Here is the Old Town Community Councils objection to the 2nd proposal for the breakthrough on the Canongate.  (The demolition of the Macrae tenements)

RESPONSE TO PLANNING APPLICATION 07/04400/FUL The Old Town Community Council welcomes the opportunity to comment on this planning application.Whilst the design of the proposed breakthrough on the Canongate by use of a pend is a significant step forward in the design and would help to retain a sense of containment on the Canongate it would appear from the detailed plans that the existing tenement flats will still be demolished.

As stated in previous responses to the Mountgrange proposals the OTCC strongly object to the unnecessary demolition of these sound residential buildings within the conservation area as this conflicts with the World Heritage Management Plan, NPPG18, Edinburgh & Lothian’s Structure Plan Policies ENV1C and ENV1D and Conservation Policies within the Central Area Local Plan.

Historic Scotland’s Memorandum of Guidance clearly states (paras 4.26 - 4.32) that development which affects unlisted buildings within Conservation Areas should aim to retain and restore or sympathetically convert to a sympathetic use before demolition is seriously investigated. The proposed development seeks consent for the demolition of all but the upper area of the existing front wall. All of the existing flats, roof structure and entire ground floor are to be demolished. The rear elevation, layout, and roof structure of the replacement tenements bears no reference to the original building. The part retention of a façade goes no way to retaining the integrity of the existing building which forms part of the narrative of the ‘conservative surgery’ approach to planning and architecture which Edinburgh is famous for. It is interesting that the proposed use remains the same with the only difference being the size and ownership - 7 one bed flats in mixed private and public ownership replaced with 2 x 2bed flats and part of a 3bed penthouse in private ownership.The proposed pended access is unsuitably high and would require, at the very least, the removal of residential accommodation at first floor level. Whilst additional accommodation is proposed within the roof, the design and proportion of the proposed dormers is alien to the building and the adjacent listed buildings

The OTCC remain opposed to the creation of a stepped access and new pend on New Street as this reduces public access and permeability of the site and conflicts with Local Plan Policy T10. The proposed public realm works on New Street will significantly reduce both visual and residential amenity as well as public safety on New Street. Existing roads and rights of way are in public ownership and form part of the Common Good. There have been a significant number of objections from the local community to the proposed change of ownership and management of these public assets and the proposed changes in accessibility of these public roads which will require further consultation under Roads legislation. The proposed development makes no provision for publicly accessible green spaces or play facilities to serve existing and proposed residents in the locality despite there being an identified lack of such facilities in the immediate area.

The OTCC strongly objects to the lack of affordable housing proposed in this application as it conflict with both National and Local Policies which require a minimum 25% within every residential development.

The applicant has stated that it is not intended to provide any affordable housing directly with this proposed development yet adopted policies clearly state the provision of affordable housing off-site is only acceptable where small developments are proposed on constrained sites.The proposed housing development on Calton Road (ref. 07/00560/FUL) and that which is the subject of this application are self contained sites each of which are capable of being developed independently and each of which are large enough to comply with the affordable housing policy requirements.  This proposal includes a significant level of housing (161 units) and includes the development of ground source heating and cooling which is to be subsidised with public funds (a grant from the DTI).

 The provision of private parking for all the residential units proposed conflicts with the Council’s aims to reduce the need to travel by car and encourage the use of walking, cycling and public transport (as set out in the Structure Plan).Given the Planning Committee’s acceptance of no provision of residential parking to serve the development (ref. 07/00560/FUL) at Calton Road due its’ location close to public transport links a similar approach should be taken here. Any parking provided within the podium should be for general use and subject to standard parking fees. This would assist in providing public parking to replace that lost from the demolition of the former bus depot and the development of the new Council HQ.

The design, bulk, height, layout and roofline of the 2 proposed residential blocks is out of character with fine grain of the Old Town Conservation Area.Whist the proposed blocks include pended access routes through the design does not promote permeability and public access. Community safety issues are likely to arise from the proposed pends which could only be resolved by forming gated access. This would conflict with the masterplan’s principle to improve permeability of the site.By breaking up the 2 residential blocks improved access, permeability and community safety could be achieved within a more sympathetic layout and design. This would also allow an opportunity to manage blocks for a variety of tenure (private or public) creating a mix of sizes and tenancies throughout the development.

The proposed New Public Square is of a design which will create an inhospitable environment which suffers from a sterile design and a lack of civic character.The size and orientation of the square, in combination with the height of the adjacent buildings proposed, will result in it being almost permanently in shadow and subject to an increased chill factor from prevailing winds through the Waverley Valley.The square is to be privately owned and managed by the developer and has no civic uses bounding it. This approach is well documented as not being successful in achieving vibrant public sense of place. Although the inclusion of public seating, trees and public art (in addition to the proposed cafes and shops fronting the square) would usually assist in creating an attractive and vibrant open space the size, lack of sunlight and open nature of the square demonstrates a complete lack of understanding of the local climate and how to design within it.It is most likely that the ‘public’ square will become little more than a windswept gap within the development which is used as an extension to the hotel and/or office block for occasional corporate and private events.

The OTCC strongly oppose consideration of any of the Mountgrange applications in isolation and respectfully request that all the applications are considered together.The demolition of the McRae tenements must be considered in tandem with all proposals for redevelopment to prevent the creation of any new gap sites. The applicant has clearly stated that Caltongate is an all or nothing development and as such individual elements cannot be considered in isolation. The justification presented in the supporting documents for the demolition of listed and unlisted buildings claims to be the wider economic benefits of the Caltongate Development Project. The development appraisal on which these benefits are based has not been revealed to the public or statutory consultees and cannot therefore be assessed, however it is widely recognised that a development of this size should be adaptable to changing market forces and local needs if it is to have a successful future. Finally, serious concerns have been raised by local residents regarding the financial involvement of CEC with Mountgrange resulting from the proposed sale of publicly owned buildings, homes, streets and Common Good Land which does not appear to have been conducted in accordance with ‘best value’ . It is therefore considered appropriate for any decision to be referred to Scottish Ministers for final approval as CEC cannot remain truly impartial in determining this application.