Support our campaign for a Greener Docks Development.

If you agree with what we say below, then you should send an email  or letter in support of our campaign. You can download a letter template here. Emails should be sent to kevin.ryan@edinburgh.gov.uk . All comments must be in by 15th of July.

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Greener Leith submission in relation to Outline Planning Application 07/03895/OUT

Provision and use of Green space.

We note that both the City of Edinburgh Council Parks department and Sports Scotland are critical of the Forth Ports Planning Application, as the proposals do not seem to contain sufficiently well thought out plans to accommodate the likely demand for green space, especially with regard to provision of play facilities, sports pitches and allotments. Whilst Greener Leith would prefer to see sufficient green spaces, and sports pitches (as defined by Sport Scotland in their submission) located within the docks area itself, it should also be recognised that the development will place additional pressures on Leith Links.

Greener Leith is currently carrying out a public consultation process - called "The Leith Links Ask" - to identify local priorities for the redevelopment of Leith Links. Greener Leith urges the council to ensure that appropriate mechanisms are put in place to ensure that developer contributions are made towards the improvement of Leith Links. Developer contributions should be focused on the priority developments identified by the Leith Links Ask  - especially if the accepted standards for play, sports and allotment provision are not met within  the redevelopment itself. 

Greener Leith also notes some inconsistency between the recent consultation on the 'OS7' Leith Links Seaward Extension (LLSE) Design and a number of the Forth Ports documents that make up the Outline Planning Submission. For example, this Forth Ports document shows four football pitches covering the length of the LLSE. When we attended the City of Edinburgh Council meeting on the Draft Design proposals for the LLSE, it was indicated that there would only be one full sports pitch, and that this would probably be shared with the proposed new secondary school. Greener Leith volunteers are not sure who to believe. However, we do know that neither of these proposals for the design of LLSE provides  an adequate balance of sports pitch provision and other public space uses when we consider the area as a whole.

We also know that there is no extra capacity available on Leith Links for more sports pitches so it is clear to us that more sports pitch provision needs to be made elsewhere in the docks redevelopment. The LLSE 'OS7' proposals will not provide enough new public space on their own. Ideally, we would support the calls by Sport Scotland and the City of Edinburgh Council Parks Staff for a document that identifies a hierarchy of sports and play facilities, within specific green spaces in the docks redevelopment.

We note the call for provision of allotment or community garden space. There is indeed a massive under supply of allotments in Edinburgh. If the docks redevelopment goes ahead at the high densities proposed it is likely that this will generate further demand for allotments. Allotments are not simply a desirable addition to a development, they are a vital part of any 'sustainable' development, playing a role in promoting community cohesion, social capital, healthy lifestyles and of course local food production. Ideally, allotments should be sited within an easy walking distance of peoples homes.

 An Alternative Seaward Extension to Leith Links Can Meet the Demand For Green Space.  

 Whilst we know that no provision is made for extending Leith Links towards the shore to the East of the current 'OS7' LLSE in the city local plan, we believe that there is scope for a more viable park in this location. This will provide more green space, and more opportunity for full size sports pitches. Cairns ICL have produced indicative plans of how this alternative seaward extension might look. You can download a mock-up aerial photograph of this alternative LLSE proposal here.

Greener Leith believes the Cairns ICL proposals are more appealing than the 'OS7' LLSE favoured by the city of Edinburgh council and sometimes included in the Forth Ports OPA. We recognise that Forth Ports are currently constrained by the recently adopted City of Edinburgh Council Local Plan. Given the timescales involved, there will be time to review the zoning in the city local plan, were the Forth Ports OPA permitted to leave the door open to this alternative extension proposal.

Greener Leith believes that the Cairns ICL proposal has a number of advantages:

• It acts as a "green buffer" between the Seafield Sewerage works and other built land uses.
• It provides more scope to accommodate requirements for increased play and sports provision.
• It is more achievable, given the length of the leases on the site where the 'OS7' LLSE is proposed to run.
• It does not require the relocation of the existing Leith Allotments.
• It provides more opportunity to integrate with the coastal promenade, and the east Edinburgh cycle network.
• It will see the creation of a significant sized park, that will be an asset to Leith and indeed the whole city.  
• It would have a more organic form, in keeping with the character of the rest of the park, reflecting the heritage of the area.

We understand that city officials are keen to ensure that a rail head is maintained to the eastern docks area  and that the area affected by Cairns ICL proposals are currently zoned for 'light industrial' use in the local plan. City officials we have spoken to argue that the area needs to be kept for 'light industrial' use in order to safeguard jobs in the area.

However, recently we've also seen that council officials propose to permit 'mixed use' of the areas covered by the Jane Street/Steads Place and Bonnington Road development briefs, despite local concerns that this will result in a loss of jobs in the light industrial sector there. We urge the council planning authorities to retain the majority of the light industrial units in those areas, and to consider the scope for modifying the local plan to accommodate the alternative Leith Links extension proposed by Cairns ICL.  This will go some way to offset the negative impact on local employment in this sector that the adoption of the Cairns LLSE proposals would have.

Other Public Spaces

There appears to be no significant 'focal' public open space proposed in this development. Yes, there are landmark buildings, but we would also like to see a commitment to developing a high quality public space that can act as a destination in itself. We do not believe it is enough to rely on buildings alone. Major public spaces, such as the coastal promenade, should be planned at the outset - we are concerned that the proposals to build a series of discrete 'villages' will lead to disjointed and fragmented public spaces.

We also note that the promenade design code consultation invites comments from interested parties on various types of 'activity nodes' along the route. Given that Forth Ports have already been required to modify their plans to accommodate the tern colony, we wonder whether there is scope to accommodate and plan for a 'biodiversity' node on the promenade route? This could incorporate viewing opportunities, and interpretation to help explain the value of the local natural heritage. We would also like to see the Forth Ports proposals identifying other 'activity nodes' on the coastal promenade.

 Active Travel Provision

We would like to see more detail on the specifications of cycle and pedestrian routes. The cycle lane provision around Ocean Terminal is so badly designed that it is virtually useless - if not dangerous. We hope that the City of Edinburgh council can enforce better design standards through the planning process. If not, we hope that Forth Ports and the other developers involved in the docks redevelopment will actively seek more detailed advice, rather than wasting money on tokenistic add-ons to finalised designs. 

We would hope that cycling and walking are prioritised in the design of the built environment as the preferred means of travel. This means reducing the dominance and priority given to motorised transport, particularly on non-arterial routes through the use of 'home zones.'  Further measures such as quality signage for safe 'off-road' routes, and widespread cycle storage facilities are also desirable. Consideration should also be given in the design of the built environment to integrate active travel modes with public transport hubs in the development.

The revised plans outlining pedestrian and cycle routes submitted by Forth Ports do not feature the 'OS7' LLSE whatsoever. Again, this obviously is concerning, as the LLSE may form a major active travel link between Leith Links, the shoreline and new developments nearby.

We also note that little mention of the Waterfront Promenade proposals are made in the planning application. We would like to see a commitment to integrating the promenade effectively into the development. This means that the promenade should be accessible, with a high number of access points, and consideration given to active frontages looking onto it to deter anti-social behavior.

Furthermore, where the promenade runs through high density areas of the redevelopment, the promenade should be constructed to an appropriate width that will allow active travel uses, without conflicting with cafes, shops or other businesses that would wish to have an 'active frontage'. This may mean a commitment from Forth Ports that the promenade will be built, in some sections,  to exceed the specifications currently set-out in the promenade design code that is out for consultation at the moment.

Housing and Buildings

We note from this map that there are a great deal of tall buildings proposed in the development, with some up to 28 storeys in height. Greener Leith totally opposes any building more than 8-10 storeys high. Exciting architecture does not need to be tall. Tall buildings would detract from the Leith skyline, and have a negative impact on the Edinburgh city centre World Heritage Site as well as other locations throughout the Firth of Forth. Greener Leith does not believe that attempts to preserve key views go far enough to protect Edinburgh's fantastic built heritage - a factor that is a key component in Edinburghs continued economic success.

We also note that there is no indication in the plans for the location of the affordable housing. We hope that genuine mixed tenure neighbourhoods are built, and that developers will not seek to meet their affordable housing obligations  by building affordable housing 'off-site', as has recently been agreed in the case of the MaB development at Trinity House. To prevent this, planners should ensure that each 'village' development should incorporate the appropriate amount of affordable housing within that neighbourhood. This will help to ensure that affordable housing is spread throughout the development, rather than clustered in the least desirable parts of the docks.

We think it remarkable that so little thought has been given to the siting of public buildings such as schools, and community centres. We find the level of detail in the Forth Ports OPA unacceptable. We cannot comment when so little information is provided, and we wonder how local authority officials can make an informed decision too.

Based on our impressions of the development of the Western Harbour, we feel built environment standards need to be lifted considerably. Greener Leith would like to see a greater commitment to higher standards for recycling facilities, energy efficiency, renewable energy generation and use put in place and implemented. It is not enough to  commit to UK guidelines as they lag behind what is actually possible and shown to work elsewhere. If they can do it in Malmo, we can do it here.

Use of Water

We note that SEPA has raised concerns that the water quality in the docks may be unsuitable for some water sports. However, we would still like to see the scope for houseboats, and other active uses of the water investigated. We would also like to ensure that the redevelopment of the docks does not rule out a ferry terminus in Leith, in order that it would be possible to establish local ferries to Fife in the future if required.