Summary of NTBCC’s Representation to Amended RBS Proposals

Following the well-attended January meeting, as agreed, NTBCC have made further representations to the amended applications 16/05454/PPP and 16/05455/CON.

Thanks to the Fettes Row & Royal Crescent Association and Friends of King George V Park for their contribution and community engagement.

We continue to believe that the proposed site, given its size, central location and adjoining a precious open space within the New Town, does offer a unique opportunity to add real value to the area whilst still allowing the current owner to achieve sufficient value from the site. As such, NTBCC are not against appropriate development for the site which directly abuts the Edinburgh World Heritage site and within the New Town Conservation Area – including replacement of some of the buildings that have little or no architectural merit.

However, for the reasons outlined below, reflecting the concerns expressed by many local residents, NTBCC continues to object to this application being granted at this time and we urge that this application is either further amended or refused.

The main concerns were :

Height / Form / Massing

NTBCC maintain that area should be treated as a World Heritage Site (WHS) “Buffer zone” & proposed buildings need to be subservient to the listed buildings to the south & views from the WHS should be respected.

For blocks C/D/E/F (on the site of the existing Data Centre) – we welcome the 1 storey reduction but given the proposed form of the blocks – believe  a further reduction in the uppermost storey is necessary to achieve correct balance between new development & Fettes Row.

For the new blocks proposed for the existing car park (blocks G/H/J/K) – we note a significant reduction has occurred but proposal still outwith HES guidance issued in December. However, we are aware that there have been ongoing discussions between HES & the architects regarding the height of these blocks relative to Royal Crescent & given the lack of specific details of these discussions, NTBCC propose to defer to HES & the applicant reaching agreement on an acceptable height.

We have urged Edinburgh Council to take due diligence of the sunlight / day-lighting studies on existing buildings in Eyre Terrace & more importantly KGVP in determining maximum height of Block B (adjacent Eyre Place / King George V Park).

Mix of uses

NTBCC were disappointed that despite comments submitted to previous application by CEC Economic development & NTBCC, the flexibility to develop as essentially 100% residential is still retained. We maintain that a minimum floorspace should be limited to Class 4 use consistent with LDP Policy Emp9.

Parking Space / Allocation

We note the significant reduction in parking spaces (to 311) vs. the current estimated at 225 – 250 spaces due to re-optimisation of the basement level space and / or following discussions with CEC in line with the recently changed parking space standards. We support 100% onsite (undercroft) parking provision & no additional residential permits to be allocated – in line with current Council policy guidance.

Impact on Existing Residents During Construction

We support the requirement for a specific Construction Environmental Management which should include mitigation steps and in part, address resident’s concerns regarding ground stability during construction. Although this may not be legally enforceable, we have urged Edinburgh Council to request “good faith” commitments regarding dilapidation surveys for nearby properties from the applicant.

Socio-economic Assessment

NTBCC welcome the principle of these assessments & understand that there may not be a standard process for these but believe that taking a baseline for the assessment of an unoccupied site does not present a realistic view of the impact of the loss of the existing employment and also inflates the benefits to be gained from redevelopment.

We also note the significantly higher value to the city (GVA) supporting retention of Class 4 use (Business) on the site vs. residential use.

Demolition of Dundas Street Buildings

NTBCC were disappointed in the lack of detail of the “Alternative Use” section included in the Environmental Statement regarding options that have been explored to reuse the current buildings.

We continue to regret the proposed 100% demolition of the buildings on the site. Reusing or re-modelling the existing buildings would contribute to the sustainability of the overall development & reduce the disruption to local residents and businesses.

The full text of the objection submitted against the 16/05454/PPP application can be seen here (which replaces our previous objection) & the supplement to our original representation for the 16/05455/CON here.