The Fettes Row & Royal Crescent and The Drummond Civic Associations (FRRCA and DCA)
The proposals
This application, given the code 20/03034/FUL on the City of Edinburgh Council Planning Portal, is for redevelopment of a site formerly owned by the Royal Bank of Scotland on Dundas Street and Fettes Row. This is a sensitive site, it is:
The application is to demolish the former RBS office buildings on the site, which the developer claims cannot be repurposed. Having demolished offices they want to build........ another office! Also seven residential blocks totalling around 350 flats and - currently still - a hotel, alongside other uses.
Firstly just to say we agree that it is important to see this site brought back into use. It is close to the city centre and benefits from the character of the surrounding conservation area and important park adjacent. It is a brownfield site and if the buildings really can't be repurposed, perhaps development is the best approach. Housing is needed and could be provided on this site, especially genuine social housing, and especially with a developer contribution to education, given primary schools are stretched. So we don’t object to the principle of development on this site. However we strongly object to the current planning application.
What is proposed is grossly insensitive, being:
Furthemore it will:
These are not just our opinions, Historic Environment Scotland and the Edinburgh Urban Design Panel out forward many of these points.
20/03034/FUL will go to a hearing of the Development Management Subcommittee on 17th February 2021 when a few objectors, including the New Town and Broughton Community Council will have a few minutes each to underline our key points. We hope that the planning officer will have time, given their other commitments to properly assess this application against the Local Development Plan. In doing so the conclusion can only be that the proposals are NOT of an appropriate scale, form, and design and must be refused.
The application includes hundreds of documents totalling thousands of pages. One could be forgiven for missing important details or finding it hard to see beyond the gloss. If that wasn't enough it turns out the plans for the site are more complicated than just 20/03034/FUL. There is a seven-year old Planning Permission in Principle that RBS started for a part of the site. This has been pursued by the Developer and was recently granted. A new Prior Application process was started to revise "Plot 1" on Dundas St that is currently proposed to include a hotel, but this has not yet been turned into an application and will not be considered at this time.
The main grounds for refusal are:
In layman's terms it boils down to "too built-up".
This rather long section is provided for those who have an interest in heritage and balancing the need for housing with protecting heritage for future generations. There is clearly potential for sensitive development on this site and FRRCA and DCA would welcome this. What is also clear is that Historic Enviornment Scotland's view, whilst not objecting, is that what is proposed currently is not sensitive development.
To give some context, Historic Evironment Scotland (HES) objected to on a planning application brought forward by a previous appilcant. In this they stress the importance of the open ground to the North of Royal Crescent to protecting our Heritage. Their clear advice at that time is not to build above the level of the road on Royal Crescent. They objecteds to 2 storeys above the road level in the open bowl to the North of Royal Crescent.
The developer bought the site knowing that this was HES's view. They then benefited from seven tax-payer funded advice notes from HES before they made their application. Each of these advice notes was addressed to the Planning Officer and copied to the developer by HES. We have extracted quotes from these in this section.
In case you are short of time the key things to note are that HES:
1. Disagreed from the outset with the developer's assessment of the heritage value of the site, and their attempts to reduce or belittle certain aspects of it. This disagreement is still reflected in their comment on the application bought forward 20/03034/FUL.
2. Disagreed from the outset with 6 storey blocks immediately to the south of the Park on the grounds they would block the view of Royal Crescent from the park and ignored site topography. Yet 20/03034/FUL still brings forward 6 storey blocks.
3. Repeated advice given previously on more than one occassion.
4. Concluded that "the proposed development would give rise to "adverse effects on the OUV of the Old and New Towns of Edinburgh World Heritage Site (WHS) and the setting of the Category A listed Royal Crescent" "We have therefore recommended changes to the design of the development which we consider would reduce and avoid the impacts described." These actions included:
“...we disagree with the assertions that the urban form of Fettes Row and Royal Crescent is entirely determined by an accident of land ownership and quality and that Royal Crescent was not intended to be experienced from the north.”
“The setting of the crescent remains as originally intended, a grand set-piece ensemble on an elevated position at the northern edge of the New Town, specifically designed to take advantage of panoramic views northwards, over undeveloped (or underdeveloped) ground.”
“In 1823 Robert Brown’s feuing of James Eyre’s estate ... notes a view of ‘Royal Crescent in front’ as well as outlining its uninterrupted views over the ‘Canonmills Meadow’. This underdeveloped ground...is therefore an important part of the Crescent’s setting.”
“On the northern part of the site the six-storey blocks would constrain much of any views to the crescent from the north… reducing the height of the crescent blocks…would… better respond to and protect the WHS topography and townscape value…. Development in this part of the site provides an opportunity to enhance the crescent’s character and setting, that of a grand set-piece ensemble on an elevated position at the northern edge of the New Town……the scale, massing and footprint of proposals for this part of the site requires further consideration to enable, alternative less detrimental options to be explored.”
HES wrote a further six pre-application advice notes. Should any interpretation of the final comments by HES be required, these advice notes are quite instructive.
“We consider that the cumulative impact of introducing 3 levels of accommodation above a 4 metre high deck alongside a broad, stepped pedestrian continuation of Dundonald Street, would result in the loss of Royal Crescent’s elevated setting above a retaining wall looking over underdeveloped ground to the north.”
“As a minimum, we recommend that the upper level of accommodation occurring on the southernmost crescent shaped blocks is removed. ...... While the removal of this level of accommodation would reduce impacts to an acceptable level, our clear preference would be for the consideration of alternative options for the footprint and massing of development in this area.”
“As made clear in previous letters, we consider that any development in this location must safeguard important framed views out of the World Heritage Site. These changes would in our view have a detrimental impact on the outstanding universal value of the World Heritage Site. The elevated, open character of Royal Crescent and its setting would be significantly diminished by the additional development to the south crescent. The latest revision would see a significant increase in the footprint of the 3-storey high south crescent blocks. The additional development, rising almost one floor above the Crescent’s street level would have a significant impact on Royal Crescent’s open character and setting."
"Our clear preference would therefore be for an additional reduction in the volume of development immediately adjacent to the Category A listed buildings along Royal Crescent and appearing within outward views along Dublin Street/Drummond Place/Dundonald Street.
"We also recommend that consideration is given to reducing the volume of additional development proposed for the northernmost crescent-shaped blocks."
"(In a previous letter, dated 28/11/19) we indicated where a reduced volume of development would lessen impacts on the setting of the Old and New Towns of Edinburgh World Heritage Site (WHS) and Category A listed buildings on Royal Crescent to an acceptable level. It should be noted that we did not issue our ‘support’ for this volume of development, and that our clear preference would be for the consideration of alternative options for the footprint and massing of development in this
area."
The full application 20/03034/FUL is then finalised in September 2020. Whilst HES's comment on 20/03034/FUL is not a formal objection, it includes many criticisms and several mitigating actions to reduce harm to the Oustanding Universal Value of the World Heritage Site. It is important for anyone reading this to be aware of the context of the pre-application meetings and to realise that, whilst not finally objecting, the representation made is hardly a letter of support. Not objecting simply means that the negative impact on the OUV of the WHS was not considered serious enough to be of National Significance. HES assured us that the points raised should treated as material considerations by City of Edinburgh Council in determining the application.
"Our decision not to object should not be taken as our support for the proposals."
"Royal Crescent with its arrangement of Dundonald Street leading to Drummond Place, Fettes Row to the west, and Bellevue Crescent to the east are integral urban components of the unified town planning of the first extension to the New Town. The characteristic use of topography, and monumental massing, comes masterfully together to form the very distinctive, and highly visible landmark to the northern new town."
"We disagree with some of the baseline analysis included within Chapter 12 of the EIA Report and the associated Heritage and Townscape Statement (August 2020). In particular, we consider that outward views from the New Town to the north, particularly those from Royal Crescent, are undervalued" and "we disagree with the assertion at paragraph 4.50 of the Heritage and Townscape Statement that any views experienced of Royal Crescent from the north were ‘unintentional’.
They point out that tree cover does make up for insensitive adn inappropriate design:
"We note that the design mitigation incorporated into the proposals includes maintaining the seasonal screening effect provided by the existing mature tree-lined northern edge of Royal Crescent and Fettes Row. It should be noted, however, that we disagree that tree cover is a relevant mitigating factor."
About Fettes Row they say:
"This proposed tall set-back roof storey would increase the overall height of the Fettes Row buildings, rising above the level of the B listed terrace opposite, where historically shallow M-shaped roofs were specifically designed to limit any visibility above the cornice and blocking course. Additionally, we consider that the different architectural expression and character of these two blocks mean they fail to respond to the continuous, uniform planned character of this part of the New Town."
Of the buildings proposed for the underdeveloped land (current car park) they say:
"We consider that the introduction of large residential accommodation blocks in this area will adversely impact on the setting and OUV of the World Heritage Site."
"The "southernmost accommodation blocks which rise to just below one storey above the Crescent’s datum (pavement) level will have a negative impact on its setting and visual prominence. We also consider that the six storey northernmost accommodation blocks will adversely affect longer views to and from Royal Crescent located along the World Heritage Site edge."
The only thing they note of benefit is the "central axial route through the site between the proposed crescent blocks", which means that there would no longer be a low-lying shed in the way of your view up Dundonald St from the Park, should you be inclined to try to view Dundonald St from this position at present. The impact of the views North from Dundonald St of said existing shed is currently minimal. The benefit of said new central axial route cannot be considered to be great, especially in comparison to the obliteration of views of Royal Crescent from elsewhere in the Park and on Eyre Place.
"extending the width of the central gap between (the two blocks of flats immediately to south of the Park) and reducing their height. Additionally, we recommend that the scale of (the three blocks nearest to Royal Crescent) is reduced and the level of development above pavement level immediately adjacent to Royal Crescent is removed."
"recommend that (the office and flats to the North of Fettes Row) are re-designed as a continuous, architecturally unified development to better reflect the scale and form of the B listed terrace opposite. Additionally, care should be taken to limit the visibility of the upper storey, this should be done either by reducing the height of the upper storey or by ensuring it is set-back further and incorporated within a defined roofscape with appropriate recessive materials. This would also apply to its associated elements e.g. glazed balustrades which can be particularly visible."
"the proposed development would give rise to some adverse effects on the OUV of the Old and New Towns of Edinburgh World Heritage Site (WHS) and the setting of the Category A listed Royal Crescent" "We have therefore recommended changes to the design of the development which we consider would reduce and avoid the impacts described."
There are many issues but the developer's plan for King George V Park is probably the one that will have the most significant negative effect on the community.
It is bad enough that they propose to flank two of its boundaries with 6-storey buildings in a conservation area where 3-4 storeys is typical.
Do you use this park as a local, or visit from further afield, as we know many do given its historic nature? If so, stop for a minute and think what that is going to be like. Where now you see trees and Royal Crescent rising above the tree-line, if these proposals are granted you’ll have 6-storey buildings blocking both your view of our heritage and the sun.
The Edinburgh Urban Design Panel said of the plans at an earlier stage “A built edge to the park may be an appropriate response. However, the Panel considered the proposal to be overdevelopment and too dominant on this edge. It was also noted that these blocks were borrowing most of their amenity from the park due to their siting, height and mass.” Following this meeting, were the designs changed to move the buildings further away, make them significantly lower, or less massive? NO!
The developer has also set out their stall for what they want in the park itself. A small part of that- a new entrance into the park- is the subject of a related planning application, which have the chance at a proper hearing at least. Although how much airtime it can be given whilst the main application is on the table is debatable. However, the “design and access statements” submitted by the developer in December give a lot of detail about what the developer thinks should happen in the Park, these do not reflect the views of locals including Friends of King George V and Scotland Yard Parks, (link to their website to see comments).
The current applications must be refused and the developer sent back to the drawing board to come up with proposals that protect and improve the character of the area. Specifically this will mean that buildings on the south and west boundaries of the Park must be much lower and further away from the park.
In 2016 Historic Environment Scotland said of Royal Crescent
"The setting of the crescent remains as originally intended, a grand set-piece ensemble on an elevated position at the northern edge of the New Town, specifically designed to take advantage of panoramic views northwards, over undeveloped (or underdeveloped) ground."
They went on to say:
"This underdeveloped ground is therefore an important part of the Crescent’s setting. Although there would be scope for some development of the open bowl ….. rising 2 storeys above the datum level of the Crescent, would, in our view have considerable impact on the Crescent’s setting, reducing its visual prominence on the site”
That Royal Crescent is still "prominent in its setting" and enjoys an open outlook to this day, 200 years on from its design, is nothing short of amazing in a city. On the other hand perhaps it shouldn't be so amazing for a street in a World Heritage Site. Whilst the land opposite is not in the WHS it should be protected by Unesco Policies such as the Historic Urban Landscape. Of course, 20 years before Unesco's inscription of the Old and New Towns of Edinburgh, part of King George V Memorial Field that lay immediately to the North of Royal Crescent had already been sold and was turned into the current car park on the RBS site. It is sad to think that, when opened in 1950, King George V Memorial Field was considered to be "the City's finest playground". The 1970s is not known for its great planning decisions. Nonetheless, even in those bad old days, the planning decisions led to the open aspect of Royal Crescent being retained.
The developer bought the site knowing HES's views about the importance of views to and from Royal Crescent. Yet, they have still brought forward proposals that HES stated in their comment on the current application will negatively affect the Outstanding Universal Value of the World Heritage site. HES have put forward proposals to mitigate the negative impacts, which are “material” to the decision and the Development Management Subcommittee must properly consider them.
This means sending the developer back to the drawing board to redesign their proposals for this aspect of the site to be lower and less massive. Taken with the requirements for redesign of the boundary with the park, the buildings on the current car park should also be further from the Park, which means closer to Royal Crescent, and therefore the original view of HES about not building above the road level of Royal Crescent on the current car park becomes even more important.
Consenting to these planning applications would mean consenting to the felling of dozens of mature trees. It would mean threatening the roots of others and pruning of still more. All to suit the proposed footprintof the buildings and the formation of hard landscaping in the Southwest corner King George V Park for a new entrance.
The mature trees on the boundaries of the site, especially Dundas Street, Fettes Row, and King George V Park, could and should have been treated as a design constraint. Asides from arguments about how many saplings or "standard" trees it takes to "replace" a mature tree, these trees are an important part of what makes the current place successful. They are good for wellbeing. Those that are viable should be retained and any that may have been neglected should be replanted in the same place.
The trees are in immediate danger. Tree works in a Conservation Area (TCO) notices were lodged by the developer in January. Unless the Council Issues Tree Preservation Orders for the street trees on the edge of the developer's land on Dundas St, Fettes Row, Royal Crescent and the boundary at the Park entrance from Scotland St, these trees could be lost forever regardless of the outcome of the current planning application. The planning application states an intention for replacement trees, the TCOs do not specify any such replacements.
The nearly 30 trees on Dundas St must be retained. They are over 40 years old and cannot be “replaced” elsewhere on the site. They provide important pollution reduction on a busy north/south route. They provide a clear delineation between the World Heritage Site and the rest of the conservation area, allowing those approaching from the North to appreciate the pavilion buildings on the ends of Fettes Row East and West. They are loved by locals for providing at least partial screening of buildings and just for being beautiful trees. They provide habitat to insects and small animals.
One of the TCOs claims that the trees on Fettes Row are “dangerous”. The planning application 20/03034/FUL does not state the position or dimension of buildings in plan view and we understand that the Council officer’s approach would be to scale from drawings. The developer was kind enough to give one of us information that shows the buildings proposed for Fettes Row are in fact 6 meters closer to the tree canopies than the current building. It is therefore the proposed buildings that are dangerous to the trees, not the other way round.
Lastly, we have a forestry plan for the Park drawn up by the Council that proposes to remove 25 trees on the southern and western boundaries of the park and replace only one. This is linked to a potential Section 75 agreement. The proposed building lines are clearly a constraint on trees here. Trees right up against the on the northern side of 6 storey buildings are not gong to flourish. The buildings should be moved further away from the boundaries to protect the trees in the Park. It is also vital that, in the unconscionable event that the application is granted as it is, Council officers do not consent to the felling of trees in this park until the relevant legal agreements are in place.
We know that the existing office building on Fettes Row- the former RBS data centre- is liked by some and not by others. It does at least provide a continuous building line along the whole length of Fettes Row, set back behind mature trees, and lower than the buildings opposite. It has gained patina over the years and is now relatively unobtrusive.
The proposed replacements- two buildings- an office and a block of flats are anything but an improvement. Aside from being too close to the mature trees, they are too tall, the eaves height of the top occupied floor being nearly 4 metres taller than than the existing buildings. In fact they are really taller still, since a roof terrace on top of the office effectively adds a further occupied space, with planting and a further partial storey. Ignoring the roof terrace, the eaves height of the new office would be 3 meters taller than the eaves height of the Georgian Terrace opposite.
The new buildings also fail to respond appropriately to Fettes Row by introducing a break in the building line because, instead of a continuous office building, there would now be an office and a separate block of flats. The impact on Fettes Row in the World Heritage Site, and the setting of the Grade A listed buildings at 23 Royal Crescent, would be very negative. It should be remembered that the setting of 23 Royal Crescent includes both the East end of Fettes Row and not just Royal Crescent. HES did include mitigating actions in their comment on the planning appliction, which was to reduce height on Fettes Row. The Edinburgh Urban Design Panel criticised an earlier version of the design for height but also for "turning its back" on Fettes Row, since what will front onto Fettes Row is actually the back of the buildings. Have the plans been changed in response? Of course not.
We hope that those determining this application will have taken the time to visit the site and appreciate the true impact on the heritage they are required to protect that this proposal represents.
The application is made by Izar V Lux, a £1.5 Billion investment fund based in Luxembourg. The investment is arranged by Orion Capital Partners. The face of the application are Ediston and their agents Turley. Turley were the agents on the Virgin Hotel development in the Old Town.
As to whether there is scope to influence plans we’ve tried but to no avail. We’ve lost count of the informal meetings we had pre-application. We, along with many of our neighbours, participated fully in the three formal pre-application consultations. The developers also met with Historic Environment Scotland 7 times pre-application and each time referred them back to previous guidance they had given that had not been taken on board. The developers presented their early proposals to the Edinburgh Urban Development Panel who criticised it on the grounds of excessive height, mass and scale. You guessed it, proposals were not subsequently revised to be lower, less massive nor less dense. A post application review with the Council officer yielded an incredibly small concession to Fettes Row in a revised application in December.
Our conclusion, the Development Management Subcommittee must refuse this application and send the applicant back to the drawing board with some clear parameters for what is acceptable.
If they do not then there is the further risk that the developer will not just take the consent but will then come back with further amendments that make their plans even worse.
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