King Alfred Development
November 2005

Representations of the Regency Society
The Society believes that the King Alfred/RNR site does need redevelopment and this offers an opportunity for a major addition to the architectural heritage of the city. It welcomes the decision of the developers to engage a team of considerable reputation at national and international level. However, it is convinced that the choice of this team, led by Frank Gehry, should not lead to a suspension of a normal critical appraisal of any proposals put forward.

Facilities
We do welcome the range and scale of the sporting facilities provided for residents and visitors to the city. But we believe that the scheme should demonstrate adaptability as leisure facilities are particularly prone to changes in fashion and new directions.

Impact on the area and neighbourliness
Our major concern is about the impact of the development on its neighbours. The ten storey blocks on the south side of the Kingsway and the west side of St Aubyns South will have a devastating impact on the residents of existing residential buildings.
They face a wall of buildings and have their sunlight and daylight reduced to an unacceptable degree. The applicants in their submission state

‘1.99 The daylight results show that there will be some reduction beneath the BRE Guidelines, particularly to the properties at 1-8 St Aubyn’s Gardens. Some reduction beneath the BRE Guidelines is likely to be acceptable, due to the dense urban location of the site. It should also be noted that many of the surrounding properties currently enjoy an uncharacteristically high level of light amenity due to the open aspect of the site as existing. The impact to daylight will be minor to moderate.

1.100 In relation to sunlight, properties north of the Kingsway again enjoy particularly high levels of existing sunlight. The scheme will reduce the sunlight to some of these rooms beneath that recommended in the BRE Guidelines. The impacts to sunlight will be minor to moderate.

1.101 In relation to transient overshadowing, there will be relatively little overshadowing during the summer months. However, for the winter months there will be an increase in transient overshadowing, particularly to the properties north and east of the site. This is not unusual for an urban environment.’

Thus we have the situation that residents, who at present enjoy an excellent degree of daylight and sunlight, will be asked to accept a lower standard than the minimum recommended because they are in an urban environment. This adds insult to injury. The proposals are contrary to policy QD27 of the adopted Brighton and Hove Local Plan 2005.

(In this connection the Society considers that the photomontage, referenced CPM 9, is grossly misleading in showing the impact of the of the tall slab buildings on residential properties on the north side of Kingsway as the viewpoint is taken from a position a significant distance to the West of Hove Street. If it were to represent the true impact, the viewpoint should be close to the traffic lights)

Urban and Architectural design
The site adjoins the Cliftonville, Old Hove, Pembroke and Princes Conservation areas . Whilst one of this area’s characteristics is that, unlike other parts of Hove, the is no dominant architectural style it is an area which is predominately residential set around a Victorian grid pattern of streets. There is a mixture of well-proportioned, elegant Victorian and Edwardian houses and flats on land which slopes gently to the shore giving many of the residents an open prospect of the sea. The overall attribute of the area is one of openness for both residents and visitors. Any overdevelopment will destroy this ambience. Relating to these considerations, we have a number of strong concerns and fears about this scheme.

Judging the architectural merits of the scheme is bound to be subjective. The two towers have a sculptural, if eccentric, appearance. As shown in the submissions, they have a delicate white, lace-like, almost cut-paper appearance. On the montages, the viewer gets the impression that he/she will be able to look through the building but structural floors, vertical partitions, furnishings, curtains etc. will inevitably block these views removing this feeling of lightness. There is a lack of clarity as to how the towers will work in practice and how they will appear in reality. This should be made more explicit before a judgement can be reached on whether this part of the scheme is acceptable.

Where the buildings abut the promenade, there is no detailing of a human scale. Instead the eight-eleven storey buildings appear to rise straight up from the back edge of the promenade with no concessions to the quite different scale of people enjoying the promenade. There appears to be nothing to encourage people to venture close to the proposed new buildings. On the contrary where the flats abut the promenade, people will feel it would be rude to venture too close. They will feel pushed away by the scale of the buildings. The ten storey block facing west over Hove Lawns will be a slab-like wall dominating and reducing the visual scale of the open space. This conflicts with policy QD2 of the adopted Brighton and Hove Local Plan 2005.

Whilst we welcome the inclusion of piazzas with south facing entrances, we consider that, as they would be hemmed in by 10 storey buildings, they will become dark and overlooked working more as draughty corridors than pleasurable sitting out areas. This is contrary to policy SU2 of the adopted Brighton and Hove Local Plan 2005.

We do have concerns about the use of colour as shown on the submitted plans. The use of most colours is driven by fashion and, as such, can become quickly dated. But other colours are so abrasive and extreme that they are offensive to their surroundings. We feel that the garish colours used for the landward frontages of the sports centre will add a jarring note to viewpoints in the residential areas especially Vallance Gardens? In this context we note that, according to Hugh Pearman in The Sunday Times, Gehry himself had favoured a more subdued colour scheme but was ‘urged to be more extreme by the government’s advisors (CABE)’. This is said to reflect the ‘lively, slightly louche nature of the seaside city’ but that is not the tradition or context of Hove. As it now stands, the proposals are contrary to policy HE6 of the adopted Brighton and Hove Local Plan 2005.

Private Amenity Space
Although the scheme includes over 700 flats, there is no private amenity space as required by policies HO5 and HO6 of the adopted Local Plan. This will leave the residents of the flats and their children without safe play space near at hand.

Traffic
Despite the proposals for car sharing etc and the generous assumptions made for the use of other forms of transport, there will also be very significant amounts of extra traffic. The applicant’s consultants estimate ( Table 22 of Appendix C) that there will be an additional 4519 trips daily generated by the development onto a road (Kingsway) which was intended to be relieved of traffic when the A27 by pass was constructed. This additional amount of traffic will conflict with policy TR1 of the adopted Brighton and Hove Local Plan 2005.

Infrastructure
Policy SU15 of the adopted Local Plan requires new development to be compatible with existing or possible new infrastructure. We are not clear what work has been carried out by the City Council to determine what thresholds apply to present levels of infrastructure. How much new development can the Victorian sewage system absorb. This major scheme could have very significant consequences for drainage and water supply unless the Council can show that it is within the limits of present capacity.

The amount of development
We have come to the conclusion that the scheme is flawed and that this stems from the amount of development proposed. This is a result partly of the brief. The City Council expects the developer to provide both high quality sports facilities and affordable housing on a site which has difficult physical conditions. This is a recipe for overdevelopment. Our view is confirmed by reference to the Adopted Local Plan where the amount of development expected from the site is put at 300 units (Table HQ1) and 200-400 units (Paragraph 6.99) rather than the 754 units now proposed. The scheme, therefore, puts forward almost double the maximum figure set out in the Local Plan.

Conclusion
The Society feels very strongly that the present scheme is unacceptable and should be refused. However, if the City Council is minded to approve it, the Society feels even more strongly that the scheme ought to be ‘called in’ and be the subject of a public inquiry. This is not only because of the controversial nature of the proposals, but the need to be seen to be completely above board when dealing with a major site owned by the City Council.

A way forward?
We would be reluctant to see the loss of the benefits arising from the scheme. However, the amount of development could be reduced. One possible solution would be to remove the affordable housing from this site and to provide it on another site owned by the City Council elsewhere in the city. This strategy could be achieved by legal agreements with the City Council as land owners and a section 106 agreement with the City Council as Local Planning Authority. This would enable a less dense and more neighbourly scheme to be planned for the site