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18th October 2007      

Dear Mr. Nicholson

The Canongate Community Forum welcomes an opportunity to make further comment on the following applications;

07/01241/FUL, 07/01288/FUL, 07/01237/FUL, 07/01287/FUL, 07/1235/FUL, 07/01289/LBC,
On the basis that amended plans have been submitted.
However as additional information has been submitted by the applicant, which is intended to provide justification for the proposed demolition of listed and unlisted buildings in the Old Town Conservation Area, we believe there should be an opportunity to make further comment on all the current Caltongate applications.

THE CASE FOR DEMOLITION
The case for demolition has not been adequately made and the argument put forward is based purely on achieving the highest economic return for the applicant. No detailed consideration has been given to the social and environmental value of existing and approved uses for the listed and unlisted buildings or the economic viability of retention of the publicly owned buildings which provides revenue to the council and opportunities for sustainable community development.
The only justification for the demolitions would appear to be delivery of the masterplan (which has been subject to widespread criticism from inception to approval by the previous administration) It must be noted that the masterplan was produced by the developer without adhering to the National Standards for Community Engagement and is only supplementary guidance. It does not take precedent over national and development plan policies, and it’s inclusion in the finalised Local Plan has generated substantial objections.
In addition the masterplan does not presume the demolition of the listed buildings is acceptable but requires it to be the subject of further detailed consideration.

THE HOTEL
The applicant states that the location and layout proposed is the only option acceptable to the client for the Hotel, this is not true. The client for the proposed hotel, Accor, have indicated their preferred option as being different to that selected and that the layout design submitted is seen as a compromise. (Response to Consultation Case for Demolition submitted 9th August)They also highlight concerns based on problems encountered at their Edinburgh Novotel where they had to close a pend due to problems with people loitering and urinating there.
If this justification prohibits a pend access to the public square from Canongate, it should also prohibit the steps and link bridge on New Street.
The amendments to the hotel do little to address the objections and concerns previously submitted and will result in increased overlooking and overshadowing of neighbouring residential properties.

THE AMMENDED PLANS
The amended plans do not seek to address the overwhelming number of objections from residents, local businesses, and community and heritage groups over the unnecessary demolition of listed buildings and tenement flats.
Whilst the amended plans indicate an attempt to reduce the impact of the proposed bulky new buildings through various amendments to the roofline, fenestration and finishings the overall size, massing and layout of the proposed buildings still fail to achieve an acceptable standard of design for this sensitive location in the heart of the World Heritage Site.
The amended proposals for the Jeffrey St. arches and realignment of Cranston St will result in the loss of panoramic historic views and have a significant negative impact on the listed buildings, the Conservation Area, and the integrity of the World Heritage Site.
The fine urban grain required cannot be achieved through minor amendments to the proposals but requires serious consideration to be given to developing a series of smaller building blocks interconnected with a variety of public routes and spaces.
The plans are therefore still considered to be contrary to Local Plan and Structure Plan policies as detailed in our original objection and should be refused.
The plans are still considered contrary to the Memorandum of Guidance, national planning policies, the EWHT Management Plan.

AFFORDABLE HOUSING, BUISINESS/WORKSHOPS, AND COMMUNITY FACILITIES.
The amended plans show an increase in 3bed flats at the expense of some smaller flats which is to be encouraged, as is the minor increase in useable green space. However, the location and layout of these flats, specifically designed as penthouse/luxury accommodation with private parking and roof gardens, will be financially out of reach for the majority of families and likely to attract part time holiday/student lets for absent landlords and property investors.
This will not contribute to building a safe and cohesive community within the historic city centre, assist in the current housing crisis in this city, or enhance the character of this unique area of the World Heritage Site.
CCF believes that the 25% policy requirement for affordable housing should be achieved on every housing proposal within the masterplan area. Whilst the principle of housing without parking has been accepted for sites on Calton Road, due to the close proximity of public transport, this has not been applied to the proposals on the bus depot site.
The need to retain publicly owned workshop/small business space in the city has been identified by the council in the report to Planning Committee on Small Business Premises Design and Supply in August 2006. This report highlighted the desire to maximise the potential of the Councils own stock and to ensure no net loss of workspace occurred.
The demolition of the bus depot resulted in the loss of workspace for around 50 artisans, as well as storage space and parking for many local traders and businesses, and the loss of a vibrant weekly market. The potential to maximise the use of public land and buildings on East Market St to provide alternative accommodation for those displaced, create a vibrant mix of complementary uses, and ensure opportunities for small scale and artisan businesses are retained in the area has not been considered either during the preparation of the masterplan or in the detailed planning.
Whilst some units have been proposed for use as small business units and community facilities no source of funding or identified service for the operating of any community facility has been proposed. No mechanism is proposed to ensure the affordability of business space can be secured in perpetuity.
The provision of publicly accessible green spaces, car free family housing, improved pedestrian access across the Waverley Valley, to the St James area and to Calton Hill are essential to achieve connectivity and long term community benefits. The proposals are still devoid of these key elements.

Yours Sincerely

Sally Richardson
Secretary (CCF)