20 Dec 2022: City Plan 2030 is now with Scot Gov for formal examination, behind schedule and with a long way to go. 

Many of you will have seen the CEC announcements of 14^th and 16^th December on the submission of Edinburgh’s Local Development Plan (LDP), City Plan 2030 (CP 2030), to the Scottish Government for formal examination. The Scot Gov ‘Division of Planning and Environmental Appeals’ (DPEA) now has custody, referencing it LDP-230-3. (Scottish Government - DPEA - Case List (scotland.gov.uk))

The CEC Planning Committee approved CP 2030 for submission on 30^th November. The LDP Team faced a huge challenge in the form of the sheer volume of responses (over 1800) received over the plan’s public consultation and representation periods. The Planning Committee agreed with the LDP Team that these comments should best be wrapped up in an Appendix to the main document, rather than have further time-consuming attempts made to resolve them before submission.

The upshot is the DPEA Reporter now has an Appendix of 1500+ pages to work through! How that task will be tackled will become apparent over 2023; but shifting responsibility away from CEC could be seen as a smart move if there are any further delays in the LDP process. That looks inevitable.

Delays, delays! - but all down to Covid? In August 2018, the CEC Planning Committee set out a timetable for the new LDP, envisaging its submission to the Scottish Government in March 2020. In October 2019, this was revised to January 2021. There was already significant slippage before Covid struck; then Covid became a harsh reality, seriously disrupting workflow and the whole LDP programme.

In the round, at the end of November, CEC Planning Committee was understandably right in congratulating the LDP Team on its achievement in getting CP 2030 wrapped to the point where we are now. But in future we surely need a more robust assessment of timetable risks.

A quick trip through the main Appendix to the submission shows that Edinburgh’s Community Councils were able, despite Covid, to submit a good number of comments on CP 2030. This served to counterbalance to a degree the torrents of submissions from development interests. Community Councils made their voice heard and that is encouraging.

A core thrust of CP 2030 is, of course, towards housing, including the change to a minimum 35% affordable housing obligation from new developments. That may increase pressure to provide this ‘offsite’. Linked to that, prioritising ‘brownfield’ sites over greenfield for housing is understandably also important, but I’d argue we mustn’t drive away industry and business from Edinburgh by being too rigid about brownfield site use. Edinburgh really needs to attract inward investment in business for future economic success. It is not just about more hotels and it cannot be a question of more retail, given how retail has changed.

CP 2030 is the first Edinburgh LDP with a ten-year plan horizon, but this will have been eroded by the time it is adopted, perhaps by March 2024, some three years behind initial schedule. So how will the DPEA Reporter reflect (if at all) on the ten-year plan’s ‘2025 half-time review’ and on the likely need in the second half to ensure a further five years effective land supply for housing?

Over all of this, there sit the climate change impacts and the different climate strategy responses pursued by CEC and by the Scottish Government. CP 2030 is as important as it gets for the city in an era of big change and challenge. As Edinburgh moves through 2023 towards the eventual adoption of CP 2030, expect a few more surprises. Watch with interest !

Tony Harris, former Grange Prestonfield Community Councillor and Planning Lead from end-December 2022. Tony writes here in a personal capacity.