The Planning
Inspectorate
3/18A Eagle Wing
2 The Square
B51 6PN
FAO Mr. N. Patch
17th June 2013Dear Mr. Patch,
Appeal Description: Erection of 54 extra care apartments for the
over 70s (use class C2) with associated landscaping and car parking
Site Address: Greaves Hotel, Greaves
Road , Lancaster Lancashire , LA1
4UW
Inspectorate Reference: APP/A2335/A/13/2195739
Following Planning
Inspectorate advice on the avoidance of duplication, we, the undersigned, are
making a single submission AGAINST
the upholding of the above appeal.
Summary of Case against
upholding the Appeal
1. Lack of compliance with policy
The developer has been
over-reliant on the “presumption in favour of sustainable development (NPPF,
2012), at the expense of balance and compliance with other national and local
policy imperatives. Details of non-compliance are provided.
2. Contribution to the achievement of
sustainable development
The level of economic,
social and environmental benefit for the local area may not be sufficient to
outweigh the disadvantages incurred by the build. Detail of issues is provided.
3. Traffic/Parking issues
The location and
nature of the site is unsuitable for the attendant traffic demands, such that a
range of issues remain largely unresolved. These are explained and commented
on.
4. Lack of Compliance with National and Local
Conservation and Heritage Policy
There has been
inadequate discussion of the “Conservation
Area and of the significance of the heritage assets affected, including any
contribution made by their setting, and the proposal’s impact upon that
significance in line with NPPF, para
128” (Conservation Officer). The significance of the heritage of the area is
explained, with particular reference to English Heritage’s concept of sense of
place which provides evidence of aspects of life and the potential of a place
to yield evidence about its past activity.
5. Lack of Impact based Planning re Public
Amenities
There would be several
adverse effects on the amenities of local residents. Issues have been ignored,
or their importance unreasonably diminished by the skewed imperative towards
development. There has been a significant and unreasonable lack of impact based
planning The Householder Development Consents Review (2007) is referenced.
6. Consultants’ Reports
Not all of the reports
can be deemed supportive. There are inadequacies and issues of
misinterpretation in relation to some aspects of various consultancies, which
mean that issues have either not been properly addressed, or they have been
discounted on slight or erroneous grounds. Relevant Reports are identified.
7. Design/Site fit
The shoe-in fit incurs
design problems in relation to overshadowing, privacy, loss of daylight, and
the build does not comply with national (or local) good practice re separation distances. The aesthetic design is
poor from every elevation, industrial in its use of materials, out of character
with the area, and is already looking like an anachronism from the last decade.
Shortcomings are identified and illustrated.
8. Relationship to the scale and pattern of
existing development in the area
The build would bear
little relationship to existing development in the wider Greaves area in terms
of character, aesthetic, building materials, roofline, overbearing proximity to smaller neighbouring properties,
need for external servicing, traffic, access, parking issues. In its immediate
vicinity, it is totally anomalous with the surrounding neighbourhood.
Illustrations are provided.
9. Community Response and Local Opposition
In the community there
is much concern about adverse impacts, and there has been a considerable amount
of local participation in the democratic process. Written and personal representations
have been made to the developers, which have not really been heeded. The developers’
claims about their level of meaningful engagement with the community is refuted
in an accompanying appendix.
As a community we do
realise that the planning process has its procedures concerning appeals, and
that these will deal mainly with the issues raised in the Refusal of Consent,
and with the grounds raised by the appellant. To address the Planning Agenda on
like terms, we have engaged a Third Party Response to be made on our behalf by
a professional Planning Consultant. However, the strength and range of our
collective misgivings about this development occurring on this site, and the
very adverse effects it will have on us all, (and on some more than others) has
lead us to put forward the wider community perspective in this submission. We
are not anti-development, but we do not believe
this over-large build is right in this location, for all the reasons we set
out.
It cannot comply with
the LCC Draft Local Plan 2003-2023/4,
Part A Development Management DPD – Preferred Option Stage: Policy CSC1-Design
of Development.
It does not
have/cannot/ cannot ensure:
- “a high quality of design
- appropriate siting, layout, orientation,
scale, massing
- enhance the visual amenity of the locality
- no detrimental impact occurs to the
residential amenity of neighbouring properties particularly in relation to
overshadowing, visual amenity and pollution
- suitable and safe access to the existing
highway network and road layout design
- due regard to the implications of highway
capacity
- the street scene is not compromised by
inappropriate parking provision.”
The City Council had
the wisdom to see the development holistically, and to listen to the concerns
of the local community as part of the democratic process. The Council’s reasons
for withholding planning permission were absolutely valid and reasonable, and
the City Council has the complete backing and support of the local community in
its stance on this matter.
We ask, and very much
hope, that the Planning Inspectorate will also take a balanced view, which is
not just founded on “ the presumption in favour of sustainable development” but
which is holistic and takes account of
other policy directives and guidelines, against which this proposal and appeal
can be found seriously wanting.
We ask that the appeal
be refused.
Yours sincerely,
Andrew Neal, Professor
Michael Abramson, Teresa Abramson, Gillian Whitworth, David Bennett, Karen
Miller, Sorrell Thompson, Gary Rycroft, Dr Columba Scallon, Jennifer Bennett,
David Denver, Barbara Denver, Denise Lancaster, Daniel Whittle.
Appeal: 13/00014/REF
Inspectorate ref: APP/A2335/A/13/2195739
Authors: Greaves Residents
Section 1. Lack of compliance
with policy
The developer has been
over-reliant on the “presumption in favour of sustainable development” (NPPF,
2012), at the expense of balance with other national and local policy imperatives
which inform and determine good planning practice.
There are numerous
examples of non-compliance with national and local policy. Those identified are
set out in Appendix 1 of this letter
(attached).
The Letter of Refusal of Consent from Lancaster
City Council similarly specifies a number of policies which the proposed
development was in breach of.
Appeal:13/00014/REF
Inspectorate ref: APP/A2335/A/13/2195739
Authors: Greaves Residents
Section 2. Contribution to the
achievement of sustainable development
The development may
not yield the level of economic, social and environmental benefit to the
community to outweigh the disadvantages incurred by the build (NPPF, 2012: Para 7).
As a business venture,
which this undoubtedly is, there should be significant, positive economic and
social benefits to the local community. A number of factors suggest that this
is not the case:
·
Local need for this type of care is uncertain – Lancaster Local Plan (2.6.13) states: “there is likely to be only limited demand
for additional accommodation for elderly people”. There are at least two residential care homes
for the elderly within 500metres (Burrowbeck and Nazareth House), and a further
apartment block which caters mainly for retirees within 100 metres(Brunton
House), as well as another McCarthy and Stone development less than a mile away
in the City Centre.
·
Staffing levels--projected as 14FT/9PT jobs when fully operational. However, some
posts may be specialist roles, and not recruited from the local market. In
terms of operational capacity, 60-80% appears to be the norm for this type of
development (see Transport Survey). At
the nearest McCarthy and Stone development (less than 1 mile from this site)
there were 11 apartments for sale and several for rent recently. 23 posts could then be an overestimate
of the staffing level.
·
Job losses--the gaining of posts should also be offset against the loss of 11FT/PT posts (at the time of the
Planning Committee meeting) (plus the potential for more) at the Greaves Hotel,
all of which are held by local people. There is a previously documented need
for more hotel spaces in Lancaster
·
Local Economy With an average age of 83, and a target market
of the frail elderly, residents in Extra Care will be unlikely to patronise
local shops, including local hairdressing and fast food facilities, because of either
their frailty or the availability of in-house provision, or both. Apart from
the local Spar, it seems unlikely that the local economy will benefit greatly.
·
Affordability--- Purchase costs are significantly higher than local property market
values. (c.£149,000 for a 1 bed flat v. local example of £109.950: £199,000 for
a 2 bed flat v. local egs of (£99,950,Greaves area; £120,000, town centre).
(Prices seen for Lancaster
`This
development is not social housing, and it is not affordable for local people. The Lancaster City Council Meeting
Housing Needs Supplementary Planning Document (2012) Chapter 4, 4.1 (p25)
indicates that a key priority for the area is affordable dwellings. There is an
annual shortfall of 330 (up from 216) such dwellings, and the document
indicates that “the need for affordable
housing is acutely high”. It does not meet the key priority in the Lancaster
District Core Strategy (2008), Paras 4.57 and 4.58, of addressing the annual
shortfall of Affordable Dwellings. This build has secured exemption from
affordable housing requirements (letter from Chris Butt to Andrew Drummond, 24
August 2012).
Again, therefore, it falls short of making a valid contribution to local
sustainability.
Table 1 “Capable of being
developed without loss of or damage to features of
significant landscape, …or built
heritage importance”, nor is
it:
Policy SC1: “ integrated with the character of
the landscape…and creates publicly
accessible open space”.
The development would actually remove the currently available publicly
accessible open space. See also Section 4 re heritage below.
Appeal: 13/00014/REF
Inspectorate ref: APP/A2335/A/13/2195739
Authors: Greaves Residents
Section 3. Traffic/Parking
issues
Despite the best
efforts of the traffic professionals, a range of issues remain largely
unresolved. They are unsatisfactory because the location and nature of the site
is unsuitable for the traffic demands that would be put on it:
·
Avoidance of demonstrable harm--lack of a
traffic impact assessment for the
A6(especially in relation to kerb build-outs) undermines the claim for the avoidance of demonstrable harm.
Glen Robinson, Senior
Engineer (Developer Support) (Letter of 24/10/2012): “The developer has failed to discuss the effect of the development on
road safety in the TS(Transport Statement) and as such it can only be assumed
that the developer believes that their development will not impact on road
safety.”
This is effectively a
disclaimer, not an endorsement of the transport
plan’s level of safety, as some have chosen to interpret it as.
·
Unsuitable topographical location for the elderly because of steeply sloping
Streets, (Brunton Rd Bridge Rd Brunton Rd
·
Use of pavement to east of A6 (Greaves Rd Brunton Rd
recommended by Bryan
Hall, Transport Survey) .
This is not a safe
option. The pavement on the A6 level
east side, (below BVTerrace) is narrow, especially for manoeuvring mobility
scooters. Other than getting to/from the bus-stop or the crossing, local people
do not walk down there. It is too cramped and dangerous. BVT, above the main
road level, is used by pedestrians, but there are 10 steps to ascend so it is
unsuitable for mobility scooters..
·
Kerb build-out proposals for Bridge and Brunton
Roads (main access routes into
West Greaves).
These are not a good
solution. Lack of local usage knowledge has lead to some potentially harmful
suggestions for resolving crossing and safety problems (principally kerb
build-outs). They need modelling in the light of actual local conditions, not
least since Bridge Rd Ripley
School
There appears to have
been no traffic impact assessment for theA6, and no assessment of potential
future demands, or of emergency measures arising from motorway incidents, on
this national trunk road, which is also the main alternative to the M6. If
approved, this build would be here for decades. Some future-proofing analysis
would be prudent, not least since there is a proposal to build 1600 extra homes
in South Lancaster .
·
Traffic movements
Access to and egress
from the site by large vehicles is extremely difficult ((See Appendix 2/P3, photo of vehicle unable to turn into Ash
Grove) yet there will be vehicle
deliveries to this site 365 days a year. Furthermore, however you calculate
the number of vehicular movements per day (92 or 147) these are too many for a
narrow street like Ash Grove, where children live (Appendix2/P1), rendering the area as potentially unsafe.
·
On-street parking.
There are statements
from the developers (para 5.3 Transport
Statement ; Bryan Hall, 7/12/2012) that residents without permits, and
visitors will have to find other on-street parking, but parking is already a
problem, and particularly so between 5.00pm and 9.00am, and during University
terms. The streets are narrow, most houses are without garages or drives, there
is multiple occupancy (student housing), multiple car families (young professionals/students
e.g. No. 2 Ash Grove is a 5 car residence), and much commuter parking by school
and hospital staff
·
Permit arrangements
A permit system will
enable the site to demonstrate that on-site parking can be managed, but it
ignores the impact of the acknowledged
extra parking needs of the visitors to 74 residents, and of the resident non-permit
car owners, (and there are bound to be some), beyond this. The existing parking
problems of this area will be exacerbated by this build, which will therefore
have an adverse impact on the quality of life of existing residents. It would
be dishonest and unrealistic not to recognise this.
Appeal: 13/00014/REF
Inspectorate ref:
APP/A2335/A/13/2195739
Authors: Greaves Residents
Section 4. Lack of compliance with national and local conservation and heritage
policy
The chronology of the proposal documentation provides clear evidence
that the building was designed first, (April 2012) without any regard for
heritage considerations, which effectively came as an afterthought. The
Heritage Addendum was produced months later (November 2012) following a
requirement by the Conservation Officer, who noted that there was: “no discussion of the Conservation Area, of
the significance of the heritage assets affected, including any contribution
made by their setting, and the proposal’s impact upon that significance in line
with NPPF para 128.”(See CO’s memo of 2/11/2012).
The only discussion relating to heritage/assessment using appropriate
expertise (the developer’s architect, Christopher Butterworth, RIBA) by the
developer focused on the lack of value of the retention of the Greaves façade,
and on the use of natural stone and better quality building materials, instead
of the ugly, yellow reconstituted stone, as first proposed, in order to
correspond better with the local built environment. On both aspects the developer
subsequently acceded to the requirements of the Conservation Team.
The rest of the Heritage Addendum document is purely descriptive of the
local built environment. There are erroneous ascriptions to some of the
photographs. There is no attempt to consider or discuss the heritage significance
of the conservation area and heritage assets, nor the historic links between
them. A map is provided (p4 of Heritage Addendum, see Appendix2/P4), showing that the site lies within 800 metres of two Conservation Areas, Aldcliffe and
Greaves, with the Greaves Conservation Area (regarded as a heritage asset) and
the Ripley heritage assets only c. 200 metres distant (see map). They are separated
from each other by the new build, but there is no attempt to consider either
the impact on the Conservation Area(s), or the historical /heritage
implications.
There has, in fact, been an historic visual link between these two
heritage assets since the building of the Ripley Hospital Ripley Hospital
The Heritage Addendum
does not therefore comply with NPPF Section 12: “ LA’s should require an
applicant to describe the significance
of any heritage assets affected, including any
contribution made by their setting”. The NPPF(2012) elucidates further:
“Significance (for heritage policy): The value of a heritage asset
to this and future generations because of its heritage interest. That interest may be archaeological,
architectural, artistic or historic.
Significance derives not only from a heritage asset’s physical presence, but
also from its setting.”
And comments: “Our historic environment-
buildings, landscapes, towns and villages- can better be cherished if their spirit of place thrives, rather
than withers”. (NPPF
Ministerial Foreword).
In relation to conservation
areas and their surroundings, the Lancaster District Local Plan (LDLP,2004, p172)
commented: “Many conservation areas rely for their character on the
relationship between buildings and spaces and the nature of these spaces. These spaces may be both within and outside
the actual boundary of the conservation area” (5.7.20) “When
determining any development affecting a conservation area, the City Council
will take account of the impact of views
into and across the area and the wider landscape setting.”(5.7.21).
The new draft LDLDP
(due for publication in 2014) includes English
Heritage Guidance on the
preservation of the historical value of areas:
“…..the way in which past people, events and
aspects of life can be connected through a place. This could be illustrative or
associative …
(and indicates the
importance of)
“Evidential value—the potential of a place to
yield evidence about its past activity”.
The proposed build
would be within and between the viewing range of two conservation areas and would
interrupt a direct line of sight between a conservation area/heritage asset
(Greaves, and key heritage assets (Ripley), which have a longstanding
historical connection (see photo).
The erection of a
huge, modern urban block on this site will remove the last connections and
vestiges of the early Edwardian way of life in this area. It will no longer be possible to yield illustrative or associative evidence
about past people/ activity/aspects of
life of the gentry promenading on the Monkey Rack (see Appendix 2/P6), because the
original evidential vista down
to the Ripley heritage assets and beyond
to the Aldcliffe Conservation Area and Morecambe Bay, which was intrinsic to the promenading activity,
will no longer exist. The local historical narrative will become meaningless.
It will be irrevocably lost.
The proposal is also
in direct contravention of LDC Policy
E35:
“Development proposals which would adversely
affect important views into and across a conservation area or lead to an
unacceptable form of its historic form and layout, open spaces and townscapes
will not be permitted.”
The sheer bulk of the proposed development
will completely destroy the heritage value of this area, and will be at odds
with both the letter and spirit of the NPPF, the Local Development Plan, and
the English Heritage imperatives which the new LDLD Plan intends to adopt
(confirmed on 20/05/2013 by relevant Senior Planning Officer).
The increased
urbanisation and loss of openness and heritage vista incurred by this large
build, and, in particular, its specific location between the sightlines of the
Greaves/ Ripley/Aldcliffe Conservation Areas/Heritage Assets would undoubtedly
detract from the visual quality of the area, and would cause demonstrable harm
to the heritage and conservation aspects thereof . The proposal is also in
breach of national and local policies relating to conservation and heritage as
demonstrated above.
The
same basic issue is currently being raised at international level, where UNESCO has condemned the development of Elizabeth House in London because of its concerns that several famous views
of Westminster Westminster
English Heritage has commented in this case
that “there do not seem to be…agreed constraints in place to ensure that new
tall buildings do not impact on important views and other attributes of the
property.” Questions are being raised about the protection to UK
Of course there are differences in scale
and importance here, but essentially there are not differences of principle.
Environment of conservation area
Similarly there has
been no attention given to environmental considerations for BVTerrace as a
conservation area in terms of loss of
amenity: loss of several hours of sunlight, overshadowing, reduction in
natural heat and light levels in homes,(thereby increasing our carbon
footprint); also potential environmental
damage to buildings and eco-systems: impact on public and private gardens
(most trees on BVT have protection orders on them), higher levels of traffic
noise and pollution because of the funnel effect of the massing of the
building. These could be cumulatively detrimental to the fabric of the houses
(as can be seen further north along the A6 at South Rd
Appeal:13/00014/REF
Inspectorate ref: APP/A2335/A/13/2195739
Authors: Greaves Residents
Section 5. Lack of Impact
Based Planning re Public Amenities
Adverse impact on
amenities, viz: overshadowing, loss of daylight/sunlight
,overbearing presence, loss of privacy, impact of increased noise and pollution
through intensification of traffic effects because of funnelling between two
large building blocks, failure to meet the 21 metres of separation rule, have
been ignored or diminished.
The Householder
Development Consents Review (2007), not listed as superseded by
the NPPF) stresses the importance of impact based planning:
Sections 1.11-1.12:
“1.11 The planning system is underpinned by the
concept of “impacts”. If the impact of a proposal is acceptable, then it should
proceed; if…not…the proposal should not proceed. Such an approach can be
applied equally to large and small development proposals.
1.12 The way in which the planning system deals
with proposals….mirrors this approach, encompassing an assessment as to whether
a proposed extension could overlook or overshadow neighbouring dwelling houses,
or be deemed visually inappropriate or be harmful to highway safety, or has
other cumulative impacts, which make it unacceptable.”
P11 1.24 (HDCR) cites as sound examples of good guidance on planning:
·
BRE’s Site
Layout Planning for Daylight and Sunlight, the standard text for assessing
overshadowing impacts.
·
Essex Design
Guide (2005 version) which enjoys a national reputation for its approach to
good design and assessing overlooking impacts
·
Residential
Design Guides drawn from a sample of Planning Authorities across England and Wales
·
P13-14
Sections2.4-2.9 deals with issues of overlooking (loss of privacy)
·
P15-18
Section 2.10-2.19 deal with issues of overshadowing (loss of daylight---tests
commonly undertaken on 31 March in order to establish a norm in relation to the
position of the sun.
·
P21
Section 2.30: “It is commonly stated
that tall, flat roof extensions….. are inappropriate.”
·
Section
1.6 places “THE ONUS ON THE DEVELOPER TO
JUSTIFY DEPARTURES FROM THE CODE”
There has been no
significant amelioration of amenity issues in the slight modifications made to
the plan, for example: Chapter 5,
Section 2.5 (HDCS) Overlooking (Loss
of Privacy) indicates: “Our research
into local Planning Authorities Householder design guides suggests that 21
metres is the commonest minimum privacy distance”.
The Lancaster District
Residential Code (1988, but still current) also indicates at p3,2.17: “There should normally be at least 21
metres between dwellings where windows of habitable rooms face each other, and
12 metres where a habitable room faces onto a wall with no such window; …. The
main windows of habitable rooms should not be overshadowed by….two storey gable
walls.” (See Appendix 2/P7)
Despite discussion and
“amended” designs, separation distances for Brunton Rd
In the various amendments there have been no
genuine concessions made to planning policy, no amelioration to public amenities,
or to people’s lives, and very little significant amendment to design and
layout, despite written and personal representations to the developers.
Appeal: 13/00014/REF
Inspectorate ref: APP/A2335/A/13/2195739
Authors: Greaves Residents
Section 6. Consultants’ Reports
There are inadequacies
and issues of misinterpretation in relation to some aspects of various consultancies,
which have resulted in their being deemed supportive of the development, when,
in fact only part of the issue, or in some cases, a different issue, has been
commented on . The upshot of this is that either the issues have not been
properly addressed, or they have been discounted on slight or erroneous grounds.
These are outlined below:
Impact on the Conservation Area of Increased
Traffic noise and Pollution
Legitimate public
concerns on these issues were recorded and noted, but were given inadequate
assessment and treated dismissively in the Planning Officer’s Report cf 7.19 :
“The Air Quality and
noise impacts have been considered by the developer and assessed by the
Council’s Environmental Health Service. There are no objections on air quality
grounds or noise grounds in relation to traffic impacts, the proximity to the
main road or to the implications of building on this site….a concern raised by
residents….(that)it would create a funnel effect and cause an increase in
noise/pollutants by refection (sic) against the building. This is not a significant reason for opposing the development,
particularly given no objection from Environmental Health Officers.”
In fact the SRL Technical Report prepared for
McCarthy and Stone clearly states that its recommendations are about protecting
the development’s “internal spaces from
noise”. There is NO assessment of
the impact of the development on the EXTERNAL environment.
The very brief memo
from the EHS in response to the SRL
Report, commented largely on site
construction impact issues, viz: dust control, burning of wastes, site
clearance times, silencing equipment for construction noise control, about
which the EH Officer felt there was “significant
potential for adverse impact(s) “.
There is no evidence that EHS was asked to assess
the potential increased impact on the noise and pollution on the neighbourhood
and the environment by the presence of the new build. It was not the case that EHS had no objections in
relation to these specific concerns. They did not express a view, and
presumably had not been asked for one.
These concerns, which
could cumulatively affect the appearance and fabric of the houses in the Conservation Area, and the amenity value,
noise and pollution levels for residents and pedestrians have not therefore been
addressed.
Traffic Safety
Mr. Robinson
(Lancashire County Council Officer) has effectively issued a disclaimer in
relation to traffic safety (Section Three, first bullet point refers, and his
letter of 24/10/12). His comment
certainly could NOT be taken as unmitigated support of the developer’s
proposals re traffic safety.
Conservation/Heritage
The Conservation Team
has done some good work in securing better building materials which are more in
keeping with the area, and in particular, with the conservation area. It is
unfortunate that neither they, nor the Civic Society, have concerned themselves
with commenting the specific design of the build beyond the retention of the
Greaves façade. Do they actually want a flat roof, zinc cladding and grey
aluminium curtain walling in this main heritage gateway to the City for the
next 40 years or more? How do zinc and aluminium age over a 40year period? Like
so many of the McCarthy & Stone developments (see Appendix 2/P9), it already looks anachronistic.
Despite initially
requiring that the developers discuss the
significance of the heritage assets and their setting, the wider heritage issues of the impact on the
conservation area have not been addressed fully (if you count discussion of the
Greaves façade as partial fulfilment). No issue of significance or contribution to the setting of the conservation
heritage asset has been discussed (see Section 4 of this document), nor has
this been commented on by the Officers or the Civic Society. In view of this
lack of consideration of the full heritage issues, it is difficult to see how
the Conservation Team’s Report might be regarded as fully supportive of the
development.
Trees
The Tree Protection
Officer had no initial objection to the development proposal, subject to
conditions (26/09/12). The amended plans
flout the conditions of the Officer by proposing to remove all trees. The
Officer has re-iterated her condition, but, de facto, this must be regarded as an objection to the proposal.
Ground Investigation
The EHS Officer
appears to have some issues with the Arc Environmental Desk Top Study Report
(Mark Edwards memo to Development Control of 18/09/12). There is no evidence on
the website of a response to this. Presumably the issues have therefore not
been resolved satisfactorily, and the proposal remains deficient?
Fire Service Consultation
The Fire Authority
letter (14/09/12) to the RPDM Team offered generic advice at that stage, and
suggested LA Building Control/Approved inspector and the Fire Service should be
consulted at the earliest opportunity. There is no evidence available to
indicate that this has occurred. Given the size, location and access issues of
the site, it cannot be assumed that there is currently an endorsement in
respect of fire safety, especially in view of the frail, elderly nature of the
proposed residents of this development.
Appeal: 13/00014/REF
Inspectorate ref: APP/A2335/A/13/2195739
Authors: Greaves Residents
Section 7. Design/site fit
From the perspective
of the developers, doubtless the site fit and design optimise the business
profit potential. However, the footprint of this build is too cramped in this
location.(See Appendix 2/P10).
Making it work is at the expense of adequate separation distances,
overshadowing, loss of daylight and privacy etc.. The development is shoehorned
into an inadequate space for the mass. Like a cuckoo in a sparrow’s nest, it is
too big and steals resources and amenities from its unwilling hosts.
The flat roofline to
the main building is, like the zinc cladding and the grey aluminium curtain
walling to the front Greaves link section, out of character with the surrounding
Victorian /Edwardian built environment.. The development presents an already
anachronistic, boxy, “noughties”(2000 and something) look, and proposes the use
of materials which will date quickly, like a number of other McCarthy &Stone developments (See Appendix 2/P12). From every elevation the design is ugly,
blocky, unattractive and with no clear form or line (See Appendix 2/P13).
The build frontage
would present unrelieved urbanisation and a loss of openness in the street
scene. The design is poor at the front (the façade is institutional, industrial
even, and the massing unwelcoming, the long balcony is tenement –like [See Appendix 2/P11]). Similarly at the
north side, where maintaining an already unsuitable building line, (and thereby
compounding previous planning faults), is given more priority than the privacy
of local residents. There appear to be more side windows in the new build than
the present one, and there will be permanent
residents with continuous overlooking potential to Brunton Rd
In relation to Ash
Grove (rear) the blank full building height massing at only 15-17 metres separation
is unacceptable. To indicate that the separation distance to Greaves Rd
Designing- in
separation distances of only 14 metres for Brunton Rd
It is unreasonable to
expect that local residents should accept such poor planning practice with
regard to a new build. Similarly, citing precedents of poor planning in the
past is no excuse for bad planning in the present or the future.
Appeal: 13/00014/REF
Inspectorate ref: APP/A2335/A/13/2195739
Authors: Greaves Residents
Section 8. Relationship to scale and pattern of existing
development in area
It is the case that
there are a few other large residential buildings in the wider Greaves area and
smaller blocks of flats. One other building is 5 storey, as is this. But
NOTHING else in the area is likely to have the length, cubic capacity or massed
presentation of the site in question, nor do existing buildings have the level
of close proximity and overbearing presence to neighbouring smaller properties
that exist at the Greaves Hotel site.
All are used as
private dwellings without the need for significant external servicing, and the
roads to the sides of these buildings are wider, so there are not the same
traffic, access or parking problems that are present on the Greaves Hotel site.
Most of them fit the character of the area, and do not have those dateable
features which conflict with the local heritage context, e.g. grey aluminium
curtain walls, zinc cladding and flat roofs.
Some are evidently
examples of previous poor design and planning—overlarge buildings in cramped
footprints, use of unsuitable materials. Some existed before the smaller,
neighbouring homes were erected. But
replicating the mistakes of the past should be a lesson to us, not a precedent
or an excuse for compounding bad practice. It is not a good option for a city
which wants to develop and enhance its heritage credentials, not add to its
planning problems. The proposed build,
therefore, bears little relationship to the existing development in the area.
It has the added disadvantage of being in the middle of two historically linked
conservation/heritage asset areas.
In relation to the
immediate vicinity of the site, it is clear from the ARC Environmental Aerial
Surveys (See Appendix 2/ P14 and P15) that
this huge, impersonal, modern development would be totally at odds with the
scale and pattern of the narrow streets and the surrounding community of 19th
–early 20th century modest terraced houses. It would, indeed, be a
cuckoo in a sparrow’s nest.
Appeal: 13/00014/REF
Inspectorate ref:APP/A2335/A/13/2195739
Authors: Greaves Residents
Section 9. Community Response
and Local Opposition
Residents’ opposition
has shown the development would be at odds with the NPPF (para 61 (Community))
concept of building a “sustainable community” in which planning development
would have a “vital role in facilitating
social interaction and creating healthy inclusive communities”. There is much community concern because of adverse
impacts on amenities, parking and traffic, pollution, noise and heritage. More
than 200 people have voiced discontent so far, either by personal letter, (some
have made four or more responses, including some direct to McCarthy and Stone),
or by signing petitions. Eight residents attended and spoke at the LA Planning
Committee Meeting on 7 January 2013, when the proposal was refused consent. There
are 105 written responses, reflecting the discontent of 118 individuals, on the
Planning Office’s Public Access website.
McCarthy & Stone’s
Community Involvement Summary suggests a far more positive picture
of its efforts to involve and heed the community than the reality of the
community’s experience of dealing with company. A refutation of that summary is
included in this submission (See
Appendix 3). There were in fact a number of shortcomings: failure to
involve BVT residents until January 2012, avoidance of group meeting with BVT
residents, ignoring of dissatisfaction of Ash Grove residents after meeting of
May 18, emails from residents after 7 February exhibition totally ignored,
inaccuracy in use of statistics resulting in inflation of the number of
supporters of the development by c.10%, and a reduction of the real percentage
of objectors by an unknown amount.
With the exception of
the change to building materials and the reduction of windows on the Ash Grove
elevations, the amendments to the plans have been negligible. The size and
scale of the building (a major concern for residents) has not altered greatly.
In fact in the December 2012 amendment two protruding opaque bay windows appeared
to have been added to two floors the
South end of the building. A professional scrutiny of the amended versions
would show how little real change was made. At the last amendment stage the
recommendations of the Tree Protection Officer were flouted.
McCarthy & Stone communicated with the
residents via newsletter, not via individual replies to letters or to their
questionnaires. On the occasions when there were personal meetings (7 February
Exhibition, 18 May meeting with Ash Grove residents) objections were listened
to with apparent courtesy, but then completely ignored. They listened, but they
did not hear.
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