Notice of meeting and agenda
Development Management Sub-Committee of the Planning Committee 10.00 am Wednesday 3 September 2014
Council Chamber, City Chambers, High Street, Edinburgh This is a public meeting and members of the public are welcome to attend. This meeting is also being broadcast via the Council’s internet site
Contact: email: [email protected] / [email protected] Tel: 0131 529 4261/0131 529 4716
1. Order of business
1.1 Including any notices of motion and any other items of business submitted as urgent for consideration at the meeting.
2. Declaration of interests
2.1 Members should declare any financial and non-financial interests they have in the items of business for consideration, identifying the relevant agenda item and the nature of their interest.
3. Application for Hearing
The Acting Head of Planning and Building Standards has identified the following applications as meeting the criteria for Hearings. The protocol note by the Head of Legal, Risk and Compliance sets out the procedure. 3.1 Napier University Craighouse Campus, Craighouse Road, Edinburgh – Protocol Note by the Head of Legal, Risk and Compliance (circulated)
3.1(a) Napier University Craighouse Campus, Craighouse Road, Edinburgh – Proposed change of use + conversion of existing buildings from university campus to residential, construction of new build residential with ancillary development, public realm, utilities infrastructure, access roads, car parking, landscaping - Application no. 12/04007/SCH3 - report by the Acting Head of Planning and Building Standards (circulated).
It is recommended that this application be GRANTED.
3.1(b) Napier University Craighouse Campus, Craighouse Road, Edinburgh – Proposed conversion of existing listed buildings at New Craig , Queen's Craig, East Craig, Bevan Villa, South Craig, Craighouse Lodge, Old Craighouse to form residential properties, including extension at South Craig and demolition of Boiler House (as amended) - Application no. 12/04007/LBC - report by the Acting Head of Planning and Building Standards (circulated).
It is recommended that this application be GRANTED.
3.1(c) Napier University Craighouse Campus, Craighouse Road, Edinburgh – Demolition of Learning Resource Centre (LRC) Building - Application no. 12/04007/CON - report by the Acting Head of Planning and Building Standards (circulated).
It is recommended that this application be GRANTED.
Carol Campbell Head of Legal, Risk and Compliance
Development Management Sub-Committee – 3 September 2013 Page 2 of 4 Committee Members
Councillors Perry (Convener), Howat (Vice-Convener), Bagshaw, Blacklock, Brock Cairns, Child, Dixon, Heslop, McVey, Milligan, Mowat, Rose, Robson and Ross. Information about the Development Management Sub-Committee
The Development Management Sub-Committee consists of 15 Councillors and usually meets twice a month. The Sub-Committee usually meets in the Dean of Guild Room in the City Chambers on the High Street in Edinburgh. There is a seated public gallery and the meeting is open to all members of the public. Further information
All members of the Council have been notified of the publication of this agenda. Any member can request a Hearing if an item raises a local issue affecting their ward. Members must advise Committee Services, by no later than 9.00am on the Tuesday preceding the meeting if they wish to be heard: Contact Stephen Broughton 0131 529 4261 email: [email protected]
A summary of the recommendations on each planning application is shown on the agenda. Please refer to the circulated reports by the Acting Head of Planning and Building Standards or other Chief Officers for full details. Online Services - planning applications can be viewed online by going to www.edinburgh.gov.uk/planning - this includes letters of comments received.
Members of the Sub-Committee can request a detailed presentation on the applications in Section 5 of the agenda. The Clerk will advise of any requests received under “Order of Business” and the report will be discussed later in the meeting.
Members of the Council who are not members of the Sub-Committee can make a request for an application to be considered by means of a Hearing, in order to speak on an application if the development is located in their Council ward. The Clerk will report this under “Order of Business” prior to the Sub-Committee considering the request. Otherwise, ward members are not permitted to speak on applications at the meeting.
Only elected members and officers of the Council may speak at the meeting unless the item is shown as a Hearing. For Hearings, the list of individuals and/or organisations invited to speak at the meeting will be detailed in the relevant report. The Development Management Sub-Committee does not hear deputations on planning applications. For the majority of planning applications, the decision rests with the Development Management Sub-Committee. The Sub-Committee only makes recommendations to the full Council on national/major planning applications, as defined in legislation. Reports on that type of application which require a “pre-determination hearing” will explain the process.
If you have any questions about the agenda or meeting arrangements, please contact Stephen Broughton, Committee Services, City of Edinburgh Council, City Chambers, High Street, Edinburgh EH1 1YJ, 0131 529 4261 email: [email protected]
A copy of the agenda and papers for this meeting will be available for inspection prior to the meeting at the main reception office, City Chambers, High Street, Edinburgh.
Development Management Sub-Committee – 3 September 2013 Page 3 of 4 The agenda, minutes and public reports for this meeting and all the main Council committees can be viewed online by going to www.edinburgh.gov.uk/cpol.
Webcasting of Council meetings
Please note: this meeting may be filmed for live or subsequent broadcast via the Council’s internet site – at the start of the meeting the clerk will confirm if all or part of the meeting is being filmed. You should be aware that the Council is a Data Controller under the Data Protection Act. Data collected during this webcast will be retained in accordance with the Council’s published policy. Generally the public seating areas will not be filmed. However, by entering the Council Chamber and using the public seating area, you are consenting to being filmed and to the possible use of those images and sound recordings for web casting or training purposes. If you have any queries regarding this, please contact Committee Services on 0131 529 4105 or [email protected]
Development Management Sub-Committee – 3 September 2013 Page 4 of 4 Development Management Sub-Committee
10.00am Wednesday 3 September 2014 Protocol Note for Hearing
Planning Application Nos: 12/04007/SCH3, 12/04007/LBC and 12/04007/CON
Napier University, Craighouse Campus, Craighouse Road, Edinburgh
Item number 3.1 Report number Ward Fountainbridge/Craiglockhart
Carol Campbell Head of Legal, Risk and Compliance
Contacts: Stephen Broughton/Chris Kelly Email: [email protected] / [email protected]
Tel: 0131 529 4261 / 0131 529 4716 Summary
Protocol Note for Hearing
Summary
The Council is committed to extending public involvement in the planning process. Hearings allow members of the public to put their views on planning applications direct to the Councillors on the Development Management Sub-Committee. The Sub-Committee members have a report on the planning application which contains a summary of the comments received from the public. Copies of the letters are available for Councillors to view in the group rooms.
Committee Protocol for Hearings
The Planning Committee on 19 May 2011 agreed a general protocol within which to conduct hearings of planning applications, the protocol for this meeting will be:
- Presentation by Acting Head of 30 minutes Planning and Building Standards
- Presentation by Community Councils 15 minutes each party
- Presentation by Friends of 15 minutes Craighouse
- Presentations by Other Parties 5 minutes, each party
- Presentation by Applicant 30 minutes
- Presentation by Ward Councillors 5 minutes each member
- Debate and decision by members of the Sub-Committee
Order of for Hearing
1 Acting Head of Planning and Building Standards 10:00 - 10:30 presentation
2 Questions by Members of the Sub-Committee 10:30 - 10:45
3 Craiglockhart Community Council 10:45 – 11.00 David Owen and Nick Honhold
Merchiston Community Council 11:00 – 11.15 Mairianna Clyde
Morningside Community Council 11.15 – 11.30 Goff Cantley 4 Questions by Members of the Sub-Committee 11:30 – 11.45
5 Friends of Craighouse 11:45 – 12:00 Rosy Barnes
6 Questions by Members of the Sub-Committee 12:00 – 12:10
7 Cockburn Association 12:10 – 12:15 Marion Williams, Director
Architectural Heritage Society of Scotland 12:15 – 12:20 Euan Leitch
Craiglea Proprietors Association 12:20 – 12:25 Betty Barber
8 Questions by Members of the Sub-Committee 12:25 – 12:35
9 Ian Murray MP 12:35 – 12:40
Jim Eadie MSP 12:45 – 12:50 Alison Johnston MSP 12:55 – 13:00
10 Questions by Members of the Sub-Committee 13:00 – 13:10
Lunch Break Until 13:45
Applicants 13:45 – 14:15 Andrew Munis - Montagu Evans William Gray Muir - Sundial Properties Questions by Members of the Sub-Committee 14:15 – 14:30
3 Ward Councillors 14:30 – 15:00 Councillors Andrew Burns, Melanie Main, Gavin Corbett, Mark McInnes, Paul Godzik and David Key.
Questions by Members of the Sub-Committee 15:00 – 15:15
5 Debate and Decision on Application by Sub- 15:15 Committee
Scheduled times are approximate but within this the time limits for speakers will have to be enforced – speakers will be reminded when they have 1 minute remaining. Speakers should keep to “material planning matters” that the Sub-Committee can take into account. Any visual material must be submitted to Committee Services at least 24 hours before the meeting. Decisions will generally be to approve or refuse. Conditions of approval or reasons for refusal may be considered at a subsequent meeting. If the application is continued for further information, the Hearing will not be re-opened at a later stage and contributors will not be invited to speak again. In such cases, the public can attend the meeting to observe the discussion from the gallery. Development Management Sub Committee
Wednesday 3 September 2014
Application for Scheme 3 12/04007/SCH3 At Napier University Craighouse Campus, Craighouse Road, Edinburgh Proposed change of use + conversion of existing buildings from university campus to residential, construction of new build residential with ancillary development, public realm, utilities infrastructure, access roads, car parking, landscaping.
Item number Report number
Wards A09 - Fountainbridge/Craiglockhart
S um m a ry Summary
The proposals are contrary to policies Des1, Des3, Des10, Env3, Env6, Env11, Env12 and Os1 of the Edinburgh City Local Plan. However, the application is for enabling development and it has been demonstrated that the proposed quantum of development is the minimum necessary to fund the long term future use of the category A listed buildings and the surrounding landscape. The significance of the public benefits, which crucially not only ensure the long term future of these buildings but retain public access to this historic place to the benefit of the wider community, outweigh the more moderate disbenefits of allowing development contrary to policy. There are no other material considerations which outweigh this conclusion.
Development Management Sub-Committee – 3 September 2014 Page 1 of 174 12/04007/SCH3 Links
Policies and guidance for LPC, CITD1, CITD2, CITD3, CITD4, CITD5, CITD6, this application CITD10, CITE1, CITE3, CITE5, CITE6, CITE8, CITE9, CITE11, CITE12, CITE15, CITE16, CITE17, CITE18, CITOS1, CITOS3, CITH1, CITH2, CITH3, CITH4, CITH5, CITH7, CITH8, CITCO1, CITCO2, CITT1, CITT2, CITT4, CITT5, CITT6, CITT1, NSG, NSGD02, NSLBCA, NSDCAH, NSP, NSESBB, OTH, CRPCHI, CRPLEW,
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Report
Application for Scheme 3 12/04007/SCH3 At Napier University Craighouse Campus, Craighouse Road, Edinburgh Proposed change of use + conversion of existing buildings from university campus to residential, construction of new build residential with ancillary development, public realm, utilities infrastructure, access roads, car parking, landscaping.
Recommendations
1.1 It is recommended that this application be Granted subject to the details below.. Background
2.1 Site description
The site is located on the north and east slopes of Craiglockhart Hill and covers an area of approximately 20.6 hectares. It is enclosed by the old walls of the former estate. Merchants of Edinburgh Golf Course lies to the south, it adjoins the Easter Craiglockhart Hill Local Nature Reserve to the west and to the north is a small housing development known as Meadowspot. Craighouse Road runs along the eastern boundary and access to the site is from here.
The site is composed of a series of individual listed buildings set within the larger landscape setting of Easter Craiglockhart Hill, one of the 'seven hills' of Edinburgh. The site is steeply sloped and is generally open and grassy at lower levels and wooded higher up. The existing listed buildings include Old Craig which is category A listed (reference number 28046 and listed on 14.12.1970) and a series of Victorian category A listed buildings separately listed (reference number 27736, listed on 28.08.1979). All the buildings formed part of the Napier University campus until recently.
The site was formerly an extension to the Royal Edinburgh Asylum to provide hospital and residential accommodation for fee paying patients. It was owned by the Lothian Health Board prior to being bought over by the University in the late 1990s and adapted for educational use. A more modern, unlisted building, known as the Learning Resource Centre building (LRC) was part of the redevelopment of the site and this lies to the south of the site, beyond Bevan and South Craig.
This application site is located within the Craiglockhart Hills Conservation Area.
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2.2 Site History
13 September 2001 - An application for the development of a new arts faculty building and minor works to existing 'A' listed building was withdrawn (Application reference - 01/01435/FUL).
24 September 2001 - An application for the development of a new arts faculty building and minor works to existing 'A' listed building was withdrawn (Application reference - 01/01435/LBC).
24 May 2002 - Listed building consent was granted for minor works to basement area of New Craig in conjunction with development of new arts facility building (Application reference - 01/04599/LBC).
26 June 2007 - Permission was granted for the development of a new arts facility building, new surface car park and minor works to existing 'A' listed building (Application reference 01/04599/FUL).
19 September 2012 - An application for the modification of clause (fourth) and clause (seventh) of the legal agreement relating to application no. 01/04599/FUL was withdrawn (Application reference - 12/02261/OBL).
22 November 2012 - Permission was granted for the modification of clause (fourth) and clause (seventh) of the legal agreement relating to application no. 01/04599/FUL (Application reference - 12/03397/OBL).
There has also been several applications for minor works relating to the operation of the university estate.
Related applications
An application for the proposed change of use and conversion of existing listed buildings at New Craig, Queen's Craig, East Craig, Bevan Villa, South Craig, Craighouse Lodge, Old Craighouse to form residential properties including an extension at South Craig and Bevan Villa is running in parallel with this application (Application reference - 12/04007/LBC).
An application for the demolition of Learning Resource Centre Building is running in parallel with this application (Application reference - 12/04007/CON). Main report
3.1 Description Of The Proposal
Scheme 3
The proposals are for the change of use of the existing seven, category A listed buildings from institutional use to residential and the erection of six new residential blocks. The works will involve the complete restoration of these buildings which is the subject of a separate listed building consent. The total number of dwellings proposed is 145, with 64 within the existing listed buildings and 81 within new build elements.
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It is proposed to create 44 units within New Craig, 10 within Queens Craig, 2 within East Craig, 3 within Bevan, 3 within South Craig and single dwellings within the lodge house and Old Craig. Six new development sites have been identified, which include the site of the existing Learning Resource Centre (LRC) building which will be demolished and is the subject of a separate Conservation Area Consent application. The proposals are for the following new build elements:
North Craig - The proposal is to replace the existing boiler house and coal stores that serve New Craig with 10 terraced houses. The site is on a steep gradient and the terraced block is designed to integrate with the existing embankment. The houses are two and a half storeys and are of a simple contemporary design finished in red sandstone with timber doors, aluminium windows and with pitched slate roofs. All the properties will have a balcony/terrace. Car parking is located remotely within a fully screened and landscaped parking court to the south.
West Craig - The proposed development is for 10 terraced houses. These are sited to the south of the existing Queens Craig building and will have a stepped form to address the existing topography and landscape. The houses are four storeys, each with a private roof terrace. They are of a contemporary design with flat roofs and will be finished in red and buff masonry, timber cladding to the rear elevations, green rainscreen cladding and metal balustrades. These properties incorporate integral garages at ground floor level.
Kings Craig - The proposed development is for 11 terraced houses. These are sited to the south of the existing New Craig building and will have a stepped form to address the existing topography and landscape. The houses are four storeys, each with a private roof terrace. They are of a contemporary design with flat roofs and will be finished in red and buff masonry, timber cladding to the rear elevations, green rainscreen cladding and metal balustrades. These properties incorporate integral garages at ground floor level.
Clouston Villa - The proposal is to replace the existing LRC building with a block accommodating 14 apartments over five storeys. The block is of a contemporary design with a flat roof. It will be finished in red and buff masonry and glazing. Parking provision will be within an underground car park.
Craiglea Place - The proposal is for 4 terraced houses providing a continuation of the existing terraces on Craiglea Place. The houses are contemporary in their design and will be two and a half storeys. The houses will be finished in red sandstone and timber cladding, will have aluminium windows and a slate roof. They will also incorporate a metal framed 'green wall' to the south facing elevation and photovoltaic solar panels to the south facing roof areas. Vehicular access is from Craiglea Place and parking provision will be to the front of the properties in a small parking court.
Burton Villa - The proposal is for a block (linear in plan) accommodating 32 residential units (6 town houses located at each end of the block and 26 flats located centrally). This block will be sited to the north side of the main vehicular access, just beyond the entrance to the site. The block is of a contemporary design with a flat roof. It will be finished in red and buff masonry, timber cladding and glass, with facing metal detailing. Parking provision will be accommodated within part of the existing car park which is located opposite. The townhouses will have surface parking to the front of the building.
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The proposal includes new infrastructure required to facilitate the conversion and new build elements. Principal circulation routes follow existing paths and roads to ensure the retention and protection of mature trees. The existing single entrance off Craighouse Road will be retained for vehicular traffic, albeit this will be narrowed, with the existing lodge house entrance retained for pedestrian access.
It is proposed to retain the large area of open space which will be made publicly available. There will be a number of trees removed, estimated at around eighty four, to accommodate the development., however The proposals include significant tree planting, approximately seven hundred trees, to address this. The planting of a lime tree avenue is included in the proposals along the north/south ridge adjacent to the South Craig and Bevan.
The proposals also include the reinstatement of the garden and wall around Old Craig and relocation of the substation to facilitate these works.
The area of new build proposed equates to 139 255 NIA square feet.
Scheme 2 (superseded)
The total number of dwellings proposed is 189, with 64 within the existing listed buildings and 125 within new build elements. It is proposed to create 44 units within New Craig, 10 within Queens Craig, 2 within East Craig, 3 within Bevan, 3 within South Craig and single dwellings within the lodge house and Old Craig.
North Craig - 10 terraced houses with car parking is located remotely within a fully screened and landscaped parking court.
West Craig - 10 terraced houses with car parking is located remotely within a fully screened and landscaped parking court.
Kings Craig - 11 terraced houses with car parking is located remotely within a fully screened and landscaped parking court.
Clouston Villa - a new block to replace the existing LRC building accommodating 16 apartments over five storeys. Parking provision will be within an underground car park.
Craiglea Place - 4 terraced houses with vehicular access from Craiglea Place and parking provision to the front of the properties in a small parking court.
Napier Villa - a block ('cruciform' in plan) on the former car park, on the south side of the main vehicular access accommodating 24 residential units over four storeys. Parking provision will be within an underground car park.
Burton Villa - a block (linear in plan) accommodating 50 residential units over five storeys. This block will be sited to the north side of the main vehicular access with parking provision within an underground car park.
Materials included natural stone, red and buff masonry, metal rainscreen cladding/roofing, timber windows, aluminium doors, glass and metal balustrades.
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The area of new build proposed equates to 185,695 NIA square feet.
Scheme 1(superseded)
The total number of dwelling proposed is 153, with 64 within the existing buildings and 89 within new build elements.
North Craig - 9 terraced houses on this site with integrated car parking sited between the units.
West Craig - 10 terraced houses and 3 apartments in an 'L' shape configuration on the former car park adjacent to Queens Craig. Parking to the front of the properties with additional parking sited remotely within a fully screened and landscaped parking court.
Kings Craig - 7 terraced houses and 3 apartments in a linear form on the site south of New Craig with parking to the front of the properties.
Duncan Villa - a new three storey block sited between Bevan and South Craig comprising 3 apartments with parking provision to the front.
Clouston Villa - a new block, replacing the LRC building, extending to eight storeys and accommodating 7 apartments, with parking provision sited remotely to the north.
Craiglea Place - 6, two and a half storey, terraced properties with parking to the front and remotely in a small screened parking court.
Old Craig Grove - this is a site is on the edge of the open parkland to the east of the site and is for 11, two/three storey, terraced properties. Parking provision is to the front of the properties.
Old Craig Court - this is on the site of the car park and to the north of the access road (Scheme 2 locations for Napier Villa and Burton Villa) and is for 30 dwellings distributed within five terraced blocks and five individual dwellings. Car parking is to the front of the properties.
Materials also included large areas of coloured render in place of natural stone.
The area of new build proposed equates to 175,110 NIA square feet.
The following documents have been submitted in support of the application and are available to view via the Planning & Building Standards online services:
• Design and Access Statement; • Design Statement; • Environmental Statement; • Transportation Assessment; • Transportation Safety Audit; • Drainage strategy report; • Flood risk assessment and Overland Flows Report; • Geotechnical and Environmental Assessment Report;
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• Planning Statement; • Pre-application Consultation (PAC) report; • Sustainability Statement (Form); • Estate Management Strategy Report; • Conservation Audit; • Roads and Footway Design Proposals; • Landscape Design and Access Statement; • Outline Softworks Specification; • Landscape and Woodland Management Plan; • Combined Tree Survey; • Enabling case report and; • Report on Financial Case.
In addition the applicants have provided information in respect of sales figures and build costs. The applicants have requested this information be treated as confidential.
3.2 Determining Issues
Do the proposals harm the character or appearance of the conservation area? If they do, there is a strong presumption against granting of consent.
In considering whether to grant consent, special regard must be had to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses. For the purposes of this issue, preserve, in relation to the building, means preserve it either in its existing state or subject only to such alterations or extensions as can be carried out without serious detriment to its character.
Do the proposals comply with the development plan?
If the proposals do comply with the development plan, are there any compelling reasons for not approving them?
If the proposals do not comply with the development plan, are there any compelling reasons for approving them?
3.3 Assessment
To address these determining issues, the Committee needs to consider whether: a) the principle of the proposed development on the site is acceptable; b) the proposals affect the setting of the listed buildings; c) the proposals preserve and enhance the character or appearance of the conservation area; d) the proposed layout, scale, design and materials are acceptable; e) the proposed development will have an adverse impact on the landscape character of the site and views to and from it;
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f) there will be a detrimental impact on trees and biodiversity; g) the development would impact on Open Space provision and restrict recognised rights of way; h) there will be any impact on archaeological remains; i) the proposals will adversely affect neighbouring residential amenity; j) an acceptable living environment will be afforded to future residents; k) there will be any implications in terms of traffic generation and road and pedestrian safety; l) the development would introduce an increased flood risk; m) the proposals are acceptable in respect of infrastructure requirements (education and school capacities, affordable housing provision); n) the proposals meet the Council's requirements in respect of sustainability; o) representations raise issues to be addressed; p) the proposals have any equalities or human rights aspects that need to be considered; a) Principle of the Development
The development plan comprises of the Strategic Development Plan (SDP) for South East Scotland (SESplan) approved in June 2013 and the Edinburgh City Local Plan (adopted January 2010).
The SDP Spatial Strategy builds on existing committed development and Policy 1A identifies five Sub Regional areas, one of which is the Regional Core, within which the city of Edinburgh lies. The application site does not lie within one of the strategic development areas within this core, however, it is recognised that the city as a whole plays a crucial role in the Scottish (and SESplan) economy and forms an important centre of economic activity. The Spatial Strategy in line with Policy 1B encourages the formulation of Local Plan policy and broad principles for bringing development forward. Policy 7 of the SDP encourages the maintenance of a five year housing land supply on greenfield sites. This site is within the Urban Area of the adopted Central Edinburgh Local Plan (CELP) and is not a 'greenfield' site as defined within the SDP. It has not been identified through the emerging Local Development Plan (LDP) process as an allocated housing site either.
The site is located within the urban area in the adopted Central Edinburgh Local Plan. The surrounding area is primarily residential in character with a significant component of the land given over to sporting activities. The reuse of the listed buildings on the site for residential use is compatible with the surrounding area and a sympathetic use which
Development Management Sub-Committee – 3 September 2014 Page 9 of 174 12/04007/SCH3 is acceptable in principle. This aspect is assessed in greater detail within the parallel listed building application.
New housing development is acceptable in principle within the Urban Area in accordance with policy Hou1, however this is subject to compliance with other Local Plan policies.
The site is covered by a number of local plan designations. The site forms the setting of the category A listed buildings where there is a presumption against development which would harm their setting. It lies within the Craiglockhart Conservation Area and is on the edge of the Plewlands Conservation Area where local plan policy only permits development which preserves or enhances the special character or appearance of the area. It lies within an Area of Great Landscape Value (AGLV) and has also been identified as a candidate Special Landscape Area (cSLA) which will replace the AGLVs in the emerging Local Development Plan. There is also a presumption against development which would damage or detract from the overall character and appearance of the AGLV. The site is also in part designated Open Space and a Local Nature Conservation Site. These are the key considerations in terms of the principle of proposed new build development on this site and these are assessed in detail in this assessment, (from paragraph b) below. It will be demonstrated in the forthcoming assessment that the proposed development does not fully accord with local plan policies and as such is contrary to the Development Plan.
In this case the applicants have put forward an argument that this is an "enabling development" which is where the new buildings being proposed, despite being contrary to the Development Plan, are necessary to fund the future use of the existing category A listed buildings and the place. In support of the proposal the applicant has submitted an Enabling Case Report (May 2014) and a Report on Financial Case document (May 2014). The applicant has presented a case that the quantum of proposed new build development is required to repair and convert the seven listed buildings and ensure the long term financial sustainability of the maintenance of the listed buildings and the wider grounds. While there is no specific local plan policy relating to enabling development Scottish Planning Policy states:
"142. Enabling development may be acceptable where it can be clearly shown to be the only means of preventing the loss of the asset and securing its long-term future. Any development should be the minimum necessary to achieve these aims. The resultant development should be designed and sited carefully to preserve or enhance the character and setting of the historic asset."
The first element of this statement requires the enabling case to be the only means of retaining the listed buildings. In considering this question we need to consider the continued use of the listed buildings in their existing use and the redevelopment of the listed buildings alone.
Continued institutional use
Napier University have disposed of the site and vacated the buildings. The disposal of the site involved a number of interested parties bidding to purchase the site. None of the parties were institutions and the Planning Authority is unaware of any institutions interested in locating in this location in this type of premises. It is also noted that the
Development Management Sub-Committee – 3 September 2014 Page 10 of 174 12/04007/SCH3 ongoing maintenance burden of the buildings and grounds was a factor in Napier University's decision to relocate. It is therefore reasonable to state that there is no prospect of the buildings continuing in their current institutional use.
Alternative use of listed buildings
Enabling cases frequently relate to buildings which have been derelict for many years and have little or no value. However, it is acknowledged that the most complex cases can be buildings/assets with a viable, low-key use where the return on investment does not justify permanent repair. In these cases the buildings have a market value for as long as they are usable with limited expenditure. It is also accepted that it is this value which should be taken into account irrespective of the price paid for the site by any given purchaser. The applicant has submitted a conservation deficit appraisal, which considers the continued use of the buildings, and a development appraisal which considers the reuse of the buildings and elements of new build. Both appraisals include a land value of £4,700,000, significantly below the £10,000,000, plus uplift figure, paid for the site. The figure of £4,700,000 is based on a break up valuation for a range of uses within the existing buildings, including the use of New Craig for a wedding venue. It is reasonable to assume that if the buildings and land have this inherent value in their own right then there is the prospect that the buildings can be retained without the requirement for enabling development. This assumption needs to be tested further to ensure this would offer a long term sustainable solution.
Prior to the sale of the buildings Napier University commissioned an appraisal of the ongoing costs associated with the maintenance of the buildings and the grounds. The applicant has provided additional specialist analysis by Drake and Kannemeyer in respect of the anticipated ongoing maintenance of the listed buildings. The annual maintenance, security and landscaping costs associated with this use are estimated at £287,500. The applicant has prepared an indicative business case, based on alternative wedding venue use within New Craig and the maintenance figures provided by Napier University. The business case is based on 50 wedding functions each year and 132 other functions. The business case demonstrates that this use would be able to contribute £20,500 per annum to the ongoing maintenance of the building and grounds, well short of the £287,500 estimate. The business case demonstrates that the alternative use of New Craig does not generate sufficient income to maintain the listed building and the grounds. Furthermore this illustrates the prospect that a low key use of the buildings would result in the buildings reaching a point where they become derelict. At this point the conservation deficit is likely to be significantly greater than at present and therefore investing in the building repairs sooner rather than later will reduce the quantity of any enabling development.
Redevelopment of listed buildings alone (conservation deficit)
This site valuation of £4,700,000 has been accepted by CEC Estates Services on behalf of Planning. The cost plans for the conversion of the listed buildings have been independently audited by Thomas and Adamson on behalf of Planning and are now accepted. The sales values have been adjusted since scheme 1 and are now accepted by CEC Estates Services on behalf of Planning. A more detailed statement on the assessment of all financial aspects of the appraisals is contained within Appendix 2 (CEC Financial Appraisal Review). The revised conservation deficit appraisal, as submitted with scheme 3, reflects the true market land value, accurate conversion costs
Development Management Sub-Committee – 3 September 2014 Page 11 of 174 12/04007/SCH3 and realistic sales valuations. The appraisal considers the reuse of the listed buildings for residential use only and assumes a developer profit at 20%. This appraisal identifies a deficit of £4,656,078 and it is accepted that this arises from the need to secure the future of the asset not the circumstances of the owner or price paid for the site.
It is therefore accepted that the only financially sustainable future for the listed buildings is an enabling development to cross fund the listed buildings.
The elements of SPP paragraph 142 in relation to design quality, protecting the listed buildings special interest, character and their setting are assessed in detail in section 3 b), c) and d)
SPP 142 also requires that the enabling case represents the minimum quantum of development necessary to enable its conservation and re-use.
The development appraisal submitted in support of the case has been internally and externally audited and is accepted (Appendix 2). This appraisal demonstrates that the proposal represents a quantum of new build which would provide a reasonable developer profit and secure the future of the site. Planning has provided the developer with guidance to locate development in parts of the site which will minimise its impact upon the historic asset while maximising capital receipts from the new build elements. The revisions have resulted in a scheme 3 proposal which delivers far greater efficiency of new build development and value from each unit. The scheme 2 appraisal included two blocks referred to as Burton and Napier Villas, where the applicant had chosen a flatted solution with underbuild car parking. The removal of these underbuild parking elements, and change to a mix of flats and townhouses, has had a significant impact in reducing the overall quantum of development required while maintaining a viable developer's profit. A sensitivity assessment of the impact of potential changes in build costs and sales values is contained within the CEC Financial Review (Appendix 2) and demonstrates that developer profit would remain within appropriate levels.
It is accepted that in financial terms the proposal represents the minimum quantum of development necessary to secure the future of the listed buildings and the wider asset, giving due consideration to the market demand in this location and the high quality and cost of development appropriate to the context.
English Heritage Policy
There is no specific Scottish guidance in respect of enabling cases and therefore it is considered appropriate to consider the English Heritage guidance 'Enabling Development and the Conservation of Significant Places'. It is accepted that enabling can extend beyond listed buildings and be applied to other heritage or cultural assets. In the case of this site the asset not only includes the buildings, the land within the conservation area and the landscape setting, but extends to the enjoyment of the site by the local community. This wider view of enabling is reflected more clearly in the English Heritage document which states;
"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
Development Management Sub-Committee – 3 September 2014 Page 12 of 174 12/04007/SCH3 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."
Given the lack of Scottish guidance on this matter it is considered good practice to consider each of these in turn: a) the impact on the heritage values and setting are assessed in assessment 3b) to 3d) below. b) the reuse of the site for a single land use, specifically residential use, is a very sensitive solution which retains the overall character of the place and landscape setting. It is also a sympathetic reuse for the buildings themselves as is assessed in the parallel listed building application (ref 12/04007/LBC). This proposal retains the site as a single unit, maintaining access to the woodland and avoids the fragmentation of the site. c) Edinburgh has a long history of residential properties within historic buildings. The long term maintenance of the buildings on this site and spaces around them is secured through their conversion to residential use and the future home owners' responsibility for maintenance. In addition the formation of a significant number of new build dwellings is a significant factor in securing the viability of the maintenance of the buildings and external space as the costs will be shared across a greater number of owners.
The existing woodland contributes to the overall value of the asset through both its visual quality and as an attractive place for the local community to use and enjoy. The woodland requires a significant amount of work to ensure it provides a safe and suitable environment for public access. Discussions have taken place with Parks and Recreation regarding the future ownership and maintenance of the woodland. They have indicated that a sum of £150,000 would be required to bring the woodland, paths and wall up to an acceptable standard and contribute to its future maintenance. The applicant has included this sum in their revised financial appraisal for the transfer and future maintenance of the woodland. It is therefore reasonable to conclude that the enjoyment of the woodland, as part of the asset, can be secured through this application and an appropriate S75 agreement.
As part of this development public access to the woodland and open space will also be retained. As this is one of the community benefits of this enabling case it is appropriate to ensure this is delivered through the planning permission, controlled by a restriction on the title of the land.
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The proposal will secure the future of the listed buildings, woodland and open space and public enjoyment of the whole asset. d) Napier University invited bids for the site through its agent. There were a number of bids for the site with Napier University selecting Craighouse Partnership. The Craighouse Partnership bid amounted to £10,000,000 with an additional uplift value, potentially in the region of £3,000,000, dependant upon the quantum of new build. It is not accepted that this is a true value for the site as it reflects a hope value and is not based on Local Development Plan Policy at the time of sale. In instances where the property is in a useable condition it is appropriate to apply a market value to any appraisals. As mentioned previously the applicant has commissioned a valuation of the site to reflect the potential continued use of the buildings. This site valuation of £4,700,000 has been accepted by CEC Economic Development on behalf of Planning. As mentioned previously the revised conservation deficit appraisal is accepted and identifies a deficit of £5,156,078. It is accepted that this arises from the need to secure the future of the asset not the circumstances of the owner or price paid for the site. e) At the time of scheme 2 the applicant submitted very limited information in support of their case that subsidy was unavailable. It was not accepted that the applicant had explored all available sources of funding to secure the future of the asset and the applicant subsequently agreed to apply to Historic Scotland for grant assistance but this has yet to be submitted. The revised financial appraisal assumes a grant of £500,000 which Historic Scotland has indicated is the maximum sum which could be granted to the project.
Residential development on this scale within the City of Edinburgh is required to contribute to the provision of affordable housing and this is secured thought a S75 agreement. The level of contribution is based at 25% of the land value i.e. 25% of £4,700,000 = £1,175,000. The financial appraisal includes a sum for S75 contributions based on education infrastructure impact and securing the future of the woodland as part of the wider asset. There is no contribution to affordable housing and this could be considered to be a form of subsidy from the City of Edinburgh Council. This approach is being pursued for three reasons, these are;
1. The cost of constructing affordable housing on the site to an appropriate design standard is prohibitively expensive, 2. The ongoing maintenance costs for the upkeep of the buildings and the extensive landscaping would be financially unattractive to a affordable housing provider, 3. The requirement for financial contributions for off site provision would require additional new build elements which would unacceptably harm the setting of the listed buildings and the wider asset. The CEC Financial Review (Appendix 2) examines the scenario of including this contribution and estimates that an additional area of 22 500 gross square feet new build development would be required on the site. This additional accommodation could not be suitably located on the site without having an unacceptable level of impact on the historic asset.
It is therefore reasonable to say that the accepted development appraisal assumes a level of subsidy at £500,000 from Historic Scotland and £1,175,000 from the City of
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Edinburgh Council through the relaxation of the affordable housing provision on the basis of an enabling case. f) The requirement to demonstrate that the amount of enabling development is the minimum necessary to secure the future of the place is the same issue as contained in the SPP and assessed above. It is accepted that the development appraisals are correct and that the overall quantum of development represents the minimum to secure the financially sustainable future of the asset while maintaining a viable developer's profit.
The requirement to ensure that the development form minimises harm to other public interests has in part resulted is the extensive revisions which culminate in scheme 3. The extent of the impact is assessed in further detail later in this assessment.
The form of the development has been significantly revised, through negotiation with the applicant, from the scheme 1 proposal. The revisions have been informed not only by guidance from City of Edinburgh Council but also by consultees and third party representations. The most significant changes include removal of the terraced block referred to as Old Craig Grove (scheme 1) from the main area of open space, the removal of the terraced housing referred to as Old Craig Court from the existing car park and to the north of this carpark (scheme 1), the removal of the building referred to as Duncan Villa (scheme 1) between the existing Bevan and South Craig buildings, the removal of the block referred to as Napier Villa (scheme 2) from the existing car park, reduction in size of the block referred to as Burton Villa (scheme 2) and reduced height to the replacement LRC building, referred to as Clouston Villa (scheme 2).
The scheme 3 proposal has far less impact on the asset than the scheme 1 or scheme 2 proposals. It is concluded that the form, location and height of development minimises any detrimental impact on the asset, given the required quantum of development. 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 applicant has submitted detailed methodology, evaluation and scoring of benefits and disbenefits (Enabling Case Report appendices 2 and 3). This takes into account the breadth of impact, ranging from site specific to national, and the magnitude of impact, ranging from none to major. The applicant's findings show an assessed score of 65 for benefits and 27 for disbenefits.
An assessment of benefits and disbenefits has been undertaken by officers based on the Scheme 3 proposals and these are listed below:
The public benefits:
• The sympathetic renovation and use of these nationally important listed buildings.
• The long term sustainable future for these nationally important listed buildings.
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• A land use which is both in keeping with the area and sympathetic to the conversion of the listed buildings.
• The creation of a new desirable place to live and the provision of additional housing.
• The retention of the woodland and open space with continued public access to and enjoyment of these elements.
• The retention of the historic asset and the recognisable 'place' for the enjoyment of the public and future residents.
• Funding and delivery options to maintain the woodland and open space, including continued public access.
• The removal of the bus route will benefit the setting of Old Craig and reinstate the clarity of boundary between the primary public road and secondary nature of the site.
• Reduction in surface water run off will reduce impact on neighbouring land.
• Development will generate employment during the construction period and to a lesser extent through the on-going maintenance.
Given the national importance of these listed buildings, most of which are included on the Buildings at Risk Register, (New Craig being the exception), the range and extent of the benefits identified are considered to be very significant.
The disbenefits
• The composition of the Victorian institutional listed buildings set within a distinct landscape setting will be diminished.
• The character of the Victorian institutional buildings of similar architectural style (with the exception of Old Craig) including their unique landscape setting will be diminished, although planting mitigation will lessen the impact in the long term.
• The quantum of new development required and the resulting impact on the asset.
• The impact the proposed development will have on the setting of the listed buildings, both individually eg. the impact Kings Craig will have on New Craig and the impact West Craig will have on the setting of Queens Craig, and cumulatively on the group as a whole.
• The impact on the AGLV (and designated cSLA).
• Impact on the woodland/landscape through the removal of trees although planting mitigation will lessen the impact in the long term.
• The change in character of the place due to the activities and intensification of its use associated with residential use.
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• The impact on landscape setting through the cumulative impact of the buildings and the infrastructure required to support them.
• Light pollution from additional street lighting and light breakout from buildings
The most significant disbenefit is to the setting of the listed buildings and the damage to the historic asset. The disbenefit on the historic place and the woodland are also significant, however, mitigation measures will reduce this impact. Other disbenefits are relatively moderate.
The assessment concludes that an enabling development is the only means of preventing the loss of the asset and securing its long term future. On balance the significance of the public benefits of the development, critically the long term retention of the listed buildings and the place, for the enjoyment of the public, decisively outweigh the disbenefits of the enabling development and breach of policies. The overriding objective is securing the future of these nationally important buildings. This assessment is made in the knowledge that without this development, the category A listed buildings will remain unoccupied or be used in an unsustainable manner, and with no other likely source of funding will deteriorate and create a greater funding shortfall. b) Setting of Listed Buildings
The Edinburgh City Local Plan Policy ENV3 states that development within the curtilage or affecting the setting of a listed building will be permitted only if not detrimental to the appearance or character of the building, or to its setting.
An assessment on the impact on the setting of the historic assets and place is identified through the Environmental Impact Assessment. A Conservation Plan has also been submitted in support of the application and looks in detail at the buildings and their setting.
Setting is defined in the Scottish Planning Policy as, "... more than the immediate surroundings of a site or a building, and may be related to the function or use of a place, or how it was intended to fit into the landscape of (or) townscape, the view from it or how it can be seen from areas around about, or areas that are important to the protection of the place, site or building"
To assist with the assessment with respect to the impact of change to the setting of the historic assets and the place reference has been made to Historic Scotland's document 'Managing Change in the Historic Environment Setting'.
Setting is described in this document as:
"the way in which the surroundings of a historic asset or place contribute to how it is experienced, understood and appreciated. Monuments, buildings, gardens and settlements were not constructed in isolation. They were often deliberately positioned with reference to the surrounding topography, resources, landscape and other monuments or buildings. These relationships will often have changed through the life of a historic asset or place. This often extends beyond the immediate property boundary of a historic structure into the broader landscape context.'
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The City of Edinburgh has a series of volcanic hills of varying heights and prominence that play an important role in the city landscape, character and setting. The site is located on one of the 'seven hills of Edinburgh' and makes up the north eastern flank of the Easter Craiglockhart Hill. The views to the site form a unique part of the city structure both from a local and city perspective.
Craighouse is a historic place. The 'place' is located on a hill, with outstanding listed buildings 'harmoniously integrated with the landscape' resulting in a place of exceptional natural and built environment. All of the buildings are category A Listed and all, with the exception of Old Craig, use a cohesive architectural language. They benefit from a unique setting due to their location on this volcanic hill. The setting of the buildings to date has remained relatively constant and unaltered. Therefore their layout and spatial pattern on the site and relationship with the landscape setting is equally as important as their individual merit.
Easter Craiglockhart hill has a distinctively rugged character with woodland and outcropping rock and grassland with dense urban development around the base of the hill. The A Listed Sydney Mitchell Hospital Buildings are 'set in superb landscaped hilltop site, still completely unspoiled either by later accretions or more modern buildings' as noted in the Historic Scotland listing note for this group of buildings. Old Craig, also A Listed separately, and the only harled building on the site has individual character and merit.
Craighouse Hospital was designed to make the best of its hillside site. It was designed as a hospital set on a hillside, set back from the city, exclusive and extravagant in its design. The layout of the buildings was carefully considered, set in a relatively open landscape with extensive and impressive views, considered at the time as part of the healing process. The relationship between the hospital buildings is very important with the present character of the villas being "smaller country houses, set informally in the grounds of a palace, each with their own relationship to the topography and to the views," (Conservation Plan - Simpson and Brown). New Craig is by far the dominant building within the group from both within and outwith the site with the other four hospital buildings, Queens Craig, East Craig, Bevan House and South Craig are carefully placed in the landscape to the west, east and south of New Craig. Although, designed as buildings to be viewed in the round, they all have primary entrance elevations and in their layout and spatial relationship with each other, provide a clear distinction between public and private open spaces with each landscaped area around the buildings contributing to the setting and strong unity of the composition of this listed group. A cohesive architectural language and the same building materials are used throughout each of the Sydney Mitchell Hospital Buildings however, each building has been given its own character. For example Bevan is tall and narrow in its design.
The Craighouse Campus is described as "...restorative effects of architecture and landscape", in Gifford's 'The Buildings of Scotland: Edinburgh.' The hillside location provided the opportunity to ensure views were "extensive and impressive", therefore these views both from within the buildings and from the landscape form part of their setting as a group.
The most important city views with respect to setting and how the place is identified within the Edinburgh context are the views from the north, west and east.
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From many city and local views from the north and west the tower of New Craig forms a focal point on the wooded hill, given it is the only building that breaks the treeline, which demonstrates its scale. These views back to the dark wooded hill with New Craig therefore from part of the setting of the group of buildings and identifies Craighouse as a place within the city structure.
The site as viewed from the east, particularly from the adjacent conservation area and from Blackford and the Braids Hills, is easily identifiable as Craighouse. The historic function /use of this site has also played an important part in its current character and setting. A single owner has ensured that the group of buildings and their landscape has not been fragmented. An institutional use on the site has ensured that the site has not been fragmented in terms of land use and that the vehicular movements associated with institutional use have been mainly restricted to the entrance of New Craig from the main road and within the carpark area which is located at the base of the hill away from the listed buildings. Some small service roads exist around the buildings but vehicle moments have been limited and are associated generally with maintenance access. They are read as country or estate roads and critically do not accommodate many car movements.
The development of multiple sites within the group of listed buildings changes their setting both physically and their character and how the spaces around the building are used and occupied particularly with respect to activities associated with residential use.
• New Craig: i) Description
New Craig is the dominant and landmark building on the site and forms part of the group of A Listed Sydney Mitchell Hospital buildings. The positioning of the building on the hilltop site, the spatial relationship with the other listed buildings, and the relationship with the landscape both on and off the site forms part of the setting of New Craig.
New Craig was designed to make the best of its hillside site and exploits views from the site. New Craig was also designed to make a 'remarkable impression' in views towards the site from the north. The impression of New Craig from these views is a confident response to the hillside, one of scale, height and a tower in a romantic architectural style. This confident response to the hillside is complimented by wooded banks of trees which have been left to grow within the recent past and which now contribute to its setting and romantic impression.
The area to the north of New Craig provides wide open views with a more public character and is where the principle entrance to the building is located. The character of this area and the views is part of the setting of this building.
The area to the south of New Craig is informal, private and more rural in character with access drives to secondary service entrances. Significant rooms are located on this south elevation. These look out onto the landscaped area to the south with some distant views towards Bevan House and the trees and landscape beyond. The character and views of this space forms part of the setting of New Craig.
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Approaches to New Craig are also important. In these views New Craig is seen with Old Craig with both buildings forming the focal point of the view. Also, the approaches from both the main entrance and through the lodge entrance allows views of both New Craig with Old Craig and the revealed panoramic view of the site over the open space. This allows the group of buildings and the landscape to be understood and appreciated in their landscape setting.
The view from the footpath going up the hill from Craiglea Place, across the open space affords a view of New Craig and its rural setting and character with the listed building silhouetted against the skyline. ii) Impact
North Craig: The appearance of the wooded hill will be altered with the introduction of this development. This in turn will alter the setting of New Craig when viewed from the north due to the visibility of the new building through the trees, especially in the winter months and at night when lights are on. Its dominance upon the dark wooded hillside will be diminished. New tree planting will help mitigate this impact but only over time.
West Craig: West Craig will alter the distinct views from the north in particular during the winter. Due to its height and design it will be partly visible in the background, rising above Queens Craig. It will interrupt this view and will change the impression New Craig has on this view thus detracting from its setting. The more public, enclosed space created to the front of Kings Craig (see below) will continue through the site and compound the change of character already set up by West Craig. Views from New Craig out over this private garden space and beyond will be lost as a consequence of the proposed development here to the detriment of its setting.
Kings Craig: The scale and mass of this building will change the relationship New Craig has with the landscaped area to the south. It will change the character of this space from an informal, private and more rural space, with open aspects over the landscaping beyond to a more enclosed, public space. This space will facilitate the main vehicular road through the site and the associated traffic movements. Views from the south elevation of New Craig out over this private space and the landscape beyond will be altered with the introduction of built form in this location. This will obstruct these views in part. This will impact on the setting of this listed building to its detriment.
Clouston Villa and Craiglea Place: these buildings do not have a direct impact on the setting of New Craig as individual buildings. However, cumulatively the extent of change the overall development imposes on both the landscape character of the site and the spatial relationship of the existing buildings has a detrimental effect on the setting of this group of A Listed buildings.
Burton Villa: This will change the character of the dark wooded hill to the north of New Craig in views from the north. The character and reading of the hill will be damaged by the proposed loss of trees and the introduction of this building of this mass and scale. The building will be visible through the trees especially at night and during the winter months. Planting mitigation will help reduce this over time, however in the short term, this will impact on the setting of New Craig, again diminishing its dominance on its hillside location. It will also alter the character of the approach to New Craig by
Development Management Sub-Committee – 3 September 2014 Page 20 of 174 12/04007/SCH3 interrupting the view within which New Craig (and Old Craig in the foreground) is the focal point. It will therefore change how New Craig is experienced within the site on the main approach, the perception of it as a focal point will be lost. City views to the east from the main entrance of New Craig and the upper levels of east elevations will be impacted upon by the presence of this development. iii) Summary
The cumulative impact of the proposed new development on the site will have a detrimental impact on the character, appearance and setting of this category A listed building.
• Queens Craig: i) Description
Queens Craig forms part of the group of A Listed Sydney Mitchell Hospital buildings. The south, west and north elevations are designed to be seen with their landscaped backdrops and with the principle entrance to the west. These landscaped backdrops from part of the setting of this listed building. Private garden space was laid out to the south with spectacular city views from the north side of the building, through the mature trees, on the steeply sloping north slopes. A tunnel linked this building to New Craig. Long and low is the best way to describe this building with a two storey pavilion element to the west and single storey to the east.
With its positioning on the dark wooded hillside and relationship with New Craig - it sits on its axis, Queens Craig contributes to the distinctive skyline views from the north and west. New Craig forms the back drop to this elevation therefore forming part of the setting of this building.
Queen's Craig has two designed green spaces, one to the south and one to the west, both of which are formally arranged in relation to Queen's Craig. The formal garden space to the south is intimate and private in character with a small garden pavilion. They are both surrounded to the west and south with a hillside and woodland giving an overall, quiet, more rural character to these spaces. This character forms part of the setting for this building. ii) Impact
North Craig: The proposal will impact on the appearance of the dark wooded hill as seen from the north and the west (Lockarton Crescent). The loss of trees in this location will result in the proposed new building being visible through the woodland, especially after leaf fall and through the winter months and at night. The perception of a dark, undeveloped wooded hill with the silhouette of Queens Craig (and parts of New Craig) will be diminished with the introduction of a building in this location to the detriment of the setting of Queens Craig.
West Craig: West Craig will alter the distinct views from the north due to its height and design. It will rise above this low rise building and as a consequence part of the listed building's recognisable form and silhouette against the wooded hill will be lost from views from the north.
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West Craig will completely alter the existing character of the landscape area to the south of Queens Craig by introducing built form into the space. It will enclose this garden space with a row of town houses thus losing the open landscaped edge of the garden space. The proposed building will front the space with entrances, introducing hard landscaping, increasing pedestrian movement and introducing vehicular movements into this former private garden space. This has a detrimental effect on the setting by both the change in character of the private garden space and the loss of the relationship with the adjacent wooded landscaped hill. The quiet secluded garden space becomes an enclosed more public space to the detriment of the setting of the listed building.
Kings Craig: this development will have a lesser impact on Queens Craig than West Craig, however, it will contribute to the loss of this more private garden space associated with Queen Craig to the detriment of this listed buildings setting.
Clouston Villa, Craiglea Place and Burton Villa do not have a direct impact on the setting of Queens Craig as individual buildings. However, cumulatively the extent of change the overall development imposes on both the landscape character of the site and the spatial relationship of the existing buildings has a detrimental effect on the setting of this group of A Listed buildings. iii) Summary
The cumulative impact of the proposed new buildings referred to as North Craig, West Craig and Kings Craig will have a detrimental impact on the character, appearance and setting of this category A listed building.
• Old Craig: i) Description
Old Craig is the oldest building on the site and it was designed as a fortified house in the countryside with walled gardens. It was designed in a rural open setting and had formal walled policies, with cultivated fields to the east. It could be argued that this historical setting was compromised by the introduction of the Sydney Mitchell hospital buildings.
The current setting is more open than in certain periods of history and the building, although listed separately from the group of Sydney Mitchell buildings, is perceived as part of the group of buildings on the site. The landscape surrounding Old Craig is semi-rural parkland which is generally peaceful, enclosed by mature woodland to the west and with open space to the south. An existing car park which served the former institutional use and access route used by Lothian buses lies to the east. Generally the surrounding landscape is perceived as being remote or set back from the city and Old Craig is viewed from across this wider landscape which forms part of its setting.
On site Old Craig exerts an influence on the quality of the surrounding landscape, due to its unique and attractive qualities. Old Craig is set apart from the other buildings both physically and also visually by its architectural style and colour.
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The arrival experience, from both the main site entrance and from the lodge, is particularly impressive with views of Old Craig forming part of that arrival experience. Historically it would have been the focal point from the main entrance, however, this changed when the Sydney Mitchell hospital buildings were introduced onto the site.
Part of the character of the open space and views from this space are characterised with the visual presence of Old Craig with its backdrop of the woodland edge and former hospital buildings, which is beautiful, unique and instantly recognisable. This gives a very strong sense of place to this part of the hill and an impressive setting to Old Craig.
In views to the north from the open parkland, Old Craig is the main focal point with the city skyline beyond. This key characteristic of the setting is also one of the most sensitive. ii) Impact
Burton Villa: The main area of new development which directly affects the setting of Old Craig is the development located in the woodland where Burton Villa is proposed. This building will dominate the existing view to Old Craig and its backdrop in both on site and off site views removing it as the focal point within these views and the landscape setting. This building will therefore alter the setting and experience of how Old Craig is read within the landscape setting. This is particularly evident when viewed from the open space.
The siting of Burton Villa on the adjacent woodland lowers the quality of the long distant views as this building becomes a focal point, encroaching into the long distance view of Old Craig and parts of the site's unique skyline.
Burton Villa will exert a negative visual influence on the open space, which is intrinsic to the setting of Old Craig. The arrival experience is interrupted by this dominant form which alters the character and open aspect of the current approach to Old Craig.
North Craig, West Craig, Kings Craig , Clouston Villa and Craiglea Place do not have a direct impact on the setting of Old Craig as individual buildings. However, cumulatively the extent of change the overall development imposes on both the landscape character of the site and the spatial relationship of the existing buildings has a detrimental effect on the setting of this group of A Listed buildings. iii) Summary
The impact of the proposed new building referred to as Burton Villa will have a detrimental impact on the character, appearance and setting of this category A listed building.
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• East Craig: i) Description
East Craig was built as a single storey detached hospital specifically for ladies. Its main entrance was to the east although, like Bevan, it was designed as a building to be seen 'in the round'. It is the least elaborate of the group.
Its setting is primarily the spatial pattern between it and Bevan. ii) Impact
The main impact on this building's setting will be the proposed landscaping and infrastructure works. The main access route will pass directly adjacent to it and through the space between it and Bevan. This will introduce increased pedestrian and vehicular movements associated with residential use. The creation of this more public space will diminish the spatial pattern between the listed buildings to the detriment of their setting. The nearest new build development will be Kings Craig, however, planting mitigation will minimise the impact of this in the long term.
North Craig, West Craig, Clouston Villa, Craiglea Place, and Burton Villa do not have a direct impact on the setting of East Craig as individual buildings. However, cumulatively the extent of change the overall development imposes on both the landscape character of the site and the spatial relationship of the existing buildings has a detrimental effect on the setting of this group of A Listed buildings. iii) Summary
The impact of the proposed new infrastructure and associated landscaping will have a detrimental impact on the character, appearance and setting of this category A listed building.
• Lodge: i) Description
From historical maps, the Lodge seems to have always been intended as the entrance point for the Sydney Mitchell Hospital Buildings.
The view from the conservation area through the gates and past the lodge to New Craig and Old Craig, over an area of open semi rural landscape which separates the lodge from the main buildings on the site, is part of the setting of this listed building. ii) Impact
There is a minor impact to the setting of the lodge due to the cumulative impact the proposals have on the character of the site as a whole.
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• Bevan: i) Description
Bevan forms part of the group of A Listed Sydney Mitchell Hospital buildings. The spatial pattern with the other listed buildings and the relationship with the landscape forms part of the setting of the building.
Bevan was carefully located on the hillside to take advantage of the beautiful unbroken panoramic views over the open space to Edinburgh and the Firth of Forth as part of the 'healing experience'. Bevan House, a tall, narrow building with a landscaped backdrop, was designed as a ladies' villa. Although conceived as a building in the round it was designed with a principle entrance elevation with its principal rooms to the east addressing the open space and the panoramic city views. It was connected to New Craig via an underground passage.
It forms the focal point in vista views from Morningside Drive in the Plewlands Conservation Area to the east. Views to Bevan from both the approaches and across the open space show the building in its context within the group of buildings and within the landscape setting. Therefore, both views to and from the building to the east form part of its setting.
Designed to be seen in the round the view of the building in the landscape and on the hillside from the open space south of New Craig reinforces the rural character of this part of the site and the distinct turreted skyline characteristic of this site. When viewed from the east over the open space is forms an integral part of the group of the listed buildings. These views form part of the setting of this building.
Bevan was designed with more private garden spaces to the west and south with its public face to the east. These areas and their different characters form part of the setting of Bevan. ii) Impact
Kings Craig: This building will alter the spatial relationship between Bevan and New Craig by introducing built form into landscaped spaces which have a quiet, more rural character. This space will become more public with hard landscaping and increased pedestrian and traffic movements. New planting, however, will mitigate the impact over time. It will change the spatial pattern and the uninterrupted skyline between Bevan and New Craig, both in city and site views. This building will have a detrimental impact on the setting of this building.
Clouston Villa: The proposed development competes with the listed villas located on the hillside and detracts from the overall grouping of these listed buildings within their landscape setting. This spatial relationship has already been eroded by the existing LRC building, however, the proposed building further erodes this relationship given its scale and massing and detracts from the cohesive composition of the listed buildings, in particular when viewed from the main pedestrian entrance to the site over the open space up towards the ridge where Bevan is sited. It will be visually prominent and will not integrate with the group of listed buildings. This building will have a detrimental impact on the setting of Bevan.
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Burton Villa: This development damages the beautiful panoramic views from Bevan. The scale and mass creates an impenetrable form in this view. The impact on the quality of these views damages the setting of the listed building. Burton Villa changes the character of the approach to the site, however views over the open parkland have been retained which allow Bevan to be read in context with the other buildings on the site.
North Craig, West Craig and Craiglea Place do not have a direct impact on the setting of Queens Craig as individual buildings. However, cumulatively the extent of change the overall development imposes on both the landscape character of the site and the spatial relationship of the existing buildings has a detrimental effect on the setting of this group of A Listed buildings. iii) Summary
The impact of the proposed new buildings referred to as Kings Craig, Clouston Villa and Burton Villa will have a detrimental impact on the character, appearance and setting of this category A listed building.
• South Craig: i) Description
South Craig is part of the group of A listed Sydney Mitchell Hospital buildings. The positioning of the building on the hilltop site, the spatial relationship with the other listed buildings, and the relationship with the landscape both on and off the site forms part of the setting of South Craig.
Views to South Craig and the other listed hospital buildings from other city hills reads as a legible distinct pattern on the wooded hill and forms part of the setting of South Craig. Views to South Craig from the approaches, over the open space and read with the landscape backdrop and the group of other A Listed Buildings also forms part of this building's setting.
Views from the south historically were important and formed part of the setting of this building showing its magnificent architecture against the skyline, however, this aspect of its setting has already been lost with the siting of the LRC Building.
Although it was designed as a building in the round it has a principle public entrance to the east.
It is the highest element of development on the hill with a large external paved entrance space providing panoramic views across the open space to Edinburgh and beyond to the Firth of Forth. Views to this entrance elevation with its wooded backdrop and the panoramic views from this entrance area, across the open space to the city beyond, all form part of the setting of this building.
South Craig was designed with private lawns to the south and north. These spaces also are part of the setting of the building.
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Clouston Villa: This development alters the way in which both Bevan and South Craig are read on the hillside and detracts from the overall grouping of these listed villas within their landscape setting. The spatial relationship and setting of these buildings on the hill has already been eroded by the LRC building. The scale, mass, height and design of the proposed building further erodes the spatial pattern and the cohesive composition of the listed buildings, in particular, when viewed from the entrance over the open space, and also from the city views from the east. Clouston Villa has introduced substantial built form which does not integrate with the existing group. This building therefore affects the setting of South Craig and the reading of the group of listed buildings.
It impacts on the quality of the views from the main public rooms to the south and impacts on views to its principle elevation resulting in a built form which dominates South Craig and erodes the landscape setting of this building.
Burton Villa : This development will interrupt the designed views from South Craig. It will lower the level of the quality of the panoramic view, creating a new form that impacts on the view and disrupts the existing green edge and the city landscape beyond.
Burton Villa will also damage the beautiful panoramic views to the listed buildings and the character of the approaches to the listed buildings, however views over the open parkland have been retained which allow South Craig to be read in context with the other buildings on the site.
Burton will therefore affect the setting of this building.
North Craig, West Craig, Kings Craig and Craiglea Place do not have a direct impact on the setting of Queens Craig as individual buildings. However, cumulatively the extent of change the overall development imposes on both the landscape character of the site and the spatial relationship of the existing buildings has a detrimental effect on the setting of this group of A Listed buildings. iii) Summary
The impact of the proposed new buildings referred to as Clouston Villa and Burton Villa will have a detrimental impact on the character, appearance and setting of this category A listed building.
Conclusion
As described above, the setting of the site is complex. The site's former use, the relationship the existing buildings have with both the surrounding landscape and with each other, and both views to and from the site all contribute to the setting of Old Craig and this group of former hospital buildings which collectively create this historic place.
The extent and form of the proposed changes will alter how the site is understood and appreciated. The introduction of new development on multiple plots onto the site will significantly alter the unique appearance and character of the setting of this group of
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The proposals are therefore contrary to Policy Env 3 of the local plan.
c) Character & Appearance of the Conservation Area
Policy Env 6 of the local plan seeks to preserve and enhance the special character and appearance of conservation areas. Development should be consistent with the relevant conservation area character appraisal. The site lies within the Craiglockhart Conservation Area and directly adjoins the Plewlands Conservation Area. The Craiglockhart Hills Conservation Area Character Appraisal, in its overview, states that:
"The essential character of the Craiglockhart Hills Conservation Area derives from its significant cluster of Victorian institutions... within a very high quality landscape and topographic setting... The area encompasses a mosaic of habitats which are exceptional in a city environment, and provide extensive panoramic views of Edinburgh and across to the Firth of Forth and to the hills beyond. 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 area... The Craighouse complex has a strong unity of composition derived from the inter relationship of buildings, woodlands, open spaces and views over the city'.
The proposal to change the use of one of these Victorian institutions to residential will, in itself, alter the character of the site with the introduction of activities associated with residential use. It will introduce a level of new development into the landscape setting of these existing institutional buildings. As a consequence of this, the panoramic city views enjoyed to and from the site will be altered. The new development will sit within the landscape prominently and as such will alter this existing landscape setting of the existing buildings. The extent of the visual effect will reduce over time given the proposed planting mitigation, however, the character is weakened as the balance between landscape and buildings will be altered permanently. The proposals will damage the essential characteristic of the high quality landscape setting of this part of the conservation area.
The character appraisal goes on to identify the essential characteristics of the conservation area. The Spatial Structure and Townscape are described as follows:
'In terms of the overall city context this conservation area is one of the seven groups of hills which gives great distinctness to the city. They are part of the basic structure and character of the city. The hills give legibility and identity to the city and its component parts. They provide outstanding backgrounds, settings, landmarks and views in themselves and over a wide extent of the city and beyond... The Conservation Area has sharp, contrasting and strong edges in the form of steep slopes, mature avenues and belts of trees, a pond and the profiles and skylines of existing and former institutional buildings... The original health institutional uses were thought to require physical separation from city neighbourhoods.
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'A major three dimensional element in town structure both locally and city wide...' this describes an essential characteristic where the hill provides a backdrop and setting to other areas in the city. The character of the wooded hill with open spaces and the impressive listed buildings placed in a distinct pattern in the landscape is instantly recognisable from other parts of the city. In the short term the effect of the development will alter the existing landscape spatial pattern and extend development up the lower slopes of the area to the front of Old Craig. The impact of this will lessen however over time due to new tree planting.
'A major visual recreational amenity surrounded by residential areas'... this essential characteristic is appreciated at both a city and local context. The site is recognised for its high recreational value given its beauty and unique qualities. It is widely used by members of the public for a variety of uses and is considered an exceptional place. The change of use along with the new build development will impact on these qualities and the open aspect of the site which are key to providing the strong sense of place that people are attracted to visit. The nature of how the 'place' is used and the activities associated with the proposed development will alter the current perception of the site as a recreational destination and thus will impact on this particular characteristic of the conservation area.
'Landmark buildings harmoniously integrated with the landscape...' The 'landmark building' in this part of the conservation area is New Craig, however, all the buildings at Craighouse "form a homogeneous group" set within their landscape setting. The cumulative effect of the new development will interrupt the harmony of the existing listed buildings and will alter the strong relationship these landmark buildings have with their surrounding landscape to the detriment of this characteristic.
Development well integrated into the structural landscape...' The existing buildings on the site are well integrated into the structural landscape, (those spaces created between the planting). The new planting has been designed to try and sympathetically integrate the quantum of new development onto the site. Some elements of the new development will overtime integrate into the structural landscape however, other parts will not. There is a sense of maturity within the site. The existing mature trees create a strong sense of place and solidity that is comforting and relaxing. This is part of the landscape character and setting of the existing buildings. The proposed development plans to introduce many young trees with appropriate supports and as such this will alter this characteristic. This will be recovered as the new trees mature, however, this will not be for a number of years.
This site is currently detached from the adjacent urban form given the desire for these institutional buildings to have physical separation when they were originally designed. This contributes to the legibility of the hill and forms the unique character of a wooded hill with open slopes and purposely located buildings of quality. Craighouse Road forms a frontage to the conservation area. This frontage delineates between the semi- rural parkland of Craighouse campus and the adjacent urban form. The distinction between the two environments contributes to the townscape character of this conservation area. The scale and mass of the proposed Burton Villa will erode this character. This introduces a building to the north east corner changing the relationship between the suburban form and this more rural space where further development of such a scale and massing was not intended.
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The architectural character of Craighouse is described as follows:
"The Craighouse complex has a strong unity of composition derived from the inter relationship of buildings, woodlands, open spaces and views over the city. Areas of woodland to the south west provide a backcloth to the buildings, the setting of which is further enhanced by varied specimen trees which provide a sense of scale."... The buildings form a homogeneous group round the old mansion, as they are closely related in design, layout and materials.
The development will impact on this key characteristic. It will alter this "unity of composition" between the 'family' of high quality buildings and their setting within a mix of wooded and open slopes with the introduction of the new build elements, in particular Burton Villa, West Craig, Kings Craig and Clouston Villa. In the long term the proposed tree planting will help unify the site but the original composition will not be recovered.
The introduction of the new build elements will change how the existing group of buildings will be read and understood. In particular the four larger blocks, which are not of a similar design and 'family' will compete with the existing group, and therefore this characteristic will be lost.
The proposals include the reduction of the existing car park and the removal of the bus turning area. The loss of these hard surfaced elements and the introduction of soft landscaping will contribute to enhancing the conservation area.
Conclusion
The proposed change of use and intensification of development will change the character and appearance of this part of the conservation area, however, the scale of the change and the subsequent impact on the conservation area, however, varies. Some characteristics are damaged but not lost. The wooded hill, in the long term, will be strengthened by the proposed tree planting mitigation.
The proposals will, however, introduce changes that will alter the existing balance between the landscape and built form. Notwithstanding the new development will over time, due to the proposed planting integrate more into the landscape setting, the cumulative effect of development will exert a strong influence over the existing landscape which will weaken the high quality landscape and topographic setting of the site. Perceptions of the site will be altered by the proposed change of use. The recreation value will be secured in the long term by the retention of the public open space and extension of the Local Nature Reserve. The strength of the relationship between this existing family of buildings with their unique setting will be weakened however and the distinct physical separation between the more rural hillside and the urban form at its base will be diminished. The unity of composition on the site will be diminished and the cumulative effect of the existing buildings and the new buildings will result in built form becoming more dominant within the landscape.
As the development does not preserve or enhance the character and appearance of the Craiglockhart Hills Conservation Area and is therefore contrary to ENV 6.
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Policy Des 1 (Design Quality and Context), of the Edinburgh City Local Plan states that 'planning permission will be granted for development where it is demonstrated that the proposal will create or contribute towards a high quality, sustainable living or working environment. Design should be based on an overall design concept that draws upon positive characteristics of the surrounding area to create or reinforce a sense of place, security and vitality. 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.'
In addition, Policy Des 3 of the local plan (Development Design) only permits development which satisfies a number of detailed design criteria. It states that development should 'have a positive impact on its setting, having regard to the positioning of buildings on the site, their height, scale and form, materials and detailing, wider townscape and landscape impacts and impacts on views.'
The proposed masterplan has evolved through thorough site analysis and extensive consultation and has been through several iterations prior to the current scheme. A major influence which has informed the masterplan process for this site is the enabling case argument and the quantum of new development required to secure the future of the category A listed buildings.
The masterplan is based on the concept of 'Pavilions in the Park'. The new buildings all take the form of linear blocks, with the exception of the replacement LRC building which is more of a villa form (Clouston Villa). While the concept of pavilions in the park is an appropriate concept the insertion of sizeable residential blocks and associated infrastructure, unlike previous development associated with its institutional use, will permanently change this clearly recognisable special place.
The new buildings have been designed as a 'family' of buildings which will be easily recognisable within the context of the existing listed buildings. Although they retain the collegiate form which is characteristic of the site, they will clearly be distinct and not part of the homogeneous group of listed buildings. The introduction of Kings Craig and West Craig, in particular, disrupt the spatial pattern of the existing buildings within their landscape setting. They set up their own pattern and relationship on the site. Cumulatively, the new buildings as a group, impose their own presence on the site due to their height, mass and scale and alter the relationship the listed buildings have with their landscape setting by changing the balance of built form to landscape on the site. This is outlined in more detail in assessment b) and c).
The masterplan approach retains the woodland as an extension to the LNR and also includes the retention of the public open space.
These contemporary buildings will all be finished in high quality materials with natural stone to principal elevations and timber cladding to the less prominent elevations that overlook the existing woodland. Roof areas will be clad in either natural slate or zinc, with glass, timber and metals finishes, all in keeping with the more traditional context. The design of the buildings themselves is of a high quality and appropriate to the parkland setting.
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The design strategy for the site regarding garden space is to encourage the use of the communal open space and woodland, which in turn will reinforce the site's parkland setting. Private garden space is limited to small gardens and roof terraces. This is to ensure the limited fragmentation of the landscape design of the site as whole.
The proposed quantum of development for the site will generate vehicle movements associated with 145 residential units. To accommodate these movements a new road and footway network and parking areas has been designed as part of the masterplan for the site. The character of the new road has been designed as a parkland road and where possible the existing road and network of paths have been used and/or adapted/upgraded to help to minimise the impact on the landscape. Parking for the residential units is generally contained in landscaped parking courts with some underground parking below Clouston Villa. This has been designed to minimise the impact on the landscape. The design for the vehicular movements forms part of the overall landscape masterplan for the site and forms a cohesive design approach for the site.
Part of the character of the existing site is quiet parkland with few vehicular movements particularly to areas west of the existing main carpark. Napier University, through their occupation of the site, increased traffic movements but concentrated the car parking in the lower car park. The proposed change of use and proposed quantum of new development will significantly change the character by introducing increased vehicular movements which will be dispersed throughout the site. This, in turn will increase activity and noise, which will further contribute to the loss of the semi-private landscaped setting, in particular of New Craig and Queens Craig. It is recognised that the proposals have been designed to minimise the impact of vehicular movements and parking further up the hill adjacent to the other listed villas (Bevan and South Craig).
The existing pedestrian routes through the site are generally maintained and where appropriate the existing surfaces will be upgraded or resurfaced. Access through Craiglea Place to the Lodge House and to the summit of Easter Craiglockhart hill will be retained. The pedestrian route to the nature reserve on the west of the site remains although the experience and character of this route will change with the insertion of the residential blocks of West Craig and Kings Craig and the road infrastructure into the landscape.
The landscape of the site in its current form is the result of incremental changes and in part to it not being formally managed. The planting design for this scheme has been developed in response to the need to screen the development, safeguard key landscape characteristics, incorporate flooding requirements and create a coherent unified approach to the landscape design. It has also had to respond to the historical elements that have been present on the site in the past. As such it is a robust and logical approach.
The proposals extend the native planting in both the tree planting specification and the grassland areas, which will create a more biodiverse site in the future. The planting specified varies in size, which, given its location and the conditions on site, is a sensible response. This will increase the chance of a robust and age diverse landscape in the future. There is a requirement to screen Clouston Villa and link the new planting together. This will introduce an avenue of trees to the front of Bevan and South Craig which will reduce the visual influence these buildings have on the open
Development Management Sub-Committee – 3 September 2014 Page 32 of 174 12/04007/SCH3 green space. However, as it reinstates a historic feature and provides unity to the site, it is acceptable. The proposals also include accent planting and more exotic plants to highlight certain areas and provide visual interest close to the buildings while maintaining a parkland character. Further planting details will be required and an appropriate condition is recommended.
The hardworks details proposed are of a high quality and are appropriate to this site.
The proposed loss of such a significant number of trees that are worthy of retention is not supported and contrary to policy, this is discussed in detail in assessment f).
In September 2011, pre application proposals were presented to The Edinburgh Urban Design Panel. The EUDP concluded that for it to be considered an Enabling Case it was vital that a sound and credible financial appraisal be put forward. Any enabling development would have to be phased along with the redevelopment of the listed buildings. The site should be considered as a whole with landscape and access improvements implemented at the same time. All new build should be of the highest architectural quality and should be that minimum necessary to enable the reuse of the listed buildings. The strategy for the location of the new buildings was considered reasonable, although they identified areas which they considered required closer examination, the south east development area and Old Craig. It was recognised that the proposals were at an early stage, however, the approach was commended and they encouraged the same level of aspiration to be carried through the design process. It was considered that it was very important that there would be no adverse impacts on the setting of the listed buildings and that the quality of the public access in and around the site be maintained.
The proposed scheme has taken cognisance of the comments made at the EUDP during the early stages of the design process. A masterplan approach has been adopted for an enabling development supported by a fully appraised financial case. Development to the south east of the site has been omitted from the scheme and a more sensitive design has been proposed with regard to Old Craig. Public access in and around the site will be retained.
The pre-application proposals were also presented to Architecture and Design Scotland as a Locally Significant Project through their Design Forum Programme in 2012. There was a site visit and four workshops. The conclusion of this process was that the proposals were rated as 'category 2 - well considered - supported, subject to the amendments discussed. These included revisions to the housing layout referred to as Old Craig Grove (scheme 1), adjusted extent/layout of houses at Old Craig Court (scheme 1) to include consideration of a more structured terrace/park interface, a redesigned more direct and stronger gateway and route into the park from the Lodge house, development of the public realm detail and 'collegiate' courtyards between buildings, a more subtle 'collegiate' approach to private boundaries, minimising tree planting around the new park, a review of the block referred to as Duncan Villa (scheme 1) and the development of the modelling of both hilltop buildings.
The proposed scheme also reflects the comments made by A&DS. The current proposals are significantly different from those presented to A&DS. Elements that were identified to be amended have been omitted from the current scheme, (Old Craig Grove, Old Craig Court and Duncan Villa) which have addressed concerns regarding
Development Management Sub-Committee – 3 September 2014 Page 33 of 174 12/04007/SCH3 the park interface. The Lodge House pedestrian access has been retained and the proposals endeavour to take a 'collegiate' form with the introduction of the individual blocks within the site. The open space (park) will be retained with planting restricted to the boundaries of it. The hilltop buildings (West Craig and Kings Craig) are significantly different from the 'pin wheel' design presented during the initial design stage.
Conclusion
In summary, the design concept is appropriate however the proposed quantum of development will change the special character of the site. The proposals will change the site to a place of more general character, with high quality residential buildings set within attractive parkland. The existing unique character of one of Edinburgh's seven hills will be diminished. It will detract from this recognisable place of outstanding natural and built environment by changing the balance of the landscape to buildings. The planting proposals, in the long term, will mitigate some, but not all, of the impact of the development. Notwithstanding the planting proposals present a robust, sensible response given the level of new development proposed on the site, the proposals will introduce built form which is not sympathetic to its context by virtue of its quantum, height and siting. Through the application process, in consultation with key stakeholders and the community, the proposals have been significantly revised to reduce the impact upon the many important characteristics of the site and surrounding area. It is accepted that the proposal represents the minimum level of change to the characteristics of the site given the particular requirements of this enabling case. While the design concept and quality of the new buildings are appropriate, the quantum of development will not have a positive impact on the setting of the listed buildings. As such the proposals are contrary to local plan policies in respect of design. e) Landscape character and views
The proposal was submitted with an accompanying Environmental Impact Assessment. This examines the impact of the development on both the landscape character of the city and the site and separately on the visual amenity of the city and the site. A number of viewpoint locations were identified both on and off site which included views from sensitive locations. Photomontages and wirelines have been created to assess the visual impacts of the proposed development.
The City of Edinburgh has a series of volcanic hills of varying heights and prominence, each with its own unique characteristics. They play an important role in the city landscape character and setting. These hills are part of the setting of the World Heritage Site. The World Heritage Site Management Plan states that "the main objective outside the World Heritage boundary is to protect the iconic skyline, key views in and out of the site as well as its setting."
Local Plan Policy Env 1 - The World Heritage Site, states... "Development which would harm the qualities which justified the inscription of the Old and New Towns of Edinburgh as a World Heritage Site or would have detrimental impact on the Site's setting will not be permitted." The text further explains that "setting may include sites in the immediate vicinity, viewpoints identified in the key views study and prominent landscape features throughout the city."
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Policy Des 3 states that new development should "have a positive effect on its setting, having regard to the positioning of buildings on the site, their height, scale and form, materials and detailing, wider townscape and landscape impacts and impacts on the views."
Policy Des 10 - Tall buildings, states that... "Proposals for buildings that rise above the prevailing building height..." should not adversely "impact on important views of landmark buildings, the historic skyline or landscape features or the landscape setting of the city."
Policy Env 11 - Landscape Quality states that planning permission will not be granted for development that "would damage or detract from the overall character and appearance of AGLVs..."
The Edinburgh Design Guidance states that new development should "reinforce its surroundings by conserving and enhancing the character and appearance of the landscape and townscape; including protecting the city skyline and locally important views"
Compliance with the above policies has been tested by analyzing the character and views in the following sections.
City wide character
The site is located on Easter Craiglockhart Hill. This is part of an area designated as an Area of Great Landscape Value (AGLV) which has recently been designated as a proposed Special Landscape Area (cSLA 11). The description of the Craiglockhart SLA states that:
'The Craiglockhart Hills have an intimate quality as twin, distinctive, small scale urban hills... Characterised by steep slopes, woodland scrub, and exposed rock, the hills contribute to the local setting and identity, forming a landmark in south - west Edinburgh... the hills offer panoramic views across the city and the Firth of Forth... In addition to providing a focal point for local views, the cSLA is visible from the city's hills.'
It states that the hills have strong cultural connections and mentions 16th century Old Craighouse, its use as the former Royal Edinburgh Asylum and more recently its institutional use associated with Napier University. These architecturally impressive buildings are set within this rural landscape context, in a recognisable pattern and form part of the unique character of the hills. Urban development is around the base of the hill.
The hills are also considered one of the 'seven hills' of Edinburgh and these types of features, although typical landscape features in Lothian and Fife, are quite unique in an urban context.
The pressures on the landscape integrity of the cSLA are given in the description. These include inappropriate development affecting the appreciation of the historic buildings and the cumulative effects of development upon visual amenity and landscape character.
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The site itself is on the lower slopes of Easter Craiglockhart, however the gradients on site remain significant. It is semi-rural parkland with a mature wooded edge of varying depths and a large open grassed space to the east. Six category A listed buildings have been carefully placed in a reversed L- shape configuration on the higher part of the open space and around the hillside, away from the city. The Learning Resource Centre (LRC), a modern addition, is located at the furthest point up the hill. The lower slopes therefore remain undeveloped.
New Craig is currently the dominant building on the site. On the edge of the open green space are a grouping of villas, (East Craig, Bevan and South Craig), which are of a smaller scale and massing. Although different architecturally, Old Craig also forms part of this group in terms of its scale and mass. All the other buildings, including New Craig and Queens Craig, are designed in a similar architectural style. The overall architectural style of these buildings is one of elegance, beauty and extravagance. The historic buildings combined with the mature landscape, create a sense of romance to the site. Elegant chimneys and towers and mature trees creates a unique wooded hill, wooded ridges and skyline. There is a harmonious balance between the landscape and the buildings. The effect of the overall design is very coherent. The only exception is the LRC building. Even though its scale and mass are not damaging to the rest of the group, poor material choice and form and its location means it detracts from the overall character.
The impact on the overall city wide landscape character
At a city wide scale the wooded character of the hill will be maintained. Extensive tree planting has been proposed by the applicant (700 trees) which will strengthen this characteristic in the long term. The large open amenity space will also remain undeveloped and in keeping with the existing landscape character of the site.
The institutional /campus style of buildings in a parkland will also remain as will some open space between the buildings. However, the balance between the buildings and the landscape will alter as a consequence of the proposed new buildings and tree planting, therefore altering the composition of the original hospital buildings to the detriment of the overall character.
The dominance of New Craig will be diminished by the new development from a city wide perspective due to the number of large buildings proposed. The replacement building on the LRC site, Clouston Villa reflects the siting of the existing pattern of buildings on the hillside, however this building is not in keeping with the scale and mass of the adjacent villa buildings, which is detrimental to the character and from the north affects the wooded ridge characteristic. The location, scale and mass of Burton Villa is also uncharacteristic of this undeveloped lower slope and thus detrimental to the character.
Burton Villa will not encroach on the wooded skyline from the north and maintains this characteristic. The building will however, create a link between the more urban development at the base of the hill and the existing buildings. North Craig also creates development further down the wooded hillside. This alters this recognisable characteristic of the adjoining suburban development being restricted to the base of the hill.
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From the south of the site, the character of the landscape around the site and the site itself is experienced as a rural landscape. The lights from Clouston Villa will be visible in the winter months through the trees on the wooded ridge, altering this rural character, however, in the summer months the rural experience will remain.
In summary, a key part of the character, at a city wide perspective, is the recognisable low wooded hill and the large, open, grassed amenity area, neither of which will be lost. However, some of the other unique characteristics of the site will be altered to their detriment. The relationship between the existing landscape and the limited quantum of unique built form, will change with the introduction of new build elements of such scale and massing.
Character of the site
The landscape character of the site today is influenced by the historic development.
This is described in the 'Edinburgh Survey of Gardens and Designed Landscapes' November 2009. The landscape of Old Craig included open tree lined fields and estate walls with some formal gardens to the south of the house. Some sense of this landscape is evident in the rig and furrow within the original fields that is now in the open space.
The hospital buildings were introduced into this landscape and were set apart from one another in an institutional/campus style layout with landscape backdrops and open landscape between each building. The landscape was specifically chosen and the buildings were spaced carefully, designed to be set within a particular semi-rural parkland landscape which in turn was designed to respond to the needs of the hospital environment providing a venue for therapy, through visual stimulation, exercise and relaxation.
The landscape of the hospital was developed to achieve a setting resembling a country house. Many elements of the landscape remains including the informal perimeter footpaths, large open space, remnants of the orchard, and the woodland. The majority of spatial characteristics were maintained when Napier University occupied the site. The woodland further expanded from the early hospital landscape layout throughout the time that the hospital and Napier University occupied the site and now creates the mature woodland and tree belts that form the boundaries. The informal network of footpaths is well used and includes a footpath to the summit of Easter Craiglockhart Hill from Craiglea Place. The historic buildings sit harmoniously with this historic parkland.
The dominance of New Craig remains today and the recognisable scale of the villas and Old Craig and Queens Craig's subservient size creates a unique and recognisable character on site. The space between and around the buildings is an important aspect of this character. The balance of the landscape and the buildings maintains the semi- rural parkland character of the site.
There is a sense of tranquillity away from the main entrance and a strong sense of antiquity and romance throughout the site due to the location, design of the historic buildings and landscape. Some of these trees and shrubs are exotics. The LRC building, car parking, signs etc. associated with Napier University do affect this characteristic but only to a limited extent.
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The woodland and trees create a green edge around all the perimeter of the site and provide a strong sense of enclosure.
There is a more sheltered, enclosed, rural area in the south part of the site around New Craig and Queens Craig with important mature specimen trees. The area is enclosed by hillside and woodland.
In contrast there is a more open and parkland character in the area with Old Craig and the existing villas (East Craig, Bevan and South Craig). Long expansive views from the open space create a sense of openness even though the space is surrounded by trees and woodland. The open space has a strong relationship with Bevan and South Craig.
On site the area at Craiglea Place is perceived as a more enclosed corner almost separate to the main parkland area. It also has a parkland character.
Impact on the character of the site
The quantum of development and associated infrastructure and the cumulative effect this has on the site will alter the historic, semi-rural parkland characteristics. The historic buildings will no longer be the overall dominant built form on the site and the balance and composition between the landscape and the built form will alter. Instead, the modern development, including the roads and lighting, will exert a strong influence on the site weakening the existing unique historic, almost romantic character and affecting the existing composition. Whilst the first effect will be mitigated with time as the modern development is screened, the change in composition will be permanent. This is detrimental to the existing character of the site.
The change of use is likely to affect the tranquilly particularly at certain times of the day due to the introduction of traffic movements further into the site.
The proposals, however include the transfer of the existing woodland to Council ownership and its inclusion within the Local Nature Reserve. They also include the retention of the existing area of public open space which will contribute to retaining the site's character.
The introduction of West Craig and Kings Craig will impact on the landscape setting and alters the character of the area around New Craig and Queens Craig. The area becomes enclosed with built form as opposed to being enclosed with trees and landform, altering a recognisable characteristic. The new development will exert a strong influence over the space due to its height and mass as it forms a new edge and partially encloses the area. This will alter the rural and historic character of that part of the site. This is partially mitigated by maintaining some specimen mature trees. However, this creates a new character for this area which is contrary to policy. In a similar manner Kings Craig affects the character of the area to the south of New Craig.
The open space on the site remains free from development and therefore maintains this important characteristic. The rig and furrow features are protected. The relationship the open space has with Bevan and South Craig will alter as the planting will screen the historic buildings as well as screening the proposed Clouston Villa.
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The loss of mature trees to facilitate the development as described in c) trees and biodiversity, is contrary to policy, however there are many trees being planted as mitigation. In the long term the numerous young trees and the maintenance plan will strengthen the woodland and perimeter planting. An appropriate condition is recommended to ensure this is implemented.
The development at Craiglea Place will move the parkland character towards a more formal built up character but the scale of the development means that the parkland characteristic is still dominant.
In summary, whilst many of the characteristics of the landscape character remain the scale and height and quantum of the built proposals and associated infrastructure will exert a strong influence on the overall character and change it to its detriment. In contrast the woodland planting and maintenance proposals will in general terms strengthen aspects of the character, although only in the long term.
City Views from the east to the site:
The topography of the site allows the buildings and the landscape to be appreciated sequentially and from many viewpoints across the city. The views from the east are all highly sensitive, as they are from areas that are well used by the public and are tourist attractions.
There will be a slight adverse impact in the short term from Arthur's Seat (EIA Viewpoint 2), however this will lessen as the proposed tree planting matures. From Edinburgh Castle (EIA Viewpoint 3b) (protected view C1d) the most obvious change will be the introduction of Clouston Villa. It will sit at the level of the treetops and its mass will be seen together with South Craig. Its flat roof will be uncharacteristic within the context of the site and affect the skyline. The proposed tree planting, once matured will lessen the impact of Clouston Villa in the long term but the skyline effects, although small, are likely to remain.
From Blackford Hill (EIA Viewpoint 5) the views are distinctive and attractive. The site provides a focal point when viewing the wider landscape and townscape of the city from Blackford Hill which is also an Area of Great Landscape Value and proposed cSLA. This view of the site affords unique qualities, displaying the limited number of buildings and the green space between them and the dominance of existing woodland.
Until the proposed tree planting is well established West Craig and Kings Craig will be visible. Cumulatively they will be read together and will alter the spatial pattern and the landscape space between New Craig and Bevan. Clouston Villa is sited higher up the ridge and will be higher than South Craig which lies adjacent. Clouston Villa will be as prominent in this view as the existing listed buildings and as such will have a detrimental impact. In the long term, however, the proposed planting will screen the new development in the summer months, although, it will also unfortunately partially screen the existing buildings which contribute to the quality of this view. After leaf fall the buildings will remain partially visible through the trees which will be detrimental to this view.
From the Braid Hills (EIA Viewpoint 4) (part of protected view S8d) - one characteristic is the distinct separation of the existing listed buildings from the surrounding urban
Development Management Sub-Committee – 3 September 2014 Page 39 of 174 12/04007/SCH3 form. Old Craig is seen as a unique 'pink gem', contrasting with the surrounding 'green woodland'. Burton Villa, due to its footprint and scale results in the development of the lower slope and thus unfortunately diminishes this distinct separation. This will be more apparent after leaf fall. It will also reduce the prominence of Old Craig, all to the detriment of this view. The retained trees on the eastern boundary and the proposed tree planting, in the long term will help mitigate this impact.
City Views from the north
From the school athletic grounds (EIA Viewpoint 10) (Craiglockhart Hill CACA View) the tower at New Craig sits prominently above the trees on the skyline. The new development sits below the top of the wooded skyline. Part of West Craig is likely to be visible above Queens Craig, particularly through the winter months as well as part of North Craig. The main impact will be in the winter months due to the lights of Burton Villa, West Craig and North Craig affecting the current 'dark wooded hillside'. In the long term the woodland management will reduce this impact but will not completely remove it.
The view from Colinton Road (EIA Viewpoint 18) will be impacted upon in the same manner. Following leaf fall, in the winter months, the lights from the development will be visible. From this view part of the roofscape of West Craig will be visible, again in particular within winter. The materials and form of the buildings specified should reduce the impact however the existing recognisable iconic view will be altered to its detriment.
Similarly from Lockharton Crescent (EIA Viewpoint 17) night time lights of North Craig will impact on the view extending the perception of development on the hill. It is likely that some parts of the development will be visible in autumn after leaf fall but the impact will be minimal.
City Views from the south, south/west
The view from Glenlockhart Road (EIA Viewpoint 25 Rev B) includes the existing golf course in the foreground with the wooded ridge beyond and with the city and Arthur's Seat in the background. In the summer the development is likely to be screened. However after leaf fall lights from Clouston Villa will be visible through the trees. The impact is likely to be slight. From the top of Wester Craiglockhart Hill (EIA Viewpoint 15) (part of protected view S4d) the view is currently dominated by a rural foreground and focuses on Arthur's Seat. In the centre of the view lining up with Arthurs Seat is the location of Clouston Villa. The eye is drawn to this location due to the high point on Arthur's Seat. When the trees are in leaf Clouston Villa will be screened but after leaf fall, in winter, lights will be just perceptible, altering the rural character of the view in the foreground.
In summary, there are impacts on the city views, however, these vary in significance. The impact on these views will be more apparent after leaf fall. In views from the north the lights of the development will be seen through the trees and to a lesser extent from the south. The greatest impacts that reduce the quality of the views lie in views from the east and south east due to the volume of development as this will alter the composition of the views that are currently recognisable and attractive. In the long term these effects will be reduced however some unique qualities will be diminished.
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Views from the site
Views from the site to the city are part of the way the city is perceived and appreciated and form part of the character of both the AGLV and candidate SLA.
Views from the site to the north
Views to the north over to the city are experienced through the trees from the northern part of the site and over the tree tops from the north side of New Craig. North Craig will be seen in some of these views and there will be a loss of trees due to this development. The scale and extent of new development creates a new foreground but will be less damaging than the effect of the new development in other areas of the site. Views to the north will therefore not be significantly impacted upon.
Views from the site to the East (EIA Viewpoint 1, 2)
Views to the east, to the city landscape, are a key characteristic of this site. They look over the open space towards the city, the Castle, Salisbury Crags and the Firth of Forth, Arthurs Seat and Blackford Hill. These are very beautiful vistas. The eye is drawn to the cityscape beyond the site and in some places Old Craig provides a beautiful focal point. Further down the hill the eye is drawn to Arthur's Seat. Burton Villa will not obscure any part of this cityscape but will establish another focal point which will not positively contribute to this view, however, once the new screen planting is established, the new development will have less of an impact on this view.
Views within the site
At the entrance (EIA Viewpoint 11) at Craiglea Place the view to the mature shrubbery adjacent to the existing housing will be altered and the introduction of the contemporary development will replace the landscape setting. The grassed area will be replaced by hard standing resulting in the loss of this more rural, parkland perception. Further into the site (EIA Viewpoint 10), within this view up the hill and along the right of way, the skyline of the view will remain unchanged. Clouston Villa will initially be visible however, once the new planting has matured, within the summer months, the building will be screened. The view of Burton Villa (EIA Viewpoint 12) approached from Craiglea Place, will alter the wooded edge to the lower part of the site. There are proposals for screen planting in this area also which will, in time screen the building. Kings Craig is also visible in this view and links development between New Craig and Bevan. This damages this view as the buildings no longer sit separately within the landscape. Screen planting will mitigate this impact to a degree but this will be in the long term as the height of Kings Craig will require mature trees to effectively screen it.
The view westwards from the main entrance will be altered. The eye is drawn up to the top of the building line to Clouston Villa. The scale of this building is greater than South Craig or Bevan as seen from this view and it does not compliment these two listed buildings. As it is at the top of the ridge it becomes the focal point of the view. The flat roof will be visible for many years which is uncharacteristic of the roofscape amongst the trees currently seen on site. Screen planting will help mitigate this impact and in the long term all the planting will partly screen the ridge buildings and the impact of Clouston Villa will be reduced. However, despite careful selection of materials and
Development Management Sub-Committee – 3 September 2014 Page 41 of 174 12/04007/SCH3 simple building design the volume of Clouston Villa will exert a visual dominance in this view that currently does not exist. This effect will be more apparent after leaf fall. This is detrimental to this view. Kings Craig is also visible in this view. Its presence is not a positive contribution to the view but screening will be more quickly effective from this viewpoint. The open aspect and view of the open space will be retained. This is a key characteristic of the view.
In summary, the views on the site will be altered and the quality of the views changed. In some places this is damaging to the existing high scenic quality of the site. In the long term the planting will provide screening reducing the initial impact but certain unique qualities will be damaged. The effect on visual amenity on site will be greater than at a city wide level.
Closer in views are more fully assessed in paragraph c) - Conservation Areas, above.
Conclusion
In conclusion, the site is considered a prominent landscape feature within the City's setting, and the proposed development will have an impact on it. The extent of this impact varies. It will be minimal in terms of the City's World Heritage status, as it will not significantly harm the qualities which justified the inscription of the Old and New Towns of Edinburgh as a World Heritage Site, nor will it have a detrimental impact on its Setting. As such the proposals comply with policy Env 1 of the local plan.
The new build elements by virtue of their scale and design are inappropriate within this context and cumulatively will have an adverse impact on important views both to and from the site which is a unique landscape feature within the urban area of the city. These impacts cannot be mitigated from certain views in the short or medium term. In the long term, planting will partially screen these buildings, however, this will not be until the trees reach a level of maturity, which could be for some years to come. The proposals are therefore contrary to policy Des 10 - Tall Buildings and the Skyline.
The introduction of this quantum of development will have a detrimental impact on the scenic quality of this site and the cumulative effect of the proposed development will damage the compositional arrangement of the built form and the surrounding landscape therefore damaging the character. Views within the site will be compromised and to a much lesser extent views to the site. Planting will mitigate some of the effects but only in the long term. The proposed development will have a significant detrimental impact on the character and view of the AGLV (candidate SLA), contrary to local plan Policy Env 11 and Policy Des 3 - Development Design of the adopted Local Plan. f) Trees & Biodiversity
Policy Env 12 of the Edinburgh City Local Plan states that "Development will not be permitted if it is likely to have a damaging impact on a tree or trees protected by a Tree Preservation Order or other trees worthy of retention on or around a proposed development site, unless for good arboriculture reasons". Policy ENV 6 also applies as the site is within a Conservation Area where development will be permitted where it 'preserves trees which contribute to the character of the area'. The topography of this site means that the trees are intrinsic to its character and visual amenity. They
Development Management Sub-Committee – 3 September 2014 Page 42 of 174 12/04007/SCH3 contribute to an instantly recognisable skyline, the wooded character of the hill and the setting of the listed buildings. In their current locations they create landscape backdrops, frame outstanding views and are historic landscape features on the site. The woodland areas are also very important to the ecology of the site. There are also some excellent quality individual trees that contribute to the visual amenity and ecology of the site.
The proposals indicate that the development would require the removal of eleven category A (high quality 40+ years life expectancy) trees, thirteen category B (moderate quality minimum 20 - 40 years life expectancy) trees and twenty-eight category C (adequate condition 10 - 20 years life expectancy) trees, a total of fifty-two trees. Thirty- two other trees will be removed because they are unsuitable for retention and their value will be lost in 10 years. Most of the trees are mature specimens, varying in height between 10m to 20m. The main areas of loss of the category A and B trees include the area behind the Craiglea Place development, the woodland edge opposite Queens Craig and the area behind Clouston Villa. The historic avenue adjacent to the car park at the entrance will not be affected.
The site is one of the few woodland areas in Edinburgh. The proposed removal of such a high number of trees, particularly within the woodland area opposite Queens Craig, is considered to be a significant adverse effect of the development. It is also anticipated that further tree loss will result from the development given the proximity of the trees adjacent to the proposed Clouston Villa. In particular, a mature 19m high beech tree is at risk as the canopy reaches beyond the edge of the proposed building and is only nine metres away towards the south.
The development proposes to plant 700 trees as mitigation. Of these about half are woodland trees which vary in planting height between 1.0m and 4.25m. About 40 trees will be planted at around 4m in height as specimen trees. In general terms the trees will take at least 15-25 years to reach maturity and have the intended effect.
Once the trees have reached maturity, and are in full leaf in summer, the intention is to screen the existing buildings and new development. This will maintain the existing wooded hill and the skyline trees. However, as the proposed tree planting is mainly deciduous, in the winter months, the trees, while breaking up the mass, will not fully screen the new the development after leaf fall. The lights of Burton and North Craig will also be visible in the evening through the trees in the views to the north which will affect the wooded character of the hill. Also views to the existing listed buildings from the east, will be screened by trees which is an alteration to the existing situation. The alteration of the views due to the tree planting will be more fully discussed in paragraphs c) - conservation area, d) - design and e) - landscape character and views. Also the role the trees play in the setting of the listed buildings will be further discussed in paragraph b). The ecological impact will be partly mitigated in the short term, but the cumulative effect of the loss of so many trees will take the long term before the ecology fully recovers.
The submission includes a Woodland Management Plan which is acceptable. This document indicates the maintenance operations that will be implemented over the next five years.
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In summary, there will be a significant number of trees lost to accommodate development which is contrary to policy, and potentially a greater number as a consequence of developing into woodland, especially at pinch points around Clouston Villa. Mitigation will reduce the impact in the long term but it remains contrary to this policy.
It should be noted that planning authorities have a duty to have regard to the preservation and planting of trees and to make TPOs where necessary for giving effect to planning conditions. The new tree planting will be too small in size to enjoy any protection under the Conservation Area designation therefore the long term retention of these trees will need to be secured by TPO. A TPO for the entire site, including new planting, can be progressed by City of Edinburgh Council in advance of the planting scheme and an informative is attached to this effect.
A legal agreement is recommended to ensure that the woodland, and suitable rights of access, shown in the Woodland Plan (Appendix 3) to this report, is transferred to Parks and Recreation, Services for Communities, City of Edinburgh Council prior to the commencement of development. Prior to the transfer of woodland any landscape works within the woodland shall be transferred, as identified in an approved landscape phasing plan, and shall be carried out by the developer. The legal agreement shall also require the payment of the sum of £150,000 by the developer to Parks and Recreation, upon transfer of the woodland to facilitate the upgrading of the woodland and walls within, and its ongoing maintenance. The transfer and securing of future access and maintenance are a significant public benefit which can be delivered through this enabling development and it is therefore appropriate to ensure their delivery though legal agreement.
The proposal will have an adverse impact on other aspects of the biodiversity and ecology of the site. In general terms there will be an increase in disturbance post- development, caused by the introduction of activities and noise associated with residential use.
The development is within part of a Local Biodiversity Site and it is adjacent to a Local Nature Reserve. Policy Env 15 applies, as it is a Local Biodiversity Site. This states that development will only be acceptable if the adverse consequences of allowing development are minimised and mitigated in an acceptable manner.
Protected species surveys have confirmed the presence of bats, a bat roost and badger setts within the development site. Therefore Policy ENV 16 applies, which states that planning permission will not be granted for development that would have an adverse impact on species protected under European Law or UK law unless suitable mitigation is proposed. In addition, under the Conservation Regulations, the applicants must ensure that EPA licences are obtained from SNH if required, and that full consideration is given to the impact of development on protected species, prior to the determination of the application.
One bat roost has been identified in Queens Craig therefore a licence is likely to be be required from SNH, for any work which might affect the roost. SNH have previously indicated that, given the relatively low activity levels and numbers of bats, a licence would be likely to be granted, although further survey work is also likely to be required in advance of work on site. Other buildings, and some mature trees on site, are
Development Management Sub-Committee – 3 September 2014 Page 44 of 174 12/04007/SCH3 identified as having 'high' potential to support bats, although to date surveys have found no evidence of roosts in these other buildings or any trees.
The impact on this species would be considered to be a 'major adverse' effect if there was no mitigation. Suitable mitigation has been proposed although the location of this mitigation is not in the design documents. The new buildings will occupy existing foraging sites for the bats and therefore there will be a long term minor adverse effect from this.
In conclusion, there is no reason in relation to bats why planning consent cannot be granted. A licence from SNH will be required however prior to work commencing which may affect the known bat roost.
Surveys have identified one active badger sett within the site. If any of the proposed works fall within 30m of the sett a licence will also be required from SNH to allow the works to lawfully cause disturbance. Suitable mitigation can be delivered.
Breeding birds are present on the site and a number of species common to suburban woodland and parklands have been identified. In particular, there is a sparrow hawk, which would be adversely effected without mitigation. A buffer zone around the breeding site is to be agreed with Scottish Natural Heritage. The mitigation proposed is acceptable, however, the bird boxes or nesting opportunities in the new build have not been incorporated into the building or landscape design. Birds will also be affected by the loss of foraging habitat, however, the new tree planting would be considered sufficient to mitigate this effect. The replacement of non-native species in woodland with a greater percentage of native trees will in the long term have a beneficial effect.
It should also be noted that Japanese Knotweed has been identified on site and a mitigation eradication strategy is recommended.
In summary, the main biodiversity impacts on protected species can be mitigated, however, there are residual minor impacts arising from the change of use and the loss of foraging habitat. In the long term, (25 years) the impacts will be reduced further. If planning consent is given, a condition must be attached requiring the applicant to obtain the relevant licences from SNH relating to bat roosts and the badger sett, and the location of the sparrow hawk buffer zone, prior to work commencing. Conditions are also required relating to location of the mitigation for birds and bat boxes and eradication strategy for Japanese Knotweed. g) Open Space & Rights of Way
Edinburgh City Local Plan Policy Os 1 states that 'proposals involving the loss of open space will not be permitted unless it is demonstrated that: a) there will be no significant impact on the quality or character of the local environment b) the open space is a small part of a larger area or of limited amenity or leisure value and there is a significant over-provision of open space serving the immediate area and c) the loss would not be detrimental to the wider network including its continuity or biodiversity value and either
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d) there will be a local benefit in allowing the development in terms of either alternative equivalent provision being made or improvement to an existing public park or other open space or e) the development is for a community purpose and the benefits to the local community outweigh the loss.'
Much of the site is identified as open space in the Open Space Audit (2009). The woodland to the west and north is classified in the Audit as 'other semi-natural greenspace', reference numbers NAT 58 and 59 respectively. The significant pieces of green space in the main part of the campus are collectively identified as institutional', numbered INS 13. The Open Space Audit describes the woodland areas as publicly accessible, and the institutional grounds as not publicly accessible.
The proposal involves the partial loss of:
• Institutional open space to the south of New Craig • Woodland open space to the south of Queen's Craig • Woodland open space to the north of New Craig • Institutional open space to the north of the main vehicular entrance drive
To comply with Policy Os 1, a proposal involving loss of open space has to demonstrate that it meets criteria a), b) and c), and either d) or e).
Criterion a) requires that there will be no significant impact on the quality or character of the local environment from the loss of open space.
Institutional open space to the south of the New Craig is being developed as Kings Craig. This development damages the informal and rural character of the setting of New Craig. Significant rooms are located on this south elevation of the building which looks out onto this landscape to the south with some distant views towards Bevan House and the landscape beyond.
Woodland open space to the south of Queen's Craig is being developed as West Craig. West Craig development damages the informal and rural character of the setting of Queens Craig . The new development also damages the setting of Queens Craig from the north due to its height and effect on the skyline. These effects cannot be mitigated by planting.
Institutional open space to the north of the main vehicular entrance drive is being developed as Burton Villa. The height, scale and mass of this building partially damages the woodland setting of New Craig as it will be visible through the trees, particularly during the winter months in the dark. The height, scale and mass also damage the quality of the and character of the setting for Old Craig and the listed villas on the hillside due to its dominance in local views within the site and panoramic views out of the site.
Therefore criterion a) is not met.
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Criterion b) requires that the open space be a small part of a larger area or of limited amenity or leisure value and that there is a significant over-provision of open space serving the immediate area. In the current scheme, the areas to be lost are on the fringes. They have not previously had a defined leisure function. As such their amenity value is primarily visual. Their loss relates to the damage to the quality of the views due to the loss of the landscape setting of the existing listed buildings therefore contrary to this part of criterion b). Compliance with the second part of this criterion, the significant over provision of open space can be the case when the loss would neither:
• create a deficiency in terms of the standards in the Strategy, nor:
• remove an opportunity to address an existing deficiency or need identified in the Strategy.
There is not currently a deficiency in terms of the Local or Large Greenspace Standards (see Maps 4a and 5a of the Strategy). There is a deficiency in terms of play space access in the housing areas to the north (see Map 10). The loss of open space proposed would therefore not create a deficiency. The areas of open space in question could not reasonably be expected to provide a new play area of sufficient play value to address the play space access deficiency. Similarly, they could not reasonably be expected to be established as allotments to address the allotment need. Notwithstanding this, given this application is an enabling case, any further financial contribution would result in the quantum of new build increasing to the further detriment of the setting of the historical asset. Accordingly, the second part of criterion b) can be met.
Criterion c) requires that the loss would not be detrimental to the wider network including its continuity or biodiversity. The loss of open space here, given it is only small areas and within the wider context will not be detrimental to the wider network of open space. Paragraph 3f) of this assessment concluded that there would be a detrimental loss in terms of biodiversity, however, this can be mitigated over the long term. Therefore it is not contrary to c).
Criterion d) is relevant in respect of local benefit and requires that there will be a local benefit in allowing the development in terms of either alternative equivalent provision being made or improvement to an existing public park or open space. Criterion d) therefore is relevant.
Criterion e) is not relevant as the development is for housing which is not a community use.
The large area of greenspace is currently publicly inaccessible in formal terms (and was identified as such in the Audit in 2009). This area is to be formally established as publicly accessible greenspace in perpetuity following any granting of planning permission, and as such would represent a significant gain in terms of formal open space provision in the area. The proposals also include the formation of additional new greenspace within the site in the form of new landscaped areas, for example the introduction of formal lawns and flower gardens on part of the former car park. This will further contribute to open space provision in line with criterion d). Once the large area of open greenspace becomes formally publicly accessible, it is likely that the new
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In summary, the proposed development will result in the loss of open space which will have a detrimental impact on the quality and character of the local environment, contrary to criteria a) of Policy Os1.
There is a right of way that runs along the south of the site, up the hill, down and along the northern part of the site. The northern section is also Core Path CEC 15.
The development of 'Craiglea Place' will cause disruption to the right of way however the maintenance of the right of way will be secured through a planning condition.
Open space situated in the vicinity of the development as shown outlined in the Woodland Plan and Open Space Plan (Appendix 3 ) to this report will remain as open space, fully accessible to the general public and will remain un-built upon in perpetuity. A suitable title condition to this effect will be imposed upon the area of open space, with the right of enforcement attaching to the landowner of the woodland (i.e. the areas to be transferred to CEC - Parks and Recreation). This restriction will also apply to the woodland transferred to Parks and Recreation to ensure it is not built upon. h) Archaeology
The site which includes Old Craig House and the former Craighouse Hospital are regarded as being of national archaeological and historic importance (category A-listed) with the wider estate suspected of containing significant archaeological remains relating primarily to the former medieval and post-medieval estate and the more recent 19th / 20th century hospital. The proposed development will require extensive excavations and given the potential for significant archaeological remains, the aim should be to preserve archaeological remains in situ, however, where this is not possible archaeological excavation and recording of significant remains must be undertaken.
It is agreed that, overall, the proposed development will have a moderate archaeological impact, however, proposed mitigation is insufficient and should encompass the whole site and not just focus on the area immediately surrounding Old Craig.
Accordingly it is recommended that a programme of archaeological works is undertaken prior to development. This would require a phased archaeological programme of works, the initial phase being an archaeological evaluation up to a maximum of 10% of the site. The results of which would allow for the production of appropriate more detailed mitigation strategies to be drawn up to ensure the appropriate protection and/or full excavation, recording and analysis of any surviving archaeological remains affected.
In addition any agreed woodland management plan for the site must have an appropriate mitigation strategy which would aim to protect and enhance the site's archaeological heritage.
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There is concern regarding the site of a dovecote within the woods to the north of Old Craig which appears to be in close proximity to the line of the proposed new drainage track. Drainage should avoid damaging this archaeological site. The proposed drainage strategy does not appear to have taken this into consideration, and accordingly it is recommended that the exact location of this historic dovecote is established prior to the proposed drainage track being agreed to ensure appropriate mitigation measures are put in place for its protection.
It is therefore, appropriate to impose a condition requiring a programme of archaeological work in accordance with a written scheme of investigation prior to the commencement of development and that the drainage strategy takes cognisance of potential archaeological remains (e.g. historic dovecote) within the site boundary.
Given the potential importance of any remains in terms of the history of Edinburgh and in particular Craighouse, it is essential that this programme of works contain a programme of public/community engagement (e.g. site open days, viewing points, temporary interpretation boards) the scope of which will be agreed with CECAS.
As stated the site contains a range of nationally important historic buildings the development of which will see significant works to their fabric. Accordingly if consent is granted it is recommended that a programme of historic building survey (level 2-3) is undertaken prior to and during any works that may either affect or reveal new sections of historic fabric of the listed Old Craig and later Sydney Mitchell hospital buildings. The works will be undertaken in accordance with an agreed brief with the City Archaeologist. This will ensure that any archaeological remains (historic building fabric) that may be affected are properly recorded where preservation in situ is not possible.
It is essential therefore that a condition be applied to any consent granted to secure this programme of archaeological works. i) Existing Residential Amenity
Policy Hou8 of the local plan states that 'developments, including changes of use, which would have a materially detrimental effect on the living conditions of nearby residents will not be permitted.'
An air quality impact assessment (AQIM) was submitted in support of the application and updated in May 2014 for the scheme 3 proposals. The assessment considers the potential air quality impacts associated with additional road traffic likely to be generated by the proposed development. Dust arising from the construction phase of the works is also considered.
Regarding road emissions from the operational phase of the development, the report finds that the impact will be negligible and therefore mitigation measures are not required.
Most of the pollution considered is derived from road traffic vehicles, cars associated with the development being the most likely source. Car parking levels within the development are in keeping with the Council's Parking standards, however, it is proposed, through Travel Plans, that encouragement will be given to residents, to use other alternative and more sustainable forms of transport. This is a positive aspect of
Development Management Sub-Committee – 3 September 2014 Page 49 of 174 12/04007/SCH3 the proposals. Notwithstanding the negligible impact these emissions will have, Environmental Assessment recommends the applicants consider some element of mitigation in providing electric vehicle charging infrastructure. This could be achieved by either providing dedicated parking spaces with charging capacity or ducting and infrastructure to allow electric vehicles to be readily accommodated in the future. These suggestions are also detailed and encouraged in the Council's Parking Standards. An informative is prescribed to this effect.
Regarding the impact on air quality during the construction phase of the development, mitigation measures have been identified within the air quality impact assessment.
Environmental Assessment also advises that any Combined Heat and Power plant associated with the development must comply with the Clean Air Act 1993 and that the use of biomass will not be supported.
In terms of land contamination, some localised land contamination could be issue given its former use as a hospital and hence the developer should undertake a site survey, as a minimum, to establish the level of risk posed to human health and the wider environment from any contamination in, on or under the land. A condition to this effect is recommended.
Environmental Assessment has no objections to the proposed development in terms of air quality and land contamination subject to the recommended conditions.
In terms of daylighting, overshadowing and loss of daylight, the proposed new development is located a suitable distance from existing properties to ensure there will not be any impact on neighbouring residential amenity. There will also be no loss of privacy as a result of the proposed development. The proposals satisfy the requirements of daylighting, overshadowing and privacy in terms of the approved design guidance.
In summary, there is potential for the proposed development to impact on neighbouring residential amenity in terms of air quality and land contamination. These issues, however, can be controlled through appropriately worded conditions. There will be no impact in terms of overshadowing, loss of daylight or privacy. The proposals are acceptable in terms of their impact on existing residential amenity and comply with Policy Hou8 of the local plan. j) Future Living Environment
The design concept has taken cognisance of the Council's approved Design Guidance in terms of ensuring a satisfactory level of amenity is achieved within all new residential units. New buildings have been located to ensure there will be no loss of daylight to the existing category A listed buildings. The location and design of the new development, notwithstanding its proximity in part to mature woodland, also ensures that adequate levels of daylight are provided in accordance with the approved standards. All new dwellings, both within the existing buildings and new build will achieve satisfactory levels of privacy also.
The site's location within an outstanding landscape setting of open parkland and woodland will provide a high standard of varied outdoor amenity space to future
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The site's location within an outstanding landscape setting of open parkland and woodland will provide a high standard of varied outdoor amenity space to future occupants. The design strategy proposes limited private amenity space with small gardens and roof terraces given the unique setting to encourage residents to use this communal parkland.
All units are generously proportioned and provide spacious living accommodation well in excess of minimum standards.
Environmental Assessment has raised concern regarding the potential noise conflict between the existing golf clubhouse at the south eastern end of the site and the proposed residential properties at Craiglea Place. The clubhouse is licensed to 1am on a Friday and Saturday night and occasionally holds late night events, although Environmental Assessment has never received any complaints regarding these operations. The west facing elevation of the nearest residential property has windows to habitable rooms and there are first floor balconies to the rear. The impact of the operations of the clubhouse have not been fully assessed and therefore a condition is recommended to ensure this can be fully assessed and addressed if necessary.
In summary the proposals will afford a high quality of living accommodation for future residents in accordance with approved guidance and local plan policies, subject to a condition regarding noise in relation to the proposed properties at Craiglea Place. k) Road & Pedestrian Safety
A Transport Assessment has been submitted that demonstrates that the proposed development employs sustainable development principles to ensure that the proposed development can be accessed by all modes of transport, with priority given to walking, cycling and public transport. Existing walking and cycling facilities within the vicinity of the site are of a high standard and provide links to existing city centre transport interchanges and local amenities. There are frequent and high quality bus services operating adjacent to the site within a reasonable walking distance. These services currently provide connections to the city centre from neighbouring areas.
Given the unique setting of the site and its challenging topography, the usual design standards for adoptable roads could not be applied without resulting in unacceptable environmental and amenity impacts. As a consequence it has been necessary for the design of the roads infrastructure to integrate into the existing sensitive landscape. The principles of Designing Streets have been employed wherever possible which encourage low speed limits and minimise segregation of travel modes. Cycle and pedestrian circulation will be provided by a combination of contiguous footways, adjacent to the road carriageway and segregated footpaths. Public access to all the residential areas within the site will be by an adopted footway/footpath network. A secondary private, but publicly accessible network, utilising much of the existing routes on the site will, be retained and upgraded to provide wider cycle and pedestrian access throughout the site.
Although there is no formal speed limit, the roads have been designed with a 20mph implied speed limit. The applicant will be required to apply for the appropriate Traffic Regulation Orders to introduce waiting restrictions on the passing places and proposed road network to deter nuisance parking and to enforce the disabled parking bays. A
Development Management Sub-Committee – 3 September 2014 Page 51 of 174 12/04007/SCH3 formal road hierarchy has not been imposed, and a logical progression of road standards has been used within the site. Specific properties given their sensitive location adjacent to the western park edge are served by a new road which is in keeping with the existing infrastructure. Particular emphasis has been placed on the use of hard landscaping and changes in surfacing materials to reduce the impression of a vehicular dominant high speed road network. A mix of segregated and shared surface provision has also been employed to emphasise the lack of priority for any one travel mode. The parkland setting of the site will help to promote the perception of a private estate.
Both car parking and cycle parking is in accordance with the parking standards. A total of 308 spaces will be provided. Resident car parking space will be provided by curtilage parking for new dwelling houses and courtyard parking for new apartments and the converted buildings. It has been agreed that the requirement for visitor parking to be directly accessible from the public road should be relaxed given the topographical and environmental constraints of the site. Visitor parking will be contained within the private courts, but be clearly delineated. This will discourage unregulated on street parking and ensure connectivity between the different parts of the site. This will also encourage the sense of the 'shared use' function of the road network.
There will be a narrowing of the existing vehicular entrance to the site which will improve pedestrian crossing at this junction.
Assessment of the surrounding road network has concluded that the proposed development can be accommodated without any physical alterations to it.
Transport has raised no objections to the proposed development subject to a suitable legal agreement to ensure the payment of costs for the adjustment of signal timings and the required Traffic Regulation Orders. The existing site incorporates a bus stop which served students and staff of the former university use. The removal of the bus stop and associated road significantly enhances this section of the site and allows an enhanced landscape solution. Transport has also requested that the developer pay a sum of money to provide an alternative turning facility for buses. They have also requested that a contribution to Safer Routes to School be paid. It is not accepted that these monies are necessary as a result of the proposed enabling development.
The proposals are in accordance with policies in relation to Transport as contained within the adopted local plan. l) Flood Risk
Policy Env 17 does not allow for development which would increase flood risk. The applicants have submitted a Drainage Strategy which outlines the design of both the foul and surface water drainage systems. SEPA, who originally objected to the Scheme 1 proposals, are now satisfied with the level of treatment for surface water run- off. Scottish Water does not object to the proposals and is satisfied that the capacity issues can be addressed outwith the planning process. The impact of the proposal upon the water and waste water network has been considered. Glencorse Water Treatment Works has limited capacity available for new demand and Edinburgh PFI Wastewater Treatment Works has capacity to serve the development. There may be a
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Flood Prevention has raised concerns regarding the surface water discharge levels exceeding the recommended rates. They have indicated that the applicants will have to take measures to decrease the proposed discharge to a more acceptable level. This can be addressed through an appropriately worded condition. The applicants have indicated that they intend to carry out remedial work on an existing Scottish Water sewer pipeline to enable water to be discharged in to it. This may potentially involve re- lining the pipe to ensure minimal disturbance to the trees within the immediate vicinity of it. Technical approval and acceptance by Scottish Water will be required however, this can also be addressed by an appropriate condition. The proposals include the introduction of 'swale banks' within the woodland into the south east of the site. The current proposals are not of sufficient and accurate detail and therefore further information should be sought through the imposition of a condition showing the exact location and flowpaths of these bunds. The proposed development and its associated flood prevention measures, however, will have a positive impact by reducing surface water run-off from the site to the bebefit of the wider community. Flood Prevention do not object to the proposed development subject to the conditions outlined.
In terms of drainage and flood risk the proposals are acceptable. m) Infrastructure & Affordable Housing
The proposals have been considered by Children and Families and the impact on the local schools. In response to Scheme 1, it was identified that South Morningside Primary School is currently operating at near capacity and with numbers expected to increase, a financial contribution of £2,567 per house and £411 per flat should be sought towards addressing accommodation pressure at the school or, subject to Council approval, a possible catchment change.
Boroughmuir High School is the catchment non denominational secondary school for the area and it is proposed to provide a replacement high school with increased capacity on a new site at Fountainbridge. A financial contribution of £2,142 per house and £357 per flat should be sought towards the provision of new accommodation.
The Roman Catholic catchment schools (St Peter's Primary School and St Thomas of Aquin's High School) are also operating at capacity but management controls will be applied to address demand and no developer contributions will be sought in relation to these schools.
Based on this original consultation response for the Scheme 1 proposals, the sum equates to £335 997. This sum has been factored into the current financial appraisal and is considered an appropriate sum to address issues in relation to education infrastructure.
In terms of affordable housing provision, policy would normally require 25% of the total number of homes, which would equate to 36 units to be provided of approved affordable tenures as part of the development. Given this application is an enabling case, the affordable housing contribution is not being sought. On site provision, in this instance, is not financially viable. The costs of constructing affordable housing units to
Development Management Sub-Committee – 3 September 2014 Page 53 of 174 12/04007/SCH3 an appropriate design standard in keeping with the rest of the buildings on site would be excessively high. It is also recognised that a commitment to the ongoing maintenance costs for the buildings and the surrounding landscape would not be financially appealing to affordable housing providers. Furthermore, to seek a financial contribution for off site provision, which would be well in excess of one million pounds, would require more new build development which would further harm the setting of the listed buildings and the wider historic asset.
A financial contribution has been agreed of £500,997 on the basis of the current quantum of new build development and includes a contribution to improve education infrastructure, transport infrastructure and to help secure the future of the woodland which forms part of the wider historic asset. n) Sustainability
The applicant has submitted a sustainability statement in support of the application.
Essential Criteria Available Achieved
Section 1: Energy Needs 20 20 Section 2: Water conservation 10 10 Section 3: Surface water run off 10 10 Section 4: Recycling 10 10 Section 5: Materials 30 30 Total points 80 80
Desirable Elements
In addition the applicants have provided a commitment to further sustainability measures as set out in the desirable elements. Additional measures include using recycled materials, providing composting facilities and promoting passive design.
In summary, the proposal complies with the requirements of the Edinburgh Design Guidance in respect of sustainability. o) Representations
Material Issues - Scheme 1
Principle of the proposed residential development
• Contrary to Scottish government policy; • Contrary to Scottish Historic Environment Policy (SHEP); • Contrary to the structure plan; • Contrary to the local plan; • The threat of dereliction should not be used to force through such excessive level of new build; • Pre-acquisition advice from Historic Scotland and CEC indicated that development opportunities on the site were limited and this advice was available to all bidders when they were preparing their bid; • The applicant knew what the site restrictions were prior to purchasing the site;
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• Council should take a long term view on what is best for the site and not a short term response to threat of dereliction; • Potential benefits to development do not outweigh disbenefits; • Craighouse not designated for housing in local plan; • Contrary to all the designations on the site; • Development brief of 1992 has been superseded; • Brownfield sites should be looked at before Greenfield; • No need for additional houses in this area; • Not an adequate mix of housing types and need for affordable housing; • Another use for listed buildings may be more appropriate and not require so much new build; • A retirement village may be an appropriate use. A hotel or conference centre also a possibility; • The buildings should be kept in educational use.
Character of Site/ Listed Buildings and Conservation Area • Impact on character and views of the site; • Impact on setting of listed buildings; • Neither preserves nor enhances the character and appearance of the conservation area; • Is inconsistent with the conservation area character appraisal; • Proposals will threaten the UNESCO designation; • Kings Craig will compete with New Craig; • It is not acceptable to damage a designed landscape forming the setting of an historic building simply to finance the building repair. The site needs to be assessed in its entirety; • The setting of the listed buildings extends to perimeter of the site boundary; • There is not an adequate assessment of wider cultural and environmental heritage; • There is insufficient assessment as to how parking, roads, lighting and garden grounds will affect the setting of the listed building; • Demolition of boiler house and filling in of tunnels will detrimentally impact on the character of the listed buildings; • The spaces between the buildings are integral to the status of the listed buildings and impact of the original buildings; • Clouston's original vision was as a healing place for patients to be located within "the most beautiful site in Edinburgh". This will be compromised by new build; • Proposed development at Craiglea Place is not in keeping with the area; • The listed buildings were added to the Buildings at Risk Registry at the applicants request and because they were "vacant with no identifiable use" and not because the buildings were run down; • New build is in excess of number of units in listed buildings and this is inappropriately high; • Concerns that further development may occur in the future; • New development will be of detriment to the listed buildings and will damage the integrity of the culturally significant group of buildings contrary to policy ENV3; • The applicant has a statutory duty to maintain the listed buildings; and • The proposed design of new build is inappropriate in design and materials in the context of the listed buildings.
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Citywide landscape and views • Contrary to CEC Guidelines on the Protection of Key Views; • Craighouse has the status of being one of seven hills of Edinburgh. As one of the seven hills it contributes to city's place identity; • Hill has an important role in views from other points in the city; • Proposed development would result in detrimental impact on character of city; • Adverse impact on City Skyline from Braid and Blackford Hills; • Adverse impact on local views; • Increased light pollution; • A Zone of Theoretical Visibility should have been submitted; • Conflicts with policies on tall buildings and key views; • The addition of Clouston Tower and Duncan will create an incongruous line in views from Blackford Hill; • Views submitted are not entirely well selected or informative; and • Views from the site to the castle and Edinburgh, the Forth and other landmarks will be adversely affected.
Landscape • Adverse impact on AGLV - contrary to Policy ENV11; • Proposed landform is inappropriate; • Private gardens will encroach in to landscape; • Individual garden plots to flats should be avoided to ensure that buildings relate to a wider designed landscape; • There is not an adequate assessment of landscape setting and designed landscape; • The site should be in Historic Scotland's Inventory of Gardens and Parks; • The site is described as "superb" by Historic Scotland and is of "outstanding scenic significance" in the Council's Survey of Gardens and Historic Landscape; • McGowan inventory assessed the site as having outstanding architectural quality; and • Scale and massing will dominate the designed landscape.
Design of the New Proposals • Design is inappropriate for its setting - massing/height/materials; • The new build at Plot 11 (Craiglea Place) would be detrimental for access to woods; • The massing and height of new build inappropriate; • Proposals are an urban type architecture in a semi rural environments; • Proposals contravene Des 10 (tall buildings) - replacement LRC higher than tree line; • The proposed new build do not meet sustainability criteria; • Boiler House buildings encroach on hill; • A+DS criticised design quality; • The range of types of new build is inappropriate; and • Any new build need to add a 21st layer and vocabulary of architecture to the site of a quality to match that of existing layers.
Biodiversity • Replacement trees should be fast growing and native and will take a long time to mature; • The development on the woodland edge would affect biodiversity;
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• There will be loss of species habitat due to development; • There will be loss of woodland edge due to development; • Protected species (bats and badgers) will be affected; • Ecological assessment gives no consideration to owls; • Development will have a detrimental impact on SSSI; • The site is an important wildlife corridor; and • There is insufficient information on impact on wildlife and biodiversity.
Loss of trees • There will be an unacceptable loss of trees; • There will be loss of apple trees in the "orchard" area; • Loss of 58 healthy trees is not acceptable; • A+DS report says that proposed tree removal is an underestimate; • Loss of trees would create wind tunnel; • No tree survey to latest BS standard; and • Trees to be planted in mitigation are badly chosen.
Open Space provision and rights of way • Now that Council is likely to take over the maintenance of the open space there is less argument for so much new build; • Preservation of green space and heritage is essential make Edinburgh an attractive place to live, work and visit; • Contrary to OS1 of ECLP - loss of open space; • Open space and green space are necessary for health and well being; • Loss of "green lungs"; • Proposed public park considerably smaller than what is existing and access will be restricted; • Continued public access needs to be secured/Concerns about a 'gated' community being created; • The proposals to lease the open area to local residents is overly complicated; • Old Craig Grove will materially alter the character of the open space; • Green space will be cut off from woodland; • Loss of amenity for local residents in loss of green space; • Loss of recreational/ community space/ children's play area; • Loss of traditional routes through the site/ impact on rights of way; • Proposed new fences would restrict access and movement through the site; and • Community should not have to choose between the architecture and the green space.
Impact on archaeological remains • There has not been an adequate assessment of archaeological features; • All layers of the designed landscape should be fully and independently documented as part of an archaeological assessment; and • Potential damage to the archaeology on the site including, but not limited to, the rig and furrow pattern evident in the landscape.
Neighbouring residential amenity • Increase in noise; • Increase in light pollution; and • Loss of privacy and overlooking for residents of Craiglea Place.
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Traffic generation and road and pedestrian safety • Area cannot accommodate circa 323 additional cars; • Existing problems with parking in surrounding area will be exacerbated; • The entrance to site is already in a dangerous location and this would be further compromised; • Traffic safety in general will be compromised; • Large amount of green space will be covered by tarmac; • The transport impact has not been adequately assessed; • Proposed puffin crossing too close to site entrance; • No mention of a green travel plan; • Deterioration of air quality by increase in car numbers; • A pavement is required on the Craighouse hill side of Craighouse Road; • Cycle lanes needed; • No assessment of transport provision for means other than cars or impact on traffic levels; • Where will buses terminate?/ More bus provision required; • Roads built on the hill will be dangerous in snowy and icy weather; and • A carriageway will be extended along a right of way and it appears that there is no separate provision for pedestrian or other non-vehicular vehicles.
Flood risk • Additional buildings, roads and parking areas will exacerbate existing problems with flooding on Balcarres Street/ Meadowspot; • Potential for sewage to enter the storm water system in the event of flooding; • No mitigation strategy for potential drainage problems; • The proposals have not been properly analysed for potential impact on flooding; and • It has not been demonstrated that there is enough water pressure or sufficient sewerage capacity for the development.
Infrastructure • Local primary and secondary schools already over subscribed; • No associated proposals to provide health and other community facilities; • No details on utility works and earth works; and • No on site affordable housing proposed.
Sustainability • The LRC building should not be demolished but reused.
Issues of process • There have been irregularities with respect to the handling of this application; • Information submitted has been incomplete and misleading; • The community's views have not been listened to; • The consultation questions were misleading and permitted a limited range of responses; • EIA inadequate; • The consultation process was misleading.
The case for enabling development • This is not an enabling development - site and buildings purchased in good condition;
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• Any "enabling development" must be kept to absolute minimum; • Listed buildings could be converted without need for new build; • Financial argument has not been presented or made public; • Financial argument should not be a planning consideration; • Given the level of protection that the site has, the only justification for new build is the enabling development argument; • The enabling development should not be a means for recouping the purchase costs of the site; • This application does not fulfil the criteria described in the English Heritage guidance on Enabling Development; • The Knight Frank report did not assess the enabling development case. It was based on a previous proposal and was assessed as reasonable by economic development not planning; • Bangour Village Hospital is a false comparison as the constraints and conditions differ; • The Meadowspot development was an "enabling development" and it failed to secure the long term future of the listed buildings; • No guarantee that the new build will secure the long term future of the listed buildings especially if listed buildings will be converted last; and • Napier received public funding for their conversion and there should be to need for any additional buildings to fund current conversion.
Support Comments - Scheme 1
• Support for the conversion of the listed buildings to ensure their sustainable future; • Primary aim to secure long term future for listed buildings is challenging because of their varying size, scale and nature; • Residential conversion is the only valid option; • The cost to convert the listed buildings is prohibitive against market value of end product; • Reaction against proposals focuses too much on what is being lost and not on what is being retained; • New build is on less than 5% of site, is designed to be largely hidden and will have minimal impact of skyline; • The development will secure the open space and ensure continued access for the community; • There is a need for additional housing in the city; • The proposals will provide employment; • New build will be largely invisible from outwith the site; • The new buildings are sympathetically sited to protect setting of listed buildings; • SUDS will reduce flood risk on Balcarres Street; • The proposals would see the provision of over 50 affordable housing units; • Extending the LNR would protect and enhance biodiversity; and • A modest amount of new build may be acceptable and should match style of existing buildings.
Non-Material Issues - Scheme 1
• The developers are not to be trusted; • Planners should not have accepted the application;
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• There are legal implications around leasing of the land; • Proposals are motivated by profit; • The promise of off site affordable housing is "bribery"; • Other bidders of the site when it was marketed may have been more appropriate and may not have proposed such a large level of development; • Allowing development here would set a precedent for developing other sites; • Old Craig should be kept in public use and not sold to a private owner; • The new build will be located too near the golf course for safety; • New structures could cause wind turbulence that would be detrimental to adjacent listed structures; and • Loss of boiler house at new Craig will impact on power supply.
Morningside Community Council - Scheme 1
The Community Council continues to object on the following grounds: • Contrary to local plan policy; • Lack of financial evidence to justify new development; • Contrary to SPP11, Open Space and Physical Activity; • Development within a designated area of open space and Area of Great Landscape Value; • Adverse impact on views and skyline; • Development inconsistent with the Craiglockhart Conservation Area Character Appraisal; • Detrimental impact on existing category A listed buildings; • They state any development of the site should be phased to ensure the refurbishment of the listed buildings is carried out in parallel to the new development. • Detrimental impact on the biodiversity of the site and the adjacent Easter Craiglockhart Hill Nature Reserve; • Inappropriate design; • Clouston Villa is excessively high and inappropriate; • Excessive new build is required in part for off site social housing, this obligation should be reduced to minimise new build on site; • Local schools are already at capacity and this have a detrimental impact; and • Concern regarding drainage capacity and potential flooding.
Craiglockhart Community Council - Scheme 1
They object to the proposals on the following grounds: • It represents an unacceptable loss of open space for private use detrimental to the setting of these listed buildings; • Inappropriate design, not harmonising with existing listed buildings; • Clouston Villa is too high; • Foot, cycle and vehicular circulation are not clear and require clarification; • Increase in traffic and unconvinced by proposed solutions; • Inappropriate use of 'weld mesh' fencing; • Phasing of the development should ensure renovations to the listed buildings are carried out in parallel to the new development; • Lack of information available to assess financial case; • Proposals constitute overdevelopment; • Query whether drainage is adequate;
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• Local schools are at capacity and this will exacerbate the problem; and • Query the retention of viable mature trees within the site.
Merchiston Community Council - Scheme 1
They object to the development on the following grounds: • The site is designated as Open Space; • The site is designated as an Area of Great Landscape Value (and a candidate for Special Landscape Area); • The site is in a Local Nature Conservation Site and Local Nature Reserve; • The site is within the Craiglockhart Hill Conservation Area; • All trees have TPO status; • Development is contrary to Scottish Government Policies; • Development contravenes the Scottish Heritage Environmental Policy (SHEP); • Development is contrary to the Development Plan; • Proposals are at a variance to the Edinburgh Planning Concordat; • Challenge the argument that this is an 'enabling development'; • Loss of valuable recreational and social space; • Inappropriate design; • Destruction of the setting of the listed buildings; and • The character and setting of the hill will be destroyed to the detriment of its status as one of the 'seven hills' of Edinburgh.
Material Issues - Scheme 2
Principle of the proposed residential development
• New build development not supported; • Increase in new build numbers between scheme 1 and scheme 2 unacceptable; • New build excessive; • Scheme 2 has increased size of dwellings and square footage; • New build covers 60% of the site; • Not designated for housing within the ECLP; • Scheme 2 fails to address any previous concerns; • Scheme 2 poorer quality than scheme 1; • Layout is inconsistent with established settlement pattern; • Additional housing not required within the city; • Viable alternatives to housing; • Institutional use should be maintained on the site; • Brownfield land should be developed first; • Failure to deliver family housing; • Contrary to many policies of the ECLP and proposed LDP; • Contrary to the Structure Plan and SESPLAN; • Contrary to SPP; • Development of the site will create an unacceptable precedent; and • Adverse impact on designations.
Citywide landscape and views
• Proposed boiler house block impacts on setting of site; • Adverse impact on wider city views and skyline;
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• Impact on views out of the site and; • Contrary to Guidelines on Protection of Key Views.
Character of Site/ Listed Buildings and Conservation Area
• New build has an adverse impact on setting of category A listed buildings; • Impact on setting and approach to Old Craig; • Surface parking impacts on setting of listed buildings; • Adverse impact on conservation area; • Happy to see existing buildings crumble and area returned to nature; • Demolition of A listed boiler houses not supported by a survey; • Negative impact on the relationship between open space and buildings; • Buildings only on at risk register due to current developers and ongoing vacancy rather than deterioration; and • Contrary to SHEP policy.
Landscape
• Adverse impact on character of AGLV; • Undermines greenbelt boundary at Hermitage Drive; • Candidate Special Landscape Area; and • One of Edinburgh's seven hills.
Design of the New Proposals
• Design of new build inappropriate; • Height of proposed flats; • New build proposals reflect recent student accommodation developments within the city; • Design is not traditional - stone should be used; • Footprint of Clouston is bigger than current LRC; • Entrances to the site are dominated by large blocks of flats; • New build developments are very prominent; and • New build at Craiglea out of scale with adjacent houses.
Biodiversity
• Adverse impact on Local Nature Conservation Site; • Impact on protected species; • Insufficient surveys carried out on protected species including bats; and • Insufficient mitigation proposed.
Loss of trees
• Query condition of trees proposed for removal; • Encroachment into wooded areas; • Unacceptable loss of trees; • Excessive new tree planting in areas designed to be open; and • Woodland is not currently degraded and is the developers terms not widely acknowledged as in such a condition.
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Open Space provision and rights of way
• Reduced public access through site; • Erection of security fence on site unacceptable; • Loss of open space; • Gated community created; • Future access to woodland unclear; and • Threatens Right of Way through site.
Impact on archaeological remains
• Archaeology Impacts.
Neighbouring residential amenity
• Impact n recreational facilities for local residents; and • Impact on privacy of Craiglea Place from rooftop patios.
Amenity of Occupiers
• Lack of amenity space for residents.
Flood risk
• Risk of flooding at Balcarres Street and Meadowspot; • Issues with drainage calculations submitted; and • Surface water run-off will increase.
Traffic generation and road and pedestrian safety
• Impact on road capacity particularly during peak times; • Transport Assessment is unrealistic; • Increased traffic implications due to Royal Edinburgh development; • More buses needed to service area; • Assumptions made within Traffic Assessment on vehicle movements unreliable; • Traffic impact at Craiglea Place; • Impact on on-street parking in adjacent areas; • Transport Assessment - Increased scheme but less trips than scheme 1; • Decrease in parking numbers per property; and • Underground car parks add to the requirement for new build in order to finance them.
Infrastructure
• Adverse impact of school capacity; • Sewer capacity; • Not sustainable as development is too remote from amenities, shops etc; • No affordable housing has been provided; and • Lack of small scale retail unit within scheme.
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The case for enabling development
• Contrary to guidelines on Enabling Development SPP 4/2009; • Number of mistakes in the financial numbers; • The disbenefits of scheme 2 are decisively greater than the benefits - public loss of these proposals is severe; • Phasing of development should not allow for listed buildings to be developed last; • Potential to generate profit from site without new build; • Full enabling case should be made public; • Price per square foot for listed building conversion is too low; • Planning Authority being asked to judge the financial risks taken by the developer in a risky market not the merits of building on a landscape on national importance; • Not persuaded by the valuations used; • New build exceeds minimum necessary; • Profit without the requirement for new build; • Developer is seeking an increase in profit of £7.3 million between scheme 1 and scheme 2; • Conversion costs have increased by 20% in scheme 2; • Enabling guidelines make it clear that Enabling Development cannot be used to compensate a developer for overpaying for the site; • English Heritage policy criteria on Enabling Developments have not been met, namely • Will not materially harm the heritage values of the place or its setting; • It avoids detrimental fragmentation of management of the place; • It will secure the long term future of the place, and where applicable, its continued use for a sympathetic purpose; • 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 paid price; • Sufficient subsidy is not available from any other source; • 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; • The public benefit of securing the future of the significant place through such enabling development decisively outweighs the disbenefits of breaching other public policies; and • Insufficient enabling case put forward.
Quality of Submission
• External views are poor quality; • Query number of new build boiler houses 9 or 10; • Artists impressions are misleading and inaccurate, buildings are shown in the wrong place; • Too many mistakes in submission to list; • Not an accurate representation of actual development proposed; • Technical reports are inaccurate and out of date; • Application not in an appropriate state to consider; • Why has no physical model been prepared; • LBC application and FUL application drawings do not match;
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• Breeding bird survey incompetent; • Badger Report refers to an old submission; • Transport Report - parking numbers don't add up; • No plans of underground parking areas; • Masterplan has scheme 1 for West Craig and Kings Craig; • East and West elevations wrongly labelled/ wrong colours labelled; • Statement that less trees to be removed but on counting actually more; and • Not a competent submission.
Support Comments - Scheme 2
• Support the redevelopment of the existing buildings; • Increase in trade for local businesses; • Support some new building on the site; • Consistent architectural style welcomed; and • West Craig and Kings Craig sensible for new development sites.
Non-Material Issues - Scheme 2
• Track record of developers - previous failures; • Developers lobbying the Scottish Government to call in the application; • Timing of the hearing should be the evening; • Question why the Council are even considering the proposals; and • Timing of submission over Christmas period;
Morningside Community Council - Scheme 2
They object to the development on the following grounds:
• The apparent evidence that public criticism of Scheme 1 has led to an even greater number of new properties being proposed in Scheme 2 appears to have hardened attitudes against any new buildings; • Scheme 2 development would breach many of the adopted Edinburgh City Local Plan Policies; • Craighouse is not designated for housing in the Local Plan and, with all the above policies in place, Craighouse should be protected from development. • Proposed LDP does not allocate site for housing; • Adverse impact on a number of designations across the site; • Impact on trees and wildlife; • Impact on iconic 7 hills; • Enabling Case - do not accept that development represents minimum required; • No Enabling Case Criteria have been satisfied; • Impact on Infrastructure - schools, roads, drainage; • Scheme 2 does contain design consistency but is of an overbearing design and height; • Phasing; • Quality of submission; • Disappointed in lack of input from Historic Scotland; and • Geology survey should be carried out now that there is underground parking.
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Craiglockhart Community Council - Scheme 2
They object to the development on the following grounds:
• Development is excessive; • An enabling case does not justify this level of development; • The financial case is flawed in that it does not reflect current market conditions; • The phasing programme proposed will not ensure the refurbishment works to the listed buildings will be completed; • Design is incongruous; • The setting of the listed buildings will be destroyed; • Loss of open space; • Detrimental to the AGLV; • Impact detrimentally on the character and appearance of the Conservation Area; • Increase in traffic; • Flood risk; and • Pressure on local school's capacity.
Merchiston Community Council - Scheme 2
They object to the development on the following grounds:
• Contrary to local plan designations; • Loss of public access to valuable recreational and social space; • Challenge the argument that this is an 'enabling case'; • Destroys the setting of the listed buildings; • Poor incongruous design and finishes; • Road safety implications; and • Question the principle of enabling development.
All material issues raised with respect to Scheme 1 and Scheme 2 that remain relevant to Scheme 3 are addressed in Section 3.3 of this report.
Material Issues - Scheme 3
Issues relating to the principle of development • Proposal is contrary to spatial strategy of SDP which directs development towards 4 strategic development areas; • Contrary to Policy 1B of SDP due to significant adverse impact on listed buildings, does not enhance the natural and built environment and not high quality design; • The site is not designated for housing development; • Craighouse is an important community resource for the whole population of Edinburgh; • Loss of amenity space for dog walkers and runners; • Irreversible loss of public amenity and recreational space; • Proposal is contrary to Scottish Planning Policy; • The plans have increased the number of dwellings and the square footage of new development from Scheme 2; • Proposals constitute a significant departure from the proposed LDP; • Proposal is contrary to Policy 7 of the SDP;
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• No part of the site has ever previously been consented for housing; • This area of Edinburgh is already crowded and increasing the number of homes is not only unnecessary but is highly undesirable; and • The planning statement says that the vast majority of new build would be built on brownfield land and existing consented sites - what brownfield sites, most new build is on woodland or open space.
These issues have been addressed in section 3.3 a) of this report.
Issues relating to the enabling case • Applicants are still refusing to do the listed buildings first; • There is no immediate risk to the condition of the listed buildings that requires an urgent decision; • Proposal is contrary to policy on enabling development on the basis that the new build will materially harm the heritage value of the site; the proposals exist to increase profitability of the site rather than benefit the architectural, heritage and landscape value, and that the financial methodology used significantly underestimates the value of the proposed units; • A profit margin of 20% is overly generous; • A decision by a Planning Inspector regarding a 20% profit margin does not set a precedent; • The listed buildings are profitable developed alone; • There are viable alternatives for the buildings; • The estate has not been properly market tested on the open market; • It is not the place of CEC to be writing an applicant's enabling development case for them; • No consideration appears to have been given to an alternative use for the historic buildings as part of this development; • The site value is not zero, a requirement for enabling development, regardless of how the figures are manipulated; • The proposed amount of new build is not at a proven minimum; • With a land value of £1 the redevelopment and safeguarding of the listed buildings would be commercially viable with no enabling development and still achieve a 20% profit; • As the land is designated as of Great Landscape Value with presumptions against development it is difficult to see how it has a break up value of £4.7m when it cannot be built on; • A full detailed review of the financial viability of the projects, including the potential profit should be made available to the general public; • English Heritage advocates a 'presumption against enabling development' unless it meets the specified criteria a-g; • The proposed scheme has to fit all the English Heritage criteria to be a candidate for enabling development and it clearly does not; and • There is no clear public benefit from allowing the disbenefit of such a large amount of new build which would badly affect the conservation area, setting of A-listed buildings, protected views, wildlife and the amenity of the local community.
These issues have been addressed in section 3.3 a) of this report.
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Issues relating to the setting of listed buildings
• Contrary to Policy Env 3 as the proposals are detrimental to the character and appearance of several listed buildings; • Proposals will have a negative impact upon the architectural character of a unique site; • The proposal spoils the setting of the listed buildings; • There is no guarantee that listed buildings will be saved and every reason to believe that their fabric and setting will deteriorate as the new build is constructed; • Old Craig will be obscured by a housing estate; • New Craig and the villas will be dominated by the proposed blocks; • The character of Victorian buildings against a dramatic landscape backdrop will be spoilt; • Proposals will introduce a suburban element into the setting of the listed buildings; • Proposal is contrary to SHEP (1.14); SHEP is not relevant in the determination of this listed building • Phasing of development should ensure redevelopment of listed buildings early unlike at Quartermile and Redhall; • Clouston Villa, although lower than in scheme 1, is still greatly out of scale with the surrounding A-listed villas; • New Craig will be removed from the wooded landscape in which it sits; and • North Craig will necessitate that the listed boiler houses be demolished contrary to policy.
These issues have been addressed in section 3.3 b) of this report.
Issues relating to the character and appearance of the conservation area
• Contrary to Policy Env 6 as the proposals will have a negative impact on the appearance and character of the conservation area; • Craighouse defines and epitomises the character of the Craiglockhart and Plewlands conservation areas and the proposed new build is out of keeping; • The Craiglockhart Hills Conservation Area Character Appraisal is clearly ignored; and • The new build blocks, West Craig and King's Craig are out of keeping with the conservation area and are also placed uphill from listed buildings making them even more prominent.
These issues have been addressed in section 3.3 c) of this report.
Issues relating to archaeological interest
• There will be loss of sites of currently unknown archaeological, historical and paleontological interest. This issue has been addressed in section 3.3 h) of this report.
Issues relating to scale and design
• Still more new build than old across six development sites and 12 car parks;
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• Reduction of one unit fails to address previous objections; • No indication that there will be use of sustainable building materials; • Proposal is contrary to Policy Des 1 as the character of the surrounding area would be damaged by the height, massing, location and materials of the proposals; • The appearance is not in keeping with the area; • Height of Burton and Clouston Villas are not in keeping with the landscape; • New buildings look like an industrial estate; • Vast increase in surface parking will spoil the green setting of Craighouse; • Huge overdevelopment of the site; • Clouston Villa will be a blot on the skyline; • New buildings will dwarf and crowd the historic buildings; • Proposed buildings look like prison blocks; • Emphasis on surface parking rather than underground contravenes aspects of the Edinburgh Design Guidance; • New houses and car parking at Craiglea Place are out of keeping and spoil the country feel of the entrance of the site and right of way; • There should be no increase in height to the existing modern library building; • In terms of architecture and urban design the proposals are mean, utilitarian and would affect real damage on the setting, character and amenity of a historic group of buildings and its open established landscape; • The materials proposed could be changed to a better match without resorting to pastiche; • The mass needs to be greatly reduced to match blend in with the current buildings; • Proposed building plan does not make best use of the beautiful site and seems excessive; • Timber and brick external materials is wholly inappropriate; • There is no feeling of domestic scale; • if any development is to be considered it should have undercroft parking, be tall blocks like existing and finished in high quality materials like stone or slate; • The new builds are visually dominating on the site, they are neither subservient or complementary to the main building and there is a lack of composition to the buildings as a group; and • The new design for 4 houses at Craiglea Place is little better than before and are completely inappropriate next to the nearby Victorian houses.
These issues have been addressed in section 3.3 d) of this report.
Issues relating to landscape character and views
• Proposal is contrary to Policy Des 10 as the proposal would have an adverse impact upon views to/from Craiglockhart Hill and the elevated position would make the proposals highly visible and exceed the height of neighbouring residential buildings; • Proposal is contrary to Policy Env 11 as the proposal clearly detracts from the character and appearance of an Area of Great Landscape Value; • The site is a candidate to be a Special Landscape Area; • The view from Blackford Hill will be spoilt; • The site's character as a city landmark will be spoilt from viewpoints around the city;
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• Protected views and the skyline will be greatly damanged and spoilt by the proposed monolithic blocks; • Craiglockhart Hill (Easter) would be permanently altered as a city landmark by this development; and • The landscaping as designed will corrupt the existing views out to Edinburgh from several vantage points.
These issues have been addressed in section 3.3 e) of this report.
Issues relating to trees and biodiversity • Proposal is contrary to Policy Env 12 as the proposal will have a negative impact on protected trees that the re-planting proposals will not ameliorate, particularly in the short-medium term; • Proposal is contrary to Policy Env 15 as it will have a detrimental impact upon flora, fauna and landscape of a local nature reserve; • Proposal is contrary to Policy Env 16 as the proposals may have a negative impact upon nesting birds, badgers and bats; • Proposals will involve a substantial loss of protected woodland and open space; • Considerable impact upon the area's abundant wildlife; • As a Local Biodiversity Site and Nature Conservation Site the wildlife should especially be protected; • Loss of habitat for protected species; • Scottish Government policy includes a presumption in favour of protecting woodland; • The submitted survey on bats and badgers is not comprehensive; there are more than 1 badger sett and no bat surveys have been undertaken at Craiglea Place or in the area around the LRC; and • Loss and damage to plant species and loss of biodiversity.
These issues have been addressed in section 3.3 f) of this report.
Issues relating to loss of open space and Rights of Way
• Contrary to Policy Os 1 of ECLP as they involve the loss of open space with no significant benefits; • Green space must not be eroded; • Areas of traditional walks will be destroyed; • The proposals will see the loss of protected mature trees as well as open green space while the Concordat with the CSGN commits the City to protect and enhance such existing green spaces; • Loss of unimpeded access to parts of the site both for the local community and for new residents, and for wildlife; and • The proposed new build on the south side of the development is on a Right of Way, which cannot be built on.
These issues have been addressed in section 3.3 g) of this report.
Issues relating to residential amenity
• Scale of Craiglea appears to overshadow its neighbours and affect privacy; • Concerned about residential property being overlooked by new development;
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• Noise and light pollution; and • Pollution from traffic fumes.
These issues have been addressed in section 3.3 i) of this report.
Issues relating to road and pedestrian safety
• The TA underestimates the number of car trips that the proposals will generate; • The walking/cycling isochrones in the TA fail to take account that Morningside Drive and Craighouse Road are steep hills and walking times are underestimated; • The site is no longer served by Service 41 bus, the replacement 36 service ends at 20.00 hours and the stops served are a 5-10 minute walk from the development; • Most of the bus services listed in the TA are only accessible from Comiston Road, which is a 20 minute walk, thereby reducing their attractiveness; • The TA omissions means that the site's modal share estimates are unlikely to be met and are still below the targets set in the Local Transport Strategy; • The TA has failed to consider the major congestion at Craighouse Road/Myreside Road generated by George Watson's College drop off/pick ups; • Proposals will add more traffic on already congested streets; • Developer should install pavements along both sides of Craighouse Road; • Roads/car parks - there would be increased hazards to children and pedestrians; • Parking spaces have been reduced and there is nothing to suggest that these are adequate for residents and will adversely impact upon neighbouring streets that are already under pressure; • The access road is being made smaller which will impact upon traffic flow to/from the site; • Spaces for the City Car Club should be provided; • The narrowness of the proposed roads will cause problems for vehicles larger than cars; • There is a major assumption that traffic flowing south from the site will move to Comiston Road via Morningside drive; any local resident will view this assumption as unrealistic; • The traffic surveys were undertaken three years ago and given the site's derelict nature now, the traffic flows are not representative of current conditions including the large Royal Edinburgh development adjacent to the site; • The TA has a major omission with the Balcarres Street/Myreside Road priority junction not included in the capacity analysis; • The capacity analysis is clearly flawed; it provides no evidence of calibration against existing queue lengths at the Gray's Loan junction; • The conclusion that a development with 308 parking spaces will generate 75 vehicle movements in the morning is unbelievable; and • No TRICS analysis, Linsig inputs/outputs and Picady inputs/outputs have been supplied with the TA; this should be provided as evidence that the TA has been undertaken correctly.
These issues have been addressed in section 3.3 k) of this report.
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Issues relating to flood risk
• Concern over increased surface water and sewage into an already overloaded system; • Increase in non-permeable ground will increase flooding risks in surrounding land; • The SUDS do not look adequate; and • Construction of rain water retention pits on hard volcanic rock with limited depth of top soil must be queried.
These issues have been addressed in section 3.3 l) of this report.
Issues relating to infrastructure and affordable housing
• Amount of rock blasting needed must be assessed; • Soil cover on Craighouse Hill is relatively thin and subject to down slope movement; • No retail unit is planned and shops are a good walk away thereby increasing car use; • Construction of a new primary school should be a condition of redevelopment; • Proposal will put strain on local schools, which are already at capacity; • Inadequate supporting infrastructure such as medical facilities; • The money to be put towards a new school is minimal compared to the total build cost and the Council have no plans to build a new school at this time; • SMPS is already the most reliant on temporary accommodation in Edinburgh; • Some SMPS class sizes are above Council guidelines and the playground is only a third of the size required by current legislation for new schools; • Should consider the existing Council forecast for rising primary school roles before the potential compounding effect of new housing developments; and • Failure to provide associated affordable housing.
Support Comments - Scheme 3
• There is a need for more housing in south Edinburgh and the modified scheme adds to this in a fairly sensitive manner; • Don't object to the conversion of existing buildings for residential use; • Retention of public access to the site following redevelopment of the site. • Scheme can be supported as overall number of new build properties has reduced, reduction in amount of tarmac and subsequent improvement in green space preserved, improved drainage scheme, safeguarding public access, and the landscaping management scheme; • Proposal is a good compromise in continuing public access to the site and protecting listed buildings; • The development is sympathetic to its surroundings and will be good for the local area; • It will be positive to see the site occupied and it will be a very pleasant area for the new residents to live; • The revised proposal appears to improve the relationship between built development and open space; • The Partnership has a unique expertise and commitment to the protection of historic buildings;
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• Revised proposal demonstrates the willingness of the partnership to engage with the concerns of the community and address these in a way that provides for the long-term sustainability of the site; • The alternative if the application fails is that an iconic site will likely go to waste and the impact of dereliction on the immediate and wider community, not least in economic terms and this cannot be overlooked; • The site is important and needs a secured future - only redevelopment as housing provides that; • Main areas where new build is proposed are mainly unused areas to the outskirts of the existing gren areas and do not take away anything from the image of the area; • Any less development on this site will not make the project financially viable for those involved and will lead to deterioration of the existing buildings; • This development will bring in a great amount of employment and job opportunities for many people in Edinburgh; • The local community will gain guaranteed access to what is currently a privately owned site; • The open green space remains as open space and becomes a public park maintained by the residents; • Several hundred trees will be planted; • A substantial financial contribution will be made to local schools; • This is a great example of a new development which respects and harmonises with the traditional old landscape and surrounding buildings; and • The whole community really does seem to be involved and will benefit from this development in the long run.
Non-Material Issues - Scheme 3
• Say yes to the financially viable community plan; • Ownership and responsibility for the community park should be split between new residents, the Council and the Community Council; • Concern that existing buildings may be empty for many years resulting in the development being an ongoing building site for many years; • The developers are untrustworthy; • Concern that little has been done to maintain the integrity of the site whilst the planning process is taking place; • Proposal creates a dangerous precedent for Edinburgh's historic sites and green spaces; • New builds are struggling to sell and remain empty (i.e. Springside); • Chaos will happen as a result of building works; • Loss of views from private property; and • Likely reduction in the value of property.
General Comments - Scheme 3
• Information provided by the developers has been of consistently low quality with many errors and omissions; • Promise of off site land for affordable housing could be construed as an inducement to accede the application; • Whole site should be returned to woodland and the current buildings removed or left to decay;
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• The hills of Edinburgh should not be built on; • Extra strain on local schools will lead to a drop in education standards; • Brownfield land and disused commercial premises are better suited than parkland; • No clear plan for how the woodland will be managed as a whole; • Council and community should work together to make sure the woodland and green space is preserved and listed buildings developed positively in line with alternative community plan; • Craighouse is one of only 8 AGLVs that are protected against development in the LDP; • Build on the green belt beyond the bypass instead of ruining unique sites within the city; • Do not need more expensive houses; • Should masterplan the site sensitively for some low-cost quality self-build/social housing; • Could more brown land sites be made available; • This is not a real enabling development; • There are better ways to use Craighouse than as accommodation; • Developer claims that the proposal increases open green space to the public via a community park but this is unenforceable; • The track record of the applicant is a major cause for concern; • Deadline for comments should be extended due to holiday season; • Parkland spaces are essential for the health of any city; • The land should be taken into public ownership; • The enabling case is deeply flawed; • To encourage development on this site would make a farce of all the statutory and regulatory processes, as well as the City's commitment to sustainable development; • The Council should require the applicant to properly market test the property before further consideration of the application is permitted; • The applicant should be required to publish the data and model used to calculate their projected sales figures before their application is considered further; • There appears to have been less notice and less publicity than for previous schemes; • The site will be adversely impacted by the proposals, putting the future wellbeing of users at risk, contrary to Scottish Government ambitions and at odds with well established medical principles on the health benefits of open green space; • It is a prized nature reserve to be enjoyed and passed on to the next generation to enjoy; • The importance of health and well-being cannot be underestimated and sites like Craighouse can provide Edinburgh's citizens with that experience, and for free; • The need to uphold the integrity of the planning procedure; • Successive submissions show no fundamental change; and • Enabling development should only be considered as a last resort and cognisance needs to be taken of the number of times it has devalued a place of special character rather than saved it.
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Craiglockhart Community Council - Scheme 3
• The enabling development case appears to enable the applicant to exploit the site far beyond that required to meet the conservation deficit necessary; • The site has many protections, including the local plan designation and conservation area status that preclude development; • The proposed phasing of the development exposes the site to the risk of abandonment before completion; • The number, design and mass of the new buildings appear to clash with and dominate the existing structures; • Grave concerns over the security of wildlife and flora and the Environmental Impact Study does not allay these fears; • The proposal to create a community park is welcomed but the detail of how access and use would be controlled remains uncertain; and • We recognise the benefit of the s75 contribution, the much improved drainage plan and the gift of land to CEC to increase the Local Nature Reserve.
Morningside Community Council - Scheme 3
• The proposed Scheme 3 development would breach many of the adopted Edinburgh City Local Plan policies, including Env 3, 5, 6, 11, 12, 15, 18 and Os 1; • Craighouse is not designated for housing and with all these policies in place, Craighouse should be protected from development; • Many of the green areas around the site have been substantially developed and by virtue of this reduction in green space, the protected Craighouse site has become a very important recreational area; • Craighouse is not designated for housing in the LDP; • The site has many important designations - open space, Local Biodiversity Site, Nature Conservation Site and Area of Great Landscape Value and these designations are incompatible with any new build; • The proposed development is incompatible with the conservation area status as the new build cannot be considered as likely to enhance the site; • The landscape setting of the listed buildings is part of what justifies their status as A-listed buildings with the character appraisal describing Victorian buildings against dramatic landscape backdrops - the new build contrasts sharply with that character; • The protected setting and the views of the listed buildings would be totally changed by up to 6 storey blocks of flats and housing partially built into the woodland; • Views to and from the site, as well as within the site, would also be materially affected; • There is great public concern about the impact of the development on the natural environment of the existing woodland, woodland edge habitats, the wildlife generally, and protected species in particular; • There are known badger setts close to the existing buildings that would be disturbed by any new development and there is no indication of what would happen to them or mitigation measures that would be adopted; • The Craiglockhart Hills are together accepted as one of the iconic seven hills of Edinburgh and it is essential to protect all these hills from new development if the character and enjoyment of Edinburgh is to be preserved;
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• Since the A-listed buildings can be profitably converted, on the evidence of the developer's own report, there is no justification for the request for enabling development to allow them to profit excessively; • The fundamental principle of enabling development is that new development should be the minimum required to enable maintenance and conversion of the original buildings - we cannot accept that the quantum of new building proposed is anywhere near the minimum required; • The proposals do not present viable alternatives, which the community would like to see presented and MCC would welcome an independent opinion on whether the developer has done enough to demonstrate that there are no viable alternative uses; • There is a presumption in an enabling development case that a zero or negative site value be applied but the developer uses the significant figure of £4.7 million; • The proposal will place excessive pressure on local school places, where there is no spare capacity and there is no prospect of school expansion or catchment change; • The proposal will place excessive pressure on the surrounding road network which is already operating close to capacity; • Fears remain that the proposed SUDS may not cope properly with overland run- off in severe storms resulting in large amounts of excess surface water running into Craighouse Road and affecting existing properties; • Serious concerns remain regarding foul water discharge into the combined sewer running under Balcarres Street; • The extent of new roads/car parks on the site will turn areas of green space to tarmac spoiling the character of the site; • Scheme 3 arguably retains a design consistency but the new build is institutional in scale with the Burton and Clouston blocks continuing to dominate the existing neighbouring buildings; • The pitched roof cabin building bears no relationship to any part of the development either existing or proposed; • The amount of new build will substantially damage the environment and hence the enjoyment of the site; • Recent development means Craighouse will be left as the major local green space for walking, recreation and wildlife watching for all those dense developments around the site; • It is unclear from the proposed phasing of the development that the proposals will save New Craig; • In the unwelcome event of significant new build being permitted, the issue of phasing the conversion of existing buildings in parallel with any new build will be critical; and • Sustainability claims could be further addressed by the developer funding improved pathway links to the Happy Valley shopping area. p) Equalities & Human Rights
The proposals have been assessed in terms of Equalities and Human Rights.
Human Rights: The proposed development has the potential to raise issues of air quality which may have an impact on health. There is also the potential for an increase in noise levels and activity within the immediate vicinity which could impact standard of living. However, the imposition of appropriate planning condition will address the
Development Management Sub-Committee – 3 September 2014 Page 76 of 174 12/04007/SCH3 potential negative impacts the development could have in terms of air quality and noise nuisance. Positive impacts of the development are the retention of these nationally important listed buildings and the public access to the open space and woodland to improve health and standard of living. Improved flood defences will also contribute to improvements to standard of living.
Equalities: The development will be accessible for people with physical disabilities in accordance with current standards. It incorporates disabled parking spaces and areas of public realm will make provision for those with physical disabilities. The proposals will impact positively on disabled people.
An Equalities and Rights Impact Assessment has been completed and can be viewed on the Council's website.
Conclusion
The assessment of this application has involved a thorough evaluation and understanding of all aspects of the asset. The proposals have been assessed against the relevant provisions of the development plan and it is concluded that they do not fully accord with development plan policy. The proposed development is contrary to local plan policy to a greater or lesser extent in terms of the impact on the setting of the listed buildings, the impact on the character and appearance of the conservation area, , the impact on landscape character and views to and from the site, the loss of trees and the loss of open space, namely policies Des1, Des3, Des10, Env3, Env6, Env11, Env12 and Os1 of the Edinburgh City Local Plan.
The application has been submitted as an enabling development application where, despite the new build development being contrary to the development plan, they are deemed necessary to fund the restoration and ensure the long term use of these nationally important listed buildings. The applicants have submitted a financial case that demonstrates that the proposed quantum of development is the minimum necessary to secure the retention of this historic asset. This financial appraisal has been audited both internally by Council officials and externally by an independent consultant and the figures that have been presented are accepted.
The restoration and securing the future of the seven, category A listed buildings and the surrounding landscape is the fundamental objective in this instance. The impact of the proposed new development and the associated disbenefits to the historic asset has to be balanced against the public benefits this enabling development will bring. All impacts and material considerations have been considered in the assessment above. It is recognised that the introduction of new build will have an impact on the setting of the historic asset however this will be minimised through appropriate mitigation. It has been shown that compliance with other local plan policy is satisfied. The significance of the public benefits, which crucially not only ensure the long term future of these buildings but retain public access to this historic place to the benefit of the wider community, outweigh the more moderate disbenefits of allowing development contrary to policy. There are no other material considerations which outweigh this conclusion.
It is recommended that planning permission be granted subject to conditions which would ensure any archaeological remains are preserved, details of all external materials and landscaping proposals are given full consideration, residential amenity
Development Management Sub-Committee – 3 September 2014 Page 77 of 174 12/04007/SCH3 and biodiversity will be protected and site investigations and appropriate flooding measures are carried out. A legal agreement will ensure the woodland and rights of access to it are transferred to Council ownership along with a financial contribution to secure its upgrading and long term maintenance, the area of open space is retained and public access to it and that the development will be carried out in accordance with the approved phasing plan to ensure all listed buildings are restored prior to the completion of the enabling new build elements.
In considering an enabling case it is essential that the benefit of the case should be controlled through the planning consent. The transfer of the woodland ownership, the retention of the open space for public use and the phasing of the development are all linked to the enabling case. A legal agreement is recommended to ensure development shall be carried out in accordance with the supporting phasing plan (Appendix 4) of this report. This is required to ensure the heritage benefits are enforceably linked to the enabling development. Development shall comprise phase 1 (Parkland), phase 2 (Woodland) and phase 3 (Western). Infrastructure works for all three Listed Building phases shall be completed prior to the residential occupation of 20% of the residential units within the phase 1 new build elements. This is required to ensure that all listed buildings including phase 2 and 3 are financially viable in their own right. The location of the infrastructure is identified in the Infrastructure Plan (appendix 5) to this report. The extent of the infrastructure shall be specified within a suitable legal agreement. In addition, only 80% of the new build development within Phase 1 can be occupied prior to (practical completion) of all listed buildings elements within Phase 1. The legal agreement and phasing plan shall ensure that 5 of the 7 listed buildings, plus the west wing of New Craig, will be restored in the first phase of development and all listed building conversions are financially viable in their own right.
It is recommended that this application be Granted subject to the details below.
3.4 Conditions/reasons/informatives
Conditions:-
1. No development shall take place until the applicant has secured the implementation of a programme of archaeological work, in accordance with a written scheme of investigation which has been submitted to and approved in writing by the Planning Authority, having first been agreed by the City Archaeologist.
2. A detailed specification, including trade names where appropriate, of all the proposed external materials shall be submitted to and approved in writing by the Head of Planning and Building Standards prior to work commencing on site; Note: samples of the materials may be required.
3. Detailed drawings indicating the arrangement of material junctions on all new build external elevations, shall be submitted for written approval by the Head of Planning & Building Standards prior to the commencement of works on site.
4. Prior to the commencement of works on site, material sample panels, (no less than 2m x 2m) shall be prepared, demonstrating all the proposed external materials and accurately indicating the quality and consistency of future workmanship, for subsequent written approval by the Head of Planning & Strategy.
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5. Setting out drawings for all new build elements will be submitted for written approval prior to the commencement of each phase of the works on site.
6. A detailed landscape phasing plan shall be submitted to and approved in writing by the Head of Planning and Building Standards prior to commencement of work on site.
7. A fully detailed landscape plan for each landscape phase including details of hard and soft surfaces, boundary treatments and all planting numbers shall be submitted to and approved in writing by the Head of Planning and Building Standards before work is commenced on site.
8. On completion of any phase the associated hard and soft landscaping shall be implemented within 6 months and maintained as agreed by the Head of Planning and Building Standards for a minimum of five years.
9. The location of the mitigation bird, bat boxes/tubes shall be submitted for approval by the Head of Planning and Building Standards and shall subsequently be installed prior to the commencement of works on each phase of the development.
10. Should any works fall within a 30 metre radius of a badger sett within the site then further survey work will be required to determine the status of the sett and the requirement of a license from Scottish Natural Heritage. This survey shall be submitted for approval of the Head of Planning and Building Standards.
11. Prior to the commencement of construction works on site: a. A site survey (including initial desk study as a minimum) must be carried out to establish to the satisfaction of the Head of Planning, either that the level of risk posed to human health and the wider environment by contaminants in, on or under the land is acceptable, or that remedial and/or protective measures could be undertaken to bring the risks to an acceptable level in relation to the development; and b. Where necessary, a detailed schedule of any remedial and/or protective measures, including their programming, must be submitted to and approved in writing by the Head of Planning and Building Standards.
Any required remedial and/or protective measures shall be implemented in accordance with the approved schedule and documentary evidence to certify those works shall be provided to the satisfaction of the Head of Planning and Building Standards.
12. Prior to commencement of work, a noise impact assessment shall be submitted to the Head of Planning and Building Standards for confirmation that residents to the Craiglea Place proposed properties will not be adversely affected by noise from the normal operations of the Merchants Golf Club house, to the south east of the application site.
13. The construction phase of the development shall proceed in accordance with the requirements and recommendations of the air quality impact assessment (Wardell Armstrong, ST12296/ES01 November 2012, section 8.7).
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14. The surface water discharge shall be decreased to a level no more than 8.41l/s to accord with the levels previously agreed to satisfaction of the Head of Planning and Building Standards.
15. Detailed design drawings showing the exact location of the 'swale bunds' and the surface water flowpaths will be submitted to and approved in writing by the Head of Planning and Building Standards prior to work commencing on site.
16. A drainage phasing plan shall be submitted to and approved in writing by the Head of Planning and Building Standards prior to commencement of work on site.
17. The drainage infrastructure must be implemented in accordance with the drainage phasing plan as agreed by the Head of Planning and Building Standards.
Reasons:-
1. In order to safeguard the interests of archaeological heritage.
2. In order to enable the Head of Planning Authority to consider this/these matter/s in detail.
3. In order to enable the Head of Planning Authority to consider this/these matter/s in detail.
4. In order to enable the Head of Planning Authority to consider this/these matter/s in detail.
5. In order to enable the Head of Planning Authority to consider this/these matter/s in detail.
6. In order to ensure that a high standard of landscaping is achieved, appropriate to the location of the site.
7. In order to ensure that a high standard of landscaping is achieved, appropriate to the location of the site.
8. In order to ensure that a high standard of landscaping is achieved, appropriate to the location of the site.
9. In the interests of safeguarding biodiversity.
10. In the interests of safeguarding biodiversity.
11. In order to ensure that the site is suitable for redevelopment, given the nature of previous uses/processes on the site.
12. In order to safeguard the amenity of neighbouring residents and other occupiers.
13. In order to safeguard the amenity of neighbouring residents and other occupiers.
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14. In the interests of adequate drainage of the site.
15. In the interests of adequate drainage of the site.
16. In the interests of adequate drainage of the site.
17. In the interests of adequate drainage of the site.
Informatives
It should be noted that:
1. The development hereby permitted shall be commenced no later than the expiration of three years from the date of this consent.
2. No development shall take place on the site until a 'Notice of Initiation of Development' has been submitted to the Council stating the intended date on which the development is to commence. Failure to do so constitutes a breach of planning control, under Section 123(1) of the Town and Country Planning (Scotland) Act 1997.
3. As soon as practicable upon the completion of the development of the site, as authorised in the associated grant of permission, a 'Notice of Completion of Development' must be given, in writing to the Council.
4. The development hereby permitted shall be commenced no later than the expiration of three years from the date of this consent.
5. The Environmental Statement has been taken into consideration in the making of this decision as required under Regulation 3 of the Environmental Impact Assessment (Scotland) Regulations 1999.
6. Consent shall not be issued until a suitable legal agreement, including those requiring a financial contribution payable to the City of Edinburgh Council, has been concluded in relation to: a) Transport infrastructure -
1) All costs associated with the adjustment of the signal timings at the Colinton Road / Myreside Road / Grays Loan / Merchiston Gardens junction as described in the developer's Transport Assessment. (£10K) 2) All costs associated with the Traffic Regulation Orders within the site and within the vicinity of the site (£5K). b) Education infrastructure -
The sum of £335, 997 shall be made to Children and Families to alleviate accommodation pressures in the local catchment area. This will be paid pro rata for each phase of development. £4709 per house and £768 per flat shall be paid prior to
Development Management Sub-Committee – 3 September 2014 Page 81 of 174 12/04007/SCH3 the occupation of the first dwelling of each phase of the development. These figures shall be indexed linked from the date of consent. c) Woodland
1. Prior to the transfer of woodland to Parks and Recreation any landscape works, as identified in an approved landscape phasing plan, within woodland areas W1 and W2 (Appendix 3) shall be carried out and completed by the developer. 2. Woodland areas W1 and W2 shown in the Woodland Plan (Appendix 3), and suitable rights of access, will be transferred to Parks and Recreation, Services for Communities, City of Edinburgh Council prior to the commencement of development. 3. The developer will pay the sum of £150,000 to Parks and Recreation, upon transfer of the woodland area. d) Open Space
Open space situated in the vicinity of the development as shown outlined in the Woodland Plan and Open Space Plan (Appendix 3 ) to this report will remain as open space fully accessible to the general public and remain un-built upon in perpetuity. A suitable title condition to this effect will be imposed upon the area of open space, with the right of enforcement attaching to the landowner of the woodland (i.e. the areas to be transferred to Parks and Recreation).This restriction will also apply to the woodland transferred to Parks and Recreation to ensure it is unbuilt upon. e) Phasing
Development shall comprise phase 1(Parkland), phase 2 (Woodland) and phase 3(Western).
Development shall be carried out in accordance with the supporting phasing plan (Appendix 4) of this report.
Infrastructure and utilities works for all three Listed Building phases shall be completed prior to the residential occupation of 20% of the residential units within the phase 1 new build elements.
The location of the infrastructure is identified in the Infrastructure Plan (Appendix 5) to this report.
All utilities required for the re-development of all of the listed buildings will be taken to a point immediately adjacent to each of the listed buildings and, where appropriate, capped. For the avoidance of doubt the definition of utilities shall include:
1. Electricity supply, including the relocation of the sub station; 2. Domestic water supply; 3. Mains gas supply; 4. Connection to sewerage; 5. Such ducting as is required for telecoms provision; 6.Road access to all of the listed buildings as set out in the Appendix 5; 7. Parking provision for the listed buildings as set out in the Appendix 5; and
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8. A Sustainable Urban Drainage Scheme with sufficient capacity to serve the site as a whole following the completion of the entire development scheme (listed buildings and enabling development).
All to have sufficient capacity available, notwithstanding the development of the enabling development, to supply the residential re-development of the listed buildings envisaged in the application.
Only 80% of the new build development within Phase 1 can be occupied prior to (practical completion) of all listed buildings elements within Phase 1.
7. The applicants are advised that technical approval and acceptance by Scottish Water will be required to carry out remedial work on an existing Scottish Water sewer pipeline.
8. Surveys have indicated that bats are present on the site and buildings do have roost potential, however at the current time no evidence of roosting was seen. Information gained from previous surveys 2011/2012/2013 indicate that general bat use is low and largely consists of foraging bats moving around the area. The one roost identified in 2011 was small and unlikely to be a maternity roost. No other roosts have been located even though there is a potential or uncertainty in some of the buildings.
Bats are a European Protected Species protected under the habitat regulations 1994, as amended. The council must satisfy itself in its statutory duties under the above regulations, that the licensing tests are able to be met. The applicants are advised that advice from SNH indicates that this is likely to be the case. It is recommended that the following ES recommendations should be adhered to:
• Further surveys required where detailed design identifies the need for roof works or repairs, particularly in buildings with high roost potential. A follow up survey also required for any roof works around the confirmed roost to provide up to date information for any licence application if required.
• To discuss bat licence requirements with SNH depending on the nature of the building/roof works undertaken.
• Undertake mitigation as necessary e.g. roost provision in the buildings or woodland.
• Soft fell all mature trees identified as having roost potential, where they have to be removed as part of any woodland or development.
Consideration should be given to developing a species management plan for the site.
9. The Traffic Regulation Order will be applied for prior to the commencement of works on site.
10. Noise from the clubhouse should not exceed noise rating NR15 (inaudibility) in the nearest proposed residential property.
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11. The applicants are advised that a method statement for the removal of invasive weeds should be undertaken and the removal of invasive weeds (e.g. Japanese Knotwood) started prior to the commencement of Phase One.
12. A Tree Preservation Order covering the entire site shall be pursued by City of Edinburgh Council to ensure the existing trees and the mitigation planting are safeguarded in the long term.
Financial impact
4.1 The financial impact has been assessed as follows:
The application is subject to a legal agreement for developer contributions. Risk, Policy, compliance and governance impact
5.1 Provided planning applications are determined in accordance with statutory legislation, the level of risk is low. Equalities impact
6.1 The equalities impact has been assessed as follows:
This application was assessed in terms of equalities and human rights. The impacts are identified in the Assessment section of the main report. Sustainability impact
7.1 The sustainability impact has been assessed as follows:
This application meets the sustainability requirements of the Edinburgh Design Guidance. Consultation and engagement
8.1 Pre-Application Process
In line with planning legislation, a Proposal of Application Notice (11/02543/PAN) was submitted on 3 August 2011 to the Council as planning authority with a copy provided to Craiglockhart and Morningside Community Councils. Further consultation was also carried out with South West and South Central Neighbourhood Partnerships, Edinburgh World Heritage Trust, The Cockburn Association, Friends of Craiglockhart Woods, Morningside Heritage Association and the local ward members.
The first public consultation was held in Old Craig over three days in September 2011. The exhibition was attended by approximately 800 people with 204 surveys returned. Issues raised included vehicular access; the extent of public access, the design of land forms, the impact upon trees, the design of new buildings and the maintenance of open space.
Further consultation took place at the Eric Liddell Centre, Boroughmuir Rugby Football Club and Old Craig in March 2012 to discuss more detailed proposals. Approximately 200 people attended the event. In addition to the issues highlighted above, the matters
Development Management Sub-Committee – 3 September 2014 Page 84 of 174 12/04007/SCH3 of building heights, impact upon local schools and financial justification for development were also raised.
Outwith the consultation events, the applicants have also sought to engage with the Craighouse Community Liaison Forum Group; undertake a 'Meet the Streets' exercise, and keep political representatives informed of progress.
The proposals were considered by the Edinburgh Urban Design Panel on 28 September 2011. The Panel's report is set out in Appendix A of this report. A series of workshops was held with Architecture & Design Scotland (ADS) over the summer of 2012. A copy of the ADS pre-application report is available to view via the Planning and Building Standards Online Services. ADS' consultation response is set out in full in Appendix A.
A copy of the Pre-Application Consultation report is available to view via the Planning and Building Standards Online Services.
8.2 Publicity summary of representations and Community Council comments
The application (Scheme 1) was advertised on 20 November 2012 and 1309 letters of representation were received 1185 objecting and 124 letters in support. Two petitions were received, one petition of objection with 5640 signatories and an additional petition of 5 signatures from the Carnethy Hill Running Club.
The letters of objection include letters from: Ian Murray MP, Jim Eadie and Alison Johnston MSPs, Councillors Andrew Burns, Melanie Main, Gavin Corbett and David Key.
The following community councils have also commented: Morningside Community Council, Craiglockhart Community Council and Merchiston Community Council, all statutory consultees. In addition Grange Prestonfield Community Council, Toll Cross Community Council and Gorgie and Dalry Community Council have also submitted comments.
The following amenity bodies / interest groups have submitted comments: Architectural Heritage Society of Scotland, The Cockburn Association, The Garden History Society, Friends of Craighouse, Friends of Corstorphine Hill, Woodland Trust Friends of Craiglockhart Wood and Nature Trail, Morningside Court Residents Association, Friends of Braidburn Valley Park, Royal Park Terrace and Spring Gardens Residents Association, Fairmilehead Association, Scottish Wildlife Trust and the Lothian and Borders Badger Group.
The following material issues have been raised: • Principle of development; • Scale and design of the proposed development; • Impact upon the historic environment; • Impact upon landscape character, biodiversity and key views; • Road and pedestrian safety; • Capacity of existing infrastructure and provision of affordable housing; • Impact upon flood risk; • Open space and rights of way;
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• Sustainability; • Residential amenity; and • The case for enabling development.
The application (Scheme 2) was advertised on the 13 December 2013 on receipt of changes to the proposals. A 1140 letters of representation were received, 1133 objecting to the proposals, 4 in support and 3 neutral comments.
The letters of objection include letters from Cockburn Association, Architectural Society of Scotland, Spokes, Friends of Craighouse, Friends of Braidburn Valley Park, South Morningside Primary School - Parent Council, Alison Johnstone MSP, Jim Eadie MSP, Ian Murray MP, Councillors Paul Godzik, Mark McInnes, Gavin Corbett, and Melanie Main.
Jim Eadie MSP also submitted a questionnaire on the scheme completed by local residents. This detailed 104 comments opposing the proposals and 4 comments in support.
The following community councils have also commented Morningside, Craiglockhart, Merchiston, Grange/ Prestonfield and Gorgie Dalry.
The following material issues have been raised: • Principle of development; • Scale and design of the proposed development; • Impact upon the historic environment; • Impact upon landscape character, biodiversity and key views; • Road and pedestrian safety; • Capacity of existing infrastructure and provision of affordable housing; • Residential amenity; • Open space and Rights of Way; and • The case for enabling development.
The application (Scheme 3) was advertised on 6 June 2014 and 1153 letters of representation were received, with 1139 objecting and 14 letters in support.
The letters of objection include letters from: Ian Murray MP and Councillors Andrew Burns, Melanie Main, and Mark McInnes.
The following community councils have commented: Morningside Community Council and Craiglockhart Community Council as statutory consultees and in addition, Grange Prestonfield Community Council, Tollcross Community Council, Currie Community Council and Gorgie Dalry Community Council have also submitted comments. Merchiston Community Council was formally consulted as a statutory consultee but has not offered any comments in respect of Scheme 3.
The following amenity bodies / interest groups have submitted comments: Architectural Heritage Society of Scotland, The Cockburn Association, Friends of Craighouse, Spokes, Craiglea Place Proprietor's Association and the South Morningside Primary School Parent Council.
The following material issues have been raised:
Development Management Sub-Committee – 3 September 2014 Page 86 of 174 12/04007/SCH3 • Principle of development; • Scale and design of the proposed development; • Impact upon the historic environment; • Impact upon landscape character, biodiversity and key views; • Road and pedestrian safety; • Capacity of existing infrastructure and provision of affordable housing; • Open space and Rights of Way; • Residential amenity; and • The case for enabling development.
A full assessment of the representations can be found in the main report in the Assessment section. Background reading / external references
• To view details of the application go to • Planning and Building Standards online services
David R. Leslie Acting Head of Planning and Building Standards Contact: Emma Wilson, Planner Email: [email protected] Tel: 0131 529 3634
Contact: Emma Wilson, Planner Statutory Development The application site is identified within the Edinburgh Plan Provision City Local Plan as being part of a wider area of open space. The site is also identified as part of an Area of Great Landscape Value and being within the Craiglockhart Hills Conservation Area. Part of the site is within a Local Nature Reserve and part is within a Local Nature Conservation Site.
Date registered 27 May 2014
Drawing numbers/Scheme 1-32, 33A, 34-49, 33A, 50A-54A, 55-202,
Scheme 3
Links - Policies
Relevant Policies:
Relevant policies of the Edinburgh City Local Plan.
Policy Des 1 (Design Quality and Context) sets general criteria for assessing design quality and requires an overall design concept to be demonstrated.
Policy Des 2 (Co-ordinated Development) establishes a presumption against proposals which might compromise the effective development of adjacent land or the wider area.
Policy Des 3 (Development Design) sets criteria for assessing development design.
Policy Des 4 (Layout Design) sets criteria for assessing layout design. Policy Des 5 (External Spaces) sets criteria for assessing landscape design and external space elements of development.
Policy Des 6 (Sustainable Design & Construction) sets criteria for assessing the sustainable design and construction elements of development.
Policy Des 10 (Tall Buildings) sets out criteria for assessing proposals for tall buildings.
Policy Env 1 (World Heritage Site) protects the quality of the World Heritage Site and its settings.
Policy Env 3 (Listed Buildings - Setting) identifies the circumstances in which development within the curtilage or affecting the setting of a listed building will be permitted.
Policy Env 5 (Conservation Areas – Demolition of Buildings) sets outs criteria for assessing proposals involving demolition of buildings in conservation areas.
Policy Env 6 (Conservation Areas Development ) sets out criteria for assessing development in conservation areas.
Policy Env 8 (Protection of Important Remains) establishes a presumption against development that would adversely affect the site or setting of a Scheduled Ancient Monument or archaeological remains of national importance.
Policy Env 9 (Development of Sites of Archaeological Significance) sets out the circumstances in which development affecting sites of known or suspected archaeological significance will be permitted.
Policy Env 11 (Landscape Quality) establishes a presumption against development which would adversely affect important landscapes and landscape features.
Policy Env 12 (Trees) sets out tree protection requirements for new development.
Policy Env 15 (Sites of Local Importance) identifies the circumstances in which development likely to affect Sites of Local Importance will be permitted.
Policy Env 16 (Species) sets out species protection requirements for new development.
Policy Env 17 (Flood Protection) sets criteria for assessing the impact of development on flood protection.
Policy Env 18 (Air, Water and Soil Quality) sets criteria for assessing the impact of development on air, water and soil quality.
Policy Os 1 (Open Space Protection) sets criteria for assessing the loss of open space.
Policy Os 3 (Open Space in New Development) sets out requirements for the provision of open space in new development.
Policy Hou 1 (Housing Development) supports housing on appropriate sites in the urban area, and on specific sites identified in the Plan.
Policy Hou 2 (Housing Mix) requires the provision of a mix of house types and sizes in new housing developments.
Policy Hou 3 (Private Open Space) sets out the requirements for the provision of private open space in housing development.
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Policy Hou 4 (Density) sets out the factors to be taken into account in assessing density levels in new development.
Policy Hou 5 (Conversion to Housing) sets criteria for assessing the change of use to residential.
Policy Hou 7 (Affordable Housing) requires 25% affordable housing provision in residential development of twelve or more units.
Policy Hou 8 (Inappropriate Uses in Residential Areas) establishes a presumption against development which would have an unacceptable effect on the living conditions of nearby residents.
Policy Com1 (Community Facilities) sets requirements for the provision of community facilitiesassociated with large scale residential development, and the proptection of existing community facilities.
Policy Com2 (School Contributions) sets the requirements for school contributions associated with new housing development.
Policy Tra 1 (Major Travel Generating Development) supports major travel generating development in the Central Area, and sets criteria for assessing major travel generating development elsewhere.
Policy Tra 2 (Planning Conditions and Agreements) requires, where appropriate, transport related conditions and/or planning agreements for major development likely to give rise to additional journeys.
Policy Tra 4 (Private Car Parking) requires private car parking provision to comply with the parking levels set out in supplementary planning guidance, and sets criteria for assessing lower provision.
Policy Tra 5 (Private Cycle Parking) requires cycle parking provision in accordance with levels set out in supplementary guidance.
Policy Tra 6 (Design of Off-Street Car and Cycle Parking) sets criteria for assessing design of off-street car and cycle parking.
Policy Tra 1 (Major Travel Generating Development) supports major travel generating development in the Central Area, and sets criteria for assessing major travel generating development elsewhere.
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Relevant Non-Statutory Guidelines
Non-Statutory guidelines Edinburgh Design Guidance supports development of the highest design quality and that integrates well with the existing city. It sets out the Council's expectations for the design of new development, including buildings and landscape, in Edinburgh.
Non-statutory guidelines 'LISTED BUILDINGS AND CONSERVATION AREAS' provides guidance on repairing, altering or extending listed buildings and unlisted buildings in conservation areas.
Non-statutory guidelines on Developer Contributions and Affordable Housing gives guidance on the situations where developers will be required to provide affordable housing and/or will be required to make financial or other contributions towards the cost of, providing new facilities for schools, transport improvements, the tram project, public realm improvements and open space.
Non-statutory guidelines on 'PARKING STANDARDS' set the requirements for parking provision in developments.
NSESBB Non-statutory guidelines Part B of 'The Edinburgh Standards for Sustainable Building' sets principles to assess the sustainability of major planning applications in Edinburgh
Other Relevant policy guidance
The Craiglockhart Hills Conservation Area Character Appraisal emphasises the outstanding quality of the natural topography and its visual relationship with the city, the high quality buildings set within a mixture of wooded and open slopes, the use of natural stone and slate as the traditional building materials.
The Plewlands Conservation Area is mainly comprised of two storey residential terraced development. The predominant height is two storeys with a small number of flatted elements of mainly three and four storeys. The buildings are complemented by mature trees, extensive garden settings, shallow stone boundary walls and spacious roads.
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Appendix 1
Application for Scheme 3 12/04007/SCH3 At Napier University Craighouse Campus, Craighouse Road, Edinburgh Proposed change of use + conversion of existing buildings from university campus to residential, construction of new build residential with ancillary development, public realm, utilities infrastructure, access roads, car parking, landscaping.
Consultations
Edinburgh Urban Design Panel
1. Introduction 1.1 This report relates to proposals for the redevelopment of Craighouse Campus.
1.2 The brief for the project envisages the conversion of the range of existing listed buildings to residential use and the incorporation of new build residential. In addition changes are proposed to the access arrangements and to the landscape.
1.3 This is the first time that the proposals have been reviewed.
1.4 No declarations of interest were made by any panel members in relation to this scheme.
1.5 This report should be read in conjunction with the pre meeting papers which provide an overview, context, concept, plans, sections and 3D visualisations of the scheme.
1.6 This report is the view of the Panel and is not attributable to any one individual. The report does not prejudice any of the organisations who are represented at the panel forming a differing view about the proposals at a later stage.
2 The Panel's views on enabling development 2.1 The proposed level of additional new development within the site to "enable" the maintenance and development of the existing listed buildings and grounds may have some merit was explored in relation to the ongoing costs.
2.2 For the case to be made for enabling development it is vitally important that its need is demonstrated through a robust and persuasive financial appraisal of the costs of maintaining the listed buildings and site in the future.
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2.3 Any enabling development should be phased with the redevelopment of the listed buildings themselves. This will ensure that the benefits of the enabling development are directly linked to the listed buildings.
2.4 Alongside this, it is essential that the site is considered as a whole with the proposed improvements to the landscape and access taking place at the same time as the development of buildings.
2.5 Because of the site's sensitivities, constraints and significance it is crucial that any new buildings are of the highest architectural quality. If the case can be made for enabling development, the size and scale of any new buildings should be the minimum that is required to enable the maintenance of the original buildings.
3 The Panel's views on layout and impacts on listed buildings 3.1 Broadly the strategy of location of new buildings within the site seems reasonable provided that the massing and height of the buildings are appropriate. This stated, there are 2 areas of development which merit closer examination.
- South East Development Area - There is concern about the proposal to build on the South East of the site on the edge of the ridge in relation to the conflict this will have on the public routes through the site. Currently in there is a sense of being on a rural walk and it is difficult to see how this quality can be maintained if the site is built on.
- Old Craig - The design of the steading development proposed to the east of Old Craig would require to be handled very carefully to ensure that it does not have an adverse impact on the setting of the listed buildings, particularly Old Craig itself. While it is possible to envisage a development within this site it is important that it is of an appropriate scale and quality.
3.2 Making use of the existing stair cores seems a sensible approach to fitting residential accommodation into the existing listed buildings.
4 The Panel's views on landscape 4.1 The proposed land forms running through the open space at the South East of the site are intriguing and have the potential to enhance the quality of this landscape.
4.2 Ensuring enduring public use of this space is encouraged.
5 The Panel's views on access and parking 5.1 The proposed new access would provide significant benefits for the development of the site. Its alignment with New Craig rightly strengthens the importance of this building within the site. The access also helps provide Old Craig with a new and fitting setting and create a logical development site to one side of the proposed avenue rather than straddling the access road.
5.2 Car parking will require to be carefully integrated into the proposals to ensure that it does not have adverse visual impacts.
6 Other matters 6.1 The long term maintenance and management of the site should be considered at this early stage. A coherent management plan should be put in place. The notion of the
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6.2 It has been useful to understand the importance of the history of the site in informing strategic design decisions. It would be helpful if this could be made clear in any future explanation of the proposals, for example at the planning application stage.
6.3 The previous proposals for the development of the site would not enhance the site and therefore it is not considered that much weight should be ascribed to them in any future assessment of the proposals.
7 Summary 7.1 Clearly, the design is at an early stage, however the approach taken thusfar is applauded. The subtlety of the series of individual design moves cumulate to create a proposal of significant ambition. It will be important to carry this level of aspiration through the continued design process. The proposed new access in particular is likely to have significant benefits to the design as a whole.
7.2 In developing the proposals further the matters raised in this report should be addressed. It will be very important to ensure that there are no adverse impacts upon the setting of the listed buildings, that the quality of the public access in and around the site is maintained.
Morningside Community Council - Scheme 1
I write on behalf of Morningside Community Council to object to the above development in the strongest terms.
This objection reflects opinions expressed at several Morningside Community Council meetings over recent months, by local groups at meetings of the Craighouse Forum and also at a public meeting called by the Community Council on 7th December 2012. Directly following that meeting, an exhibition of plans was held at Morningside Library.
After this, the Community Council undertook its own survey of opinions. Around 3,400 questionnaires were delivered in the area south of Balcarres Street and west of Comiston Road with some patchier cover in other parts of Morningside. Questionnaires were also available in the Library and on our website. Of 200 responses received, around 80% of respondents found the plans unacceptable and 85% thought the CC should continue to oppose the development.
At the CC meeting on 21 March 2012, the following resolution was adopted: "If the planning application for the Craighouse site proposes new development on areas which are designated in the Edinburgh City Local Plan as Open Space and/or Areas of Great Landscape Value, we will submit an objection." This was based on the original plans and reflected the views of the majority of residents who had contacted us expressing fears about the loss of valuable green space to new building and loss of public access to a much-loved recreational area.
In subsequent months, the Community Council met the developers on three occasions, at their request, to discuss proposed amendments to the original proposal. Whilst these amendments were quite significant and did address a number of the main
Development Management Sub-Committee – 3 September 2014 Page 94 of 174 12/04007/SCH3 criticisms of the original plans, they failed to address the primary cause of opposition namely the unwanted, unjustified and hence inappropriate development on protected Open Space.
In this context, it is appropriate to comment on the extent of the developer's efforts to liaise with local community groups during the consultation period prior to the submission of the planning application. (At the meeting with your planning colleagues on 3rd December 2012, you specifically asked for the Community Council's views on this.) We do not doubt the developer's claim that they have held some 50 meetings with local groups over the last nine months. Whilst this could well be considered exemplary, with real changes being offered, it is also a reflection of how much opposition to their plans the developer faces within Morningside and beyond.
At the most recent Community Council meeting on 19th December 2012, members voted overwhelmingly in support of their continuing objection to the development on the grounds detailed below:
1. The development is contrary to the Local Development Plan, specifically policies ENV 3, 5, 6, 11, 12, 15, possibly 16, and 18. Also Os 1. 2. The development is contrary to Scottish Planning Policy SPP 11 Open Space and Physical Activity. 3. The development is proposed within Designated Open Space and an Area of Great Landscape Value. 4. The development is inconsistent with the Craiglockhart Hills Conservation Area Character Appraisal. 5. A significant area of existing woodland is planned for clearance; hence the new development will impact significantly on the biodiversity of the site and the directly adjacent Easter Craiglockhart Hill Local Nature Reserve. 6. The scale of new development will radically change the historic and protected setting of the "A"-listed buildings contrary to Edinburgh City Local Plan Policy Env 3. 7. Views to and from the site are protected; the development will have an adverse impact on such views particularly skyline views. 8. No financial evidence has been presented to prove the need for new build to compensate for the "Conservation Deficit" claimed in respect of the conversion of the existing buildings. 9. The existing listed buildings have a consistent architectural style. No such consistency, or "Design Coherence" as the developer claims to show, appears to exist in the proposed new buildings e.g. between proposed Clouston, Duncan, Kings Craig, North Craig and Old Craig Grove designs. 10. The proposed height of the Clouston 8-storey tower building is excessive and unacceptable, as it will intrude into the otherwise rural landscape views from Glenlockhart Road and parts of Greenbank. 11. The excessive new building proposed is in part due to the obligation to fund offsite social housing. This obligation should be altered to reduce the demand for new build on such a sensitive site. 12. The development lies within the catchment area of South Morningside School which already operates unacceptably across three sites and cannot entertain further demand for primary places. The proposed development will inevitably impact upon this issue. 13. Any new development must ensure a phased refurbishment of the listed buildings in parallel with any new build, so that existing buildings are not left to decay.
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14. Morningside Community Council is not satisfied that the provisions for drainage from the development will be enough to prevent an increase in the already high risk of flooding in Balcarres Street. We are concerned about both existing sewer capacity and the long term efficacy of the on-site SUDS.
In the light of the above concerns and objections, Morningside Community Council requests that planning application 12/04007/FUL be refused.
Morningside Community Council - Scheme 2
I refer to Morningside Community Council's letter of objection, dated 28 December 2012, to what is now referred to as Scheme 1 for the above development. Members of the Community Council have now had the opportunity to consider the revised Scheme 2 for the development.
To gauge public opinion on this Scheme 2, the Community Council called a special public meeting at St Peters School on Wednesday 8th January 2014 at which some 110 people attended. Drawings of the revised proposals were displayed to aid understanding of the proposals. The meeting overwhelmingly mandated the Community Council to sustain its earlier objection to the development and to add more points of objection, as raised at the meeting. This letter seeks to collate community concerns and bring them to the City Council's attention.
At the Community Council's regular meeting on 15th January 2014, this action and the expanded form of objection was approved by members of the Community Council.
The public meetings held by MCC to hear views from the community have expressed a resounding view that, whilst the conversion of the existing buildings is welcome, the planned extent of new buildings is totally unacceptable. The apparent evidence that public criticism of Scheme 1 has lead to an even greater number of new properties being proposed in Scheme 2 appears to have hardened attitudes against any new buildings. Opposition to Scheme 2 is based on many material considerations which may be summarised as follows:
Policies: It appears necessary to reiterate that the proposed Scheme 2 development would breach many of the adopted Edinburgh City Local Plan Policies including ENV 3, 5, 6, 11, 12, 15, possibly 16, and 18. There are particular concerns that the development would breach policy ENV 17 having regard to the risk of flooding from the development to which further reference will be made.
One of the most important policies in relation to this highly protected site is Policy Os 1 which ".....seeks to protect all open spaces, both public and privately owned, which contribute to the amenity of their surroundings and the city, which provide or are capable of providing for the recreational needs of residents and visitors or which are an integral part of the city's landscape and townscape character and its biodiversity… It will be more important to protect open spaces in the future, as the population of parts of the city increases and brings added pressure on existing resources". The proposed development would be a clear breach of this policy.
Craighouse is not designated for housing in the Local Plan and, with all the above policies in place, Craighouse should be protected from development. It should be
Development Management Sub-Committee – 3 September 2014 Page 96 of 174 12/04007/SCH3 remembered that many of the green areas around the site have been substantially developed in the last two decades, including the former Greenlea Nursing Home, the former City Hospital, Meggetland and Meadowspot. By virtue of this reduction in greenspace elsewhere, the protected Craighouse site has become a very important recreational area and a much used and appreciated beauty spot for this increased population.
Looking forward, there is already a substantial redevelopment of the Royal Edinburgh Hospital site in Myreside proposed, and potential development of greenspace at the Astley Ainslie site in Morningside. These foreseeable developments make it all the more important to protect this very important Craighouse site for the increased urban landscape and for the population to retain an important natural greenspace and wildlife site in this area.
It is noted that the Edinburgh Local Development Plan - "Proposed Plan March 2013" carries forward these same policies. Craighouse is not designated for housing in this new document.
Designations: This site has many important designations not only as Open Space but also as a Local Biodiversity Site, Nature Conservation Site and Area of Great Landscape Value. These designations are considered incompatible with any newbuild. Craighouse is one of only 8 Areas of Great Landscape Value in whole Edinburgh area - others include the Hermitage of Braid, the Botanical Gardens and Arthur's Seat. It should therefore be protected against this excessive and dominating newbuild and its associated infrastructure that would ruin this beautiful area.
Craiglockhart Hills Conservation Area: The proposed development is considered incompatible with the Conservation Area status of the site since the newbuild cannot be considered as likely to enhance the site. The landscape setting of the listed buildings is part of what justifies their status as listed buildings. The Craiglockhart Character Appraisal speaks of "Victorian buildings against dramatic landscape backdrops". The newbuild does not reflect that character. The protected setting and views of the A- listed buildings would be totally changed for the worse by large 5 to 7 storey blocks of flats partially built into the woodland.
Views to and from the site, as well as within the site, would also be materially affected. The Character Appraisal Overview identifies that "the area encompasses a mosaic of habitats which are exceptional within a city environment".
Impact on the natural environment: Notwithstanding the formal designations referred to above, there is great public concern about the impact of the development on the natural environment of the trees, the wildlife generally, and protected species in particular. This will be particularly acute during the long period of construction works. There are known badger sets close to the existing buildings which would be disturbed by any new development. Overall, there is a significant and permanent loss of habitat. Most of the development sites are on Local Nature Conservation Sites which become Local Biodiversity Sites in the Proposed Plan March 2013.
Edinburgh's Seven Hills: The Craiglockhart Hills are accepted as one of the iconic seven hills of Edinburgh and it is considered essential to protect all these hills from new development if the character and the enjoyment of Edinburgh, both as a place to live
Development Management Sub-Committee – 3 September 2014 Page 97 of 174 12/04007/SCH3 and as one of the most beautiful cities in the world, is to be preserved for the future. In the event that permission was granted for this development, it would be increasingly difficult to defend other hills and green spaces from similar development.
The Questionable Financial case: Since the A-listed buildings can be profitably converted, on the evidence of the developers' own financial report, there is no justification for the request for 'Enabling Development' to allow them to profit excessively.
It is a fundamental principle of Enabling Development that the size and scale of any new buildings should be the minimum that is required to enable the maintenance and conversion of the original buildings. The Community Council cannot accept that the quantum of new building proposed across seven separate blocks of construction is anywhere near the minimum required.
English Heritage Enabling Development Policy: The developer has stated in their Enabling Case Report - November 2013, that their proposals meet the criteria for Enabling Development as set out in the English Heritage Policy Document "Enabling Development and the Conservation of Significant Places". However, English Heritage set out seven key criteria, all of which must be met in order to justify an Enabling Development Case. Morningside Community Council does not believe that the developers have adequately proved that any of these criteria have been met by their proposals.
In opting to pursue planning consent through the use of an Enabling Development case, the developer has selectively used parts of English Heritage policy which may support the case, while ignoring important areas of policy which do not. The very first condition of English Heritage's criteria is that "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". The proposed development does not stand up to this test.
A further example of policy being ignored is: "2.4 The role and responsibilities of the developer - explore a range of alternative development strategies". In their Enabling Case Report - November 2013, the developer details at length the alternative development strategies proposed by rival bidders for the site. However, there is no evidence that this developer in particular has explored a range of alternative strategies, nor have they complied with the key requirement: "4.7.1 Before any enabling development is considered the applicant normally needs to demonstrate that real efforts have been made, without success, to continue the present use or to find compatible alternative uses for the place. This should normally include the offer of the unrestricted freehold or long leasehold (125 years or more) on the market at a realistic price reflecting the condition of the place, and, so far as ownership allows, with an appropriate curtilage.
The proposals do not present viable alternatives which local residents, as a community, would like to see presented. There were 6 bids for the site when it was last put on the market and since then, the current owners have not tested to see if the site would sell for an alternative use.
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Morningside Community Council would welcome an independent opinion on whether the developer has done enough to demonstrate that there are no viable alternative uses, as is required by section 2.4 of the English Heritage guidelines.
Other references to the English Heritage criteria are relevant: The English Heritage Guidelines warn that Enabling Development should always be a subsidy of last resort due to its inefficiency. They quote enabling development of a value of 3 or 4 times the conservation deficit as an example of this inefficiency. However, the Craighouse Partnership are pursuing an enabling development of a value of almost 13 times the claimed conservation deficit - 4 times the amount that English Heritage Guidelines use as an example of inefficiency!
It adds that the enabling development itself will have a threshold above which the further infrastructure costs involved (roads, sewage and other services) requires more enabling development: and that this threshold should also be identified as a key constraint. The application at Craighouse requires substantial infrastructure costs much of which are associated with the newbuild - at nearly 13 times the conservation deficit and with large infrastructure costs predominantly associated with the newbuild - this cannot be said to be a minimum and would seem to have crossed this threshold.."
The scale of these proposals is thus out of all keeping with the 'problem' of these buildings, which should be highly valuable and relatively easy to convert.
Disposal Values of Existing Properties: The developer's proposals fail to show consideration of the final values of the existing buildings, after conversion, depending on whether they look out on woodland and the natural environment, or whether occupants would look out on closely adjacent modern flatted development and town houses. Community Council members anticipate a significant difference between such values and they are strongly of the view that this would have an equally significant impact on the amount of the calculated Conservation Deficit. Community Council members also believe that the properties will be more valuable without all the newbuild. This leads members to question whether there is any such deficit.
The community struggles with the proposed valuations which are significantly less than the average for EH10. There is a large consensus in the community that these proposed properties will be very desirable and very valuable.
The proposed development is being argued on the basis it will 'save' the listed buildings. However, the public harm caused by these proposals will impact wildlife, schools, transport, public green space, beautiful views as well as making the buildings much less visible and spectacular for the public. It is also extremely unclear from the proposed phasing of the development that the proposals will even save New Craig.
Excessive Pressures from the Development: The proposed development will place excessive pressure on local school places, primarily at South Morningside Primary School, where there is no spare capacity, and on traffic levels in the surrounding road network which is already felt to be operating close to capacity.
Drainage: The potential impact of any newbuild development on the surface water and foul drainage system of the Craighouse site is a particular concern as Balcarres Street is already experiencing serious periodic flooding. The current proposals do not take
Development Management Sub-Committee – 3 September 2014 Page 99 of 174 12/04007/SCH3 into account the potential impact of the parallel development at 21/22 Balcarres Street. The new buildings will greatly increase the amount of hard surface on the site and hence the potential for surface run-off during intense rainfall. Whilst the proposed SUDS drainage system may cope under normal conditions, the Community Council members feel that the drainage strategy should more clearly and specifically address overland run-off in severe storms, which could result in large amounts of excess surface water running down the access roads into Craighouse Road potentially affecting the flats at the west end of Craighouse Gardens.
Residents are also concerned about the foul water discharge into the combined sewer running under Balcarres Street. There are acknowledged capacity issues downstream and a propensity to flooding in both Morningside Road and Balcarres Street. The Community Council understands that Scottish Water and CEC are analysing the problems with the sewer and the culverted Jordan Burn. Until this study is complete, and the problems better understood, the Community Council objects to further large- scale connection into this system from Craighouse.
Car Parking: Community Council members are very concerned at the potential impact that up to 325 extra vehicles will have on congestion on local roads considered by local residents to be already at capacity. The extent of new roads/car parks on the site will turn areas of this green Open Space to tarmac spoiling the character of the site contrary to all policies and designations. Even with this level of parking provision, the outcome could be yet further loss of amenity by use of open spaces as informal parking lots by 2- and 3-car households.
Design Consistency: The Scheme 2 proposals arguably demonstrate a greater design consistency (the lack of which was criticised in Scheme 1) but at the expense of the latest structures being over-bearingly large in bulk and height. The reduction in the height of the Clouston Tower is welcome, if marginal, however its footprint has greatly increased and its gross internal area increased to 4.8 times that of South Craig demonstrating clearly that this building will dominate South Craig in an unacceptable manner. Similarly, the very large block of four town houses to be sited at the top of Craiglea Place now bears no relationship in scale to the existing Victorian terraced houses and no longer offers a "discreet extension" to this fine terrace. The Burton and Napier blocks are institutional in scale whereas in such a sensitive site they should be subservient and complimentary particularly to the nearby Old and New Craig.
Impact on the Community: Much is being written on the impact of the current proposals on the built environment but the strongest message being conveyed to Morningside Community Council members is the impact on the local community for whom the Craighouse Campus has become their recreational space where all kinds of physical activity are enjoyed and where the natural environment is greatly appreciated. This use of the area feeds straight into Scottish Government ambitions to improve the health and wellbeing of all citizens. It is widely felt that the amount of new build will substantially damage the environment and hence the enjoyment of the site. This is borne out in the many objections being raised by local residents and shared with the Community Council.
The Craighouse site has been encroached on all sides by development and the community now has this critical protected space, which is used by communities on all sides, from Craiglockhart and The Steils, to the City Hospital Development,
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Meggetland, Shandon, Ashley, Polwarth, Merchiston, as well as Plewlands, and Morningside. It is of a sufficient scale that makes it viable as a natural space for walking and for nature appreciation. Many of the other surrounding green spaces have been fully developed and the green space at the Royal Edinburgh Hospital will soon be developed too. That means Craighouse will be left as the major local green space for walking, recreation and wildlife watching for all those dense developments round about.
There is a high priority in Health and Social Care to prioritising social prescribing (non medical interventions). This goes beyond referring people to gyms and other institutional leisure facilities it includes accessing greenspaces which contributes to a sense of belonging. It can promote individuals 'spiritual' wellbeing which also has a positive impact on a person's mental health. In a recent Lothian's Joint Mental Health and Wellbeing Strategy Programme document "A Sense of Belonging - A Joint Strategy for Improving the Mental Health and Wellbeing of Lothian's Population 2011-2016", paragraph 14 on Greenspace, sub-para 14.1, states: "There is increasing evidence of the influence of the environments that we experience throughout our lives on both our physical and mental health and wellbeing. Good quality greenspaces provide low-cost opportunities to take part in physical activity which we know have a positive impact on mental health. Good quality greenspace can also provide opportunities for people to meet and engage with friends and neighbours and well as provide identity to neighbourhoods".
The Heritage Objective and Phasing: In the unwelcome event of significant newbuild being permitted, the issue of phasing the conversion of the existing buildings in parallel with any newbuild will be critical in ensuring that the existing buildings are not left to decay. This will ensure that the benefits of any enabling development are directly linked to the listed buildings. This must be an enforceable link to the heritage objective. If the developer were to complete the new build ahead of the conversion, then the financial viability of converting the existing buildings would be unchanged. The Council should consider requiring the developer to take out a performance bond to cover such an eventuality.
Sustainability: The developers claim that many aspects of the development are sustainable however it can be anticipated that the distance from shopping facilities will lead to significant car use by residents. This could be addressed to a welcome degree by requiring the developer to fund improved pathway links to the "Happy Valley" shopping area, just north of the site but currently separated from it due to the absence of footways.
Quality of plans and accompanying information: At the Community Council meeting on 8th January 2014, members expressed dismay that even after the excoriating criticism by the City Council of the first tranche of documentation, and 3 years of preparation, the documentation for Scheme 2 remains of poor quality. Buildings are misplaced on some plans, orientations are wrong, aspects are confused on others and the financial data contain such errors as buildings having a larger interior than exterior. There are only a few photo-montages among the drawings and these are of poor quality. Faults include manipulation of tree heights against buildings and distortions of the current magnificent views out from the site. The consensus was that the competence of the application has to be questioned by the planning department.
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Role of Historic Scotland: Members of the Community Council have been disappointed at the apparent lack of input from Historic Scotland to the development proposals in terms of defending the setting of such important historic buildings and their protected setting.
Geology: It is considered unsatisfactory that no geological survey of the site appears to have been carried out yet some car parking areas are shown as cut into the hill slopes. There is a concern that if this proves unfeasible, then there may be fresh pressure to allow surface parking at a later stage.
Conclusion: The developer is looking to push through this excessive development in order to return maximum profit for their investors without regard for these social and local factors for which the City of Edinburgh Council is our guardian. Morningside Community Council members consider it their duty to protect this site from excessive development and believe that the proposed scale/development of new buildings should not be allowed. Refusal of this planning application is thus requested.
Morningside Community Council - Scheme 3
Further to Morningside Community Council's letter of objection, dated 15 January 2014, to what is now referred to as Scheme 2 for the above development, I can report that members of the Community Council have now had the opportunity to consider the revised Scheme 3 for the development.
Summary of Responses: To gauge public opinion on this Scheme 3, the Community Council hosted a public meeting on 13 June, at which the developer presented the new proposals, and then called a Special Meeting 11 July which some 60 people attended and at which Community Councillors reached a decision. Both meetings were advertised on our seven notice boards in Morningside, on our Facebook page and on our website. Both were also mentioned in the press. Drawings of the revised proposals were displayed at the Special Meeting to aid understanding of the proposals.
Those attending the Special Meeting overwhelmingly rejected Scheme 3 as not sufficiently different to Scheme 2 to change their previously expressed views. The removal of the large Napier building was welcomed but too many other points of criticism had not been addressed by Scheme 3. Community Council members went on to vote to sustain its earlier objection to the development and to add more points of objection, as raised at the meeting.
Our advanced publicity for the meeting, and indeed earlier notifications on Facebook of the basics of Scheme 3, asked residents to let us know their views, for or against. 160 e-mailed or written communications were received, of which 155 objected to the proposals and 5 supported. Those objecting did so for a wide variety of reasons. Many letters were written from a very passionate and emotional standpoint, demonstrating the real sense of ownership that so many people have for this site. Of those supporting, it is noteworthy that only 1 expressed unequivocal support. Others referred to an acceptable compromise or felt that concern over a possible increasing deterioration of the site overcame their dislike of the new building. As with the earlier Scheme 2, Morningside Community Council's opposition to Scheme 3 remains based on many material considerations which are detailed as follows:
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Policies: It appears necessary to reiterate that the proposed Scheme 3 development would breach many of the adopted Edinburgh City Local Plan Policies including ENV 3, 5, 6, 11, 12, 15, possibly 16, and 18. There are particular concerns that the development would breach policy ENV 17 having regard to the risk of flooding from the development to which further reference will be made. One of the most important policies in relation to this highly protected site is Policy Os 1 which ".....seeks to protect all open spaces, both public and privately owned, which contribute to the amenity of their surroundings and the city, which provide or are capable of providing for the recreational needs of residents and visitors or which are an integral part of the city's landscape and townscape character and its biodiversity" It will be more important to protect open spaces in the future, as the population of parts of the city increases and brings added pressure on existing resources". The proposed development would be a clear breach of this policy.
Craighouse is not designated for housing in the Local Plan and, with all the above policies in place, Craighouse should be protected from development. It should be remembered that many of the green areas around the site have been substantially developed in the last two decades, including the former Greenlea Nursing Home, the former City Hospital, Meggetland and Meadowspot. By virtue of this reduction in greenspace elsewhere, the protected Craighouse site has become a very important recreational area and a much used and much appreciated beauty spot for this increased population.
Substantial redevelopment of the Royal Edinburgh Hospital site in Myreside has been approved and, looking forward, development of greenspace at the Astley Ainslie site in Morningside seems likely. Thus it is all the more important to protect this very important Craighouse site for the population to retain an important natural greenspace and wildlife site in this area.
It is noted that the Edinburgh Local Development Plan - "Proposed Plan March 2013" carries forward these same policies. Craighouse is not designated for housing in this new document.
Designations: This site has many important designations not only as Open Space but also as a Local Biodiversity Site, Nature Conservation Site and Area of Great Landscape Value. These designations are considered incompatible with any newbuild. Craighouse is one of only 8 Areas of Great Landscape Value in the whole Edinburgh area - others include the Hermitage of Braid, the Botanical Gardens and Arthur's Seat. It should therefore be protected against this excessive and dominating newbuild and its associated infrastructure which would ruin this beautiful area.
Craiglockhart Hills Conservation Area: The proposed development is considered incompatible with the Conservation Area status of the site since the newbuild cannot be considered as likely to enhance the site. The landscape setting of the listed buildings is part of what justifies their status as "A" listed buildings. The Craiglockhart Character Appraisal speaks of "Victorian buildings against dramatic landscape backdrops". The newbuild contrasts sharply with that character. The protected setting and views of the listed buildings would be totally changed for the worse by up to 6 storey blocks of flats and housing partially built into the woodland.
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Views to and from the site, as well as within the site, would also be materially affected. The Character Appraisal Overview identifies that "the area encompasses a mosaic of habitats which are exceptional within a city environment". These habitats would be disrupted by the proposed development.
Impact on the natural environment: Notwithstanding the formal designations referred to above, there is great public concern about the impact of the development on the natural environment of the existing woodland, woodland edge habitats, the wildlife generally, and protected species in particular. This will be particularly acute during the long period of construction works. There are known badger setts close to the existing buildings which would be disturbed by any new development. There is no indication of what is to happen to them or what mitigation measures are to be adopted. Overall, there is a significant and permanent loss of habitat. Most of the development sites are on Local Nature Conservation Sites which become Local Biodiversity Sites in the Proposed Plan March 2013.
Edinburgh's Seven Hills: The Craiglockhart Hills are together accepted as one of the iconic seven hills of Edinburgh and it is considered essential to protect all these hills from new development if the character and the enjoyment of Edinburgh, both as a place to live and as one of the most beautiful cities in the world, is to be preserved for the future. In the event that permission was granted for this development, it would be increasingly difficult to defend other hills and green spaces from similar development.
The Questionable Financial case: Since the A-listed buildings can be profitably converted, on the evidence of the developer's own financial report, there is no justification for the request for 'Enabling Development' to allow them to profit excessively.
It is a fundamental principle of Enabling Development that the size and scale of any new buildings should be the minimum that is required to enable the maintenance and conversion of the original buildings. The Community Council cannot accept that the quantum of new building still proposed across six separate blocks of construction is anywhere near the minimum required. This is the third time that the public have been told that the proposals represent the minimum but there is still no detailed case proving this statement.
English Heritage Enabling Development Policy: The developer has stated in their Report on Financial Case - May 2014, that their proposals meet the criteria for Enabling Development as set out in the English Heritage Policy Document "Enabling Development and the Conservation of Significant Places". However, English Heritage set out seven key criteria, all of which must be met in order to justify an Enabling Development Case. Morningside Community Council does not believe that the developer has adequately proved that any of these criteria have been met by their proposals.
In opting to pursue planning consent through the use of an Enabling Development case, the developer has selectively used parts of English Heritage policy which may support the case, while ignoring important areas of policy which do not. The very first condition of English Heritage's criteria is that "Enabling Development that would secure the future of a significant place, but contravene other planning policy objectives, should
Development Management Sub-Committee – 3 September 2014 Page 104 of 174 12/04007/SCH3 be unacceptable unless: a) it will not materially harm the heritage values of the place or its setting". The proposed development does not stand up to this test.
A further example of policy being ignored is: "2.4 The role and responsibilities of the developer - 2.4.1 (to) explore a range of alternative development strategies". However, the developer has not convinced us that alternative strategies would not deliver a better result. In particular, they have not complied with the key requirement: "4.7.1 Before any enabling development is considered the applicant normally needs to demonstrate that real efforts have been made, without success, to continue the present use or to find compatible alternative uses for the place. This should normally include the offer of the unrestricted freehold or long leasehold (125 years or more) on the market at a realistic price reflecting the condition of the place, and, so far as ownership allows, with an appropriate curtilage".
The proposals do not present viable alternatives which local residents, as a community, would like to see presented. There were 6 bids for the site when it was last put on the market and since then, the current owners have not tested to see if the site would sell for an alternative use.
Morningside Community Council would welcome an independent opinion on whether the developer has done enough to demonstrate that there are no viable alternative uses, as is required by section 2.4 of the English Heritage guidelines.
Other references to the English Heritage criteria are relevant: The English Heritage Guidelines warn, in para. 4.3.6, that Enabling Development should always be a subsidy of last resort due to its inefficiency. They quote enabling development of a value of 3 or 4 times the conservation deficit as an example of this inefficiency. However, the Craighouse Partnership are pursuing an enabling development of a value of almost 9 times the claimed conservation deficit - approximately three times the amount that English Heritage Guidelines use as an example of inefficiency.
It adds that the enabling development itself will have a threshold above which the further infrastructure costs involved (roads, sewage and other services) requires more enabling development: and that this threshold should also be identified as a key constraint. The application at Craighouse requires substantial infrastructure costs much of which are associated with the newbuild - at nearly 9 times the conservation deficit and with large infrastructure costs predominantly associated with the newbuild - this cannot be said to be a minimum and would seem to have crossed this threshold.
The scale of these proposals is thus out of all keeping with the 'problem' of how to preserve these buildings, which should be highly valuable and relatively easy to convert.
The notion that some £47m of newbuild is required to overcome a profit shortfall on a £30.7 m conversion of the existing buildings is out of all proportion. This view is supported by the fact that the area of proposed newbuild of some 172,851 sq.ft. is more than that of all the existing buildings put together.
Site Value: Under English Heritage Guidelines, there is a presumption in an Enabling Development case for the site value to be zero or negative. However, the developer does not address this issue in the application and instead uses the significant figure of
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£4.7 m to value the site (that being their estimated break-up value of the site). It is unclear to MCC members how the site can be simultaneously financially unviable and deemed by the developer to be requiring significant Enabling Development, yet also be worth £4.7 m as individual buildings.
Disposal Values of Existing Properties: The developer's proposals fail to show consideration of the final values of the existing buildings, after conversion, depending on whether they look out on woodland and the natural environment, or whether occupants would look out on closely adjacent modern flatted development and town houses. Community Council members anticipate a significant difference between such values and they are strongly of the view that this would have a significant impact on the amount of the calculated Conservation Deficit. Community Council members believe that the existing properties will be more valuable without all the newbuild. It is also clear from the developer's figures quoted that they have used disposal values only some 12% more than their current Leith Academy development whereas an uplift of some 25% of those figures could be anticipated for the exceptional elevated landscape location of Craighouse. The recent newbuild development at Polwarth Terrace suggests substantially higher prices can be expected for similar sized newbuild properties locally. MCC suggests, therefore, that both newbuild and the conversion sales prices should be reviewed. Other objectors to the developer's proposals, who have been shared their objections with Community Council members, have demonstrated that if one applies such more realistic values to this development, the developer's profit target can be achieved without resorting to any newbuild.
The developer's approach to their stated profit target of 20% has to be questioned since this is being calculated on the gross development value of the project and not on the usual basis of a percentage of costs - English Heritage Enabling Development Guidelines para. 5.12.2 refers.
Excessive Pressures from the Development: The proposed development will place excessive pressure on local school places, primarily at South Morningside Primary School, where there is no spare capacity, and on traffic levels in the surrounding road network which is already felt to be operating close to capacity. The development that many parents want to see first in Morningside is the provision of a new primary school ahead of any further housing development in the catchment area. Consequently, as there is no prospect of school expansion or catchment change, the South Morningside Primary School Parents Council have made it clear to MCC that local parents object to the development of housing in the area.
Drainage: Despite the revised drainage plan, members of Morningside Community Council still have concerns about the potential impact of the development on the surface water and foul drainage systems of the area. Fears remain that the proposed SUDS drainage system may not cope properly with overland run-off in severe storms. The latter could still result in large amounts of excess surface water running down the access roads into Craighouse Road potentially affecting the flats at the west end of Craighouse Gardens.
Serious concerns also remain regarding foul water discharge into the combined sewer running under Balcarres Street. There are acknowledged capacity issues downstream and a propensity to flooding in both Morningside Road and Balcarres Street. The Community Council understands that Scottish Water and CEC are analysing the
Development Management Sub-Committee – 3 September 2014 Page 106 of 174 12/04007/SCH3 problems with the sewer and the culverted Jordan Burn. Until this study is complete, and the problems better understood, the Community Council objects to further large- scale connection into this system from Craighouse.
Car Parking: Community Council members are very concerned at the potential impact that up to 308 extra vehicles will have on congestion on local roads considered by local residents to be already at capacity. Also, the Scheme 3 drawings fail to show the visual impact of parked vehicles around the site and, in this respect, the removal of underground car parking to many of the blocks is regrettable.
The extent of new roads/car parks on the site will turn areas of this green Open Space to tarmac spoiling the character of the site contrary to all policies and designations. The claim that tarmac is being reduced in Scheme 3 is not accepted since it does not take account of the new areas of hard-standing now required for surface car parks.
Design Consistency: Scheme 3 arguably retains a design consistency however the newbuild is considered institutional in scale with the Burton and Clouston buildings continuing to dominate their neighbouring Old Craig and South Craig respectively. The overbearing scale of the Burton building has been likened to "a new Debenhams" which graphically describes this enormous structure. The scale of the Clouston building is also particularly inappropriate, being situated as it is, so close to and really overshadowing the A-listed South Craig building. With Clouston being sited at the top of the slope, it makes its bulk even more dominant. The gross internal area of the Clouston building is 3.9 times that of South Craig demonstrating clearly that this building will dominate South Craig in an unacceptable manner. In such a sensitive site, the Burton and Clouston blocks should be subservient and complimentary particularly to their respective A-listed neighbours, namely Old and South Craig.
Similarly, the pitched roof cabin building which is now proposed at the top of Craiglea Place is a change in the design philosophy and approaches architectural incoherence. It replaces the previous very large block of four town houses to be sited at the top of Craiglea Place, but this latest proposal bears no relationship to any part of the development, neither the existing Victorian terraced houses nor the other newbuild blocks. It does not represent the "discreet extension" proposed by the developer for this fine terrace.
Impact on the Community: Much is being written on the impact of the current proposals on the built environment but an equally strong message being conveyed to Morningside Community Council members is the impact on the local community for whom the Craighouse Campus has become their recreational space where all kinds of physical activity are enjoyed and where the natural environment is both greatly appreciated and highly valued. This use of the area feeds straight into Scottish Government ambitions to improve the health and wellbeing of all citizens. It is widely felt that the amount of new build will substantially damage the environment and hence the enjoyment of the site. This is borne out in the many objections being raised by local residents and shared with the Community Council.
The Craighouse site has been encroached on all sides by development from Craiglockhart and The Steils, to the City Hospital Development, Meggetland and Meadowspot. We now have this critical protected space left which is used by communities all around it, e.g. Craiglockhart, Shandon, Ashley, Polwarth, Merchiston,
Development Management Sub-Committee – 3 September 2014 Page 107 of 174 12/04007/SCH3 as well as Plewlands, Morningside and others further afield. It is of a sufficient scale that makes it viable as a natural space for walking and for nature appreciation. Many of the other surrounding green spaces have been fully developed and the green space at the Royal Edinburgh Hospital will soon be developed too. That means Craighouse will be left as the major local green space for walking, recreation and wildlife watching for all those dense developments round about.
MCC recognises the proposal to transfer an as yet undefined area of woodland to public ownership. We also note the intention to transfer other open space to a trust in which CEC has a "golden share" in order to protect future use. Nevertheless, some members of the CC feel that such a mechanism would not adequately guarantee public access and use of the non-woodland open space.
There is a high priority in Health and Social Care to prioritising social prescribing (non medical interventions). This goes beyond referring people to gyms and other institutional leisure facilities it includes accessing greenspaces which contributes to a sense of belonging. It can promote individuals 'spiritual' wellbeing which also has a positive impact on a person's mental health. In a recent Lothian's Joint Mental Health and Wellbeing Strategy Programme document "A Sense of Belonging - A Joint Strategy for Improving the Mental Health and Wellbeing of Lothian's Population 2011-2016", paragraph 14 on Greenspace, sub-para 14.1, states: "There is increasing evidence of the influence of the environments that we experience throughout our lives on both our physical and mental health and wellbeing. Good quality greenspaces provide low-cost opportunities to take part in physical activity which we know have a positive impact on mental health. Good quality greenspace can also provide opportunities for people to meet and engage with friends and neighbours and well as provide identity to neighbourhoods". The use of the Craighouse Campus in this way has become well established.
The Heritage Objective and Phasing: The proposed development is being argued on the basis it will 'save' the listed buildings, thereby fulfilling the "heritage objective". However, the public harm caused by these proposals will adversely affect wildlife, schools, transport, public green space, beautiful views as well as making the historic buildings much less visible and spectacular for the public. The heritage being defended by objectors is the combination of A-listed buildings in their greenspace setting. To divide these aspects is to negate the heritage objective.
It is also extremely unclear from the proposed phasing of the development that the proposals will even save New Craig. The proposed Phase 1 includes the early construction of two of the most profitable buildings, Burton and Clouston, to generate income for the conversion of the first third of New Craig and Queens Craig. With this profit in hand, however, the developer may abandon the project and leave Queens Craig and the majority of the New Craig to an uncertain future, all as currently seen at the Quartermile site in the city.
In the unwelcome event of significant newbuild being permitted, the issue of phasing the conversion of the existing buildings in parallel with any newbuild will be critical in ensuring that the existing buildings are not left to decay. This will ensure that the benefits of any enabling development are directly linked to the listed buildings. This must be an enforceable link to the heritage objective as advised by English Heritage in their Enabling Development Guidelines Section 7 ( page 9 ): "Success depends on the
Development Management Sub-Committee – 3 September 2014 Page 108 of 174 12/04007/SCH3 benefits of the proposal being properly secured. Legally enforceable arrangements must be put in place to ensure that the commercial element of the development cannot be carried out or used until the heritage benefits have first been delivered, or there is a bond in place to ensure performance". Specifically in para. 7.1.1 ( page 54 ): "Where a decision has been taken that proposals for enabling development are acceptable in principle, it is essential that the benefits are properly secured. Legally enforceable arrangements must be put in place to ensure that the commercial element of the development on which the scheme has been predicated cannot be carried out or used without the heritage benefits materialising". If the developer were to complete the new build ahead of the conversion, then the financial viability of converting the existing buildings would be unchanged. The Council should consider requiring the developer to take out a performance bond to cover such an eventuality.
Sustainability: The developer claims that many aspects of the development are sustainable however it can be anticipated that the distance from shopping facilities will lead to significant car use by residents. This could be addressed to a welcome degree by requiring the developer to fund improved pathway links to the "Happy Valley" shopping area, just north of the site but currently separated from it due to the absence of footways.
Quality of plans and accompanying information: Previous drawings for earlier schemes have been criticised for their poor quality and errors. Scheme 3 drawings show some improvement but the financial data still contains such errors as buildings having a larger interior than exterior. There are only a few photo-montages among the drawings and these remain of poor quality. Faults include manipulation of tree heights against buildings and distortions of the current magnificent views out from the site.
Role of Historic Scotland: Members of the Community Council have been disappointed at the apparent lack of input from Historic Scotland to the Scheme 3 development proposals in terms of defending the setting of such important historic buildings and their protected setting. MCC consider that a detailed response to Scheme 3 should be provided.
Alternatives to Scheme 3: Reference has been made to the fact that the developer's case for Enabling Development rests on questionable disposal values of finished properties. It is also dependant upon the English Heritage advice that there must be no alternative solution for this site for the argument for Enabling Development to succeed. Early indications from some members of MCC suggest that there is potential for viable alternative uses of the site using the Community Development Trust model for the site. This suggestion has met with wide approval amongst those objecting to the current scheme and Morningside Community Council would support further examination of this option by the City planning team working with the community representatives.
Conclusion: The developer is proposing excessive development in order to return maximum profit for their investors without sufficient regard for those social and local factors for which the City of Edinburgh Council is our guardian. The case rests on highly questionable figures, particularly for final disposal values and credible research has shown that the developer's profit target could be met from converting the existing buildings alone, without any newbuild. Given this, there is considered to be no Conservation Deficit and no case for Enabling Development as defined by English
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Heritage. Based on all the representations made to them, at public meetings and in copy emails, Morningside Community Council members consider it their duty to protect this site from excessive development and believe that the proposed scale of new buildings should not be allowed. Refusal of this planning application is thus requested.
Craighlockhart Community Council - Scheme 1
I set out below the Craiglockhart Community Council response to Consultation on the Planning Applications specified.
Planning Application 12/04007/LBC Change of use and conversion of listed buildings; we have no objection to this application
Planning application 12/04007/CON Demolition of Learning Resource Centre building; we have no objection to this application
Planning Application 12/04007/FUL Napier University Craighouse Campus
1.0 Firstly we believe that the preservation of the listed buildings is of paramount importance and accept that some development of the site with new build properties will be required to co- finance the project. However, we are of the view that such development must not degrade the open space, must complement the existing buildings and have reasonable access for the public.
However we Object to this Planning Application because we believe that as it stands it represents an unacceptable amount of abstraction of open space for private use from the setting of the listed buildings.
2.0 In relation to the material matters : 2.1 We understand that the site is protected under various regulations e.g. Local Plan and that these will only be overridden to allow minimal new build.
2.2 In regard to Appearance,while the materials shown for the new build blocksand terraces, West Craig, Kings Craig, Duncan, Clouston and Old Craig Grove look to be appropriate the designs of the predominately rectangular elevations are incongruous in relation the existing buildings. The listed blocks feature tall chimneys, turrets, dormers and gables as vertical elements breaking the skyline while the design of the proposed blocks does not harmonise with these aspects at all. The height of the replacement for the library (Clouston) is a cause for concern as although the current building has little to recommend it is hardly seen from any prospect while the proposed replacement appears to be much more prominent.It again, of course, shares the unsympathetic block-like design we dislike elsewhere. Better matching of styles between listed and new build has been achieved locally in the Greenlea and City hospital sites. In fact earlier iterations of the design exercise seemed more suitable to the site.
2.3 Amenity. Paths which are currently only footpaths due to the width and steps are stated as off-road cycle routes(Transport Assessment Para 3.7), if they are to become cycle paths then upgrading will be necessary. There is little detail on how pedestrianaccess will be protected to the north west of the development towards the
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Local Nature Reserve. A fuller presentation of how the public will pass through the site on foot, cycle and car is required.
2.4 Traffic Overloading towards Colinton Road. This is a concern at present, with many more vehicles predicted at peak times the suggested re-phasing of the traffic lights is not a convincing solution(Transport assessment Para 6.10)
3.0 Other issues 3.1 The Landscape plans show 'Eurogard Weldmesh boundary fencing 2.0M high' this sounds wholly inappropriate for the setting.Fencing and walling should be of a modest scale to avoid a sense of enclosure and exclusion.
3.2 Development phasing, while it is understood that cross subsidy from the sale of new build to support development of the listed buildings is necessary the two should be carried out in parallel to avoid the non-completion of the listed renovation.
3.3 We would like to see more of the business case to be assured that new building is minimised consistent with a reasonable profit for the sponsor.
3.4 Pre-application consultation comments. We are of the opinion that the developers have spent a great deal of effort in seeking the views of interested parties andwe have seen the proposals evolve over the period of consultation.
3.5 The area proposed for private use, i.e. new build housing, gardens and car parking appears to be a large proportion of the available open space resulting in a crowded appearance in the illustrations provided. This looks to us like overdevelopment.
3.6 Numerous residents have stated that they believe that significant improvement is needed in the Drainage infrastructure in and around Balcarres Street/Meadowspot to avert recurrence of recent flooding which could be expected with more surface water in the system as a result of there being more hard surfaces on the Craighouse site.
3.7 Capacity in local schools is, we understand,currently stretched and the number of new build family houses proposed would exacerbate this problem if no plans to increase places are implemented.
3.8 Concern has been expressed regarding the maximisation of the retention of viable mature trees; it expected that this aspect of the application will be given appropriate scrutiny.
3.9 The affordable housing contribution is welcome as this is much needed in the city.
Craiglockhart Community Council - Scheme 2
Craiglockhart Community Council wishes to lodge an OBJECTION to the above application on behalf of residents.
On the following bases in particular:
Development Management Sub-Committee – 3 September 2014 Page 111 of 174 12/04007/SCH3 a) While we accept that some new build may be necessary to to cross fund the preservation of the listed buildings and share the overheads of maintenance the extent of that proposed in scheme 2 is excessive. The Enabling Development case as given does not justify the amount of new build proposed and does not appear to conform to the guidelines of English Heritage. Additionally it has been pointed out to us that the valuations used in the calculations do not reflect the current market conditions, independent assessment of the business case is required. b) We are very concerned about the proposed phasing of the development. The developers propose a three phase development with some conversion of buildings in each phase but with the development of the two new large blocks in the first phase. In particular, the conversion of New Craig is to be undertaken partially in each phase. This means that the funds will not be available and the work not fully undertaken as early as possible. This is a high risk approach which could result in a large amount of new build without any significant conversion of the present buildings. This could end up with a similar situation to the old Edinburgh Infirmary / Quartermile development. The developers could take their profits and run, leaving the CEC to clear up the mess. The phasing should be altered so that the conversion of New Craig is undertaken and completed in the first phase. c) We feel that the design of the new build blocks is incongruous to the site and devalues the overall architectural standard. Moreover, the scale of scheme as proposed would dominate the existing buildings and destroy the setting. d)The Edinburgh City Local Plan designates Easter Craiglockhart Hill as 'open space' and an "area of great landscape value". Our understanding is that these designations predicate against development that will diminish the landscape (Policy ENV11) or fail to preserve or enhance the conservation area (Policy ENV6). e)The new build will significantly impair the character of the Conservation Area, and will be contrary to policy. The Craighouse site is a significant part of the character of the area - the Craiglockhart Character Appraisal talks of Victorian buildings against dramatic landscape backdrops, which makes the proposed new build blocks completely out of character. Craighouse stands in an historic setting, the Old Craig building being some 450 years old, and the remaining buildings (from 1890) being beautiful examples of Victorian architecture. The built heritage of this site needs to be kept well clear of 21st century sprawl and development. The new plans provided by the developers show a complete and insensitive disregard for the existing architecture. f) A major concern of residents is that the extent of development proposed would stress the local infrastructure well beyond capacity. For example;
They foresee major problems for the management of traffic on Myreside Road/ Colinton Road at peak times, including school runs. These difficulties will be compounded with the Royal Edinburgh Hospital development construction entrance/exit on the bend.
Also Scottish Water appear not to provide any reassurance of future capacity to accept both surface and soil drainage raising the flood risk for sites lower than Craighouse.
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Local schooling is currently over stretched and would be struggling to cater for a possible major influx of additional pupils.
Craiglockhart Community Council - Scheme 3
Craiglockhart Community Council has attended a public consultation meeting with the developer on 18/06/14 and held a public meeting on 08/07/14 to hear community comments on the proposal . Additionally comments have been received from local residents. After careful consideration of the application and as a result of these steps we OBJECT to the Planning Application. A summary of our concerns is as follows:
1 The enabling development case for the application appears to enable the applicant to exploit the site far beyond that required to meet the "conservation deficit" necessary to secure the future of the listed buildings and site and provide a reasonable margin for the enterprise.
2 The site has many protections, including the current Edinburgh Local Plan designation and Conservation Area status which preclude development.
3 The proposed phasing of the development exposes the site to the risk of abandonment before completion and the ability to enforce the schedule is doubted.
4 The number, design and mass of the new buildings is such that they appear to clash with and dominate the existing structures.
5 Grave concerns are held over the security of wildlife and flora and the Environmental Impact Study does not allay these fears.
6 While the proposal to create a Community Park is welcomed the detail of how its access and use would be controlled remains somewhat uncertain.
7 We do however recognise the benefit of the section 75 contribution, the much improved drainage plan and the gift of land to CoEC to increase the Local Nature Reserve. However, they do not compensate for the drawbacks outlined above.
Merchiston Community Council - Scheme 1
At our last November meeting Merchiston Community Council took the unanimous decision to oppose this development. I wish therefore on behalf of Merchiston Community Council to formally object to the current proposals to develop the Craighouse site for new build housing in contravention of a raft of landscape protections, notably:
- Its designation as Open Space. - Its designation as an Area of Great Landscape Value (candidate for special landscape area). - Its being in a Local Nature Conservation Site and Local Nature Reserve. - Its situation within the Craiglockhart Hills Conservation Area. - All the trees have TPO status. - Development is contrary to Scottish Government Policies (SSP p115)
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- Development would contravene Scottish Heritage Environmental Policy (SHEP 1.14) - It also contravenes the Development Plan (Edinburgh and Lothians Structure Plan 2004/2015, in particular, ENV1C and ENV1D). - It contravenes Edinburgh City Local Plan 2010, in particular, Os1, Env3, Env6, Env7, Env11, Env12, Env15, Env16, Env17, Hou1, Des1, Des 3, Des 5 and Des 10. The Local Plan specifically states that "....development needs must be met by making better use of urban land without damaging the historic environment or building on important open space..." (para 2.5) - Similarly the proposals are at variance with the City of Edinburgh's commitment to "...adhere to the Vision of the Central Scotland Green Network...and to identify opportunities and priority areas for Green Network enhancement..." as stated in the Concordat signed by the Leader of the Council Andrew Burns on 13 September 2012.
We fail to see why these necessary public constraints should be overturned for these developers and consider there is both 'development' and 'economic development' and that they are not necessarily the same thing. We feel that this will not bring the latter, so there is no long term public gain from building elite private housing selling for over £0.5 million per unit on an unsuitable site that will only bring it into conflict with residents and the wider community who visit the hill for recreation. The developers bought this site in the full knowledge that it was a highly protected site both for its listed buildings AND its landscape value.
What gave them the idea that they could dispense with the rule book and ignore all the very powerful constraints on new build as if this spectacular landscape was a brownfield site?
We challenge the justification put forward by the developers that new build is justifiable on the grounds of an 'enabling development' case when we understand from CEC planners and from other research we have conducted that the controversial 'enabling development' argument (which was put forward by English Heritage and has yet to be even recognised by Historic Scotland) only applies to listed buildings whose market value is zero. 'Enabling development' may apply to instances where the case for removing planning restrictions on listed buildings is justified on the grounds that the next worst thing that could happen to them is demolition because decay is so advanced that they face imminent collapse and there is no other way of securing their future.
But clearly buildings which fetched in excess of £9 million on the open market in 2011 and attracted at least half a dozen bids - do not have zero value.
We also query whether buildings which attracted £14 million of public investment for restoration from Historic Scotland since they were purchased from the previous owners, NHS Lothian in 1994, and are currently still in use, are in danger of imminent collapse. Therefore we conclude that there is no case for 'enabling development' of new build housing at Craighouse on the scale envisaged here, as this term is currently understood by English Heritage.
The developers appear in this instance to be stretching the point in arguing a case for 'enabling development'. They stretch the criteria to include cases which may, in the fullness of time, potentially become cases for 'enabling development'. Their case is therefore based on holding the public interest in these buildings hostage to their
Development Management Sub-Committee – 3 September 2014 Page 114 of 174 12/04007/SCH3 fortune, as developers who claim to hold the key to the future of these buildings, which strikes us as arm-twisting and profoundly undemocratic. Theirs is an argument so wide in scope that, if allowed, it could be made to apply to just about any listed building, thus effectively removing any planning constraints on development where listed buildings and their settings are concerned.
We should also point out that 'enabling development' has as far as we have been able to ascertain, no status in actual law. It is not even policy. It is simply an idea - a controversial one - that English Heritage has reluctantly come up with to try to persuade planners that it would in some circumstances be worthwhile relaxing some constraints for the sake of the preservation of difficult listed buildings such as New Craig that have no current uses and are not readily convertible to new ones without substantial investment. Thus the case crucially rests on just how much additional money is needed to convert New Craig than would be recouped from the sale of the conversion.
The area covered by Merchiston Community Council stretches from Leamington Terrace in the north, Slateford Road as far as Shandon in the west, Colinton Road as far as Watson's playing fields in the south, and Whitehouse Loan and Newbattle Terrace in the east. This small area is home to 25,000 people all within walking distance of Craighouse. Population is rising rapidly as the former brewery site along the canal is developed for student housing. It is already one of the most densely packed neighbourhoods in Edinburgh according to CEC's statistics. The only public park we have within our bounds is Harrison Park, a small, compact bit of land coveted by all and sundry. Many residents do not have gardens, or they have gardens which are tiny and unsuitable for recreation beyond sedentary 'activities' such as sunbathing, barbecues, or maybe some light gardening. Many residents are living in small, cramped, houses. The canal towpath is another recreational area, but one that is so popular that it is becoming overcrowded.
We therefore take great comfort from the open space at the Craighouse site which is accessible for walks, picnics and family outings, with its magnificent views, forests, and nature trails. It provides an opportunity for exercise and a sense of well-being, away from the stresses of modern life and the limitations of compact high-density urban living. We are very concerned about the development especially the sprawling layout and modernist design of the proposed new build private housing which is totally out of keeping with the French renaissance style of New Craig and the simpler Scottish baronial style of Old Craig. New build will spoil the appearance of the hill and limit access, reducing our wider amenity, and changing the character of Craighouse forever. Eight storey modernist flats on a prominent hill will be unsightly for miles around. It was for the restorative potential of its landscape for both mind and body that Craighouse was given as a place of asylum for those suffering from mental disorders when medicine for anxiety was not available and the only remedy for stress was complete rest and recuperation in beautiful, airy, contemplative, inspiring, locations. The restorative and uplifting qualities of the open hill landscape remain, (hence the raft of protections - now proposed to be removed), and are as relevant for the wider community's 'well-being' today ('amenity') as they were when the hospital was built over 100 years ago.
Craighouse and Craiglockhart Hill provide residents with a vista like Arthurs Seat or Corstorphine Hill from which the rest of the city and surrounding countryside can be
Development Management Sub-Committee – 3 September 2014 Page 115 of 174 12/04007/SCH3 seen, as well as being a site which is itself seen for miles around. The landscape setting of Craighouse is part of Edinburgh's identity as an 'Athens of the North' - a city of seven hills, of extraordinarily diverse terrain; of hills and dales, parks and forests, canals and burns, of green space and built up areas. These create varied micro- environments that make the city interesting to explore and provide ample opportunities for a 'sense of place' in the hands of imaginative builders alive to these treasures, alas, sadly lacking here in this fragmented design.
The new build proposed here does none of that. It is sprawled across the site in an untidy manner doing much to destroy the setting of the listed buildings by requiring roads, car parks, and access points. English Heritage stipulates that preservation of the setting as a key condition for 'enabling development'. Yet here the setting is destroyed.
We urge planners to uphold existing policy constraints on this community asset which is an ornament for the whole of Edinburgh.
Merchiston Community Council - Scheme 2
I wish to object to Craighouse Scheme 2 on behalf of Merchiston Community Council.
At a recent meeting of the community council it was decided to oppose this scheme.
1. We urge planners to uphold all the landscape protections that exist on this site and reject the case for new build. This site, being on a hill, is a prominent landmark in the landscape of the city which forms part of the skyline of Edinburgh and can be seen for miles around. Many Merchiston residents enjoy walks there and views of the north face of hill can be seen from many vantage points in the Merchiston area.
2. We have a lesser objection to the existing buildings being converted to residential use though we note and regret that a former public use (therapeutic, then educational), would be changed to private use (housing), with possible consequences for public access to the hill and the nearby nature reserve. If this area becomes one of private housing there are bound to be conflicts which may result in restrictions for the public.
3. We reject the financial justification of the Enabling Development Case and consider that converting the existing buildings into residential units would be profitable without additional new build.
4. We also note that English Heritage, in its guidelines on Enabling Development, places emphasis on the preservation of the SETTING of the heritage items. New build may be permitted only if it is discreetly out of sight and does not destroy the heritage setting. However, this is not what is proposed here. Ten three storey houses will be sited in front of New Craig on the hill's north face (facing south towards the city) and many trees removed. The carefully designed 'picturesque' setting of New Craig and Old Craig against the background of the hill, framed by these trees and fronted by the Orchard would be destroyed by this and the other buildings which are randomly laid out across the site in a sprawling pattern. Some blocks are five storeys high and will be clearly visible in front of or to the side of the heritage buildings. If they were placed at the back of the hill (facing north towards the golf course) this would not be the case.
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5. The new buildings are of poor quality design. They do not complement the Scottish baronial style of Old Craig or the French Renaissance style of New Craig. There is minimal articulation of the facades and large glazed areas quite out of keeping with the fenestration of the older buildings. The materials palette is unclear.
6. We are concerned about the traffic impacts of 189 dwellings with spaces for 325 cars being on this hill. Traffic will approach a blind summit then have to make a sharp turn at the height. We are also concerned about conflict with the traffic on Myreside Road during the re-provisioning of the Royal Edinburgh Hospital and after its construction when this will be the services entrance. Myreside Road will become busier.
7. We note that Enabling Development is controversial and that no such guidelines as have been developed by English Heritage have as yet been adopted or developed by Historic Scotland. We are reliably advised that Enabling Development is in any case a strategy of LAST resort, not of first resort, and that for a case to exist, the heritage buildings should have zero value. This is clearly not the case here, when the site and buildings recently sold for £10 million on the open market and attracted six competitive bids. We feel it is a great concern that a landmark case which may create a precedent is operating in a policy vacuum and that it should not be for developers to stretch the definitions of Enabling Development or to effectively determine it as a policy of first resort. Planners, the Scottish Government and heritage bodies need to decide first of all, when, and if, an Enabling Development case exists, and on what conditions. Planners are operating in a policy vacuum and should not be bounced into this by developers to the detriment of the community. We urge you to reject these plans.
Merchiston Community Council - Scheme 3
No comments received.
Archaeology - Scheme 1
The development site is of considerable archaeological and historic interest both in terms of its rich surviving listed-buildings and potential for buried archaeology. A comprehensive history of the site is contained within the supporting Archaeological & cultural Heritage Chapter (7) of the Environmental Statement produced by Wardell Armstrong and Simpson & Brown's Conservation Plan (appendix 7.3). In summary the site is first recorded in the 12th century as belonging to the important Abbey of Newbattle in the Scottish Borders with Old Craighouse House dating to 1565. The estate survived as private estate until 1878 when it was sold by a Dr Hill Burton to Edinburgh Royal Asylum with Napier University taking over the site in the 1990's.
As stated the both Old Craighouse House and Craighouse Hospital are regarded as being of national archaeological and historic importance (A-listed) with the wider estate suspected of containing significant archaeological remains relating primarily to the former medieval and post-medieval estate and of course the 19th-20th century hospital. Accordingly this application must be considered under terms Scottish Government's Scottish Planning Policy (SPP) and Scottish Historic Environment Policy (SHEP) and also CEC's Edinburgh City Local Plan Policies ENV3, ENV4, ENV7, ENV8 & ENV9. The aim should be to preserve archaeological remains in situ as a first option, but
Development Management Sub-Committee – 3 September 2014 Page 117 of 174 12/04007/SCH3 alternatively where this is not possible, archaeological excavation or an appropriate level of recording may be an acceptable alternative.
As stated the development site is regarded as being of archaeological significance primarily in terms of its medieval and post-medieval archaeology relating to the Craighouse Estate. The proposed development will require extensive excavations in terms of construction of new buildings, landscaping, utilities, roads car-parking etc. Having read over the accompanying environmental statement by Wardell Armstrong I agree with the general conclusions that such works are regarded as having a the whole a moderate archaeological impact.
Accordingly it is recommended that a programme of archaeological works is undertaken prior to development. In essence this will see a phased archaeological programme of works, the initial phase being an archaeological evaluation up to a maximum of 10% of the site. The results of which would allow for the production of appropriate more detailed mitigation strategies to be drawn up to ensure the appropriate protection and/or full excavation, recording and analysis of any surviving archaeological remains affected.
Further given the potential importance of these remains in terms of the history of Edinburgh and in particular Craighouse, it is essential that this programme of works contain a programme of public/community engagement (e.g. site open days, viewing points, temporary interpretation boards) the scope of which will be agreed with CECAS.
Historic buildings As stated the site contains a range of nationally important historic buildings the development of which will see significant works to their fabric. Accordingly if consent is granted it is recommended that a programme of historic building survey (level 2-3) is undertaken prior to and during any works that may either affect or reveal new sections of historic fabric of the listed Old Craighouse and Hospital buildings. The works will be undertaken in accordance with an agreed brief with this office. This is in order that any archaeological remains (historic building fabric) that may be affected are properly recorded where preservation in situ is not possible.
It is essential therefore that a condition be applied to any consent granted to secure this programme of archaeological works based upon the following CEC condition;
'No development shall take place on the site until the applicant has secured the implementation of a programme of archaeological work (Historic Building Recording, excavation, analysis & reporting, publication, public engagement & interpretation) in accordance with a written scheme of investigation which has been submitted by the applicant and approved by the Planning Authority.'
The work must be carried out by a professional archaeological organisation, either working to a brief prepared by CECAS or through a written scheme of investigation submitted to and agreed by CECAS for the site. Responsibility for the execution and resourcing of the programme of archaeological works and for the archiving and appropriate level of publication of the results lies with the applicant.
Archaeology - further comments dated 11 March 2013
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Further to your consultation request as a result of the submission of revised ES reports, I would like to make the following revised comments and recommendations in respect to this application the proposed change of use and conversion of the existing buildings from University campus to residential, together with ancillary development, public realm and utilities infrastructure including access roads, car-parking and landscaping
The development site is of considerable archaeological and historic interest both in terms of its rich surviving listed-buildings and potential for buried archaeology. A comprehensive history of the site is contained within Appendix 4 Archaeological & Cultural Heritage Chapter of the revised February 2013 Environmental Statement Addendum produced by Wardell Armstrong and Simpson & Brown's Conservation Plan. In summary the site is first recorded in the 12th century as belonging to the important Abbey of Newbattle in the Scottish Borders with Old Craighouse House dating to 1565. The estate survived as private estate until 1878 when it was sold by a Dr Hill Burton to Edinburgh Royal Asylum with Napier University taking over the site in the 1990's.
As stated the both Old Craighouse House and Craighouse Hospital are regarded as being of national archaeological and historic importance (A-listed) with the wider estate suspected of containing significant archaeological remains relating primarily to the former medieval and post-medieval estate and of course the 19th-20th century hospital. Accordingly this application must be considered under terms Scottish Government's Scottish Planning Policy (SPP) and Scottish Historic Environment Policy (SHEP) and also CEC's Edinburgh City Local Plan Policies ENV3, ENV4, ENV7, ENV8 & ENV9. The aim should be to preserve archaeological remains in situ as a first option, but alternatively where this is not possible, archaeological excavation or an appropriate level of recording may be an acceptable alternative.
Buried Archaeology As stated the development site is regarded as being of archaeological significance primarily in terms of its medieval and post-medieval archaeology relating to the Craighouse Estate. The proposed development will require extensive excavations in terms of construction of new buildings, landscaping, utilities, roads car-parking etc. Having read over the accompanying environmental statement by Wardell Armstrong I agree with the general conclusions that such works are regarded as having a the whole a moderate archaeological impact.
However the scale of mitigation is larger than suggested by this report i.e. archaeological mitigation will encompass the whole site and not just be focused upon the area immediately surrounding Old Craighouse. Also it is off concern that the emerging discussions re drainage and flood prevention on the site might affect the site of the dovecot shown within the woods to the north of Old Craighouse on the 1st edition OS map. This site must be evaluated to determine state of preservation and if found to be in good archaeological condition the remains should be protected with any future drainage proposals designed to avoid damage.
Accordingly it is recommended that a programme of archaeological works is undertaken prior to development. In essence this will see a phased archaeological programme of works, the initial phase being an archaeological evaluation up to a maximum of 10% of the site. The results of which would allow for the production of appropriate more detailed mitigation strategies to be drawn up to ensure the
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Also any agreed woodland management plan for the site must have an appropriate mitigation strategy which would aim to protect and enhance the site's archaeological heritage.
Archaeological Setting It is clear that the scheme will have a significant impact upon the localised setting of the both the historic buildings occupying the site and the surviving estate's historic landscape. However I concur with the assessments contained within Wardell Armstrong's ES in that on purely archaeological grounds such impacts are on the whole moderate.
Archaeological Public Engagement Further given the potential importance of these remains in terms of the history of Edinburgh and in particular Craighouse, it is essential that this programme of works contain a programme of public/community engagement (e.g. site open days, viewing points, temporary interpretation boards) the scope of which will be agreed with CECAS.
Historic Buildings As stated the site contains a range of nationally important historic buildings the development of which will see significant works to their fabric. Accordingly if consent is granted it is recommended that a programme of historic building survey (level 2-3) is undertaken prior to and during any works that may either affect or reveal new sections of historic fabric of the listed Old Craighouse and later hospital buildings. The works will be undertaken in accordance with an agreed brief with this office. This is in order that any archaeological remains (historic building fabric) that may be affected are properly recorded where preservation in situ is not possible.
It is essential therefore that a condition be applied to any consent granted to secure this programme of archaeological works based upon the following CEC condition;
'No development shall take place on the site until the applicant has secured the implementation of a programme of archaeological work (Historic Building Recording, excavation, analysis & reporting, publication, public engagement & interpretation) in accordance with a written scheme of investigation which has been submitted by the applicant and approved by the Planning Authority.'
The work must be carried out by a professional archaeological organisation, either working to a brief prepared by CECAS or through a written scheme of investigation submitted to and agreed by CECAS for the site. Responsibility for the execution and resourcing of the programme of archaeological works and for the archiving and appropriate level of publication of the results lies with the applicant.
Archaeology - Scheme 2
Further to your consultation request as a result of this revised submission, I would like to make the following revised comments and recommendations in respect to this application the proposed change of use and conversion of the existing buildings from university campus to residential, and construction of new build residential together with
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As stated previously (see December 2012 & March 2013 responses) the development site is of considerable archaeological and historic interest both in terms of its surviving listed-buildings, landscapes and potential for buried archaeology. A comprehensive history of the site is contained within Appendix 4 Archaeological & Cultural Heritage Chapter of the revised February 2013 Environmental Statement Addendum produced by Wardell Armstrong and Simpson & Brown's Conservation Plan. In summary the site is first recorded in the 12th century as belonging to the important Abbey of Newbattle in the Scottish Borders with Old Craighouse House dating to 1565. The estate survived as private estate until 1878 when it was sold by a Dr Hill Burton to Edinburgh Royal Asylum with Napier University taking over the site in the 1990's.
As stated in my earlier responses, both the Old Craighouse House and Craighouse Hospital are regarded as being of national archaeological and historic importance (A- listed) with the wider estate suspected of containing significant archaeological remains relating primarily to the former medieval and post-medieval estate and of course the 19th-20th century hospital. Accordingly this application must be considered under terms Scottish Government's Scottish Planning Policy (SPP) and Scottish Historic Environment Policy (SHEP) and also CEC's Edinburgh City Local Plan Policies ENV3, ENV4, ENV7, ENV8 & ENV9. The aim should be to preserve archaeological remains in situ as a first option, but alternatively where this is not possible, archaeological excavation or an appropriate level of recording may be an acceptable alternative.
Buried Archaeology As stated previously, the development site is regarded as being of archaeological significance primarily in terms of its medieval and post-medieval archaeology relating to the Craighouse Estate. The proposed development will require extensive excavations in terms of construction of new buildings, landscaping, utilities, roads car-parking etc. Having read over the accompanying environmental statement by Wardell Armstrong I agree with the general conclusions that such works are regarded as having a the whole a moderate archaeological impact. The scale of mitigation is larger than is again suggested by the revised Environment Statement Appendix 6 i.e. archaeological mitigation will encompass the whole site and not just be focused upon the area immediately surrounding Old Craighouse.
Accordingly it is recommended that a programme of archaeological works is undertaken prior to development. In essence this will see a phased archaeological programme of works, the initial phase being an archaeological evaluation up to a maximum of 10% of the site. The results of which would allow for the production of appropriate more detailed mitigation strategies to be drawn up to ensure the appropriate protection and/or full excavation, recording and analysis of any surviving archaeological remains affected.
In addition any agreed woodland management plan for the site must have an appropriate mitigation strategy which would aim to protect and enhance the site's archaeological heritage.
Drainage & SUDS
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In addition to the above general programme of post determination works, it was mentioned in my response to the March 2013 revised scheme that I have concerns regarding the potential impact the new drainage and flood prevention proposals. In particular this is in regard to the site of the dovecot shown within the woods to the north of Old Craighouse on the 1st edition OS map which appears to be close or on the line of the projected new drainage track.
As stated in my earlier responses the requested aim is avoid damage to this archaeological site, with drainage proposals designed to avoid any impact. It was requested that this site be evaluated prior to determination in order to investigate its state of preservation and to allow for drainage designs to be undertaken. It is noted that although further drainage design appears to have been undertaken I refer you to the Drainage Strategy undertaken by Goodson Associates accompanying this application, no consideration appears to have been undertaken in response to these archaeological concerns. Accordingly it essential that before the route of the proposed drainage track is agreed that the exact location of this historic dovecote is located and mitigation measures submitted for agreement which will allow for its protection.
Archaeological Setting It is clear that these new proposals (Scheme 2) will have a significant impact upon the localised setting of the both the historic buildings occupying the site and the surviving estate's historic landscape. In general I concur with the assessments contained within Wardell Armstrong's revised Environmental Statement Appendix 6 that on purely archaeological grounds such impacts are in the main moderate. That said the construction of the new Napier and Burton buildings in my opinion have an significant increased impact, by want of their scale and in particular height on setting of the historic buildings and landscape.
This is particularly true in the case of the Burton building whose height above the existing tree heights obscures key views out towards Arthurs Seat and in conjunction with its neighbour Napier could be seem to conflict in scale with its neighbouring historic buildings of Old Craighouse and Craighouse Hospital. A reduction buy 1 to 2 storeys could resolve this issue.
Archaeological Public Engagement Further given the potential importance of these remains in terms of the history of Edinburgh and in particular Craighouse, it is essential that this programme of works contain a programme of public/community engagement (e.g. site open days, viewing points, temporary interpretation boards) the scope of which will be agreed with CECAS.
Historic Buildings As stated the site contains a range of nationally important historic buildings the development of which will see significant works to their fabric. Accordingly if consent is granted it is recommended that a programme of historic building survey (level 2-3) is undertaken prior to and during any works that may either affect or reveal new sections of historic fabric of the listed Old Craighouse and later hospital buildings. The works will be undertaken in accordance with an agreed brief with this office. This is in order that any archaeological remains (historic building fabric) that may be affected are properly recorded where preservation in situ is not possible.
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It is essential therefore that a condition be applied to any consent granted to secure this programme of archaeological works based upon the following CEC condition;
'No development shall take place on the site until the applicant has secured the implementation of a programme of archaeological work (Historic Building Recording, excavation, analysis & reporting, publication, public engagement & interpretation) in accordance with a written scheme of investigation which has been submitted by the applicant and approved by the Planning Authority.'
The work must be carried out by a professional archaeological organisation, either working to a brief prepared by CECAS or through a written scheme of investigation submitted to and agreed by CECAS for the site. Responsibility for the execution and resourcing of the programme of archaeological works and for the archiving and appropriate level of publication of the results lies with the applicant.
Archaeology - Scheme 3
Napier University Craighouse Campus Craighouse Road: Scheme 3.
Further to your consultation request as a result of this revised submission, I would like to make the following revised comments and recommendations in respect to this application the proposed change of use and conversion of the existing buildings from university campus to residential, and construction of new build residential together with ancillary development, public realm and utilities infrastructure including access roads, car-parking and landscaping
As stated previously (see December 2012, March 2013 & January 2014 responses) the development site is of considerable archaeological and historic interest both in terms of its surviving listed-buildings, landscapes and potential for buried archaeology. A comprehensive history of the site is contained within Appendix 4 Archaeological & Cultural Heritage Chapter of the revised February 2013 Environmental Statement Addendum produced by Wardell Armstrong and Simpson & Brown's Conservation Plan for schemes 1 & 2. In summary the site is first recorded in the 12th century as belonging to the important Abbey of Newbattle in the Scottish Borders with Old Craighouse House dating to 1565. The estate survived as private estate until 1878 when it was sold by a Dr Hill Burton to Edinburgh Royal Asylum with Napier University taking over the site in the 1990's.
As stated in my earlier responses, both the Old Craighouse House and Craighouse Hospital are regarded as being of national archaeological and historic importance (A- listed) with the wider estate suspected of containing significant archaeological remains relating primarily to the former medieval and post-medieval estate and of course the 19th-20th century hospital. Accordingly this application must be considered under terms Scottish Government's Scottish Planning Policy (SPP) and Scottish Historic Environment Policy (SHEP) and also CEC's Edinburgh City Local Plan Policies ENV3, ENV4, ENV7, ENV8 & ENV9. The aim should be to preserve archaeological remains in situ as a first option, but alternatively where this is not possible, archaeological excavation or an appropriate level of recording may be an acceptable alternative.
Buried Archaeology
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As stated previously, the development site is regarded as being of archaeological significance primarily in terms of its medieval and post-medieval archaeology relating to the Craighouse Estate. The proposed development will require extensive excavations in terms of construction of new buildings, landscaping, utilities, roads car-parking etc. Having read over the accompanying environmental statement by Wardell Armstrong I agree with the general conclusions that such works are regarded as having a the whole a moderate archaeological impact. The scale of mitigation is larger than is again suggested by the revised Environment Statement Appendix 6 i.e. archaeological mitigation will encompass the whole site and not just be focused upon the area immediately surrounding Old Craighouse.
Accordingly it is recommended that a programme of archaeological works is undertaken prior to development. In essence this will see a phased archaeological programme of works, the initial phase being an archaeological evaluation up to a maximum of 10% of the site. The results of which would allow for the production of appropriate more detailed mitigation strategies to be drawn up to ensure the appropriate protection and/or full excavation, recording and analysis of any surviving archaeological remains affected.
In addition any agreed woodland management plan for the site must have an appropriate mitigation strategy which would aim to protect and enhance the site's archaeological heritage.
Drainage & SUDS In addition to the above general programme of post determination works, it was mentioned in my responses to both revised Scheme 1 (March 2013) and Scheme 2 (January 2014), I have some concerns regarding the potential impact the new drainage and flood prevention proposals. In particular this is in regard to the site of the dovecot shown within the woods to the north of Old Craighouse on the 1st edition OS map which appears to be close or on the line of the projected new drainage track.
As stated in my earlier responses the requested aim is avoid damage to this archaeological site, with drainage proposals designed to avoid any impact. It was requested that this site be evaluated prior to determination in order to investigate its state of preservation and to allow for drainage designs to be undertaken. It is noted that although further drainage design appears to have been undertaken I refer you to the Drainage Strategy undertaken by Goodson Associates accompanying this application, no consideration appears to have been undertaken in response to these archaeological concerns. Accordingly it essential that before the route of the proposed drainage tracks is agreed that the exact location of this historic dovecote is located and mitigation measures submitted for agreement which will allow for its protection.
Archaeological Setting It is clear that these new proposals (Scheme 3) will have a significant impact upon the localised setting of the both the historic buildings occupying the site and the surviving estate's historic landscape. In general I concur with the assessments contained within Wardell Armstrong's revised Environmental Statement Appendix 6 that on purely archaeological grounds such impacts are in the main moderate.
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It is to be welcomed that this Scheme 3 has taken on board some of our earlier concerns by removing the proposed Burton Building and by reducing the scale of the neighbouring Napier Building.
Archaeological Public Engagement Further given the potential importance of these remains in terms of the history of Edinburgh and in particular Craighouse, it is essential that this programme of works contain a programme of public/community engagement (e.g. site open days, viewing points, temporary interpretation boards) the scope of which will be agreed with CECAS.
Historic Buildings As stated the site contains a range of nationally important historic buildings the development of which will see significant works to their fabric. Accordingly if consent is granted it is recommended that a programme of historic building survey (level 2-3) is undertaken prior to and during any works that may either affect or reveal new sections of historic fabric of the listed Old Craighouse and later hospital buildings. The works will be undertaken in accordance with an agreed brief with this office. This is in order that any archaeological remains (historic building fabric) that may be affected are properly recorded where preservation in situ is not possible.
It is essential therefore that a condition be applied to any consent granted to secure this programme of archaeological works based upon the following CEC condition;
'No development shall take place on the site until the applicant has secured the implementation of a programme of archaeological work (Historic Building Recording, excavation, analysis & reporting, publication, public engagement & interpretation) in accordance with a written scheme of investigation which has been submitted by the applicant and approved by the Planning Authority.'
The work must be carried out by a professional archaeological organisation, either working to a brief prepared by CECAS or through a written scheme of investigation submitted to and agreed by CECAS for the site. Responsibility for the execution and resourcing of the programme of archaeological works and for the archiving and appropriate level of publication of the results lies with the applicant.
Environmental Assessment - Scheme 1
Environmental Assessment has reviewed planning application submission for the above mentioned application, as amended on 6th March 2013.
Local Air Quality An air quality impact assessment was submitted in support of the application as per agreed methodology during the pre-planning consultation stage. The assessment considers the potential air quality impacts associated with additional road traffic likely to be generated by the proposed development as well as the impact of dust arising from the construction phase of the works.
Regarding road emissions from the operational phase of the development, the report finds that the impact will be negligible (for proposed and existing receptors) and therefore mitigation measures are not required.
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As anticipated the assessment is based on data derived from the Transport Assessment. As with any traffic generation and distribution exercise predictions are used (flows and trips) and the general intention of future operators and occupants of the development are taken into account. Typical problems with this are that the situation is underestimated.
In addition the modelling work undertaken for the air quality impact assessment did not undergo a verification process, which was agreed in the pre pre-planning stages. However, acknowledgement that the results would be conservative was not addressed in the report.
Having regard to these aspects of the submission, we suggest that the developer considers some element of mitigation for road traffic emissions and supports the Local Authority in providing electric vehicle charging infrastructure. This could be achieved by either providing dedicated parking spaces with charging capacity or ducting and infrastructure to allow electric vehicles to be readily accommodated in the future. These suggestions are also detailed and encouraged in the Councils Parking Standards, section 12 of the General Notes. An informative is prescribed to this effect.
Regarding the impact on air quality during the construction phase of the development, mitigation measures have been identified within the air quality impact assessment. A condition is recommended to ensure that these measures are incorporated into the planning and operation of the constriction phase. In addition to these it is recommended that bonfires are also restricted during demolition and construction.
Land contamination Previous use of the site includes Craighouse hospital. Some localised land contamination could be issue; hence the developer should undertake a site survey, as a minimum, to establish the level of risk posed to human health and the wider environment from any contamination in, on or under the land.
A condition to this effect is recommended.
Noise Potential noise conflict between the existing golf clubhouse at the south eastern end of the site and the proposed residential properties in that vicinity was also considered.
The clubhouse is licensed to 1am on a Friday and Saturday night so occasionally holds late night events. However Environmental Health has never received any complaints regarding these operations. The façade of the nearest residential property is located on the boundary of the clubhouse which is in closer proximity to the proposed residential properties.
It is anticipate that the amenity of future occupants will not adversely affected from this use.
In conclusion, Environmental Assessment has no objections to the proposed development subject to the following conditions:
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1. The construction phase of the development shall proceed in accordance with the requirements and recommendations of the air quality impact assessment (Wardell Armstrong, ST12296/ES01 November 2012, section 8.7).
Informative; Bonfires should be restricted during demolition and construction.
2. Prior to the commencement of construction works on site: a. A site survey (including initial desk study as a minimum) must be carried out to establish to the satisfaction of the Head of Planning, either that the level of risk posed to human health and the wider environment by contaminants in, on or under the land is acceptable, or that remedial and/or protective measures could be undertaken to bring the risks to an acceptable level in relation to the development; and b. Where necessary, a detailed schedule of any remedial and/or protective measures, including their programming, must be submitted to and approved in writing by the Head of Planning
Any required remedial and/or protective measures shall be implemented in accordance with the approved schedule and documentary evidence to certify those works shall be provided to the satisfaction of the Head of Planning.
Addendum As stated above, Environmental Assessment has no objections to the approval of the application subject to the recommended conditions being attached to any consent.
NB. However, should all of the above conditions not be applied to any consent, Environmental Assessment will require to review the recommendation. In such event, it is imperative that this is notified immediately to the Environmental Assessment case officer.
Environmental Assessment - Scheme 2
Environmental Assessment has review planning application submission for the above mentioned application, as amended on 6th March 2013. Comments remain as per Scheme 1.
Environmental Assessment - Scheme 3
Environmental Assessment has review scheme 3 for the planning application submission 12/04007/FUL in relation to the Craighouse university campus development site.
Local Air Quality An air quality impact assessment (AQIM) was submitted in support of the application and updated in May 2014 for the scheme 3 proposals.
The assessment considers the potential air quality impacts associated with additional road traffic likely to be generated by the proposed development, also updated with the scheme 3 proposals. Dust arising from the construction phase of the works is also considered.
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Regarding the latter, mitigation measures are suggested within the AQIA to control adverse impact from demolition and construction dust. A condition is recommended to ensure that these measures are incorporated into the planning and operation of the constriction phase. In addition to these it is also recommended that bonfires are restricted during this phase of the work.
The assessment finds that an imperceptible increase in nitrogen dioxide (predominately road traffic) emissions are expected at existing sensitive receptors surrounding the site. The assessment concludes that this is a negligible impact as a result of the development. Similar conclusions are derived for the pollutant Particulate Matter 10 (PM10) concentrations. Proposed residential uses within the site are not anticipated to be exposed to excessive levels of nitrogen dioxide and PM10. Mitigation measures are therefore not prescribed for the effects on these pollutants.
Most of the pollution considered is derived from road traffic vehicles, where cars associated with the development being the most likely source. Car parking levels within the development are in keeping with the Council's Parking standards, however it is proposed, through Travel Plans, that encouragement will be given to residents, to use other alternative and more sustainable forms of transport. This is a positive aspect of the proposals. It is highlighted in Edinburgh's Local Transport Strategy 2014-2019 that the Council seeks to support increased use of low emission vehicles and as well as the extension of the network of EV (Electric Vehicle) charging points.
The City of Edinburgh Parking Standards for Development Management also now encourages the use of EVs. It states that the Council is likely to introduce a requirement for EV charging infrastructure which depends on how charging technology evolves this includes: • Dedicated parking spaces with charging facilities. • Ducting and infrastructure to allow electric vehicles to be readily accommodated in the future.
Developers should now consider the potential for EV charging as they develop their proposals. Based on currently available technology Environmental Assessment recommends that at least two Electric vehicle charging outlet should be of the following standard: 70 or 50kW (32 Amp) DC with 43kW (32 Amp) AC unit. DC charge delivered via both JEVS G105 and 62196-3 sockets, the AC supply by a 62196-2 socket. Must have the ability to be de-rated to supply 25kW to any two of the three outlets simultaneously.
It should be noted that support is available to developers to adopt EV's through the Energy Saving Trust's Sustainable Transport Advice Service and Interest Free Low Carbon Loans.
Grants are also available for the installation of EV charge points for workplaces, with 100% funding currently available for installations up to £10,000. More information can be found at http://www.energysavingtrust.org.uk/scotland/Organisations/Transport/Electric- vehicles/Electric-Vehicle-Charge-Point-Funding
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Environmental Assessment also advises that any Combined Heat and Power plant associated with the development must comply with the Clean Air Act 1993 and that the use of biomass will not be supported. Land contamination Previous use of the site includes Craighouse hospital. Some localised land contamination could be issue; hence the developer should undertake a site survey, as a minimum, to establish the level of risk posed to human health and the wider environment from any contamination in, on or under the land.
A condition to this effect is recommended.
Noise Potential noise conflict between the existing golf club-house at the south eastern end of the site and the proposed residential properties in that vicinity (Craiglea Place) has not been addressed in the Amenity Assessment undertaken by the developer. Differing from previous schemes, the gardens to these properties is closer to the club house, the west facade (closest to the clubhouse) has windows to habitable windows and there are balconies to the first floor bedroom. These changes indicate a potential for noise to be an issue, hence this requires a more detailed assessment. It is therefore recommended that that a condition to this effect is put on any permission given.
In conclusion, Environmental Assessment has no objections to the proposed development subject to the following conditions:
1. The construction phase of the development shall proceed in accordance with the requirements and recommendations of the air quality impact assessment (Wardell Armstrong, ST12296/ES01 November 2012, section 8.7). Informative; Bonfires should be restricted during demolition and construction.
2. Prior to the commencement of construction works on site: a. A site survey (including initial desk study as a minimum) must be carried out to establish to the satisfaction of the Head of Planning, either that the level of risk posed to human health and the wider environment by contaminants in, on or under the land is acceptable, or that remedial and/or protective measures could be undertaken to bring the risks to an acceptable level in relation to the development; and b. Where necessary, a detailed schedule of any remedial and/or protective measures, including their programming, must be submitted to and approved in writing by the Head of Planning
Any required remedial and/or protective measures shall be implemented in accordance with the approved schedule and documentary evidence to certify those works shall be provided to the satisfaction of the Head of Planning.
3. Prior to commencement of work, a noise impact assessment should be submitted to the Local Authority confirming that residents to the Craiglea Place properties will not be adversely affected by noise from the normal operations of the golf club-house, to the south east of the application site. Informative; Noise from the clubhouse should not exceed noise rating NR15 (inaudibility) in the nearest proposed residential property.
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Flood Prevention - Scheme 1
From the drainage strategy report (DSR) it seems the development is at a higher level compared to the two water courses and I will think there should be no need for an FRA if the developer can confirm the difference in level between the property ground level and the water level.
The developers surface water discharge figure is from a green field run off calculation and the discharge from the drained hard standing area after development should be calculated and compared to the green field run off and the lower must be adopted for discharge purpose. This should not exceed 4.5 l/s/h as this is the acceptable threshold in the council.
The developer should confirm that the proposed bund to be constructed behind the properties will not increase flood risk and erosion to other properties. The details of the proposed attenuation on site between the 1:30 and 1:200 runoff should be provided.
This seems to be a straight forward application if the developer can show the adopted discharge from the development is in line with CEC guidelines as explained. Please do not hesitate to get back to me if you want to discuss this further.
Flood Prevention - Scheme 2
I refer to your memo of 23 Jan. 2014, and would respond as follows, in respect of the "drainage strategy report, scheme 2" dated 02 Dec. 2013.
1. I would like confirmation that the "SUDS and flood protection drawing", appendix F to the above report, supersedes the "revised drainage plan" dated May 2013 and still current on the portal. 2. The report states that "It is proposed that the 30 year post development critical storm for the development site area be attenuated within the underground drainage system to the equivalent of 1 in 2 year greenfield run-off. It also states that "Full attenuation for a 1 in 30 year and 1 in 200 year storm event will be provided within the underground storage structures". The report does not explain the discrepancy between these statements. Either the drainage system is designed for a 200year storm, or there is overland flow which is not described in the report. 3. The drawings show the surface water system connected to a surface water sewer within the site. I have no knowledge of the existence of a sewer in this location. The developer should either confirm Scottish Water's agreement to the connection to this sewer, or provide an engineer's report on the likely acceptability of that sewer for adoption by Scottish Water. If the sewer shown requires replacement, the environmental impact should be considered. 4. The report does not show how the proposed attenuation facilities comply with the volumes shown to be required in the initial storage checks. 5. Confirmation will be required of the adoption of the proposed attenuation and treatment facilities.
Flood Prevention - Scheme 3
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In relation to drawing no 503 rev H and an email between Janice Smith of Goodsons and Professional Officer John Wharrie (dated 23rd July 2014) the Flood Prevention Unit have the following comments:
1. An allowable surface discharge of 8.4l/s was agreed during previous consultations with the Unit. The developer has increased this to 10.4l/s due to an additional 2l/s of existing hard surfaced landscape. This increase goes against our guidelines, taking the discharge to 5.68 l/s/ha instead of the allowable 4.5l/s/ha. The developer will need to decrease the proposed discharge to the acceptable and originally approved discharge of 8.4l/s. This can be placed on as a condition. 2. The developer intends to carry out remedial work on an existing Scottish Water sewer pipeline (potentially re-lining the pipe as this ensures minimal disturbance to the trees) to enable water to be discharged to it. Technical approval and acceptance by Scottish Water will be required. This can be placed on as a condition. 3. The location of the 'swale banks' will be determined on site due to the location of trees and the steep topography of the land. It is disappointing that this could not have been designed to a greater extent prior to planning approval being sought. The current proposals outlined in drawing 503 rev H is not of adequate detail and is technically incorrect. Further drawings detailing the exact bund location and the flowpaths that the surface water will flow are required prior to work starting on site. This can be placed on as a condition. 4. The entire drainage infrastructure must be completed and in good working order during the first phase. Care must be taken in positioning the site compound. This can be placed on as a condition. 5. The Flood Prevention Unit will not take on the responsibility of maintaining the proposed 'swale banks'. The banks must therefore be sited within the developer's land and a maintenance schedule proposed. If this is not possible the Flood Prevention Unit would recommend the refusal of this planning application. 6. Ground investigation results will determine the exact location of the SUDS infrastructure. Should the design alter significantly to that shown in drawing 503 rev H then further approval will be required from this Unit. This can be placed on as a condition.
Transport Planning - Scheme 2
I would advise that the application be refused.
A meeting was held on the 14th June 2013 with the consultants for the above scheme.
The issues that were discussed are attached as an appendix to this response with the Transport Planning's comments in italics to the developer's / consultants scheme 2 submission.
The main issues to the above are summarised as follows:-
1) Road geometry vertical and horizontal profiles. 2) Visibility profile. 3) Drainage and SUDS 4) Materials - no drawings have been issued with regard to the Council's concerns over the adoptable materials.
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5) It is not clear from the drawings on how the car parking conforms with the Council's standards. There are two proposed buildings which now have underground car parking. The drawings do not show the number of cars which will park in these areas.
Should the application be minded to grant then a suitable legal agreement will be required for the following:-
1) All costs associated with the adjustment of the signal timings at the Colinton Road / Myreside Road / Grays Loan / Merchiston Gardens junction as described in the Transport Assessment. 2) Contribution towards the Council's Safe Routes to School policy. 3) Contribution to the public transport infrastructure. 4) All costs associated with the Traffic Regulation Orders within the site and within the vicinity of the site.
Informative
The Lothian Buses terminus within the site has been removed. An alternative terminus for these services was considered at the Balcarres Street terminus but in order to introduce a turning head the developer would have to acquire 3rd party land.
Transport Planning - Scheme 3
There are no objections to the application.
The issues with regard to- 1) Road geometry vertical and horizontal profiles. 2) Visibility profile. 3) Drainage and SUDS 4) Materials 5) Parking
- which nessesiated the recommendation for refusal as per my memo of 3 Feb 2014 have been resolved in this submission.
As advised a suitable legal agreement is required for the following:-
1) All costs associated with the adjustment of the signal timings at the Colinton Road / Myreside Road / Grays Loan / Merchiston Gardens junction as described in the developer's Transport Assessment. (£10K) 2) Contribution towards the Council's Safe Routes to School policy (10K). 3) Contribution to the public transport infrastructure. Specifically the provision of an alternative bus termis in Balcarress Street to replace the one in the site being lost in this re-development (£100K) 4) All costs associated with the Traffic Regulation Orders within the site and within the vicinity of the site (£5K).
Children & Families - Scheme 1
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My comments are based on a residential development of 153 dwellings which comprise a mix of conversions and new build.
This site is located within the catchment areas of:
- South Morningside Primary School; - St Peter's RC Primary School; - Boroughmuir High School; and - St Thomas of Aquin's RC High School.
South Morningside is operating at near capacity and standard developer contributions would be sought for works to address accommodation issues either at the school or if considered necessary, and subject to Council approval, via a catchment change. In line with the Council's developer contributions policy (for school extensions) a contribution would be sought of £2,567 per house and £411 per flat
Boroughmuir High School is the catchment non denominational secondary school for the area and it is proposed to provide a replacement high school with increased capacity on a new site and again standard developer contributions would be sought towards the cost of this provision. In line with the Council's developer contributions policy (for school extensions) a contribution would be sought of £2,142 per house and £357 per flat
The combined cost would be £4,709 per house and £768 per flat and payment of contributions will be index linked to the BlCS All in Tender Price Index with a base date of October 2009.
St Peter's RC Primary School and St Thomas of Aquin's RC High School are also operating at capacity but it is proposed that management controls would be applied as necessary to give priority to baptised Roman Catholics to control future intakes.
Children & Families - further comments dated 4 April 2013
I refer to your memo dated 13 March, 2013 requesting any additional comments on educational provision for the above noted planning application. My understanding is that the number of proposed dwelling remains unchanged and my earlier comments made in December 2012 still apply.
Housing & Regeneration - Scheme 1
The applicant has accepted that an affordable housing contribution of 25% of the homes is required from this development. The Council consulted with our housing association partners, who reported to us that they felt they would not be capable of delivering homes that matched the market housing on this site, given the interplay of four crucial factors:
(1) firstly, there is a requirement for the affordable housing provider to match the external materials and finishes of the market homes in order to ensure the affordable housing successfully blends in, allowing for the creation of a mixed, sustainable integrated community on this prominent development;
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(2) secondly, the external materials and construction techniques are quite fixed in this case, given the Conservation Area requirements (and others) which require the new build developments on this site to blend in with the existing impressive A-Listed building(s);
(3) thirdly, there is a maximum subsidy level of £40,000 per home at present, which limits "affordable" housing tenures to a maximum of around £126,000 per unit in construction costs in order to be considered a viable and fundable prospect - and the estimated construction costs are considerably in excess of this figure on this site; and
(4) fourthly, Affordable Housing land is a time limited use-it-or-lose-it opportunity. Should the developer hand over the land on site for affordable housing, there is a very high risk in this case that the construction funding required to build a like-for-like property, that blended-in and met all Conservation Area requirements for the site, would not be forthcoming. In that scenario (which we have assessed as being highly likely to happen) the housing association would hold the land for a maximum of 5 years before having to hand the land back to the developer (under the use-it-or-lose-it rules), the developer would be entitled to build out the housing for market homes, and (in this scenario) no affordable housing would have emerged from this development.
Edinburgh has, however, never lost any land on the use-it-or-lose-it rules. In around 4% of cases, similar to this one, the Council has recommended an arrangement where the developer gifts a different plot of land to the Council for our RSL partners or the purpose of delivering affordable housing.
In order for such a recommendation to be made the developer has to provide their accounts to be scrutinised on a confidential Open Book basis, and the Council must be satisfied that an RSL could not, in fact, afford to build a like-for-like affordable home on site taking into account current subsidy levels.
That process is currently ongoing and is being explored. The developer has provided their books and these are being scrutinised at present. Once that process has completed I shall be able to report to you the outcome and the consequent AHP recommendation. I shall revert in due course.
Housing & Regeneration - Scheme 3
1. Introduction
I refer to the consultation request from the Planning Department about this planning application.
Services for Communities have developed a methodology for assessing housing requirements by tenure, which supports an Affordable Housing Policy (AHP) for the city.
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The AHP makes the provision of affordable housing a planning condition for sites over a particular size. The proportion of affordable housing required is set at 25% (of total units) for all proposals of 12 units or more.
This is consistent with Policy Hou 7 Affordable Housing in the Edinburgh City Local Plan.
2. Affordable Housing Requirement
Regarding the application for housing at Craighouse Campus, we have examined the planning application for compliance with the Affordable Housing Policy (AHP). The AHP is a planning requirement for all residential developments of 12 units or more, requiring an affordable housing contribution for 25% of the homes. This proposal consists of 145 homes and as such there will be an AHP requirement for 36 homes of approved affordable tenures.
The City of Edinburgh Council has a strong track record in the delivery of affordable housing resource through the Affordable Housing Policy, and this is delivered in 96% of cases as on-site affordable housing either through a Registered Social Landlord (RSL) or as unsubsidised affordable housing delivered directly to persons in affordable housing need by the developer.
In 4% of cases, where there has been a viability justification, the Council has accepted either a commuted sum of money or a plot of offsite affordable housing land in lieu of onsite affordable housing. In those cases, the plot of land provided by the developer for affordable housing should be located in the same or adjacent ward as the principal site. It needs to be capable of delivering more affordable housing, quicker, than if onsite. It also needs to be in an area where there is no existing concentration of affordable housing. A commuted sum would be calculated in accordance with the City of Edinburgh Council's Planning Guidance on Development Contributions and Affordable Housing and discussions with the Developer.
Taken together, those onsite and offsite affordable housing outcomes have ensured that Edinburgh has always secured an affordable housing contribution, in line with policy requirements, for every residential planning application of 12 homes or more. The policy framework that has been in place since May 2011 has helped to deliver record numbers of affordable homes whilst being flexible in situations where developers can evidence their scheme has viability concerns.
This planning application makes no provision for an affordable housing policy resource. The need for an AHP requirement has been known and acknowledged by the developer in previous iterations. We recommend that an acceptable provision for affordable housing should be included within the proposal.
I would be happy to assist in future discussions about the delivery of affordable housing from this application.
Historic Scotland - Scheme 1
We have considered your consultation and comment as follows:
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This letter is split into 4 distinct responses - firstly we set out our response to your council in regard to the Environmental Impact Assessment, secondly our assessment of the case for development, thirdly a response to the Development Management Procedure Scotland (Regulations) (DMPR), and fourthly the Listed Building Consent application (LBC).
1. Environmental Impact Statement The following comments are based on our statutory historic environment interests. That is scheduled monuments and their setting, category A listed buildings and their setting and gardens and designed landscapes and historic battlefields in their respective Inventories.
Baseline and Methodology In general, we are satisfied that the environmental statement has identified the most relevant historic environment baseline against which to test the proposals. While the assessment would have benefited from a more holistic consideration of the group of A listed buildings within their wider setting we have based our comments on the information provided within the environmental statement. While we are in general, content to agree with the findings of the majority of this assessment we would like to offer further detailed comments on some aspects of the findings of the assessment.
Physical Impact to Listed Buildings We note that the conversion of this large group of Category A listed buildings for residential use is considered to be a Major positive impact. Subject to the detail of the Listed Building Consent process we agree that the proposals will be of significant benefit to these historic environment assets in relation to their long-term sustainable future.
In-direct Impacts As noted above, the assessment reports on the individual listed structures and their settings and is less focused on a larger consideration of their context. Notwithstanding this we would generally agree with the findings of the assessment in relation to the impacts on the setting of these sites. However, we would not agree with the assessment findings in relation to the potential impacts on the settings of both South Craig House and Bevan House. In terms of the impact on South Craig House we note that the assessment considers that there will be a minor impact from the proposed Coulson Tower, citing the removal of the unsympathetic structure currently on the site. While we agree that the current structure detracts from the setting of South Craig the substantial scale of the Tower proposal would dominate views of South Craig and we do not consider that the removal of the existing structure mitigates this impact to any significant degree. To an extent this is recognised by the assessment but we would argue that the impact on the setting of South Craig is more than the minor impact reported in the assessment. We are of the view that the impact is likely to be of greater significance and should be considered at least a moderate impact on its setting, leading to a moderate to large significant negative impact.
Similarly we do not agree with the assessment finding relating to the setting impact on both South Craig and Bevan Houses through the insertion of a structure between these two sites. The assessment considers that there is no adverse impact in relation to this intervention as intervisibility between the two sites would not appear to be a key function of their relationship. While we agree that this intervisibility component between
Development Management Sub-Committee – 3 September 2014 Page 136 of 174 12/04007/SCH3 the two sites is not a great significance our concerns lie more with the reading of these two assets in their current setting. The inclusion of another structure between these two sites (as well as Clouston Tower to the south) would create a less readable relationship between the two sites within their landscape and create a more rigid grouping of buildings lining across the hillside. We would therefore argue that this constitutes a moderate impact on the setting of both South Craig and Bevan Houses.
2. Assessment of the Case for Development The case for development
Throughout the pre-application discussions the extent of new-build development has been discussed at length. The submitted scheme reflects discussions regarding the appropriateness of various sites across the campus, and addresses many of our earlier concerns. Our comments on individual components of the development are given later in this letter.
Underpinning the case for an appropriate level of development at the Craighouse campus is the key priority of providing a sustainable economic use for the whole site, but particularly for the listed buildings. The background to such a case was submitted as a development appraisal by the developers in 2011. That appraisal was subsequently (summer 2012) considered by Knight Frank on behalf of your authority. We have had sight of both the original appraisal and Knight Frank's report, and have had the latter considered by Scottish Government colleagues.
The 2011 development appraisal was based on the scheme as then drafted. Since that time considerable amendment has been carried out, although the basic economic model, with new build residential units supporting the restoration and conversion of the listed buildings to residential, remains the same.
We note from your recent correspondence (10 December) that your authority has requested further, updated development appraisal information from the applicants. We support your authority in seeking this information. We will respond separately outlining outstanding issues, many raised by Knight Frank, that we believe need to be addressed in the updated development appraisal.
We will be happy to comment further on the updated development appraisal as and when that information is received by your authority.
3. DMPR Comments: The setting of A-listed buildings
Design and Materials Our concerns expressed in earlier comments in regard to the initial rather fragmented style approach to the new buildings across the site have now been addressed, with a revised design strategy which is applied throughout the site. This employs a careful choice of materials, colours, and textures - all seeking to harmonise with the listed buildings and their landscape setting.
Individual sites We note that since September there have been considerable revisions to both the landscaping strategy, and design of the new buildings throughout the site. As the
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Kings Craig This site is immediately to the south of the main block of New Craig, and its location and the slopping topography of the site mean that any development here will be prominent. The omission of the 2 pinwheel blocks of flats on this site, and their replacement by a terrace of contemporary town houses is to be welcomed. In terms of impact to setting and built form, this design has a better relationship with New Craig.
West Craig We support the design revision to this site to tie these buildings in with nearby Kings Craig, whilst still maintaining an appropriate scale response to Queens Craig.
Old Craig Court The development of the current car parking site to the east of Old Craig has been an area of extensive discussion and revision. The initial concerns we voiced in regard to this area have been largely addressed, with new development fully integrating with its immediate parkland setting, as was discussed in Workshop sessions with A+DS.
The location of the terraced development is an appropriate distance down the slope to avoid a negative impact on the setting of Old Craig, which will retain its visual presence in the wider landscape in key views from the south.
North Craig We have supported development of the Boiler House site throughout the pre- application process. The form and design of the proposed buildings of North Craig are respectful of the architectural language of New Craig, and utilise the falling ground to their advantage while minimising impact to the listed building.
Old Grove Court The rationalisation of development to the fringe of the site has been significantly explored and developed since September. We do not believe Old Grove Court and its associated landscaping would have a detrimental impact to the setting of the listed buildings. The site sits low in parkland and is shielded by existing planting and boundary wall.
Craiglea Place As the proposed continuation of Craiglea Place is within a very discrete part of the site, it has no setting issue to the listed buildings.
Duncan and LRC site The submission of the application sees us consulted in regard to 2 new development sites which we have had no prior part knowledge of. It is proposed to build an 8-storey tower block on the site of the Learning Resource Centre to the Eastern ridge. Furthermore there is a proposal to build a 3-storey housing block between South Craig and Bevan on the eastern ridge. In terms of assessing the impact to the adjacent listing buildings, and the site as whole, we do not feel at this moment in time there has been adequate supporting material and dialogue to allow us to make a full assessment. We would reserve comment in regard to these new development sites until such time as we have further information.
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Listed Building Consent Comments
We welcome the sensitive conversion strategy which has been adopted by the applicant to the listed buildings. While we recognise that there may be scope to introduce a more intensive scheme that would see the building divided to a greater degree, this would not be an approach that we would generally support, as it would greatly harm the value and significance of the site. We have welcomed the opportunity to visit all the listed buildings - Old Craig, New Craig, Queens Craig, East Craig, Bevan, South Craig and the Lodge on a number of occasions throughout 2012 with your officer Barbara Stuart, William Gray Muir (Sundial Properties) and Andrew Stevens (Oberlanders Architects).
In general the subdivision of the listed buildings has taken full account of their character, plan-form, and surprisingly intact survival of high quality fixtures and fittings. Furthermore there are a number of significant conservation benefits by the removal of a number of un-sympathetic 20th century alterations.
General Points
Perhaps it would be helpful in the first instance to draw upon matters that have a commonality throughout the site. We are aware that some further clarification is required in regard to meeting the requirements of building standards, and importantly how these changes will impact on the fabric and appearance of the buildings.
We welcome however that it has already been established that individual balanced flues to apartments have been discounted due to the detrimental impact they would have on the exterior appearance of the building. Instead it has been proposed to rationalise, and group flues internally throughout the building in areas where minimal disruption to historic fabric will occur.
It is proposed to adopt a fire suppression system, this approach will allow for the retention of important fixtures and fittings (for example internal doors, decorative screens, and the abundance of stylised leaded lay-lights) which otherwise would be significantly altered or compromised to comply with fire regulations.
It is the intention of the applicant to refurbish all the windows by way of repair, it has been stated that no large scale replacement of windows is proposed, and it is not proposed to re-glaze with slim-profile.
As noted above there have been a number of site visits in the last year where alterations detailed on the current submitted set of drawings have been discussed. By agreement with all those present a number of changes have been made. However as yet, a large number of these have not been translated to the plans. We would ask that these changes are reflected in the most up to date drawings. This will allow us to have confidence that the submitted proposals are an accurate representation of the verbal assurances that have been given to date.
Specific Buildings
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Old Craig Whilst being the oldest building on site, a significant part of the interior has been heavily modernised. The proposed conversion seeks to sensitively restore the building back to a single dwelling. Furthermore we welcome the proposal to lime wash the building a traditional colour which will give the building a more authentic appearance.
New Craig In general we have no major concerns with the design strategy adopted to subdivide this vast building. The removal of fire partitioning to the 1st floor of the great hall is to be particularly welcomed, re-instating this impressive space back to its original appearance. As site visits have only very recently finished at New Craig, there have been a number of changes discussed that as yet have not been revised. We would welcome the opportunity to see these added before commenting in further detail. Added to the above, one key area which needs further discussion is the proposal to partition the ground North Wing spine corridor which runs off the Great hall past the former Dining Room.
Queens Craig We have no concerns with the design strategy adopted to subdivide this building.
Lodge The refurbishment of the lodge is sensitive and respectful to the building, the omission of the proposed large extension is welcomed.
East Craig We have no concerns with the design strategy adopted to subdivide this building. The loss of the late 20th century extension is to be welcomed.
Bevan In general the design strategy to subdivide this building causes us no major issues. However there are 3 points where further clarification and discussion has been required. We recognise that the configuration of the building was particularly designed for its use as accommodation for patients. In the case of Bevan, subdivision utilising the main stair to service the 3 proposed apartments has not proved practicable. The stair therefore becomes obsolete as a stair, however its high quality design, and the fact it is the principle stair dictates its meaningful retention. Furthermore it is our understanding that plans will be revised to omit the proposed slapping from the hall into the main reception room. The architectural design, quality and integrity of the hall is such that it should not be compromised. On site there was discussion about revising the design of the new entrance to the west elevation, we look forward to seeing this. We recognise that the villa buildings are very much designed in the round, with articulated faces to each elevation. Therefore any form of extension needs to be very carefully assessed in terms of the contribution it makes. The proposed extension to Bevan is located in a discrete area on the south elevation, it is our view that it does not have a detrimental impact to the character of the building.
South Craig In general the design strategy to subdivide this building into 3 apartment causes us no major issues. However as with Bevan, the principle of placing extensions onto this 4- sided building needs to be very carefully considered. On site we noted that we could not support the extension to the principle elevation.
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Historic Scotland - further comments dated 26 March 2013
Thank you for your consultation dated 13 March which we received on 13 March. We have considered your consultation and comment as follows: We propose to address your re-consultation in the same format as our previously submitted comments of 21 December 2012. Therefore we have split the response into 4 distinct sections; Environmental Impact Statement, Case for Development, Development Management Procedure Scotland (Regulations) and Listed Building Consent Application.
1. Environmental Impact Statement We note the minor amendments contained within the addendum replacement chapter for Archaeology and Cultural Heritage. In noting that the majority of the assessment remains unchanged we would refer you to our previous comments dated 21 December 2012 regarding assessment of impact, in particular the impact on the setting of South Craig and Bevan.
2. Assessment of the Case for Development In our response to your council on the 21 December 2012 we outlined that we would respond further to your authority on information that is commercially confidential. We did so on 21 January 2013 raising a number of issues that required further clarification. We note that there has been subsequent information submitted as part of this current re-consultation. Given the business sensitive nature of this particular matter we would welcome further discussion with your Council.
3. DMPR Comments: The Setting of the A-listed Building We note that the massing, form, layout and materials of the proposed new build have not changed since our last letter, and therefore, we would refer you to our previous comments dated 21 December, particularly in regard to Duncan and the LRC site.
4. Listed Building Consent Comments We welcome the updates made demonstrating a number of revisions since our last comments, in particular the reduction of extensions to South Craig and Bevan.
One point that still remains outstanding, however, is the proposal to partition the ground floor North Wing spine corridor which runs off the Great Hall, past the former dining room. Whilst it has been argued division of this space will be of advantage to the functioning of the apartment it is intended for, this has to be weighed against the disadvantage to the character, enjoyment and understanding of the public circulation spaces which elsewhere have been sensitively handled. We would urge further consideration of this matter.
We would ask that further consideration is given to establishing the provenance of decorative wallpapers which are to be found in both Old Craig and New Craig. Should it be established that they are authentic Victorian papers, a conservation based strategy should be established in terms of their practicable/reasonable retention/recording.
As noted above there remain a number of outstanding issues, and with this in mind we would value a meeting to discuss these at the earliest opportunity with your council.
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Historic Scotland - Scheme 2
Thank you for your consultation dated 17 December which we received on 17 December. We have considered your consultation and comment as follows:
Thank you for your consultation in regard to the Craighouse Campus site. As with our previous replies to your council we propose to split our letter into distinct sections which will address the following - Environmental Impact Assessment, Development Management Procedure Scotland (Regulations) (DMPR) and the Listed Building Consent application (LBC). In our conclusions we have included comments in relation to the importance of the future of the site being protected by the achievement of a sustainable development. We have concluded that the proposals do not raise issues of national significance for the historic environment such that we would object.
1. Environmental Statement As you will be aware, in our response to the original Environmental Statement (dated 21 December 2012) we raised a number of concerns regarding the assessment and its findings. The following comments relate to our original concerns against the updated assessment in light of alterations to the proposals.
Baseline and Methodology We remain content that the environmental statement has identified the most relevant historic environment baseline against which to test the proposals. In terms of our comments regarding a more holistic approach to the assessment of the buildings as a group we welcome the expansion of consideration in this area and are content with the findings, although we consider the impact to be more neutral than positive.
Duncan Our original concerns related to the impact this component of the development would have on the setting of South Craig and Bevan Villa and their legibility in their setting. We therefore note that this building has been removed from the proposals and as such have no further comments to offer on this issue.
Clouston We note that the vertical dominance of the original proposed tower has been lessened by its reduction in height. However, the substantial increase in the massing of the block form of the revised proposal remains a significant impact on the immediate setting of South Craig. We therefore consider that this impact remains more significant than the reported minor impact from the environmental assessment.
2. DMPR Comments: The Setting of A-listed Buildings
Individual Sites We note that since the previous public consultation in the Spring of 2013 there have been considerable revisions to both the landscaping strategy and the design of the buildings throughout the site. As the naming of some of the individual elements has changed since our last comments, I should emphasise that the comments below use the plot names from the current, revised scheme.
Kings Craig
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We note that the overall massing and scale of this row of townhouses has been reduced, particularly in regard to the central vertical element, and welcome this amendment as it will reduce the impact this element of the scheme will have on the setting of the historic buildings.
West Craig We note that the overall massing and scale of this row of townhouses has been reduced, and welcome this amendment, as it will reduce the impact this element of the scheme will have on the setting of the historic buildings.
North Craig Villas We have supported the re-development of the 'Boiler House Site' since it was tabled in the masterplan process, believing that a sensitively designed development in this location should be achievable with minimal impact of the adjoining listed building. From Spring 2013 there has been a comprehensive redesign of the terrace. The proposed buildings now present more of a traditional appearance echoing the existing run of ancillary buildings they will replace. In terms of impact to setting, New Craig will retain its visual dominance, as the new buildings will sit below the main range, utilising the falling ground to their advantage, and in longer views from the north will be screened by the surrounding woodland. We therefore welcome this amendment as it reduces the impact on the historic environment.
Craiglea Place The proposed terrace of 6 houses has been reduced to 4. As we have previously noted, the continuation of Craiglea Place is within a very discrete part of the site, and therefore has no setting impacts to the listed buildings.
Duncan The proposal to build a 3-storey housing block between South Craig and Bevan on the eastern ridge has been dropped from the scheme. We welcome this revision to the masterplan as we had major concerns in relation to the potential impact this aspect of development might have on the relationship between the listed buildings.
Clouston From Spring 2013 there has been a comprehensive redesign of the architectural language and scale of this block. We welcome the reduction in height of this building, which reduces its impact on long views and the site as a whole. This reduction has, however, been achieved by greatly increasing the floorplate of the building proposed. The greater bulk of this building, will, therefore, have a regrettably higher impact on the setting of the A Listed South Craig block immediately to its north.
Napier and Burton This site, currently the car-park and bus turning circle, has seen a number of revisions during the design process. The apartment blocks are a significant departure from earlier design approaches in terms of height, footprint and design. The increase in bulk of these proposals will inevitably have a considerable impact on the overall site, particularly in long views into and out from the higher ground to the south and from the historic approaches to the site.
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In terms of footprint, Napier has been located further down the slope away from Old Craig with the formation of a generous delineated courtyard and walled garden, allowing Old Craig an appropriate breathing space and contextual immediate setting.
We believe the combined visual envelope of Napier and Burton will have a greater impact to the setting of Old Craig than the previous schemes.
3. Listed Building Consent Comments We fully welcome the conversion strategy which has been adopted to the full suite of listed buildings on the site.
Whilst we recognise that there may be scope to introduce a more intensive scheme that would see the building subdivided to a greater degree, we greatly welcome that this application does not propose this. The internal layout, and high quality fixtures and fittings of Craighouse are of particular merit, and therefore a scheme that respects the existing plan form and features is to be welcomed.
We believe the proposed refurbishment works are sensitive, responsive and retain the special value and significance of the buildings.
4. Conclusion In the course of the last three years we have been consulted, either formally or via pre- submission discussions, with a wide variety of development approaches to the Craighouse site. Underlying all has been the imperative of achieving an economically sustainable, long term future for the existing listed buildings on the site, which are currently on the buildings at risk register
Your Council has been leading considerable negotiations in establishing the appropriate equilibrium of development in regard to the interests of the landscape value of the site (designated by the Council as an Area of Great Landscape Value) balanced with that of safeguarding this group of nationally important Category A-listed buildings.
We are aware that these discussions have shaped this revised applicattion. As noted above, we consider that some of the elements of the current revised submission will necessarily have a greater impact on the setting of certain of the listed buildings, or the wider group. Your authority is best qualified to consider this impact, which arises from the need to provide an appropriate level of development on the site to make it financially sustaining, and judge whether it is necessary in order to achieve the re-use of the site as a whole.
In terms of our locus and remit, our paramount objective has to be seeing these buildings removed from the Buildings at Risk Register with the guaranteed lifeline of a sustainable future. As noted above, the proposed refurbishment works are sensitive, responsive and should guarantee the preservation of the special value and significance of the buildings.
Historic Scotland - Scheme 3
Thank you for your consultation dated 03 June which we received on 03 June. We have considered your consultation and comment as follows:
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For the avoidance of doubt and clarity our assessment is based on Scheme 3 without making reference to past applications.
We propose to split our letter into distinct sections which will address the following: Environmental Impact Assessment (EIA), Development Management Procedure Scotland (Regulations) and the Listed Building Consent application (LBC).
1. Environment Statement The following comments are based on our statutory historic environment interests, that is scheduled monuments and their setting, category A listed buildings and their setting and gardens and designed landscapes and historic battlefields in their respective Inventories.
The Environmental Statement (ES) has identified an appropriate historic environment baseline against which to test the relative impacts of the proposals. We are satisfied that the methodology employed within the assessment is sound and are content to agree with the findings of the ES as they relate to our statutory remit.
2. DMPR Comments: The Setting of Listed Buildings The design, scale and materials of the proposed new build elements are acceptable in regard to their impact to the setting of the A-listed buildings. The listed buildings will retain their prominence, both within their immediate parkland setting, and in the wider city views of the site. In important views to and across the site, the open parkland character of the site is retained, particularly in light of the decision to leave the existing car-park site undeveloped. South Craig, Bevan and Old Craig will remain dominant in the foreground, whilst New Craig will retain its over-sailing visual dominance within the site composition.
3. Listed Building Consent Comments We are supportive of the overarching refurbishment strategy that is proposed to the full suite of Category A-listed buildings. In particular we welcome the care and consideration that has been focused of retaining and integrating significant elements of the internal layout and associated high-quality architectural fixtures and fittings.
4. Conclusion Our paramount objective is to see these buildings removed from the Buildings at Risk Register with the guaranteed lifeline of a sustainable future. The site at large has been vacant for over a year and is becoming increasingly vulnerable to acts of vandalism, theft, and general maintenance issues associated with empty and underused buildings and their surrounding environment. The proposed refurbishment works for the listed buildings are sensitive, responsive and should secure the preservation of the special interest and value of the buildings. The proposed new development (and associated ancillary works) by way of their design, scale and location effect an acceptable level of change to the site without eroding its key characteristics, experience and understanding. From a Historic Environment perspective the open parkland character of the site is retained, the hierarchy and relationship of the listed buildings maintained, and its uncertain future averted.
Scottish Natural Heritage - Scheme 1
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We note the recent correspondence dated 10 December 2012 from Edinburgh Council to the applicant, outlining the deficiencies in the EIA and application and requesting additional information. Provision of further information is likely to have a bearing on SNH's assessment of the proposal and on the advice that we provide. We therefore wish to withhold comment at this stage until the situation is resolved and further information is received.
Should additional information not be forthcoming and the Council proceed towards a decision, then we will review our position and provide comment on the application as submitted.
To note: a badger survey has not been issued with the current consultation although the EIA refers to one that has been carried out. A confidential report is mentioned in the correspondence referred to above but it is not clear if it is referring to this survey.
Scottish Natural Heritage - further comments dated 03 April 2013
Thank you for consulting Scottish Natural Heritage (SNH) on the planning application and Environmental Impact Assessment (EIA) for the above application on 20 November 2012, and its addendums on 14 March 2013. The comments below relate to both the application and EIA.
Position The proposals as submitted are likely to have adverse impacts on the natural heritage of Craighouse Campus and Easter Craiglockhart Hill, particularly in terms of landscape, visual and recreational amenity. We suggest that design modifications and mitigation measures to avoid, reduce and remedy likely impacts on natural heritage interests should be considered. We provide advice below on where these impacts are likely to be most acute and suggest various mitigation measures. However, it is for the planning authority to determine, within the context of its own policies, which modifications and conditions are necessary to secure these measures.
Background Easter Craiglockhart Hill is covered by several local designations and is a prominent landscape feature in the city, forming one of Edinburgh's seven hills. Craighouse campus is an old informal designed landscape, with listed buildings surrounded largely by woodland and open parkland and is well used for public access and recreation, both within the campus site and through the site to surrounding areas.
Our remit lies in the protection and enhancement of the natural heritage and this encompasses the overall enjoyment and appreciation of the natural heritage including landscape and visual amenity, access and recreation, and ecological interests including protected species. The focus of our response is therefore on potential impacts from the proposal on these areas of interest and advice on mitigation.
Assessment Impacts on landscape character, visual and recreational amenity There will be fundamental changes to the landscape character and visual amenity of the Craighouse site as the result of the proposals. The quantity and spread of enabling development in different locations throughout the site (including tree and woodland removal, proposed access roads, buildings, lighting, associated paths, signage, walls,
Development Management Sub-Committee – 3 September 2014 Page 146 of 174 12/04007/SCH3 drainage, proposed planting and extensive earthworks) will combine to have lasting effects on the landscape character of the site and will represent a significant change to the landscape, visual and recreational amenity that is currently afforded by the area.
The built proposals will change the current compositional relationship of the large institutional buildings (plus old Craig House) to the landscape, and alter the current spatial qualities and overall landscape character of the site. Important and sensitive views from the site will also be altered by the introduction of built development and associated planting, while large scale proposals, such as the Clouston Villa will appear in key views towards the site altering the established wooded and semi - natural profile of Easter Craiglockhart Hill.
The recreational amenity of the site will be altered as a result of the above physical changes but also through the changes to the current open accessibility and the introduction of new proposed areas of private and semi-private ground in locations around proposed residential dwellings. While restrictions to public access have been noted for such areas, we also highlight the likely change of user perception that will be brought about by the introduction of new residential areas which overlook and interact with current areas of accessible semi public/ semi private open space. We set out further information and advice on the nature of these effects in Annex 1.
While there are aspects of the proposals which we consider will have fundamental and adverse landscape and visual impacts, other aspects of the proposals, as put forward in the EIA and planning submissions, have been well considered in terms of their siting, detailed design and proposed landscape mitigation.
We consider that when all aspects of the proposal are combined, the overall extent and impact of the proposals on the existing landscape character, visual and recreational amenity of the whole Craighouse site is likely to be substantial. However, we consider that the most adverse impacts on landscape and visual amenity will result from the following key areas of the scheme:
• The proposed terraced housing, associated planting and ancillary development to the east of the principle open space (Old Craig Grove) Development in this location will adversely impact on the sense of openness and the landscape character of this important space. The proposed planting intended to soften the edge of the built development will not only reduce the scale of the open space but through time is likely to interrupt and fore-shorten panoramic views outwards to the city and its key landscape features.
• The proposed Clouston Villa: The proposed 8 storey Clouston Villa will be a prominent and contrasting feature, often seen to be breaking or intruding on the natural appearance of the wooded skyline of the Craighouse Campus/ wider Easter Craiglockhart Hill. We consider these impacts to be notably adverse in terms of landscape character and visual amenity.
We also consider that there will be notable and adverse impacts on natural heritage interests in the following areas:
• The proposed development at West Craig 2 and Kings Craig:
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We note the loss of areas of open woodland edge habitat in these areas and the substantial topographic modification that will be required in order to accommodate built development and ancillary infrastructure. We also highlight that the upper reaches of these buildings will be clearly visible in wider views from the north, potentially affecting the existing compositional arrangement of landscape and built development. The proposed weldmesh fence to separate these development areas from the hill would also be a somewhat intrusive feature and have some degree of impact on landscape and recreational amenity.
• The proposed development at North Craig We note that the potential screening and visual integration of this aspect of the scheme, within wider views towards the campus, relies to a large extent on retention of existing vegetation, much of which is in poor condition and of poor visual amenity. We would suggest that further detailed consideration is given to the need for additional tree work, planting or other design mitigation proposals in this area in order to secure the best possible integration of this development in wider views.
Impacts on Protected Species • Bats Based on surveys carried out to date, a small bat roost may be affected by the development. Therefore if the application is approved, along with the mitigation set out in the EIA, a licence from SNH may still be required by the applicant before they can proceed with the development. The EIA makes further recommendations on survey work.
Additional comments are provided in Annex 1.
[• Badgers The development will result in the loss of up to three badger setts. Therefore, if the application is approved, along with the mitigation and further survey work proposed in the EIA, a licence from SNH will be required by the applicant before the development may be started. Further information will also be required to inform a licence application, as proposed in the EIA. Additional comments are provided in Annex 1.
Summary and Conclusion We have concerns regarding the overall nature of the likely landscape and visual impacts arising from the development as proposed and the consequent effects on the recreational amenity currently afforded by users of the site. In principle, these concerns arise from the volume and spread of enabling development within different areas of the campus combined with the woodland and tree loss, which will lead to extensive changes to the landscape and visual character of the site and to the recreational amenity it currently provides.
While we acknowledge that the detailed design of the proposals and the associated landscape mitigation has, in many locations been appropriately handled, we suggest that there are still key areas of the site where particularly adverse effects on landscape character, visual and recreational amenity will occur. We therefore highlight particular concerns regarding the impacts arising from the proposals at:
• Old Craig Grove and the 8 storey Clouston Villa.
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In these areas we would advise that the impacts from these proposals could be beneficially reduced through their removal, reduction in scale or through reconsideration of their detailed siting, design and landscape mitigation.
• North Craig, West Craig 2 and Kings Craig In these areas we would advise that modification, proposed planting and further consideration of landscape mitigation could reduce landscape, visual and recreational impacts, while also achieving better integration of these proposals with their surroundings.
We consider that the EIA contains a lot of appropriate content with regards to landscape design and environmental mitigation. We therefore advise that the proposals for protection, mitigation measures and enhancement of natural heritage interests, as set out in the planning application materials and EIA, are considered closely and key principles are secured and adhered to as appropriate.
Matters which may need further consideration in terms of how they address natural heritage protection and enhancement, could be secured by the production of further information or through conditions or detailed agreements. Such matters include: • Protection of trees, soils and other natural heritage features during construction • Proposed planting and seeding • Detailed design of external works, including earthworks, walls, retaining structures and night time lighting • Long term landscape and woodland management • Species licensing details • Private garden / open-space boundaries • Long term public access, including clear way-marking and signage
In summary, should the Council be minded to approve the application in its current form we would suggest that our advice on modifications and mitigation is considered further. However it is for the planning authority to determine, within the context of its own policies, the nature of such modifications or which conditions and/or legal agreements are necessary to secure all the above measures.
Annex 1 Background to the application and Craighouse campus The application site is identified in the Edinburgh City Local Plan 2010 as having several local designations, as part of the wider Easter Craiglockhart Hill. The site is a prominent hillside location and lies within an Area of Great Landscape Value (AGLV), a Local Nature Conservation Site (LNCS), a Conservation Area and is adjacent to and part Local Nature Reserve (LNR). The LNR is also recognised as an accessible open space within Edinburgh's Open Space Strategy and the paths through the Craighouse site allow access to the LNR and beyond. Craighouse campus is therefore publically accessible and is currently well used for recreation, both within the campus and for access through the site to surrounding areas.
The status of the site therefore means that there are several planning policies covering the protection of the site and the wider hill. These policies are implemented and enforced by the local authority and therefore we have not sought to discuss them further here.
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Craighouse campus is also home to several listed buildings and therefore the site poses significant potential impacts on the historic fabric and designed landscape of the site, as well as natural heritage impacts. As a consequence, there have been several pre- application meetings and workshops between the planning authority, the applicants and Historic Scotland and SNH, to resolve potential impacts and try to find an acceptable solution. As part of this, all parties partook in the Architecture & Design Scotland (A&DS) design review process.
Detailed comments and appraisal of the proposal
Impacts on landscape character, visual amenity and recreational amenity Old Craig Grove - proposed built development, planting and ancillary development. The views towards Edinburgh from the existing path and the elevated areas of the grassed open space in the southern half of the Craighouse site are arguably amongst the finest views within Edinburgh. Such views are often gradually revealed in popular walks through the site (as one gains in elevation) either from the open grassland itself or between trees from the public path directing walkers upwards towards the summit of Easter Craiglockhart Hill.
In relation to such views, the foreground of natural elements within the Craighouse campus site are seen to be in defined contrast to the expanse of cityscape which dominates the view. The openness of the panorama, the complexity and the depth of the view is notable, with the key landscape and cultural features of the city (Arthur's Seat, Salisbury Crags, the Castle and rock, Carlton Hill, Blackford Hill and the Firth of Forth) acting as key reference points in the overall scene.
While much of this view is likely be retained, with key elements of the view often seen over or above the proposed built development, we have concerns that the important role that the semi-natural or landscape foreground plays in such views will be substantially altered by the introduction of the built elements of Old Craig Grove. For example, in the short to medium term, the notable contrast, or juxtaposition, between the semi-natural or landscaped space of Craighouse Campus and the wider urban backdrop, will be eroded.
In the longer term, the proposed planting, intended to mitigate or soften the impact of this built development, will likely grow to such a height that in itself it will fore-shorten and detract from the composition of this view. While the photomontages (for example from internal viewpoints 2 and 13) show the planting at an optimal age and size, the measures and means to restrict planting to this height will be difficult to secure.
The existing open space will also be subject to substantial change in terms of its overall form and its landscape character. This will be a result of the proposed physical reduction in the scale of open ground in this part of the Campus but, also in terms of the decreased sense of openness / increased sense of enclosure that will develop over time as the proposed planting matures.
The Clouston Villa We consider that the proposed Clouston Villa will adversely impact on the sense of naturalness and existing landscape character of Easter Craiglockhart Hill. These effects will be experienced from a range of locations, with a notable change to the
Development Management Sub-Committee – 3 September 2014 Page 150 of 174 12/04007/SCH3 landscape character of the hill particularly experienced in areas of close proximity to the site as viewed from the south.
While we recognise the poor siting and poor appearance of the existing LRC building, we would suggest that its scale is accommodated and the wider landscape and visual impacts arising from it are relatively contained. The proposed 8 storey building however brings substantial new or additional landscape and visual impacts into consideration.
In particular we highlight the manner in which the proposal will be experienced from areas to the south of the Craighouse Campus site, including areas within the Merchiston Golf Course, Glenlockhart Road and Wester Craiglockhart Hill (viewpoint 15). From such areas, and as seen in other more distant views, the proposed Villa intrudes on the skyline, breaking the wooded profile of the hill in a somewhat unusual or incongruous fashion. We consider that this occurrence will to some extent erode the natural quality of the hill as experienced from these locations.
From wider views from the north, for example viewpoint 18: Colinton Road, the proposed Villa (and the West Craig 2 proposals) will also intrude on the wooded horizon of Easter Craiglockhart Hill, potentially detracting from the existing focal point of New Craig House.
The proposed villa will also be a very large and dominant feature as experienced from within the site. Sitting on one of the highest parts of the application site, it will be very prominent from the large open space to the south of the site and would be notably different in scale to the existing and proposed pattern of built development along the western side of the site (i.e. the sequence of buildings: South Craig, Bevan, and Duncan).
Tree & Woodland loss There will be several areas of tree loss around the site, in particular the woodland to the south west which will be cleared to some extent to allow development of West Craig 2 and Kings Craig. Although tree loss has been voiced as minimal, this is based on removal of larger, more mature species of tree. In addition to this, there will be selective felling and clearing of smaller trees and shrubs, which will add to the overall vegetation loss on the site. The removal of trees and woodland, and subsequent changes to woodland edges etc, will have a detrimental impact on the amenity and biodiversity of the site, for example through impacts on landscape and visual amenity and on protected species like bat and badger.
The management objectives for the woodland and estate, as described in the Landscape and Woodland Management Plan, reflect good woodland management principles. We would be supportive of more positive management of the woodlands and highlight the need for this management to be long-term. The woodland will benefit from a better age and species structure, and with a focus on native species, will improve the biodiversity and amenity value of the woodland. It should be noted that beech trees are not native to Scotland, although given the nature of Craighouse campus as a designed landscape (and with some existing beech in the estate); some planting of beech would be acceptable as well as provide some amenity benefits.
We support the principle of public access and footpath provision as a way of providing continued public access and recreation within and through the site. We recommend an
Development Management Sub-Committee – 3 September 2014 Page 151 of 174 12/04007/SCH3 access plan be provided as a useful way to detail provision of different routes and paths through the site, together with associated waymarkers etc, with clear representation of private boundaries. It is noted that the provision of paths could usefully be used to 'manage' access in a way to reduce any tension between publically accessible and private land on the site. We would suggest that, similarly, the use of appropriate shrubs and planting could be used as a way of delineating such boundaries, which may have less of an impact on the amenity of the woodland than a fence.
Finally, we would support public involvement and management of the woodlands (and open space) where it helps to deliver positive management of these areas.
Ecology
Protected Species: • Bats Bats are a European Protected Species, protected under the Habitats Regulations 1994, as amended. This means that if the Council is minded to approve the application, it must satisfy itself, in line with statutory duties under the Habitats Regulations, that the licensing tests set out in those regulations are likely to be met before approving the application. If not, the Council could risk the applicant being unable to make practical use of the planning permission or committing an offence. Our advice in relation to the bat survey work undertaken is given below.
We are content with the findings of the bat surveys that have been undertaken. The initial survey in 2011 located a roost in Queens Craig and identified some potential others. The follow-up survey in 2012 did not find this roost or evidence of any other, although the surveyor cited a poor summer as a possible reason for this. Since some of the buildings do have roost potential and there is still some uncertainty over potential roosts, the surveyor has recommended another survey in 2013 to confirm (or otherwise) previous findings and ensure that there are no other roosts.
Although the bat roost situation is still not 100% certain, there has been enough information gained from the previous surveys to show that general bat use is low and largely consists of foraging bats moving around the area. The one roost identified in 2011 is small (3 bats), unlikely to be a maternity roost and the species is known (soprano pipistrelle). No other roosts have been located, even thought there is some uncertainty in some of the buildings. We would therefore recommend that the conclusions of the 2012 survey (page 14 &15 of the survey report) are followed, namely that: • A follow up survey is undertaken in 2013 to confirm/resolve any outstanding uncertainties as well as provide a final check before development and/or licence application • If this is not possible, then have a bat-worker on stand-by for the building works, in case any roosts are identified • To discuss bat licence requirements, depending on the nature of the building/roof works undertaken • Undertake mitigation as necessary e.g. roost provision in the buildings • Woodland management: further survey of mature trees with roost potential or soft felling on trees identified as having roost potential, depending on what woodland management or vegetation removal is proposed
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• We would also recommend appropriate lighting within the development - low level or directional particularly alongside the woodland edge, since survey result indicate that bats are foraging in the woodland areas. • The above measures could usefully be integrated into a species management plan for the site, to be adhered to during development.
Based on this information, it is likely that the licensing tests would be met and therefore that a licence would be granted. Please note that this advice is given without prejudice to any later consideration by SNH of an application for a licence.
• Badgers Badgers are protected under the Protection of Badgers Act 1992, as amended. Two badger reports have been submitted; one for 2011 and a follow up survey in August 2012. The initial survey contains no real recommendations or mitigation and is factually incorrect when it states that only the active sett is protected. All setts are protected, even if inactive, if they are part of an active territory. This is described under the legislation, where a badger sett is described as "any structure or place which displays signs indicating current use by a badger" where current use means "any sett within an occupied badger territory regardless of when it may have last been used". This means that the requirement for a licence may apply to all the setts found.
This is discussed further in the second survey, which also identifies two other setts. We are content with the conclusions of this survey and would agree that setts 1-3 may require destruction under licence if directly affected by the development footprint and woodland loss. The further recommended survey work to inform any such exclusion work and subsequent mitigation is thorough and SNH can provide further information on licensing and mitigation requirements as part of this process. • We therefore recommend that the further survey work and mitigation requirements described on page 7 & 8 of the 2012 badger survey are followed, to allow full consideration of the impacts on badger and to inform any licence requirements • In addition, during construction, work areas should be left safeguarded to prevent animals getting trapped and/or provide a means to escape. • As part of woodland management, wider consideration of the badgers and setts in the area will be required to assess any licensing requirements that may be needed, or species protection measures which may need implemented. • The above measures could usefully be integrated into a species management plan for the site, to be adhered to during development.
Wider Ecology The general recommendations made through the Ecology chapter are standard good practice and we recommend that these are followed during the development process. For example, in relation to breeding birds and timing of vegetation removal to avoid the breeding season.
Under Baseline Conditions in this chapter, the designated site information is incorrect. There are not two statutory designated sites within proximity to the application site but one - Wester Craiglockhart Hill SSSI. LNRs are non-statutory designated sites and therefore should be in the non-statutory section. The SSSI is not an LNR as mentioned; however Easter Craiglockhart Hill is an LNR and forms part of the application site.
Scottish Natural Heritage - Scheme 2
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Thank you for your consultation of 11th December 2013 on the revised application for Craighouse Campus, and the EIA addendum on 17th December 2013. The comments below relate to both the application and EIA.
1. Position
The revised proposals as submitted are likely to have adverse impacts on the natural heritage of Craighouse Campus and Easter Craiglockhart Hill, particularly in terms of landscape, visual and recreational amenity. We note that the revised proposals have positively addressed several key aspects of concern, as set out in our response to the original application, especially in relation to the southern part of the site and open space. However, we consider that there are some new or residual issues of importance for consideration in this application. These primarily relate to the landscape and visual impacts arising from the scale of built development and the resultant effects on people's enjoyment of the natural heritage, including key views.
In responding to the revised application we provide advice below, and in Annex 1 (attached), on: • likely impacts on natural heritage interests that have changed from the original application; • likely impacts that remain as an important issue; and • new issues of importance to the natural heritage.
These relate to landscape and visual impacts, and impacts on protected species. We also highlight mitigation measures or key application details that could assist in reducing anticipated impacts on the natural heritage.
2. Background
We previously responded on 3rd April 2013 to the earlier application and EIA. The comments on this revised scheme and EIA addendum are given below. However, some parts of our original response are still relevant, including background description of the site and detailed advice on the context for certain aspects of the development proposals. We have not repeated all this advice in this response but do recommend that both responses are read in conjunction with each other.
3. Impacts on landscape character, visual and recreational amenity
There will be fundamental changes to the landscape character and visual amenity of the Craighouse site as the result of the proposals. The quantity and scale of enabling development in certain locations throughout the site (including tree and woodland removal, proposed access roads, buildings, lighting, associated paths, signage, walls, drainage, proposed planting and extensive earthworks) will combine to have lasting effects on the landscape character of the site and will represent a significant change to the landscape, visual and recreational amenity that is currently afforded by the area.
Some of the changes that have been made to the proposed development (when compared to the previous submission), including the removal of the proposed terraced housing at Old Craig Grove and the reduction in height of the Clouston Villa, have significantly and positively addressed several of SNH's original concerns. However, we
Development Management Sub-Committee – 3 September 2014 Page 154 of 174 12/04007/SCH3 note that the re-positioning of enabling development within the site has raised new implications for landscape and visual amenity. We consider the most significant impacts arising from the new proposal to be the intrusion of large scale built form (arising from the Burton and Napier Villas) into panoramic outward views from the neighbourhood park/ principle open space within the site.
The overall recreational amenity of the site will be altered as a result of the likely physical changes proposed to the site. When compared to the original submissions however, we consider that the concentration of development, its design relationship to principle open spaces and the clarification of access arrangements and overall site management, assist in providing a better understanding of what these effects are.
We consider that the overall extent and impact of the new proposals on the existing landscape character, visual and recreational amenity afforded by the Craighouse site is still likely to be substantial. The most adverse impacts on landscape and visual amenity will result from the following key area of the scheme:
• The proposed Burton and Napier Villas These two proposed buildings are large in scale and will provide imposing foreground features changing the composition and nature of outward views from the neighbourhood park/ principle open space. The submitted visualisations (Internal Viewpoints 1 and 2) illustrate that the degree of impact will vary depending on the particular location in relation to the open space. In certain instances, views towards the surrounding woodland and the City's landmark features will be obscured or partially curtailed by foreground built development. The open nature of views from this area and the important and well balanced composition of existing built development and natural features will also be altered.
We also consider that there will be notable and adverse impacts on natural heritage interests in the following areas:
• The proposed Clouston Villa We recognise that the proposed 5 storey Clouston Villa has been reduced in height to better reflect the height of nearby tree cover and to reduce the skyline effects of the development. However, its footprint has expanded and it remains a large scale proposal in a prominent location. Due to its scale and location we consider it will be a somewhat dominant feature of the landscape as experienced from within the site, particularly for the users of the neighbourhood park/ principle open space.
• The proposed development at West Craig and Kings Craig We note the loss of some areas of open woodland edge habitat in these areas and also the extensive topographic modification that will be required in order to accommodate built development and ancillary infrastructure in this location. We do however acknowledge the generally positive changes from the previous proposal.
The upper reaches of these buildings will be clearly visible in wider views from the north, potentially affecting the existing compositional arrangement of landscape and built development.
Compared with the original proposal we welcome the design changes to replace proposed weldmesh fence and retain the trees to the south, with additional tree
Development Management Sub-Committee – 3 September 2014 Page 155 of 174 12/04007/SCH3 planting to the south of these buildings. These changes will help to reduce impacts on woodland amenity and biodiversity, as well as reduce tree loss on the site.
• The proposed development at North Craig There may be widespread landscape and visual impacts arising from this development by virtue of its location and the condition of existing vegetation, much of which is in poor condition and of poor visual amenity. The poor quality of functional screening potentially makes the proposed development highly visible from the north, particularly in winter and also during night time conditions where lighting effects will be highly noticeable. We therefore welcome the proposed management of existing vegetation and the proposed new planting, which if delivered at a suitable scale and density, and managed well over the longer term, will partly mitigate likely impacts.
4. Impacts on Protected Species
4.1 Bats Surveys were undertaken in 2011 and 2012 for the previous application. These surveys identified low usage of the site by bats and because the revised application was unlikely to affect the findings of these surveys, no further surveys have been undertaken. These surveys, identified a small bat roost that may be affected by the development and as such a licence may be required.
Therefore if the application is approved, even with the mitigation set out in the EIA, a licence from SNH may still be required by the applicant before they can proceed with the development. The EIA makes further recommendations on survey work and this is discussed further in Annex 1.
4.2 Badgers A badger survey was undertaken in 2013 for the EIA addendum. However this does not appear to make reference to the badger surveys undertaken in 2011 and 2012 for the previous application. The results for this current survey differ from the previous ones, and setts previously identified as active have not been addressed in the latest survey. Our advice is based on all surveys.
The current survey identifies one active sett, S1, within the development footprint. S1 will not be directly affected by development but may be subject to disturbance, which would require a licence. The 2012 survey also identified an active sett S2 which potentially lies within the footprint of the Burton Villa and may therefore be lost to development; again a licence may be required. The current status of S2 was not addressed in the 2013 survey.
Therefore, if the application is approved, along with the mitigation proposed in the badger reports, a licence from SNH may be required by the applicant before the development may be started. This licence may potentially relate to disturbance or both disturbance and exclusion. This will require clarification in order to inform licence requirements and is discussed further in Annex 1.
5. Summary and Conclusion
There are likely to be adverse impacts on the natural heritage of Craighouse Campus and Easter Craiglockhart Hill, particularly in terms of landscape, visual and recreational
Development Management Sub-Committee – 3 September 2014 Page 156 of 174 12/04007/SCH3 amenity. These mainly relate to landscape and visual impacts arising from built development and the resultant effects on people's enjoyment of the natural heritage, including key views.
As discussed in our previous and current response, the EIA and addendums contain a lot of appropriate content with regards to landscape design and environmental and species mitigation. We therefore advise that the proposals for protection, mitigation measures and enhancement of natural heritage interests, as set out in the planning application materials, EIA and its addendums, are considered closely and key principles are adhered to as appropriate. These include matters such as:
• Protection of trees, soils and other natural heritage features during construction. • Proposed planting and seeding. • Detailed design of external works, including earthworks, walls, retaining structures and night time lighting. • Long term landscape and woodland management. • Long term public access provision. • Species licensing details.
Should the Council be minded to approve the application in its current form we would suggest that our advice on mitigation is considered further. However it is for the planning authority to determine, within the context of its own policies, whether conditions are necessary to secure this mitigation.
Scottish Natural Heritage - Scheme 3
Thank you for submitting the most recent badger survey information in relation to the above application and EIA.
1. Position We have responded separately to the above application and EIA (4 July 2014). The 4 July response omitted advice on badgers as further information was yet to be received. This current response relates only to the badger surveys and provides advice on likely impacts on badgers, mitigation and licence requirements.
2. Advice A badger survey update has been carried out in 2014 as part of the current ES. This information has now been submitted and we provide advice on likely impacts, mitigation or licence requirements, based on this update and the previous surveys.
A badger survey was undertaken in 2013 for the previous EIA addendum at the end of 2013. However this did not make reference to the badger surveys undertaken in 2011 and 2012 for the previous application. The results for the 2013 survey differed from the previous ones, and setts previously identified as active were not addressed in the 2013 survey. Our advice was therefore based on all surveys. The 2014 update discusses licensing requirements in terms of distances and disturbance but has not addressed these inconsistencies or clarified the status of these different setts.
The 2013 survey identified one active sett, S1, within the development footprint. S1 will not be directly affected by development but may be subject to disturbance, which would require a licence. The 2012 survey also identified an active sett S2 which potentially
Development Management Sub-Committee – 3 September 2014 Page 157 of 174 12/04007/SCH3 lies within the footprint of the Burton Villa and may therefore be lost to development; again a licence may be required. The current status of S2 was not addressed in the 2013 survey and has not been addressed within the update.
Therefore, our advice remains the same as that previous, in that if the application is approved, along with the mitigation proposed in the badger reports, a licence from SNH may be required by the applicant before the development may be started. This licence may potentially relate to disturbance or both disturbance and exclusion. This will require clarification in order to inform licence requirements and is discussed further in Annex 1.
Annex 1 Detailed Comments Badgers Badgers are protected under the Protection of Badgers Act 1992. A 2013 survey and monitoring report were completed, following on from recommendations made within the 2012 survey report. The recommended further survey work was to gather more detail on the use of the setts 1-3, as identified in the 2012 survey, to fully inform any mitigation required and any licencing requirements.
However, the 2013 report only identified and surveyed sett S1. Other setts identified in the 2012 survey were not re-surveyed, in particular, sett S2, which was identified as an active sett, probably requiring exclusion under licence (this is sett S2 as described in the 2012 survey; not the S2 in the 2013 survey which confusingly refers to a different sett and location).
In terms of sett S1, we are content with the findings of the 2013 survey and its conclusions, including the potential licence requirement for disturbance. The proposed mitigation strategy on page 5 & 6 of the badger protection plan contains clear guidance on licence requirements and measures to be followed in order to ensure no offence is committed. The 2014 update, based on the scheme 3 design, confirms this potential for disturbance still applies. We therefore recommend that the badger protection plan is adhered to.
In terms of sett S2 (2012 survey), it is unclear whether the revised application will result in the direct loss of this sett or whether it will be affected by disturbance. It is likely that a licence will be required, although we cannot advise fully on licence requirements due to the lack of detail. We therefore recommend that the extra survey work, as per the 2012 survey recommendations, will be required in order to gain more detail on current usage of sett S2 (2012) and inform licence requirements.
Lothian & Borders Badger Group - Scheme 1
I wish to object to this development on the basis that badgers, a protected species, are present on the development site and mitigation measures have not been agreed with the planning authority.
It is known that badgers from a nearby main sett have established setts within the woodland areas of Napier campus and rely on it for foraging. The proposed development appears to be located possibly on or very close to at least one of the setts.
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As a non statutory consultee we hope to be consulted with regard to the badger mitigation plan when one becomes available.
SEPA - Scheme 1
We object to this planning application unless the modifications in section 1 can be adequately accommodated. Please also note the advice provided below.
Advice for the planning authority
1. Surface water 1.1 We note the Drainage Strategy Report (September 2012) which has been submitted in support of the application. As we understand, surface water from each property is to be treated within deepened porous pits adjacent on a plot by plot basis, prior to discharging to the existing Scottish Water sewer. It is also stated that 'carriageway drainage is to be collected, treated and attenuated in a large storage unit at the end on the onsite system, before being discharged into the sewer at the appropriate rate'. However, this proposal is not reflected in Drawing Number 11221 'External works - Drainage Layout'.
1.2 Best practice requires that two levels of surface water treatment should be provided for residential developments of more than 50 houses. An exception is run-off from roofs which requires only one level of treatment.
1.3 At present, only one level of treatment has been demonstrated in the form of permeable paving in each driveway. No levels of treatment have been considered for roads. We therefore object to the proposed scheme and request that the surface water scheme is modified to provide at least two levels of surface water treatment prior to discharging to the water environment.
1.4 We also note that surface water run-off from existing buildings will continue to discharge directly to the existing surface water sewer. While there is no requirement for run-off from these areas to be treated in line with the principles of SUDS, we would strongly recommend that in order to protect water quality, run-off from existing buildings receives some form of treatment prior to discharging to the water environment. Further information for the applicant on the design of such systems is detailed below under section 3.
1.5 Please note, we have not considered the water quantity aspect of this scheme. Comments from Scottish Water, where appropriate, the Local Authority Roads Department and the Local Authority Flood Prevention Unit should be sought on any water quantity issues. Detailed advice for the applicant
2. Surface water 2.1 We have requested that the existing SUDS scheme is modified to provide two levels of treatment for all areas of hard-standing prior to discharging to the water environment. Further guidance on the design of such systems and appropriate levels of treatment can be found in CIRIA's C697 manual entitled The SUDS Manual. Advice can also be found in the SEPA Guidance Note Planning advice on sustainable
Development Management Sub-Committee – 3 September 2014 Page 159 of 174 12/04007/SCH3 drainage systems (SUDS). Please refer to the SUDS section of our website for details of regulatory requirements for surface water.
2.2 For technical guidance on techniques and treatment for road water run-off, please refer to the SUDS for Roads manual. Regulatory advice for the applicant
SEPA - further comments dated 11 April 2013
In previous correspondence dated 14 November 2012, we objected to this proposal and requested that the proposed surface water management scheme be modified.
We note the Addendum to the Environmental Statement dated February 2013 which has been submitted in support of the application and we can now advise that we have no objection to this proposal. Please note the advice provided below.
Advice for the planning authority
1. Surface water 1.1 We note the updated Drainage Strategy Report (January 2013) which has been submitted in support of the application. We would like to highlight that Drawing Number 503 of the Report has been updated by Drawing Number 503 Revision B. SEPA received this revised drawing from Goodsons Associates further to discussions regarding surface water outfall. The plan was forwarded to City of Edinburgh Council on 10 April 2013.
1.2 We understand from the Drainage Strategy Report that surface water will discharge to the existing surface water sewer to the north of the site. Run-off from each plot will discharge to the water environment via porous paving with a granular sub- base. Carriageway drainage is to discharge via filter trenches and a 'treatment pit'. The surface water drainage proposal outlined is acceptable to us in principle in terms of water quality, as it provides the required level of treatment for surface water run-off from the development.
1.3 Prior to any works commencing on site however, SEPA would require additional details of the end of pipe 'treatment pit' to ensure that this facility will provide adequate surface water treatment prior to discharging to the water environment. Specifically, justification should be provided regarding how this SUDS facility meets the standards set out in the SUDS Manual CIRIA 697.
1.4 Although there is no requirement for the surface water run-off from the existing buildings to be treated prior to discharge, we welcome the commitment to utilise the already proposed treatment units to treat run-off from existing properties where possible.
1.5 Please note, we have not considered the water quantity aspect of this scheme. Comments from Scottish Water, where appropriate, the Local Authority Roads Department and the Local Authority Flood Prevention Unit should be sought on any water quantity issues. Regulatory advice for the applicant
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2. Regulatory requirements 2.1 Details of regulatory requirements and good practice advice for the applicant can be found on our website. If you are unable to find the advice you need for a specific regulatory matter, please contact a member of the operations team in SEPA's Edinburgh office.
SEPA - Scheme 2
We have no objection to this planning application. Please note the advice provided below.
Advice for the planning authority 1. Surface water drainage 1.1 We understand from the Drainage Strategy (DS) report written by Goodson Associates (November 2013) that "surface water will be collected, treated and attenuated then discharged into the Scottish Water sewer in the north". The surface water drainage proposal outlined is acceptable to us in principle in terms of water quality, as it provides the required level of treatment for surface water run-off from the development. Detailed advice for the applicant
2. Surface water drainage 2.1 Further guidance on the design of SUDS systems and appropriate levels of treatment can be found in the CIRIA C697 manual entitled The SUDS Manual. Advice can also be found in our Guidance Note Planning advice on sustainable drainage systems (SUDS). Please refer to the SUDS section of our website for details of regulatory requirements for surface water and SUDS.
Regulatory advice for the applicant 3. Regulatory requirements 3.1 Details of regulatory requirements and good practice advice for the applicant can be found on our website at www.sepa.org.uk/planning.aspx. If you are unable to find the advice you need for a specific regulatory matter, please contact a member of the operations team in your local SEPA office.
SEPA - Scheme 3
Thank you for your consultation letter which SEPA received on 29 May 2014. We have no objection to this planning application. Please note the advice provided below.
Advice for the planning authority
1. Surface water drainage 1.1 The surface water treatment (SUDS) proposed is considered acceptable. We would highlight to the applicant that the surface water drainage on site must comply with General Binding Rules 10 and 11 of The Water Environment (Controlled Activities) (Scotland) Regulations 2011. 1.2 SEPA welcomes the statement within the accompanying Drainage Strategy Report by the Craighouse Partnership (dated May 2014) which states that, in relation to existing building surface water runoff, "although, there is no requirement for this, we will, where possible, utilise the already proposed treatment units to treat the run-off".
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1.3 Please note, we have not considered the water quantity aspect of this scheme. Comments from Scottish Water, where appropriate, the Local Authority Roads Department and the Local Authority Flood Prevention Unit should be sought on any water quantity issues.
2. Flood risk 2.1 We have reviewed the enclosures submitted with this consultation in respect to flood risk and from the information supplied no flood risk is immediately apparent. There are known flooding issues mentioned in the supporting documentation at the junction of Craighouse Road and Craighouse Gardens. As there will be attenuation storage tanks and a decrease in hard surfaces, there will be a betterment to the current situation and hence we do not object to the development. Detailed advice for the applicant
3. Surface water drainage 3.1 Further guidance on the design of SUDS systems and appropriate levels of treatment can be found in the CIRIA C697 manual entitled The SUDS Manual. Advice can also be found in our Guidance Note Planning advice on sustainable drainage systems (SUDS). Please refer to the SUDS section of our website for details of regulatory requirements for surface water and SUDS.
4. Flood risk 4.1 Please note that we are reliant on the accuracy and completeness of any information supplied by the applicant in undertaking our review, and can take no responsibility for incorrect data or interpretation made by the authors. 4.2 The advice contained in this letter is supplied to you by SEPA in terms of Section 72 (1) of the Flood Risk Management (Scotland) Act 2009 on the basis of information held by SEPA as at the date hereof. It is intended as advice solely to Edinburgh Council as Planning Authority in terms of the said Section 72 (1). Our briefing note entitled: "Flood Risk Management (Scotland) Act 2009: Flood risk advice to planning authorities" outlines the transitional changes to the basis of our advice inline with the phases of this legislation and can be downloaded from www.sepa.org.uk/planning/flood_risk.aspx. Regulatory advice for the applicant
5. Regulatory requirements 5.1 Details of regulatory requirements and good practice advice for the applicant can be found on our website. If you are unable to find the advice you need for a specific regulatory matter, please contact a member of the operations team in your local SEPA office.
Scottish Water - Scheme 1
Scottish Water has no objection to this planning application. This response is made based on the information available to us at this time and does not guarantee a connection to Scottish Water's infrastructure. A separate application should be submitted to us made for connection to our infrastructure after full planning has been granted.
Due to the size of this proposed development it is necessary for Scottish Water to assess the impact this new demand will have on our existing infrastructure. With Any
Development Management Sub-Committee – 3 September 2014 Page 162 of 174 12/04007/SCH3 development of 10 or more housing units, or equivalent, there is a requirement to submit a fully completed Development Impact Assessment form. Development Impact Assessment forms can be found on our website.
Glencorse Water Treatment Works - has limited capacity available for new demand. The Developer should discuss their development directly with Scottish Water.
Water Network - Our initial investigations have highlighted their may be a requirement for the Developer to carry out works on the local network to ensure there is no loss of service to existing customers. The Developer should discuss the implications directly with Scottish Water.
Edinburgh PFI Waste Water Treatment Works currently has capacity to service this proposed development.
Wastewater Network - Our initial investigations have highlighted their may be a requirement for the Developer to carry out works on the local network to ensure there is no loss of service to existing customers. The Developer should discuss the implications directly with Scottish Water.
In some circumstances it may be necessary for the Developer to fund works on existing infrastructure to enable their development to connect. Should we become aware of any issues such as flooding, low pressure, etc the Developer will be required to fund works to mitigate the effect of the development on existing customers. Scottish Water can make a contribution to these costs through Reasonable Cost funding rules.
Scottish Water is funded to provide capacity at Water and Waste water Treatment Works for domestic demand. Funding will be allocated to carry out work at treatment works to provide growth in line with the Local Authority priorities. Developers should discuss delivery timescales directly with us. Developers should discuss delivery timescales directly with us.
If this development requires the existing network to be upgraded, to enable connection, the developer will generally meet these costs in advance. Scottish Water can make a contribution to these costs through Reasonable Cost funding rules. Costs can be reimbursed by us through Reasonable Cost funding rules
A totally separate drainage system will be required with the surface water discharging to a suitable outlet. Scottish Water requires a sustainable urban drainage system (SUDS) as detailed in Sewers for Scotland 2 if the system is to be considered for adoption.
Appropriately sized grease traps must be installed on all drainage outlets from food preparation areas. No substance may be discharged to the public sewerage system that is likely to interfere with the free flow of its content, have detriment to treatment/disposal of their contents, or be prejudicial to health.
Scottish Water's current minimum level of service for water pressure is 1.0 bar or 10m head at the customer's boundary internal outlet. Any property which cannot be adequately serviced from the available pressure may require private pumping arrangements installed, subject to compliance with the current water byelaws. If the
Development Management Sub-Committee – 3 September 2014 Page 163 of 174 12/04007/SCH3 developer wishes to enquire about Scottish Water's procedure for checking the water pressure in the area then they should write to the Customer Connections department at the above address.
If the connection to public sewer and/or water main requires to be laid through land out- with public ownership, the developer must provide evidence of formal approval from the affected landowner(s). This should be done through a deed of servitude.
It is possible this proposed development may involve building over or obstruct access to existing Scottish Water infrastructure. On receipt of an application Scottish Water will provide advice that advice that will require to be implemented by the developer to protect our existing apparatus.
Transport Scotland - Scheme 1
The comments of the Trunk Road and Bus Operations Directorate (TRBOD) are as follows:
The proposed development represents an intensification of the use of this site however the percentage increase in traffic on the trunk road is such that the proposed development is likely to cause minimal environmental impact on the trunk road network.
On this basis TRBOD has no comment to make.
Transport Scotland - EIA response dated 24/07/2014 (Scheme 3)
With reference to your recent correspondence on the above development, we write to inform you of our involvement as Term Consultants to Transport Scotland - Trunk Road and Bus Operations (TRBO) in relation to the provision of advice on issues affecting the trunk road network. We have reviewed the Environmental Statement (ES) prepared by Wardell Armstrong on behalf of Craighouse Partnership in support of the above development. Having reviewed the information provided, we would make the following comments on behalf of Transport Scotland. This response relates only to the Environmental Impact Assessment consultation and Transport Scotland will respond separately to the planning application for this development if formally consulted.
Development Proposals We understand that the proposal is for the change of use and conversion of existing buildings at Craighouse Campus to residential use and the erection of new build residential premises. We note that the campus is approximately 3km south-west of Edinburgh City Centre and approximately 3km north of the A720(T) City Bypass. The proposals will result in 145 new dwellings.
Environmental Impacts We note that the environmental impacts associated with the traffic generated by the proposed development have not been considered. However a Transport Assessment (TA) has been produced for the proposed development which we have reviewed in terms of the volume of traffic generated at the A720(T) trunk road.
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Based on our review of the TA we can confirm that the generated traffic volumes are not significant in terms of the trunk road network and we can confirm that any associated environmental impacts at the trunk road network would be negligible. We can confirm that Transport Scotland is generally satisfied with the submitted ES and is satisfied that there are no significant trunk road impacts.
I trust that the above is satisfactory but if you have any questions please do not hesitate to contact me at our Glasgow Office.
Police Scotland - Scheme 1
I am writing on behalf of Police Scotland to provide comments on the above planning application.
Observations and comments The area surrounding Craighouse experiences a low recorded crime rate. • Reference should be made to the New Homes Secure By Design document for guidance on standards and layouts. • Consideration should be given by the architects and client to applying for Secure By Design.
Police Scotland - Scheme 2
I am writing on behalf of Police Scotland to provide comments on the above planning application.
Observations and comments The area surrounding Craighouse experiences a low recorded crime rate. • Reference should be made to the New Homes Secure By Design document for guidance on standards and layouts. • Consideration should be given by the architects and client to applying for Secure By Design.
Police Scotland - Scheme 3
I am writing on behalf of Police Scotland to provide comments on the above planning application. Observations and comments - We have no comments or recommendations to make.
Health & Safety Executive - Scheme 1
The regulations have amended the scope of consultation with HSE. As from 1st June 2011 HSE should only be consulted where Environmental Impact Assessments (EIA) applications fall within the Consultation Distant (CD) of a major hazard sites and/or major hazard pipelines. HSE will continue to be consulted on any EIA which falls within the scope of The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000.
As this consultation does onto appear to fall within the required guidelines I am returning your paperwork. However if you feel this application does fall within the guidelines please return to this office stating the reason HSE is being consulted.
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Architecture & Design Scotland
1.00 Introduction [This summarises project status and background information that was indicated to A+DS prior to the workshop or clarified by the parties during the workshop. In the event that any of the statements made in this introduction are considered incorrect A+DS should be advised and the report will be amended.]
1.01 The project is classified by A+DS as a Locally Significant Project under the Design Forum programme. The proposals have been through a number of significant design iterations since first referred to Design Forum jointly by the developer and the by City of Edinburgh Council on 12 June 2012. A+DS have previously visited the site and run three Forums with the Project Team on 12thJune, 18th June and 1st August 2012 in conjunction with City of Edinburgh Council, Historic Scotland and Scottish Natural Heritage.
1.02 The proposals for Craighouse were submitted to City of Edinburgh Council in a detailed planning application on 12th November.
1.03 The Craighouse Partnership propose a major residential regeneration of the Napier Craighouse Campus. The site is 21 hectares at the prominent wooded hilltop of Craiglochart, one of Edinburgh's 7 hills. A group of significant listed building includes Arthur Sydney Mitchell Royal Edinburgh Asylum [1889-94] and the 16th Century manor house - Old Craig. The open space and woodland on the site, whilst remaining in private ownership, has been accessible to local residents since sale of the site to Napier University by the NHS in 1992. 66 apartments are intended as conversions of the original series of detached buildings, formerly a hydropathic hotel, an asylum, a hospital and most recently a campus of Napier University.
1.04 Commercial appraisal has established a requirement for enabling development in the form of new housing development on the site 'able to contribute financially to the longterm upkeep of the [listed] buildings and landscape'. This proposed new build enabling development has become the most significant and carefully considered facet of the proposals at the A+DS Design Forums.
Numbers of units have varied as follows: June 2012 62 conversions + 138 new build 200 November 2012 66 conversions + 87 new build 153
1.05 It is beyond the scope of A+DS's role to comment on the commercial considerations governing the scale of enabling development. ss
2.00 Workshop Scope [This section of the report sets out the intended purpose of the workshop as agreed prior to the workshop or as adjusted, by common consent, during the course of the workshop.]
2.01 This final workshop has been programmed to allow a further appraisal of the project at the point of submission of the planning application. An earlier workshop on
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1st August had concluded that the project had achieved an A+DS appraisal of category 3 i.e. "with potential but unsupported".
2.02 The discussion topics for the Appraisal Forum were derived from the outstanding issues identified at workshop 3, i.e. the issues that had previously precluded support for the design proposals by A+DS. The aim of the workshop was to review the design development of the proposals, relative to the points previously raised, recorded and discussed and to carry out an updated appraisal on this basis.
2.03 At the outset of the workshop City of Edinburgh Council described their recent meeting, discussions and correspondence with the design and project team. These revolved around analysis of the potential impacts of development, arising from analysis of a matrix of 'Potential Development Impact Areas' by Wardell Armstrong, see appended plan. This background was explained to A+DS during the workshop by both the council and the design team and it has informed the A+DS panel.
3.00 Workshop Outcomes [This section of the report summarises the appraisal of A+DS arising from discussion at the workshop and subsequently consolidated in order to provide a clear statement of appraisal. The appraisal is based on the extent of information provided at the design forum. The appendix includes extracts of the material presented.]
The outcomes of the workshop are reported under the subject headings of the earlier advice notes.
3.01 A wider vision, linking all elements and integrating with the city-wide and landscape setting.
Advice note 1, point 1 stated: "A spatial vision should be fully developed beyond the Kim Wilkie masterplan, and should involve an integrated design-team approach to the overall site. This needs to include an approach to designing within the highly significant topography of the site, to respond to the distinctive way the historic buildings respond to their setting, and to interact with the wider urban and landscape settings of city and hilltop/moorland. The site is one of the seven hills of Edinburgh, visible city-wide whilst also visually linked to the open landscape seen to the south."
3.01.1 A significant advancement was evident, as compared to the early work seen at initial A+DS workshops, especially in the quality of the overall vision, integration into the wider city-wide landscape and a break from the earlier, more internalised handling of the site.
3.01.2 A+DS welcome the intent to save the listed buildings and to put them to new use. The Forum workshops have looked in detail at the constituent parts of the new build propositions to help improve the way the interaction with the historic buildings, the setting and public access have been handled, rather than to review the principle of development.
3.02 Handling of proposed housing at the southern edge at the former orchard Since the initial workshop the proposals have been adjusted to remove housing at the orchard.
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3.03 Handling of housing between Old Craig, the Craighouse Road gateway [and at the east perimeter].
A+DS advice note 2, item 3 stated: • "A double line of trees separating the housing from the slope above was considered incompatible with preserving the larger view north".
A+DS advice note 3, item 3, stated: • "The relationship of the re-positioned avenue and new buildings was supported as an improvement with the terraced format allowing views through from the park above and a more convincing, though not yet resolved, handling of private garden exposure to the park" • "The panel had insufficient opportunity to explore the question of scale and density in this area, with reservations therefore being unresolved."
3.03.1 Whilst generally acknowledging the development of proposals in this area we remain concerned that the handling of terrace end houses adjoining the park is unconvincing. The 'rotated' end houses continue to appear random in this context. A more structured and bolder park edge was encouraged, reliant more on earth modelling, for example, rather than screen planting or 'organic' geometry.
3.03.2 The walled enclosure of back gardens at Regent Terrace towards Regent Gardens was cited by SNH as a relevant example and precedent of a built edge to a park in a similar context on another of Edinburgh's 7 hills.
3.03.3 In relation to housing at the east edge of the park [landscape matrix area 2] Previous A+DS advice note 3, item 6 stated: • The theme of building into or at the woodland edge needs to be consistently handled, both in terms of the response to the mature woodland, and there being a correspondence between the strategies of the two architects involved. • The introduction of extensive new tree planting around the main park was not supported since it undermines the simplicity of character of the open grass lawn and the bigger edge elements which are already there. More trees would also prevent beneficial overlooking and views of the park by adjoining houses. • Whilst the intent to locate buildings on the eastern boundary was thought worthy of exploration, the treatment as demonstrated was not supported due to an uncomfortable relationship of rear gardens backing onto the park.
3.03.4 The revised proposal needs modification from its present form since it exacerbates the issues previously advised. Concerns remain about further tree planting shading the new housing, about the inefficient duplication of roads, paths and new planting encroaching unnecessarily into the park, reducing public parkland, creating unusable woodland and the need for complex handling of privacy issues due to back gardens overlooked from the park.
3.03.5 This could be addressed by treating the new housing as a mirror of the relationship of the existing villas Bevan and Southcraig that face onto the park. There are few or no trees intervening between the villas and the park.at the west edge. Houses at the east edge could be turned 180o to face and overlook the park, allowing them to be set lower down and closer in to the existing trees. The access route would
Development Management Sub-Committee – 3 September 2014 Page 168 of 174 12/04007/SCH3 form the park edge and, mirroring the Bevan and Southcraig relationship there could be a minimum of new tree planting. Back gardens could be re-configured and/or minimised to allow these to be integrated with the existing mature boundary trees. Such an alternate layout was considered likely to be more efficient, less wasteful and to minimise the footprint of new development and tree planting.
3.03.6 If an imaginative solution cannot be found that absorbs the complexities of building at the east edge, then proposing housing here may prove incompatible with the sensitivities of location.
3.03.7 A further related point was raised in relation to the proposed park entrance adjoining Craighouse Lodge. As proposed, the key public entrance route into the park does not form a strong gateway. The public experience entering the site from Craighouse Lodge should be to see the open space straight away. This would be improved if the housing at the east were pulled back as suggested at the workshop, see 3.03.5 above, or omitted as intimated in 3.03.6.
3.04 Handling of new buildings and spaces proposed around New Craig and Queens Craig.
A+DS advice note 3, item 4 stated: • In principle the panel considered that the Queens Craig housing proposal could work. The proposal to retain the better mature trees was welcomed, with Cambridge Accordia housing a helpful precedent for handling proximity to mature trees. The principle of preserving building heights below tree canopy is important, as is the avoidance of an overly large gap in the tree canopy as seen in distant views. • Reservations to do with angled houses at Queens Craig and apparently random geometry in plan. bullet Reservation that, when properly tested, the tree clearing required for construction of roads and houses may become larger than currently shown.
3.04.1 The housing proposed at the existing boiler house [North Craig] is supported as before.
3.04.2 The layout and geometry issues south of both buildings are much more convincingly handled than before and address earlier advice. The introduction of terraced houses in place of apartments has eased car parking numbers. The retention of existing mature trees is welcome, as is the creation of defined courtyard spaces and the move towards a collegiate character. All are positive responses to discussions at earlier workshops. Geometries are much simpler and the proposals generally much more convincing. A+DS therefore support the formation of perimeter buildings in the two distinct groupings relating to New Craig and Queens Craig as proposed, [i.e. including housing at landscape matrix areas 8, 9 and 11]. This protects existing mature trees through not building at area 10 whilst building within clearings in poorer re-growth trees and carefully handling level changes and building height as established with all parties at workshops 1 and 2.
3.04.3 The design of the two new courtyard spaces at Queens Craig and New Craig could be simpler and more clearly articulated. Greater clarity of design would help, particularly whether the courtyards are being handled as two distinct spaces or as part of a continuous landscape. Consistent and more complete plans, sections and 3D
Development Management Sub-Committee – 3 September 2014 Page 169 of 174 12/04007/SCH3 imagery would assist, however we recognise that considerable work has been done to explore levels, accesses and building scale in these areas to make a sensitive integration of the new built form. This exploration is more evident in section details, building modelling and visualisations from the distant views than in landscape plans or close-up visualisations. An extra level of detail in the design, detailed handling and imagery of the spaces created would help demonstrate and develop the approach taken to the handling of the landscape design in these areas.
3.05 Handling formal compositional interactions between the form/scale/massing of the historic buildings and the form/scale/massing of those new buildings that are proposed nearby.
3.05.1 The handling of geometry in the proposed stand-alone buildings [Plot 8 Duncan and Plot 10 Clouston Villa] now follow the pattern and alignment of Bevan and South Craig that form the west edge to the park and the wider landscape, a positive response to earlier comments by A+DS.
3.05.2 The Duncan building is unconvincing elevationally, however this could be addressed.
3.05.3 The visibility of the proposed Plot 10 - Clouston Villa was discussed. This adopts the site of the LRC building at the southwest apex. It was evident from the views circulated during the workshop that whilst the building may be visible from Blackford hill it was scaled such that it would not encroach on the skyline. The massing of the building has clearly responded positively to earlier comments by A+DS [18/06/12 - item 9]. Our advice encouraged " A building language..inspired by the horizontal string courses, the horizontality of terraces and paths to the existing buildings and the contrasting vertical spires, turrets and elements of the historic buildings." However the handling of the scale and visibility of the building remains a sensitive matter in this location and the apex in particular will need to be considered further.
3.06 Handling of private and public realm interfaces generally.
Advice note 3, point 6 stated: " • A logic is beginning to emerge of houses backing into trees and fronting onto common gardens and parkland. If the trees at Queens Craig are crown lifted then new houses here could interact with the common gardens created between new and old. • Further exploration is required of the handling of private garden and amenity space serving the existing buildings that are to be converted."
3.06.1 There has been a significant development of the proposals to tackle these issues which are now generally much better handled, with the positive move towards a sheltered collegiate character for residential areas that are further away from the public park edge.
3.06.2 Overall, we have cautioned against an overly segregated and exclusive treatment of the park and public areas in favour of good interaction between park and houses and a high quality of public experience in the park.
3.07 Handling lighting and the new infrastructure of roads and footpaths given the exposed hilltop site.
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Advice note 2, point 7 stated "It was suggested that the exposure of lighting and the new infrastructure of roads and footpaths be considered to minimise interventions that alter the character of the exposed hilltop site. There is a need to work with the authorities to keep these interventions subtle, discreet and minimal."
3.07.1 Clearly there has been positive work done in this respect both to re-configure the layout and to consider means of incorporating low level and discreet lighting. This needs to be developed in conjunction with the councils roads officers.
3.08 Means of minimising the quantum of enabling development
3.08.1 Commercial appraisals have been developed and independently analysed by the council. As noted in the introduction it is beyond the scope of A+DS's role to comment on the required scale of enabling development.
3.08.2 Previous advice notes have suggested that the Listed building conversions might be more efficient, however the points made by the team at the workshop in this respect and the rationale for sub-division are acknowledged, with any further comment requiring detailed knowledge of appraisal values.
3.08.3 It has been suggested at an earlier workshop that landscape management costs might be partially attributed to the public use of the site to reduce the quantum of residents contributions required and thereby the required quantum of enabling development. In advice note 3, item 8 we also noted " the impact of policy for affordable housing provision given the additional housing numbers that are a consequence of raising the sums required. Movement in any of these areas should, we would suggest, be directly applied to reducing the extent of required new build development." The proposal to offer parkland areas of the site for public ownership and the concurrent reduction in proposed unit numbers appear to be positive moves in this direction.
3.09 Strategy guiding architectural language/responses, landscape elements/responses and materials chosen.
3.09.1 There seemed to be much more energy in the handling of materials. The brick choice and horizontal bands seemed to be working, with the exception of the detailed handling of the Duncan building, see above.
3.09.2 The detail design work, for example of the proposed plot 10 Clouston villa, needs to work hard to prevent the intended material contrasts being superficial differences only. It will be important to maintain a contrast between glassiness then the solidity of masonry element using deep reveals and similar techniques.
4.00 Summary of comments [This section of the report summarises the appraisal and the overall rating given for design quality at the conclusion of the Design Forum process.]
4.01 An appraisal was carried out by A+DS staff and panellists following the workshop, based on the comments made. The project was rated as category 2 - well considered - supported, subject to the amendments discussed and noted below. 4.02 A+DS support the majority of the proposals and the overall vision now achieved. Our support anticipates further progress in some specific areas in the direction now established.
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Therefore this support assumes that amendments will be made in the following specific areas:
• Revised layout and potentially extent of the East housing [Old Craighouse Grove] • Adjusted extent / layout of end terraces houses at the Old Craig car park site [Old Craig Court], including consideration of a more structured terrace/park interface. • A redesigned, more direct and stronger gateway and route into the park from Craighouse Lodge • Developing the detailing of the public realm of the 'collegiate' courtyards between buildings. • Avoiding an overly exclusive approach to private boundaries in favour of the more subtle collegiate approach now emerging. • Minimising the extent of new tree planting around the new park as raised at this last and at earlier workshops [see 3.04] • Review of the architecture of Duncan • Development of the modelling of both hilltop buildings.
Scottish Rights of Way and Access Society - Scheme 1
Following our email and telephone correspondence, the Society gratefully acknowledges the additional time made available for our response. It was also mentioned that the applicant would be submitting additional documentation and that there would be a fresh round of consultation. I can confirm that ScotWays wishes to be included in the list of consultees. Here, I shall first set out what our records show and then comment directly on this application's implications for public access rights.
The National Catalogue of Rights of Way (CROW) shows that asserted right of way LC73 is affected by the area within the planning application boundary. Additionally, asserted right of way LC74 appears to lie just outside the site boundary. A map is enclosed with right of way LC73 highlighted in pink and right of way LC74 highlighted in orange. As there is no definitive record of rights of way in Scotland, there may be routes that meet the criteria to be rights of way but have not been recorded as they have not yet come to our notice.
Our records indicate that the application site is well used and greatly valued by the local community and that a number of routes exist other than those recorded in CROW. It is likely that you are aware that there may now be general access rights over any area of land under the terms of the Land Reform (Scotland) Act 2003. It is also worth bearing in mind the Core Paths Plan, prepared by the Council's own access team as part of their duties under this Act.
The application notes that rights of way will be safeguarded. However, with respect to asserted right of way LC73, it is clear from their Road Adoption Plan that it is intended that the carriageway be extended along the right of way. The right of way is not shaded as shared surface and, unlike elsewhere in the site, there is no proposal for footway adoption. It thus appears that the right of way is to follow the same line as a proposed adopted road with no separate provision for pedestrian or other non-vehicular access.
The applicant also notes that public access to the site will continue. The Estate Management Strategy outlines three stages of development which it is stated "arise
Development Management Sub-Committee – 3 September 2014 Page 172 of 174 12/04007/SCH3 from a desire to retain and maximise public access to the most popular areas of the site at all times". Despite these positive sounding words, the Society remains very concerned at the development's impact on publically accessible open space. The plans clearly show that the open space will both encroached upon and have its amenity compromised. The juxtaposition of the historic buildings and their landscape setting is a very important component of the attraction of this area to the general public. The new- build element of the proposals also encroaches both on the sweeping lawn and on the surrounding woodlands.
It is our understanding that the applicant intends to submit further documentation. Thus the concerns raised by the Society should be considered as a holding objection to this planning application.
Scottish Rights of Way and Access Society - Scheme 3
We received your "New Notification Scheme 3: Submission of Revised Proposals" letter on 23rd May 2014. Following our email correspondence, the Society gratefully acknowledges the clarification of the timescale available for our response. Having subsequently telephone the Planning Helpdesk, it was indicated that a response by today would likely also be considered timely. I regret to say that as a small charity with very limited resources, we have been unable to revisit this third version of the documentation as thoroughly as we would like, however the general principles set out in our previous correspondence remain valid.
The National Catalogue of Rights of Way (CROW) shows that asserted right of way LC73 is affected by the area within the planning application boundary. Additionally, asserted right of way LC74 appears to lie just outside the site boundary. A map is enclosed with right of way LC73 highlighted in pink and right of way LC74 highlighted in orange. As there is no definitive record of rights of way in Scotland, there may be routes that meet the criteria to be rights of way but have not been recorded as they have not yet come to our notice.
Our records indicate that the application site is well used and greatly valued by the local community and that a number of routes exist other than those recorded in CROW. It is likely that you are aware that there may now be general access rights over any area of land under the terms of the Land Reform (Scotland) Act 2003. It is also worth bearing in mind the Core Paths Plan, prepared by the Council's own access team as part of their duties under this Act.
We note that there appears to have been some retraction of the new-build element of the proposals from the lawn area. This reduction of the encroachment upon publically accessible open space is to be welcomed. However concerns about the development's impact on recreational amenity remain. We have found the documentation on the planning website so difficult to cross-reference that we cannot easily ascertain whether there has been sufficient improvement in the plans to remove our previous objection. Thus the Society's holding objection to this planning application remains.
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City of Edinburgh Council Financial Review
Context
Officers within the Disposals and Development team of Estates Services were engaged by Planning to review development appraisals submitted by Craighouse Partnership (CP) in support of the planning application. This relates to the financial case that has been put forward to justify the conservation deficit and the accompanying development appraisal.
This document provides a background to the process that has taken place.
Previous Submissions
The initial CP submission (s1) was included as part of the pre application submissions in October 2011. This scheme was not considered suitable by planning for a number of reasons. Estates Officers had no involvement at this stage, being engaged prior to the submission of the revised s2 appraisal and continuing with the s3 submission.
The role of Estates Officers has been to check the component parts and commercial assumptions of the development appraisals, in conjunction with expert advice where appropriate. This has not been an exercise in determining whether or not there is a conservation deficit and Officers have not looked at the appraisals in terms of the guidelines issued by English Heritage. Similarly Estates Officers have had no input in the design of the development which has evolved through discussions between CP and Planning.
Main Components within the Appraisals
The appraisals submitted as part of the planning application have five main components:‐
i) The Gross Development Value (GDV) of the Proposed Development ii) The costs of creating the development from which the GDV is derived iii) The land value iv) Finance costs v) The level of profit being generated by the appraisal
Gross Development Value (GDV)
The GDV is an estimate of what the proposed development will generate if sold on the open market taking current economic conditions into consideration. i.e. the GDV is an accumulation of the anticipated prices of the residential units to be developed.
The GDV has been derived from applying a rate per sq ft to the appropriate sales area for each of the units to be developed. The appropriate rate has been determined through considering sales evidence provided by CP from comparable properties in the immediate area. Evidence was also considered from substantial developments elsewhere in the city, such as Quartermile.
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To arrive at the anticipated selling price of the individual units, it is not just a case of applying a blanket rate per sq ft from all the comparable evidence to the units on a straight line basis. There is a ceiling price above which the market will just not pay taking the size of the unit and location within a particular building into account. Therefore, the flats are priced individually and the average rate derived from this process is applied to the sales area for the relevant building within the appraisal. In addition it would not be practical within a development appraisal to list each individual flat, therefore the projected sales revenue is considered on a building by building basis.
In relation to the units within the listed accommodation, Estates Officers were of the view that the initial interpretation of the sales data by CP in earlier submissions was conservative and there was scope to increase the sales rates beyond what was initially anticipated. Consequently sales rates were agreed that represented an increase of 5.4% on original sales rates on the conversion accommodation from the initial figures proposed by CP. The rate adopted is £290 per sq ft with the exception of the stand alone gatehouse which is based on £375 per sq ft.
Estates Officers are satisfied that the sales evidence for the listed buildings is reflected in the rate adopted within the appraisal.
Higher rates have been adopted within the appraisal for the new build accommodation, ranging from £325 to £390 per sq ft. The units have been priced individually as per the listed accommodation with an average rate applied to the building area. Evidence was provided by CP to justify the figures adopted from new build developments across the City. Again Estates Officers are satisfied that the sales evidence supports the adopted sales rates.
At face value, it would appear that the sales rate adopted are putting a greater value on the new build units as opposed to flats which are created within Grade A listed accommodation. However as with the listed accommodation, the size of the units being developed needs to be taken into consideration. A price per unit comparison shows that the highest price for a unit within the development will be achieved from the flats to be created within the listed buildings due to the larger size.
There is however evidence of improving conditions and sales prices in the residential market. Therefore a sensitivity analysis has been undertaken to show the impact of sales prices being achieved above expectations – see below.
Costs of Development
CP provided cost plans for each of the buildings on the site. These were prepared by quantity surveyors CBA. In addition Morham & Brotchie were instructed by CP to provide a detailed costing exercise on the proposed New Craig conversion.
In order to test the accuracy of these costs, the Council instructed construction and property consultant Thomas & Adamson (T&A) to undertake an audit of the information provided. These included costs plans and development drawings which were considered along with detailed discussions with CBA and a site visit. This initially involved a full analysis of the costings for the s2 submission.
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The conclusion of T&A was that the costs are considered to be appropriate for the proposed development in view of current market conditions and comparable with similar schemes in which T&A have had an involvement. Nevertheless potential costs savings were identified which were accepted by CP and incorporated into the appraisals. T&A were commissioned to undertake a similar exercise in respect of the s3 submission and the conclusion was that the costs plans provided were considered to be appropriate for the level of accommodation proposed.
The build costs provided do not contain an element of developer’s profit.
Further costs have been added for professional fees, disposal fees and contingencies. These costs are in line with market expectations for a development of this nature. In the absence of detailed quotes regarding the actual level of professional fees being incurred, Estates Officers are satisfied with the 12% fee level that has been adopted. Professional fees would normally include the costs of an architect, quantity surveyor, engineers (roads, mechanical & electrical, structural), CDM and planning consultant.
Analysis of the development appraisals submitted by CP showed there to be anomalies in the ratios between the gross to net areas for some of the buildings. The areas have been revisited by CP and revised appraisals submitted. The figures within this report are based on these revised appraisals.
Land Value
The land value within both appraisals is £4.70 million. This is significantly lower than the purchase price paid by CP of £10.0 million with a further £3.046 million overage payment, triggered by the level of new build within the development.
In reviewing the appraisal Estates Officers were of the opinion that the price paid for the site by CP was not truly reflective of the current market value of the site.
CP instructed Savills to prepare a valuation on the basis of the definition of Market Value as set out in English Heritage Guidance i.e. a value which takes account of the structural condition of the property and the current planning constraints but which also allows “hope value” for any potential development in accordance with the development plan.
The cumulative total of the values provided to each element was £4.70 million. The valuation has been prepared on the basis of considering alternative uses for the buildings where possible. For example New Craig being used as a wedding venue and offices, with Queen’s Craig used as a care home. Estates Officers are satisfied with the valuation figure provided by a leading national surveying practice. This represents a significant write down in the price paid by CP.
It is possible that the buildings within the site could be used independently, perhaps for an alternative use however all of the buildings on the site would need to be used/developed to avoid decaying empty premises having an adverse effect on the site as a whole.
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Finance Costs
The finance costs within the appraisal are based on the internal model of CP. This is predicated on sales revenue being recycled within the development to keep borrowing costs to a minimum.
Estates Officers believe that this is an optimistic financial scenario and many developers would look to increase the level of borrowing which would increase overall costs and reduce profitability.
Profit Level
Estates Officers are of the opinion that a reasonable return to be expected from a development of this nature would be circa 20%. It is reasonable to assume that a standard developer return would be required on a scheme of this nature.
It could be argued that if the development of the listed accommodation was undertaken in isolation then a profit on cost figure of closer to 25% would be expected.
It should be noted that the profit level represents the return to the developer taking all of the costs, including funding costs, into consideration. s1 to s2 Appraisal
The figures within the initial s1 appraisal were not accepted by the Council. Issues with the proposal included the footprint of development across the site and the construction material used. Dialogue between Planning and the CP led to a redesign of the new build element of the scheme. The main thrust of the redesign was to create a greater number of flatted units within the new build as opposed to family orientated housing units. This reduced the level of buildings to be developed on the site however increased the number of units.
The main differences between the two appraisals are as follows:
Item Difference from s1 to s2 Reason
Sales rates per sq ft on listed Increased from £275 to £290 Increased sales rate agreed accommodation per sq ft following discussions regarding evidence provided
Sales rates per sq ft on new Sales rates on Napier and Reduced floor area of individual build accommodation Burton buildings increased units due to greater emphasis from £325 to £350 per sq ft. on smaller flats.
Flats with direct lift access to underground parking achieve a higher sales rate.
Level of new build Gross new build area increased Addition of undercroft parking from 175,010 sq ft to 255,444 substantially increases gross 4
accommodation sq ft. build area
Build costs of listed Increases from £15,828,864 to Further costing exercises on accommodation £19,724,850 New Craig building increases costs for that building alone to £13.857 million from £10.45 million. Increased gross development area
Profit on GDV Increases from 11.44% to Improved revenue from 17.95% increased level of new build. Improved sales rates per sq ft across development.
s2 to s3 Appraisal
Discussions between CP and Planners following the submission of s2 revealed that the level of new build on the site was not considered to be acceptable. Therefore CP made further revisions to the design prior to submitting s3. For ease of comparison, adopting a similar analysis as above, the main differences between s2 and s3 are as follows:
Item Difference from s2 to s3 Reason
Sales rates per sq ft on listed Retained at £290 per sq ft with Sales rate agreed for s2 accommodation exception of Gatehouse which submission but sensitivity is increased to £375 per sq ft. analysis undertaken to model improving residential market
Sales rates per sq ft on new Sales rates on new build Sales rate agreed for s2 build accommodation retained. submission but sensitivity analysis undertaken to model improving residential market
Level of new build Gross building area decreased Removal of undercroft parking accommodation from 255,444 sq ft to 172,851 and relaxation of design sq ft. stipulations allow for reduced level of new build
Build costs of listed Decreases from £19,724,850 to Reduction in level of costs for accommodation £18,822,850. conversion of New Craig, although floor area increased from 95,0000 sq ft to 98,155 sq ft.
Profit on GDV Increases from 17.95% to Improved financial contribution
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18.42%. from buildings such as Burton and inclusion of Historic Scotland grant of £500,000.
Historic Scotland Grant
CP has not made an application for grant funding from Historic Scotland that may be available, up to £500,000. Until an application is made and determined it is prudent to assume that such a grant would be available and included within the conservation deficit and full appraisals.
Adding in this figure, keeping all other variables as before, would reduce the conservation deficit from £5,156,078, as suggested in the s2 appraisal, to £4,667,773. Should the grant not be received the level of profit from the development as a whole would reduce from 18.42% to 17.79%.
Alternative Uses
It has been suggested that New Craig could create a high class hotel although this would require considerable investment to create a “brand” and detailed cash flow projections would be required in order to consider a potential value. It is unlikely that such a hotel operator would fund such a conversion from their own reserves. It is more likely to be developer led with the operator signing some form of operational agreement. It should also be noted that attempts to secure a hotel use at Quartermile and Donaldson’s School failed following extensive marketing campaigns.
In addition to the potential use of New Craig as a hotel, consideration has been given to utilise the features and location of the building to develop a wedding venue. CP has considered such a use within their Enabling Case Report. This details the projected occupancy costs of the building, through a report commissioned by Napier University, over a 25 year period. CP undertook a further study of the potential ongoing maintenance costs over a 10 year period. This study suggests that, on a pro rata basis against the costs for the site as a whole, New Craig would require a minimum spend of £120,000 per year without adding for site maintenance costs.
CP has produced an indicative budget for running the building as a wedding venue. Estates Officers are not qualified to pass comment on the accuracy of these figures however on face value they demonstrate that such a use of the building is not viable without needing to attract a number of functions that would be unrealistic. Assuming the figure are correct, such a business model would have to run at over 500% to produce a level of return approaching what would be required in terms of the reported annual maintenance figures.
Affordable Housing
There is no allowance within the appraisals for the provision of affordable housing. Given the nature of development it is to be assumed that such a contribution would be in the form of a commuted sum. Based on the land value of £4.7 million the commuted sum, based on 25%, would be £1,175,000.
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In order to maintain the profit level in the appraisal of 18.42%, additional new build accommodation would be required to support the commuted sum. To calculate this on a hypothetical basis, an average sales rate of £340 per sq ft and build cost of £140 per sq ft has been utilised. Running the appraisal, adopting all other variables as before with pro rata increases to reflect the additional development, it is estimated that additional new build of circa 22,000 sq ft gross would be required to generate sufficient return to support the commuted sum for affordable housing.
Phasing
CP has provided an indicative development programme which shows 3 phases. Phases 1 shows a profit of 10.75%, Phase 2 25.9% and Phase 3, 27.17%. A lower level of profit is delivered from the Phase 1 for 2 reasons. Firstly the purchase price of the site and associated acquisition costs are included in their entirety. Secondly the, the infrastructure costs for all of the listed buildings are included in this phase, in accordance with the S75 agreement.
This would suggest that by undertaking the first phase, a developer would see the benefit of continuing with the later phases due to the increased returns, by which time the infrastructure to the listed buildings would be in place. Therefore in the scenario of a developer experiencing financial difficulty, which prevents the later phases from being completed, the remaining serviced listed buildings would be more desirable and financially viable in their own right if marketed.
Sensitivity Analysis
There has been considerable press regarding improving conditions in the residential market. Therefore a sensitivity analysis has been undertaken on the basis of increasing sales rates across the development. A similar analysis for build costs has been undertaken and the results are set out in the matrix below. It should be recognised that the proposed units within the development are at the top end of the market where prices are considered performed well over recent years. This is also an area of the City which is untested for a high quality development of this size.
The variables are % increases and decreases in the build cost and/or sales rates. The resultant figures are the profit on GDV as a figure and %.
Build Costs Sales ‐2.5% 0 +2.5% +5.0% +7.5% +10% Rates
‐2.5% £13,727,157 £15,683,764 £17,639,385 £19,595,005 £21,550,626 £23,506,247 (17.77%) (19.80%) (21.72%) (23.56%) (25.31%) (26.98%)
0 £12,630,287 £14,588,878 £16,544,499 £18,500,119 £20,455,740 £22,411,361 (16.35%) (18.42%) per (20.38%) (22.24%) (24.02%) (25.72%) CP Appraisal
+2.5% £11,533,418 £13,493,992 £15,499,613 £17,405,233 £19,360,854 £21,316,475 (14.93%) (17.03%) (19.03%) (20.93%) (22.74%) (24.46%)
+5.0% £10,436,548 £12,339,106 £14,354,727 £16,310,347 £18,265,968 £20,221,589 (13.51%) (15.65%) (17.68%) (19.61%) (21.45%) (23.21%)
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+ 7.5% £9,339,769 £11,304,220 £13,259,841 £15,215,461 £17,171,082 £19,126,703 (12.09%) (14.27%) (16.33%) (18.29%) (20.16%) (21.95%)
+10.0% £8,842,809 £10,208,028 £12,164,935 £14,120,575 £16,076,196 £18,031,817 (10.67%) (12.89%) (14.98%) (16.98%) (18.88%) (20.69%)
The red shading denotes the combination of variables that would result in a return to the developer below that which is presented in the s3 appraisal, shown in black. The green denotes where the return would be in excess of this figure.
This is an arithmetical exercise but does show that allowing for sales inflation of 10.0% and a reduction in build costs of 2.5%, the maximum level of return to the developer would be 26.98%.
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Woodland and Open Space
W1
Currently Part of LNR
W2 Open Space
Infrastructure Plan
Roads taken to adoptable standard prior to sale of an agreed portion of enabling development in Phase 1
Roads taken to adoptable standard barring their wearing course prior to sale of an agreed portion of enabling development in Phase 1 Car parking areas taken to completion prior to sale of an agreed portion of enabling development in Phase 1
Car parking areas levelled and taken to hardcore base prior to sale of an agreed portion of enabling development in Phase 1
Location Plan
© Crown Copyright and database right 2014. All rights reserved. Ordnance Survey License number 100023420 END
Development Management Sub-Committee – 3 September 2014 Page 174 of 174 12/04007/SCH3 Development Management Sub Committee
Wednesday 3 September 2014
Application for Listed Building Consent 12/04007/LBC At Napier University Craighouse Campus, Craighouse Road, Edinburgh Proposed conversion of existing listed buildings at New Craig , Queen's Craig, East Craig, Bevan Villa, South Craig, Craighouse Lodge, Old Craighouse to form residential properties, including extension at South Craig and demolition of Boiler House (as amended).
Item number Report number
Wards A09 - Fountainbridge/Craiglockhart
S um m a ry Summary
The proposals comply with the development plan and non-statutory guidance. They will not adversely affect the character of the listed building, its setting or the character and appearance of the conservation area. The case for demolition of the Boiler House is accepted. The proposals will help ensure the long term, sustainable survival of these significant listed buildings.
Links
Policies and guidance for LPC, CITE2, CITE3, CITE4, CITE6, NSG, NSLBCA, this application OTH, CRPCHI,
Development Management Sub-Committee – Page 1 of 31 12/04007/LBC
Report
Application for Listed Building Consent 12/04007/LBC At Napier University Craighouse Campus, Craighouse Road, Edinburgh Proposed conversion of existing listed buildings at New Craig , Queen's Craig, East Craig, Bevan Villa, South Craig, Craighouse Lodge, Old Craighouse to form residential properties, including extension at South Craig and demolition of Boiler House (as amended).
Recommendations
1.1 It is recommended that this application be Granted subject to the details below. Background
2.1 Site description
The application property is composed of a series of individual listed buildings set within the larger landscape setting that is Easter Craiglockhart Hill, one of the "seven hills" of Edinburgh. The site is steeply sloped and is generally open and grassy at lower levels and wooded higher up. The existing listed buildings which are the subject of this application include Old Craig which is A listed (reference number 28046, listed on 14 December, 1970) and a series of Victorian A listed buildings listed separately (reference number 27736, listed on 28 August, 1979). All the buildings have most recently been used by Napier University.
The Learning Resource Centre, an unlisted modern building, lies to the south of the listed buildings, Bevan and South Craig.
The listed buildings include:
Old Craig
Old Craig dates from 1565, with later additions, and is a three storey with attic harled L plan building initially built as a tower house. It was modified in the 19th century by Sidney Mitchell, the architect of the other listed buildings on the site. Part of the original walled gardens remains to the south.
The Victorian buildings
The other listed buildings on the site are grouped together in one listing as they were all built from 1899 to the design of Sidney Mitchell as a mental hospital to the specification of William Clouston, a pioneer in the treatment of mental illness.
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These buildings include the main hospital block which is New Craig, as well as Queen's Craig to the west and a series of pavilion buildings in a line to south which look out over the sloped open grassy area and include South Craig, Bevan, and East Craig. A small lodge house is to the west on the boundary with Craighouse Road. A boiler house is to the north of New Craig and lies lower down the slope than New Craig. These buildings are sandstone with slated roofs and were designed in the Free Renaissance style.
New Craig
New Craig is a massive, towered and gabled picturesque building with a steeply pitched roof that steps down a sloping site, dominating the site and other buildings. It is predominantly three storey with dormerheads, basements and towers and can be seen from both near and distant views. It contains the Great Hall and a series of rooms with remarkable interiors. On its northern elevation at the level of the rear service lane the Boiler House Annex is an extension that is historic, but not original to the initial building of New Craig.
Queen's Craig
Queen's Craig sits to the west of New Craig and is the least conspicuous building in views into the site. It is the second largest listed building after New Craig, being predominantly a single storey structure with a basement except for the western section which is a two storeys with an attic.
East Craig
East Craig is the first in a series of three villa buildings that run south of New Craig and across the top of the open space. It is a single storey structure with basement and attic levels. It has a non-original modern extension on its south elevation.
Bevan
Bevan is the next villa building running south after East Craig. It presents a symmetrical elevation overlooking the open space and the city beyond and is a two storey structure with basement and attic levels.
South Craig
South Craig is the most southerly villa building. It is a two storey structure with basement and attic levels. It also overlooks the grassy open space and has views of the city.
The Lodge House
This building is located by the gatepiers on Craighouse Road. It is a small single storey building with attic accommodation.
Boiler House
This building is not specifically mentioned in the list description but is listed by virtue of being a historic structure that is within the curtilage of the listed buildings.
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It was built to provide heat to New Craig via services under the rear road that runs north of New Craig. From this road, it presents a single storey structure with a prominent pyramidal roof adjacent to a long stretch of corrugated metal roof to the east. It is set into the north facing slope and from the south the building is approximately two storeys high. It has been redundant as a boiler house for a number of years and is in a poor state of repair.
There are also listed gates and gate piers at the top of Craiglea Place and adjacent to the lodge house.
Originally these buildings were connected by a series of underground tunnels. Access to the tunnels has been blocked for a considerable time and the tunnels have not been maintained. It is understood that many of them are now filled in.
The Victorian buildings designed by Sidney Mitchell are remarkable for their external and internal design and their relationship to the landscape. The 19th century buildings were designed to give the appearance inside and out of a lavish hydropathic hotel establishment rather than a hospital. They were designed "in the round". Although each of them has a principal elevation, all elevations are highly designed and conceived. The Historic Scotland list description notes that "the buildings are set in superb landscaped hilltop site, still completely unspoiled either by later accretions or more modern buildings". The buildings were sited on Easter Craiglockart Hill because the larger landscape setting was integral to the restorative and healing role of the hospital.
With the exception of Queen's Craig and New Craig, the buildings are currently on the Buildings at Risk Register. The Boiler House is rated "high risk", East Craig is at "moderate risk" and Old Craig, Bevan, South Craig and the Lodge House are at "low risk".
This application site is located within the Craiglockhart Hills Conservation Area.
2.2 Site History
There were several applications in the 1990s for conversion to Napier University.
13 September 2001 - an application for the development of a new arts faculty building and minor works to existing 'A' listed building was withdrawn (application reference: 01/01435/FUL).
24 September 2001 - an application for the development of a new arts faculty building and minor works to existing 'A' listed building was withdrawn (application reference: 01/01435/LBC).
24 May 2002 - listed building consent was granted for minor works to basement area of New Craig in conjunction with development of new arts facility building (application reference : 01/04599/LBC).
26 June 2007 - planning permission was granted for the development of a new arts facility building, new surface car park and minor works to existing 'A' listed building (application reference: 01/04599/FUL).
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19 September 2012 - an application for the modification of clause (fourth) and clause (seventh) of the legal agreement relating to application no. 01/04599/FUL was withdrawn (application reference: 12/02261/OBL).
22 November 2012 - permission was granted for the modification of clause (fourth) and clause (seventh) of the legal agreement relating to application no. 01/04599/FUL (application reference: 12/03397/OBL).
There have also been several applications for minor works relating to the operation of the university estate.
Parallel applications
Application for the proposed change of use and conversion of existing buildings from university campus to residential and construction of new build residential, together with ancillary development, public realm, utilities infrastructure including access roads, car parking and landscaping is running in parallel with this application (application reference: 12/04007/FUL).
Application for the demolition of Learning Resource Centre Building is running in parallel with this application (application reference: 12/04007/CON). Main report
3.1 Description Of The Proposal
It is proposed to convert the listed buildings on this site to form residential flats and houses. The current scheme has been amended from what was first submitted.
It is proposed to form 64 dwellings within the listed buildings that exist on this site and this will include a mixture of housing types.
The breakdown of units is as follows:
Old Craig: Single dwelling - 8 bedrooms
Lodge: Single dwelling - 1 bedroom
Bevan: Three flats - One 2 bedroom - One 3 bedroom - One 6 bedroom
South Craig: Three flats - One 3 bedroom - Two 4 bedroom
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East Craig: Two flats - Two 4 bedroom
Queen's Craig: Ten flats - Three 1 bedroom - Four 2 bedroom - Three 3 bedroom
New Craig: Forty four flats - Four 1 bedroom - Seventeen 2 bedroom - Eight 3 bedroom - Fourteen 4 bedroom - One 5 bedroom
The listed buildings will accommodate 26 wheelchair accessible units.
The proposed alterations are as follows:
Old Craig:
The building will become one single dwelling with its own garden grounds within the former walled garden. Proposed physical alterations are minor. Internally, some non- original partitions will be removed and some new partitions formed to create bedrooms and ensuites. A kitchen will be formed on the first floor. Externally a ramp to the exterior will be removed. An enclosed courtyard will be formed to the north-east of the L shaped plan.
Lodge:
The lodge will form a single one bedroom dwelling with minimal alterations including the formation of a kitchen at ground floor and the removal of an external ramp.
Bevan:
Bevan Villa will be horizontally subdivided to form three flats, one on the lower ground level, one on upper ground level and one on first and second floors. A new entrance stair and platt will be formed to the upper flat adjacent to the existing entrance to the upper ground level flat to the rear and a new stair will be formed internally to access the upper flat. A door will be formed from a window to access the lower ground floor flat. Internally a lift and some minor partitions will be removed. The flats will have gas central heating and balanced flues will be required to vent through external walls.
South Craig:
South Craig will be subdivided both horizontally and vertically to form three flats. The southern half of the building will form a dwelling over three levels.
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One flat will be formed on the lower ground floor and upper ground floor of the northern half of the building and a further flat will be formed above on first and second levels. A non-original stair and lift will be removed and a new stair formed to access the upper flat. A porch extension will be built at the bottom of the stair to the rear of the building. At first floor level a terrace on an existing flat roof will be formed and wrought iron railings erected to form a balustrade. Internally some partitions will removed and new partitions formed. The flats will have gas central heating and balanced flues will be required to vent through external walls.
East Craig:
The building will be subdivided to form two flats, one on part of the ground floor and one over three levels, lower ground, ground and first floor. A non-original extension and ramp will be removed on the south elevation. A non-original stair that is currently housed in a dormer extension will be replaced by a new stair in a new dormer extension of approximately the same footprint. A new entrance will be formed on the west elevation to access the ground floor flat in a location where there is an existing stair to one of the tunnels between buildings. The lean-to flat roof covering the tunnel in this location will be removed and the tunnel filled in. Internally some partitions will be removed and new ones erected.
Queen's Craig:
This building will be subdivided both horizontally and vertically. There will be one flat at lower ground floor level, five at ground floor level (one of which is accessed from an entrance at lower ground floor level), two flats on the first floor and two on the second floor. Some entry doors will be formed in window openings. Internally the sound proofing that Napier University has installed in many of the rooms for its use as the music department will be removed. Non-original stairs in the central corridor will be removed and the stage will be removed in the former snooker room in Apartment 4. Some partitions will be removed and others added. In order to meet requirements for fire and acoustic separation between apartments, double skin partitions with internal cavities need to be constructed between units. The flats will have gas central heating and balanced flues will be required to vent through external walls. Access to the tunnels will be blocked off.
New Craig:
New Craig, as the largest of the buildings on the site, will be converted to house 44 flats. The largest space in the building, which is the Great Hall, will be not be converted and will be in shared ownership with all the other occupants of the development.
In order to form the residential flats, the building will be subdivided both vertically and horizontally, with many flats spanning more than one floor. The scheme makes use of existing staircases and lifts although there will be the installation of an additional lift to access the flat that is being created in the tower. The nature of the sub-division with more than one flat per wing necessitates the construction of double skin subdividing partitions for acoustic and fire separation.
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Some windows will be converted to doors to provide individual entrances to flats. Access to the tunnels will be blocked off. Unlike the other listed buildings on the site, New Craig lends itself to a system of common flues which enables ventilation from each flat to be grouped in a series of shafts that ventilate out through the roof. This minimises the need for balanced flues through the exterior walls but there will be traditionally designed housing for the ventilation as they exit through the roof. The exception to this system will be the north wing where this system cannot be accommodated and balanced flues through the walls will be required.
At roof level it is proposed to install new rooflights where flats are proposed in the roof space.
It is proposed to remove the Boiler House Annex in order to increase the room for the road to the rear and to facilitate construction of new build on the Boiler House site.
Boiler House:
The boiler house, on the other side of the road from New Craig, will be demolished to make way for new build. Historically it would have served New Craig via services under the road but has now been redundant for a number of years.
Boundary Walls:
At the current, non-original front entrance to the site, which lies to the north of the lodge house gates, the modern curved entry will be modified to include gate piers and railings.
Supporting Statements
The following documents have been submitted in support of the application:
- Design Statement Listed Buildings, Document 1 (November 2012) - External Alterations; Photographic Record, Document 2 (November 2012) - Internal Alterations; Photographic Record, Document 3 (November 2012) - Internal Alterations; Photographic Record, Document 4 (November 2012) - Design Statement Listed Buildings, Document 5 (November 2012) - Conservation Plan (November 2012) - Proposed Removal of Boiler House; Supporting Statement and Photographs. (February 2013) - New Craig. Proposed Alterations to North Wing. Supporting Statement and Photographs (January 2014)
These documents are available to view on the Planning and Building Standards Online Services.
3.2 Determining Issues
In considering whether to grant consent, special regard must be had to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.
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For the purposes of this issue, preserve, in relation to the building, means preserve it either in its existing state or subject only to such alterations or extensions as can be carried out without serious detriment to its character.
Do the proposals harm the character or appearance of the conservation area? If they do, there is a strong presumption against granting of permission.
3.3 Assessment To address these determining issues, the Committee needs to consider whether: a) the proposed alterations will have a detrimental impact on the character of the listed building or its setting; b) the demolition of the boiler house is acceptable and meets the criteria specified in the Scottish Historic Environment Policy (SHEP) tests; c) the proposals will preserve or enhance the character and appearance of the conservation area; d) any impacts on equalities or human rights are acceptable; and e) comments raised have been addressed. a) Impact on the Character of the Listed Building
The application proposes that the buildings, which are currently in educational use, be converted to residential accommodation. This listed building consent application is for the physical alterations that will be required to fulfil that function. The impact of the proposed new build elements which are the subject of the concurrent planning application (12/04007/FUL) on the setting of the listed buildings, are assessed in that application. The specific proposal to demolish the Boiler House is dealt with in Section 3.3.b below.
The proposals to convert the buildings to accommodate 64 dwellings is as described in proposals above.
It is proposed to remove the Boiler House Annex which is set below New Craig's basement level and relates to the Boiler House and the road. This part of New Craig does not appear in any of the original Sydney Mitchell drawings of the buildings. It has an interesting roof configuration of a series of hipped slated roofs but presents a blank stone wall at road level. The removal of this element will enable the road to be widened to an acceptable standard which will enhance access to Queen's Craig and the top of the site. As the Annex is not original, and of no great merit, it is acceptable to remove this part of New Craig. The removal of the modern extension to East Craig and the ramp on Old Craig will be of benefit to the buildings.
With the exception of the removal of the Boiler House Annex and the non-original extension to East Craig, external changes have been minimised. In terms of new interventions, the current scheme is proposing an extension on South Craig and a dormer extension on East Craig and a new entrance to Bevan with associated platt. There will be the introduction of some railings at roof levels on South Craig and New Craig and rooflights will be formed in New Craig. The extensions and the new entrance to Bevan all enable the subdivision of the large villas into flatted dwellings. The South Craig extension is to the rear and set into the hill and the East Craig dormer extension replaces a non-original dormer element.
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The entry platt to Bevan is well designed and will be compatible with the design of the rest of the building. Similarly the design of new railings will be as per other railings and will integrate within the rest of the buildings. The new rooflights on New Craig will have a minor visual impact on the appearance of the building but will allow additional accommodation to be formed within the roof space. This increases the financial viability of the conversion of the building as the more units that can be accommodated within the building, the less pressure there is for new build.
Internally, the conversion of the buildings to residential units has been organised to make maximum use of the existing layout including stairs and access. It involves elements of both vertical and horizontal subdivision of the buildings but uses the existing configuration of the buildings to be guided by the appropriate location for subdivisions. Although it would have been possible to accommodate more dwelling units within the seven listed buildings, this would have involved a far greater level of subdivision and intervention that would be detrimental to the fabric, features and character of the listed buildings. The current layout reflects a sensitive approach to the conversion of the buildings and, although some units will be large, the layout involves the minimum alterations to achieve self contained units. Because the buildings in some instances will be horizontally sub-divided, the building of walls that will provide the necessary fire rating will necessitate the re-running of some cornices but this is acceptable within the context of the works to the whole set of buildings. The occasional introduction of new stairs is acceptable on the grounds that it enables the buildings to be converted. In addition, some level of intervention, particularly in New Craig, such as the subdivision of the occasional room of interest and the insertion of a mezzanine in one of the rooms in the North Wing are all considered acceptable in the context of the need to convert the buildings to a new use. The most significant spaces in the buildings, including the Great Hall in New Craig, will be kept intact.
The permanent blocking up of the tunnels is acceptable as many of these tunnels have already been filled in, and although of some interest, it is not feasible to open them up again. The removal of non-original features that are not of merit is to be welcomed. Overall, the scheme strives to retain the features that are of value in the vast majority of situations.
The proposals have been amended to delete some extensions that were part of the original submission. This is an improvement and the proposed alterations and works to the exterior will cause a minimal impact on the setting of the listed building. The removal of the modern extension on East Craig will be of benefit to the building. The removal of the Boiler House and Boiler House Annexe will not harm the setting of the listed buildings. There will be alterations to the main entrance gates. The narrowing of the entrances will provide a more traditional approach which will enhance the boundary treatment and the setting of the listed buildings. The proposals will have no detrimental impact on the setting of the listed building.
These former institutional buildings are at risk of long term neglect if a new and sustainable use is not found for them. Their conversion involves certain compromises that are acceptable given the need for a new use. The current scheme represents a well conceived response that balances the need to conserve what is significant about the buildings while doing the minimum required to convert the building to a new use.
There will be no adverse effect on the character of the listed buildings or their setting.
Development Management Sub-Committee – 3 September 2014 Page 10 of 31 12/04007/LBC b) The Acceptability of the Demolition of the Boiler House
The Scottish Historic Environmental Policy (SHEP) sets out the context for considering applications for the demolition of listed buildings. It states that it is Scottish Ministers' policy that no listed building should be demolished unless it can be clearly demonstrated that every effort has been made to retain it.
Consequently planning authorities should only approve such applications where they are satisfied that:
A. the building is not of special interest; or
B. the building is incapable of repair; or
C. the demolition of the building is essential to delivering significant benefits to economic growth or the wider community; or
D. the repair of the building is not economically viable and that it has been marketed at a price reflecting its location and condition to potential restoring purchasers for a reasonable period.
This position is supported by Policy Env 2 of the Edinburgh City Local Plan (ECLP), which also states that demolition will only be supported in exceptional circumstances, taking into account the merits of alternative proposals for the site and whether there are public benefits to be derived from allowing demolition which outweigh the loss.
The justification for demolition of the boiler house needs to meet only one of the SHEP tests above in order to be considered acceptable. The applicants have submitted a statement justifying its demolition based on Test A - that the building is not of special interest.
The Boiler House lies to the north of New Craig on the other side of the service road that leads up to Queen's Craig. Although physically separated from New Craig it reads from the air as part of the larger New Craig complex and is connected under the road, via its service routes, to New Craig. OS maps of 1893-4 or 1896 indicate that it was not built at the same time as New Craig but was built by the time of the 1908 map. It is possible that it may have been built because the original heating system for New Craig proved to be inadequate. There are modern extensions to the north. The building is in poor condition and has attracted vandalism and graffiti.
The Boiler House is an outbuilding to New Craig. It is not contemporary with the New Craig and is not part of the overall vision and composition of New Craig and the larger site. The building is set into the hill and is positioned to be inconspicuous. It is not mentioned in the list description and is listed only by virtue of being within the curtilage of New Craig. It is not worthy of listing in its own right, as its only interesting features are its pyramidal roof and stone arch details to the north.
The Boiler House is not of special interest and its demolition can be justified against the first SHEP test.
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Policy ENV 2 of the Edinburgh City Local Plan supports demolition only in exceptional circumstances including: the merits of alternative proposals for the site and whether the public benefits to be derived from allowing demolition outweigh the loss.
The conservation and continued viable use of these significant A listed buildings is dependent on a level of new build on the site that will cross fund the works required for the conversion. The demolition of the Boiler House will allow new build on this part of the site which has been assessed in the concurrent planning application as being an appropriate location for new development. This will help enable the significant buildings to be retained. Therefore the public benefit of conserving the main subjects of listing outweigh the loss of the Boiler House.
Conditions will be added to this consent to ensure that the building is appropriately recorded prior to its demolition and that a Notice of Initiation for the new build has been submitted which confirms the start date. c) Impact on the Character of the Conservation Area
The Craiglockhart Hills Conservation Area Character Appraisal notes that:
The views to the Hills from Arthurs 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.
And that:
The Craighouse complex has a strong unity of composition derived from the inter- relationship of buildings, woodlands, open spaces and views over the city. Areas of woodland to the south west provide an important backcloth to the buildings, the setting of which is further enhanced by varied specimen trees which provide a sense of scale. 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.
And states that: listed buildings and ancient monuments will be protected, as will their setting and surroundings.
This listed building consent application is for the alterations and extensions to the listed building and not the new build elements. Therefore this report can only assess the impact that proposed alterations to the listed buildings have on the character and appearance of the conservation area as opposed to the impact of any new build elements.
The removal of the Boiler House and the Boiler House Annex will not compromise the integrity of the listed structures and will not adversely affect the character or appearance of the conservation area. These elements are of minor interest and their inconspicuous location in the conservation area means that the impact of their loss will be minimal.
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The removal of the modern extension to East Craig will be an improvement. New external interventions to the listed buildings will be limited and of good quality. They will be sympathetic to the buildings and the area.
The elements proposed in this application will preserve the character and appearance of the conservation area. d) Equalities and Human Rights impacts
The accessibility of a large number of units is of benefit to those with disabilities and there will be an overall improvement in equalities. An Equalities and Human Rights Impact Assessment has been completed. e) Public Comments
Material representations -
• The conservation of the built environment. The case for the loss of the Boiler House is discussed in Section 2.3.b). The stopping up of the tunnels is discussed in Section 2.3.a) and the alterations and additions to the listed buildings are assessed in 2.3.a)
• The process and quality of the submission. The application was re-advertised on 15 March, 2013 after missing information had been submitted.
Non-material representations - Comments that are non-material to the assessment of this listed building consent application but that are material to the concurrent planning application (12/04007/FUL) will be assessed in the relevant report to committee.
Community Council Comments - Craiglockhart Community Council has no objections.
CONCLUSIONS
In conclusion, the proposals comply with the development plan and non-statutory guidance. They will not adversely affect the character of the listed building or its setting or the character and appearance of the conservation area. The case for demolition of the Boiler House is accepted. The proposals will help ensure the long term sustainable survival of these significant listed buildings and represent a sympathetic, minimal intervention to the buildings. There are no other material considerations which outweigh this conclusion and subject to the addition of conditions to ensure the recording of demolitions, the contract, and further details, approval is recommended.
It is recommended that this application be Granted subject to the details below.
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3.4 Conditions/reasons/informatives
1. The application shall be notified to the Scottish Ministers prior to determination.
2. No demolition shall start until the applicant has confirmed in writing the start date for the new development by the submission of a Notice of Initiation.
3. The Royal Commission on the Ancient and Historical Monuments of Scotland shall be given access to the site, at any reasonable time in a period of at least three months from the date of this consent, for the purposes of recording the building, structure or other item of interest.
4. A conservation strategy is required relating to historic wall paper in both Old Craig and New Craig prior to the submission of any proposals to alter the wall paper.
5. Details of the location of suspended ceilings shall be submitted to and approved by the Head of Planning and Building Standards before work is commenced on site.
6. Details of the treatment of interior timber panelling shall be submitted to and approved in writing by the Head of Planning and Building Standards before work is commenced on site.
7. Details of fireplace removals and relocations in the form of a schedule shall be submitted to and approved in writing by the Head of Planning and Building Standards before work is commenced on site.
8. Details of external wall treatment where the Boiler House Annexe is being removed shall be submitted to and approved in writing by the Head of Planning and Building Standards before work is commenced on site.
9. Details of housing for ventilation through the roof of Old Craig shall be submitted to and approved in writing by the Head of Planning and Building Standards before work is commenced on site.
Reasons:-
1. In order to accord with the statutory requirements of the Town and Country Planning (Scotland) Acts.
2. In order to safeguard the character of the statutorily listed building.
3. In order to safeguard the interests of archaeological heritage.
4. In order to safeguard the character of the statutorily listed building.
5. In order to enable the Head of Planning and Building Standards to consider this/these matter/s in detail.
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6. In order to enable the Head of Planning and Building Standards to consider this/these matter/s in detail.
7. In order to enable the Head of Planning and Building Standards to consider this/these matter/s in detail.
8. In order to enable the Head of Planning and Building Standards to consider this/these matter/s in detail.
9. In order to enable the Head of Planning and Building Standards to consider this/these matter/s in detail.
Informatives
It should be noted that:
1. The works hereby permitted shall be commenced no later than the expiration of three years from the date of this consent.
Financial impact
4.1 The financial impact has been assessed as follows:
There are no financial implications to the Council as a result of this Listed Building Consent application. Risk, Policy, compliance and governance impact
5.1 Provided planning applications are determined in accordance with statutory legislation, the level of risk is low. Equalities impact
6.1 The equalities impact has been assessed as follows:
The application was assessed in terms of equalities and human rights. The impacts are identified in the Assessment section of the main report. Sustainability impact
7.1 The sustainability impact has been assessed as follows:
This application is not subject to the sustainability requirements of the Edinburgh Design Guidance. Consultation and engagement
8.1 Pre-Application Process
This application was the subject of extensive pre-application discussions prior to the submission of this application.
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8.2 Publicity summary of representations and Community Council comments
The application was advertised on 23 November 2012. Due to some drawings having been omitted in the first submission, the application was re-advertised on 15 March 2013. There have been 39 letters of representation, including 33 individuals, the Craiglockhart Community Council, the Garden History Society, the Morningside Court Residents Association, the Cockburn Association and two individuals representing the Friends of Craighouse.
In all there have been two letters of support, one letter of comment and the rest have been letters of objection. One person has written two letters, one supporting the proposals and one objecting. Eight letters are non-material to the assessment of the listed building consent application.
Material Representations
The main points of objection/concern can be summarised as follows: matters relating to conservation of the built environment:
• new additions and alterations are detrimental to the character of the listed building;
• the loss of the boiler house is detrimental to the character of the listed buildings; and
• the blocking up of the tunnels is detrimental to the character of the listed buildings. matters relating to process and quality of the submission:
• there were irregularities in the processing of the application; and • the submission is inadequate in terms of its quality.
The main points of support can be summarised as follows: matters relating to the principle of the development:
• The conversion of the listed buildings into flats is to be supported.
Non-material Representations
Non material points raised are as follows: • the financial case for the conversion and new build has not been demonstrated; • matters relating to quantity of the new build element on the site; • matters relating to the design of the new build element on the site; • matters relating to road and pedestrian safety; • matters relating to residential amenity; • matters relating to local infrastructure; • matters relating to the open space; and • matters relating to the natural environment and wildlife.
These non-material points are dealt with in the concurrent planning application.
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Community Council Comments
The Craiglockhart Community Council has no objections to the listed building consent application.
A full assessment of the representations can be found in the main report in the Assessment section.
Background reading / external references
• To view details of the application go to • Planning and Building Standards online services
Statutory Development Edinburgh City Local Plan, Craiglockhart Hills Plan Provision Conservation Area, Open Space, Area of Great Landscape Value. Part of the site is within a Local Nature Reserve and part is within a Local Nature Conservation Site.
Date registered 12 November 2012
Drawing numbers/Scheme 01, 117-121, 123-127, 129-142, 144-202, 203a, 204a, 210a,,
211a, 212, 213a, 214-224, 225a, 226a, 227-232, 256-
263, 266,, 268-274, 276-281,
Scheme 3
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David R. Leslie Acting Head of Planning and Building Standards
Contact: Barbara Stuart, Planning Officer E-mail:[email protected] Tel:0131 529 3927 Links - Policies
Relevant Policies:
Relevant policies of the Edinburgh City Local Plan.
Policy Env 2 (Listed Buildings - Demolition) identifies the circumstances in which the demolition of listed buildings will be permitted.
Policy Env 3 (Listed Buildings - Setting) identifies the circumstances in which development within the curtilage or affecting the setting of a listed building will be permitted.
Policy Env 4 (Listed Buildings – Alterations & Extensions) identifies the circumstances in which alterations and extensions to listed buildings will be permitted.
Policy Env 6 (Conservation Areas Development ) sets out criteria for assessing development in conservation areas.
Relevant Non-Statutory Guidelines
Non-statutory guidelines 'LISTED BUILDINGS AND CONSERVATION AREAS' provides guidance on repairing, altering or extending listed buildings and unlisted buildings in conservation areas.
Other Relevant policy guidance
The Craiglockhart Hills Conservation Area Character Appraisal emphasises the outstanding quality of the natural topography and its visual relationship with the city, the high quality buildings set within a mixture of wooded and open slopes, the use of natural stone and slate as the traditional building materials.
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Appendix 1
Application for Listed Building Consent 12/04007/LBC At Napier University Craighouse Campus, Craighouse Road, Edinburgh Proposed conversion of existing listed buildings at New Craig , Queen's Craig, East Craig, Bevan Villa, South Craig, Craighouse Lodge, Old Craighouse to form residential properties, including extension at South Craig and demolition of Boiler House (as amended).
Consultations
Historic Scotland
We have considered your consultation and comment as follows:
This letter is split into 4 distinct responses - firstly we set out our response to your council in regard to the Environmental Impact Assessment, secondly our assessment of the case for development, thirdly a response to the Development Management Procedure Scotland (Regulations) (DMPR), and fourthly the Listed Building Consent application (LBC).
1. Environmental Impact Statement
The following comments are based on our statutory historic environment interests. That is scheduled monuments and their setting, category A listed buildings and their setting and gardens and designed landscapes and historic battlefields in their respective Inventories.
Baseline and Methodology In general, we are satisfied that the environmental statement has identified the most relevant historic environment baseline against which to test the proposals. While the assessment would have benefited from a more holistic consideration of the group of A listed buildings within their wider setting we have based our comments on the information provided within the environmental statement. While we are in general, content to agree with the findings of the majority of this assessment we would like to offer further detailed comments on some aspects of the findings of the assessment.
Physical Impact to Listed Buildings We note that the conversion of this large group of Category A listed buildings for residential use is considered to be a Major positive impact. Subject to the detail of the Listed Building Consent process we agree that the proposals will be of significant benefit to these historic environment assets in relation to their long-term sustainable future.
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In-direct Impacts As noted above, the assessment reports on the individual listed structures and their settings and is less focused on a larger consideration of their context. Notwithstanding this we would generally agree with the findings of the assessment in relation to the impacts on the setting of these sites. However, we would not agree with the assessment findings in relation to the potential impacts on the settings of both South Craig House and Bevan House. In terms of the impact on South Craig House we note that the assessment considers that there will be a minor impact from the proposed Coulson Tower, citing the removal of the unsympathetic structure currently on the site. While we agree that the current structure detracts from the setting of South Craig the substantial scale of the Tower proposal would dominate views of South Craig and we do not consider that the removal of the existing structure mitigates this impact to any significant degree. To an extent this is recognised by the assessment but we would argue that the impact on the setting of South Craig is more than the minor impact reported in the assessment. We are of the view that the impact is likely to be of greater significance and should be considered at least a moderate impact on its setting, leading to a moderate to large significant negative impact.
Similarly we do not agree with the assessment finding relating to the setting impact on both South Craig and Bevan Houses through the insertion of a structure between these two sites. The assessment considers that there is no adverse impact in relation to this intervention as intervisibility between the two sites would not appear to be a key function of their relationship. While we agree that this intervisibility component between the two sites is not a great significance our concerns lie more with the reading of these two assets in their current setting. The inclusion of another structure between these two sites (as well as Clouston Tower to the south) would create a less readable relationship between the two sites within their landscape and create a more rigid grouping of buildings lining across the hillside. We would therefore argue that this constitutes a moderate impact on the setting of both South Craig and Bevan Houses.
2. Assessment of the Case for Development
The case for development
Throughout the pre-application discussions the extent of new-build development has been discussed at length. The submitted scheme reflects discussions regarding the appropriateness of various sites across the campus, and addresses many of our earlier concerns. Our comments on individual components of the development are given later in this letter.
Underpinning the case for an appropriate level of development at the Craighouse campus is the key priority of providing a sustainable economic use for the whole site, but particularly for the listed buildings. The background to such a case was submitted as a development appraisal by the developers in 2011. That appraisal was subsequently (summer 2012) considered by Knight Frank on behalf of your authority. We have had sight of both the original appraisal and Knight Frank's report, and have had the latter considered by Scottish Government colleagues.
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The 2011 development appraisal was based on the scheme as then drafted. Since that time considerable amendment has been carried out, although the basic economic model, with new build residential units supporting the restoration and conversion of the listed buildings to residential, remains the same.
We note from your recent correspondence (10 December) that your authority has requested further, updated development appraisal information from the applicants. We support your authority in seeking this information. We will respond separately outlining outstanding issues, many raised by Knight Frank, that we believe need to be addressed in the updated development appraisal.
We will be happy to comment further on the updated development appraisal as and when that information is received by your authority.
3. DMPR Comments: The setting of A-listed buildings
Design and Materials Our concerns expressed in earlier comments in regard to the initial rather fragmented style approach to the new buildings across the site have now been addressed, with a revised design strategy which is applied throughout the site. This employs a careful choice of materials, colours, and textures - all seeking to harmonise with the listed buildings and their landscape setting.
Individual sites We note that since September there have been considerable revisions to both the landscaping strategy, and design of the new buildings throughout the site. As the naming of individual elements has changed since our last comments, I should emphasise that the comments below use the plot names from the submitted scheme.
Kings Craig This site is immediately to the south of the main block of New Craig, and its location and the slopping topography of the site mean that any development here will be prominent. The omission of the 2 pinwheel blocks of flats on this site, and their replacement by a terrace of contemporary town houses is to be welcomed. In terms of impact to setting and built form, this design has a better relationship with New Craig.
West Craig We support the design revision to this site to tie these buildings in with nearby Kings Craig, whilst still maintaining an appropriate scale response to Queens Craig.
Old Craig Court The development of the current car parking site to the east of Old Craig has been an area of extensive discussion and revision. The initial concerns we voiced in regard to this area have been largely addressed, with new development fully integrating with its immediate parkland setting, as was discussed in Workshop sessions with A+DS.
The location of the terraced development is an appropriate distance down the slope to avoid a negative impact on the setting of Old Craig, which will retain its visual presence in the wider landscape in key views from the south.
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North Craig We have supported development of the Boiler House site throughout the pre- application process. The form and design of the proposed buildings of North Craig are respectful of the architectural language of New Craig, and utilise the falling ground to their advantage while minimising impact to the listed building.
Old Grove Court The rationalisation of development to the fringe of the site has been significantly explored and developed since September. We do not believe Old Grove Court and its associated landscaping would have a detrimental impact to the setting of the listed buildings. The site sits low in parkland and is shielded by existing planting and boundary wall.
Craiglea Place As the proposed continuation of Craiglea Place is within a very discrete part of the site, it has no setting issue to the listed buildings.
Duncan and LRC site The submission of the application sees us consulted in regard to 2 new development sites which we have had no prior part knowledge of. It is proposed to build an 8-storey tower block on the site of the Learning Resource Centre to the Eastern ridge. Furthermore there is a proposal to build a 3-storey housing block between South Craig and Bevan on the eastern ridge. In terms of assessing the impact to the adjacent listing buildings, and the site as whole, we do not feel at this moment in time there has been adequate supporting material and dialogue to allow us to make a full assessment. We would reserve comment in regard to these new development sites until such time as we have further information.
Listed Building Consent Comments
We welcome the sensitive conversion strategy which has been adopted by the applicant to the listed buildings. While we recognise that there may be scope to introduce a more intensive scheme that would see the building divided to a greater degree, this would not be an approach that we would generally support, as it would greatly harm the value and significance of the site. We have welcomed the opportunity to visit all the listed buildings - Old Craig, New Craig, Queens Craig, East Craig, Bevan, South Craig and the Lodge on a number of occasions throughout 2012 with your officer Barbara Stuart, William Gray Muir (Sundial Properties) and Andrew Stevens (Oberlanders Architects).
In general the subdivision of the listed buildings has taken full account of their character, plan-form, and surprisingly intact survival of high quality fixtures and fittings. Furthermore there are a number of significant conservation benefits by the removal of a number of un-sympathetic 20th century alterations.
General Points
Perhaps it would be helpful in the first instance to draw upon matters that have a commonality throughout the site. We are aware that some further clarification is required in regard to meeting the requirements of building standards, and importantly how these changes will impact on the fabric and appearance of the buildings.
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We welcome however that it has already been established that individual balanced flues to apartments have been discounted due to the detrimental impact they would have on the exterior appearance of the building. Instead it has been proposed to rationalise, and group flues internally throughout the building in areas where minimal disruption to historic fabric will occur.
It is proposed to adopt a fire suppression system, this approach will allow for the retention of important fixtures and fittings (for example internal doors, decorative screens, and the abundance of stylised leaded lay-lights) which otherwise would be significantly altered or compromised to comply with fire regulations.
It is the intention of the applicant to refurbish all the windows by way of repair, it has been stated that no large scale replacement of windows is proposed, and it is not proposed to re-glaze with slim-profile.
As noted above there have been a number of site visits in the last year where alterations detailed on the current submitted set of drawings have been discussed. By agreement with all those present a number of changes have been made. However as yet, a large number of these have not been translated to the plans. We would ask that these changes are reflected in the most up to date drawings. This will allow us to have confidence that the submitted proposals are an accurate representation of the verbal assurances that have been given to date.
Specific Buildings
Old Craig Whilst being the oldest building on site, a significant part of the interior has been heavily modernised. The proposed conversion seeks to sensitively restore the building back to a single dwelling. Furthermore we welcome the proposal to lime wash the building a traditional colour which will give the building a more authentic appearance.
New Craig In general we have no major concerns with the design strategy adopted to subdivide this vast building. The removal of fire partitioning to the 1st floor of the great hall is to be particularly welcomed, re-instating this impressive space back to its original appearance. As site visits have only very recently finished at New Craig, there have been a number of changes discussed that as yet have not been revised. We would welcome the opportunity to see these added before commenting in further detail. Added to the above, one key area which needs further discussion is the proposal to partition the ground North Wing spine corridor which runs off the Great hall past the former Dining Room.
Queens Craig We have no concerns with the design strategy adopted to subdivide this building.
Lodge The refurbishment of the lodge is sensitive and respectful to the building, the omission of the proposed large extension is welcomed.
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East Craig We have no concerns with the design strategy adopted to subdivide this building. The loss of the late 20th century extension is to be welcomed.
Bevan In general the design strategy to subdivide this building causes us no major issues. However there are 3 points where further clarification and discussion has been required. We recognise that the configuration of the building was particularly designed for its use as accommodation for patients. In the case of Bevan, subdivision utilising the main stair to service the 3 proposed apartments has not proved practicable. The stair therefore becomes obsolete as a stair, however its high quality design, and the fact it is the principle stair dictates its meaningful retention. Furthermore it is our understanding that plans will be revised to omit the proposed slapping from the hall into the main reception room. The architectural design, quality and integrity of the hall is such that it should not be compromised. On site there was discussion about revising the design of the new entrance to the west elevation, we look forward to seeing this. We recognise that the villa buildings are very much designed in the round, with articulated faces to each elevation. Therefore any form of extension needs to be very carefully assessed in terms of the contribution it makes. The proposed extension to Bevan is located in a discrete area on the south elevation, it is our view that it does not have a detrimental impact to the character of the building.
South Craig In general the design strategy to subdivide this building into 3 apartment causes us no major issues. However as with Bevan, the principle of placing extensions onto this 4- sided building needs to be very carefully considered. On site we noted that we could not support the extension to the principle elevation.
Historic Scotland - response dated 26/03/2013
Thank you for your consultation dated 13 March which we received on 13 March. We have considered your consultation and comment as follows: We propose to address your re-consultation in the same format as our previously submitted comments of 21 December 2012. Therefore we have split the response into 4 distinct sections; Environmental Impact Statement, Case for Development, Development Management Procedure Scotland (Regulations) and Listed Building Consent Application.
1. Environmental Impact Statement We note the minor amendments contained within the addendum replacement chapter for Archaeology and Cultural Heritage. In noting that the majority of the assessment remains unchanged we would refer you to our previous comments dated 21 December 2012 regarding assessment of impact, in particular the impact on the setting of South Craig and Bevan.
2. Assessment of the Case for Development In our response to your council on the 21 December 2012 we outlined that we would respond further to your authority on information that is commercially confidential. We did so on 21 January 2013 raising a number of issues that required further
Development Management Sub-Committee – 3 September 2014 Page 24 of 31 12/04007/LBC clarification. We note that there has been subsequent information submitted as part of this current re-consultation. Given the business sensitive nature of this particular matter we would welcome further discussion with your Council.
3. DMPR Comments: The Setting of the A-listed Building We note that the massing, form, layout and materials of the proposed new build have not changed since our last letter, and therefore, we would refer you to our previous comments dated 21 December, particularly in regard to Duncan and the LRC site.
4. Listed Building Consent Comments We welcome the updates made demonstrating a number of revisions since our last comments, in particular the reduction of extensions to South Craig and Bevan.
One point that still remains outstanding, however, is the proposal to partition the ground floor North Wing spine corridor which runs off the Great Hall, past the former dining room. Whilst it has been argued division of this space will be of advantage to the functioning of the apartment it is intended for, this has to be weighed against the disadvantage to the character, enjoyment and understanding of the public circulation spaces which elsewhere have been sensitively handled. We would urge further consideration of this matter.
We would ask that further consideration is given to establishing the provenance of decorative wallpapers which are to be found in both Old Craig and New Craig. Should it be established that they are authentic Victorian papers, a conservation based strategy should be established in terms of their practicable/reasonable retention/recording.
As noted above there remain a number of outstanding issues, and with this in mind we would value a meeting to discuss these at the earliest opportunity with your council.
Historic Scotland - response dated 14/01/2014
Thank you for your consultation dated 17 December which we received on 17 December. We have considered your consultation and comment as follows:
Thank you for your consultation in regard to the Craighouse Campus site. As with our previous replies to your council we propose to split our letter into distinct sections which will address the following - Environmental Impact Assessment, Development Management Procedure Scotland (Regulations) (DMPR) and the Listed Building Consent application (LBC). In our conclusions we have included comments in relation to the importance of the future of the site being protected by the achievement of a sustainable development. We have concluded that the proposals do not raise issues of national significance for the historic environment such that we would object.
1. Environmental Statement As you will be aware, in our response to the original Environmental Statement (dated 21 December 2012) we raised a number of concerns regarding the assessment and its findings. The following comments relate to our original concerns against the updated assessment in light of alterations to the proposals.
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Baseline and Methodology We remain content that the environmental statement has identified the most relevant historic environment baseline against which to test the proposals. In terms of our comments regarding a more holistic approach to the assessment of the buildings as a group we welcome the expansion of consideration in this area and are content with the findings, although we consider the impact to be more neutral than positive.
Duncan Our original concerns related to the impact this component of the development would have on the setting of South Craig and Bevan Villa and their legibility in their setting. We therefore note that this building has been removed from the proposals and as such have no further comments to offer on this issue.
Clouston We note that the vertical dominance of the original proposed tower has been lessened by its reduction in height. However, the substantial increase in the massing of the block form of the revised proposal remains a significant impact on the immediate setting of South Craig. We therefore consider that this impact remains more significant than the reported minor impact from the environmental assessment.
2. DMPR Comments: The Setting of A-listed Buildings
Individual Sites We note that since the previous public consultation in the Spring of 2013 there have been considerable revisions to both the landscaping strategy and the design of the buildings throughout the site. As the naming of some of the individual elements has changed since our last comments, I should emphasise that the comments below use the plot names from the current, revised scheme.
Kings Craig We note that the overall massing and scale of this row of townhouses has been reduced, particularly in regard to the central vertical element, and welcome this amendment as it will reduce the impact this element of the scheme will have on the setting of the historic buildings.
West Craig We note that the overall massing and scale of this row of townhouses has been reduced, and welcome this amendment, as it will reduce the impact this element of the scheme will have on the setting of the historic buildings.
North Craig Villas We have supported the re-development of the 'Boiler House Site' since it was tabled in the masterplan process, believing that a sensitively designed development in this location should be achievable with minimal impact of the adjoining listed building. From Spring 2013 there has been a comprehensive redesign of the terrace. The proposed buildings now present more of a traditional appearance echoing the existing run of ancillary buildings they will replace. In terms of impact to setting, New Craig will retain its visual dominance, as the new buildings will sit below the main range, utilising the falling ground to their advantage, and in longer views from the north will be screened by the surrounding woodland. We therefore welcome this amendment as it reduces the impact on the historic environment.
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Craiglea Place The proposed terrace of 6 houses has been reduced to 4. As we have previously noted, the continuation of Craiglea Place is within a very discrete part of the site, and therefore has no setting impacts to the listed buildings.
Duncan The proposal to build a 3-storey housing block between South Craig and Bevan on the eastern ridge has been dropped from the scheme. We welcome this revision to the masterplan as we had major concerns in relation to the potential impact this aspect of development might have on the relationship between the listed buildings.
Clouston From Spring 2013 there has been a comprehensive redesign of the architectural language and scale of this block. We welcome the reduction in height of this building, which reduces its impact on long views and the site as a whole. This reduction has, however, been achieved by greatly increasing the floorplate of the building proposed. The greater bulk of this building, will, therefore, have a regrettably higher impact on the setting of the A Listed South Craig block immediately to its north.
Napier and Burton This site, currently the car-park and bus turning circle, has seen a number of revisions during the design process. The apartment blocks are a significant departure from earlier design approaches in terms of height, footprint and design. The increase in bulk of these proposals will inevitably have a considerable impact on the overall site, particularly in long views into and out from the higher ground to the south and from the historic approaches to the site.
In terms of footprint, Napier has been located further down the slope away from Old Craig with the formation of a generous delineated courtyard and walled garden, allowing Old Craig an appropriate breathing space and contextual immediate setting.
We believe the combined visual envelope of Napier and Burton will have a greater impact to the setting of Old Craig than the previous schemes.
3. Listed Building Consent Comments We fully welcome the conversion strategy which has been adopted to the full suite of listed buildings on the site.
Whilst we recognise that there may be scope to introduce a more intensive scheme that would see the building subdivided to a greater degree, we greatly welcome that this application does not propose this. The internal layout, and high quality fixtures and fittings of Craighouse are of particular merit, and therefore a scheme that respects the existing plan form and features is to be welcomed.
We believe the proposed refurbishment works are sensitive, responsive and retain the special value and significance of the buildings.
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4. Conclusion In the course of the last three years we have been consulted, either formally or via pre- submission discussions, with a wide variety of development approaches to the Craighouse site. Underlying all has been the imperative of achieving an economically sustainable, long term future for the existing listed buildings on the site, which are currently on the buildings at risk register
Your Council has been leading considerable negotiations in establishing the appropriate equilibrium of development in regard to the interests of the landscape value of the site (designated by the Council as an Area of Great Landscape Value) balanced with that of safeguarding this group of nationally important Category A-listed buildings.
We are aware that these discussions have shaped this revised application. As noted above, we consider that some of the elements of the current revised submission will necessarily have a greater impact on the setting of certain of the listed buildings, or the wider group. Your authority is best qualified to consider this impact, which arises from the need to provide an appropriate level of development on the site to make it financially sustaining, and judge whether it is necessary in order to achieve the re-use of the site as a whole.
In terms of our locus and remit, our paramount objective has to be seeing these buildings removed from the Buildings at Risk Register with the guaranteed lifeline of a sustainable future. As noted above, the proposed refurbishment works are sensitive, responsive and should guarantee the preservation of the special value and significance of the buildings.
Archaeology - Scheme 2 response dated 16/01/2014
Further to your consultation request as a result of this revised submission, I would like to make the following revised comments and recommendations in respect to this application the proposed change of use and conversion of the existing buildings from university campus to residential, and construction of new build residential together with ancillary development, public realm and utilities infrastructure including access roads, car-parking and landscaping
As stated previously (see December 2012 & March 2013 responses) the development site is of considerable archaeological and historic interest both in terms of its surviving listed-buildings, landscapes and potential for buried archaeology. A comprehensive history of the site is contained within Appendix 4 Archaeological & Cultural Heritage Chapter of the revised February 2013 Environmental Statement Addendum produced by Wardell Armstrong and Simpson & Brown's Conservation Plan. In summary the site is first recorded in the 12th century as belonging to the important Abbey of Newbattle in the Scottish Borders with Old Craighouse House dating to 1565. The estate survived as private estate until 1878 when it was sold by a Dr Hill Burton to Edinburgh Royal Asylum with Napier University taking over the site in the 1990's.
As stated in my earlier responses, both the Old Craighouse House and Craighouse Hospital are regarded as being of national archaeological and historic importance (A- listed) with the wider estate suspected of containing significant archaeological remains relating primarily to the former medieval and post-medieval estate and of course the 19th-20th century hospital.
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Accordingly this application must be considered under terms Scottish Government's Scottish Planning Policy (SPP) and Scottish Historic Environment Policy (SHEP) and also CEC's Edinburgh City Local Plan Policies ENV3, ENV4, ENV7, ENV8 & ENV9. The aim should be to preserve archaeological remains in situ as a first option, but alternatively where this is not possible, archaeological excavation or an appropriate level of recording may be an acceptable alternative.
Buried Archaeology As stated previously, the development site is regarded as being of archaeological significance primarily in terms of its medieval and post-medieval archaeology relating to the Craighouse Estate. The proposed development will require extensive excavations in terms of construction of new buildings, landscaping, utilities, roads car-parking etc. Having read over the accompanying environmental statement by Wardell Armstrong I agree with the general conclusions that such works are regarded as having a the whole a moderate archaeological impact. The scale of mitigation is larger than is again suggested by the revised Environment Statement Appendix 6 i.e. archaeological mitigation will encompass the whole site and not just be focused upon the area immediately surrounding Old Craighouse.
Accordingly it is recommended that a programme of archaeological works is undertaken prior to development. In essence this will see a phased archaeological programme of works, the initial phase being an archaeological evaluation up to a maximum of 10% of the site. The results of which would allow for the production of appropriate more detailed mitigation strategies to be drawn up to ensure the appropriate protection and/or full excavation, recording and analysis of any surviving archaeological remains affected.
In addition any agreed woodland management plan for the site must have an appropriate mitigation strategy which would aim to protect and enhance the site's archaeological heritage.
Drainage & SUDS In addition to the above general programme of post determination works, it was mentioned in my response to the March 2013 revised scheme that I have concerns regarding the potential impact the new drainage and flood prevention proposals. In particular this is in regard to the site of the dovecot shown within the woods to the north of Old Craighouse on the 1st edition OS map which appears to be close or on the line of the projected new drainage track.
As stated in my earlier responses the requested aim is avoid damage to this archaeological site, with drainage proposals designed to avoid any impact. It was requested that this site be evaluated prior to determination in order to investigate its state of preservation and to allow for drainage designs to be undertaken. It is noted that although further drainage design appears to have been undertaken I refer you to the Drainage Strategy undertaken by Goodson Associates accompanying this application, no consideration appears to have been undertaken in response to these archaeological concerns. Accordingly it essential that before the route of the proposed drainage track is agreed that the exact location of this historic dovecote is located and mitigation measures submitted for agreement which will allow for its protection.
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Archaeological Setting It is clear that these new proposals (Scheme 2) will have a significant impact upon the localised setting of the both the historic buildings occupying the site and the surviving estate's historic landscape. In general I concur with the assessments contained within Wardell Armstrong's revised Environmental Statement Appendix 6 that on purely archaeological grounds such impacts are in the main moderate. That said the construction of the new Napier and Burton buildings in my opinion have an significant increased impact, by want of their scale and in particular height on setting of the historic buildings and landscape.
This is particularly true in the case of the Burton building whose height above the existing tree heights obscures key views out towards Arthurs Seat and in conjunction with its neighbour Napier could be seem to conflict in scale with its neighbouring historic buildings of Old Craighouse and Craighouse Hospital. A reduction buy 1 to 2 storeys could resolve this issue.
Archaeological Public Engagement Further given the potential importance of these remains in terms of the history of Edinburgh and in particular Craighouse, it is essential that this programme of works contain a programme of public/community engagement (e.g. site open days, viewing points, temporary interpretation boards) the scope of which will be agreed with CECAS.
Historic Buildings As stated the site contains a range of nationally important historic buildings the development of which will see significant works to their fabric. Accordingly if consent is granted it is recommended that a programme of historic building survey (level 2-3) is undertaken prior to and during any works that may either affect or reveal new sections of historic fabric of the listed Old Craighouse and later hospital buildings. The works will be undertaken in accordance with an agreed brief with this office. This is in order that any archaeological remains (historic building fabric) that may be affected are properly recorded where preservation in situ is not possible.
It is essential therefore that a condition be applied to any consent granted to secure this programme of archaeological works based upon the following CEC condition;
'No development shall take place on the site until the applicant has secured the implementation of a programme of archaeological work (Historic Building Recording, excavation, analysis & reporting, publication, public engagement & interpretation) in accordance with a written scheme of investigation which has been submitted by the applicant and approved by the Planning Authority.'
The work must be carried out by a professional archaeological organisation, either working to a brief prepared by CECAS or through a written scheme of investigation submitted to and agreed by CECAS for the site. Responsibility for the execution and resourcing of the programme of archaeological works and for the archiving and appropriate level of publication of the results lies with the applicant.
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Location Plan
© Crown Copyright and database right 2014. All rights reserved. Ordnance Survey License number 100023420 END
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Wednesday 3 September 2014
Application for Conservation Area Consent 12/04007/CON At Napier University Craighouse Campus, Craighouse Road, Edinburgh Demolition of Learning Resource Centre (LRC) Building.
Item number Report number
Wards A09 - Fountainbridge/Craiglockhart
S um m a ry Summary
The proposal represents a departure from planning policy as the proposed replacement scheme on the site of the LRC building will neither enhance nor preserve the character and appearance of the Craiglockhart Hills Conservation Area. However, the existing building is of no architectural merit and its removal is required to facilitate an enabling development to help safeguard the long-term future of the A-listed buildings on the wider site. A departure is justified in this instance.
Links
Policies and guidance for LPC, CITE5, OTH, CRPCHI, this application
Development Management Sub-Committee – Page 1 of 9 12/04007/CON
Report
Application for Conservation Area Consent 12/04007/CON At Napier University Craighouse Campus, Craighouse Road, Edinburgh Demolition of Learning Resource Centre (LRC) Building.
Recommendations
1.1 It is recommended that this application be Granted. Background 2.1 Site description
The application site is the former Napier University campus situated at Easter Craiglockhart Hill.
The area of demolition extends solely to the Learning Resource Centre building located at the southern extremity of the site. The LRC building is 3-storeys high with a flat roof and is of modern design.
There are a number of mature trees to the south of the building that mark the campus boundary. The main campus buildings, which are A-listed, are located to the north of the LRC building.
This application site is located within the Craiglockhart Hills Conservation Area.
2.2 Site History
13 September 2001 - An application for the development of a new arts faculty building and minor works to existing 'A' listed building was withdrawn (Application reference - 01/01435/FUL).
24 September 2001 - An application for the development of a new arts faculty building and minor works to existing 'A' listed building was withdrawn (Application reference - 01/01435/LBC).
24 May 2002 - Listed building consent was granted for minor works to basement area of New Craig in conjunction with development of new arts facility building (Application reference - 01/04599/LBC).
26 June 2007 - Permission was granted for the development of a new arts facility building, new surface car park and minor works to existing 'A' listed building (Application reference 01/04599/FUL).
19 September 2012 - An application for the modification of clause (fourth) and clause (seventh) of the legal agreement relating to application no. 01/04599/FUL was withdrawn (Application reference - 12/02261/OBL).
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22 November 2012 - Permission was granted for the modification of clause (fourth) and clause (seventh) of the legal agreement relating to application no. 01/04599/FUL (Application reference - 12/03397/OBL).
There have also been several applications for minor works relating to the operation of the university estate.
Related applications
An application for planning permission has been submitted for the proposed change of use and conversion of existing buildings from university campus to residential and for the construction of new build residential, together with ancillary development, public realm, utilities infrastructure including access roads, car parking and landscaping (Application reference - 12/04007/SCH3). That application is also being considered at this Committee meeting.
An application for listed building consent has been submitted for the proposed change of use and conversion of existing listed buildings at New Craig, Queen's Craig, East Craig, Bevan Villa, South Craig, Craighouse Lodge, Old Craighouse to form residential properties including an extension at South Craig and Bevan Villa (Application reference - 12/04007/LBC). That application is also being considered at this Committee meeting.
Main report
3.1 Description Of The Proposal
Conservation area consent is sought for the demolition of the learning resource centre building to enable redevelopment.
A conservation plan has been submitted in support of the application, which is available to view via Planning and Building Standards online services.
3.2 Determining Issues
Do the proposals harm the character or appearance of the conservation area? If they do, there is a strong presumption against granting of consent.
3.3 Assessment To address these determining issues, the Committee needs to consider whether: a) the proposed demolition will preserve or enhance the character and appearance of the conservation area; b) the new building will preserve or enhance the appearance of the conservation area and is of sufficient quality; c) the proposal will have any detrimental impact on equalities and human rights; d) there are any other material considerations; and e) there are any material issues raised in representations.
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a) The Craiglockhart Hills Conservation Area Character Appraisal states that the essential character of the Craiglockhart Hills Conservation Area derives from its significant cluster of Victorian institutions within a very high quality landscape and topographic setting. The Craighouse complex has a strong unity of composition derived from the inter-relationship of buildings, woodlands, open spaces and views over the city. 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."
The character appraisal highlights the prominent role that the historic buildings and the landscape setting of Craighouse campus play in creating the special character and appearance of Craiglockhart Hills Conservation Area. Particular mention is made of the conformity of design, layout and materials. However, the Learning Resource Centre is a modern addition of poor aesthetic quality that does not relate to the any of the existing listed buildings on the site. It also doesn't make a positive contribution towards the character and appearance of the conservation area by reason of its design and external finishes. Whilst the building is structurally sound and discreetly located its demolition is required in order to minimise the amount of space that will be developed as part of the wider masterplan. As the landscape setting of the campus is an important feature of the conservation area it is imperative that the opportunity to reuse previously developed land is realised.
Given the limited contribution that the building makes to the character and appearance of the conservation area and its demolition is required as part of a comprehensive masterplan for the entire campus, as set out in section d) of this assessment, the proposed demolition can be supported in this instance. b) The proposed replacement building forms part of the overall development of the site which is the subject of a separate application for planning permission (12/04007/SCH3). The replacement building is referred to as Clouston Villa. The demolition of the LRC building, which has little architectural merit offers the opportunity to introduce a building of better quality to this part of the site. Whilst the replacement building will essentially cover the same footprint, it will, along with the other new build elements, by virtue of its scale and design compete with the existing listed buildings resulting in a change to how these buildings are read and understood. The proposals will alter the existing balance between the landscape and built form with the cumulative effect of existing buildings and new development becoming dominant and the high quality landscape setting being weakened. Therefore, the proposed replacement development will neither preserve nor enhance the character and appearance of the conservation area. c) Equalities and human rights
This application has been assessed in terms of equalities and human rights. No impact has been identified.
Development Management Sub-Committee – 3 September 2014 Page 4 of 9 12/04007/CON d) Other material considerations
The application site contains a collection of listed buildings that form a prominent feature within the city. Those buildings are currently vacant and given the importance of the buildings it is critical that a compatible use is found that will secure their long- term future. Residential use, as proposed, is compatible and is supported by planning policy. However, the conversion of these buildings in their own right has been found not to be economically viable and subsequently an element of new build is required to form an enabling development. Part of the proposed new build is to be located on the site of the LRC building in order to minimise the encroachment into the open landscape. Therefore, the demolition of the LRC building, which makes no positive contribution to the conservation area, is necessary in order to help safeguard the long- term future of the listed buildings. e) Representations
Material Comments
• Removing the LRC would only be to make way for unjustified and unacceptable new build and car parking; - the replacement building forms part of the concurrent application for an enabling development which will secure the long term future use of the existing category A listed buildings on the site. This development site was considered appropriate given there is already a building located here which is not of particular merit and it presents the opportunity for a better quality replacement.
• The woodland around this building is full of bats and demolition would be disruptive; - a bat survey has been undertaken as part of the concurrent full planning application and mitigation measures have been proposed to ensure minimal disruption to any roosts. The applicants will also be required to seek the appropriate SNH licence prior to any works commencing on site.
• The enabling case for the detailed application for which this application is an essential element, has not been made or submitted to the public; - details of the financial case have been made available to the public as part of the application for full planning permission.
• The developer proposes to replace the already unsightly LRC with an even more unsightly 8-storey modern building; - the quality of the proposed replacement scheme has been assessed in section 3.3 b) of this report.
General Comments • It is unclear from the application what the CON includes; - the description of the proposal clearly states that the application relates to the demolition of the LRC building.
• Cannot tell from the documents what the demolition would entail, whether trees would be removed or affected by this demolition; - the impact upon trees has been assessed in the concurrent application for planning permission.
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• It is unclear whether there is more than the demolition of the Learning Resource Centre included in this application; - the description of the proposal clearly states that the application relates to the demolition of the LRC building.
• The application is based on the case for enabling development of which there is no official record; - the enabling case is documented in the concurrent application for planning permission.
• Should be preserved in a much needed educational function; - the University use has now ceased and the planning authority has a duty to determine proposals before them.
• Do not object to the demolition of the LRC but would like reassurance that the area will not be left a building site for years while a new plan for the site is still uncertain; - a phasing plan has been provided as part of the estate management strategy and is assessed in the concurrent application for planning permission.
Conclusion
In conclusion, the proposal represents a departure from planning policy as the proposed replacement scheme on the site of the LRC building will neither enhance nor preserve the character and appearance of the Craiglockhart Hills Conservation Area. However, the existing building is of no architectural merit and its removal is required to facilitate an enabling development to help safeguard the long-term future of the A-listed buildings on the wider site. A departure is justified in this instance.
It is recommended that the Committee approves this application.
It is recommended that this application be Granted subject to the details below.
3.4 Conditions/reasons/informatives
Conditions:-
1. The application shall be notified to the Scottish Ministers prior to determination.
Reasons:-
1. In order to accord with the statutory requirements of the Town and Country Planning (Scotland) Acts.
Informatives:-
1. The development hereby permitted shall be commenced no later than the expiration of three years from the date of this consent.
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Financial impact
4.1 The financial impact has been assessed as follows:
There are no financial implications to the Council. Risk, Policy, compliance and governance impact
5.1 Provided planning applications are determined in accordance with statutory legislation, the level of risk is low. Equalities impact
6.1 The equalities impact has been assessed as follows:
The application has been assessed and has no impact in terms of equalities or human rights. Sustainability impact
7.1 The sustainability impact has been assessed as follows:
This application is not subject to the sustainability requirements of the Edinburgh Design Guidance. Consultation and engagement
8.1 Pre-Application Process
Pre-application discussions took place on this application.
8.2 Publicity summary of representations and Community Council comments
The application was advertised on 23 November 2012. There has been a total of 14 representations received. Of that total, 1 has been submitted in support of the proposals, 12 are opposed and 1 offers general comments.
The main points of objection/concern can be summarised as follows:
• Quality of the proposed replacement scheme;
• Impact upon protected species; and
• Enabling development case.
Craiglockhart Community Council raise no objections to the demolition of the LRC building.
Merchiston and Morningside Community Councils have not offered any comments on the proposed demolition of the LRC building.
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Background reading / external references
• To view details of the application go to • Planning and Building Standards online services David R. Leslie Statutory Development The application site is identified within the Edinburgh Plan Provision City Local Plan as being part of a wider area of open space. The site is also identified as part of an Area of Great Landscape Value and being within the Craiglockhart Hills Conservation Area. Part of the site is within a Local Nature Reserve and part is within a Local Nature Conservation Site.
Date registered 12 November 2012
Drawing numbers/Scheme 01-11,
Scheme 1
Acting Head of Planning and Building Standards
Contact: Emma Wilson, Planner E-mail:[email protected] Tel:0131 529 3634 Links - Policies
Relevant Policies:
Relevant policies of the Edinburgh City Local Plan.
Policy Env 5 (Conservation Areas – Demolition of Buildings) sets outs criteria for assessing proposals involving demolition of buildings in conservation areas.
Other Relevant policy guidance
The Craiglockhart Hills Conservation Area Character Appraisal emphasises the outstanding quality of the natural topography and its visual relationship with the city, the high quality buildings set within a mixture of wooded and open slopes, the use of natural stone and slate as the traditional building materials.
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Appendix 1
Application for Conservation Area Consent 12/04007/CON At Napier University Craighouse Campus, Craighouse Road, Edinburgh Demolition of Learning Resource Centre (LRC) Building.
Consultations
No consultations undertaken.
Location Plan
© Crown Copyright and database right 2014. All rights reserved. Ordnance Survey License number 100023420 END
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