02 June 2014

Craighouse : third time lucky?

A third set of plans have been released for the Craighouse site.  A friend of mine, whose response I posted last time, has now written an authoritative response. I'm posting it here as a public service - and to encourage us all to write our own! 

Thank you for the opportunity to comment on the third application for the Craighouse site (12/04007/SCH3).  I object to this proposed development, for the reasons set out below:

Buildings at Risk

A key argument of the developer is that permission should be granted for the proposed development to secure the future of the listed buildings on the site.  This is a false argument. 

The buildings only entered the Buildings at Register during June 2012, after the developer took ownership of the site.  It is the failure of the developer to propose a suitable development for the site that has resulted in their inclusion in the Register.  While the long term future of the existing listed buildings is dependent on re-development, there is no reason why that future should be dependent on the current poorly thought out proposals. The developer should work with local residents to develop a scheme that is sympathetic to this unique site while also being capable of returning a reasonable profit.

It is also worth noting that the buildings are included in the Register “due to ongoing vacancy and lack of identified new use”, rather than any fundamental risk to the deterioration of the fabric of the buildings.  There is no immediate risk to the buildings that require an urgent decision.

Enabling Development

The developer argues that the new build elements of the proposal are required as “enabling development”.  Enabling Development is not defined in Scottish planning policy, however the English Heritage policy is generally used in Scotland – which is:

“Enabling development that would secure the future of a significant place, but contravene other planning policy objectives, should be unacceptable unless:

a) it will not materially harm the heritage values of the place or its setting
b) it avoids detrimental fragmentation of management of the place
c) it will secure the long-term future of the place and, where applicable, its continued use for a sympathetic purpose
d) it is necessary to resolve problems arising from the inherent needs of the place, rather than the circumstances of the present owner, or the purchase price paid
e) sufficient subsidy is not available from any other source
f) it is demonstrated that the amount of enabling development is the minimum necessary to secure the future of the place, and that its form minimises harm to other public interests
g) the public benefit of securing the future of the significant place through such enabling development decisively outweighs the disbenefits of breaching other public policies.”

The new build elements of the proposed development are contrary to this policy on several counts:

The new build proposals will materially harm the heritage value of the site, particularly through inappropriate massing of the new build elements and the use of materials alien to the current site, such as timber cladding, zinc roofing and metal framed doors and windows.

The new build proposals exist to increase the profitability of the site for the current owner rather than benefit a site of significant architectural, heritage and landscape value.

The developer has submitted a Report on Financial Case: May 2014, which aims to show that the proposed new-build elements of the development are the minimum necessary to secure the future of the listed buildings on site. This has used an average sale price of £419,550 per unit to calculate a conservation deficit of over five million pounds. This average has been calculated using nearby sale prices paid over the past ten years and an average price paid per square foot for those sales.

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. 

 My reasons for this are as follows:

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.

2.    There are no new build properties in the local area with which to compare prices for this unique site.  Any homes on the Craighouse site would carry a price premium to reflect its location and nature

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[1] – 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[2] 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[3]

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.

The Craiglockhart Hills Conservation Area Character Statement could not be clearer about the importance of the Craighouse site, stating:

“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.


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.


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.

[1] Meadow Heights, Q22 Level 02-04.  Checked on the Quartermile website on 30 May 2014
[2] Paragraph 5.12.2, Enabling Development and the Conservation of Significant Places, English Heritage,
[3] Paragraph 5.12.3, Enabling Development and the Conservation of Significant Places, English Heritage,


Anonymous said...

"Morningside Drive is a long, steep hill". Its gradient is in fact 3%. That is not remotely steep. Your argument will have more force if you don't make up or exaggerate facts.

Objection author said...

Hello “anonymous” and thanks for taking the time to comment. I think “steepness” is something everyone experiences differently. Morningside Drive certainly feels steep when you are pushing a buggy up it, or are carrying shopping. I imagine people with mobility problems find it steep. I suppose I could have said “long, sustained climb” or some such. However, the terminology used is effectively irrelevant. The point I was making is that people are unlikely to access services in Morningside on foot or by bike due to the location of the Craighouse site at the top of a hill. The Craighouse Partnership’s transport planners have simply considered straight line distances, paying no heed to the topography of the site, when estimating trip modal share. This is important as it means that car trips from the site have been underestimated – allowing the traffic impact of the proposals to be downplayed, particularly at peak times.

No need to agree with me though - you can submit your own comments on the proposal and I would encourage you to do so.

Roderick Nelson said...

Something of a magnum opus. You have done a considerable amount of work and I am very grateful to you for your time and trouble. You have sensibly stuck to the material facts and avoided the murkier aspects surrounding the Proposals. It is hard to imagine anyone being in favour of the scheme unless they stood to benefit financially, particularly if they were based elsewhere and viewed this as quick, easy and excessively profitable. Having to employ professional lobbyists rather speaks for itself.
Is the drainage system feasible and would it cope when really needed, during a flash flood?
I would agree that Morningside Drive is not, "Steep," but is a long haul and curving, increasing its length and may require tree root navigation on the North side. I would not consider carrying shopping up its length unless desperate.
I shall certainly object again. This is not mere Nimbyism - as a schoolboy cycling to school I used to stop to admire the view of the wooded hill on a summer morning from Coltbridge. Such beauty must not be destroyed for a fast buck.
Keep up the good work.
(Is it really only 3% and is the anonymous contributor maybe part of the lobbying company?)