We thank you for the opportunity to comment on this important subject and in particular appreciate the change to a more open form of consultation which allows suggestions to be aired and explored. This contrasts well with previous Council ‘consultations’ which were often narrow, simplistic and too obviously designed to produce a pre-determined result which agreed with officers’ preferred proposals.
Our views can be summarised as follows:
- The management plan should be for spaces all the year round, not just for events
- Primary use is to be as open space, with events as occasional users
- Spreading events over a larger area of the city, consistent with protection of amenity
- Distinguish between community and commercial events; and note quality of events
- All commercial events to be subject to full consultation, not just notification
- Environmental protection and controlling impact
- Financial and economic impacts
- Robust and efficient management
- All requirements / restrictions etc to be strongly enforced
Detailed comments on each of these topics are set out below.
Scope of Plan
The current epidemic has shown the importance of access to public spaces for physical and mental well-being. The scope of the new plan should therefore extend to management and protection of these spaces overall, and not just to events within them. We understand that this concept has been favourably received by members.
This approach will also reinforce an appreciation of parks and open spaces as primarily recreational and leisure spaces accessible to all, with only occasional events held within them, rather than being unavailable for extended periods. When major events are taking place, other spaces should deliberately be kept clear to achieve a balance – for instance, during the International Festival and Fringe, there should be no major events in Princes Street Gardens so as to provide an oasis of calm and quiet to counter frenetic activity elsewhere.
We agree that there is scope for extending activities beyond the central area, providing the identified spaces are adequate in size, have good public transport links and mobility-challenged access to avoid intrusive traffic and parking in neighbouring streets, and that the nature and management of the activity ensures minimal impact on local residential properties in terms of noise, crowd control etc. It may also require CEC to pre-install access paths, electrical, water and drainage services to minimise disruption and pollution on sites identified as suitable.
Types of Events
The type and quality of events must reflect the character and scale of Edinburgh as a city and its heritage, and must contribute to it socially, aesthetically and economically. In the past there have been advocates for ever-increasing levels of intrusive tourism and festivals way beyond a small city’s capacity to function and absorb without detrimental effect on its fabric and inhabitants; indeed, some supporters appear to regard ‘punching above its weight’ as a virtue rather than the problem it actually is. The ‘Thundering Hooves’ concept, even if it was ever valid, is now outmoded and unacceptable as a future direction. The PSMP offers an opportunity to correct this approach.
Approvals must also require quality materials and detailing commensurate with the city’s ambience. We agree that installations for events should support and reinforce the special ‘place’ quality of their surrounds, and organisers should therefore define in their application the measures they intend to take to achieve it, particularly in the World Heritage Site. Temporary installations should not be erected close to monuments, iconic views should not be blocked, streets should not be overwhelmed with advertisements and clutter.
In addition to its failure to meet acceptable standards of local consultation, the current ‘Spaces for People’ programme exhibits all the wrong ways to effect even temporary changes – plastic barriers and bollards, mesh fencing panels, elements haphazardly selected and laid out, crass signage. Edinburgh can do better than this, and deserves to do so.
The approval process should distinguish between community events, run by local charities, residents and business groups, and commercial events run by for-profit organisations or those charities which nonetheless have highly paid executives, and are essentially major fund raisers not intended for local initiatives.
Small non-intrusive community events should have a simpler permissions process and lower charges to reflect their social value. Commercial events must be the subject of full consultation, not just notification as currently suggested. Merely ‘notifying’ local organisations and relying on a ‘check-list’ approach to be filled by the event organiser is not sufficient. The notification procedure used for planning applications – a fully-detailed application, published on a weekly list, advertised, advising to local community councils and other bodies, setting out proposed mitigation measures to avoid local impact, showing compliance with other standards such as construction and safety, and then reporting back to an open committee with a recommendation – would be an appropriate and workable model. There are actually relatively few major events annually to which this would apply, so they would not impose an increased burden on council resources if an appropriate fee is charged.
Controlling Environmental Impact
We agree with the view that ‘Edinburgh’s public spaces should be used in a way that enhances the city’s cultural identity, reputation and quality of life’. Proposals which fail to demonstrate this should be dismissed at the application stage. While we would not wish to descend into small-town parochialism, the drive to ‘internationalise’ the city’s tourism and events must be balanced by a realistic appraisal of how much can be absorbed without detriment.
All events should require an environmental impact assessment. This might be minimal for local community events which do not introduce any structures or fixtures, but would be significant for larger events or those with a prolonged duration. The assessment should cover greenspace protection including surface and sub-surface impacts (damage to walls, banks, drains, compacted soil etc); vegetation damage to trees, shrubs and grass; biodiversity impacts to all significant forms of life from animals to micro-organisms; as well as air, water, noise, and light pollution, controlling anti-social behaviour (i.e. littering, graffiti etc); and should set out remedial or mitigating measures as well as proposals for subsequent reinstatement. A bond should be lodged to ensure the site is promptly returned to its original state after the event.
The city has an ambitious Carbon Neutral target, and it is imperative that organisers submit estimates of their carbon footprint – including all associated travel and manufacture. Carbon offsets which transfer pollution elsewhere are not acceptable. Diesel-based and other polluting generators should not be used; all events should use mains electricity or ‘green’ generation.
Major concerns in recent years has been the damage to green space by structures compacting the ground and obstructing water flow to tree roots; and the extended recovery time after clearance before the area is again usable by the public. Other European cities restrict Christmas Markets, funfairs or similar installations to hard landscaped areas. The PSMP should impose a blanket ban on any heavy structures on soft landscape.
Noise levels have been a major concern in past events, especially city-centre concerts, both for nearby residents and for attendees. A requirement should be that specific restrictions based on scientific monitoring be agreed and adhered to.
Financial and Economic Aspects
The pressure to raise some income from assets such as parks is understandable, but this should not override the protection of environment and amenity. All income from events should be visibly used for the maintenance of parks and spaces, and not diverted to ‘administration’ or other council expenditure or causes.
Organisers of commercial events should be asked to show what benefits their events have for local residents and support for local businesses. If they cannot do so, or if the benefits go primarily to outside interests, their applications should not be approved.
While grants might be given for local events, in no instances should CEC pay commercial operators to put on a festival. All costs must be met by the organisers, through sponsorship if necessary, and any surplus after deducting reasonable fees should be reinvested in the maintenance of the space.
It should be noted that considerable areas of public realm in Edinburgh are Common Good Land, and there are consequent restrictions on uses and therefore a requirement for a stringent open and transparent process. An independent trust should be appointed to manage all such land.
All commercial events must demonstrate that they are fully compliant with CEC’s Modern Slavery charter, and that all staff are paid at least the National Minimum Wage. Sufficient funding should be lodged beforehand with a third party to ensure this.
Unsubstantiated and exaggerated claims for the value of certain events to the city have been made by their organisers and their apologists with no explanation as to how the figures have been calculated. In future all such claims must be transparent and grounded in reality. All commercial events must make their accounts open and available. They should identify who receives the benefits – whether they support local businesses and organisations, or if they are creamed off by parties who do not have any beneficial connection with the city.
Robust and Efficient Management
We agree generally with the ‘Guidance on Managing Activities and Events in Public Spaces’ set out in the consultation document, with the provisos noted above concerning proper consultation rather than mere notification to community councils and affected parties; and distinguishing between community and commercial events.
Each space or venue should have a stated maximum capacity which should not be exceeded in ticket sales or persons admitted.
Currently responsibility for various aspects of the process is divided between different functions who do not always appear to communicate. While the individual expertise of specific departments is recognised – eg building standards and safety – there should be a small co- ordinating team to process the applications, drawing together departmental and community comments and advice and ensuring all permissions, financial bonds etc are in place before reporting back to the members.
To enable a full assessment of each proposed event, full details of impacts arising should be included in their application. The application should cover the points raised above, and also:
- Safety issues – including building warrants and compliance certification
- Full insurance risk cover
- Certification, delivered by external independent assessors
- Transport and accessibility
- Parking disruption for staff, visitors and local residents and businesses
- Public Conveniences and Welfare
- Waste and Recycling
We agree that the obligations for an intending organiser need to be made clear and agreed before any event starts, including all permissions and licences. To this we would add consultation and genuine dialogue with affected stakeholders and a demonstration of willingness to resolve any issues.
Given past concerns, there must be a stronger vetting process for event organisers, particularly those who have caused previous problems such as:
- leaving unpaid accounts with the Council or city businesses
- failing to apply for necessary planning and other permissions
- not meeting basic requirements on safety, noise limitation, adverse impact, crowd control, modern slavery requirements
- not demonstrating any local benefit or actually diverting income away from established businesses
- failing to take immediate remedial action when complaints have been raised
- being in receipt of council funding and then diverting any profits elsewhere
- showing lack of consideration for or co-operation with neighbours
Where it is nonetheless decided to entertain an application from such organisations, there should be a large advance deposit as guarantee of ‘good behaviour’ before consent is granted; and which would be forfeit if problems arise.
All requirements and restrictions need to be strongly enforced to minimise problems. This is an area in which CEC is generally weak. It is essential that there is an easily contactable 24-hour single point of complaint, backed up by a fast response team to undertake remedial action. This could be part of an overall review of effective enforcement within all functions of the council.
Edinburgh has a high city-centre residential population which contributes to its success, but there is a clear conflict between protecting amenity and accommodating large music concerts with issues of noise, crowd control etc. It must therefore be recognised that at present the city simply cannot always host these without unacceptable impacts. Therefore the PSMP should also look at encouraging other appropriate facilities which are currently lacking – eg a potential 7-10,000 seater stadium / sports centre at a suitable location such as Ingliston. The PSMP should not be a substitute for avoiding a holistic approach to managing events within the city.
We note that many of the points raised at this stage require more detailed work to make them practical. We would be pleased to comment further on these as they develop, and also to see the draft of the application form when it is ready.
Stephen Hajducki for NTBCC
Original PDF: NTBCC Comments on PSMP