The Cockburn Association has considered this application and wishes to lodge the following comments. Overall, we would wish to formally object to these proposals on the grounds on impact to the historic fabric of listed buildings, the implications that this has for the integrity and authenticity of the World Heritage Site (and its compatibility with its Outstanding Universal Value) and the potential for wider disruption due to access and servicing requirements of this type of development.
Whilst the Cockburn welcomes proposals that bring the upper floors of buildings within the First New Town into active use, this must be consistent with the impact on the historic fabric of the buildings. The Heritage Statement is helpful in setting out the changes that have taken place on this site over time, but there is no escaping that this site comprises a substantial amount of first-generation New Town architecture, which is becoming rarer as further developments are undertaken. The most significant alterations have taken place on ground and first floor levels where commercial uses have been found. Substantial original fabric in the upper floors remains, and it is our view that the policy objective of development here should be retain as much of this as possible.
We can see no justification for the level of internal alteration and demolition from a historic policy or statutory focus. The proposals are inconsistent with the legal obligations of s.14 and s59 of the Planning (Listed Buildings & Conservation Areas)(Scotland) Act in that the scheme does not preserve features of architectural interest or merit. These, added to the external alterations to the historic fabric result in a scheme that is damaging to the listd buildings in question.
As such, we advise that the proposals are inconsistent with Local Development Plan policies ENV1 (impact to the integrity of the World Heritage Site) and ENV 4 Listed Buildings – Alterations and Extensions, where is it clear that no unnecessary alterations will be permitted. Similarly, the scheme is inconsistent with NPF4.
In addition, we have concerns about the operation of this use in this location. Transitory accommodation like this has a considerably higher degree of movement in terms of guests accessing the accommodation via taxis, etc as well as higher levels of service vehicles such as laundry and change over activities as well as possible catering, etc. The junction at Hanover Street and Princes Street is very congested, and this side of Hanover Street will form part of the Meadows to George Street cycleway. Pavement or curbside parking for drop-off or servicing requirements could have a substantial impact on the free movement of pedestrians and wider vehicle movements. This needs to be fully assessed before any further consideration is given.
As such, the Cockburn objects to this application. We can see some merit in the proposed use but not the current proposals, where considerable amendments will be required.-