BH2021/04167 – Brighton Gasworks Land Bounded By Roedean Road (B2066), Marina Way And Boundary Road Brighton BN2 5TJ – OBJECTION
Comprehensive mixed-use redevelopment comprising site preparation and enabling works, demolition of existing buildings and structures; provision of new buildings comprising residential use (Use Class C3) and flexible non-residential floorspace (Use Class E), new private and communal amenity space, public realm, landscaping; car and cycle parking, highway works, access and servicing arrangements; associated plant, infrastructure and other associated works including interim works. (For information: Proposed buildings to be erected range from 3no. to 12no. storeys, with 553no. residential units (Use Class C3) and 2,697m2 (GIA) flexible non-residential floorspace (Use Class E)).
Submission on behalf of the Kemp Town Society (KTS)
1. OVERVIEW / SUMMARY
The Kemp Town Society (KTS), whilst welcoming development of this site, noting it has remained undeveloped for many decades, strongly objects to the proposed mixed-use redevelopment. KTS further notes, that no learnings appear to have been incorporated from the overturning and recent ruling on the Brighton Marina development.
The Grade 1 Kemp Town Estate is a Conservation Area of national importance. It is unique amongst Britain’s Conservation Areas, all buildings being listed. This status demands it is given exceptional protection against harm from developments which could be detrimental to the quality of its character.
The proposed Gasworks development, an urban conglomeration including eleven densely packed tall buildings (over seven stories), neighbours the Grade I Listed buildings of the Kemp Town Estate. The density of the proposed development is significantly out of proportion with all surrounding architecture, comprising 553 residential units and 2697sqm of commercial space. This will have a serious and detrimental impact on current infrastructure, quality of life for residents and visitors, and public health and safety issues.
2. IMPORTANCE OF HERITAGE ASSETS AND LASTING HARM FROM THE GASWORKS PROPOSAL
From Brighton Pier to Roedean School, Marine Parade and Marine Drive together form one of the longest, continuous stretches of seafront in the country, of unparalleled high architectural quality. There are over 200 Listed buildings and structures along its length of two miles, making it the country’s most impressive marine façade to the sea. Immediately adjacent to the proposed Gasworks development, is the Kemp Town Conservation Area which incorporates the Grade 1 Listed Lewes Crescent, Sussex Square, and Chichester and Arundel Terraces; and the Grade II Listed French Convalescent Home. To the east, the locally listed Marine Gate and the Grade II listed Roedean School.
It is imperative that any development on the Gasworks site is of first-class architectural quality and respects the scale, height and character of the consistent architectural excellence of the neighbouring buildings. The proposed development conspicuously fails to respect the architectural distinction of the surrounding buildings
3. DESIGN ISSUES – HEIGHT, BULK, AFFORDABLE HOUSING
KTS is supportive of this redundant site being redeveloped for housing, which will make a valuable contribution to resolving the BHCC’s housing targets. The current proposal does not include details of affordable housing, important to create a sustainable local community. The current proposal for a densely packed conglomeration of tall blocks will dominate its surrounding neighbours by sheer size, height, scale, density and massing, with impact well beyond the curtilage of the development. With the Marina development now turned down, any proposal that tall buildings are acceptable on the Gasworks site is no longer relevant.
4. LESSONS LEARNED FROM THE BRIGHTON MARINA APPEAL
The Planning Inspector for the Brighton Marina Appeal was critical of the jarring relationship of the Marina proposals to the Heritage Assets in the immediate vicinity. Endorsed by the Planning Inspector and the Secretary of State, these are more relevant when applied to the relationship of the tall, densely packed buildings of the Gasworks development to those of the same Heritage assets as described.
It is the opinion of KTS, these grounds alone are sufficiently strong to justify refusal of this planning application. It asks the Council take note of the precedent set by the Brighton Marina appeal decision, and reject the Gasworks planning application outright.
KTS notes the Gasworks site is not identified as a ‘special site’ under Contaminated Land Regulations 2006. Decontamination procedures are effectively excluded from this planning application. Due to the significant risk of developing the site, KTS is not able to support without a detailed contamination survey, to establish there are no health and safety risks to Kemp Town Estate residents, visitors and neighbouring areas. The height and bulk of the proposed buildings, will maximise risks of deep excavations into contaminated ground.
A development of the proposed scale will inevitably stretch demands of current infrastructure. The planning application does not address the issues resulting from 553 additional residential units (c. 1000 new residents) and 2697 sqm of commercial space, including:
- pressure placed on current medical and educational provision, and parking and public transport, all of which are currently fully used by local residents;
- disruption of the congested A259 and Eastern Road thoroughfares, from additional traffic during both the construction stage and in its completed state;
- impact on access to the Royal Sussex County Hospital as a result of the additional road usage;
- health risk from pollution levels arising from increased vehicle usage (private, public and commercial);
- vehicles from proposed development (private and commercial) competing for limited existing car parking spaces;
- pedestrian safety concerns from increased traffic.
It is on these six grounds, KTS registers on behalf of its members its strong objection to: BH2021/04167 – Brighton Gasworks Land Bounded By Roedean Road (B2066), Marina Way And Boundary Road Brighton BN2 5TJ.