Letter To Councillors


Revised applications (Listed Building Consents) have recently been submitted to the Council by the developer acting on behalf of Virgin Hotels.

These are for modifications to the original consented plans (approved by the previous Council administration) and though changes to the original plans are relatively minor, with sufficient public pressure the new Planning Committee would need to scrutinised these applications and should do so in the context of re-evaluating the entire proposed hotel development.


Dear Elected Representative,


Following May 2017 local elections, the new Edinburgh Council administration has shown willing, in the case of the former Royal High School, to significantly re-evaluate contentious proposed developments of the previous administration in response to the deeply worrying, strong concerns” of UNESCO. Additionally, the new Council, unlike the previous administration, supports a Community Right of Appeal in response to the Scottish Government’s ‘game changing’ Planning Review, acknowledging the unfairness of the planning system which currently only grants appeals to developers.

According to Listed Buildings and Conservation Areas (Scotland) Act 1997, planning is to have special regard to the desirability of preserving the special interest and setting of a listed building and to preserve or enhance the character and appearance of conservation areas, matters that should be accorded considerable importance and weight. The presumption is therefore that development proposals should not harm the special interest of a listed building or the character and appearance of a conservation area.

Given the recent submission of planning applications (18/02279/LBC, 18/02280/LBC, 18/02281/LBC) associated with the highly contentious proposed India Buildings/ Virgin Hotel development (which the Old Town Community Council concludes would imperil the future of Edinburgh Central Library, the Old Town Community and the reputation of this City of Literature, World Heritage and Enlightenment), an appeal is made to Councillors serving on the Planning/ Development Management Committee to use all powers available in the public interest to fully scrutinise these applications in the context of the overall proposed development (Application 15/04445/FUL).

Many serious unresolved questions have been raised throughout this case, including a lack of regard to environmental, cultural and heritage impact, particularly the setting of listed buildings, excessive levels of air pollution (in breach of EU regulation) and traffic and pedestrian safety, which would be further exacerbated due to the proposed relocation of restaurant and kitchen facilities to the new building on the Cowgate.

The integrity and veracity of the developer’s assessments are now in question following the conclusion of the recent Council commissioned independent daylight assessment, which reveals that natural light to the Central Library would diminish by as much as 80+%.

Councillors on the Planning/ Development Management Committee are asked to give particular attention to the Old Town Community Council’s assessment which recommends:

  • An independent Heritage Impact Assessment of the proposed development, taking into consideration the upgraded A listed Central Library and its setting, historical archives not previously referenced and ‘intangible’ elements of OUV, in particular the historic/ cultural significance of the Library (as the flagship cultural asset relating to Edinburgh’s title as the 1st UNESCO World City of Literature and the finest Carnegie endowed library in the country of the founder’s birth), in order to clarify the Applicant’s conclusion* that the development would have ”no adverse impact on the character or appearance of the conservation area or the setting of adjacent listed buildings.”
  • An independent traffic and environmental impact assessment to clarify the proposed development would neither breach EU Law nor “introduce any implications in terms of road or pedestrian safety”.
  • An enforcement Stop Notice until these actions are concluded.


* Note: The heritage assessment of the Applicant is outdated, referring to the Central Library as a Category B (and NOT Category A) listed building; a crucial material change of national/ international significance requiring reassessment by Historic Environment Scotland. The Assessment is also incomplete and purposely selective, while the latest fast tracked application 15/04445/VARY is in error, describing the extension to 11-15 Victoria Street as constructed in the 1960’s, when it is actually late 19th century.

It is deeply disappointing that the Council have declined to validate the recently submitted Council Petition, which given the opportunity presented in assessing the associated LBC applications makes the case even more pressing for Councillors to use all powers available to fully scrutinise this development in serving and upholding the public interest.

Under the circumstances given the controversy of this case, representatives from the local community and the campaign ‘Let There Be Light Edinburgh’ should be allowed the opportunity to give deputations at the hearing of the LBC applications.

Please accept this correspondence as an endorsement of the above points and an objection against the LBC applications.

Thank you for your consideration.

Yours faithfully,




The Planning Committee Councillors are:

Councillor Neil Gardiner (Convener)
Councillor Chas Booth
Councillor Maureen Child
Councillor Denis Dixon
Councillor George Gordon
Councillor Ashley Graczyk
Councillor Joan Griffiths
Councillor Max Mitchell
Councillor Joanna Mowat
Councillor Hal Osler
Councillor Alex Staniforth

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