November 2006 Representation

King Alfred/RNR site development, Hove

Objections of the Regency Society of Brighton and Hove

The Society believes that the King Alfred/RNR site does need redevelopment and this offers an opportunity for a major addition to the architectural heritage of the city. It welcomes the decision of the developers to engage a team of considerable reputation at national and international level. However, it is convinced that the choice of this team, led by Frank Gehry, should not lead to a suspension of a normal critical appraisal of any proposals put forward. Our views on this aspect have been strengthened by the apparent acceptance of all of the Gehry schemes for this site by the political leadership of the Council, even those which Gehry has later disowned as being unsuitable. And we are reinforced in our concern by the wording of the CABE letter of 23 October 2006 in which it is stated ”Given the long term involvement of the architect in the scheme, we are confident that the issues we raise can be addressed. We do not wish to see this project again”. This appears to suggest that Gehry’s reputation enables his project to avoid checks and scrutiny that lesser architects undergo.

Facilities
We do welcome the range and scale of the sporting facilities provided for residents and visitors to the city. But we believe that the scheme should demonstrate adaptability as leisure facilities are particularly prone to changes in fashion and new directions.

Impact on the area and neighbourliness
Our major concern is about the impact of the development on its neighbours. Even with the reductions now proposed, the perimeter blocks on the south side of the Kingsway and the west side of St Aubyns South will have a devastating impact on the residents of existing residential buildings. Indeed, the position in relation to St Aubyns Mansions has worsened.
They face a wall of buildings and have their sunlight and daylight reduced to an unacceptable degree. The applicants in their submission state

‘1.209 The daylight results show that there will be some reduction beneath the BRE Guidelines, particularly within 1-8 St Aubyn’s Mansions. Some reduction beneath the BRE Guidelines is inevitable if any new development has a greater massing than that already existing on the site. It should be noted that those windows within the surrounding properties, which overlook the site, currently enjoy an uncharacteristically high level of light amenity due to the open aspect over the open car park and low-rise buildings currently on the site.

1.210 In relation to sunlight, properties north of The Kingsway again enjoy particularly high levels of existing sunlight. The scheme will reduce thesunlight to some of these rooms beneath that recommended in the BRE Guidelines. The impacts to sunlight will be minor to moderate.

and

1.214 In relation to transient overshadowing, there will be relatively little overshadowing during the summer months. However, for the winter months there will be an increase in transient overshadowing, particularly to the properties north and east of the site. This is not unusual for an urban environment. ‘

There will be a 29% permanent overshadowing on 21 March and the Transient Overshadowing Assessment studies produced by the applicants show massive impacts especially in the winter quarter. Thus we have the situation that residents who at present enjoy an excellent degree of daylight and sunlight, will be asked to accept a lower standard than the minimum recommended because they are in an urban environment. This adds insult to injury. The proposals are contrary to policy QD27 of the adopted Brighton and Hove Local Plan 2005.

The Society considers that some of the photomontages are misleading. For instance, the photomontage in the Technical Annex 7: Landscape and Visual Assessment, viewpoint 86, is grossly misleading in showing the impact of the of the tall perimeter buildings rising to ten and seven storeys on residential properties on the north side of Kingsway as the viewpoint is taken from a position at the southern end of Princes Crescent, a significant distance to the West of Hove Street. If it were to represent the true impact, the viewpoint should be close to the traffic lights. The photomontage from viewpoint 91 shows the new buildings in monochrome which underplays their visual impact.

Urban and Architectural design
The site adjoins the Cliftonville, Old Hove, Pembroke and Princes Conservation areas . Whilst one of this area’s characteristics is that, unlike other parts of Hove, there is no dominant architectural style it is an area which is predominantly residential set around a Victorian grid pattern of streets. There is a mixture of well-proportioned, elegant Victorian and Edwardian houses and flats on land which slopes gently to the shore giving many of the residents an open prospect of the sea. The overall attribute of the area is one of openness for both residents and visitors. Any overdevelopment will destroy this ambience. Relating to these considerations, we have a number of strong concerns and fears about this scheme.

Judging the architectural merits of the scheme is bound to be subjective. The two towers have a sculptural, if eccentric, appearance. As shown in the submissions, they have a delicate white, cut-paper, almost translucent appearance. On the montages, the viewer gets the impression that he/she will be able to look through the building but structural floors, vertical partitions, furnishings, curtains etc. will inevitably block these views removing this feeling of lightness. There is a lack of clarity as to how the towers will work in practice and how they will appear in reality. This should be made more explicit before a judgement can be reached on whether this part of the scheme is acceptable. But we are concerned that, when developed the tall buildings may not be merely “distinctive and quirky” (CABE letter , 23 October 2006) but overbearing, domineering, harsh and unfriendly.

Where the buildings abut the promenade, there is no detailing of a human scale. Instead the nine-thirteen storey buildings appear to rise straight up from the back edge of the promenade with no concessions to the quite different scale of people enjoying the promenade. There appears to be nothing to encourage people to venture close to the proposed new buildings. On the contrary where the flats abut the promenade, people will feel it would be rude to venture too close. They will feel pushed away by the scale of the buildings. The ten storey block facing west over Hove Lawns will be a slab-like wall dominating and reducing the visual scale of the open space. This conflicts with policy QD2 of the adopted Brighton and Hove Local Plan 2005. The Sports centre juts out over the Esplanade interrupting the east-west vista.

Whilst we welcome the inclusion of piazzas with south facing entrances, we consider that, as they would be hemmed in by tall buildings ranging from twenty-nine to seven storeys, they will become dark and overlooked working more as draughty corridors than pleasurable sitting out areas, this especially true of the East Piazza (see page 333 of Technical Annex 8: Microclimate) This is contrary to policy SU2 of the adopted Brighton and Hove Local Plan 2005. These concerns appear to be shared by CABE (23 October 2006).

Materials
We do have concerns about the use of colour as shown on the submitted plans. The use of most colours is driven by fashion and, as such, can become quickly dated. But other colours are so abrasive and extreme that they are offensive to their surroundings. We feel that the garish colours used for the landward frontages of the sports centre will add a jarring note to viewpoints in the residential areas especially Vallance Gardens? In this context we note that, according to Hugh Pearman in The Sunday Times, (11 September 2005) Gehry himself had favoured a more subdued colour scheme but was ‘urged to be more extreme by the government’s advisors (CABE)’. This is said to reflect the ‘lively, slightly louche nature of the seaside city’ but that is not the tradition or context of Hove. As it now stands, the proposals are contrary to policy HE6 of the adopted Brighton and Hove Local Plan 2005.

We also have major concerns about the use of a “cladding system (which) consists of an outer painted metal rainscreen and inner window wall”. How will this be maintained in the log term in such an exposed site?

Private Amenity Space
Although the scheme includes over 700 flats, there is no private amenity space as required by policies HO5 and HO6 of the adopted Local Plan. This will leave the residents of the flats and their children without safe play space near at hand. Payments for off-site provision will not meet the need.

Traffic
Despite the proposals for car sharing etc and the generous assumptions made for the use of other forms of transport, there will also be very significant amounts of extra traffic. The applicant’s consultants estimate ( Table 5.12 of the Transport Assessment Report) that there will be 4752 week day movements generated by the development onto a road (Kingsway) which was intended to be relieved of traffic when the A27 by-pass was constructed. The additional amount of traffic will conflict with policy TR1 of the adopted Brighton and Hove Local Plan 2005.

Infrastructure
Policy SU15 of the adopted Local Plan requires new development to be compatible with existing or possible new infrastructure. We are not clear what work has been carried out by the City Council to determine what thresholds apply to present levels of infrastructure. How much new development can the Victorian sewage system absorb. This major scheme could have very significant consequences for drainage and water supply unless the Council can show that it is within the limits of present capacity.

The amount of development
We have come to the conclusion that the scheme is flawed and that this stems from the amount of development proposed. This is a result partly of the brief. The City Council expects the developer to provide both high quality sports facilities and affordable housing on a site which has difficult physical conditions. This is a recipe for overdevelopment. Our view is confirmed by reference to the Adopted Local Plan where the amount of development expected from the site is put at 300 units (Table HQ1) and 200-400 units (Paragraph 6.99) rather than the 754 units now proposed. The scheme, therefore, puts forward almost double the maximum figure set out in the Local Plan. At its meeting on 6 October 2006, the Policy and Resources Committee of the City Council resolved to explore the possibility of reducing the amount of development on the site by siting some of the affordable housing on other sites in the city. Nevertheless this new application has been submitted which takes no cognisance of this decision.

A Green scheme?
Much has been made of the green credentials of the scheme, but in actuality the scheme is weak relative to the criteria for sustainable development

The scheme fails to make best use of natural light, a fundamental principle of sustainable development. A number of the new units will enjoy poor levels of natural light, particularly units on lower floors looking into the piazzas and there will be a substantial reduction in the natural light received by neighbouring properties (as noted above).

The scheme fails to minimise the demand for power from the national grid. The electricity generated on site would make only a nominal contribution to the schemes energy requirements; the wind turbines would produce only 17% of the landlord’s requirements and the solar heating arrangements would benefit only the top two or three floors of flats; a sustainable scheme would generate a very high percentage of its energy requirements on site

The residential and commercial elements of the scheme fail to achieve excellent sustainable construction ratings. The flats are only rated as Ecohomes very good and the commercial space BREEAM very good. For a scheme to be branded as sustainable the ratings of Ecohomes excellent and BREEAM excellent should be at least achieved and preferably exceeded.

Legal problems
We also have concerns that the proposed section 106 agreement will be made with a shell company.  This leaves great potential problems in enforceability.  We do not see how the agreement could be made until the developers have acquired the site as they will not have the necessary interest in the land. That will not be achieved until the freehold/ or a long lease have been transferred to the developer. An alternative mechanism should be found; for example, the monies required for section 106 obligations could be added to the contract price for the land and the Council as land owner would then have the resources for the section 106 obligations. Non-financial obligations, that would normally be covered by section 106, could similarly be secured by obligations on the land transfer.

Conclusion
The Society feels very strongly that the present scheme is unacceptable and that planning consent should be refused. However, if the City Council is minded to approve it, The Society feels even more strongly that the scheme ought to be ‘called in’ and be the subject of a public inquiry. This is not only because of the controversial nature of the proposals, but the need to be seen to be completely above board when dealing with a major site owned by the City Council.

A way forward?
As we wrote in November 2005, we would be reluctant to see the loss of the benefits arising from the scheme. However, the amount of development could be reduced. One possible solution would be to remove the affordable housing from this site and to provide it on another site owned by the City Council elsewhere in the city. This strategy could be achieved by legal agreements with the City Council as land owners and a section 106 agreement with the City Council as Local Planning Authority. This would enable a less dense and more neighbourly scheme to be planned for the site. We were gratified to read that the Policy and Resources Committee has voted to explore this option.

Dr Michael Ray
Chairman
23 November 2006