! ! ! ! ! ! ! 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! 36, Newhaven Road Edinburgh EH6 5PY justask@greenerleith.org www.greenerleith.org

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.


“Sustainable Urban Development: the Case of Hammersby Sjostad” Poldermans, C (2006) Available at: http://www.solaripedia.com/files/720.pdf Wheeler, 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.


“Last day for Leith Power Plant objections” Greener Leith, Available at: http://www.greenerleith.org/greenerleith-news/2011/3/11/last-day-for-leith-power-plant-objections.html

“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

“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-influenceleithers.html
6 7

“Aberdeen Heat and Power” http://www.aberdeenheatandpower.co.uk 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 shortmedium 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.


City 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.

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