March 2007 Objection

King Alfred/RNR site development, Hove
Objections of the Regency Society of Brighton and Hove
 

Improper Procedure
We are extremely concerned about the procedure adopted in dealing with this most controversial planning application. The City Council is both the land owner and Local Planning Authority. To deal with possible conflicts of interest, a “Chinese wall’ was put in place. Whilst members of the Planning Department , including the Chief Planner, were involved in the formulation of the brief and the planning policies in the Local Plan, the development control staff was kept separate and was not involved in these discussions. This separation is difficult to achieve and needs great care. But now we see the date of the Planning Committee advanced so as to occur only two days after the closure of the consultation period with the report being sent to members before the period has expired and, more seriously, the report and recommendations have been prepared by the City Planner and not by the Case Officer or Development Control Manager. It is quite clear that the “Chinese Wall” has broken down. We submit that it would be improper for the application to be dealt with in this way. We require that consideration be postponed until it is clear what view the relevant development control staff take.

New Information
On the basis of the new information submitted in February 2007, the Society sees no reason to withdraw the strong objections it made in November 2006.

Based on the new information it would make the following further representations

Description of Development
The proposed development will include two 100KW Combined heat and Power boilers. These boilers will have flue stacks located on top of the two towers being approximately 95m above ground level. However, no plans showing these have been submitted. They need to be part of the scheme BEFORE consent is considered leaving this to be dealt with by condition is unsatisfactory. We have all been shocked by quite unacceptable additions to the roofscapes of buildings.

Air quality
The new information states that the scheme will have a negligible impact on the area following the use of the AEROMOD model. But this is an assertion; no details have been given.

Ecology
We note that the peregrine falcon nesting facilities have been removed because of the proximity of wind turbines. This is one more example of disappearing promises.

Microclimate
We note that “it was agreed not reasonable to consider building or cladding noise in this Environmental Statement. We are not aware of a precedent whereby planning has been granted or refused upon this particular issue. Nevertheless, we agreed that wind-generated noise is a real phenomenon that can produce adverse environmental impacts, both inside and outside buildings. As such, wind generated noise could be an issue that might be considered in future Environmental Statements. However, it should be noted that at present we are not aware of any generally available practical advice or criteria that would allows such an assessment to be carried out.”

This means that additional problems from wind noise are expected but as no one appears to know how to assess them, the issue will be ignored. This will lead to potential problems for residents in the future. Similar problems were reported to have arisen at the Beetham Tower in Manchester.

We have also noted the inclusion of mitigation measures for wind impact in the internal plazas. This reinforces our view that they will be dark, and unpleasant spaces dominated by high-rise buildings surrounding them.

Overshadowing
We note that the council’s adviser and the applicant’s expert “ were unable to agree on the classification of impacts for loss of daylight to the different buildings affected.” We remain convinced that impact on daylight and sunlight will be unacceptable.

The new information states “There has been some concern raised over the potential for solar glare or dazzle produced upon the sloping roof of the development fronting Vallance Gardens. At the time of the initial assessment no details were given of the cladding to be used on these roofs. It is now understood that this section of the roof is to be clad with a painted metal that will have a low specular nature. In this case any potential solar glare effects will be mitigated by the cladding material.”.

We are concerned about this issue which has arisen at the Gehry building in Los Angeles. And in particular we are fear that a painted surface will create problems for a such an exposed, sea front complex.

Public art
We notice that it is now proposed that an approach to public art had been agreed with Paula Murray, the Head of Creative Arts and Industries. It is accepted that the Frank Gehry design will constitute public art and the strategy will be to further express this in the final detailed design, focusing on the incorporation of artistic influence across the piece. It is not proposed to have stand alone pieces of artwork and as such there will be no environmental impacts to assess either cumulatively or collectively when considered with other aspects if the scheme.

So the promise to use Antony Gormley, which we strongly supported during early meetings between Frank Gehry and the Council’s consultative panel , has also disappeared.

Cumulative Effects
It is stated that “There are areas around the site where the effects of the development may accumulate. In conditions where winds are from the south and southwest areas to the west and east of the scheme may experience increased wind speeds. In areas to the east of the site along St Aubyns South there may be areas where wind speeds act in accumulation with shadowing effects to affect amenity of the area relative to that which currently exists. The complexity of wind speed, orientation, time of day and general weather and temperature conditions make it difficult to determine the magnitude of the effect. However the area is used for walking and is an area that already experiences windy exposed conditions and experiences a degree of shading therefore the accumulation of impacts is likely to be minor in nature.”

These assertions seem to boil down to the the opinion that the seafront is windy and therefore exacerbation of windiness and shading is acceptable.

Michael Ray
Chairman
Regency Society of Brighton and Hove
16 March 2007

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