The Scottish Planning System – response to Scottish Government’s Consultation on Planning Reform

In January 2017, the Scottish Government published a consultation paper ("Places People and Planning") which provided details of the proposed changes to the planning system in Scotland. This was in response to an independent review of the Scottish planning system in May 2016, Empowering Planning to Deliver Great Places”.

NTBCC submitted comments to the initial independent review in August 2016 (which can be viewed here) as well as responding to these latest Scottish Government (SG) proposals, titled "Places People and Planning" ; this April 2017 NTBCC submission can be viewed here.

Overall, NTBCC were disappointed in the SG response to the Independent review’s recommendations. Planning should and can provide a long-term perspective, tackling important issues such as development delivery, health, inclusion, environmental quality and climate change. But the SG response is too vague; containing too many aspirational proposals and too much “sloganeering” with too few practical detailed actions. The importance of creating “place” is barely touched on. Despite statements about increasing “people” involvement, too many of the suggestions imply drawing control into the centre. We believe that considerably more work is required to redress these issues and we hope that following further consultation, a more meaningful proposal will emerge.

Key NTBCC comments to the latest SG proposal include :

  • Questioning the lack of defined role for Community Councils in “Community Partnerships” (which are aimed at aligning community planning and spatial planning) and further examination of Community Councils’ status within the formal planning process.
  • Concern over the very limited statements covering the role of planning in achieving high quality place making, urban design, landscape and architecture. We believe that the aims should be rewritten to include protection and enhancement of our distinctive places and high quality environment; ensuring that changes are in keeping with and of comparable quality with the established townscape.
  • The real or perceived effectiveness of the Pre-application consultation process and the need to lower the threshold for what constitutes a “major development”.
  • Raising many concerns with the current planning process which undermine public trust e.g. questionable decisions following appeals ; accountability of Councillor’s decisions (no record of individual votes) ; attritional approach to gaining approval by some developers by resubmitting almost identical applications; lack of enforcement (adequate powers exist but local authorities frequently too timid or risk-averse to exercise them) ; concern over the decision-making process where the local authority is also party to the development.
  • Questioning the absence of proposals to extend the right of appeal to objectors in certain cases e.g. when an application has been approved (often on appeal) contrary to the officials’ recommendations and to the council’s own adopted policies ; or where the local authority has a financial or other interest.
  • Support in principle for an infrastructure levy for specific developments but with some caveats.
  • Support for increasing planning fees for larger developments to reflect the added complexity but noting that this needs to provide a more dedicated service.
  • Ensuring that the planning service is properly trained and resourced to deliver good planning.

Thanks to Stephen Hajducki for drafting this response for NTBCC.

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Campaign by Edinburgh Old Town Development Trust to Challenge “India Building” Planning Approval

The £65m scheme which includes the historic cluster known as India Buildings at the bottom of Victoria Street and Cowgatehead Church, across from the Grassmarket was approved in May 2016. The consented development comprises a 200+ bed hotel with bar, restaurant, café as well as retail and commercial uses. The developer argues the scheme will bring the listed India Buildings back into use for the first time in 10 years.

Edinburgh Old Town Development Trust as well as others aim to mount a legal challenge to the granting of the application though a campaign ‘SAVE Edinburgh Central Library’ (although to be clear, the library function will remain unchanged).

NTBCC have been contacted to make people aware of a public meeting on 5th April – full details can be seen here. This will also include the launch of online fundraising to cover legal costs.

As this falls well outside of the NTBCC boundary, as is normal, we did not make representation on the proposal.

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Leith Street Closure Proposal – NTBCC submission

A recommendation for the closure of the top of Leith Street in both directions for all traffic except cyclists for up to 44 weeks is due to presented to the Transport & Environment Committee on 21 March.

At the March NTBCC meeting, a last minute briefing by representatives from the Leith Street Stakeholder Engagement team was made - prompting disappointment (that residents were ‘left in the dark’), frustration with the process and concern over the consequences in equal measure.

The Stakeholder Engagement team did acknowledge that their “stakeholder engagement“ was more communication – resulting in NTBCC being told what diversions  would happen. NTBCC were frustrated over the absence of a more useful consultation process with a reasonable time to respond.

Whilst we accept that, for efficiency and public safety, that it will be necessary to close Leith Street for a period of time to enable the work to be carried out and we also accept that considerable work has gone into the diversion routes proposed for bus and general traffic. However, it is unclear to us that a closure for as long as 44 weeks would be supported by an independent economic assessment, and we also have significant concerns on the absence of specific measures to ensure that the spill-over of diverted traffic into residential streets is minimised.

Although there is no formal consultation process, we have nonetheless submitted our thoughts on the proposal for consideration by councillors on the Transport & Environment Committee on Wednesday 21 March – the full submission is available here

This includes several further potential measures to minimise as far as possible the disruption caused by this closure as well as suggestions for continued review and amendments if required.

NTBCC March meeting agenda – UPDATE

As well as the normal items, the agenda includes a presentation and Q & A on the revised hotel proposal for the former Royal High School by Duddingston House Properties and Urbanist Hotels development team – see planning application 17/00588/FUL. with representatives from Urbanist Hotels, Hoskins Architects and Sorrell Associates.

In addition, given the various news items on the proposed closure of Leith Street (between Waterloo Place and Calton Road) which is scheduled for discussion at next weeks Edinburgh Council Transport & Environment Committee, we will also be hearing from Donald Anderson (who is working with Henderson Global regarding the St James Centre) about the justification and background to the proposed closure of Leith Street for 44 weeks, starting after this year's Edinburgh Festival. More details can be found here.

 

 

Former Royal High School – Revised Plans for Luxury Hotel Development Submitted

Following on from the Public Consultation in November 2016 for the proposed re-development of Edinburgh’s former Royal High School into a luxury hotel, the developer (Duddingston House Properties / Urbanist Hotel group) have unveiled a scaled-back vision for the site (see Edinburgh Planning portal reference 17/00588/FUL). New plans lodged with the city council for the project reveal that it will now have 127 rooms (20 fewer than before). The new submission’s stated aims are to pursue their original vision “to restore the unique building to prominence” and “create a world-class hotel of international standing”.

The original proposal was rejected by the Council planning officials and elected Councillors in late 2015 after the majority of heritage bodies and many residents (including the New town and Broughton Community Council )  objected to the scale of the development proposed and the adverse impact on the setting of this important listed building.

A parallel application to restore the building as a home for the St Mary’s Music School already has planning consent but cannot proceed due to contractual arrangements between Edinburgh Council and Duddingston House Properties.

Whilst we fully support in principle any scheme that will restore and safeguard the long-term future of this building , what was shown at the November public Consultation was not in our view sufficient to dispel the significant concerns we had with the previous proposal. That said, we  are currently examining  the planning application carefully before making our detailed response and we have extended an invitation to the developers to discuss these proposals in more detail with NTBCC and are awaiting their response.

We will communicate more details in the next few days but would urge everyone who is interested in the building’s future to examine these proposals and express their views to Edinburgh Council before 24 March.

Let us know what you think by contacting us through our website or attending our meeting on Monday 13 March.

Update on RBS Site Redevelopment including Historic Environment Scotland’s Response

The New Town & Broughton Community Council has consulted widely on the proposal for redevelopment of the RBS site fronting Fettes Row, Royal Crescent, Dundas Street and Eyre Place.

We have also had extensive engagement with the architects / agents who have been involved with bringing forward a planning application.

NTBCC have further refined the draft of the representations that we published on our website recently and have now submitted the final versions covering the Planning Permission in Principle application (16/05454/PPP) as well as the Conservation Area Consent application (16/05455/CON) for the demolition of the existing buildings on the site.

NTBCC’s final representation for 16/05454/PPP can be viewed here and the parallel representation covering 16/05455/CON here. They are also now available on the Edinburgh Planning portal along with other statutory consultees.

We have been encouraged by the high level of community engagement regarding this development and we appreciate the significant effort made by many local residents associations and other groups as well as the robust discussions at many community council meetings.

We have also encouraged many heritage bodies to register their comments on these applications and are pleased that our neighbouring community council (Stockbridge & Inverleith) have submitted their objections as well as Edinburgh World Heritage, the Architectural Heritage Society of Scotland (AHSS) and the Cockburn Association.

We are also encouraged by the detailed objection submitted by Historic Environment Scotland - who has taken a strong position regarding the negative impact that the proposed development would have on the World Heritage Site due to the proposed height and massing (which can be viewed here with key statements highlighted). We would hope that their formal objection will ensure that current proposal is withdrawn and significantly amended followed by a further period of public consultation.

We remain of the view that a more appropriate level of development of this prime New Town site has the potential to create a complex of buildings that would truly enhance this area of the city.

 

NTBCC Draft Representations on RBS Scheme

The New Town & Broughton Community Council have had extensive discussions with the developers of this scheme. NTBCC members attended the three Public Consultations over the preceding 12 – 18 months and have provided comments at each stage.

Furthermore, we have discussed the developing plans at many community council meetings and have had active discussions with many residents’ groups in the local area – the majority of whom would be affected by this development. It is worth noting that despite the high level of pre-consultation by the developers with the community and despite many groups not being adverse to development or redevelopment on the site, there has been a growing level of concern expressed as the proposals have matured.

We have now concluded a draft of the representation that we intend to submit prior to 18 December. Although the majority of the discussion has been associated with the Planning Permission in Principle application (16/05454/PPP), we will also object to the Conservation Area Consent application (16/05455/CON) for the demolition of the existing buildings on the site.

The draft representation for 16/05454/PPP can be viewed here  and the parallel representation covering 16/05455/CON here.

A summary of these representations will be covered at the NTBCC meeting on Monday 12 December.

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