How to begin to understand the Sackville Trading Estate planning application

16.04.19…..Way back when we were dealing with the Karis planning application for King Alfred one could talk to planning officers and ask questions and learn from them.  I learned this:
First things first
Begin by looking at the Planning Statement (if there is one).  This one also includes a Health Impact Assessment.  Look at the Design & Access Statement (if there is one).  For this scheme there are multiple parts in various places out of sequence with other documents so I give a link just to the documents page.That orientates you as to what they intend to achieve from the site.   These will give you the questions that come to mind and a sense of what to then look at.  Choose a subject area that has direct relevance for you, which impacts on you or for which you have expertise or can provide evidence. Don’t feel you have to give up because it is a lot of reading or too difficult.  Just look for what IS accessible and understandable and LOOK FOR THE MISTAKES AND FABRICATIONS!
Look not only at the bare bones description saying how many flats or units of housing are proposed.  A scheme may look like it would not be too crowded for the site but until you know how many BEDROOMS are in the flats you have not got a clear view.  This scheme of 260 Mayfield care home units for leasehold sale and some 600 or so Moda flats for rent have multiiple bedrooms in many of them.  And some bedrooms will accommodate couples or a few children!  The Application Form is a quick source of key information.  Add up the number of bedrooms to see what the minimum population of a site is likely to be. 
Ensure you follow the progress and further uploading of documents and changes to schemes, especially if readvertised because of significant changes as happened on 26th March for this one.  Sadly no revised Application form has so far been provided so that the increase in 2 and 3 bed flats can be offset or calculated against the reduced number of flats! 
Properties adjacent to any redevelopment site or likely to be affected by overshadowing or overlooking will be included in drawings and the identity and use of rooms behind windows guessed at.  Every use has a distinct value in Planning and some windows have more clout than others.  Make sure yours is correctly identified in drawings.  If there is a big threat it could be worth your while challenging their claims by hiring an expert to do it for you.  This is a key area where you need to be able to provide evidence to back up claims.
Look at CGI photomontage pictures of how fabulous the applicant has made their scheme look.  Notice things like how big the trees look and what they are there to hide.  On April 12, following readvertisement, a set of comparative CGI views were uploaded that are pretty jaw dropping.  Scroll on down to see them!  And marvel.
1.  The clusters of grey stumps all have tidy flat roofs….no sign of lift equipment bumps, receiving equipment or other maintenance access equipment.  And rooftop furniture is always ugly. Where is it if not visible?
2.  Look at the views from Old Shoreham Road across the big carpark by Furniture Village.  Suppose the owners of the carpark decide to build something there.  All those Mayfield windows I see in these CGI’s tell me THEY would be able to block neighbouring redevelopment on light loss and privacy grounds because of being so close to the boundary or to at least force a much reduced use of sites.  Same goes for Newtown Road and all those little employment spaces.  What if they wanted to demolish and build higher?  The plans for Sackville Trading Estate compromise future land use adjacent in a big way.
3.  Look for how the scheme will impact the area visually and ask if it is in keeping with Listed buildings or important areas.  How does it impact the character of the area?  The Conservation Advisory Group have concerns about the views from Hove Park which would see these big grey stumps looming like broken teeth between the park’s trees.
Most people just complain about parking issues and heights.  You can do MORE.  Look at other issues.  Get ideas from a quick look at the above!


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BH2018/03697 The Sackville Trading Estate application….some guidance

14.04.19…..Since the end of November, after I writing the 2018 posts on the Sackville Trading Estate scheme proposed by Moda and  Maycroft,  the planning application was registered and put out for consultation.  On 26th March a site notice went up readvertising it due to significant changes to the scheme. 
The biggest change was to the trackside tower heights and their positions and a reduction in the number of housing units (but an INCREASE in the number of 2 and 3 bed flats).  See the post below concerning population proposed vs number of units of housing. 
It is majorly important to understand that opinion does not make much difference to outcome – even hundreds of them.  Unless attention is given to document claims and plans; and consultation responses relate to what is advertised, planning officers cannot actually DO much with your opinion, except log it.  It is not for residents to pour over ever line and word.  That is the officer’s paid job.  But you CAN look at things in some kind of order that helps make sense of it all.  And you CAN assemble photographic evidence and EMAIL IT with a covering letter discussing your point. It can be wise if affordable to hire a planning consultant to represent a specific area’s interests.
1.  So what should you do at this point?  Sackville Road is a major issue.  So is Old Shorehame Road and the junction.  You will know that the junction was recently redesigned and how that is working out.  With only one vehicle access/egress point into/out of the Sackville Trading Estate, all traffic in and out of the proposed new scheme would pour into the existing load.  Take timed and dated photos of traffic volumes, parking etc. and set your findings against the applicant’s claims if you think they are wrong and you are right.  Prove it!  What issues do they fail to take into account? 
It is worth looking at the Maycroft part of the scheme too.  How many elderly people paying £400,000 for their sheltered leasehold flat there (thank you Francine for getting that info at the exhibition) will be satisfied with a bicycle rack instead of a car parking space?  I love the idea of a minimal-care home with facilities on tap that is central instead of stuffed away out of sight on the urban fringe.  But this on its own with 260 flats would be burden enough on that site without all the rest that is planned. 
As well as this scheme, eventually Sackville Road will have to accommodate whatever gets built at King Alfred.  The council cannot overlook that!  Look carefully at the staircase from Sackville Road and the mooted pedestrian bridge over the tracks.  They are only ideas….and it would be either/or if money was found and Network Rail was on board….
Go to the documents list and keep up with responses there.  In particular read the responses from official consultees like Southern Water.  Apparently a water main runs right up the middle of the site – I read – and the present plan cannot be allowed on top of it…..etc.  And what about GP provision?  Where is the NHS response that actually says whether there is capacity at any practice in the city?  I wrote a post below this one about that.  Snorted my contempt actually.  The CCG says they can say nothing as practices are privately run!  I have asked before that practices be consulted and it does not happen.  And they continue to close, one by one.  Where is the evidence going to come from to say that the 1,500 to 2,000 residents will be able to get a GP?  For the elderly especially this is an issue that Maycourt MUST address.
There is pre-application advice and feedback.  Maybe.  There is an exhibition.  There is a pre-app viewing by Planning Committee who can comment.  Maybe.  The application is submitted and then it begins.  Officers scrutinise.  The public scrutinise (or just kneejerk react and wail).  Official consultees scrutinise. And there is formal feedback as battle is conjoined.  Maybe there is media attention too if scarce resources allow or demand coverage.  The number of letters to the Argus used to help them decide.  Nobody bothers writing them now!  Minimal involvement gets minimal results.
Like Game of Thrones there is a battle.  And it is about conquest.  What the applicant wants, they will take unless challenged.  It means effective planning officers are needed who won’t be browbeaten down when they have a too big workload.  Internal consultees who won’t just bend the knee and keep shtum about issues.  A public paying close attention and catching everyone “at it”.  Councillors capable of making the officers accountable for their recommendation to Grant or Refuse and Reports’ content.
There is an ongoing upload of new material, comments and readvertisements, etc. that MUST be kept in mind and followed.  You are not done after a first look and a consultation response.  You can ADD to your existing comments and make new ones.  Whatever you submitted before March 26, you need to now comment on the changes to the scheme.  Other changes are inevitable too.  The conversation, the negotiations, it all goes on – even after the decision by officers under delegated powers or by Committee.  There is the s106 agreement, the Community Infrastructure Levy, the list of Conditions to be met and  discharged.  This last may include the Construction Management Plan that MUST involve residents.
Residents on Sackville Road could usefully look at how overbearing the appearance may be, how the overlooking and light loss can be demonstrated.  Do drawings correctly identify your windows for use?  That matters as use determines values and impact allowed.  Residents in the side streets need to worry about visitors and residents for the scheme seeking parking spaces.  Are you all resident permit only?  If not you have a problem.  Are you someone who cannot find a GP to take you?  That is evidence of an issue.  Choose something that affects YOU first and deal with other issues secondarily.
If you have Thousands of Pounds going spare, hire a good Planning Consultant for this one!  But remember they judge the documents against the NPPF, City Plan policies for compliance – same as the officers – and cannot provide or replace personal/local expertise/knowledge.
City Plan
Look at City Plan policies DA6 and SA6 (Sustainable Neighbourhoods).  These policies SHOULD dominate but all decisions are “on balance” which means policies are a maybe.  Quote to back up any point you want to make.   Look at other policies if you have the time and will!
Previous Consent for this site
It is useful to know the facts around the precedent planning consent (P2 renewing Parkridge consent) and what issues were identified.  Look at the Reports (esp 5.17 of this one), documents for the previously approved scheme to know the unresolved issues that could snag this development.  Look at the Conditions attached to consent and the s106 agreement.
Don’t forget to ensure you have Ward Councillors on board to speak knowledgeably for you at Committee.  This is why your vote in May is important.  You need useful & knowledgeable  Councillors!  The next Planning Committee meeting is May 15 but I would not expect this application to be ready for it.
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Kicking GP provision into the long grass….official Planning Apps consultee failure

13.04.19…..When I read the Clinical Commissioning Group response for the Lyon Close application I put in a response for saveHOVE asking that the Planning Department consult the Charter Medical Centre and the new Trinity one in Blatchington Road in the converted Holy Trinity church.  It didn’t happen.  Now I see that particular response has been forwarded by the case officer to the current Sackville Trading Estate application documents list.
The closure of a lot of GP practices has put a staggering level of pressure on those remaining who have to add those patient lists to their existing.  And nobody is asking these practices if their lists are open or what spare capacity they have?  Responses like my example above are simply filed and the issue of GP provision is shrugged away.
Applications may well include a slot for a GP, or ‘wellness’ or other health type provision but, without an NHS consultee letter welcoming it and some GP’s lined up to swan in and guarantee provision for a de minimus number of patients, it is just ‘bull dung’.  And you MUST object.  You must NOTICE and object to the failure of consultation about this vital bit of infrastructure that is not being dealt with because there is no public outcry and GP’s are probs totally unaware of planning issues in their catchment area.
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Sackville Trading Estate: Assessing potential population proposed!

13.04.19…..Look at this from section 16 of the Application Form.  And do the maths.
262 one-bed units plus 402 two-bed units plus 114 three-bed units added to 112 studio/bedsits equals a minimum of 890 individuals in the total of 613 units of housing specified.  And some of those bedrooms will have more than one occupant.  Lots will.  Couples. Children.  But this application form is no longer even valid!  And a new one has not, as I write, been provided to account for changes advertised on a 26th March site notice.  The care home is on top of that.

Add up the number of bedrooms to assess minimum likely populations.

This original Moda Application Form is no longer valid.  It calls for 613 units of C3 housing (including 10 live/work units) and 265 C2 care home units; but following the readvertisement of BH2018/03697 (site notice dated 26.3.19) these figures no longer pertain.
The downward revision has 581 C3 units, 10 live/work units and 260 C2 care home units.  This followed from reduction in building heights.  But no revised application form has been uploaded.  But look at this! Within this 25th March covering letter about revisions is a statement that means there must be even MORE bedrooms (and a higher population to be expected) than before, in spite of the reduction in the number of flats!  I quote: ” Revised housing mix to provide an increased number of two and three-bed homes (54% studio and one-beds and 46% two and three-bed homes) “.
It matters because reading the  Application Form is a fast way of gaining a real sense of what is proposed and it MUST be correct.  Today a saveHOVE objection was lodged concerning the failure to upload a revised Application Form.
Since 26th March some 581 C3 residential units are now proposed with 10 live/work units housing; but  HOW MANY PEOPLE?  The care home now proposes 260 units; but HOW MANY PEOPLE?  It’s a LOT more than the units of housing figure suggests and not many people realise that because they do not look.
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Oh dear, oh dear, oh dear….. BHCC shafts Hove Library again

01.04.19…..I keep saying I am no longer well enough to keep tabs on every planning application….and I left this one to those dedicated to safeguarding Hove’s Cargnegie Library interests.  It is a Listed application to install intrusive modern emergency exit equipment on the main historic front entrance door within the lobby.  But there are NO DOCUMENTS ONLINE, and there are NO PUBLIC COMMENTS ONLINE, and only one official consultee, the council’s virtually non-existent heritage dept.  THE COMMENT IS NOT ONLINE on the Planning Register.  See this page on the planning register
1.   As I have said before, ward councillors get the planning lists for their ward each week, but even without Cllrs Moonan and Wealls telling anyone who needed to know, no site notice was seen by campaigner Christopher Hawtree.  Was there a site notice?  The fact there are NO DOCUMENTS online for this application begs the question! What does this equipment look like and what alternative is there to junking up that Grade 2 Listed door with it?  Where is the justifying documentation? Not one word is online.  Not one word.
2.   Were there ANY public consultees for this Listed Application?  Nothing online suggests it.
3.    Was CAG consulted?  There is no comment provided by the Conservation Advisory Group within the Report to Committee either.  This is a serious ommission.  They have a co-opted, non-voting advisory seat on the Planning Committee but there is no evidence online that the Planning Department informed CAG about the application, that CAG has seen it or commented in any way.
4.  Worst of all, the all-party working group of councillors tasked with overlooking the library’s interests WERE NOT CONSULTED.

The whole sorry thing only gets to be made public at the Planning Committee and only if the Committee have a clue what questions to ask or notice what is missing.  WHAT IS NEEDED IS DEFERRAL AND PROPER CONSULTATION!

Without anyone having seen a single drawing or photo of what is proposed, the application is going to Planning Committee members on Wednesday this week for decision, recommended to grant.  Why has the worst Chair in the history of the BHCC Planning Committee – a trained former Brighton planning officer – allowed this onto the Agenda? Preston Park Cllr Julie Cattell:  j’accuse!
Democracy.  Dont’cha just love it.  What a dirty great corpse it now seems to have become.  And will any committee Member bother with the glaring holes in the Report where information should be?  Some pride themselves on never reading an email alerting them about upcoming application issues – preferring to rely entirely on officer reports and their own (sometimes baffled) game-show like questionings.
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