HS/CD/16/00655
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Discharge of condition 4 (details of the planting scheme and soft landscaping), 6 (archaeological monitoring), 7 (foul and surface water drainage scheme) and 8 (external colour scheme) of Appeal A ref. APP/B1415/C/15/3029007 - (EN/15/00028)
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Rocklands Private Caravan Park, Rocklands Lane, Hastings, TN35 5DY
- Total Consulted: 1
- Comments Received: 7
- Objections: 4
- Supporting: 0
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Mr Chris Hurrell
Comment submitted date: Thu 25 Aug 2016
Dear Mrs Evans
Thanks for your reply.
We are very concerned that the proposed planting scheme does nothing to replace the
substantial loss of screening made when the building was constructed.
Should the planting scheme be discharged in its current form then the very last chance to
protect the visual amenity of our Country Park and this part of the AONB will be lost for ever.
Given the sensitivity of this site and the degree of public interest over the last few years I
amvery disappointed with your reply.
It appears that the new policy is to try and decide everything behind closed doors without any
attempt at openness and transparency.
This flies in the face of the Bahcheli report recommendations approved by cabinet in December
2014.
There may be no statutory requirement to include members of the public or other interest
groups. However SEG and FOTCP have always been consultees in the past.
There is no constitutional requirement to exclude us from being consultees and this decision is
therefore a purely arbitrary executive decision.
SEG has reviewed the application and has very serious concerns that should the application be
discharged in its current form then the intentions of the Planning Inspector and our Planning
Committee will be ignored.
The HS/FA/12/952 approval was discharged without proper consideration and led to the two
and half years of refusals and appeals. We are fearful that the same mistakes are now going to
be repeated.
SEG will soon be writing to HBC officers and to our councillors documenting our concerns
andhope that these will be properly considered prior to any decision being made.
Some of our concerns include:
The planting scheme dos not comply with the intentions of the planning inspector.
? The planting scheme does not conform with the conditions stipulated by the Planning
Inspector
? The planting scheme does nothing to shield the building from the country park ? only 3
tiny oaks are to be planted
? The plans submitted are not the plans approved by the planning inspector
? The plans have numbers that relate to previous applications that have now lapsed or
been rejected
? The plans imply that building control regulations have already been met and approved.
But none of the listed amendments have been through the planning system and
approved.
? The building control recommendations are not shown on the plans. We fear that
building control will not reassess the development from scratch.
? The plan now state that the building is ?a dwelling?. The building is a holiday home.
SEG consider this the last chance to protect the visual integrity of the East Hill and
Ecclesbourne Glen from the damage caused by the building of the Rocklands holiday let
building.
Should condition 4 be discharged according to the planting scheme as proposed then the visual
amenity of the area will be lost for good.
SEG hope that HBC will demonstrate its determination to protect our Country Park (as
evidenced in the two decisions of the PlanningCommittee to refuse applications) by stipulating a
planting scheme that is in alignment with the requirements intended by the Planning Inspector
and by decisions and comments made by HBC and other consultees over the history of this
development.
Yours sincerely
Chris Hurrell
On behalf of the Save Ecclesbourne Glen Campaign Group
Comment submitted date: Fri 26 Aug 2016
Dear Mrs Evans
Thanks for your reply.
I am not very happy with this reply. With all due respect to the Case Officer this application is of
such a sensitive and critical nature that it needs to be processed by a senior planning officer who
has a strong knowledge of the Rocklands affair.
The site is a highly sensitive site and has attracted much public interest over the last few years.
This application should never have passed validation. The planting schedule does not meet the
requirements of the planning inspector.
Should the conditions be discharged in their current form then the very last chance to protect
the visual amenity of our Country Park and this part of the AONB will be lost for ever.
It would also be in the public interest to allow both SEG and FOTCP to be consultees.
The recommendations of the Bahcheli report endorsed by Cabinet are once again being ignored.
We urge you to investigate these issues in depth. We shall soon be submitting a detailed
critique of the discharge application.
SEG hope that HBC will demonstrate its determination to protect our Country Park (as
evidenced in the two decisions of the Planning Committee to refuse applications) by stipulating
a planting scheme that is in alignment with the requirements intended by the Planning Inspector
and by decisions and comments made by HBC and other consultees over the history of this
development.
We fear a repeat of the previously approved application HS/FA/12/952 where the conditions
were discharged without any proper consideration of the facts on the ground.
The screening conditions were discharged despite the fact that they had been breached and all
screening removed from the site three months previously.
None of the terms of the screening conditions were met. The plans supplied did not meet the
conditions and offered no details whatsoever of the planting scheme to be approved.
As a consequence all screening of the building was lost and the visual amenity of the Country
Park destroyed.
I would like to conclude by quoting the words of Councillor John Hodges concerning the
Rocklands application in May 2014 which seems so appropriate to the current application :
'This is the green jewel in the crown of this town's tourism offer, our duty as
councillors is to protect it.........
if we let this recommendation go ahead without what I, and many others have asked
for as a minimum protection of their visual enjoyment,
then we have failed miserably in discharging our duty towards those who look to us
for their support.'
Yours sincerely
Chris Hurrell
Comment submitted date: Tue 30 Aug 2016
Dear Mrs. Evans
Following the successful appeal, Rocklands have been granted permission to retain a slightly modified version of the building subject to conditions. The proposed planting scheme (attached) submitted with this application does not comply with the screening conditions imposed by the Planning Inspector.
We are very concerned that the proposed planting scheme does nothing to replace the substantial loss of screening made when the building was constructed.
The proposed scheme fails to screen the building from any part of the Country Park at all. The building dominates the landscape and has destroyed the beautiful coastal views of the Country Park.
Should the proposed planting scheme be discharged in its current form then the very last chance to protect the visual amenity of our Country Park and this part of the AONB will be lost forever.
Unfortunately SEG have been refused the status of consultee for this application. Nevertheless we believe it is vital to comment on this and we request that our views are taken into account.
The proposed scheme makes no attempt whatsoever to screen the building from the Country Park. The proposed scheme specifies that only three tiny oak trees will be planted. These trees should they grow will protect residents of the new building from views of the caravan park. Visitors to the Country Park will have uninterrupted views of both the building and caravans.
The planning history of the building shows that all parties involved were aware of the visual impact of the building and the need for mitigation by increased screening. We will demonstrate this by quoting some of the comments and decisions made during the long and complicated history of this development.
Rocklands own Heritage Statements which were instrumental in obtaining permission have acknowledged the harm to visual amenity and have stated that screening is to be increased. HBC Planning officers, the HBC Planning Committee and the Appeal Inspector have all recognised the harm to visual amenity and the need for increased screening.
Instead of increasing screening Rocklands removed most of the vegetation that screened the building from viewpoints in Ecclesbourne Glen and the East Hill.
SEG hope that HBC will demonstrate its determination to protect our Country Park (as evidenced in the two decisions of the Planning Committee to refuse applications) by refusing the proposed scheme in favour of a new scheme that provides effective screening. A new scheme that meets the requirements of the Planning Inspector and respects the planning conditions imposed by the Planning Inspector. A new scheme that recognises Rocklands previous commitments to screening. A new scheme that meets the expectations of HBC, consultees and the public over the history of this development.
The proposed scheme compares unfavourably with previous planting schemes. The number of plants and the areas to be covered are considerably reduced in comparison with previous planting schemes.
The proposed scheme claims that no new plantings can be made in the area of the Scheduled Ancient Monument (SAM) and that therefore no plantings will be made. Rocklands own Heritage Statements which were instrumental in obtaining permission for the building acknowledge the harm to visual amenity and propose increased screening within the SAM. Interestingly no planting is proposed in areas outside of the SAM either.
We believe that Rocklands are merely using SAM status as an excuse to avoid any replanting. SAM status does not preclude the planting of trees and hedgerows. English Heritage commenting as a consultee on previous applications has supported additional screening being planted within the SAM. Scheduled Monument Consent (SMC) might be required prior to any such plantings and we have written to English Heritage about this. It is very likely that SMC would be granted by English Heritage.
The proposed scheme states that 70 small holly sticks have already been planted to the south of the building. Some holly sticks were planted in the SAM in summer 2014 without Scheduled Monument Consent. Few if any of these sticks remain as witnessed by an on-site visit by SEG in April 2016. A site visit from an HBC officer is needed to properly establish the location of the holly sticks, how many were planted and how many have survived. We have had professional advice that states these sticks will never grow sufficiently to be adequate screening ? the Borough Arboriculturist was also of the same opinion at the Planning Committee meeting of 18/06/2014.
The proposed planting scheme is unacceptable on the following grounds:
The proposed scheme does not meet the intentions of the planning Inspector when determining the appeal.
The proposed scheme does not meet the conditions imposed by the planning inspector when granting the permission.
The proposed scheme offers no screening whatsoever from any part of the Country Park.
The proposed scheme has inaccurate plans and lacks sufficient detail.
The claim that the 70 holly sticks which Rocklands says it planted will provide adequate screening is incorrect.
The proposed scheme specifies far less screening than specified in previous planting schemes
The proposed scheme does not increase screening of the building as expected by all parties in previous applications.
See appendices of attached document for full details.
Both Councillors and election candidates have spoken about the need for public involvement in any replanting schemes. SEG would be happy to meet with the Borough Arboriculturist to discuss a planting scheme that meets the requirements of the Planning Inspector and screens the building from the Country Park. See Appendix 8 of attached document.
We request that you give this document full consideration and urge you to reject the proposed planting scheme in favour of one that meets the expectations of all concerned parties by screening the new development from all view points in the Country Park.
The words of Councillor John Hodges concerning the Country Park and the Rocklands application in May 2014 are so appropriate to the current application ? 'This is the green jewel in the crown of this town's tourism offer, our duty as councillors is to protect it.........if we let this recommendation go ahead without what I, and many others have asked for as a minimum protection of their visual enjoyment, then we have failed miserably in discharging our duty towards those who look to us for their support.'
Yours Sincerely
Chris Hurrell
On behalf of the Save Ecclesbourne Glen Campaign Group
Comment submitted date: Tue 30 Aug 2016
Dear Mr Davidson
I am writing to you in your role as the Natural Resources Manager and consultee on this application.
Following the successful appeal, Rocklands have been granted permission to retain a slightly modified version of the building subject to conditions.
The proposed planting scheme (attached) submitted with this application does not comply with the screening conditions imposed by the Planning Inspector.
We are very concerned that the proposed planting scheme does nothing to replace the substantial loss of screening made when the building was constructed.
The proposed scheme fails to screen the building from any part of the Country Park at all. The building dominates the landscape and has destroyed the beautiful coastal views of the Country Park.
Should the proposed planting scheme be discharged in its current form then the very last chance to protect the visual amenity of our Country Park and this part of the AONB will be lost forever.
The Planning committee has demonstrated its determination to protect our Country Park by refusing two applications for the building. Unfortunately their decision was overthrown at the appeal.
It is not too late to ensure that a planting scheme is implemented that screens the building from the Country Park.
The proposed scheme states that 70 small holly sticks have already been planted to the south of the building. Some holly sticks were planted in the SAM in summer 2014 without Scheduled Monument Consent.
Few if any of these sticks remain as witnessed by an on-site visit by SEG in April 2016. A site visit from the Borough Arboriculturist is needed to properly establish the location of the holly sticks, how many were planted and how many have survived
I hope that you can dedicate some time to reading the attached document which describes the issues with the proposed planting scheme.
We are aware that the Borough Arboriculturist had concerns about previous planting schemes. In your report for HS/FA/14/1036 he said:
'I am not sure if the proposed number of plants will adequately cover the 2 sites proposed for planting. However, if we can ask for the trees and shrubs to be planted at 30cm centres then we will be assured of 2 compact blocks of trees so affording them the best chances of establishment.
In addition I see no reason why we should not attempt to introduce Aspen and Holm Oak into the species planting schedule. The Aspen has the potential to establish quickly so being the first to provide screen. The Holm oak being evergreen and extremely tolerant of the heavy salt laden winds that frequently blow over the Rocklands site.'
The new proposed scheme is far worse than the HS/FA/14/1036 scheme and fails to implement any screening at all.
Both Councillors and election candidates have spoken about the need for public involvement in any replanting schemes.
SEG would be happy to meet with you to discuss a planting scheme that meets the requirements of the Planning Inspector and screens the building from the Country Park.
We are aware that you have dismissed the idea of a replanting scheme in the Hastings Country Park.
We believe that planting semi-mature specimens within the Hastings Country Park on the East Hill boundary could screen the building from the East Hill.
We ask you to use your influence to ensure that the proposed planting scheme is rejected in favour of a new scheme that provides effective screening.
A new scheme that meets the requirements of the Planning Inspector. A new scheme that recognises Rocklands previous commitments to screening.
A new scheme that meets the expectations of HBC, consultees and the public over the history of this development.
Best regards
Chris Hurrell
On behalf of the Save Ecclesbourne Glen Campaign Group
Comment submitted date: Fri 02 Sep 2016
See report on IDOX
Comment submitted date: Fri 02 Sep 2016
See IDOX for full document:
Dear Mrs. Evans
Please find attached copy of letter sent to building control.
This letter focuses on building control issues found. However there are also a number of planning issues described in the letter.
The issues we have with the application include:
The plans submitted are not the plans approved by the planning inspector
The plans have numbers that relate to previous applications that have now lapsed or been rejected
The plans imply that building control regulations have already been met and approved. But none of the listed amendments have been through the planning system and approved.
The building control recommendations are not shown on the plans. We fear that building control will not reassess the development from scratch.
The plans now state that the building is 'a dwelling'. The building is a holiday home.
The plans submitted are different from the plans approved by the Planning Inspector
These differences include:
Stanchions on the south elevation
Two down pipes and gully to rear of property not on approved plans
Amendments to drainage system
It is essential that planning check the submitted plans in detail against the approved plans. Any deviations from the approved plans must be processed as a minor amendment.
Yours sincerely
Chris Hurrell
On behalf of the Save Ecclesbourne Glen Campaign Group
Comment submitted date: Fri 09 Sep 2016
Dear Miss Roots
We note that you have discharged condition 8.
We are surprised and concerned that you have already determined this as the consultation period has not ended. Some consultees might disapprove of the materials.
We are concerned that the 'Draft Report' has been written and Building Control comments are not going to be taken into consideration. There are a number of changes to the submitted plans that have not received prior planning consent including: the land drainage system, the reduction in the number of stanchion posts, the changes to the roof profile.
We note that you refer to plans 11.396/03. As highlighted in previous correspondence this plan is not the approved plans approved by the planning inspector but a plan relating to the previous application HS/FA/12/952 which has now expired.
The plan numbers should be the ones that are noted on the Inspector's Decision notice, that is 11.396/14 and should be amended accordingly to the LPA or Building Control requirements.
Therefore, in our opinion they should be amended to 11.396/14A if the 'amendments' do not require additional planning permission. There is a danger of approving additional 'amendments' which require additional planning permission, by noting plans that are only relevant to hs/fa/12/952 on the 'Decision Notice'.
SEG are concerned that you have not taken this into account and are happy to allow Rocklands to vary the plans that were approved by the inspector. Any variations to plans require a minor variation application to be submitted.
There are reductions in the number of stanchion posts and the 'amendments' to the drainage system that have not received planning permission. These are material changes in circumstances so should require a Section 73 of the Town and Country Planning Act 1990 to be submitted. Any Non material amendments will require a section 96A.
The plans submitted state that it is a "dwelling". This is not true the building is a holiday let. The very same "error" was on the plans for hs/fa/14/406. The description of the building on the plans approved by the inspector clearly states that the building is a holiday let.
We are also concerned that you have discharged the use of materials that have not been approved by Building Control.
We remain very concerned that Planning are not examining the plans submitted by Rocklands properly. The plans should conform to the plans approved by the appeal inspector. This is not the case.
We urge you to consider the discharge against the plans approved by the inspector and not by the new unauthorised plans submitted by Rocklands. This is especially important when considering the discharge of condition 7 (foul and surface water drainage).
We urge you to read the SEG document submitted to building control and copied to you for consideration (attached).
We urge you to insist that Rocklands submit plans based upon the plans approved by the inspector and not the plans for an expired application.
Any revisions to the inspectors approved plans should be subject to approval as a minor material amendment under section 73 of the Town and Country Planning Act.
Yours Sincerely
Chris Hurrell
On behalf of Save Ecclesbourne Glen
Comment submitted date: Fri 09 Sep 2016
Dear Miss Roots
We believe that Condition 4 of the permission granted by the inspectorate appeal has been breached, and now cannot be fulfilled. The deadline for submission and LPA approval for a planting and soft landscaping scheme for the two storey holiday let unit proposal has now passed so therefore, it is not possible to discharge this condition. The appeal APP/B1415/C/15/3029007 and 8) decision date was the 07/06/2016. The 3 months stipulated by the planning inspector has now been exceeded and the condition has not been met.
We also believe that the tree screening proposal cannot be discharged as it does not satisfy the wording of the Condition, or the intentions of the Inspector that the holiday let building is screened from prominent views. It is now too late for Rocklands to submit a new planting scheme as the deadline imposed by the inspector has passed.
Condition 4 of the appeal decision states:
"Details of the planting and soft landscaping scheme to the north-east of the building and on the south and west boundaries shall be submitted to and approved in writing by the Local Planning Authority within 3 months of the date of this decision. The details shall include indications of all existing trees and hedgerows on the land including details of those to be retained, together with measures for their protection in the course of development. New soft landscaping details shall include planting plans; written specifications (including cultivation and other operations associated with plant and grass establishment); schedules of plants, noting species, plant sizes and proposed numbers/densities where appropriate together with an implementation programme."
The planting schedule as submitted fails to meet the terms of the condition on the following grounds:
There has been no planting scheme specified for the North East Boundary, the three oaks specified are not on the North East Boundary and offer no screening from the Country Park.
There has been no planting scheme specified for the Western boundary.
There has been no planting scheme specified for the Southern boundary. The scheme for the refers to holly planted back in 2014. Most (if not all) of this no longer exists and is not suitable as screening.
The planting scheme does not specify details of all existing trees and hedgerows on the land.
The planting scheme lacks sufficient detail, is incomplete and contains errors.
The planting scheme does not screen the building from the Country Park.
The AONB have concerns about the effectiveness of the planting scheme. They state that holm oaks are an invasive species and that the holly will not screen the building.
Historic England have concerns about screening and state that screening can be planted on the scheduled monument subject to consent.
The planting scheme claims that no trees can be planted on the scheduled monument. This is clearly not the case in the light of the latest Historic England comments.
Please see our critique of the Planting Scheme(attached) for more details.
It is now too late for Rocklands to submit a new planting scheme as the deadline imposed by the inspector has passed.
SEG are seeking further legal advice on whether the permission granted by the inspector can now be implemented at all and whether Rocklands will have to now apply for a new permission. The enforcement order imposed after HS/FA/14/1036 was rejected (EN/15/00028) is still valid and should the planning permission now be invalid then enforcement action can now be taken to remove the building.
Please post this correspondence as a further consultee comment from SEG.
Yours Sincerely
Chris Hurrell
On behalf of the Save Ecclesbourne Glen Campaign Group
Comment submitted date: Tue 13 Sep 2016
See full report on IDOX
Comment submitted date: Tue 13 Sep 2016
Email sent 13/09/2016 to Planning: Plans invalid and require a new planning application for drainage and other changes
Application: HS/CD/16/00655 | Proposal: Discharge of condition 4 (details of the planting scheme and soft landscaping), 6 (archaeological monitoring), 7 (foul and surface water drainage scheme) and 8 (external colour scheme) of Appeal A ref. APP/B1415/C/15/3029007 - (EN/15/00028) | Address: Rocklands Private Caravan Park, Rocklands Lane, Hastings, TN35 5DY Dear Ms Roots Being given the status of consultee for the above planning application, 'Save Ecclesbourne Glen Campaign Group' have now had the chance to look at the submitted plans in more detail, and are concerned to see that the submitted plans contain 'amendments', which have not been given prior planning permission by the Local Planning Authority. There are a number of variations to the approved plans: 11.396/03E, such as the addition of two drainage runs and a gulley to the rear of the property on the north-west elevation. There are two additional rainwater down pipes on the north-west elevation, with an extension to the balcony that were not on the approved plans; The rainwater downpipes on the north-east elevation seem to have disappeared. There are three stanchion posts on the south-west elevation on the approved plans: 11.396/14, but on the 'revised' plans there are only two. The revised plans, that are not relevant to the scheme approved by the Inspector for the Secretary of State, have been 'amended' to include drainage runs along the northern side of the building linking to a combined sewer system. The author of the 'Written Scheme of Investigation', Archaeology South-East, document confirms that this is a 'minor material amendment', but states that the 'amendments' do not require 'Scheduled Monument Consent' as they are not within the 'Scheduled' area of the monument. It is understood from the content of the document that Mr Roberts, of 'Historic England', was consulted on whether the existing consent for 'SMC' was still valid, but was not consulted on the proposed 'amendments'; Mr Roberts was not consulted on the 'revised' scheme, and only confirmed that the 'written scheme of investigations', previously submitted in November 2015 to 'Historic England' and 'East Sussex County Council' for approval prior to the commencement of fieldwork, and in order to apply for scheduled monument consent (ref:S00123929) remains valid. Drawing number 11.396/03E shows the 'addition of the minor works within the non-scheduled area?' The proposed additional drainage runs to the north-east corner of the new building appear to be close to, if not within, the scheduled area of the 'Scheduled Ancient Monument'; drawing number: 11.396/02F shows the proposed drainage run to be on the boundary between the non-scheduled and the scheduled area of the 'SAM'. It is proposed that the excavations will be dug using a 2.5 mini-digger fitted with a 600mm diameter auger attachment, without prior planning permission from the LPA, or additional 'SMC'; as the proposal without proper consent, and archaeological monitoring might have damaging effect on the 'SAM', and on any likely archaeological remains.
Therefore, the 'revised' plans (11.396/03E and 11.396/02F), submitted with the 'Discharge of Conditions' application: HS/CD/16/00655, should be the subject of a separate Section 73 of the Town and Country Planning Act 1990 application as there are 'minor material amendments' to the foul and surface water drainage system that have not received prior planning approval, and 'Historic England' should be invited to comment on whether additional schedule monument consent is required for the additional changes to the approved plans that may affect the 'SAM' because of their close proximity. The applicants should also be invited to submit applications for other material amendments, and non-material amendments, that have been included within the revised plans: 11.396/03E and 11.396/02F. On your recent 'Decision Notice', written to the applicants' agent, Mr Cos Polito, you make reference to the colour of the rendered walls as being weber.sil P (mushroom)? as set out in drawing no 11.396/03E?, but there is no reference to the colour of the render on the 'revised' plans, drawing number: 11.396/03E on states 'render finish'. It is our opinion that the plans approved by the Inspector at the recent appeal hearing should be the only plans that are revised, and that the plans submitted with the 'Discharge of Conditions' application should not be taken into consideration as they relate to a previous proposal that has now expired. There should only be one set of approved plans, as plans that relate to a 'dead plan' can only cause confusion. Please see attachment for additional details. Please add this correspondence as additional comments from seg on the planning web site.
Yours sincerely Chris Hurrell On behalf of Save Ecclesbourne Glen
Comment submitted date: Tue 20 Sep 2016
Dear Mrs Greathead
Following the publication of Rocklands replanting scheme as part of the discharge application HS/CD/16/00655, we are very concerned that that there will be no replanting scheme within the grounds of Rocklands or within the landslip area of the country park at all. This is a reversal of over two years of HBC statements which have stated that there will be replanting within the grounds of Rocklands to mitigate the visual impact of the new building and to replace screening which has been lost across the site, both as a result of tree removals by the operators of Rocklands Caravan Park and of course the landslip.
HBC have stated that the licence agreement would include conditions to ensure that the site would be replanted. Could you please clarify the HBC position on replanting.
I have intentionally included the previous correspondence with yourselves regarding a proposal to increase tree and shrub screening in adjacent areas to the south and east of the caravan site. I am hopefully of the correct opinion that this previous correspondence does not refer to land within Rocklands or within the landslip area; the phrase used 'the existing natural shrub and tree screen?' implies to me that I am correct as there is little or no natural shrub or tree screening within the landslip.
Could you please confirm that HBC intends to maintain its commitment to replant the Rocklands site.
Can you please ensure and confirm by return that this email is shared with the following council officers;
Murray Davidson, Mike Hepworth, Chris Wilkins and Cllr Peter Chowney. All of which have an interest in this issue.
With kind regards
Bob Okines
20/09/2016
For and on behalf of Save Ecclesbourne Glen Campaign Group
Comment submitted date: Tue 20 Sep 2016
HS/CD/16/00655 | Discharge of condition 4 (details of the planting scheme and soft landscaping), 6 (archaeological monitoring), 7 (foul and surface water drainage scheme) and 8 (external colour scheme) of Appeal A ref. APP/B1415/C/15/3029007 - (EN/15/00028) | Rocklands Private Caravan Park, Rocklands Lane, Hastings, TN35 5DY
HBC Consultees have not yet commented.
We note that the consultation period for this application is coming to an end soon.
We are concerned that key council officers who are consultees have not yet submitted comments on the application. These include
? The Borough Arboriculturist
? The Leisure and Resources Manager
? The Licencing Manager
The comments of these officers is vital for proper consideration of the application. The Arboriculturist is the HBC specialist on trees which are covered in condition 4.
The Leisure and Resource Manager is directly responsible for the Country Park which is affected by this application.
The Licencing Manager is responsible for the long awaited new Rocklands licence which HBC have stated will include conditions covering replanting within the site and issues such as surface water drainage - both relevant factors in this application.
We note that Building Control have been consulted and yet no comments have been posted. Building Control comments on the plans and proposed drainage schemes are essential.
We note that the following HBC officers have also been consulted and have not yet replied:
The Head of Corporate Services
? The Head of Environment
? The Head of Finance
? The Head of Housing and Development
? The Head of Leisure
? Environmental Health Pollution
? The Head of Regeneration and Planning Policy
Following the Bahcheli report which was adopted by cabinet in Dec 2014 it is now policy for HBC consultees to comment on applications where they are nominated as consultees. This was recommended by the Bahcheli report and approved by Cabinet. Please see paragraph 46 of Agenda to Cabinet subsection iii.
'46. Consultant Recommendation No. 4
The council could consider a review of its internal consultation procedures, to
ensure that all departments with an interest in a planning application have an
opportunity to consider the implications of a development proposal.
Response to No. 4
iii. A rigorous internal system of written consultation on applications. Where the planning service has requested input from a service this will be provided through and in the name of the head of service concerned. A response be required even if it was a simple "no comment". Response returns would be reported to the planning committee or recorded in a delegated decision.'
In accordance with the above it would be appropriate that all HBC officers who are nominated as consultees provide comments prior to the closure of the consultation period. This will then give other consultees the opportunity to comment as necessary.
Please post these additional SEG comments as a .pdf document under the title 'HBC Consultees have not yet commented'.
Yours Sincerely
Chris Hurrell
On behalf of the Save Ecclesbourne Glen Campaign Group
20/09/2016
Comment submitted date: Wed 21 Sep 2016
HS/CD/16/00655 | Discharge of condition 4 (details of the planting scheme and soft landscaping), 6 (archaeological monitoring), 7 (foul and surface water drainage scheme) and 8 (external colour scheme) of Appeal A ref. APP/B1415/C/15/3029007 - (EN/15/0...
Wed 21/09/2016 10:31
Dear Miss Roots,
HS/CD/16/00655 | Discharge of condition 4 (details of the planting scheme and soft landscaping), 6 (archaeological monitoring), 7 (foul and surface water drainage scheme) and 8 (external colour scheme) of Appeal A ref. APP/B1415/C/15/3029007 - (EN/15/00028) | Rocklands Private Caravan Park, Rocklands Lane, Hastings, TN35 5DY Please see additional consultee comments from SEG.
These comments are an email trail of queries from SEG to HBC on the replanting of the Rocklands site.
They are very relevant to the current application as it is clear that Rocklands have no intention of replanting the site and it is unclear whether HBC will take any measures to ensure the site is replanted.
Please post attached .pdf file as comments with the title "Concerns about HBC commitment to replanting Rocklands site"
Yours sincerely
Chris Hurrell
On behalf of the Save Ecclesbourne Glen Campaign Group
Comment submitted date: Thu 22 Sep 2016
Dear Miss Roots
We note that Building Control have now commented and expressed some concern about
emergency access.
With this in mind it seems appropriate that East Sussex Fire and Rescue Service should
be on the list of consultees.
We believe that they have been consultees in the past.
Could you please correct this omission and notify them as consultees for this application.
Please post this correspondence as additional comments on the planning website in .pdf
format with the title "East Sussex Fire and Rescue should be consulted".
Your sincerely
Chris Hurrell
On behalf of Save Ecclesbourne Glen Campaign Group
Comment submitted date: Fri 21 Oct 2016
See full report on IDOX
Comment submitted date: Thu 03 Nov 2016
Further Consultee Comments on the Arboriculturalist statement of 03/11/2016.
Mr Wilken has now commented again on the application. This time he states that he has visited the site. This is a strong indication that his previous statement was made without benefit of a site visit.
Unfortunately the latest statement is even more inadequate than the previous one.
Mr Wilken has not taken into account any of the issues raised in our previous comments.
If nothing is done to impose a proper planting schedule on Rocklands than the building will continue to mar the visual enjoyment of the glen for generations to come. Mr Wilken makes no attempt to meet the conditions and expectations imposed by the planning inspector. It is necessary to plant several semi-mature ever green specimens on the East Hill side of the building and on the slopes of the Iron Age hill fort to screen the building from the East Hill. And a large number on the other side to screen the building from views from the east.
Most seriously Mr Wilken claims that there are 70 holly whips planted on site. We have very serious concerns about the factual accuracy of this statement and request that further evidence is provided to show that there are 70 whips planted. We have submitted a separate document on this issue.
There is no detailed planting scheme proposed and Mr Wilken still fails to specify the location, quantity and species of any proposed plantings to screen the site from views.
Mr Wilken does not address the issue of how natural regeneration will occur in areas that are currently devoid of any plantings.
The issues raised in our previous comments remain unaddressed by Mr Wilken. Please see our previous comments.
We had hoped that given the sensitivity of the site that Mr Wilken would have produced a clear statement on what he considered to be a planting schedule that would satisfy the requirements imposed by the planning inspector and the expectations of all other parties involved.
Our concerns remain that Mr Wilken's places an over reliance on natural regeneration. Some natural regeneration from hedgerows might be possible but in most areas that require replanting to establish screening there are no established hedgerows or trees from which regeneration can take place. In these areas it is essential that replanting including semi mature specimens is carried out in accordance with the expectations of the Planning Inspector.
Our concerns remain that Mr Wilken's emphasis on natural regeneration contradicts his comments made for planning application HS/FA/14/1036 where he advocates a replanting scheme.
Our concerns remain that Mr Wilken does not fully understand the topology of the site and the areas that require replanting in order to screen the building from public lines of sight.
Our concerns remain that Mr Wilken has not taken the comments made by the AONB, CRPE, Historic England, the Friends of the Country Park or SEG into consideration when making his comments. We would be happy to meet with Mr Wilken to discuss our concerns. We repeat our invitation to meet with Mr Wilken to discuss planting locations and schedules for the site.
Chris Hurrell
On behalf of SEG
03/11/2016
Comment submitted date: Fri 04 Nov 2016
See full report on IDOX:
Mr Wilken has stated in his latest document dated 03/11/2016 that during an undated site visit that he has confirmed that:
'The 70 previously planted Holly are now no longer visible when viewed from outside of the site, obscured by the continued growth of trees that pre-date the Holly plantings. Subsequent to a visit to Rocklands CP I confirm that their condition is good, it will nevertheless take sometime until they are of such a size that they begin to contribute to the screening of the building.'
This statement has not allayed any of our concerns. We have very serious concerns about the accuracy of this statement. We do not believe that there are 70 holly whips planted on the southern boundary of the building. In order to maintain public confidence that this discharge process is being conducted properly we believe it is essential that some documentary evidence is provided to support the claim that there are 70 healthy holly whips in the area.
We believe it is essential that the following information is provided:
The date of Mr Wilken's visit
Photographic evidence showing the 70 holly whips.
Detailed information on the position and size of the 70 holly whips as specified by condition 4 of the appeal decision
We shall be submitting a request under EIR 2004 to obtain this and other information relevant to the planting scheme.
Please find attached detailed concerns about the claimed 70 holly whips on the latest statement from the Borough Arboriculturalist.
Comment submitted date: Fri 11 Nov 2016
See full report on IDOX
Comment submitted date: Fri 11 Nov 2016
Dear Ms Cameron
We are very concerned that the posting of the Officer's report to Committee for the discharge of Condition 6 was posted far too late to allow Consultees to review it properly.
We have been in communication with Country Archaeology and Historic England and we believe that they were not informed of this recommendation to discharge.
They only became aware following correspondence with SEG today. Had we not contacted them we believe they would have been completely unaware of the recommended discharge.
Mr Roberts of Historic England expressly wished to be kept informed
'We would welcome the opportunity of advising further. Please consult us again if any additional information or amendments are submitted.
If, notwithstanding our advice, you propose to approve the scheme in its present form, please advise us of the date of the committee and send us a copy of your report at the earliest opportunity.'
Despite this it appears he was not notified.
We believe that insufficient time and no notification whatsoever has been given to key consultees including County Archaeology, Historic England, Southern Water and Building Control.
Consultees have not been notified and therefore there are no longer 5 working days available before the planning committee meeting.
Given the sensitivity of the site and the application it is essential that it is seen that proper process is being followed and all consultees given an opportunity to comment.
We request that the decision is deferred until the December Planning Committee to allow all consultees an opportunity to review.
Yours sincerely
Chris Hurrell
On behalf of SEG
11/11/2016
Comment submitted date: Tue 15 Nov 2016
Please see documents tab.
Comment submitted date: Fri 18 Nov 2016
Please see documents tab.
Comment submitted date: Thu 22 Dec 2016
Please see documents tab.
Comment submitted date: Fri 06 Jan 2017
Please see documents tab.
Comment submitted date: Mon 09 Jan 2017
Please see documents tab.
Comment submitted date: Tue 10 Jan 2017
Please see documents tab.
Comment submitted date: Thu 12 Jan 2017
Please see documents tab.
Comment submitted date: Fri 20 Jan 2017
Not Available
Comment submitted date: Fri 20 Jan 2017
Please see documents tab.
Comment submitted date: Mon 23 Jan 2017
Please see documents tab.
Comment submitted date: Mon 23 Jan 2017
Please see documents tab.
Comment submitted date: Wed 25 Jan 2017
Please see documents tab.
Comment submitted date: Mon 30 Jan 2017
Please see below objection sent in on Wednesday 25/01/2017.
The covering email has been posted on the website but the attached objection document has not been posted.
Could you please ensure that the attached objection is posted with a DESCRIPTION of 'Second revised planting scheme remains inadequate'.
I note that despite several requests you continue to post SEG consultee comments as from Chris Hurrell.
Can you please ensure that these are recorded as being posted from SEG who are consultees on this application.
Thanks in advance
Chris Hurrell
On behalf of SEG
14 High Wickham
Hastings
TN35 5PB
Comment submitted date: Mon 30 Jan 2017
Dear Mrs Evans
A new planting scheme was submitted by the applicants on the 25/01/2017.
A further 3 weeks must now be granted to allow full and proper consideration by consultees.
This means that the application cannot be decided until at least February 15th.
Can you please confirm that the consultation period for the application will be extended by 3 weeks from the 25/01/2017 to allow full and proper consultation by all parties.
Can you please confirm that the application will not be decided prior to the 15/02/2017 and will not go to the planning committee on the 08/02/2017.
Please log this correspondence on the application web site.
Yours sincerely
Chris Hurrell
On behalf of SEG
Comment submitted date: Mon 30 Jan 2017
Dear Mrs Evans
Thank you for your email.
I am perfectly aware that this discharge application is not open to public comments. However I do not see how this point is relevant to my query.
My query concerns consultees and the need for consultees to be given adequate time to consider changes to the applicants submitted documents.
Consultees are perfectly entitled to comment and any changes to applicants documents require a 3 week extension to the consultee consultation period.
Thank you for confirming that the planting scheme will not be considered in February. Can you please also confirm that the drainage will not be considered in February.
I am puzzled how the archaeological monitoring can be discharged given that 1. Drainage has not been discharged and 2. Building Control have not approved.
I believe that in order to conform with the requirements of Southern Water and Building Control further excavation works will be necessary.
Rocklands own agent Cos Polito has stated on the 24/01/2017 that surface drainage has yet to be installed. This correspondence was obtained through FOI.
This correspondence should have been posted on the application web site and should be available to all consultees.
Southern Water have stated that new works must conform to Building Regulations H3 and foul and surface cannot be combined until the boundary of the property. Southern Water will not approve any new connections that break this rule.
It is clear that the drainage connections for the building are not new and therefore must conform to Southern Water requirements.
Building Control have yet to comment on disabled access, fire appliance access, rainwater harvesting and conformance with building regulations. Further works will be necessary within the ANA.
These works will entail further excavations in an archaeological notification area and it is therefore premature to discharge condition 6.
SEG consider that all the reasons given in our previous objection to discharge of condition 6 remain valid.
SEG will be objecting to the discharge of condition 6 and I shall submit an objection in due course.
Please log this correspondence on the application web site.
Yours sincerely
Chris Hurrell
Comment submitted date: Tue 31 Jan 2017
HS/CD/16/00655 | Discharge of condition 4 (details of the planting scheme and soft landscaping), 6 (archaeological monitoring), 7 (foul and surface water drainage scheme) and 8 (external colour scheme) of Appeal A ref. APP/B1415/C/15/3029007 - (EN/15/00028) | Rocklands Private Caravan Park, Rocklands Lane, Hastings, TN35 5DY
We write as consultees to this application.
We have been informed that the discharge of condition 6 will be decided by the Planning Committee on the 8th February 2017.
Please see attached our further objection to the discharge of condition 6.
Please post attached document on the planning web site titled 'SEG further Objection to discharge of condition 6 Archaeology'
Yours sincerely
Chris Hurrell
On behalf of SEG
Comment submitted date: Wed 01 Feb 2017
Fyi
They have ignored all our comments on this.
Comment submitted date: Wed 01 Feb 2017
Dear Mrs Evans
Thanks for your reply. As you are no doubt aware the Case Officer is on leave until the day of the Planning Committee so will be unable to take any action.
I note that you have not addressed our concerns which are addressed to you as the senior officer responsible for planning.
Can I take this to mean that Planning will give no assurances that any future excavation works will be protected by a condition requiring archaeological supervision?
If this is the case what measures will be taken to ensure that further works do not cause more damage to scheduled monument/iron-age hill fort?
I repeat my query below to give you the chance to provide us with a clear answer:
'We are concerned that should this condition be discharged then all future works will not be protected by archaeological monitoring.
Can you give us your assurance that should this condition be discharged all future works affecting the ANA will be protected by a new condition requiring archaeological supervision?
If this assurance is not given then the site will be left unprotected and Rocklands could carry out works which will damage archaeology as they have done in the past.'
May I remind you that the inspector's decision states that:
'No further groundworks required to complete the development shall take place until the implementation of a programme of archaeological works has been secured in accordance with a written scheme of investigation'
Since there will be further works necessary to complete the building the discharge of this condition is premature and ignores the requirements of the Inspector.
Rocklands agent has admitted that there are further woks necessary to complete surface drainage, yet Planning have not informed consultees of this and have not taken this into account on the report to committee.
Building control have not approved. Southern water object to the drainage plans. Again there is no mention of this on the report to committee.
The Planting schedule has not been signed off, it is possible that further plantings will be required within the ANA.
We repeat it is premature to discharge this condition.
We request that the officer's report is changed to include our reasons for objecting and updated to reflect the latest comments from the applicants and consultees.
The current officer's report does not include any of this.
Please post this email as a further objection on the planning web site.
Yours sincerely
Chris Hurrell
On behalf of SEG
Comment submitted date: Wed 15 Feb 2017
Please see below copy of email sent to the Freedom of Information Officer requesting details of correspondence between HBC and the archaeological consultees.
Please post the contents of this email as a further comment from SEG with a description of 'Request for details of correspondence with Archeological Consultees'.
Thanks in advance
Best regards
Chris Hurrell
On behalf of SEG
From: chris hurrell [mailto:duckbrand@talktalk.net] Sent: 15 February 2017 14:47To: 'Information Officer'Cc: 'Stephanie Roots'; 'Eleanor Evans'Subject: FOI - HS/CD/16/655 Tockalnds discharge of Condition 6 - Correspondence between HBC and Archeaological comsultees
Dear Ms Greathead
At the Planning Committee meeting of 08/02/2017 the development control manager Mrs Evans stated:
'Also I would add that the concept and the suggested wording of an amended discharge similar to that proposed was sent to the archaeologist, our archaeologists, to check whether they were happy with that and whether that would, in their eyes, compromise the situation, should there be further changes. And they weren't ? they're fine with it. They said that was acceptable to them, and I think that as they are the specialists it's reasonable that we have regard to what they say and to recommend accordingly'
I note that this correspondence has not been posted on the application web site.
Could you please provide me with copies of this correspondence and ALL correspondence between HBC and all Archeaological Consultees for the lifetime of this application.
Please take this as a formal request under FOI regulations.
I would be grateful if this request could be dealt with as soon as possible as it is part of an open planning application and the information is relevant to other consultees.
Thanks in advance
Best regards
Chris Hurrell
On behalf of SEG
Comment submitted date: Fri 24 Feb 2017
Further Objection to Discharge of Condition 6 ? Archaeology following Planning Committee of 08/02/2017.
SEG believe that a further proposal to discharge condition 6 will be presented to the Planning Committee in March. It is likely that this discharge will include the last minute amendment proposed at the Planning Committee meeting in February.
SEG Object to the discharge of Condition 6 on the grounds that there are further episodes of groundworks necessary to comply with building regulations, Southern Water requirements and screening. These arguments have already been presented in our previous objection and in Mr Okines presentation to the committee in February.
SEG also has serious concerns about the way discharge has been handled by planning officers. Based on the strength of past evidence (detailed below) we are very concerned that yet another recommendation to hastily discharge this condition prematurely will be made at the next Planning Committee meeting.
At the previous two Planning Committee meetings planning officers have tried to pressurise the committee into making hasty decisions by: tabling last minute amendments, proposing a flawed and unenforceable amendment, misinterpreting the condition and stressing false time constraints. Planning have consistently ignored the fact that further groundworks episodes will be necessary and persisted in seeing groundworks as a single episode.
In November the Planning Committee were misinformed by officers that it was necessary to partially discharge the condition before groundworks could proceed (when all that was required was approval in writing). Unfortunately the committee approved partial discharge when it was unnecessary, premature and against the recommendations of County Archaeology.
In February the Planning Committee were told that the condition must be discharged in full that evening. If not then the first part of the condition would be invalidated and would need to be conducted again and that the whole planning permission might be invalidated. The last minute amendment made provision for the condition to be reinstated if necessary (despite the fact that no mechanism exists for reinstating a discharged condition). Fortunately the Planning Committee ignored officers' recommendation to discharge with a last minute amendment and deferred the decision to a future meeting.
We now ask the Planning Committee to reject the amendment and the recommendation to discharge the condition until the scale and scope of all anticipated further groundwork episodes are known and completed and all other conditions have been discharged. 2
Our concerns can be summarised as follows:
? Planning have misinterpreted Condition 6
o The condition is not a single episode. Planning has assumed that the first stages of groundworks are the ONLY groundworks needed to complete the development. There are further groundworks episodes necessary in order to comply with building control, southern water drainage and planting requirements.
o Part 1 of the condition should not have been discharged prior to full discharge. The written scheme of investigation should have been approved in writing as specified by the inspector instead.
o There are no time constraints on the condition. Officers stated that the discharge must be done immediately, as it risks the entire permission becoming invalid. Officers also argued that part 2 of the condition must be discharged within three months of discharge of condition 1. These statements are incorrect there are no time constraints on discharge of the condition.
? The last minute amendment on 08/02/2017 to fully discharge is flawed.
The amendment has no basis in planning procedures, is unenforceable and would remove all protection of archaeology.
o The amendment is an 'informative' only rather than a legally binding agreement between the applicants and the Council.
o Once a condition is discharged it is discharged. No mechanism exists for bringing a condition back once it has been discharged.
o A new Planning Application would be required. Once a Condition is discharged, then it is gone, and a new planning application would need to be submitted for amended plans. There are no guarantees that the previously discharged Condition would be copied over to the new application.
o Archaeology is left unprotected. Should Rocklands carry out further groundworks without seeking a new section 73 planning application then there would be no protection of the archaeology.
o Vulnerable to appeal. Should the amendment be approved then it could easily be challenged at appeal as invalid. There is no suggestion of holding part 1 in abeyance only part 2 There is no provision in the amendment for bringing Part1 of the condition back.
? The Recommendation for full discharge on 08/02/2017 is premature
Full Details for opposing discharge can be seen in the SEG Objection documents.
o Further groundwork episodes will be necessary
o The Planting schedule has not been discharged.
o The Drainage Plan has not been approved by Southern Water/Building Control
o The Drainage Plan differs from the plans approved by the Planning Inspector.
? The Recommendation for full discharge was based upon the following false arguments
o Time Constraints must be adhered to otherwise the permission will be invalidated
o Part 2 of the condition must be discharged within three months
o Failure to discharge will lead to an endless cycle of applications.
Comment submitted date: Fri 10 Mar 2017
Dear Ms Roots
This application has an agreed expiry date of Thursday 09/03/2017. This application has now expired.
The evidence necessary to discharge this application has not been provided by the applicants.
Key consultants such as Southern Water, the High Weald AONB, Archaeology , English heritage and Building Control have not agreed to discharge conditions.
Will this application now be refused with a view to a new application being submitted when sufficient evidence has been supplied by the applicants?
Please log this query on the application web site.
Yours sincerely
Chris Hurrell
On behalf of SEG
Comment submitted date: Mon 13 Mar 2017
Dear Mrs Evans
The minutes of the 08/03/2017 Planning Committee meeting record that Planning Officers will be meeting with some of the consultees to the application.
'The Planning Services Manager advised that Southern Water had raised concern in response to the consultation and therefore a meeting has been arranged by the Planning Officer to take place between Southern Water, the applicant and the County Archaeologist on 24th March 2017.
An update will be provided at the next Planning Committee meeting.'
We assume that this meeting will be covering drainage issues which affect discharge of Condition 7 and Archaeological Monitoring issues that affect discharge of Condition 6.
It is to the best of our knowledge unprecedented for such a meeting between Planning and Consultees to take place.
SEG tentatively welcome this move but have some concerns about such a meeting where discussions will not be available for review in the public domain.
Communications between HBC and consultees is normally in email form and the correspondence is recorded on the application web site in an open and transparent manner for the planning committee and all interested parties and the public to see.
It is essential that the Planning Committee have full access to the full detailed minutes of this meeting and the evidence discussed at this meeting when the discharge application is next decided by the committee.
The full detailed minutes should also be fully available to all consultees and the public.
We are concerned that the history of this application to date shows that consultees have not been provided with a full account of the issues affecting this application by planning officers.
We have concerns that a closed meeting could lead to an unbalanced view of the issues being presented to the consultees.
With these concerns in mind and for the removal of doubt we believe that the detailed minutes of the meeting should be recorded and made available on the application web site.
We also believe that in the interests of openness and transparency that an objective observer should be present at the meeting ? we hope that a local councillor would be acceptable in such a role.
We note that not all consultees affected by the discharge of conditions have been invited. The Friends of the Country Park and SEG have made significant comments on these issues.
We believe that in the interest of balance and for proper consultation these parties should also be represented at the meeting of 24/03/2017.
There is no mention of the discharge of planting condition 4 which remains very controversial.
The 24/03/2017 meeting sets a precedent for proper consultations between HBC and consultees about controversial planning applications.
We believe that another meeting between planning, the HBC tree officer and interested consultees such as the AONB, CPRE, Friends of the Country Park and SEG should be organised to discuss the issues concerning planting at Rocklands.
SEG would welcome the opportunity to discuss this issue with the relevant HBC officers.
We therefore request:
That meetings between HBC and consultees are fully minuted and the minutes are put into the public domain just like any other correspondence concerning planning applications.
That an objective elected representative is present at such meetings in the role of observer.
That the 24/03/2017 meeting is extended to include other consultees such as the Friends of the Country Park and SEG.
That a similar meeting is held to discuss the issues concerning discharge of condition 4 Planting with representations from HBC officers and consultees such as the AONB, CPRE, Friends of the Country Park and SEG.
Please log this correspondence as a comment on the application web site.
With thanks in advance.
Yours sincerely
Chris Hurrell
On behalf of SEG
Comment submitted date: Tue 21 Mar 2017
Hi please add my response as sensitive and mr hurrell's email as a rep (public)
ta
Eleanor Evans
Planning Services Manager
Development Management
Hastings Borough Council
Muriel Matters House
Breeds Place
Hastings
East Sussex
TN34 3UY
Tel: 01424 783251
Web: www.hastings.gov.uk/planning
From: Eleanor Evans Sent: 21 March 2017 10:55To: 'chris hurrell'Cc: Stephanie Roots; DCCommentsSubject: RE: HS/CD/16/655 Rocklands Discharge of Conditions - Meeting with Consultees
Dear Mr Hurrell,
Thank you for your email which will be forwarded to the case officer, as was your email of 13th March 2017.
I have copied in dccomments@hastings.gov.uk and would ask you again that any letters/emails you submit in respect of this application, whilst under consideration, or any other application that you may wish to write to us about, whilst live, include that email address in order to ensure the letter or representation is attached to the file. This is our procedure so it would helpful if you could remember this in future.
I note you have raised a number of queries in respect of the above noted application, which is currently under consideration. I should point out that letters/emails of representation are an opportunity for residents to express their views on the planning application and bring to light information material to the assessment of the application. The case officer, Ms Stephanie Roots, will have regard to all the points you have raised in your email and will take the appropriate action where necessary. However, given the volume of the letters of representations received as a whole, the Planning Service do not respond to letters of representation that are submitted. You can check to see whether your email has been received by going on line and viewing the application. You can also view all the latest plans on the web site associated with this application using the planning application reference number.
You may wish to view our Comments and Objections Leaflet using the following link:
http://www.hastings.gov.uk/environment_planning/planning/info_advice/leaflets/comments/
In terms of meeting notes, these are not as a matter of course placed publically on the web site. Stephanie will take a view as to whether the meeting notes in this case will be placed for public view on the web. Please also note that the meeting you refer to is not a public meeting. Furthermore, other meetings that may be held will not be public meetings and your opportunity to comment on the application will be in the usual manner, that being through the submission of letters/emails as you have been doing and through making a presentation at Planning Committee when the application is discussed. I would remind you, as mentioned before, that there is no statutory duty to consult with members of public or groups comprised of members of the public when considering applications for the discharge of planning conditions.
I hope the above is of assistance
Kind Regards
Eleanor
Eleanor Evans
Planning Services Manager
Development Management
Hastings Borough Council
Muriel Matters House
Breeds Place
Hastings
East Sussex
TN34 3UY
Tel: 01424 783251
Web: www.hastings.gov.uk/planning
From: chris hurrell [mailto:duckbrand@talktalk.net] Sent: 21 March 2017 10:07To: Eleanor EvansCc: Cllr James BaconSubject: RE: HS/CD/16/655 Rocklands Discharge of Conditions - Meeting with Consultees
Dear Ms Evans
Thanks for your email.
I note that my letter has been added to the case file.
However I have not received any answers to any of the issues raised in my email. I would be grateful if you could respond to my requests which I repeat below.
We request:
That meetings between HBC and consultees are fully minuted and the minutes are put into the public domain just like any other correspondence concerning planning applications.
That an objective elected representative is present at such meetings in the role of observer.
That the 24/03/2017 meeting is extended to include other consultees such as the Friends of the Country Park and SEG.
That a similar meeting is held to discuss the issues concerning discharge of condition 4 Planting with representations from HBC officers and consultees such as the AONB, CPRE, Friends of the Country Park and SEG.
Yours sincerely
Chris Hurrell
On behalf of SEG
From: Eleanor Evans [mailto:EEvans@hastings.gov.uk] Sent: 14 March 2017 07:32To: chris hurrellCc: Stephanie Roots; DCCommentsSubject: RE: HS/CD/16/655 Rocklands Discharge of Conditions - Meeting with Consultees
Dear Mr Hurrell,
Thank you for your letter of representation. I will pass this onto the case officer and the letter will be added the case file.
Kind Regards
Eleanor
Eleanor Evans
Planning Services Manager
Development Management
Hastings Borough Council
Muriel Matters House
Breeds Place
Hastings
East Sussex
TN34 3UY
Tel: 01424 783251
Web: www.hastings.gov.uk/planning
From: chris hurrell [mailto:duckbrand@talktalk.net] Sent: 13 March 2017 08:29To: Eleanor EvansCc: Cllr Richard Street; Cllr Michael Wincott; Cllr Judy Rogers; Cllr Alan Roberts; Cllr Bruce Dowling; Cllr Mike Edwards; Cllr Martin Clarke; Cllr Sue Beaney; Cllr Philip Scott; Cllr Matthew BeaverSubject: HS/CD/16/655 Rocklands Discharge of Conditions - Meeting with Consultees
Dear Mrs Evans
The minutes of the 08/03/2017 Planning Committee meeting record that Planning Officers will be meeting with some of the consultees to the application.
'The Planning Services Manager advised that Southern Water had raised concern in response to the consultation and therefore a meeting has been arranged by the Planning Officer to take place between Southern Water, the applicant and the County Archaeologist on 24th March 2017.
An update will be provided at the next Planning Committee meeting.'
We assume that this meeting will be covering drainage issues which affect discharge of Condition 7 and Archaeological Monitoring issues that affect discharge of Condition 6.
It is to the best of our knowledge unprecedented for such a meeting between Planning and Consultees to take place.
SEG tentatively welcome this move but have some concerns about such a meeting where discussions will not be available for review in the public domain.
Communications between HBC and consultees is normally in email form and the correspondence is recorded on the application web site in an open and transparent manner for the planning committee and all interested parties and the public to see.
It is essential that the Planning Committee have full access to the full detailed minutes of this meeting and the evidence discussed at this meeting when the discharge application is next decided by the committee.
The full detailed minutes should also be fully available to all consultees and the public.
We are concerned that the history of this application to date shows that consultees have not been provided with a full account of the issues affecting this application by planning officers.
We have concerns that a closed meeting could lead to an unbalanced view of the issues being presented to the consultees.
With these concerns in mind and for the removal of doubt we believe that the detailed minutes of the meeting should be recorded and made available on the application web site.
We also believe that in the interests of openness and transparency that an objective observer should be present at the meeting ? we hope that a local councillor would be acceptable in such a role.
We note that not all consultees affected by the discharge of conditions have been invited. The Friends of the Country Park and SEG have made significant comments on these issues.
We believe that in the interest of balance and for proper consultation these parties should also be represented at the meeting of 24/03/2017.
There is no mention of the discharge of planting condition 4 which remains very controversial.
The 24/03/2017 meeting sets a precedent for proper consultations between HBC and consultees about controversial planning applications.
We believe that another meeting between planning, the HBC tree officer and interested consultees such as the AONB, CPRE, Friends of the Country Park and SEG should be organised to discuss the issues concerning planting at Rocklands.
SEG would welcome the opportunity to discuss this issue with the relevant HBC officers.
We therefore request:
That meetings between HBC and consultees are fully minuted and the minutes are put into the public domain just like any other correspondence concerning planning applications.
That an objective elected representative is present at such meetings in the role of observer.
That the 24/03/2017 meeting is extended to include other consultees such as the Friends of the Country Park and SEG.
That a similar meeting is held to discuss the issues concerning discharge of condition 4 Planting with representations from HBC officers and consultees such as the AONB, CPRE, Friends of the Country Park and SEG.
Please log this correspondence as a comment on the application web site.
With thanks in advance.
Yours sincerely
Chris Hurrell
On behalf of SEG
Comment submitted date: Fri 26 May 2017
Please see documents tab.
Comment submitted date: Thu 15 Jun 2017
Email + Attachment - see IDOX:
Dear Sir/Madam
Please see attached our further objection to discharge of condition 4 (details of the planting scheme and soft landscaping) following agent's email of the 05/06/2017.
Please record this objection with a title of 'Objection to discharge of condition 4 planting following agent's email of 05/06/2017'
Yours faithfully
Chris Hurrell
Comment submitted date: Thu 22 Jun 2017
Please see documents tab.
Comment submitted date: Mon 10 Jul 2017
Many thanks for your email concerning the petition for this application.
I would like to confirm that we wish to speak and the petitioner will be Mr Bob Okines as before.
The petition previously submitted was in respect of the discharge of condition 6.
Mr Okines would like to concentrate his speech to the committee on discharge of condition 4 (planting scheme).
Can you please confirm that we do not need to submit a new petition in order for Mr Okines to be allowed to speak on the discharge of condition 4.
If we need to submit a new petition to speak on planting conditions please let me know the deadline for submission of the petition.
Thanks in advance
Yours sincerely
Chris Hurrell
On behalf of SEG
Comment submitted date: Fri 14 Jul 2017
Please see documents tab.
Comment submitted date: Sun 16 Jul 2017
Please see documents tab.
Comment submitted date: Tue 18 Jul 2017
HS/CD/16/00655 | Discharge of condition 4 (details of the planting scheme and soft landscaping of Appeal A ref. APP/B1415/C/15/3029007 - (EN/15/00028) | Rocklands Private Caravan Park, Rocklands Lane, Hastings, TN35 5DY
A new planting scheme has been submitted at the last moment on the 17th July.
The application is scheduled for decision by the Planning Committee on the 20th July.
The deadline for comments has already passed as there are less than three working days until the meeting.
The new planting scheme requires review by all consultees. It is standard practice to allow two weeks further consultation when new documents are received.
There is insufficient time for consultees to be informed of this new version and for consultees to review the new planting scheme.
The changes to the planting scheme include confirmation that proposed plantings will be made on the Scheduled Monument. It is therefore necessary for Archaeology and English Heritage to be re-consulted on this matter.
Scheduled Monument Consent will be required for these plantings.
All other consultees including the AONB, FOTCP, CPRE and SEG need to be re-consulted about the changes to the planting scheme.
Archaeological and drainage conditions cannot be discharged until the planting scheme has been approved and the full impact of it on drainage and archaeology is known.
For these reasons it is therefore necessary for the consideration of this application to be deferred until the next Planning Committee meeting in August.
Please confirm that the application will be removed from the agenda for the July planning committee.
Yours sincerely
Chris Hurrell
On behalf of SEG
Mr Bob Okines
Comment submitted date: Thu 02 Feb 2017
Please see documents tab.
Comment submitted date: Wed 12 Jul 2017
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Cllr James Bacob
Comment submitted date: Wed 05 Jul 2017
Dear Ele,
Please may I call in the following: HS/CD/16/00655 | Discharge of condition 4 (details of the planting scheme and soft landscaping of Appeal A ref. APP/B1415/C/15/3029007 - (EN/15/00028) | Rocklands Private Caravan Park, Rocklands Lane, Hastings.
The main reason for calling this in is due to the proposed scheme not meeting the conditions proposed by by the planning inspector for the appropriate screening and planting scheme. It is important that sufficient screening is in place with appropriate and increased planting to protect this area of natural beauty.
Many thanks.
Kind regards,
James
Councillor James Bacon
Old Hastings Ward
Hastings Borough Council
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Mrs Lynne Okines
Comment submitted date: Wed 01 Feb 2017
Not Available
Mr Chris Lewcock
Comment submitted date: Mon 21 Nov 2016
Hi Eleanor
Slightly puzzled by the wording of the recommendation on HS/CD/16/00655. Shouldn't it refer to the partial discharge of the condition since the exploratory works required to be carried to within 3 months haven't yet been carried out or assessed? I would suggest at least a covering letter to the applicant reminding them that the clock has started ticking on the second half of the condition?
Hope that is helpful.
Chris
Comment submitted date: Fri 27 Jan 2017
Dear Eleanor
You were kind enough to advise me back in November on the extended compliance period you had granted for the enforcement notice on HS/CD/16/00655. I note that since that time two planting schemes have been submitted. The first was presumably deemed unsatisfactory and the most recent, with a mere change of tree species, doesn't appear much better, if at all. Neither seems likely to match the substantial requirements set out by the Inspector. Possibly some degree foot-dragging is going on by the applicant? Having given the applicant generous time and two goes at it I should think that the Council is now well placed, and would be fully justified, to pursue action for non-compliance? It would send a valuable signal of the Council's future determination in such matters?
Mr Stephen Hardy
Comment submitted date: Thu 15 Sep 2016
14 September 2016 Hastings Borough Council Planning Department Town Hall Queens Road Hastings East Sussex TN34 1QR Dear Sirs HS/CD/16/665 ? Rocklands On behalf of CPRE Sussex, we wish to object to this application for discharge of conditions. The reason we object is as follows: The scheme is incredibly thin in terms of the quantity of tree cover proposed. There is a balance which needs to be achieved between the growth of trees and the effectiveness of cover. We do not believe that the number of trees suggested, and the time it would take for them to mature into adequate screening cover is sufficient to compensate for the visual detriment the unscreened building presents. The building, unscreened, has a hugely detrimental impact on the High Weald AONB, as well as being part of an extremely sensitive ecological area. This was emphasised in the Inspector's decision (paras 18 and 19). The Inspector also suggested in para 36 the planting of semi-mature specimens. We leave it to others more knowledgeable than ourselves to suggest the type of trees to be used. Yours faithfully Stephen Hardy
Comment submitted date: Fri 06 Jan 2017
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Comment submitted date: Fri 27 Jan 2017
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Comment submitted date: Fri 27 Jan 2017
This is a response to the revised planning scheme recently submitted to yourselves in respect of the requirement for a planting scheme for the above premises.
We wish to object to the scheme for the very simple reason that the scheme as presently revised fails absolutely to achieve the necessary aim of the required planting scheme i.e. that of attempting to screen views of the building from the public access points within the Country Park which is what it should be doing. Instead the planting perversely would achieve screening for the benefit of the caravans in the caravan park, rather than for the benefit of the substantial number of people who walk the Country Park.
We are not able to comment on the change from very small holm oak to very small English oak, but given the quantity and the size of trees has not changed we suggest that such a change in specification is totally meaningless in the context of the principled objection we have raised above.
Andrew Blackman
Comment submitted date: Wed 21 Sep 2016
I write as Chairman of the Friends of Hastings Country Park Nature Reserve, on behalf of the committee. We object to the application to discharge conditons 4, 6, 7 and 8 in relation to the new building at Rocklands Caravan Park. Our main concern is with condition 4 relating to screening of the holiday let, though this is no way implies that we feel any of the other conditions are worthy of discharge. The Landscaping Plan is, in theory, submitted to address the Inspector's concerns about the highly detrimental visual impact of the new building on the Country Park. The Landscaping Plan proposes the planting of three evergreen oak whips of 8-10cm - we feel that is all anyone needs to know to realise the staggering inadequacy of the scheme. Absolutely no attempt has been made, true to well-proven form, to come up with any serious plan to mitigate the enormous damage which this building has done to the Country Park and the AONB. Will HBC now show that they are willing to do anything on their side to protect the Country Park? The Friends' committee very sincerely hopes so; this is the council's last chance to act on councillor's much-repeated claim that they value the Country Park as one of the town's most valued assets. Please see documents tab.