no objections to its “soft” use as a festively lit route between East and West Gardens and believe that there are some positive opportunities for the use of the existing shelters as points of interest along this path.

Whilst we appreciate the desire for this part of the Christmas Market to be open later than usual closing time (dusk), the implications of this need careful consideration and effective/active management.  Will this result in the erection of a barrier across the Gardens to prevent access to areas to the east of the Ross Fountain?  How will it look?  Will it be manned, and by whom?  This could present an unsightly and aggressive barrier which would affect open access during normal hours or would at least impact on the openness of this most important civic space. No information on this has been provided on this and should be before any consent is considered.

The use of St Cuthbert’s Graveyard for operational servicing should be avoided.  Experiences of other events recently suggests too great a conflict between vehicles and pedestrians as well as impacting on it as a heritage asset.  The management of the graveyard in the dark hours is also issue that requires attention.  There is no reason why it could not be made attractive.

Image: Pixabay