Protect Scotland's Venues

Question

Yes / No / Unsure

Answer

Question 10: Do you consider that proposals to convert the ground floor or entirety of buildings in town and city centres to residential use should benefit from PDR? 

No

I oppose the PDR proposals due to the significant risk of noise nuisance complaints from new residents of the converted buildings, which threatens the viability of music venues, pubs and clubs in our town and city centres. Noise complaints have already caused the closure of Electric Circus and Studio 24 in Edinburgh and Downstairs in Aberdeen. In Glasgow, new development proposals continue to put world-renowned venues such as King Tut’s and Subclub at risk. The PDR proposals make the risk of closure significantly higher and as such will have a knock-on effect on the vitality and viability of our town and city centres. To protect these cultural institutions, all proposed changes of use to living accommodation in town and city centres should require full planning applications with adequate noise mitigation and appropriate consultation with venues and the public before any decision is taken.

Question 11: Do you consider that there should be PDR for the change of use of properties above Use Class 1A premises to residential use? 

No 

I oppose this proposal for the reasons explained in response to question 10.

Question 12: Do you have any comments about the prospect that the PDR would allow a change of use to residential from any existing use? 

Unsure

As explained in response to question 10, I believe all changes of use to living accommodation in town and city centres should require submission of a full application for planning permission and be subject to appropriate consultation and publicity.

Question 13: Do you think PDR for the change of use of properties above Use Class 1A premises to residential use should include any limits on the minimum or maximum floorspace, size and/or number of residential units that can be formed? Please explain your answer and describe what you think the limits should be, if any.

Unsure

As explained in response to question 10, I oppose any form of PDR for change of use to living accommodation in towns and city centres.

Question 14: What other potential limits, restrictions and exclusions to such PDR should be considered? 

N/A

As explained in response to question 10, I oppose any form of PDR for change of use to living accommodation in towns and city centres. However, if proposals are brought forward, it is essential that limits, restrictions and exclusions are put in place to protect pre-existing music venues, pubs and clubs. This could include drawing an exclusion zone around pre-existing venues. If that approach was adopted, venues should be consulted on the proposed exclusion zone.

Question 15: Do you consider that a prior notification and approval mechanism should be required in respect of a PDR for ‘town centre living’ as discussed in the consultation?  If yes, what matters do you consider should potentially be subject to prior approval? 

Unsure

As explained in response to question 10, I oppose any form of PDR for change of use to living accommodation in towns and city centres. The prior notification and approval process does not involve consultation with venues and the public. In England, PDRs have resulted in unsuitable residential conversions next to music venues pubs, and clubs despite being subject to a prior notification and approval mechanism. 

Prior notification and approval will not protect pre-existing venues from the impact of noise sensitive developments. Full planning permission is necessary to ensure sufficient measures are put in place to mitigate, minimise or manage the effect of noise between the development and any existing cultural venues or facilities.

Question 16: Should any such PDR (permitting the change of use of floors above Use Class 1A premises) also permit certain external alterations of a building to facilitate the conversion to residential use, if so what alterations? 

No 

As explained in response to question 10, I oppose any form of PDR for change of use to residential use in towns and city centres. However, if proposals are brought forward, it is essential that external alterations are not permitted on the basis that changes such as the installation of windows and doors create an increased risk of noise nuisance complaints. External alterations should therefore require full planning permission with adequate noise mitigation and planning conditions.

Question 17: Please provide any other comments regarding the potential options to introduce PDR for ‘town centre living’ proposals as discussed in the consultation.

In England, PDRs have resulted in unsuitable residential conversions next to music venues, pubs and clubs. This has led to poor quality housing, as new residents face intolerable conditions while venues receive complaints and restrictive applications, resulting in closures. This has undermined, rather than revitalised, England’s high streets. Scotland should learn from this by excluding PDR for change of use to residential from town and city centres.  

Question 27: What are your views on the accuracy and scope of the environmental baseline set out in the environmental report? 

N/A

The environmental baseline does not take proper account of current pressures facing live music venues.     

Question 28: What are your views on the predicted environmental effects of the proposals as set out in the environmental report? Please give details of any additional relevant sources.

N/A

For the reasons outlined above, I believe the report fails to predict the likely impact of the proposals on cultural institutions such as live music venues, including the risk of closure due to noise nuisance complaints. 

Question 31: Please provide any comments on the partial Business and Regulatory Impact Assessment (BRIA) and information on the potential business or regulatory impacts of any of the options identified in this consultation. 

N/A

For the reasons outlined above, I do not agree with the statement: “By encouraging town centre living, options 5–6 would likely lead to increased footfall and vibrancy in town and city centres, supporting local businesses.”

The recognition that “New residential developments near existing businesses (e.g., pubs, factories) may lead to complaints and costly mitigation requirements for those businesses” confirms that the PDR proposals conflict with the Agent of Change principle.