Objection to First Base’s Edward Street proposals

We had previously criticised First Base, the developers, for their poor public consultation procedures in relation to the preliminary proposals for the Edward Street site – see http://www.brighton-society.org.uk/edward-street-quarter-an-exercise-in-public-obfuscation/

Following submission of First Base’s planning application, we lodged an objection – see the full text below.

After our initial article was published we had a request from First Base for a meeting, to which we replied saying we were always ready to have a constructive dialogue. But true to form we never received a reply.

Our primary concerns with these proposals are:

1.  the poor quality of the public spaces, particularly the lack of direct sunlight which will make them sunless and unattractive;

2. the excessive height and bulk of the buildings which are not much lower than the Amex building just to the north, exacerbated by boxy, unimaginative design, which, particularly in conjunction with the Amex building immediately to the north, will result in a conglomeration of tall bulky buildings with an overbearing impact on the skyline when viewed from important viewpoints, particularly those from the west.

Poor presentation

Besides the poor quality of the proposals themselves, the application is badly presented and drawings and images inaccurate or misleading

Inaccurate location plans

 You wonder how much care went into the preparation of the planning application when the plans showing the Conservation Areas adjacent to the site and the Heritage Assets Plan show their site in completely the wrong place – just to the south of Queen’s Park!

Inaccurate elevations

As well as this, some elevations are inaccurate and show the building lower in relation to the Amex building immediately to the north than it actually would be.

Poor quality images

The CGIs submitted with the application show distant views of the new buildings.  Particularly those from the west – from Pavilion Gardens and Queens Road, they are of such low quality as to be almost meaningless.  Obfuscation again? Yet these are important views and the impact of the new buildings from the City’s historic assets need to be shown clearly so we can see what the impact would be.

Misleading information

One drawing shows new trees at the Northern end of Mighell Street between the site and Mighell farmhouse.  We asked during the public consultation stage if they were part of the proposals and were told they were not. Yet they are still shown on the planning application documents.  Misleading or sloppy presentation?

Yes, these are minor details – but after what appeared to be a deliberate attempt to conceal the actual heights of the buildings during the public consultation stage, it seems to follow a consistent pattern.
Like the design itself, First Base’s performance throughout does not reach the high standards that the importance of this site justifies.

We accordingly decided to lodge an objection to the planning application.

Council’s failure to register our objection

Following our concerns about this planning application, we lodged an objection, but to compound our concerns about the public consultation process and the scheme itself, we noticed that our objection had not been registered on the Council Planning Department’s website. We asked why not and were told the Council has been having some recent problems with the Register not updating.

This raises some serious questions, particularly as the Council has claimed in the past (most recently in relation to Hove Library) – see https://www.brighton-society.org.uk/further-row-over-hove-library/  that when less than 5 objections are received, an application does not have to go to committee.  We need to know the answers to the following questions:

• Was ours the only objection affected?
• Does this problem affect other planning applications?  Presumably, from the Council’s response it does.
• What happens in a case where objections are not registered – with the result that the Council could claim that less than five objections have been received, and the application need not therefore go to committee?
• How can we know how many objections are made when the system for registering objections is  not reliable?  How does the Council know?

The system has to be reliable otherwise confidence and trust in the Council to operate in the public interest is severely diminished.

Our objection

BH2018/00340 Former Amex House Edward Street Brighton
The Brighton Society wishes to object to the plans proposed in this application. We have two main reservations about the proposals:

(i) The poor quality of the public spaces, particularly the lack of direct sunlight which will make them sunless and unattractive;
(ii)   The excessive height and bulk of the buildings, exacerbated by boxy, unimaginative design, which will result in an overbearing impact when viewed from important viewpoints, particularly from the west.

Quality of the public spaces
Our concerns relate to the quality of the new public and private spaces, as the buildings appear to be too high relative to the sizes of those spaces, resulting in them being in shadow for much of the day.
A tall commercial building is proposed on the west side of the new thoroughfare to Mighell Street, between that and a new public square proposed just to the south of the new Amex building. This public square is separated in turn from John Street to the west by another rather tall building.
The new Mighell Street north – south thoroughfare will be in shadow for much of the day which will result in a sunless canyon which will be very different in feel to the sunny spaces illustrated in the architect’s sketches.

Likewise the new western square is likely to be particularly vulnerable to future development of the building on the corner of Edward and John Street (outside the scope of this proposal).  Any future development of this site is most likely to be higher than the existing building. This, together with the tall buildings to the south and west proposed by this scheme, is likely to overshadow the square completely for much of the year in the future, seriously compromising its potential as an attractive and popular public space.

The overshadowing diagrams clearly indicate that for most of the year most of the public spaces and thoroughfares will receive sunlight only for a short period around the middle of the day.  If these public spaces are to make a significant contribution to the quality of the city’s environment, the new buildings should be considerably lower than they are proposed to be at present.  The site is being overdeveloped.

To the east of the new pedestrian space are residential buildings varying between about 3 storeys at their south-eastern corner to much taller buildings towards the north-eastern end of the site. They are separated from the existing terrace houses on White Street by a garden space which will be private for residents’ use only.  This garden area, together with the west-facing gardens of the houses on White Street will be in shadow for much of the afternoon during the spring to summer period.  This is not only poor design in terms of the new housing – it will also have a severely detrimental effect on the quality and amenity of the existing gardens to the White Street housing.

Height, bulk and design
We consider the design and appearance of the proposed new buildings to be unsatisfactory, and potentially detrimental to heritage assets in neighbouring conservation areas and elsewhere. The highest buildings, fronting Edward Street, appear from the plans to be eight storeys high, the building on John Street to be six storeys. Besides being too high, the buildings appear very boxy. This is particularly so when they are considered in relation to key potential viewpoints and surrounding high points, particularly from the west.

The upper floors are the ones which tend to be most prominent from viewpoints, so a more graceful profile where floors are stepped back as they get higher and are treated in a finer, more transparent style, would not only reduce the apparent height and mass of the buildings but would also make them look more attractive.

We are concerned too at the bulky and boxy character of the proposals on views from several points within the city, such as from Dorset Gardens just to the south, views from Valley Gardens as well as from the Royal Pavilion, and from high points from the west such as the upper parts of Church Street and North Street.  The views provided in the planning application are very blurred and give a completely misleading impression of what these bulky and out of scale proposals will look like in reality.

Finally we would like to see – as part of the proposals – the landscaping quality proposed for the new north – south route extended to include the upper part of Mighell Street and up to the listed Mighell farmhouse in order to better integrate the new street into the existing townscape to the north.

Overall, these proposals need to be much more sensitively designed and must get the balance right between the new buildings proposed and the attractiveness of the public spaces they enclose. At the moment, that balance is tilted far too much in favour of buildings that are too high and bulky in relation to those public spaces.