Forth Ports Limited Consultation Response to Edinburgh Local Development Plan Main Issues Report Forth Ports Limiteds

s future strategy for the Port of Leith is its continued focus on port operations, and its potential to serve the manufacturing and support needs of the offshore renewable energy industry. The Port of Leith is Scotlands largest enclosed deep water Port with over 60 hectares of portside development land and is an important asset to the Citys economy. The National Renewables Infrastructure Plan prepared by Scottish Enterprise has identified the Port as Scotlands top location for development and support for off-shore wind infrastructure. A Memorandum of Understanding, signed in 2011 by City of Edinburgh Council, Scottish Enterprise and Forth Ports Limited sets out an agreed vision for the future of the Port of Leith. This seeks to ensure that it continues to operate as a successful port, leading to increased job creation and economic prosperity. In January 2012, the Scottish Government identified the Port of Leith as a key component of a new Enterprise Area, as it sees potential for growth and new jobs and achievable opportunities for development exist in the short term. To enable the Port to achieve its economic potential and contribute fully to the Citys economy the Local Development Plan must support Forth Ports Limiteds commitment to the continued operational use of the Port; a strategy which is supported by the City of Edinburgh Council, Scottish Enterprise and the Scottish Government.

Question 5 Do you agree with the preferred approach to how the LDP should deal with housing in the built up areas? Of do you support the alternative? Forth Ports Limited supports the preferred option, to review existing local plan housing proposals based on the identified principles, especially bullet point 2 (page 18) which requires consideration of whether there is evidence to support the deletion of existing housing proposals e.g. because the site is no longer available for housing development. The following comments relate to the land holdings of Forth Ports Limited: Forth Ports Limiteds (Forth Ports) strategy for the Port of Leith will see the majority of the Port remaining in operational use for the foreseeable future. It is therefore no longer Forth Ports intention to support housing-led mixed use development on the majority of its land holding at Leith. As a significant level of housing is proposed at the Port of Leith within the adopted City Development Plan, it will be appropriate to recognise Forth Ports new strategy in the forthcoming Local Development Plan. Scottish Planning Policy (paragraphs 15 and 17) requires development plans to (inter alia) concentrate on what will happen, where and why; to be realistic, and to address the spatial implications of economic change.

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The continued operational use of the Port removes the majority of the land at the Port of Leith from the future housing land supply, and as a consequence, the treatment of this site and its contribution to the Citys housing land supply requirements will need to be reviewed and amended as part of the preparation of the Local Development Plan. Forth Ports will support housing-led mixed use at the following locations: Western Harbour (Edinburgh City Local Plan reference WAC 1a) and Planning Permission No 01/03229/OUT; The housing proposed within the Harbour Masterplan area which is the subject of a Resolution to Grant Planning Permission, application number 08/04232/OUT totalling 1312 units as well as other housing-led sites owned by Wimpey, CALA and Port of Leith Housing Association in the Ocean Drive area; Granton Harbour area, Planning Permission number 06/03636/REM.

Question 6 Do you agree with the preferred option for the future of Leith Docks? Or do you support the alternative? Forth Ports Limited (Forth Ports) supports the reasonable alternative for the Leith Docks area identified in the MIR, which would see the north eastern area of the Port identified for business and industrial use. Forth Ports strategy is for the majority of the Port of Leith to remain in operational use. It is currently an area occupied by a wide range of industrial and port related uses, with the potential to accommodate further industrial growth. In the future it has the potential to play a key role in making industrial sites available to support Scotlands growing renewable energy industry. Harnessing the potential of the Port to facilitate the development of the offshore renewable energy industry has the support of Scottish Enterprise, City of Edinburgh Council and the Scottish Government. The National Renewables Infrastructure Plan (N-RIP) prepared by Scottish Enterprise, recognises the economic growth opportunity that the offshore renewables industry can bring to Scotland. Phase 1 of N-RIP highlights the very specific locational needs of the offshore wind industry and provides a spatial framework to accommodate these requirements. The Port of Leith is ranked as the top location within Scotland for integrated manufacturing for offshore wind infrastructure. The Memorandum of Understanding (MOU), dated October 2011, signed by City of Edinburgh Council, Scottish Enterprise and Forth Ports, which received high level political support form the Scottish Government, sets out an agreed vision for the Port of Leith. The vision recognises,

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It is in the common interest to ensure that the Port of Leith continues to operate as a successful port. This will ensure that the commercial success of the Forth Ports business is maintained for the long term, leading to increased job creation and economic prosperity. The ports location on the Firth of Forth with direct access to the North Sea and a large portside land allocation makes it a key Scottish asset that should be protected for future manufacturing and other port related activities. The Scottish Government has recently announced the creation of Enterprise Areas. These areas have been created to target the sectors with the greatest potential for growth and new jobs and they represent strategic locations where the Scottish Government consider achievable opportunities for development exist in the short term. The Low Carbon/Renewables East Enterprise Area supports marine renewable sites at the Ports of Leith and Dundee. The area to remain in operational use encompasses the whole peninsula area of the Port extending to Seafield, including the area of land currently identified for Business Development Proposals (BUS 3) in the Edinburgh City Local Plan (adopted 2010). The Local Development Plan should include a policy designation for this area, identifying it as an area for industrial and operational port use. A policy should also be included to support the development associated with renewable energy. This should include a reference to the options for berthing larger vessels than can currently be accommodated in the lock at the Port of Leith, as larger vessels will be essential to the offshore renewables industry going forward. Scottish Enterprise is leading the preparation of masterplan to accommodate the requirements of the Port of Leith and N-RIP, in partnership with City of Edinburgh Council and Forth Ports. The masterplan requires an Environmental Impact Assessment and will also be the subject of Appropriate Assessment under the Habitats Directive. Any identified impacts on the conservation interests of the Firth of Forth will be assessed and mitigated as part of this process. It is noted that the Council has been granted approval by the Scottish Government for a proposal to use Tax Incremental Funding (TIF) as a means of funding infrastructure delivery and unlocking the development potential of the Waterfront. (City of Edinburgh Council, 2011, Waterfront and Leith Area Development Framework). The TIF proposal includes a new link road between Seafield Road and Constitution Street. This infrastructure improvement in Leith is important to ensure delivery of the economic opportunity presented by N-RIP, the MOU and Low Carbon/Renewables East Enterprise Area at the Port of Leith, therefore the link road should be identified as an opportunity within the Local Development Plan. In relation to open space, Forth Ports notes the diagram on page 45 of the Main Issues Report. The Councils Open Space Strategy (City of Edinburgh Council, September 2010, Map 3 pp10:11) identifies the creation of the following:

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Leith Docks Community Park; Leith Links Seaward Extension; and The Waterfront Promenade along the north of the Port of Leith, extending across the breakwater.

The Leith Docks community park was proposed as part of the Leith Docks Development Framework to serve the new community of 15,000 homes at Leith Docks. As Forth Ports, no longer supports housing-led mixed use on the areas associated with this open space, it is therefore no longer appropriate to support the development of this park. There is also no need to identify a replacement site, as the proposed housing development it was designed to serve will not be brought forward; therefore the proposal should be deleted from the Plan. The other two proposals are the waterfront promenade and the seaward extension to join Leith Links to the waterfront. Whilst the aspiration behind these proposals is recognised as part of a wider mix-use regeneration of the waterfront, they are incompatible with continued industrial use of the Port. Forth Ports would support the Councils proposal to identify an alternative inland route for the Promenade, through Leith and potentially passing by Victoria Dock and utilising the proposed waterfront Promenade around the Western Harbour in front of Ocean Terminal, which forms part of the Harbour Masterplan (application number 08/04232/OUT). This will allow an interesting and varied route to be created, in keeping with the overall vision of allowing a waterside walk from Cramond to Portobello. This should be recognised by policy for the waterfront, in the implementation of the Central Scotland Green Network (Question 16) and policy on open space (Question 20). Forth Ports will support housing-led mixed-use development at the following locations: Western Harbour (Edinburgh City Local Plan reference WAC 1a) and Planning Permission No 01/03229/OUT; The housing proposed within the Harbour Masterplan area which is the subject of a Resolution to Grant Planning Permission, application number 08/04232/OUT totalling 1312 units as well as other housing-led sites owned by Wimpey, CALA and Port of Leith Housing Association in the Ocean Drive area; Granton Harbour area, Planning Permission number 06/03636/REM.

The Reasonable Alternative also identifies the area between Ocean Terminal and Victoria Quay for mainly business, retail and leisure use. This reflects the sites designation as a Strategic Business Centre in the Edinburgh City Local Plan (adopted 2010) and is welcomed by Forth Ports.

Question 9 Do you agree with the preferred approach to seeking developer contributions towards infrastructure provision? Or do you support the alternative? Forth Ports Limited supports the Reasonable Alternative set out in the Main Issues Report.

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The recognition that the City cannot rely on developer contributions to fund all the infrastructure investment the City needs, and also the recognition that in the current economic climate, the sums involved in developer contributions may be high enough to affect the viability of development (paragraphs 4.6 and 4.7) of the Main Issues Report are welcomed. The ability to make developer contributions is based on the uplift in value of land when its use changes as a consequence of planning permission. Where an industrial site is to be redeveloped for an alternative industrial use, there is unlikely to be significant uplift in land value, and therefore limited scope to fund contributions. There is significant scope for growth in the renewable energy industry in the plan period, bringing economic growth to the City. It is especially important to note that investors in renewable energy projects are often large international companies, which will be considering a range of Scottish and European locations, with which Edinburgh will be in competition. Restrictive or over-ambitious policies on developer contributions could result in developments locating elsewhere. Scottish Government Planning Circular 1/10: Planning Agreements sets out the tests which must be satisfied for the appropriate use of planning agreements and in this regard, the application of the existing policy provision set out in the Edinburgh City Local Plan (adopted 2010) and Edinburgh Supplementary Planning Guidance: Developer Contributions and Affordable Housing is not always appropriate. For example, an industrial development on an existing industrial site is unlikely to trigger a need for contributions to off-site public realm. Requirements for contributions which affect the viability of developments should be avoided. The use of Planning Agreements should be restricted to require contributions to measures which are absolutely essential to allow development to go ahead.

Question 10 Do you agree with the preferred approach to planning for and providing for office space in Edinburgh? Or do you support the alternative? Forth Ports Limited supports the Preferred Option for providing office space in Edinburgh and the identification of Leith as a strategic office location. Both the preferred option and the reasonable alternative strategy for Leith Docks continue to identify the area between Ocean Terminal and Victoria Quay to fulfil the requirement for the strategic office location (as referred to in more detail in Forth Ports response to Question 6).

Question 16 Do you agree with the preferred approach to implementing the Central Scotland Green Network? Or do you support the alternative? Forth Ports Limited (Forth Ports) broadly supports the Preferred Option for implementing the Central Scotland Green Space Network. Notwithstanding this support, Forth Ports notes that the diagram on page 45 of the Main Issues Report and the Open Space Strategy (City of Edinburgh Council, September 2010, Map 3 pp10:11) identifies the creation of the following:

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Leith Docks Community Park; Leith Links Seaward Extension; and The Waterfront Promenade along the north of the Port of Leith, extending across the breakwater.

The Leith Docks community park was proposed as part of the Leith Docks Development Framework to serve the new community of 15,000 homes at Leith Docks. As Forth Ports, no longer supports housing-led mixed use on the areas associated with this open space, it is therefore no longer appropriate to support the development of this park. There is also no need to identify a replacement site, as the proposed housing development it was designed to serve will not be brought forward; therefore the proposal should be deleted from the plan. The other two proposals are the waterfront promenade and the seaward extension to join Leith Links to the waterfront. Whilst the aspiration behind these proposals is recognised as part of a wider mix-use regeneration of the waterfront, they are incompatible with continued industrial use of the Port. Forth Ports would support the Councils proposal to identify an alternative inland route for the Promenade, through Leith and potentially passing by Victoria Dock and utilising the proposed waterfront Promenade around the Western Harbour in front of Ocean Terminal, which forms part of the Harbour Masterplan (application number 08/04232/OUT). This will allow an interesting and varied route to be created, in keeping with the overall vision of allowing a waterside walk from Cramond to Portobello. This should be recognised by policy for the waterfront and in the implementation of the Central Scotland Green Network.

Question 18 Do you agree with the preferred approach to setting out carbon reduction requirements? Or do you support the alternative? Do you support the suggested policy changes in relation to green roofs and Combined Heat and Power plant? Forth Ports Limited (Forth Ports) does not support the Preferred Option or the Reasonable Alternative in relation to this topic, and suggests modifications. Forth Ports has a range of interests in renewable energy: through the N-RIP and planning for the offshore renewables industry; in relation to the development of CHP and heat networks, through its joint venture with SSE, Forth Energy; and in detail in relation to building-specific requirements for each development.

Forth Ports considers it important that the plan takes a strategic view of renewable energy targets and carbon reduction, as well as one focused on solutions that are applicable to individual new buildings. The proposed approach to renewable energy in the MIR will not enable City of Edinburgh to realise its full carbon reduction potential, as the policy approach is specific to individual new buildings, rather than on a hierarchical and City-wide focus on

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how to deliver renewable energy and specifically renewable heat to meet Scotlands demanding targets. The strategy should focus on renewable energy and carbon reduction across the City, through decentralised generation of low carbon electricity and heat; CHP and district heating systems; carbon reduction in the existing building stock, as well as solutions specific to new buildings. Policy Inf 4 Renewable Energy and paragraphs 9.42 9.43 of the Edinburgh City Local Plan (adopted 2010), support the development of a range of renewable technologies provided that such development does not cause significant harm to the local environment and will not unacceptably affect the amenity of the neighbouring occupiers. The Main Issues Report at paragraph 8.4 states, current policy on renewable energy development, including freestanding turbines, micro generation retrofitted to existing buildings, and energy from waste will also be carried forward. This statement omits combined heat and power/district heating which is the realistic way to meet the 2020 heat target, and can be powered from a range of fuel sources. The Port of Leith should be recognised as having the potential for larger-scale decentralised renewable electricity and heat generation above 10MW. This is especially important as the proposed new manufacturing developments in the area will use large volumes of electricity and heat, and it will be important to ensure that these developments are powered by renewable sources. Fuel can be brought to the Port by ship, the lowest carbon means of transportation, being over 14 times more carbon efficient that road transport (DECC and
DEFRA, (2009) Guidelines to DECC/DEFRAs GHG Factors for Company Reporting 2nd Issue).

The proposal to require major developments, above a specified scale, to include land or floorspace for a CHP plant is limiting in the following ways. Firstly, it requires a proposed development to make specified provision for a CHP plant and does not allow the selection of alternative options for electricity and heat generation for example connection to a district heat network. Secondly, it does not support the development of CHP plants at a commercial scale which are capable of delivering electricity, large volumes of heat/cooling to industry and heat to district heat networks. It is also noted that the proposal at paragraph 8.9 seeks to put in place a requirement for CHP above a specified scale but gives not indication of what this scale would be or what work will be undertaken to establish an appropriate scale. Forth Ports and its joint venture partner, SSE, would welcome the opportunity to work with the Council to develop its thinking on the delivery of heat in urban areas.

Question 19 Do you agree with the preferred approach to waste management? Or do you support the alternatives? Forth Ports Ltd supports the Preferred Option for waste management.

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Question 20 Have you any comments on the other possible changes outlined in Chapter 9? All responses on these matters will be taken into account in preparing the LDP. Infrastructure Safeguards The Council has been granted approval by the Scottish Government for a proposal to use Tax Incremental Funding (TIF) as a means of funding infrastructure delivery and unlocking the development potential of the Waterfront. (City of Edinburgh Council, 2011, Waterfront and Leith Area Development Framework). The TIF proposal includes a new link road between Seafield Road and Constitution Street. This infrastructure improvement in Leith is important to ensure delivery of the economic opportunity presented by N-RIP, the MOU and Low Carbon/Renewables East Enterprise Area at the Port of Leith, therefore the link road should be identified as an opportunity within the Plan. The Local Development Plan should make provision for the new road between Seafield Road and Constitution Street as part of the waterfront development strategy and identify it as a transport infrastructure proposal. Existing Business and Industry Designations Forth Ports Limiteds (Forth Ports) strategy is for the majority of the Port of Leith to remain in operational use. It is currently an area occupied by a wide range of industrial and port related uses, with the potential to accommodate further industrial growth. In the future it has the potential to play a key role in making industrial sites available to support Scotlands growing renewable energy industry. Harnessing the potential of the Port to facilitate the development of the offshore renewable energy industry has the support of Scottish Enterprise, City of Edinburgh Council and the Scottish Government. The National Renewables Infrastructure Plan (N-RIP) prepared by Scottish Enterprise, recognises the economic growth opportunity that the offshore renewables industry can bring to Scotland. Phase 1 of N-RIP highlights the very specific locational needs of the offshore wind industry and provides a spatial framework to accommodate these requirements. The Port of Leith is ranked as the top location within Scotland for integrated manufacturing for offshore wind infrastructure. The Memorandum of Understanding (MOU), dated October 2011, signed by City of Edinburgh Council, Scottish Enterprise and Forth Ports, which received high level political support form the Scottish Government, sets out an agreed vision for the Port of Leith. The vision recognises, It is in the common interest to ensure that the Port of Leith continues to operate as a successful port. This will ensure that the commercial success of the Forth Ports business is maintained for the long term, leading to increased job creation and economic prosperity. The ports location on the Firth of Forth with direct access to the North Sea and a large portside land allocation makes it a key Scottish asset that should be protected for future manufacturing and other port related activities.

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The Scottish Government has recently announced the creation of Enterprise Areas. These areas have been created to target the sectors with the greatest potential for growth and new jobs and they represent strategic locations where the Scottish Government consider achievable opportunities for development exist in the short term. The Low Carbon/Renewables East Enterprise Area supports marine renewable sites at the Ports of Leith and Dundee. The area to remain in operational use encompasses the whole peninsula area of the Port extending to Seafield, including the area of land currently identified for Business Development Proposals (BUS 3) in the Edinburgh City Local Plan (adopted 2010). The Local Development Plan should include a policy designation for this area, identifying it as an area for industrial and operational port use. A policy should also be included to support the development associated with renewable energy. This should include a reference to the options for berthing larger vessels than can currently be accommodated in the lock at the Port of Leith, as larger vessels will be essential to the offshore renewables industry going forward. Implementing Open Space Strategy Forth Ports notes that the diagram on page 45 of the Main Issues Report and the Open Space Strategy (City of Edinburgh Council, September 2010, Map 3 pp10:11) identifies the creation of the following: Leith Docks Community Park; Leith Links Seaward Extension; and The Waterfront Promenade along the north of the Port of Leith, extending across the breakwater.

The Leith Docks community park was proposed as part of the Leith Docks Development Framework to serve the new community of 15,000 homes at Leith Docks. As Forth Ports, no longer supports housing-led mixed use on the areas associated with this open space, it is therefore no longer appropriate to support the development of this park. There is also no need to identify a replacement site, as the proposed housing development it was designed to serve will not be brought forward; therefore the proposal should be deleted from the plan. The other two proposals are the waterfront promenade and the seaward extension to join Leith Links to the waterfront. Whilst the aspiration behind these proposals is recognised as part of a wider mix-use regeneration of the waterfront, they are incompatible with continued industrial use of the Port. Forth Ports would support the Councils proposal to identify an alternative inland route for the Promenade, through Leith and potentially passing by Victoria Dock and utilising the proposed waterfront Promenade around the Western Harbour in front of Ocean Terminal, which forms part of the Harbour Masterplan (application number 08/04232/OUT). This will allow an interesting and varied route to be created, in keeping with the overall vision of allowing a waterside walk from Cramond to Portobello. This should be recognised by policy for the waterfront, in the implementation of the Central Scotland Green Network and policy on open space.

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The Main Issues Report at page 59 states that there is unlikely to be any significant change to Policy OS3 Open Space in New Development of the Edinburgh City Local Plan (adopted 2010). In implementing the Policy, the Council should be mindful of a developments use, for example the continued operational and industrial use of the Port of Leith should not trigger a requirement for open space. In addition, open space use at the Port of Leith will be incompatible with continued industrial use.

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