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NTBCC Response To Draft Planning Guidance Documents

NTBCC has two general points for consideration.

• There is a need for greater consistency regarding decision-making on planning matters generally. At times decisions appear to be contradictory or are otherwise inexplicable. The Council should have in place systems that can provide internally and externally assurance that decisions have the necessary degree of consistency.
• There should be a tighter enforcement regime. The Council should review its approach to enforcement regarding planning decisions to provide reassurance that owners and developers are not able to disregard regulations and guidance without any consequences.

Response To City Of Edinburgh Council’s Consultation On Draft Planning Documents

• Guidance for Householders: Consultation Draft 2024
• Edinburgh Design Guidance: Consultation Draft – December 2024
• Listed Buildings and Conservation Areas: Consultation Draft 2024

The New Town & Broughton Community Council (NTBCC) has considered the draft planning guidance documents from the City of Edinburgh Council. NTBCC decided that in the circumstances it was appropriate to make general, but nonetheless important, comments on matters principally of concern to the Community Council in its role regarding planning matters.

Guidance for Householders: Consultation Draft 2024

This is a well-established document, and the current draft version is seen to provide valuable advice and guidance to householders regarding making a planning application and the requirements that have to be met. There are no other substantive comments.

Edinburgh Design Guidance: Consultation Draft – December 2024

This is obviously a lengthy document, providing the Council’s expectations for design quality regarding development in Edinburgh.

We would make the following observations.

• The order of the two principal sections of Sustainable Places and then Liveable Places gives an unwelcome emphasis about the major strategic planning priorities of the City Council, i.e., providing Liveable Places should take precedence over any considerations of sustainability.

• We also believe that the status of the guidance should be made more explicit, and that what matters is the City Plan 2030 and planning legislation while guidance is about ‘expectations.’ This also includes being clearer that this is for larger developments in the City.

• In many instances we were uncertain as to the practical implications of the guidance, much of which appeared aspirational, and it was uncertain if such aspirations were generally achievable or whether expectations could be being unrealistically raised.

• NTBCC believes that there is a need for some audit process to assess the extent to which the guidance is applied to/valuable for planning decisions. Community Councillors – and indeed the public generally – often struggle to reconcile the guidance with applications approved, and this requires to be addressed

Listed Buildings and Conservation Areas: Consultation Draft 2024

It is regarding the guidance on Listed Buildings and Conservation Areas that NTBCC has the most significant comments. This is guidance for householders who will not necessarily have an understanding of the law and regulations applying. The guidance does advise that ‘it is advised to obtain specialist advice when considering alterations and repairs to traditional buildings’ but, even allowing for that, the guidance needs to be much more user friendly and provide more information. Specifically:

• The beginning of the document should set out how anyone contemplating undertaking work on ‘a traditional building’ should proceed to use the document. In other words, it needs to be more of ‘a guide how to’ that sets out the matters about which the reader will need to address and require guidance.

• There is a need for information about what defines a traditional building.

• There is a need for more guidance about what is meant by specialist advice.

• The differences between listed buildings and conservation areas need to be drawn out more precisely in the document. One possibility might be to have separate sections for each of the topics. In any case, there has to be a clear map(s) setting out where are conservation areas.

• Overall, this guidance requires more detail. The use of links to various websites is not an appropriate way to present primary information about listed buildings and conservation areas. Often such links are no longer available or become outdated. The critical elements from the listed documents should be drawn out and presented in the guidance document itself. This is particularly the case for the parts on Internal Alterations and External Alterations.

• The sections on Internal Alterations and External Alterations should offer precise summaries of what can and cannot be done.

• It would be much more helpful to the user if the guidance were set out as ‘decision tree’ that takes the reader through the steps which they need to take. This would probably necessitate a more prescriptive approach, but this is likely to be more helpful.

• There is a need to be clearer what are minimum requirements that have to be met e.g., on windows and draughts which can be counteracted in a number of ways.

• There should be much more and precise guidance on the use of specific technologies to mitigate the effects of fossil fuel use. What is presented does not offer much certainty and clarity.

• The existence of the document, when finalised, should be widely publicised to raise awareness.

4. General Considerations

NTBCC has two general points for consideration.

• There is a need for greater consistency regarding decision-making on planning matters generally. At times decisions appear to be contradictory or are otherwise inexplicable. The Council should have in place systems that can provide internally and externally assurance that decisions have the necessary degree of consistency.

• There should be a tighter enforcement regime. The Council should review its approach to enforcement regarding planning decisions to provide reassurance that owners and developers are not able to disregard regulations and guidance without any consequences.

Peter Williamson
Chair, New Town & Broughton Community Council

2 April 2025