Objection Letter to Craighouse Plans from Alison Johnstone MSP

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Letter from Alison Johnstone MSP

We have been collecting objections and statements from our politicians and will be putting them onto the politicans part of the website in due course. Click here to see Politicians’ Statements Part 1 and we will be posting Politicians’ Statements Part 2 in due course.In the meantime, this letter from MSP Alison Johnstone was so good, we decided to post it up on the front page in full. (Note: this letter mentions that extra information should be submitted without prejudice to her objections contained in this letter. To read our analysis of the extra information that was put in to planning in March go here. The financial case has still not been made.)

Letter from Alison Johnstone MSP

I would like to register my strong objection to application 12/04007/FUL for the development at Craighouse.

My objection is to the principle of the new buildings and resulting loss of natural environment and open space, and these are based on the arguments below I believe to be material considerations. I do not object to the change of use and refurbishment of the existing buildings.

Proposals are contrary to the Edinburgh Local Plan adopted recently in 2010. The site is not designated for housing. Rather the site is designated in the Local Plan variously as a ‘Designated Conservation Area’; ‘Area of Great Landscape Value’; ‘Local Nature Conservation Site’; ‘Local Nature Reserve’ and ‘Open Space’. The proposals do not accord with the aims of these designations or the policies attached to the designations.

The proposals are also contrary to many of the Local Plan policies as set out below.

Policy Des 1 – Design Quality and Context The proposed new-build housing will significantly damage the character and appearance of the area. The area is currently open space and of special importance as a result of its Grade A listed buildings, landscape value recognised through designation and nature value recognised through designation. New build proposals would significantly damage all of these.
Policy Env 3 – Listed Buildings – Setting New build proposals will be detrimental to the appearance and character of the listed buildings’ setting as they will introduce new structures of a different character on what is currently open space surrounding the listed buildings.
Policy Env 6 – Conservation Areas – Development Proposals for new build does not preserve or enhance the special character and appearance of the conservation area which is described as Victorian buildings against dramatic landscape backdrops in the Craiglockhart conservation character appraisal. The proposed new buildings are not consistent with this conservation area character appraisal.
Policy Env 11 – Landscape Quality The proposals will damage and detract from the overall character and appearance of the area designated as an ‘Area of Great Landscape Value’ because the current designation is based on the open space and natural character of the area where development is proposed. The area is also a prominent topographical feature and changes to development will be highly visible.  The expansive new build footprint will have a devastating impact on the quality of the landscape.
Policy Env 15 – Sites of Local Importance The reasons for allowing the development of new build housing do not outweigh the nature conservation interest of the site. The developer argues that new build housing is required to finance the renovation of existing structures however these proposals are designed to maximise profits for the developer and not to improve the area or raise necessary finance.Mitigation of the loss of public amenity and loss of open space are not mitigated or minimised. The ‘public park’ created in the plans are placed on open space already use as a public park amenity. This is a reduction in the amenity and a represents a loss of flora, fauna and landscape features of this important doubly-designated ‘Local Nature Reserve’ and ‘Local Nature Conservation Site’.
Policy Env 17 – Flood Protection Car park development with provision for over 300 car parking spaces and new buildings will result in an increased flood-risk on Balcarres Street.
Policy Os 1 – Open Space Protection New build proposals will significantly impact upon the character of the local environment through the loss of a significant proportion of the available open space in a nature reserve. The new build development will not improve the existing provision of public amenity; the proposals include a park surrounded by housing for an area that is already a much larger park and public amenity.
Policy Os 3 – Open Space in New Development These proposals will not deliver new publicly accessible and useable open space. They propose a small park in an area that is already a park.
Policy Hou 7 – Affordable Housing The proposals are for much more than 20 housing units but no affordable housing is proposed onsite.

This proposal is contrary to the proposed strategic development SESplan policy 7.

The new build proposals in 12/04007/FUL are for housing outwith the identified Strategic Development Areas. The land is not zoned for housing in the local plan and the proposed development is large scale and not in keeping with the character of the local area which is identified as Victorian buildings against dramatic landscape backdrops in the Craiglockhart conservation character appraisal.

The proposals will also result in the following significant impacts and material considerations:

  • A loss of open space contrary to the Council’s aim to protect and develop Edinburgh’s open space.
  • A loss of public amenity – the proposed park is sited on an existing larger park; extra traffic and new roads will degrade the amenity.
  • Significant traffic impact and congestion of local roads
  • Significant new demand on local schools and other public services
  • The removal of a significant number of trees from a site designated as a ‘Designated Conservation Area’; ‘Area of Great Landscape Value’; ‘Local Nature Conservation Site’ and ‘Local Nature Reserve’.
  • Significant negative impacts on the biodiversity of the ‘Local Nature Conservation Site’ and ‘Local Nature Reserve’.
  • Significant changes to the skyline and views.

I am concerned that the information available to the public, planners and Councillors was not adequate. The Council itself considered the accompanying environmental impact assessment to be “not competent” and concluded there were serious inaccuracies, incomplete drawings and images not representative of the development. The proposals do not contain a financial appraisal and the developer has not made the case for the necessity of the new build housing. Planning officials have considered the ‘enabling development’ case to be “weak at best and wholly lacking in other areas” and have noted the complete absence of a financial appraisal. This development cannot be determined without this important information.

Without prejudice to my objections, the developer must be required to come back with full, accurate and factually correct information to allow a fair decision to be made.

This is an important historic Edinburgh site of city-wide significance. The open green space and woodlands of Craighouse have been used by the local and wider Edinburgh community for generations and it is essential to preserve public amenity and ensure that current levels of access are maintained, not eroded. The quite excessive amount of new-build being proposed would result in a massive increase in residential traffic for the area. We must hold onto green sites such as this which really make our neighbourhoods special.

Yours faithfully

Alison Johnstone MSP

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