NTBCC submission on proposed IMPACT development (18/04657/FUL)

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25th October 2018

Emma Fitzgerald,
Development Plans Teams – Planning and Transport, Directorate of Place,
The City of Edinburgh Council,
Waverley Court, Business Centre G3,
4 East Market Street,
Edinburgh, EH8

18/04657/FUL Erection of music and performing arts venue with licensed café/restaurant and bar facilities, and related arrangements for infrastructure, demolitions, and other works.
35 – 36 St Andrew Square Edinburgh EH2 2AD

Dear Ms. Fitzgerald,

We are very grateful for the extension proposed for the New Town & Broughton Community Council to allow NTBCC to reflect the views of the community council and wider community to this important application.

We would want to firstly acknowledge the level of engagement extended by members of the development team with community council members and other local residents during the extended consultation process.

Broadly, we expressed support for the approach taken during this consultation of initially setting the context of the proposal and exploring the wider public’s thoughts on the key aspects that were important to them, and then using the feedback obtained to develop more specific design details covering the style, footprint, massing and height of the new building. We would, however, note that the initial Design Brief as set by the IMPACT team to achieve their goals has resulted in a significant challenge as to the facilities to be accommodated on this constrained site; requiring both an innovative approach to be taken as well as some compromise to the wider setting including the proximity to the residential tenement to the east. NTBCC would have preferred a slightly less tall main auditorium but we fully understand that is not possible with the proposed brief, and the ‘normal’ option of reducing a residential or office building by one storey is not feasible.

The approach taken by the architects is innovative and achieves high levels of permeability for pedestrians through and/or around the building providing a real enhancement to this area.

Several members of the NTBCC attended the various Public Consultations (either at the Preview session or the later public sessions). Although some NTBCC members had already completed e Questionnaire – expressing their personal views on what they saw – we agreed to provide a broader consensus of views from within the community as far as we are able to gauge at this time. Hence, we responded to the Pre-Application consultation (17/04797/PAN) summarising our collective thoughts in November 2017 ; which we were happy to see included in the Pre-Application Consultation report lodged with the above application.

Furthermore, NTBCC were appreciative of the presentation by David Chipperfield Architects and others from the IMPACT team on the near-final proposals at the NTBCC meeting in June 2018.

We fully acknowledge and welcome the significant efforts of the developers to consult with a wide variety of stakeholders, including importantly residents, throughout the development of the final design for this project. We were also encouraged by the fact that the detailed presentation boards used at these consultations was available on the ImpactScotland.org.uk website. We would further note that the design evolution has reflected many of the comments generated by this extensive consultation.

We also welcomed the early engagement with the Edinburgh Urban Design Panel and note their conclusions.

Support for a new international music and performance venue in central Edinburgh

NTBCC are clear in stating their full support for the principle to develop a world-class purpose-built concert hall/performance venue in this part of the city centre. The facility as envisaged will be a welcome addition to performance spaces across Edinburgh, offering a mix of classical & other performances in an acoustically-excellent building.

Collectively, we are in full agreement that this new performance venue will add immeasurably to the amenity offered in central Edinburgh & specifically at the east end of the New Town. This would add to and complement the mix of resident/visitor offerings in this part of the city centre in addition to the already well-provided for retail, accommodation & food/beverage offerings.

We take the view that this project will make a significant and positive contribution to overall residential amenity and act as a transformative catalyst for the revitalisation of the streets, lanes and businesses that surround it.

Although this proposal will provide ‘an acoustically-excellent home for the Scottish Chamber Orchestra’, the benefits to the wider community to provide a ‘year-round bustling arts destination for performers, audiences and the wider community’ should not be under- estimated. We are also supportive of the applicant’s desire to develop partnerships, creative programming and community outreach to engage and encourage participation of people regardless of age or background.

NTBCC also note, acknowledge and support the aim of IMPACT Scotland that the range of activities need to be consistent with longer term economic sustainability – despite the substantial public contribution being given in support of the capital costs (through the Edinburgh City deal).

Location for the IMPACT Centre building

St Andrew Square is an excellent location for this new performance venue both in terms of complementing the mix of resident/visitor offerings in this part of the city centre as well as the transport infrastructure (bus, tram and train) as well as motor vehicles given the proximity to the new Edinburgh St James development. It is also well-positioned regarding pedestrian flows through this part of the city centre.

Permeability and Relationship to Other Currently Consented Developments

The proposed design provides a welcome inter-connection with neighbouring developments and improves the permeability between St James Square, Elder Street and West Register Street, Register Place and St Andrews Square

We support this opening of access through the site, and with the design of the ground floor, we understand that this open access will be available for extended hours irrespective of the operation of the concert hall.


We acknowledge the considerable connectivity of this site with Edinburgh’s public transportnetwork. However, given that it is likely that many concert attendees (at least in the short/medium term) will still travel by private car and will be tempted to park in nearby residential areas of the New Town – putting further pressure on these parking zones which already suffer due to the imbalance between available residential parking spaces versus Allocated Residential parking permits. We therefore support the suggestion from The Cockburn Association who advocate some relationship with the operators of the new car park associated with the Edinburgh St James development be agreed , with perhaps concessionary ticketing for evening performances (when the car park is less likely to be used). Similarly, the integration of concert and public transport ticketing would be advantageous (i.e. buying a bus or tram ticket as part of the same purchase).

We acknowledge that this may be an operational matter and outwith the scope of planning conditions but given the concerns raised by residents in the New Town who may be impacted, we felt it necessary to register this issue.

Impact on Setting of Adjacent Buildings

NTBCC support the principle of designing the new facility from ‘inside to out’ i.e. ensuring that the building functions as an acoustically-excellent space but that does dictate to a degree the height and massing necessary to achieve this.

Accepting this, the key design element is to ensure that the new building complements the adjacent listed buildings and does not unduly detract from them or dominate them. We do, however, recognise that there is a desire to ensure that the new building has an individual presence on the site and to a degree, does stand out but this need not nor should not be a priority. The relationship between the new build and Dundas House in particular is key to a successful design that would be embraced by the local community. We recognise that the new building will be visible from many viewpoints within Edinburgh city centre and beyond, but we believe that the key viewpoint is that from George Street/St Andrews Square.

Although we understand that concerns have been raised by others, we do not believe that a major consideration should be whether the new building detracts from the new hotel andother adjacent buildings in the new Edinburgh St James development. From the residents’ standpoint, it is the views from George Street/St Andrew Square that are of paramount importance rather than the views of hotel residents from the top of the ‘W’ hotel.

There are differing views as to the benefits of the ‘W’ hotel as a suitable backdrop/framing for Dundas House versus that of the more symmetrical and geometric proposed IMPACT development. On balance, NTBCC believe that whilst accepting that the IMPACT development cannot be described a subservient to the existing Dundas House, it does offer a different perhaps grander view from the George Street axis. Further, the oval domed roof of the proposed development is perhaps more fitting and consistent with the domed roof of Dundas House and could be seen as more beneficial in views from further afield, albeit with a denser development that the current view.

The key to ensuring harmony with the existing buildings is the choice of materials for the new development.

Finally, whilst acknowledging that within the constraints of the available site, the proposed concert hall is an effective and positive use of space, in terms of positioning of the new development within this constrained site, we take the view that locating the new building close to (or abutting) the rear of Dundas House (once the later extensions has been removed) has the benefit of both ensuring that there is maximum spacing between any new development and the existing tenements (both residential & commercial) to the east of the site as well as allowing in the longer term, consideration for a more fitting permanent access route through the current RBS building, which we believe would be advantageous in the longer term and therefore we support the proposal to retain that option with the proposed building design.


We understand that although the Design & Access Statement covers the approach to be taken in terms of choice of materials, the exact choice of final surface finishes (for both the main elliptical concert hall and the orthogonal support (annex) buildings) has still to be made. NTBCC share the Cockburn’s view that it would be appropriate to make some acknowledgement to the stone context of the building’s setting. We also share and support the proposal by the Cockburn to ensure that sample panels (of whatever is proposed) be made available on site before any final decision is taken.

We have separately had various discussions with the architect on proposed materials and whilst normally being an advocate of sandstone for important developments within the New Town & especially when positioned close to existing listed buildings, we can appreciate the advantage of using reconstituted stone within parts of this development from the standpoint of being able to ensure consistency and also enable finer detailing of some of the building elements. We are also of the view that the use of polished reconstituted stone (formed from an amalgam of materials/colours from buildings adjacent to it) in certain areas could rest sympathetically with the buildings that surround the development site –including the limestone facades of the Edinburgh St James development. The key however is the quality of the final finish and the attention to detail given to it.

As we understand it, the elliptical concert hall building itself is shown to have a distinctive façade different from the adjoining orthogonal (annex) blocks. If our understanding is correct, this approach, including choice of materials could help to visually reduce the overall mass of the building and furthermore create additional visual interest.

It is worth noting that as far as we are aware, the roof of the annex blocks has still to be finalised. Given that these will potentially be visible from a number of viewpoints, this aspect of the detailed design should also be fully considered.

We would support further community consultation on the final detailing of the project if possible through a further AMC application if necessary.

Overall, whilst expressing a preference, we would defer the final choice of materials to CEC Planning Dept, perhaps after further consultation with Historic Environment Scotland.

Impact on Local Residents

NTBCC would want to stress the importance of giving due regard to the small ‘enclave’ of local residents immediately to the east of the proposed development. Whilst we are aware that they already have communicated their concerns directly, we believe that these concerns should be considered fully with respect to the relevant LDP policies.

It is one of Edinburgh city centre’s main attractions that it still has a residential presence in its heart which in our view, should be preserved. Furthermore, those residents have already been subject to many disturbances and changes and this will continue for some years.

We note that the application includes a comprehensive daylight/sunlight study on the adjacent buildings (Design& Access Statement Appendix C) by Thornton Tomassetti, and we would especially refer to those sections covering ‘Building No. 1’ & ‘Building No. 2’ as defined in the report.

Whilst not having expertise in this area, NTBCC notes that this assessment would appear to show that there are multiple windows that do not pass the initial assessment regarding adequate daylighting and are therefore (based on existing LDP policies) required to undergo a further VSC analysis. The VSC analysis which we understand has been carried out in line with CEC policies then indicates that several windows still do not meet the required standards, and are then analysed further under the ‘Average Daylight Factor Analysis’.

This would then appear to conclude with the statement ‘Room does not meet acceptable daylight target in the existing condition. No further analysis required.’

We would request that the Planning officer ensures that this analysis regarding the impact on residential properties has been carried out in accordance with the current LDP policies.


We share the view of the Cockburn Association that it is essential that the floorscape around the new Concert hall be integrated with the Registers and wider environment. This should respect the limited palette of paving materials in the New Town and be designed so that the pedestrian environment appears seamless to users who will approach the building from the various access points. Linkages to the new Edinburgh St James development should ideally also follow this approach. We would support efforts to regarding access to the several garden areas currently under the auspices of the Registers of Scotland (RoS) – (although we appreciate that there seems some reluctance from RoS to engage currently. There is an opportunity to create a new, interesting and intimate pedestrian quarter, in which the new concert hall forms the centre-point.

It is also key that the proposed building connects seamlessly with the new developments that surround it.

As we have previously stated, we are somewhat surprised and disappointed) by the current thoughts regarding integration of the new concert hall development with the existing bank branch in 36 St Andrews Square. We would support (perhaps in the longer term) that a single main entrance to the new concert hall is defined and as we would expect the majority of those attending events at the new concert hall would be arriving from the west – either the St Andrews Square tram-stop, bus station or by pedestrian routes from Waverley station or the eastern end of George Street across St Andrews Square, that this would be preferable through 36 St Andrew Square.

Access for servicing

We have discussed the potential issue of ensuring adequate servicing for the facility during the various conversations with the architects. Our strong preference would be to ensure that there is sufficient hard-standing at the rear of the new building to allow for waste removal/deliveries etc. but more importantly, adequate access for delivery vans (in support of the resident orchestra and others) with access from the extension of Elder Street to the square in the new Edinburgh St James development. This should be feasible as we are aware that there is already limited planned access at this location for hotel guests to the new ‘W’ hotel. Although this should be a predominantly pedestrian area, we would hope that arrangements could be agreed (and with the necessary permissions) to provide access to the new concert hall by this route. The alternate of providing access from St Andrews Square could be detrimental to and interact negatively with the pedestrian flow from St Andrews Square; servicing should be located away from the main entrance to the building.

We would again express the appreciation of NTBCC members that you have accepted a late representation on the above application.

In summary, whilst we are fully supportive in principle with much of the application as stated above, given the concerns on the potential impact of the proposed development on the local residents that live directly adjacent, we would maintain a ‘neutral’ stance on this application.

We trust that this representation will be taken as constructive input to the determination of this application.

Yours sincerely,

Richard Price
NTBCC Planning Convener
On behalf of new Town & Broughton Community Council