HS/FA/24/00549
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Variation of condition 3 (approved plans) of Planning Permission HS/FA/15/00175 (as varied by Planning Permission HS/FA/17/00439, HS/FA/18/00291, HS/FA/20/00369 and HS/FA/22/00635) (Conversion of Grade II listed building to create 24 residential units, demolition of all other structures and erection of 97 residential units, with associated cycle and car parking spaces, new vehicular access from Archery Road, associated landscaping and enabling works) - Amendment to Blocks A and B to create 5 additional flats and associated external alterations and relocation of bin/cycle stores.
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Site of former Hastings College of Arts and Technology, Archery Road, St Leonards-on-sea, TN38 0HX
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Mr Christopher Hurrell
Comment submitted date: Fri 16 Aug 2024
This application is a RETROSPECTIVE application to increase the number of units by 5 units from 112 to 117 units. Work has already started on the units.
I object on the grounds that it does not comply with policy H3 affordable housing.
The additional 5 units mean that to comply with policy H3 additional affordable housing contributions have to be made. The current permission allows for 28 units out of 112 units which meets the minimum of 25% affordable housing. The existing S106 agreement needs revision to ensure that the developer makes the full affordable housing contributions required under policy H3.
The site has a history of diminishing affordable housing contributions. The site was originally granted permission with a promise of 56% affordable housing. This was whittled down to the bare minimum of 28 units in 2018 with the loss of 30 units. An application in 2022 added a further 3 units to the total units without increasing affordable housing contributions.
This application does not mention increasing the affordable housing contributions. Hastings cannot afford to lose affordable housing and it must be ensured that the additional 5 units contribute another 1,25 affordable housing units.
The existing S106 agreement also needs revision to ensure that other planning obligations covered by the section 106 agreement are updated to allow for the additional 5 units. These contributions include libraries contribution, play facilities, policing and rights of way. This application does not mention increasing the other contributions.
This application should not be approved until a new Section 106 agreement has been approved by all parties which guarantees that affordable housing and other contributions reflect the increased number of units.
Comment submitted date: Thu 29 Aug 2024
This development has been subjected to a large number of variations. The accumulative effects of these variations is far, far more than minor amendments were intended to be used for.
Over time the developers have whittled away at the quality and appearance of the units, reduced the affordable housing by 40 units and are now cramming an additional 5 units into the development.
The development control manager had justified the use of variations on the grounds that as long as the number of units remain the same and the title of the application remans unchanged then variations are allowed. Little if any consideration has ever been given to the accumulative effects of a large number of variations.
Developers are very aware of our planning departments liberal interpretation of what constitutes a minor amendment and have exploited it to the hilt.
This latest (hopefully last) variation should require the submission of a fresh and full application. The number of units has changed as has the description of the development. The accumulative effects on this development over time justify a fresh and full application.
Comment submitted date: Mon 25 Nov 2024
I further object to this application on the grounds that a pre-commencement condition for the original application does not appear to have bene discharged.
There is no record online of Condition 17 Construction Management Plan for application HS/FA/15/00175 having been discharged.
Condition 17 states that: "No demolition or development shall commence on site until a Construction Management Plan setting out mitigation measures to protect against disruption caused during demolition and construction has been submitted to and approved in writing by the Local Planning Authority"
Failure to discharge pre-commencement conditions before works are started can render an application invalid. This appears to be the case with application HS/FA/15/00175.
The current application seeks to vary application HS/FA/15/00175 which appears to be invalid due to failure to discharge the pre-commencement condition for demolition and construction.
If HS/FA/15/00175 is invalid it cannot be varied.
Comment submitted date: Wed 05 Mar 2025
Following the publication of the committee report on 04/03/2025. I wish to make a further objection concerning the failure to discharge pre-commencement condition 17 Construction Management Plan.
The committee report incorrectly claims that pre-commencement condition 17 Construction Management Plan was discharged by HS/CD/17/00448 in August 2017.
The committee report incorrectly states that
"Construction Management Plan. [Officer note: approved in August 2017 planning reference HS/CD/17/00448] "
This is incorrect. There is no record of condition 17 being discharged with HS/CD/17/00448.
Please provide evidence that condition 17 has been discharged.
Condition 17 was a pre commencement condition. Failure to discharge a pre-commencement condition invalidates the original permission HS/FA/15/00175 . An invalid permission cannot be varied.
The changes proposed by the current application and all other works carried out require a fresh and full application and cannot be dealt with using a variation.
HS/CD/17/00448 did not discharge condition 17 Construction Management Plan as incorrectly claimed by the committee report.
The decision notice for HS/CD/17/00448 dated 18/08/2017 states that the condition is still outstanding and not discharged:
"Condtions 6 (bridge details), 7j (verandah), 7k (enclosure), 7m (wall, railings & gates), 7n (portico), 7o (external stairs), 7p (lantern), 7q(i) (garden wall), 7q(ii-iii) (demolition of wall), 17(construction management plan) are still outstanding as at the date of this decision notice. The condition cannot be fully discharged until the works are completed in accordance with the approved details."
Condition 17 of permission HS/FA/15/00175 reads:
17. No demolition or development shall commence on site until a Construction Management Plan setting out mitigation measures to protect against disruption caused during demolition and construction has been submitted to and approved in writing by the Local Planning Authority. The management Plan shall Include:
a) Parking for vehicles of site personnel, operatives and visitors; b) loading and unloading of plant and materials; c) storage of plant and materials d) programme of works (including measures for traffic management) e) Proposed methods of excavation, demolition, piling and all other construction associated with the development; f) Noise and vibration monitoring arrangements for any piling that may be undertaken; g) Methods of controlling dust emissions from the site h) Details of wheel washing facilities and equipment to be provided during periods of demolition, excavations, earthworks and construction to be provided within the site to prevent the carrying and deposition of mud, dust or other debris on their wheels and to prevent contamination and damage to adjacent roads.
Comment submitted date: Wed 05 Mar 2025
Following the committee report I wish to object on the grounds that affordable housing contributions have yet again been whittled down on this application. Hastings has a housing crisis why are we still indulging developers with reduced contributions? The ctte report has reduced the 150k suggested by HBC housing to 96k. A discount of 54k for the developer.
HBC Housing in their consultee comments requested that 1.25 units be provided as a commuted sum. they stated that this commuted sum should be 150,000 pounds.
The committee report has reduced this amount to around 96k. No explanation has been given as to why the recommendations of housing have not been complied with.
Comment submitted date: Fri 07 Mar 2025
Please see documents tab
Despina Anagnostelis
Comment submitted date: Thu 06 Mar 2025
Further to my previous comments on affordable housing.
The HBC housing consultation comments are not based on a market figure for the 5 additional units. The 150k figure appears to be the results of a worked example plucked from the air. It's a shame that housing could not have commented based on the real market values of the units.
The application does not give any details of the 5 additional units. Are they studio, one bed, two bed flats or larger? This remains unclear.
Planning have not provided the estate agent market evaluations of the units. Planning has merely stated that the contributions will be 96k. Without knowing the average market value of the units its not possible to asses whether the 96k for 1.25 units is reasonable. It would be in the interests of open and transparent decision making to have the evaluation information published for the committee and the public.
A 96k Affordable housing contribution for 1.25 units suggests that the average open market value(OMV) of a unit has been set at 192,000 pounds. Without further details of the units and the estate agents evaluations this figure seems on the low side.
Policy H3 calculation states that the contribution should be the residual value multiplied by the number of AH units. where the residual value = 40% of the average OMV of the units .
The infrastructural elements of the S106 have not been upgraded to include the additional 5 units. No evidence has been supplied that ESCC , police and HBC parks and open spaces were consulted and are happy to not increase the contributions.
Comment submitted date: Fri 07 Mar 2025
I wish to raise a further objection concerning the misuse of Section 73 applications.
Looking at the numerous variations to the original permission it is clear to see that the planners are not following the rules, they might have found some obscure case law that suits their latest argument, but they are not following the rules of a 'Section 73 Application'. The 'amendment' should sit alongside of the original, which remains intact and un-amended, with all conditions copied over to the new approval, unless they have been discharged. In the case of discharged planning approvals, the details of the approval are copied over to the new approval.
Each amendment seems to have a new set of conditions, which cannot be cross-referenced to the original, as though they are considering the new approval as being stand alone. They are stating that they are amending condition 3 of the original approval, but the plans on the previous 'amended' approval are condition 1.
Although they are careful to use the wording from the original approval in the description, the description has changed where the 'amendments' are included within the revised description. In my view the previous amendments should not have been accepted, as they changed the description of the original approval - by decreasing the number of units and changing the volume, and then increasing the number of units within the void of Block J that was previously designed as being storage space.
Gem Select's Agent, who is Kember, Kember, etc, etc, states in one of the 'amendments' that the developer has the option of taking part of the amended application, whilst working to the plans from the original - This is another interpretation of cherry picking and choosing what application to implement/ or work to/from. As far as I am aware the developer has the choice of working to the revised plans, or sticking to the original, they cannot mix and match from separate variations to suit.
The developers use the wording 'minor material amendment' on HS/FA/17/00439. Filling the void within the footprint of the blocks A and B was something that had already been considered under 17/00439; filling the void which was an original proposal for bin and cycle storage with 3 units under 17/00439, which would do a lot to alleviate the housing crisis within Hastings, is now being used as a proposal within this latest application. The large void under the properties, which is large enough to accommodate an extra five units was obviously featured into the original design; I wonder why it was not questioned when the original was approved, as it was obviously not an effective use of space, when there is room within the development to accommodate extra car parking spaces and bin and cycle storage elsewhere on site. This trick is obviously in line with the extra-large roofing structures used on other applications that can accommodate extra bedroom within the void at a later date as a 'material amendment'.
How many other blocks can have the same treatment once this application has been approved? Filling the void within the footprint of the building requires more than internal changes, there are the access, new doors, windows, balconies - the void is obviously not entirely sub-terrarium, or there would not be access to the newly created gardens. Locals have said that the development under this latest proposal has already started, the addition of access, doors, window openings would be an indication.
There is nothing within the case study that even mentions increasing the number of units, so the planning officer's liberal view/interpretation is misplaced. The case study was to change the design of one unit... The description of the proposal did not change by the approved plans being revised.
It seems as if the case officer, whose views appear copied from the applicants agent submission , is arguing that amendments to the original approval can be endless, unless the description within the original approval does not increase, this is incorrect , as the description is changed within each subsequent amendment. The developer must be working to the latest approval, which was for three additional flats, or they would not be considered within this latest proposal - do they propose to build 117, if this application is approved or 121?
The application is a complete and utter confusing mess. I suspect that this obfuscation and confusion is deliberate and makes proper consideration of applications nigh on impossible. It is no wonder that enforcement in Hastings is totally ineffectual, as they would not have a clue what conditions were being breached.
The continued misuse of section 73 variations continue to the benefits of developers. It is time that HBC prevented such misuse of section 73 and prevented developers playing the system.
Mr Gordon Abbey
Comment submitted date: Wed 14 Aug 2024
I live in the townhouse immediately next to this development at %comment redacted% The developer has been presumptuous and already constructed these additional flats without permission in place. They have chosen not to directly engage with neighbours to discuss proposals and canvas support.
The bin stores have been moved in this proposal . The previous variation to these caused a major delay to the completion of my sale relating to boundaries and bin store access that delayed my completion by 6 months and now they have changed it.
The ground floor flats will directly look out on the side passageway and the rubbish and recycling bins to my property . I question the "Right to Light" of this proposal. Has this been modelled and demonstrated?
The proposal has been poorly thought out, not consulted on and already constructed by a greedy developer trying to squeeze more development into the scheme.
Comment submitted date: Thu 19 Dec 2024
I live at %COMMENT REDACTED% and am directly affected by the proposed variations to the original planning permission and subsequent variations and amended plans.
Firstly, this is a retrospective application has the developer has already implemented these changes albeit not complete which seems somewhat arrogant and an assumption that planning permission is a given!
Secondly, the submitted plans showing the existing properties is drawn incorrectly or the houses have not been built as the plans. There is no recess for our waste and recycling bins so these sit directly in the passage between the existing and new properties. The proposed new flat at Ground Floor Level openable windows are approximately 2 meters distance from my refuse bins.
Thirdly, my property boundary extends to the line of the current developers hoarding line. I am within my rights to park my vehicle unto the boundary. The Right to Light Survey has not taken this into account and this will only reduce the already negligible daylight and view for this flat.
The space and location for this particular flat is inappropriate and planning permission should be declined
Bernard McGinley
Comment submitted date: Tue 27 Aug 2024
Please see documents tab
Comment submitted date: Thu 12 Dec 2024
Please see documents tab
Ms Tiffany Dawn Waddleton
Comment submitted date: Wed 04 Sep 2024
Objection to Planning Variation for Archery Gardens: Addition of Flats, Reduction of Parking, and Unallocated Spaces.
1. Existing Parking Issues and Impact of Additional Flats
The estate is already struggling with a severe parking shortage, leading to cars being dangerously parked on roads and obstructing access. Currently, there are only five visitor parking spaces for the entire development of 112 units, and the only other designated disabled parking spot has been removed. The proposed addition of five flats, along with the reduction of parking spaces, including disabled spots, will exacerbate these problems. The plan to make parking unallocated will worsen the parking chaos, as there is no strategy to accommodate the increased demand from additional residents.
2. Misleading Information Regarding Traffic Access and Safety Concerns
Residents were originally told that the entrance and exit for the flats would be via Archery Road. However, the developer has shifted access to Archery Gardens, a narrower road that is already difficult to navigate. This change has raised significant safety concerns, particularly for the children who play on the green. Increased traffic will pose a hazard to residents and children, as the one-way exit through Archery Gardens increases vehicle flow in an area intended as a safe communal space.
3. Lack of Notification and Disregard for Residents' Rights
There have been numerous changes to the development without proper notification to affected residents, including this new variation. As residents within the designated notification area, we have not been informed, which raises questions about transparency and accountability. This variation is dangerous and unsound, compromising the safety and quality of life for existing residents.
4. Structural and Maintenance Issues of the Development
The current state of the estate reflects substandard construction. Paving stones are improperly laid, leading to frequent breakages, and building renders have not been applied correctly. Other communal areas, such as the greens and gardens, are poorly maintained. Despite these issues, residents are being charged maintenance fees. It is unjust for residents to bear the cost of these defects when they should be addressed by the developer before maintenance fees are imposed. A comprehensive repair of all defects, including individual 'snagging' issues like black mold and water damage, is required to ensure safety and quality standards are met.
5. Unaddressed Financial Obligations and Mismanagement of Maintenance Fees
The addition of more flats affects the division of maintenance costs among residents, yet the developer has not provided an updated breakdown of fees. Despite being promised no maintenance charges until all flats are sold, residents recently received bills while many blocks remain incomplete. The council must ensure that maintenance fees are fairly distributed and only imposed after the estate is brought up to an acceptable standard.
6. Overcrowding and Lack of Natural Light in Proposed Flats
The new flats are being squeezed into spaces originally designated for other uses, such as refuse storage, due to their poor location and lack of natural light. The proximity of the new flats to existing homes will reduce privacy and diminish the aesthetic appeal of the area. This overcrowding is a clear attempt to maximize profit at the expense of living conditions, raising serious concerns about whether these flats are viable, livable spaces or just a means to increase the developer's revenue.
7. Environmental and Safety Impact of Increased Traffic on the Communal Green
The communal green is a crucial recreational space for residents, especially children, but increased traffic threatens its safety and functionality. Delivery vans and vehicles frequently mount the kerbs, damaging paving slabs that were poorly constructed. With the additional traffic from the proposed flats, these issues will only worsen, imposing further costs on residents for repairs and undermining the community's safety.
8. Mismanagement of Planning Process and Retrospective Applications
The ongoing piecemeal changes to the development are being treated as minor amendments, but the cumulative impact is far beyond what was originally approved. This approach allows the developer to circumvent proper scrutiny and public consultation, effectively altering the development's character and increasing density without adequate consideration of the broader impacts. Retrospective applications, like the current one, undermine the planning process and erode public trust.
9. Impact on Affordable Housing Commitments and Lack of Compliance with Policy H3
The addition of five units without a corresponding increase in affordable housing contributions violates policy H3, which mandates that developments of this size must include a proportionate number of affordable units. The developer's history of reducing affordable housing contributions on this site highlights a pattern of non-compliance and disregard for local housing needs.
Conclusion and Recommendations
The proposed planning variation is fundamentally flawed, unsafe, and detrimental to the quality of life for existing residents. I urge the council to:
1. Reject the planning variation for any additional flats.
2. Instruct the developer to reinstate all parking spaces, including designated disabled spots, and to allocate parking to specific flats rather than making it unallocated.
3. Reinforce the original promise that entrance and exit to the flats will be via Archery Road.
4. Require the developer to address and rectify all defects in construction and maintenance before imposing fees on residents.
5. Ensure maintenance fees are only charged once the estate meets acceptable standards and costs are fairly allocated based on an updated assessment.
6. Mandate the completion of all outstanding snagging issues reported by residents, particularly those affecting health and safety, such as mold and structural damage.
This objection reflects the serious concerns of the community regarding the continued overdevelopment and mismanagement of Archery Gardens. The planning authority must take decisive action to protect the rights and safety of current and future residents.
Comment submitted date: Sat 14 Sep 2024
Additional to my previous comment. It has come to the residents of the estates attention this week after some residents of the existing flats (in 2 Archery Gardens) built on this site by GemSelect received a notice that Orbit, the social house provider that took over care of this block of flats did a fire safety and it is not up to code. The deficiency is serious enough that they've created a 24 hour a day, 7 days a week, in person walking watch monitoring the building for fire. This creates serious concerns about the safety of other buildings on the site, including the specific blocks of flat for this variation in which they constructed 5 extra flats in secret without approval.
Please reject this variation and do a council led inspection of all the properties on the site including the buildings that had requested the variation. It is concerning that the privately signed of building controls inspections for the flats were not properly done and therefore the council should inspect with its own inspectors rather than allowing GemSelect to choose their own.
Thank you.
Mr Stephen Van Dulken
Comment submitted date: Tue 10 Sep 2024
The Burtons' St Leonards Society objects to this application. As records show (cases HS/FA/15/00107 and HS/FA/18/00291 for instance), the Burtons' St Leonards Society and its members and neighbours have long been concerned about the meritorious development of the Archery Ground. This new case (HS/FA/24/00549) is unsatisfactory.
For most of this century, the future of the Archery Ground was a subject of intense dispute. STAG (Save the Archery Ground) explained why the proposals were unsatisfactory. The Laing /Gladedale proposals were resisted by STAG and other local residents, English Heritage, and the Burtons' St Leonards Society, who fought a long campaign to secure a concept that in its design and quality made some recognition of the architectural importance of the site. Case HS/FA/09/00482 for 134 units was refused and dismissed at Appeal.
Case HS/FA/13/00590 for 97 units (+ 21 at Decimus Burton's Archery Villas) was approved with conditions. This became the base case. With the arrival of Marcus Beale of Marcus Beale Architects, and some material alterations to this previously approved planning application, which have come about through the more iterative design process eventually HS/FA/15/00175 was put forward and accepted: an agreement uneasily arrived at on what the agreed future of the Archery Ground was to be. Unfortunately there followed a succession of 'variations of conditions', steadily reducing the quality of the development and the area. The present application is the eighth by Gemselect since 2015 (Discharges aside).
The pattern here has been one of evasion of responsibility and reneging on agreements, including cheaper materials and inferior design, This is a betrayal of the undertaking to 'preserve and enhance'.
Regarding HS/FA/15/00107, STAG said of Gemselect's proposals:
. . . the reality is simply that the new owners want to save money. The casualties will be the residents, their neighbours, the Conservation Areas and the surrounding heritage assets. A pared down, lower quality development will also undermine regeneration promises - and prospects - for both the site itself and the rest of St Leonards. [bold in original]
That was in May 2015 and the opinion has been amply vindicated. Gemselect reached for thin excuses such as expected antisocial behaviour problems, or alleged health and safety issues or maintenance problems. More accurately, motivation of cost saving led to deterioration and cheapness, degradation and watering down, in a Conservation Area regarded as of national importance.
The saving of Decimus Burton's Archery Villas caused the number of accepted units to go from 121 to 109, then to 112. Now it is proposed to go to 117 - or perhaps already has.
Case HS/FA/24/00549 is the 8th variation in as many years for the Archery Ground. There are no good reasons why the
Amendment to Blocks A and B to create 5 additional flats and associated external alterations and relocation of bin/cycle stores.
should be approved. Grounds to reject it include 'scope creep', tampering with the parking provision (and loss of spaces, including two disabled bays), damage to living standards and access, predictable damage to paving, loss of light, 'overlooking', rerouting of traffic from what was agreed, and extra noise and nuisance. The developer has not explained the proposals to local residents. The adjustment to the affordable housing provision in the present application is unexplained, and should be the subject of a new s.106 Agreement.
The Society understands the need for additional accommodation in St Leonards but this should not provide carte blanche for developers to ride roughshod over previously settled agreements. It is absolutely unacceptable to undertake works ahead of completing due process in an attempt to present a fait accompli.
In addition, it is preposterous for the developer's agent to assert that 'The proposals will help achieve this by utilising areas that were previously 'wasted' and by optimizing the efficient use of this part of the site'. A site so scrutinised over so long has no wasted space.
Please reject this application, which has no merit. The proposal is one of overdevelopment. The relentless pattern of Variations of Conditions is a form of gaming the system. There was an approved agreement about the accepted future of the Archery Ground, and it has been repeatedly reneged on. (For instance, the original planning permission provided 68 homes for affordable housing, with 46 homes specifically allocated for affordable rent. Application HS/FA/18/00291 reduced the affordable housing by 40, to 28 homes (for no clear reason), and provided no assurances regarding the provision of affordable rent. Now the developer seeks in HS/FA/24/00549 to squeeze in another five flats, with 'new vehicular access', all in a variation of condition. This is not appropriate procedurally, and not appropriate for this small part of St Leonards.)
Stephen VAN DULKEN
Chair, Burtons' St Leonards Society
Mr Neil Marshall
Comment submitted date: Fri 06 Sep 2024
I object to this proposal on the following grounds:
Removal of parking spaces to increase abodes will add huge pressure to an already short of parking spaces is absurd.
To remove disabled parking spaces is in my opinion is at least, immoral.
Subsequent increase in traffic, parking demand, deliveries and visitors.
This is retrospective planning, as the flats are built. Building works were concealed from view.
This is over development. The sole drive can only be for profit. No consideration or respect on show for residents welfare, children's and residents safety, or for the historic and aesthetics of the conservation area.
I question the right to light for the proposal, along with the Social Housing requirements not being met.
Increased footfall right outside our front door. Concerns over people parking on our drive.
This appears to be an attempt to overturn previous decisions made by the planning inspectorate.
Ms Dale Thompson
Comment submitted date: Fri 06 Sep 2024
HS/FA/24/00549
I object to this planning application on the following grounds:
1. Increase in number of flats (additional 5) will increase need for further parking. Parking is already an issue around Archery Gardens and on Archery Road.
2. Vehicle increase will put increased pressure on Archery Gardens, which is currently a safe green community space and safe for children. The increase in traffic will make this less safe for children. The current construction of the path around the green is very poorly constructed and slabs crack when cars/vans often mount the pavement. The increase in residents' vehicles and delivery vehicles will add to this problem. The cost of repairing the slabs will fall to the residents under the future maintenance schedule of the grounds which is not sustainable or practical.
Mrs Sarah Cerioli
Comment submitted date: Thu 05 Sep 2024
I object to the planning proposal of the extra flats. As a resident of Archery gardens there has not been any communication or consultation with residents regarding these extra flats. The plans when purchasing our house did not state this. The extra volume of traffic is a huge concern as children play outside and already traffic is busy. The flats car park is directly on to Archery gardens and this is going to directly impact residents. Parking also could be an issue as although allocated parking flat residents with more than one vehicle will park on the inner circle obstructing flow of traffic and emergency vehicle access.
Mr Nigel Mousley
Comment submitted date: Tue 03 Sep 2024
My wife and I are residents at this development and strongly object to the proposed changes including additional accommodation for the following reasons:
1. Vehicle overcrowding on a development with too few existing car parking spaces:
The flats occupy a space previously allocated to parking but additional flats will require additional parking not less parking. As parking is not allocated in this area and there is no plan to accommodate additional vehicles, one must assume parking for residents in these new flats will spill into areas not suitable for parking.
2. Additional vehicles exacerbating vehicle movements:
We were led to believe the access and egress for cars would be via Archery rd. we are now told egress will be one way and all vehicles exiting the flats will be through Archery gardens. This will sadly have an impact on the young families who currently have a safe place to play. More traffic becomes a safety issue limiting one of the few places children can play.
Inevitably the footpath areas will be mounted by delivery vans or cars exiting a narrow one way street. We know from our experiences of the last 3 years that these paving blocks are not fit for purpose with many replaced and many still to be replaced. Broken paving slabs is a further safety issue when we will be more reliant on the pathways.
We are requesting that the developer review their decision and replace the remaining paving slabs that are not backed properly, but Gem Select remain unwilling.
Clearly more vehicles moving through Archery Gardens will impact the residents and add to an issue not properly considered.
3. Proposed additional accommodation is too close to existing residents and lacks natural light:
Is it a viable proposition for a dwelling to have a metre or so of space between their windows and the side of an adjacent house. These flats will be have little natural light or privacy.
Also, in the initial planning proposal this space was allocated as a refuse area due to its uninhabitable outlook, so, is this a genuine attempt to provide a home for someone or just an attempt to create more profit.
Finally, what is the alternative plan for refuse. There is no space for the bins to live on the pedestrian path.
I do hope these comments will be considered.
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