LHNCC has submitted the following reasoned argument against this proposed development. The main argument is
We are objecting to the proposal because it represents inappropriate and gross overdevelopment of a small site, and would adversely impact Rennie’s Isle and the wider Leith Waterfront and Conservation Area
7 Exchange Crescent
C/O Union Property Services Ltd
Silver Fox Way
Newcastle Upon Tyne
Dear Mr. Evans
REFERENCE NUMBER: 21/00877/PAN: Redevelopment of existing office for residential flatted accommodation including affordable housing and ancillary uses. at 1 Rennie’s Isle, Edinburgh EH6 6QT Decision Notice – Proposal of Application Notice: APPROVES the proposed consultation, Date:12 March 2021
I am submitting consultation feedback response and supplementary information relating to the above application on behalf of Leith Harbour and Newhaven Community Council (LHNCC) who object strongly to proposed plan as it stands The application has been reviewed by our Planning Sub-Group following presentation from Agent at CC meeting held on 27 March 2021 .
The response to review and our completed feedback survey below is supported by our members. This response also reflects the views from members of the public who attended the digital presentation and provided recorded chats, comments and questions that were recorded in the LHNCC meeting minutes that were forwarded to the Agent who acknowledged receipt.
Critically we are using this consultation to show everyone – the developers, the planners and councillors that
- there are a large number of people and organisations objecting to the proposals
- that the development, as currently proposed, appears to be contrary to planning policy and guidance
- that we know what we are talking about – we’re not just nimby locals protesting against any development adjacent to our community, but we are objecting to a proposal because it represents inappropriate and gross overdevelopment of a small site, and would adversely impact Rennie’s Isle and the wider Leith Waterfront and Conservation Area.
- Experienced planning professionals were consulted have supported the following criticism of the proposed development. This reply is not just represent nimby locals protesting against any development adjacent to our community. We are objecting to the proposal because it represents inappropriate and gross overdevelopment of a small site, and would adversely impact Rennie’s Isle and the wider Leith Waterfront and Conservation Area
Jennifer Marlborough, Secretary, LHNCC
Cc. Declan Semple, Planning Officer
David Givan, Chief Planning Officer
Cllr Chas Booth
Cllr Adam McVey
Cllr Gordon Munro
Feedback Survey, response and references
VRS Ltd. C/O Union Property Services – https://renniesisledevelopmentleith.co.uk
Online Feedback Survey – https://renniesisledevelopmentleith.co.uk/feedback/
VRS Ltd (part of Union Property Services) is proposing to redevelop the existing office building at Rennie’s Isle into a major new landmark residential development- do you consider this location is suitable?
- Strongly Agree
- Don’t know or not sure
- Strongly disagree ✔️
- This location is definitely not a suitable location for development with high density and up to 18 Floors.
- The site is too small and in a very unique position with limited space and approach for construction site. It is used for deliveries to Scottish Government building, and also exits onto
- Tram line, that is potentially dangerous for residents.
- Title deeds have Bank of Scotland as owner and there may also be conditions that need to be addressed.
- It is adjacent to Conservation area and is not at all sympathetic to surrounding environment and its heritage.
- Obscures views from The Shore and surrounding areas.
Do you like the existing building ?
- Yes ✔️
- What is purpose of this question?
- The current building has features that relate to the heritage of the area, designed to relate to its surroundings: the Rennie’s Isle development and small tower is similar in design to that of Forth Ports office and The Scottish Government cupola,
What do you think of the initial concept sketches for a new building? Please provide as much detail as possible as these comments are very helpful.
- These do not comply with planning policy ✔️
- Are seriously out of scale in terms of massing and height ✔️
- Inappropriate design and materiality for this site✔️
- No regard to the scale and character of existing Rennie’s Isle housing or adjacent Conservation area and listed buildings ✔️
- Will impact on local residents from gross overdevelopment of site ✔️
- do not comply with planning policy and local planning guidance
- pay no regard to the scale and character of the existing Rennie’s Isle development
- the proposed development the inappropriate scale and massing would dominate the present
- views and diminish the protected status of the Shore.
- would adversely impact on local residents, overshadowing the site, creating wind tunnels, and
- introducing cafes and general disturbance to an existing quiet residential development
- are detrimental to the adjacent Conservation Area and context of the listed buildings
- show a gross overdevelopment of the site.
What do you think Edinburgh should encourage or discourage new forms of development like this in these sorts of locations like other UK and European cities?
- Encourage and accommodate new forms
- Discourage new form of development ✔️
- A pointless question biased towards a response the Developer wants – a positive response. It is obvious the developer is not familiar with Leith, its history, heritage or its people.
A pointless question biased towards a response the Developer wants – a positive response. It is obvious the developer is not familiar with Leith, its history, heritage or its people.
For any new developments in this part of the City, what do you consider to e important? Tick as many as you want.
- A building of real design quality that responds to all of its surrounding context?
- Has attractive, safe and vibrant street level frontage?
- Is well used and well lit at all times day and night?
- Provides an attractive and safe pedestrian environment along its frontage?
- Has plenty of cycle storage?
- Has plenty of car parking?
- Provides a mix of accommodation for young and old, single and families as well as affordable
- provided ‘tenure blind’ (i.e. no distinction)? o Has 24 hr. security cameras/CCTV?
- Should include employment use?
- Should include coffee shop/retail
- Other (please specify) –
- All of above are also pointless leading questions
- This site is not is not suitable for a development of this scale and impact,
- All questions are desirable in this or any new build in any area of the city, however good quality development with positive creatures is a good idea on appropriate sites in Edinbutgh
- The narrow access and exit facilities for a site this size are inadequate and not appropriate, this would be particularly relevant during construction phase. Also used for deliveries and maintenance vehicles to Scottish Government building.
- All of these questions are covered and considered in the ELDP and Edinburgh Design documents referenced below.
In terms of initial design sketches, do you think there is potential for a significant new building on this site? And if so what are the key points of reference?
- No, not at all
- Yes, it’s exciting opportunity for something really positive
- Any new proposal needs to reference old Leith and new Leith
- Any new building should only reference old Leith
- Any new building should only reference new Leith regeneration
- Other (please specify) –
- Any new building needs to relate sensitively, this design is totally out of scale with existing Rennie’s Isle development and The Shore area. Reasons for this also given in reply to Q3
7. Do you think that this site is accessible?
- By foot?
- By bus?
- By cycling?
- By Tram?
- By car
- This question is too leading and not appropriate
- Accessibility requires inclusion of surrounding areas not just Rennie’s Isle.
- The proposed shared surface to the current Rennie’s Isle Road at the junction with Ocean would be unsafe – this junction is used by all vehicles accessing the 90 flats of Rennie’s Isle, and by constant large delivery vehicles and refuse collection from the Scottish Government building. It is totally inappropriate and unsafe and would not work#
- Yes by all means listed of course – it is not surrounded by quicksand!
- Do you think the type of accommodation and uses would be good for this location?
- Buy to rent is for the financial benefit of to the developer. Not appropriate for this location as nearby proposed Skyliner development is build to rent and provides more that enough of this type of development. The development is an over provision which will not enrich or develop the area.
Do you think zero parking is positive or negative for this type of development?
- Negative ✔️
- Leading question and not relevant as very little car parking shown in plans.
Do you think the design, materials, massing and height need to relate to…?
- Other new developments such as Skyliner
- Only Rennie’s Isle
- To Rennie’s Isle and Skyliner and other adjacent buildings
- Only to Old Leith and The Shore
- It needs to relate to the Dock area as well
- All of the above, in the round
- None of the above and should be judged on its own
- The sketches in presentation documents make it impossible to tick many of the boxes. These areas are also covered in the EDLP and Edinburgh Design document
Do you think the type of flexible rentable accommodation for a range of unit sizes and live work facilities will….?
- Do you think the type of flexible rentable accommodation for a range of unit sizes and live work facilities will….?
- Be good for the area
- Not good for the area
- Support local shops, bars and services
- Not be supportive
- Appeal to a wide range of residents
- Only appeal to a limited range of residents o Add something to the area
- Detract from the area
- Other (please specify) –
- At its current scale the negative impacts caused by development on the local community and local conservation area will outweigh any potential benefits.
- Build to Let is a high profit scheme enabling developers to go for high density occupation and will potentially exclude availability for some sectors of the public and attract a niche market!
- Statement from resident – ‘There’s a build-to-rent band wagon that’s careering out of control (Skyliner will also be build-to-rent, bank rolled by Legal & General).
- Enslaving people to a rental management company isn’t solving the issue of non-affordability of housing.’
Do you have any other comments at all?
- The questions are leading and biased to illicit supportive responses, overall a flawed and self-serving exercise.
- This limits ability to express how the proposed development is poorly designed, out of scale, inappropriate for this site and does not meet planning policy or local planning guidance.
- Additional comments made for each response are included to highlight and reflect residents concerns and reference legislative argument that development appears to be contrary to planning policy and guidance.
ELDP (November 2016)
Part 1 Section 2 – A Plan to Protect and Enhance the Environment
3) Creating Successful Places Place-making and Design
Edinburgh’s distinct geography and rich and varied heritage of buildings and urban design combine to create a cityscape of excellence. New development, through its design and contribution to place-making, should enhance not detract from the city’s overall character and quality of environment.
Part 2 Section 5 – Housing and Community Facilities
- To meet the requirement for additional housing in Edinburgh whilst protecting environmental quality in established housing areas
- To promote more sustainable, better balanced communities
- To ensure that provision is made for necessary community facilities
Part 2 Policies – Design Principles for New Development
150. The Council encourages innovation and well designed developments that relate sensitively to the existing quality and character of the local and wider environment, generate distinctiveness and a sense of place, and help build stronger communities
Policy Des 1 Design Quality and Context
Planning permission will be granted for development where it is demonstrated that the proposal will create or contribute towards a sense of place. Design should be based on an overall design concept that draws upon positive characteristics of the surrounding area. 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.
Policy Des 3 Development Design –
Incorporating and Enhancing Existing and Potential Features
Planning permission will be granted for development where it is demonstrated that existing characteristics and features worthy of retention on the site and in the surrounding area, have been identified, incorporated and enhanced through its design.
Policy Des 6 Development Design
Planning permission will only be granted for new development where it has been demonstrated that:
a) the current carbon dioxide emissions reduction target has been met, with at least half of this target met through the use of low and zero carbon generating technologies.
Policy Des 11 Tall Buildings – Skyline and Key Views
Planning permission will only be granted for development which rises above the building height prevailing generally in the surrounding area where:
- a landmark is to be created that enhances the skyline and surrounding townscape and is justified by the proposed use
- the scale of the building is appropriate in its context
- there would be no adverse impact on important views of landmark buildings, the historic skyline, landscape features in the urban area or the landscape setting of the city, including the Firth of Forth.
Policy Hou 2 Housing Mix
The Council will seek the provision of a mix of house types and sizes where practical, to meet a range of housing needs, including those of families, older people and people with special needs, and having regard to the character of the surrounding area and its accessibility.
223 It is important to achieve a good mix of dwelling types and sizes to avoid the creation of large areas of housing with similar characteristics. This approach supports more socially diverse and inclusive communities by offering a choice of housing and a range of house types to meet the needs of different population groups, from single- person households to larger and growing families.
Policy Hou 4 Housing Density
The Council will seek an appropriate density of development on each site having regard to:
a) its characteristics and those of the surrounding area
b) the need to create an attractive residential environment and safeguard living conditions within the development
c) the accessibility of the site includes access to public transport
d) the need to encourage and support the provision of local facilities necessary to high quality urban living.
8 Resources and Services
Policy RS 1 Sustainable Energy
Planning permission will be granted for development of low and zero carbon energy schemes such as small-scale wind turbine generators, solar panels and combined heat and power/district heating/energy from waste plants and biomass/woodfuel energy systems provided the proposals:
LOW AND ZERO CARBON TECHNOLOGY
Equipment provided on-site or integrated into buildings and which use solely renewable sources, resulting in zero carbon dioxide emissions, or which include use of fossil fuels but with significantly lower carbon dioxide emissions overall, which may include combined heat and power (CHP) and/or a range of other method
Edinburgh Design Guidance – January 2020
Technical Guidance (p13)
- New developments should be sensitive to historic character and attain high standards in design, construction and materials.
- In assessing whether or not unlisted buildings make a positive contribution to the special architectural or historic interest of a conservation area, the following questions will be considered:
- Does it have landmark quality?
- Does it reflect the traditional functional character of the area?
- Does it have significant historic associations with local people or past events?
- Shared surface in housing—Cakemuir Gardens.
- The houses come right up to the edge of the carriageway. The tight space that results means that
- motor vehicles have to move around slowly. This helps make the space safe for pedestrians and
- children playing.
- Pedestrian route in the city centre—Multrees Walk
- This shopping and office development creates an attractive street. The shops and little square
- within it make it an interesting space to pass through. The Council will seek to make more routes
- like this where opportunities arise.
- Connections outside the city centre—Brandfield St.
- An important new connection has been made through the former brewery site. It is made as
- accessible as possible by the inclusion of the ramp. Landscape and overlooking contribute to its
1.5 Density (p30)
Increased density can be achieved on sites where the surrounding density is lower provided that:
- the increased density would not have an adverse impact on neighbouring amenity or valuable natural heritage features.
2. Designing places: buildings
The key aims are for new development to:
- Have a positive impact on the immediate surroundings; wider environment; landscape and views, through its height and form; scale and proportions; materials and detailing; positioning of the buildings on site, integration of ancillary facilities; and the health and amenity of occupiers.
2.1 Height and form
- Match the general height and form of buildings prevailing in the surrounding area.
2.12 Purpose built homes for rent (BTR)
Design should be place specific, high quality and energy efficient.
Shared on-site facilities should be high quality, accessible and safe.
Leith Docks Development Framework (February 2005)
0.10The masterplans should establish a 0.11 modulating built form with ambient building height between 5 – 8 residential storeys.Along the coastal edge, building heights will be between 1 -5 residential storeys. At Edinburgh (Western) Harbour, building heights can be between 8-10 residential storeys. Potential zones within which masterplans may be able to justify building heights of up 16 residential storeys are identified at Waterfront Plaza (due to the accessibility to the strategic city link), and the north and south edges of the Western Harbour (to relate to the large expanse of water).