IT’S TIME TO OBJECT!

You can get your objections lodged in right up to the date of the planning hearing.

This is a huge urban conglomeration of Tall Buildings to be located immediately to the east of the Grade 1 Listed Buildings of Kemp Town. It is vital that as many people as possible object to this massively inappropriate development proposal.

Here is how to object:

• It’s best to compose your own letter or email. You should include your name and address and make it clear that you are lodging an objection. Some possible grounds are set below.
• Letters of objection should be sent to Liz Hobden, Head of Planning, City Development & Regeneration, Brighton & Hove City Council, Hove Town Hall, Norton Road, Hove, BN3 3BQ, quoting reference BH2021/04167.  Hard copies sent by post are acceptable and indeed preferable.
• Alternatively you can send an email with your comments on the application to planning.applications@brighton-hove.gov.uk quoting reference BH2021/04167
• Or thirdly you can go to the Council website https://bit.ly/3q7JnWA and register your objection.
  • Click on ‘Comments’ on the menu which appears
  • Click on ‘Make a Comment’.  
  • If you are already registered with The Council, fill in your email and password.  
  • If you are not registered, click on Register here and fill in the details requested.  
  • This will bring up your details and a box in which you can choose a number of options or write your objection.
  • It’s best by far to write your individual objection.  Be sure to click the objection option at the top of the box.
  • Once you’re satisfied with your objection, take a copy and click the Submit button. 
  • It would be a good idea too to forward your objection to all councillors on the Planning Committee.

Good luck and Thank you!

Here are some objection topics to help you.

1. The Kemp Town Estate – a Conservation Area of National Importance

Kemp Town is unique amongst Britain’s Conservation Areas in that virtually all the buildings within the conservation area are listed.  This development is less than 100m away from the Grade 1 Listed Buildings of Kemp Town.  It will have a severely detrimental effect on those very important Heritage Assets.

2. Importance of Heritage Assets and Harm caused by the Gasworks proposals

From Brighton Pier in the west to Marine Gate in the east, Marine Parade is one of the longest stretches of seafront in the country with a consistently high architectural quality along the whole of its length of about 1.6 miles.

There are some 216 Listed buildings and structures along its length, plus four locally listed, up to and including the Grade II listed French Convalescent Home on de Courcel Road, only a few yards to the west of the Gasworks site.

It forms the country’s most impressive marine façade.  It is a unique sequence of architectural excellence.  At the upper level this sequence includes the East Cliff Conservation Area with many listed buildings along its frontage.  Even the occasional modern building such as the Van Alen building is of high architectural quality.

It is vital that any development on the Gasworks site right on the eastern end of this parade of excellence matches the high architectural quality of the rest of Marine Parade.

3. City Plan Policies and the Urban Design Framework SPD

The City Plan does not include the Gasworks site within an area of the City where Tall Buildings (ie buildings over 6 storeys) will be permitted.  It is not included within the Marina Tall Buildings zone. 

As part of the draft Urban Design Framework SPD, there was a proposal to extend the Marina Tall Buildings zone on to the Gasworks site, but that was withdrawn in the final version dated June 2021.  So that was a clear indication that tall buildings could be considered only under exceptional circumstances.

The Berkeley/ St William’s Homes proposals include 11 tall building elements which range from 7 – 12 storeys, most of them way higher than 6-storeys:

            Buildings B & C –  Two of 11 storeys and one of 7-8 storeys

            Building D – 12 storeys

            Building F – 11 storeys and 7 storeys

            Building G – 10 storeys and 8 storeys

            Building H – 10 storeys

            Building I/1 – 7 storeys

            Building I/2 -10 storeys.

These cannot be described as anything other than a conglomeration of “Tall Buildings”. They occupy about two thirds of the built area on the site.

4. National Planning Policies

The NPPF (para 195 p.56) states that, “Local Planning Authorities should identify and assess the the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset) taking account of the available evidence and any necessary expertise.  They should take this into account when considering the impact of a proposal on a heritage assets, to avoid or minimise any conflict between the the heritage asset’s conservation and any aspect of the proposal”.

  It goes on to say that the greater the asset, the greater the weight should be given to the asset’s conservation (para 199 p.57).

It’s hard to imagine anything a greater asset in conservation terms than the Grade 1 Listed buildings of Arundel Terrace, Lewes Crescent, Chichester Terrace and Sussex Square just 100m to the west. 

5. Design – height, bulk, quality, sunlight, daylight, density overshadowing, open space.

The National Planning Policy Framework (NPPF) places great emphasis on quality of design. The proposed  buildings are too high, too bulky, out of scale and character with its surroundings, be of low quality design, will create deep canyons in shade most of the day, and will overshadow the residential areas to the east and west.  Most of the open spaces within it will be windswept and sunless.  And above all it is ugly.

6. Landscape – views and viewpoints

This huge development of tall buildings will be visible from miles around and have a very detrimental impact on the Heritage Assets adjacent. A Planning Inspector noted in a recent Appeal Decision that “buildings are not generally experienced from fixed viewpoints, they are seen in a sequence of views as the viewer moves through the locality.”

7. Lessons from the Marina Appeal

The Planning Inspector highlighted the way the Marina development would 

“….the proposal at issue would undoubtedly be a major intervention that would have a significant status this being in respect of those designated heritage assets near the site, that is Lewes Crescent (Grade I), Chichester Terrace (Grade I), Arundel Terrace (Grade I), and Sussex Square (Grade I), the Kemp Town Enclosures (Grade II Registered Park and Garden), and the Kemp Town Conservation Area, and the linked Esplanade Cottages (Grade II), Old Reading Rooms (Grade II), and Temple (Grade II), and the Madeira Terrace, Madeira Lift and Shelter Hall buildings (Grade II*) and the East Cliff Conservation Area….…the proposed development would have a very strong visual presence in some views of, and/or from, these important buildings and spaces, with implications for how they are experienced as heritage assets (IR11.28). The proposal would not therefore respond to its context in a positive way, and would not reflect the ambition of these groups of buildings and spaces (IR11.29). The very strong visual presence of a significant, but incongruous, complex, in some views of, and/or from these important buildings and spaces, would be jarring (IR11.29), in particular in respect of Lewes Crescent.” (Para 27 p.5)

These criticisms of the jarring relationship of the Marina proposals to the Heritage Assets in the immediate vicinity which were key to the Marina planning refusal and were endorsed by both the Planning Inspector and the Secretary of State, are even more relevant when applied to the relationship of the tall, densely packed buildings of the Gasworks development to those same Heritage assets described above.

The Marina Appeal decision has emphasised the importance of good design as set out in the latest version of the NPPF, together with the implications this has in determining the appropriate balance of benefits and harm.  The Marina  appeal decision has set a precedent by which all future and current planning applications for large-scale developments such as the Gasworks should now be judged.  That is of particular relevance to the Gasworks proposal.

8. Decontamination issues

Decontamination and its implications for public health during the construction period or even afterwards  is not something which would be a planning consideration.  It is a Health and Safety issue.  Nevertheless concerns about how the decontamination process is carried out and monitored is very much a matter of public concern and there is a case for using the public consultation process on the planning application as a way of drawing attention to those concerns.  It is essential that the decontamination procedure is carried out with full transparency and is discussed with the community – not decided behind closed doors.

9. Affordable Housing

There is NO Affordable Housing proposed in the planning application.  If one looks at the the Community Infrastructure Levy (CIL) document, it confirms that the proposal includes absolutely NO affordable housing.

Policy CP20 of the City Plan requires 40% affordable housing.

10. Community Involvement

A community survey was carried out by local residents during the summer of 2021 to ascertain the views of residents and to record their concerns about the Berkeley Group’s proposals and their preferences in terms of what sort of development they would like to see on the Gasworks site.   The majority of people who responded lived within half a mile of the site.

The survey respondents rejected the Berkeley proposals overwhelmingly.

11. Sustainability Issues

The development makes no attempt to aspire to the Council’s intentions to make the City carbon neutral by 2030.

The construction programme runs through to 2029.  By the time it is completed it will be utterly non-compliant with Council policy. In fact by its intensive use of concrete and steel in its construction it is not even up to date now with sustainable construction techniques that have been used in other cities for many years.

University College London has carried out authoritative research into the environmental performance of taller buildings.  This highlights the rapidly increasing rates of energy use and CO2 emission per sq.m. for taller buildings. From an optimum of compact development at 6 floors, CO2 emissions nearly double by the time buildings get to 20 storeys.  

For heating, it is proposed to use air-source heat pumps (which will be inadequate), backed up by gas boilers.  These won’t be allowed soon after completion.

This development is out of step with current and projected sustainable building standards.  

The area around Brighton & Hove has been designated by UNESCO as the Brighton & Lewes Downs Biosphere in recognition of its biodiversity and quality of environment.

The biosphere, known as the Living Coast, aims to conserve and enhance nature; support sustainable human development and promote environmental awareness, knowledge, learning and engagement.

And we have a Council controlled by the Green Party.  It doesn’t add up.

12. Traffic, Pollution, Parking and infrastructure

There are no proposals provided in the planning application for additional medical, education, parking, public transport facilities, all of which are currently fully utilised by current residents.  There are 553 new flats proposed.  That could mean up to 1500 more people living in a very small area.