Objection to Change of use from residential to short term visitor accommodation at 1F2 68B Grassmarket
Ref: 21/02351/FUL – Comment Here: https://citydev-portal.edinburgh.gov.uk/idoxpa-web/applicationDetails.do?keyVal=QSBNYLEWJUU00&activeTab=summary
1). The development is contrary to Hou 7 Inappropriate Uses in Residential Areas.
Short-term lets make life a misery for those who are forced to share spaces with them.
- Increased disturbance and waste – The enforcement notice and DPEA decision (ENA-230-2186) which exists against this property, details the increased disturbance and waste at this property arising from its use as a short-term let. It has been concluded in 98% of the 45 DPEA planning appeals in tenements, that short-term lets have a materially detrimental impact on the living conditions for close neighbours8, such as in this case.
- Concentration of short-term lets – The applicant places significant importance to an appeal decision at Johnston Terrace where an application for change of use to STL was sustained. The decision seemed to suggest that the living conditions of the final resident must be so compromised that they no longer needed to be protected. The views in this appeal decision are an exception and not consistent with the 98% of cases in tenements which have been dismissed.
Other concentrations of short-term lets in a single tenement have been closed in other equally busy locations including 5 Castle Wynd (Flats 6, 7 and 9), 22 Haymarket Terrace (3F2, 3F3, 4F3) and 63 Bread Street (F2, 3 and 11). In each of these cases the reporter has cited the need to protect the security and peace of other residents.
- External vs internal noise – PPA-230-2239 notes “…there is an important distinction to draw between external ambient noise, which is a characteristic of a city centre location such as this, and sources of noise and disturbance from within the building itself.
- Loss of security – The loss of security is a huge concern to residents who share spaces with unlawful short-term lets. The Johnston Terrace decision acknowledges this loss of security but offers no reason why the remaining resident of this block, who objected so passionately to the change of use, should be expected to live with this.
The DPEA decision at this property notes how the use of lockboxes and high turnover of customers represent the loss of security to permanent residents at this property – “This would change the level of actual and perceived security for permanent residents in a manner that would not otherwise be the case under typical residential circumstances.”
- The existence of a large number of unlawful short-term lets in the area – should not be taken in support of such applications. CLUD-230-2009 – “the decision should be made against the lawful use of the neighbouring properties (which is as homes)”.
- Intrusion of business into private family life – Lastly, it is saddening to note the sheer number of comments of support to this application, which have been mobilised by a section of the short-term letting industry. In this case, almost two hundred commenters have been motivated to exert their influence to attempt to overturn a decision which protected the peace and security of the homes of people who they have never met, to protect a potential financial loss to themselves. These actions, which place profit above the peace of neighbours, exemplify what is happening in too many of our communities.
2). The development is contrary to emerging policies in the City Plan – 9A – Protecting the loss of Edinburgh’s homes to other uses, and 9B Short Term Let Control Area.
3). The development is contrary to the Scottish Government Housing policy on More Homes – “everyone has a quality home that they can afford and that meets their needs”
4). The development is contrary to Scottish Planning Policy on “socially sustainable places”.
- Material considerations – Scottish Government Policy is listed as a material consideration under “Planning Circular 3/2013: Development management procedures, possible material considerations”. Policies in the emerging Development Plan are listed as a material consideration by the “Material Considerations” document produced by Planning Advice Scotland (PAS)
- Loss of housing stock – Edinburgh has a housing, and accessible housing crisis. The Strategic Housing Investment Plan states the rapid growth in short term lets is creating further pressure on supply, rent levels and house prices in some areas as properties are purchased for short term let rather than long term rent or owner occupation.
To demonstrate the scale of the problem, independent research for the Scottish Government finds 12.78% of all Edinburgh City Centre dwellings are listed as entire-property short-term lets on Airbnb alone. In the Old Town, where this property is listed, one in four properties are listed on Airbnb. Very few have planning authorisation.
- Loss of community – Short-term letting affects the ability of the area to function as a “socially sustainable place”.
- Economic cost – The number of Airbnb properties in Scotland have risen from 74 in 2011 to 31,884 in 2018. Over the same time, according to the Scottish Government’s own figures, there has been zero growth in the Scottish Tourism Economy. The Economic Policy Institute finds that claimed increases in economic activity due to short term lets are often vastly overstated because the spending would have occurred anyway. by travellers staying in other accommodations. Industry leaders say there is already an oversupply of tourist accommodation in Edinburgh.
 Scottish Government, Research into the impact of short-term lets on communities across Scotland, 2019