Northcliffe officer reports not accurate and misleading

2017/00541/FUL Northcliffe Lodge Penarth going to the VoG planning committee cmte on Thursday 

I wrote to the Planning committee today after reading the report shocked at the sloppy inaccurate reports from VoG council officers. 

I wish to oppose this development and draw attention to bias and misleading inaccurate statements in the report to the planning committee. Inaccurate and misleading reports should be challenged and this application rejected again or at least the reports of council officers should be rewritten in an objective honest manner. The developers' reports are clearly biased (see that on accessibility below), making objective reports by the officers vital.    

1. The CADW report states "We do not provide an assessment of the likely impact of the development  of the development on listed buildings or conservation areas, as these are matters for the local authority.

The report actually states "Cadw were consulted and having carefully considered the information provided with the planning application, confirm that the advice given in the pre-application response to LRM Planning on 13 April 2017 remains unchanged. The proposed development is located within the vicinity, c300m to the south, of the scheduled monument known as Penarth Churchyard Cross (Now in St Augustine’s Church) (GM227); as the name suggests located within the church itself. There are no other designated historic assets in the vicinity and so no historic assets will be affected." This statement in the report suggests that CADW approves the application . The CADW report is not on the Planning website  http://vogonline.planning-register.co.uk/PlaRecord.aspx?AppNo=2017/00541/FUL

2. The comments from the 'Councils Housing strategy team' are misleading. The number of units of affordable housing should be 40% = 12 which may or may not include 2 units of actual social housing and there is no explanation why onsite contributions are 'usually favoured.' or any statement of the amount. 'Contributions' are a developers massive get out clause permitting them to carry out financial viability assessments for their proposed developments, which often conclude that meeting the affordable housing targets set by local authorities would reduce their profits to a point that the scheme would be worth their while. However those assessments are kept confidential, with even Councillors unable to see them. In order to make sure schemes goes ahead, the local authorities typically reduce their targets or accept payment from the developer in lieu of the affordable homes. That money is supposed to be invested into social and community projects, or the council’s own affordable housing schemes. 

The  'Councils Housing strategy team' give no amount, however a report to the Penarth town council  put the offer at a mere £300,000. Penarth Cllr Luxton  said that “no real evidence” had been provided regarding the issue of the ground and footings which was one of the reasons which the developers had given for reducing what would ordinarily be a Section 106 payment of £1,100,000 - £679,000 should be the contribution towards social housing . On top of that should be  £209,000 for education, £29,000 for community facilities,  £68,000 for open spaces, plus another 1% for art.

The inadequate misleading statement in the report to the planning committee - 

"The Council’s Housing Strategy team were consulted and have advised that there is substantial need for housing in the Penarth area. One bedroom Two bedroom Three bedroom need Four bedroom need Penarth 261 175 68 16 There is a need more affordable housing in Penarth, and an onsite contribution is usually favoured. However on this site we would prefer to take the full off site contribution if approved by Members. The reasons for this are that it would be very difficult for a social housing landlord to manage two units within a large block of market properties and also the service charges could over time with unrestricted increases make the units unaffordable even if they were not at the point of purchase"

3. Highways response is misleading and inaccurate on 'sustainability'  They state that the councils parking standards allow for a relaxation of the site if the location has good access to local services and other modes of transport but this site has NOT good access to local services and other modes of transport and with extremely steep routes to services.  

This evaluation has been made by Vale planners contacted the developers, who submitted a “score-sheet”.  This claims that there are public facilities “within 200 metres  walking distance of the site (>two)” but FoE points out that there are none.  Headlands School is 250 metres away and that is not a public facility. The Clive Pub and Paget Road pocket park are both 300 metres walking distance away. The developers say Windsor Terrace bus stop is“750 metres walking distance” away from Northcliff –  yet tracing the route on Google maps gives a distance of 850m –  which is above what is 800m maximum scoring distance. The developers’ claim for exemption from parking standards on grounds of ‘sustainability’ is wrong: their allocation of 42 parking spaces is over 21 below the “one-parking-space-per bedroom” standard (plus 1 casual visitor-space per 5 units.  The Highways statement "scores well on sustainability points" is wrong (copied/pasted from the January officers report which was challenged). The only evidence provided is the developers score-sheet shown as above to be false. How is it that the officers have brought the report to Committee without making their own check on the sustainability claims?  Let us see their own list of facilities and their own scoring as we asked in our objection.   

Highways statement in the report to the planning committee "The Council’s Parking Standards SPG require one space per bedroom, and this equates to two spaces for each of the 24 two bedroom flats and 3 spaces for the 6 larger units. Six spaces are required by the standards for visitor parking, based on a requirement of 1 space per 5 units. However, the SPG allows for a relaxation if the site is located sustainably, with good access to local services and other modes of transport. The site scores well on sustainability points due to its close proximity to bus stops, a public house, schools, a restaurant, public open space, community hall and a church. Consequently, the parking requirements are reduced in accordance with the SPG to 1 space for the 2 bedroom units and 2 spaces for the three bed units, which is a total of 42 spaces including visitors."

Proper enforcement of the Council's parking standards (as was done for the adjacent development in Mariner Heights) require 72 parking places.  These proposals are short by 30 parking spaces.  This shows the developer has tried to cram over-many apartments onto the site.  The failure to provide adequate parking space - and the overflow implied onto neighbouring roads - is a further reason for rejecting the application.  

4. Stunned by the 'conservation' officers report.  

He acknowledges a presumption in favour of preservation of a listed buildings settings then proceeds to ignore that advice, without any reason of "public interest" for ignoring that presumption. He fails to refer to the photomontages showing trees above the Custom House replaced by apartment blocks. He is misled by the developers assurances and perhaps the developers own report on heritage matters, which wrongly prefer English Heritage guidance than the new Welsh Guidance in force since 31 May 2017. He also ignores the contrary view of the Penarth Town Council. I would ask that the committee question the accuracy and dimensions in any photo-montages.  Look at what the controversial architect Chris Loyn has to say re the Northcliffe development for 30 flats/apartments in his own words. The priority is for extensive views ....

"Organised from a pragmatic response to the challenging site topography and an unequivocal ambition from the outset for all principal living spaces to have an extensive view out over Cardiff Bay, the three distinct linear apartment blocks step down the cliffside, allowing vistas over the lower rooftops and framing landscaped streets or mews spaces in between." 

The setting of the listed buildings, particularly Penarth's admirable Custom House, damaged forever.  

Planning Policy Wales - 6.5.11 There should be a general presumption in favour of the preservation of a listed building and its setting, which might extend beyond its curtilage. For any development proposal affecting a listed building or its setting, the primary material consideration is the statutory requirement to have special regard to the desirability of preserving the building, its setting or any features of special architectural or historic interest which it possesses.

Northcliffe Lodge: Faulty assessment for “sustainability” of the location

Northcliffe Lodge: Faulty assessment for “sustainability” of the location

The Council planning report (5 Jan 2017 committee) shows officers willing to reduce parking spaces:

 “The Council’s Parking Standards SPG require one space per bedroom, and this equates to two spaces for each of the 23 two bedroom flats and 3 spaces for the 7 larger units. Six spaces are required by the standards for visitor parking, based on a requirement of 1 space per 5 units. However, the SPG allows for a relaxation if the site is located sustainably, with good access to local services and other modes of transport. The site scores well on sustainability points due to its close proximity to bus stops, a public house, schools, a restaurant, public open space, community hall and a church. Consequently, the parking requirements are reduced in accordance with the SPG to 1 space for the 2 bedroom units and 2 spaces for the three bed units. The development makes provision for the necessary visitor parking and each of the 30 units would be served by a single parking space. This equates to a shortfall of 7, when compared against the Council’s Parking Standards”

The Planning officer calculated 37 parking spaces – at one space per two-bed flat, 2 per 3-bed flat.  The new scheme has 24 two-bed and 6 larger; including visitor spaces (1 per 5 flats) the requirement is now said to be 42 (Highway Authority Observation Sheet, 23 June 2017).  In comparison, the original 1984 approval for 30 units (84/0206) required 55 parking spaces; that was recognised as inadequate in the adjacent Mariner Heights decision (~2005) when 1 space per bedroom plus visitor spaces at 1 per 5 units was prescribed.

The Parking Standards SPG says they follow the CSS Parking Standards 2008, but they categorised the whole north Penarth area and Penarth Haven as:

Zone 3 - Urban - Very much part of a substantial built up area with a number of basic local facilities within 400m walking distance.  (400m from the Clock reaches the top of Albert Rd).

Objective people would look at the dearth of “basic local facilities within 400m, and categorise Northcliffe and Penarth Haven as

Zone 4 - Suburban or Near Urban - This zone comprised the outer edges of the largest towns; suburban locations in towns.

The CSS Parking Standards 2008 document is restricted to CSS members, but can be found on the internet.  Its Appendix 5 has a prescription for allocating “sustainability points”, which must total 7 or more for a “sustainability” reduction.

Local facilities (a foodstore, PO, health facility, school etc.): access to two of these within a 400m walking distance scores 2points, access to more than two – 4 points.  For two within 400-800m walking distance, the score is 1 point, or for more than two - 2 points.

Access to a bus stop or railway station: 300m – 3 points; 400m – 2 points, 800m 1-point.

Frequency of public transport: if does not operate consistently between 7am and 7pm, deduct 1 point.

The planning officer states “close proximity to bus stops, a public house, schools, a restaurant, public open space, community hall and a church”.   Let’s measure distances using the google-map facility, though real distances are further than the map projection, because of the strongly sloping ground.

► Bus Stops – about 100m, on Paget Place

► A public house -  The Clive in John St is about 300m

► Schools – the officer apparently included Headlands special school (250m), which is not available to the local public;  Albert Rd primary school is 450m.

► A restaurant – the Custom House is close as the crow flies, but the walking route round by road is 450m; the Pilot on Queens Road is 500m away.

► Public open space – the Paget Road play area and pocket park is 300m away

► Community Hall – St Pauls is closed; Belle Vue Park hall is hardly used except by the Bowling club and for special events; it is 580m away

► Church – St Augustines is 480m by the most direct route (plus some increase for the steep slopes)

Sustainability Score Within 400m – a Pub and Play area -  scores 2 points. The officer wrongly included Headlands school and/or the Custom House restaurant to score 4 points.  

Within 800m, there is a school, GP surgery (unmentioned by the Planner), restaurants etc., but these still score only the two points.

Rail stations are too far away (1000m), regular buses near the roundabout are 850m away, but anyway score just 1 point – the Paget Place bus-stop scores just 2 points, because of limited hours (first bus to Cardiff workplaces is 9.25am) and no Sunday service.

Total Sustainability Score  - 4 points: does not qualify for any reduced parking spaces.   Even if the Officer included Headlands school and the Custom House restaurant within the 400m facilities, the score is only 6 points.  The Officer might have wrongly taken the bus service to meet the 7am to 7pm standard (to gross 7 points), though objectors wrote in on the point.

Walkability the steepness of hills needs to be taken into account (above assessment assumes it’s flat, when 400m is a brisk five minute walk).   The standard for high accessibility to the range of services is 10 minutes walk.  The  850m walk to the Town Centre bus-stops, foodstores is

a)      Well over 10 minutes for fit adults, due to the hill (eg. via St Augustines Cres)

b)      The very steep hill is challenging, even impossible for many elderly people or parents with laden buggies; routes avoiding the steep hills via Paget Road are much longer  to the town.

Northcliffe Lodge not enough parking & dodgy sustainable report

Northcliffe Lodge: Faulty assessment for “sustainability” of the location

The Council planning report (5 Jan 2017 committee) shows officers willing to reduce parking spaces:  “The Council’s Parking Standards SPG require one space per bedroom, and this equates to two spaces for each of the 23 two bedroom flats and 3 spaces for the 7 larger units. Six spaces are required by the standards for visitor parking, based on a requirement of 1 space per 5 units. However, the SPG allows for a relaxation if the site is located sustainably, with good access to local services and other modes of transport. The site scores well on sustainability points due to its close proximity to bus stops, a public house, schools, a restaurant, public open space, community hall and a church. Consequently, the parking requirements are reduced in accordance with the SPG to 1 space for the 2 bedroom units and 2 spaces for the three bed units. The development makes provision for the necessary visitor parking and each of the 30 units would be served by a single parking space. This equates to a shortfall of 7, when compared against the Council’s Parking Standards”

The Planning officer calculated 37 – at one space per two-bed flat, 2 per 3-bed flat.  The new scheme has 24 two-bed and 6 larger, so the total requirement is now said to be 42 (Highway Authority Observation Sheet, 23 June 2017).  In comparison, the original 1984 approval for 30 units (84/0206) required 55 parking spaces; that was recognised as inadequate in the adjacent Mariner Heights decision (~2005) when 1 space per bedroom plus visitor spaces at 1 per 5 units was prescribed.

The Parking Standards SPG says they follow the CSS Parking Standards 2008, but they categorised the whole north Penarth area and Penarth Haven as:

Zone 3 - Urban - Very much part of a substantial built up area with a number of basic local facilities within 400m walking distance.  (400m from the Clock reaches the top of Albert Rd).

Objective people would look at the dearth of “basic local facilities within 400m, and categorise Northcliffe and Penarth Haven as

Zone 4 - Suburban or Near Urban - This zone comprised the outer edges of the largest towns; suburban locations in towns.

The CSS Parking Standards 2008 document is restricted to members, but can be found on the internet.  Its Appendix 5 has a prescription for allocating “sustainability points”, which must total 7 or more for a “sustainability” reduction.

Local facilities (a foodstore, PO, health facility, school etc.): access to two of these within a 400m walking distance scores 2points, access to more than two – 4 points.  For two within 400-800m walking distance, the score is 1 point, or for more than two - 2 points.

Access to a bus stop or railway station: 300m – 3 points; 400m – 2 points, 800m 1-point.

Frequency of public transport: if does not operate consistently between 7am and 7pm, deduct 1 point.

The planning officer states “close proximity to bus stops, a public house, schools, a restaurant, public open space, community hall and a church”.   Let’s measure distances using the google-map facility, though real distances are further than the map projection, because of the strongly sloping ground.

► Bus Stops – about 100m, on Paget Place

► A public house -  the Clive in John St is about 300m

► Schools – the officer apparently included Headlands special school (250m), which is not available to the local public;  Albert Rd primary school is 450m.

► A restaurant – the Custom House is close as the crow flies, but the walking route round by road is 450m; the Pilot on Queens Road is 500m away.

► Public open space – the Paget Road play area and pocket park is 300m away

► Community Hall – St Pauls is closed; Belle Vue Park hall is hardly used except by the Bowling club and for special event, is 580m away

► Church – St Augustines is 480m by the most direct route (plus some increase for the steep slopes)

Sustainability Score Within 400m – a Pub and Play area -  scores 2 points. The officer wrongly included Headlands school and/or the Custom House restaurant to score 4 points.  

Within 800m, there is a school, GP surgery (unmentioned by the Planner), restaurants etc., but these still score only the two points.

Rail stations are too far away (1000m), regular buses near the roundabout are 850m away, but anyway score just 1 point – the Paget Place bus-stop scores just 2 points, because of limited hours (first bus to Cardiff workplaces is 8.25am) and no Sunday service.

Total Sustainability Score  - 4 points: does not qualify for any reduced parking spaces.   Even if the Officer included Headlands school and the Custom House restaurant within the 400m facilities, the score is only 6 points.  The Officer might have wrongly taken the bus service to meet the 7am to 7pm standard (to gross 7 points), though objectors wrote in on the point.

Walkability to Town Centre facilities, over St Augustines hill

The steep hills and poor-quality pavements have to be considered in assessing  walkability to facilities**.  The town centre clock roundabout is 850m away, with main buses and general food stores (Post Office slightly closer).  The IHT Guidelines give the ‘preferred maximum’ walking distance to Town Centres as 800m.  The Manual for Streets says a range of facilities within 10 minutes walking distance (around 800 metres). 

The route over St Augustines hill puts the town centre 15 minutes distance for fit people, more for those less fit or with a pushchair and/or shopping, and scarcely possible for those with mobility problems.   Observation shows relatively few people currently living in the Northcliffe area actually do walk.  One mobility scooter user lives near the top of Paget Road, where the route to the town centre is less steep.  Crutch/stick users and scooterists from Northcliffe would probably take the route up Arcot Road, but dropped kerbs are lacking.

** The LDP background paper on Sustainable Settlements says (s.3.6) “the general safety and nature of the walking environment in accessing these services will therefore need to be considered” – it cites the ‘Manual for Streets’ that sustainable ‘walking neighbourhoods’ are typically characterised as having a range of facilities within 10 minutes walking distance (around 800 metres). It also notes that the propensity to walk is influenced not only by distance, but also by the quality of the walking experience in terms of safe, accessible, attractive and stimulating walking environments.

NO to Penarth Northcliffe lodge "LITTLE BOXES" SCHEME

NORTHCLIFF LODGE "LITTLE BOXES" SCHEME - OPPOSED BY PENARTH COUNCIL - GETS VALE PLANNERS OK - VoG planning Cmte THURS, 5^TH JAN 2017 AT 6.00 P.M. 

Venue  COUNCIL CHAMBER, CIVIC OFFICES

Our historic mature woodland in St. Augustine’s Ward would be trashed for spec housing on the side of the cliff.
►high risk of landslide, just above the Custom House hotel - See here
►rich reserve of up to 40 trees and wildlife to go
►a big gash in Penarth’s iconic wooded headland
►the developers refuse their share of affordable housing
►the developers pretend new residents will walk or bus to town, so plan few car-spaces, creating a parking problem

Planning papers here More details  Details for : 2015/01449/FUL 

Lab CLLR LIS BURNETT
ST AUGUSTINES
WARD PENARTH
@lisburnett

VoG planning cmte - those in bold also St Augustines Ward and members of Penarth Town Council 

Chairman: Councillor Fred Johnson @CllrFred

Vice-Chairman: Councillor Margaret Wilkinson

Councillors: Rhiannon Birch, Jonathan Bird, Bronwen Brooks, Lis Burnett @lisburnett, Pamela Drake, John Drysdale, Chris Franks, Eric Hacker, Howard Hamilton, Val Hartrey, Nic Hodges @NP_H13, Jeff James, Peter King @CllrKing, Andrew Parker, Bob Penrose, Anthony Powell, Audrey Preston, Gwyn Roberts and Clive Williams.

Penarth Town Council SAYS NO  

Penarth Town Council –

That the application should not be approved for the following reasons:- 

1. Overdominant form of development that could threaten the future of the listed buildings, Custom House and Marine Building. 

2. Overcrowded form of development. 

3. Detrimental to this iconic headland known as the Bears Head believed to be where the name of Penarth is derived.

4. Request the Vale Council’s own ecology officer carry out a comprehensive ecology survey as it is considered that the submitted survey is inadequate. Local Knowledge is aware of an extensive and active bat population. 

5. The loss of so many mature trees is also of concern. If the Vale Council is minded to approved the application the Town Council wishes to reserve the right to comment at a later date with regard to any S106 agreement and the community needs within the locality.