Final Draft submission to the ‘Use of Public Spaces in Edinburgh for Events and Filming’ Consultation

The Council’s ‘Use of Public Spaces in Edinburgh for Events and Filming’  Public Consultation ends 15 December – final draft for discussion (by exception) at 13 December NTBCC meeting 

Many public events happen within, and around, the area of the New Town and Broughton Community Council (NTBCC).

Members of the community council contributed many texts and comments, written during the ‘collaborative engagement’ stage of what was then the ‘Public Spaces Management Plan’ (October 2020 to January 2021).

These included NTBCC’s contributions to the key principles: area conditions, carbon neutrality 2030, heritage, noise, and residential-area public spaces.

Moreover NTBCC contributed the following guidelines: access to parks and greenspaces, carbon footprint, certification, complaints hotline service, fireworks, greenspaces environmental impact assessment, heavy equipment and temporary buildings, impact on the surroundings, onsite generators, overcapacity events, pesticides in public spaces, public art installations, reflecting Edinburgh, rest periods from events and activities, sound levels at music events, statistics, and use of space for different users.

We published an NTBCC Statement for the City of Edinburgh Council Public Spaces Management Plan ‘Collaborative Engagement’ January 2021 (Stephen Hajducki for NTBCC) as a summary of our position at that time (Appendix 1).

Members representing NTBCC attended each workshop stage workgroup (April 2021 to July 2021). At the end of that process we wrote a New Town and Broughton Community Council (NTBCC) PSMP Group submission of 21 July 2021 (Appendix 2).

The NTBCC ‘team’ have held frequent meetings to exchange opinions. NTBCC have been more involved, and arguably have more experience of, and expertise in, public events than any other citizen or community group in Edinburgh. Accordingly we hope our conclusions in this submission will be read and considered.

Comments on the individual topics covered by the workshops are as follows:

1. Application and approval

NTBCC welcome well-managed events which reflect the character of our city and contribute socially, aesthetically and economically. We do not require intrusive over-scale interventions beyond the city’s capacity to accommodate without detriment.

At present there is a bewildering array of permissions required (or not) which do not always seem to be submitted or enforced. CEC should therefore simplify the application process so that all events are advertised (as per planning proposals), consulted on, and screened for suitability – their impact on the environment, residents, businesses, transport etc.– with streamlining for small local community events. Events which fail to meet acceptable requirements should be refused. [Stephen Hajducki]

2. Area conditions

We agree that, in addition to the overall scrutiny of proposals for events outlined above and in subsequent parts of this response, it would be helpful to organisers and affected parties for more area-specific conditions to be imposed where they are relevant to particular locations.

These should include requirements to address impact on the cityscape, including conservation areas and skylines; proximity to residential properties in terms of noise, disturbance, parking management; protection of the green environment; compliance with the city’s green / climate change and pollution agendas including power sourcing; and neighbourhood social and economic impact, particularly in respect to benefit for the local community and small businesses. [Stephen Hajducki]

3. Engagement and communication

NTBCC would hope that engagement and communication is first and foremost as open and transparent as practically possible. Whilst we accept that proportionality (e.g. to scale of event and impact) is also a consideration, this needs to be applied consistently and with care.

NTBCC also support engagement at the earliest opportunity, ideally to all those who may have an interest in it, through a medium that is as accessible and inclusive as possible.

As with planning applications, engagement would provide comments to be fully considered in decision-making; with stakeholders being entitled to an explanation where their views are not upheld. [Richard Price]

4. Filming

Officers must recognise that it is not a given that all filming should take place if it does not benefit Edinburgh communities. Increased future over-tourism is not a good measure of success. Minimising disruption to residents is not enough when considering filming: diversions and the loss of amenity may make residents late for caring responsibilities, work, or for missing travel connections. Therefore, good engagement / communication is essential prior to filming starting.

Using social value and community wealth building approaches should maximise a positive legacy through training and employing a diversity of local people and businesses, and spending that stays in Edinburgh. [Deirdre Henderson]

5. Economic

Pursuit of revenue streams by the council from commercial use of public spaces are not necessarily compatible with other objectives. The key principles and guidelines need to reflect these competing requirements, specifically the costs/benefits of: the true financial costs of making public spaces available; loss of access to public spaces; the economic and social costs/payback for local communities and businesses (community wealth); accessibility and transport links to events; site restoration; compliance with environment and employment policies; and the frequency with which adverse impacts are imposed on communities. To apply the principles and guidelines a proper model for assessing economic/social costs and benefits must be employed. [Peter Williamson]

6. Environmental

NTBCC hope to see the publication of key principles and guidelines which provide environmental protections and consistent alignment with council policies on sustainability and carbon neutrality. These key principles and guidelines will need to be scrupulously observed.

In particular, standards for air, light and noise pollution — which cause annoyance to residents and harm to the natural environment — should be clearly and unambiguously defined. NTBCC believe certification and adherence to the ISO 20121 will help simplify maintaining appropriate standards by both the council and event organisers. [Simon Holledge]

7. Social

NTBCC hope to see the publication of key principles and guidelines fully covering social value, which needs to be defined and used as a measure of the benefits to and impact on local residents as well as the wider Edinburgh community. This measure should be used to assess if an activity should proceed. The application process to incorporate social value should be proportionate to the activity.

We would like to see guidelines to ensure public access to public spaces, protection of personal green space (for mental health etc), diversity (i.e. public space for different kinds of users), definition of ‘community events’, and the management of ‘social problems’ such as vandalism, litter and graffiti, and the provision of toilets. [Simon Holledge]

The full document pdf can be viewed and downloaded here.