! ! Greener Leith!

! ! 36, Newhaven Road

! ! Edinburgh
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Andrew Sikes,
City of Edinburgh Council,
Planning, City Development Department,
Planning Delivery, Business Centre
G.1 Waverley Court, 4 East Market Street,
Edinburgh EH8 8BG

28/3/2011

Greener Leith Draft Comments Waterfront & Leith Development Framework

Greener Leith welcomes this opportunity to comment on the Draft Waterfront &
Leith Development Framework.

Having attended two of the charettes, we agree that the vision expressed in this
document largely represents the views of the charettes’ participants in that the three
areas at the Waterfront, Leith, Newhaven and Granton, are considered to have a
very clear and strong individual identity. They are complimentary to the overall
identity of Edinburgh, but also function separately as the “beating hearts” of their
community. We agree with the broad thrust of the ADF that it is the strong identities
of these existing ‘hearts’ along the waterfront that need to be supported,
strengthened and extended.

We are however concerned that the brush strokes with which this ADF is painted
are too broad and that it is therefore open to conflicting interpretations. We
understand that this ADF is likely to have a strong influence on the next local plan,
and therefore we feel that it is important that ambiguity should be avoided wherever
possible.

The language used in this draft framework is in our opinion often too ornate and
elaborate to give the average reader a clear idea of what is proposed. Greener
Leith would welcome a more down to earth style and practical approach. Our fear is
that in years to come it will be impossible to hold anyone to account unless the
existing documentation defines clearly what is being proposed and is not open to
conflicting interpretations. This is particularly relevant to a local population which
consists of some of the most deprived in the UK. It should therefore be written in as
accessible style as possible.

The downloadable online images are not large or sharp enough to be able to see
them in fine detail, especially those that are hand-drawn. We would welcome an
option to download higher resolution images of key diagrams.
Greener Leith is a Scottish Charity and a Company Limited by Guarantee No. 365095.
We note that the document makes reference to the “Hammarby model,” for
promoting sustainable development on the Waterfront. The Hammarby planners set
challenging targets across a broad range of planning issues 1 when they put
together the Hammarby model; for energy efficiency, sustainable transport use,
renewable energy generation, waste minimisation, housing standards and green
space, to name but some.

There are no specific targets set out in the ADF document, but we note a
commitment to develop more detailed supporting plans and ‘sustainability
frameworks’ at a later date. The Hammarby model was based on sustainability
standards dubbed “twice as good” as their conventional city standards. Greener
Leith would be keen to see the city take a similarly ambitious approach with this
plan.

We would also be keen to see safeguards put in place, as far as possible, to ensure
that any standards that are put in place are not then ‘waived’ or watered down at
planning committee stage. As we have witnessed in recent years, some landowners
appear to have invested more energy in working out how to undermine the planning
standards that are already in place for the area, rather than working out how to
innovate solutions to meet them.

As we are sure city planners are aware there are many factors that must be
balanced in order to build a sustainable place. Wheeler (1998) identifies2 these key
factors:

● Compact, efficient land use

● Less automobile use, better access
● Efficient resource use, less pollution and waste
● Restoration of natural systems
● Good housing and living environments
● A healthy social ecology
● A sustainable economics
● Community participation and involvement
● Preservation of local culture and wisdom

It is implicit in the ADF that much of the largely private sector led regeneration in the
area to date has not taken account of these factors as fully as most people would
like. A further key factor in the perceived success of the Hammarby model was the
willingness of the city authorities to use compulsory purchase powers to acquire
key areas of land in support of the wider regeneration of the area. We note that this
is not an approach that CEC has taken to date.

1“Sustainable Urban Development: the Case of Hammersby Sjostad” Poldermans, C (2006) Available at:
http://www.solaripedia.com/files/720.pdf
2Wheeler, S. (1998), Planning Sustainable and Livable Cities. In: LeGates, R. T. & F. Stout (2003), The City
Reader. Urban Reader Series. Third edition. Routledge: London.
Greener Leith is a Scottish Charity and a Company Limited by Guarantee No. 365095.
Leith Docks may resemble Hammarby to the extent that both are post-industrial
areas, close to a city centre, with a waterfront. The difference is that Hammarby has
turned out to be a very attractive place to live, whereas the housing plans for Leith
Docks have faltered, with piecemeal housing development to be expected in the
short term. The prospect that a giant, inefficient power plant which is not scaled to
meet a specific heat demand may be built in a prime area of the waterfront hardly
inspires confidence that all the above criteria are any more likely to be met in the
future.

At the charrettes that informed the ADF, the proposed Forth Energy Biomass plant
was clearly identified as a potential threat to the continued regeneration of the area
(Pgs 14 and 15), and not reflective of a truly decentralised, low carbon green
energy development.

We are concerned that an attempt is being made in the ADF to reserve space for
the giant power plant proposed by Forth Energy, under the Hammarby banner, but
without the intention to achieve all of the Hammarby environmental objectives for
the rest of the community. We note that a key component in the success of the
Hammarby plant was the attractiveness of the built environment as a place to live.

No-one in Leith, or indeed elsewhere3 , believes the large power plant proposed by
Forth Energy will enhance the neighbourhood as a place to live, and the ADF
should do more to explicitly recognise that large scale, ‘bad neighbour’ industrial
developments that will have a significant impact on the surrounding area are
incompatible with the publicly funded efforts to develop a mixed economy in the
area.

The ADF should seek to protect the area from further inappropriate development
proposals such as the Forth Energy power plant and do more to support the
development of a genuinely mixed, resilient, local economy.

Without a more developed and wide-ranging commitment to deliver a liveable,

attractive, genuinely sustainable place, some may view it as disingenuous to use
Hammarby as a relevant exemplar. Whilst we don’t wish to be unfairly cynical, we
can’t help but note that local residents have also been skeptical of Forth Energy’s
recent attempts to compare their proposed plant to the genuinely low carbon,
decentralised, energy systems implemented in Hammarby too4.

3 “Last day for Leith Power Plant objections” Greener Leith, Available at: http://www.greenerleith.org/greener-
leith-news/2011/3/11/last-day-for-leith-power-plant-objections.html
4“The Big Leith Biomass meeting: The Tweets” Greener Leith. Available at: http://www.greenerleith.org/
greener-leith-news/2011/2/9/the-big-leith-biomass-meeting-the-tweets.html

Greener Leith is a Scottish Charity and a Company Limited by Guarantee No. 365095.
To be clear, Greener Leith is not opposed5 to genuine, decentralised renewable
and/or low carbon energy generation in the docks. However, this must be
developed at an appropriate scale and high efficiency from the outset.

In addition, we have noted that some of the most successful and sustainable district
heating systems in Scotland have been built on a non-profit basis, and that this is
likely to require strong leadership from the local authority if it is to happen in Leith.
Rather than looking to Hammarby for inspiration, perhaps we need only look to
Aberdeen and aim to emulate the practical successes of Aberdeen Heat and Power
in developing small scale, economically viable CHP and district heating systems?6

Great City Streets and “Development of Nodes”

Greener Leith would like to see the beginnings of workable ideas outlined for the
‘major nodes’ especially where it concerns finding solutions for existing roads. We
are also concerned that there is no precise definition of the ‘Great City Streets’ or
‘Development of Nodes’ in this draft document. All the streets blocked out in red in
figure 6 (p18) are already ‘great city streets’, but also suffer from too many cars,
congestion, rat-running a lack of dedicated bicycle lanes and poor quality public
realm.

Greener Leith would welcome more precise definitions of the proposed elements
such as ‘hearts’, ‘links’, ‘urban restructuring.’ We would like to see a how these
ideas reflect and link to existing city plans and strategies. For example, does the
ADF supersede the existing Open Space Strategy? Has it taken account of the
aspirations laid out in the recently approved Active Travel Strategy? What are the
implications for the North Edinburgh Transport Action Plan (NETAP)?

Our own community involvement work7 which draws together the views of hundreds
of local residents shows that there is strong public support for improved on road
cycle facilities - even on arterial routes - and that poor quality public realm is a
major factor that deters more people from adopting active travel modes. We
therefore wholeheartedly support any moves to develop this infrastructure on the
streets identified as ‘great city streets.’ We also believe our work suggests that a
greater commitment to improving cycling infrastructure throughout the document is
warranted.

We have been following the development of the 20mph pilot project on the South
side of the city with interest, and note that there is local community support for the
extension of the proposed 20mph zone to cover some arterial routes in the area
too. Whilst we are fully supportive of proposals in the ADF to designate secondary
roads in Leith as 20mph zones, we would also propose that the 20mph limit is

5 “How Forth Energy could win friends and influence Leithers.” Greener Leith. Available at: http://
www.greenerleith.org/greener-leith-news/2010/10/27/how-forth-energy-could-win-friends-and-influence-
leithers.html
6 “Aberdeen Heat and Power” http://www.aberdeenheatandpower.co.uk
7 Greener Leith Consultations. Available at: http://www.greenerleith.org/a-z/c-is-for/consultations.html
Greener Leith is a Scottish Charity and a Company Limited by Guarantee No. 365095.
extended to cover ‘Great City Streets.’ Afterall, this is where the 20mph limit is likely
to have the most impact, both in terms of reducing accidents and promoting active
travel.

The Green Grid and Greenspace

We note that the identified “green grid” does little to elaborate any development of
this network. Given that the ADF appears to have acknowledged that the Leith
section of the Waterfront Promenade is unlikely to be completed in the short-
medium term, we would like to see a greater priority given to extending and
developing quality active travel routes that will link the eastern section of the
promenade, with the western section at Portobello.

The council is already investing in improving routes between Seafield Street and
Leith Links/Easter Road. The plan should identify the provision of appropriate
facilities and ‘missing links’ between east and west as development priorities. This
is already identified as a priority in the council Active Travel Strategy but it would be
helpful if it were referenced in the ADF.

It would also be useful to have a more precise explanation of how the green
network will allow for a ‘greater density of development’. As it stands, Leith, whilst
being the most densely populated area of Edinburgh, has less open space than
any other part of the city (1.31ha per 1000 people Open Space Audit 8, Dec 2009).
We maintain that a start should be made now to redress this situation and the ADF
presents an opportunity to do this.

New, quality, green space is something which should be prioritised more explicitly in
the ADF, otherwise, we are concerned that there is a risk of over development - in
that green space (and indeed other components of the public realm) may be
provided in a piecemeal manner in order to satisfy the letter of the planning policy
at the time - rather than planned out in a strategic manner to reflect the wider needs
of local residents as a whole.

In particular, the ADF must address what alternative green spaces will be provided
in the area if the eastern area of the docks retains a more industrial use for years to
come. If the proposed Central Park and the Leith Links Seaward Extension are now
unlikely to be realised for many decades, the ADF should address the issue of
where future green space will be provided as new residential developments are
built in and around the waterfront.

We would welcome the inclusion of the concept of temporary green spaces that
would provide additional recreational areas for people in Leith.

8City of Edinburgh Open Space Audit. City of Edinburgh Council. Available at: http://www.edinburgh.gov.uk/
downloads/file/2030/open_space_final_audit
Greener Leith is a Scottish Charity and a Company Limited by Guarantee No. 365095.
Area Frameworks - Leith

One feeling that was strongly expressed at both charettes was a consensus for the
need to improve many of the existing parts of Leith. In our opinion this is not really
reflected in the Urban Design Proposal (figure 10 p27), where large parts of Leith
are not considered. Greener Leith would welcome more details in this document
that show which areas between the centre of Edinburgh and the Waterfront should
be the focus for investment.

Whilst there are other examples, we are particularly concerned about the quality of
the public realm on Leith Walk, Duke Street, Great Junction Street, Constitution
Street and the Kirkgate. These are all areas deserving of the same quality of public
realm as the rest of Edinburgh.

In our view, to neglect this point, will impact on the successful regeneration of the
whole area.

Figure 12 ‘Consolidating the Heart of Leith’

If this drawing aims to explain how the existing heart of Leith must be strengthened,
Greener Leith would like to see this explained in much clearer diagrams and explicit
language.

Figure 14 ‘A Medium-Term Mixed Character View of Leith’

The lack of clarity in this diagram underlines an urgent need to define a hierarchy of
circulation. Even though Commercial Street (A901) might be described as a ‘Great
Street’, retro-fitted and de-trafficked, it not only still appears to be an important
traffic artery towards the West, but also dissect the heart of Leith neatly in two.

Building heights.

In order to prevent developers from building more than the number of stories
allowed, the heights quoted in the Urban Design Guidance should surely be quoting
a maximum, as well as a minimum number of stories permitted.

View Corridors

In previous regeneration plans we note that much was made of the protected ‘view
corridors’ that were identified with the aim of preserving important views into and
out of the city centre World Heritage Site. The proposed ADF appears not to make
any reference to these view corridors. We would be interested in learning why
these view corridors have suddenly become unimportant. These were praised by
UNESCO as useful for preserving the integrity of the World Heritage Site. Surely,
there are some that are worth retaining?

Greener Leith is a Scottish Charity and a Company Limited by Guarantee No. 365095.
About Greener Leith

Greener Leith is a Scottish Charity and a Company Limited by Guarantee. It aims to

promote better public spaces, sustainable development and community
development throughout Leith.

Set-up by local residents in 2006, Greener Leith continues to be managed entirely

by local residents to this day. Greener Leith has an open membership, and the
board is elected each year from the membership.

You can contact us and find out more about Greener Leith from our award winning
website at www.greenerleith.org

Greener Leith is a Scottish Charity and a Company Limited by Guarantee No. 365095.