Greener Leith 36, Newhaven Road Edinburgh EH6 5PY www.greenerleith.

org

27/1/2012

The Local Development Plan Team, Waverley Court (G1), East Market Street, Edinburgh EH8 8BG
Dear Sir/Madam,

Please find our consultation response to the Main Issues Report below. Edinburgh Local Development Plan - Main Issues Response by Greener Leith Question 1: In considering the future of Edinburgh, what matters most to you? Do you agree with these 5 aims or are there other priorities? Please provide a reason for your answer. Few would argue with the headline aims of the Local Development Plan. A key component of the success of the city is its compact and walkable nature. Every effort should therefore be made in the development of the LDP to maintain a compact city and guard against urban sprawl and car dependency across all land use types. Furthermore, given the uncertain economic outlook, we believe that the predictions of housing demand that inform the plan have considerable margin for error. There remains numerous brownfield sites within the city, particularly within the North Edinburgh area which provide a great deal of capacity for new housing.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

Against this backdrop, we question the need to develop so many areas of the citys existing greenbelt and believe that the plan should support a robust brownfield first approach to accommodating housing demand as it arises over the lifetime of the plan. Like the Cockburn Association we question whether the assumption that the economic growth of the city requires it to physically expand. Indeed the plan should acknowledge the economic and environmental risks of policies that promote low density, greenfield suburban sprawl could entail. On Transport the Local Development Plan should explicitly aim to cut carbon intensive transport use. It should also explicitly set out a commitment to supporting Scottish Government aims for 10% of all journeys to be undertaken by bike and the City of Edinburgh Council Active Travel Action Plan targets. Furthermore, the LDP should explicitly set-out and protect routes that may form part of future expansion to the Edinburgh tram line that is currently under construction. On Heritage and Building Conservation it is clear from the ongoing controversy over sites such as the Caltongate, that the citys existing built heritage and its wider historic setting is often viewed by property developers, and even local councillors, as an anachronistic barrier to development and economic growth. In our view this is far from the case, as the citys unique built and natural heritage is what makes attracts so many people to Edinburgh in the first place. We would wish to see the Local Development Plan take a more robust approach to preserving and conserving our environment. We note that there is little mention of air quality in the LDP, and under section 8.5 we note that the MIR adopts a complacent approach to air pollution. Given that an increasing number of sites in the city are either breaking, or at risk of breaking, air quality standards we feel that the LDP should explicitly recognise the health impacts of poor air quality in the city and include more concrete provisions for tackling this very real problem.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

Questions 2-4. We strongly oppose all proposals to build on green belt land whilst there is sufficient brownfield land, and scope for increasing density, within the current urban area of the city. New development in the greenbelt is likely to be a significant driver of increased CO2 emissions, particularly relating to transport, and therefore if any development is permitted in these areas it must only receive consent on the basis that the developments are well connected to public transport and active travel routes, as well as mandating specifically for electric, or very low carbon fuel vehicles. Question 5. Do you agree with the preferred approach to how the LDP should deal with housing in the built up areas? Or do you support the alternative? The primary aim of this question seems to be supporting the house building industry. In our view there is no justification for reducing the density or the amount of existing housing land within the urban boundaries of the city simply to provide an indirect bail out for property firms that made poor economic decisions in the past. The city should establish a minimum density policy throughout the city sufficient to promote a compact, liveable city and sustainable development. Such a policy, coupled with a presumption in favour of developing existing housing land before permitting development in the green belt, will help to minimise the amount of agricultural land that needs to be sacrificed within the green belt. Given that our current food production and distribution system depends on cheap fossil fuels, a long term vision of a sustainable city should adopt a prudent approach toward protecting existing agricultural land that is located relatively close to the city on the basis that fossil fuel inputs into the food system may decline over LDP timescales.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

Question 6: Do you agree with the preferred option for the future role of Leith Docks? Or do you support the alternative? The future of the Leith Docks area is extremely difficult to foresee. Clearly, there are many in the city, who largely support the existing mixed use development proposals for the docks. Numerous small and medium size businesses have been attracted to the area, and indeed flourished, against the unique mixture of creative, culinary and tourist attractions that have developed in the area. Historically, Forth Ports attempts at place making have left much to be desired, but in spite of this there is broad local support for a continuation of the mixed use development approach, based on improving access to the Waterfront, redeveloping the area around Ocean Terminal as both a high density mixed use area and a tourist attraction. Following the economic downturn, and the sale of Forth Ports, the primary land owner in the area, together with Scottish Enterprise and backers in the Scottish Government and the City of Edinburgh Council have stated a preference for an alternative, largely industrial future for the docks area. Even though this future has only been very roughly sketched out in the MIR, as the reasonable alternative, it is clear that with more than 500,000 committed from Scottish Enterprise to fund a detailed new masterplan for the area, that the option described as a reasonable alternative in the MIR is fast becoming the preferred option, and perhaps even the only option on offer to Leithers. Given this, we would like to reject the two choices outlined in the MIR and argue that a far more flexible future for the docks needs to be accommodated in any new LDP. A means of obtaining a reasonable balance between national economic ambitions to develop the area as a renewable manufacturing hub and the requirements of the local community must be found. Achieving this will require a far greater commitment from the city council, key land owners, and Scottish Government agencies to transparency - and meaningful, early, community engagement over the future of Leith Docks. Greener Leith, like many in the local area, would be delighted to see green industries set-up on the docks.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

However, not all industries have the same local environmental impact and to date, no new large manufacturer has committed to investing in the docks area. Despite the optimistic rhetoric over renewable energy jobs from some quarters, the only tangible major development on the table is the proposed Forth Energy power plant. This has been dubbed the most unpopular planning application in Edinburghs history. It is a good example of an industrial development that, if consented, will bring few new jobs or benefit to local people. On the contrary, as objections from Vist Scotland, and local businesses attest, it is widely held by the existing community in the neighbourhood to be a serious threat to the local economy. Therefore, the LDP should explicitly set out parameters within which every proposed industrial development on Leith Docks must comply. It should not provide a blanket designation that could provide a green light for any project which claims to hold green credentials. For example, the view corridors in the existing masterplan for the area should remain protected, as these serve to support the integrity of the city centre world heritage site, as well as preserving local amenity. The LDP should give careful consideration to air quality impacts in the area, given that there are several streets in the area that are already in breach, or at risk of breaching, EU air quality rules. The LDP should explicitly support the current Scottish Government policy on biomass power. Scottish Government policy on biomass favours deployment of biomass in heat-only or combined heat and power plants, particularly in off gas-grid areas, and to a scale which maximises heat use and local supply. Furthermore, in order to help promote the city as a leading proponent of high sustainability standards, the LDP should support the requirements set out in the EU Renewable Energy Directive, which require biomass developers to achieve a conversion efficiency of at least 70%.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

With regards to green space provision in the area the LDP should take heed of the findings of the citys Open Space Audit. In 2009, we noted in our response to the council Open Space Audit consultation: The average amount of open space per 1000 people in Edinburgh is 4.25 ha. In the Leith Partnership area this figure however is only 1.35ha, or about one third of what the rest of Edinburgh enjoys. As a result these open spaces are very heavily used and generally in a somewhat tired condition. Leith Links, a Premier Park, is a telling example: of all Premier Parks in Edinburgh the Links are the smallest and the least well kept. Virtually all the sites available to develop meaningful new green space in the Leith area is on land owned by Forth Ports. Both options set out in the MIR will result in a reduced provision of public green space when compared with existing plans. This is unacceptable, and will hinder mixed use regeneration of the area. In our view, a greater quantity of public green space, and indeed new allotment space, which is in very high demand in North Edinburgh, must continue to be identified and safeguarded in any future LDP regardless of the nature of the development around it. There should be a presumption in favour of early investment in such greenspaces, in any future development. If the housing allocation is significantly reduced in the Leith area, this in turn, runs the risk of critically undermining the business case to complete tram line one to Newhaven. It also increases the risk that more green belt land will have to released elswhere to make up for the shortfall in housing land. In our view, this would be undesirable, as the completion of tram line 1 to Newhaven has the potential to provide a significant economic stimulus to the whole of North Edinburgh and the Leith Docks area. Given that no detailed independent studies are available that compare and contrast the economic and environmental benefits to Leith and Edinburgh of the two MIR options for Leith, we feel that it may not be prudent to zone such a large expanse of land for, as yet, unspecified industrial uses, when other uses may generate more local employment, more rapidly, were they to enjoy the backing of the right combination of government backed regeneration policies. Adopting an inflexible, and dogmatic policy toward the zoning of Leith Docks runs the risk of curtailing the wider regeneration of the area for a generation.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

With regards to housing there is a considerable local demand for larger dwellings with three bedrooms or more located in family friendly neighbourhoods. In order to promote sustainable, stable, mixed communities the LDP should set out a presumption in favour of the development of larger family homes in Leith, as opposed to the current focus which has succeeded only in supplying the monotony of one and two bedroom flats that have typified the mode of development in Leith over the last decade. It is clear that the current preferred route of the Waterfront promenade around the edges of Leith Docks may never materialise over the lifetime of the new LDP. In order to promote active travel, the LDP should explicitly identify, protect and support investment in an active travel route that will provide an alternative link between the two developing sections of waterfront promenade to the East and the West of Leith. We note several development proposals in the area that could see land currently used as light industrial land converted into housing and office/commercial uses. In our view, the LDP should take a more explicit stance on the maintenance of small, light industrial capacity in the area, in order to maintain a diversity of employment opportunities and support local small businesses in the Leith area. Lastly, in order to protect the vitality of the traditional town centres of Leith on Great Junction Street, and Leith Walk, there should be a presumption against any significant expansion of retail floor space at Ocean Terminal, or the immediate vicinity. Retail growth in the docks should only be permitted if it is combined with an increase in new housing. Question 7: Do you agree with the preferred option for the four potential housing regeneration sites on existing open space? Or do you support the alternative? Greener Leith supports the alternative option.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

Question 9. Do you agree with the preferred approach to seeking developer contributions towards infrastructure provision? Or do you support the alternative? Greener Leith strongly supports the present system of developer contributions. The contributions should be as loosely tied to the site of the development as possible as local councillors, in consultation with planning officers and local residents, are best able to assess the infrastructure required to support any specific project. Given that public sector capital budgets are likely to be under significant pressure in forthcoming years, maintaining a flexible approach to developer contributions is essential. Question 10: Do you agree with the preferred approach to planning for and providing office space in Edinburgh? Or do you support the alternative? Greener Leith strongly disagrees with all the options. We have sympathy for the views put forward by the Cockburn Association who note that no account is being taken of the increasing number of empty new offices throughout Edinburgh and that some have never been occupied since building nearly 10 years ago. As housing land without detrimental environmental effects is becoming a scarce resource, we believe that the scope for 'surplus' new offices being reused for housing should be explored as a matter of urgency. We commend this as the preferred option at this time. We also question the rate of conversions in existing office accommodation in the city centre, which is the most environmentally sustainable location in terms of accessibility. It is not desirable to take existing office accommodation out of the supply equation simply to recreate it in an office park on the edge of the city. Any new strategy for providing new office space must look at the change-of-use impacts and develop an overall strategy for existing and future stock to see how this impacts on potential supply requirements. In general we support the maintenance of a strong central business district where public transport connections are concentrated, so as to minimise the growth in car use for journeys to work.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

Question 12: Do you agree with the preferred approach to planning for new retail development? Or do you support the alternative? The LDP should continue to promote retail growth in the city centre. Policies that seek to limit out of town, and out of town centre shopping developments, need to be robustly worded and enforced more effectively than at present. Furthermore, new retail developments should seek to prioritise active travel modes over car access. Question 13: Do you agree with the preferred option to allow some non-shop uses along Princes Street? If so, on which frontages do you think non-shop uses should be allowed (see A - G on map)? Or do you support the alternative? Greener Leith strongly supports the preferred option. Question 14: Do you agree with the preferred approach to non-retail uses in town centres? Or do you support the alternative? Greener Leith supports the preferred option. Question 16: Do you agree with the preferred approach to implementing the Central Scotland Green Network? Or do you support the alternative? Given the emphasis on access and open space we strongly support calls from SPOKES that this section of the LDP should be explicitly linked to general pedestrian and cycle networks as outlined in the Active Travel Action Plan. Specifically, references should be made to the ATAP Family Network and Cycle Friendly City network; and to reinforce this the proposed Family Network map (page 23 of ATAP) and the Cycle Friendly City concept diagram (page 25 of ATAP) should be reproduced in the LDP. With this proviso, Greener Leith supports the preferred option.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

Question 17: Do you agree with the preferred approach to changes of uses relating to local centres and facilities? Or do you support the alternative? Greener Leith supports the preferred option. Question 18: Do you agree with the preferred approach to setting out carbon reduction requirements? Or do you support the alternative? It is remarkable that this section of the MIR makes virtually no reference to low carbon and active transport. Just as the LDP proposes to place a requirement on large developments to incorporate CHP, there should be also be a requirement on new developments to take specific measures to support low carbon travel. For example, this could include funding quality cycle route connections into the wider city network, incorporating electric vehicle charging infrastructure, and minimising private car parking. The LDP should contain an explicit presumption in support of renewable energy schemes that are owned and developed by non-profit community organisations. Do you support the suggested policy changes in relation to green roofs and Combined Heat and Power plant? Yes. Question 19: Do you agree with the preferred approach to waste management? Or do you support one of the alternatives? Greener Leith supports alternative option 2. In our view local residents would be more keen to support other land uses in this area of the docks - for example, a more generous seaward extension to Leith Links. Furthermore, given that air quality in the area is already poor, we would be concerned over the local environmental impact of a waste to energy facility on that site. We do not believe reference to Best Practical Environmental Option should be dropped.

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095

Question 20: Have you any comments on the other possible changes outlined in Chapter 9? We are strongly opposed to allow developers to meet their obligations to provide a proportion of affordable homes off-site. This is a retrograde step that runs the risk of creating low income ghettos and increased social segregation within the city. The evidence suggests that the current policy that favours on-site provision of social housing is effective and should not be altered as the long term social and economic costs could be significant. The Depot site in Inverleith Park should be re-designated as open space as it is part of the park. The community should be consulted about proposals for its future use. About Greener Leith Greener Leith is a registered charity that aims, with the help of hundreds of local supporters, to promote community involvement, better public spaces and sustainable development. Greener Leith has an open membership structure and each year our management committee is elected from the members. You can find out more about Greener Leith at www.greenerleith.org Contact This consulation response was prepared by Alastair Tibbitt on behalf of Greener Leith Alastair Tibbitt, Greener Leith, 36, Newhaven Road, Edinburgh. Email: justask@greenerleith.org

Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095