I would argue that these methods significantly underestimate the potential value of the units that will be built on the Craighouse site, thus overestimating the amount of new build development required to secure a reasonable profit for the developer.
1.
There are no properties comparable to the units
proposed for the site in the nearby area.
The local area consists of Victorian tenements, terraces and 1930‘s
semi-detached houses built in a traditional street pattern, the price of which
does not reflect the unique nature of the Craighouse site.
3.
Prices charged for properties on similar iconic
sites are significantly higher than those used in this report, e.g. an average
two bed flat in the Quartermile development retails at £426 per square foot – which
is between £36 and £136 per square foot higher than the sales prices quoted by
the developers in this report.
The developer also highlights a figure of 20% profit as fair and
reasonable, mentioning a decision by an English Planning Inspector to back this
up. It is worth quoting the English
Heritage Guidance
on this matter, which states:
“As a very rough
guide, in today’s market, a pure entrepreneurial residential developer will
look for an overall return on costs of between 15% and 20%, while a
builder/developer may seek only a 10% return on the construction cost element,
as a builder’s profit should be included in those construction costs. It is
important that a double profit is not allowed.”
Given this, 20% seems an overly generous profit margin which, again,
would allow for more enabling development to be built than is required to
secure the future of the listed buildings.
The developer also indicates that the decision of the English Planning
Inspector sets a precedent for the level of profit that should be considered
fair and reasonable. This decision does
not set a precedent. The English Heritage
guidance is clear on this point, stating “Each scheme is different, and must be
assessed on an individual basis, normally within the range indicated
”
It is also worth remembering that the English Heritage guidance goes
on to state that:
“…a developer will
normally wish to maximise the conservation deficit to be covered by enabling
development, and thus the quantum of development, in order to maximise
allowable profit, since it is directly related to the scale of the operation… The
public interest will almost always lie in minimising the quantity of enabling
development.”
Development Plan Policies
The proposed development is contrary to many development plan
policies, including:
1. It is contrary to the spatial strategy set out in Strategic Development Plan for the regional core, which directs development towards the four Strategic Development Areas within Edinburgh.
2. It is contrary to Policy 1B of the Strategic Development Plan, as the new build proposals would have significant adverse impacts on several A listed buildings, due to their proposed location, height, massing and materials used. These proposals would have an adverse impact on a highly visible setting, which can be seen from many parts of Edinburgh.
3. It is contrary to Policy 1B of the Strategic Development Plan as the proposals do NOT have regard to the need to improve the quality of life in local communities by enhancing the natural and built environment. The proposals will reduce available open space, negatively impact on a site of architectural and historic value and make the surrounding area less, rather than more, attractive.
4. It is contrary to policy 1B of the Strategic Development Plan as the proposed new build elements are not a high quality design and there is no indication that there will be use of sustainable building materials.
5. It is contrary to Edinburgh City Local Plan policy Des 1 which states “Planning permission will not be granted for poor quality or inappropriate design or for proposals that would be damaging to the character or appearance of the area around it, particularly where this has a special importance.” The new build proposals would be damaging to the character of the surrounding area, which is of special importance (given the presence of A listed buildings and conservation area status) due to their height, massing, location and proposed materials.
6. It is contrary to Edinburgh City Local Plan policy Des 10 which states that “Proposals for buildings which rise above the building height prevailing generally in the surrounding area will only be permitted where… there would be no adverse impact on important views of landmark buildings, the historic skyline, landscape features in the urban area or the landscape setting of the city, including the Firth of Forth.” The proposed new build development would have an adverse impact on views to and from Craiglockhart Hill, as the elevated position means the buildings would be highly visible and exceed the height of all other nearby residential buildings.
7. It is contrary to Edinburgh City Local Plan policy Env3 as the proposals are detrimental to the appearance and character of several listed buildings.
8. It is contrary to Edinburgh City Local Plan policy Env6, as the proposals will have a negative impact on the appearance and character of a conservation area.
9. It is contrary to Edinburgh City Local Plan policy Env 11, which states “Planning permission will not be granted for development which would damage or detract from the overall character and appearance of the Areas of Great Landscape Value shown on the Proposals Map, prominent ridges, or other important topographical or landscape features.” The proposed development clearly detracts from the character and appearance of an area of great landscape value.
10. It is
contrary to Edinburgh City Local Plan Env12, as it has a negative impact on
trees within a conservation area which the proposed re-planting proposals do
not ameliorate, particularly in the short to medium term as mature trees are
being replaced by far smaller plants.
11. It is
contrary to Edinburgh City Local Plan policy Env15, as it will have a
detrimental impact on the flora, fauna and landscape of a local nature reserve.
12. It is
contrary to Edinburgh City Local Plan policy Env16, as the proposals may have a
negative impact on nesting birds, badgers and bats.
13. It is
contrary to Edinburgh City Local Plan policy Os 1, as the proposals involve the
loss of open space with no significant benefits.
Developer’s Planning Statement
The developer’s
Planning
Statement sets out to prove that the proposed development is in accord with
the development plan and, where this is not the case, there are material
considerations which outweigh the policies and proposals in the development
plan.
Hopefully, the detailed objections above are enough to refute the
claims made by the developers that the proposed development complies with the
development plan. The following section
questions the heroic assumptions made by the developers with regards material
considerations.
Paragraph 25 of the Scottish Planning Policy states that “material
considerations should be related to the use and development of land”. Clearly, the Scottish Government’s 2012-13
Programme for Government and Historic Scotland’s Corporate Plan 2012-15 do not
meet this criteria and these document should be disregarded as material
considerations.
The policies and proposals set out in the Strategic Development Plan
and Edinburgh City Local Plan are already in accordance with the requirements
of the National Planning Framework for Scotland 2, the Scottish Planning Policy
and the Scottish Historic Environment Policy. The national policies highlighted by the
developers have been effectively incorporated into the development plan
policies I have highlighted above and there is nothing new in the points raised
under these headings that aren’t already covered in the development plan
policies.
The English Heritage policy on enabling development is discussed
above, it is clear that the new build elements of the proposals do not meet the
definition of enabling development.
“Views to the
Hills from Arthur’s Seat, Calton Hill, Blackford Hill and Edinburgh Castle are
also spectacular, in particular to Easter Craiglockhart Hill on which high
quality Victorian buildings are set against a predominantly wooded hill, the
woodlands emphasising the visual prominence of the site over the local
surrounding area.”
It is clear that the new build development proposals would have a
significant detrimental impact on these spectacular views. The Character Appraisal goes on to state the
following about the Craighouse site:
“The buildings
form a homogeneous group round the old mansion, as they are closely related in
design, layout and materials. This character has remained largely unchanged
since the late 19th century. The conversion of the site by Napier University
has maintained the essential historic and architectural character, and
conserved and enhanced the surrounding landscape.”
Again, the new build proposals could only have a negative impact on
the architectural character of this unique site.
The proposals do not meet the definition of enabling development or
enhance the character of the conservation area and cannot be seen to meet the
policies set out in PAN65 and PAN71 as claimed by the developer.
Transport
The Transportation Assessment which accompanies the planning
application fails to take account of several factors that act against walking,
cycling and public transport use from this site and significantly
underestimates the number of car trips that the development would generate. This is contrary to the key aims set out in
the National Transport Strategy of improving journey times, reducing emissions
and increasing access to public transport.
It is also contrary to policies
set out in the Local Transport Strategy 2014-2019, which aims to encourage
modal shift to active and sustainable modes, reduce car travel and reduce
emissions.
The errors/omissions in the Transportation Assessment include:
- The straight line distance based walking isochrones set out in Figure 3.3 do not take account of the fact that Morningside Drive is a long, steep hill and that Craighouse Road is among the steepest roads in Edinburgh and only usable by the most able pedestrians. This results in a significant underestimate of the time taken to walk along these routes, e.g. it takes a fit adult at least 20 minutes to walk from the centre of the Craighouse site to Comiston Road and not 15 minutes quoted.
- The straight line distance based cycling isochrones set out in Figure 3.5 do not take account of the fact that Morningside Drive is a long, steep hill and that Craighouse Road is among the steepest roads in Edinburgh and only usable by very fit cyclists. This results in a significant underestimate of the time taken to cycle up Morningside Dive and the fact that most cyclists in Edinburgh would choose to avoid Craighouse Road due to the gradient.
- Bus services near the site were reorganised on 1 June 2014. The site is no longer served by Lothian Buses 41.
- Bus stops served by the replacement Lothian Buses 36 are a 5-10 minute walk from the proposed development and the service ends at around 2000 each night.
- Most of the bus services mentioned in the transport appraisal can only be accessed from Comiston Road, which is approximately 20 minutes’ walk from the site. Significantly reducing their attractiveness.
Given these errors/omissions, it is highly unlikely that the modal share estimates for the site (24% bus, 9% walking and 3% cycling) would be met and it is likely that a far higher proportion of trips would be made by car than estimated.
It is also worth noting that these modal share estimates are far below the 2020 modal share targets for active travel set out in paragraph 2.3 of the Local Transport Strategy 2014-2019 (walk 36% and Cycle 10%).
It is clear that the transport assessment has also failed to consider the major congestion on Craighouse Road/ Myreside Road at the morning and evening peaks caused by parents and carers dropping off and picking up pupils from George Watson’s College – something that cannot be shown by simple traffic counts. This is a significant oversight, as additional traffic on these routes at these times will have a far greater effect on congestion in the area than assumed in the assessment.
Summary
In summary, I object to the proposed Craighouse development for the
following reasons:
1. It is contrary to Strategic Development Plan policies.
2. It is contrary to Edinburgh City Local Plan policies
3. It is contrary to Local Transport Strategy 2014-2019 policies
4. The new-build elements of the proposal do not meet the definition of enabling development
5. There are no material considerations which indicate that the development should be approved contrary to the numerous development plan policies which require its refusal.