Application for ‘Non Material Variations’ added to Edinburgh Council Planning Portal

An application for ‘Non Material Variations’ to the original plans for the Raeburn Place Stadium Development has added to Edinburgh Council Planning Portal (ref 12/03567/FUL). It was submitted on December 20th and can be viewed here:

The closing date for comments of 10th January 2019 (next Thursday). It is important that opponents of this scheme take the opportunity NOW to object to these latest proposals.

We strongly believe that scale and scope of these changes is such that they should not be afforded the status of ‘non material’. Our position is that these are material changes that affect the initial planning decision and hence if the Accies wish to proceed on this basis, fresh planning permission should be sought.

Below is a summary of the proposed variations and the arguments as to why they should considered as ‘material’. Please ensure that any objections focus on legitimate justifications for why these proposals should be denied ‘non-material’ status as outlined below otherwise they may not be counted as valid objections. You can use our notes below as a basis for your response but please try to use your own words where possible. Please do this immediately – the closing date for applications is this coming Thursday (10th January).

We have heard from some people that the portal has been closed to comments. If you are unable to submit your comments via the portal, you should email the case officer directly with your comments before the closing date:


Proposed Non-Material Variations

  1. Stand access and egress strategy reconfigured. Security gate added to North Entrance.
  2. Running track relocated to the North of the site.
  3. Revised stand and seating layout:
  • Seats on upper terrace relocated to lower terrace;
  • External escape stairs added;
  • Wheelchair spaces relocated
  1. Revisions to internal layout at Ground Floor Level including:
  • Amalgamation of retail units 4-5. One set of external doors omitted.
  • Amalgamation of retail units 6-8. Two sets of external doors omitted.
  • Tunnel to West end of stand omitted.
  • Stone wall to east of main entrance relocated. Steel access gate added between the two walls;
  • Cinema/AV room replaced with rugby museum. Portgower Place entrance relocated;
  • Increased plant areas under the stand;
  1. Revisions to internal layout at First Floor Level including:
  • Slight relocation of the main kitchen;
  • Reconfiguration of plant area;
  • Admin offices relocated from Ground floor level to First Floor Level;
  • Relocation of café and associated finishing kitchen;
  • Slight relocation of the finishing kitchen in the East Wing;
  • Relocation of staircore to the North End of the building; Improvement to the circulation flow within the building.
  1. Minor adjustments to elevations. For more details refer to drawings (PL)050- (PL)055 – The amended internal layouts;
  2. Changes to area schedule: While the building Footprint and the Total Gross Area have slightly increased, as explained below, the retail spaces and hospitality spaces have been reduced.
  • Building footprint: increased by 126sqm; Due to the relocation of seats from the upper terrace to lower terrace.
  • Total Gross area: increased by 334 sqm; Increased use of the space under the stand.
  • Retail Space: reduced by 120 sqm:
  • Hospitality spaces including function suites, Bar/ Lounges, Corporate Boxes and Café: reduced by 127 sqm;
  • Overall kitchen area: reduced by 2sqm Resulting from:
  • Finishing kitchens: increased by 40 sqm;
  • Main kitchen: reduced by 42 sqm.

This long list of variations to the approved scheme are thought to be linked to the partial building of the project, as announced by the Accies/ Raeburn Place foundation in the Spring of 2018.  By building the Commercial elements of the project along Comely Bank Road as a “Phase 1” with no absolute commitment to build the rest as a phase 2, the developers are reneging on the tacit agreement made with the people of Edinburgh and the Planning Committee that this is a sport led development with associated commercial elements.

By starting the civil engineering elements of the project in advance of the decision on whether the extensive changes are material, they may be trying to force the hand of the Council into accepting a fait accompli.  The Council should not accept the work to date as in any way material to its decision.

This proposal remains a matter of public concern and highly controversial.  If officers intend to approve the changes as ‘non-material’ a report should be put to the Committee for their decision.  Another “Murrayfield mistake” would not be in the interests of proper planning procedures.

Grounds of Objection

The variations have to be considered in terms of the cumulative change to the terms of the planning permission originally granted.  Taken cumulatively, the variations amount to a material change to the approved scheme.  Furthermore, several specific elements are material in themselves, including:

 Total Gross area increase of 334 sq metres (3595 sq feet)

This is an intensification of development.

Building Footprint Increase of 126 sq metres  (1356 sq feet)

This increases the area of playing fields lost due to the development, contrary to LP policy OS1.

Amalgamation of Retail Units 6, 7 and 8 omitting 2 sets of external doors

The Planning Committee were told in the Report that that the “rhythm of smaller units” in  Raeburn Place “would be continued with the proposals” and be” Echoed in the design”. The proposed revision does not do that.

Amalgamation of Retail Units 4-5 omitting external doors

The Planning Committee were told in the Report that that the “rhythm of smaller units” in  Raeburn Place “would be continued with the proposals” and be “Echoed in the design”. The proposed revision does not do that.

The gable wall to the East of the Main Entrance which will be exposed upon the completion of the so called “phase 1” is not addressed in the variations but will be a major issue affecting the setting of the listed Raeburn House Hotel.

Deleting the Cinema/AV room – Relocation of cafe

In the planning application the cinema was part of or linked to the museum and hence part of the historical argument for the development on the site of the first rugby international.




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