Our response to the Officers report     ( APRIL)

We disagree with the officers reasoning.
We believe the officers report is unbalanced, questionable and potentially flawed.
The recommendation is one opinion and contains many subjective views.
Some statements contradict what thousands of residents have said. Their comments are summarized, then completely ignored.

'Werther's Original' *
Whole sections are warmly benevolent toward the development - but this is in complete contrast to the strong condemnation by the only specialist opinion involved. 

Text is copy-pasted directly from the developers submission.
Documents are accepted wholesale.
We believe the council would benefit from a second opinion.
No SPD exists for tall buildings in the borough. The public has not been consulted on building heights.
At the very least this should go to public inquiry.

Conservation Area Statements are missing

94-104: The Site and Surroundings section still refers to heights in numbers of storeys instead of absolute measurement in meters. This muddles office and residential comparisons and conceals the fact that the proposed tower is vastly higher than other tall buildings in the vicinity. It should be a condition that if permission is granted then each tower height should be specified to a maximum height in meters. ( Refer to planning case history )

127: "It is important and essential that the consideration of this application is considered against the context of the proposed regeneration of this part of the town centre, and not the existing quality, appearance, character and density of the area." - and yet the opposite has been used in reasoning:  "unloved"  "underutilized" "at risk" for example item 271 should not use "underused urban block". The Eden Walk proposal which is already in consultation has been completely disregarded. The confusion and combined impact of the twin towers from these adjacent schemes haven't been taken into account. This is surprising since the Area Action Plan has planned for the Eden Walk landmark long before the 19 storey block on this old post office site.

130: The Eden Quarter Development Brief SPD requires both listed buildings to be retained. The cost therefore must be reflected in the land value in the viability calculations.

This is not sustainable development
137-140: The NPPF applies a presumption in favour of sustainable development. The arguments that this is sustainable are questionable. Economic role: we question the viability of restaurants in the old post office given the significant harm of near year-round shade and wind issues;
Social role: the lack of child play areas, the smaller than guideline room sizes, the poor aspect of some homes, the density ( item 154). We predict the substandard homes will generate future public health problems;
Environmental roles: Historic England condemns the scheme due to the harm to the historic assets both on and off the site. This view is unchallenged. 
Employment land is not protected
145. 75% of the existing office space is lost with this proposal. The under use of existing office space is a poor defense. 
148, 150. "Future office floorspace is planned for the wider Eden Quarter area" - This is not ring-fenced. Future plans may not happen. This is a weak defense. You can't cherry-pick from future developments to back your developer.

161. We strongly disagree with statement "The scheme is broadly compliant with the Eden Quarter Development Brief with regards to ...  the scale of the development."
Has the accumulated impact been carefully considered? How so? By Heritage England?
 
158 & 162: Much is made of "improvements" in the April revision. What should be assessed is the proposal as it stands, not whether the revision is now less bad than the original submission. This is irrelevant.

Impact on Character of area ignores adjacent conservation area.
Impact on view into and out of the adjacent conservation area are completely missing in this section of the assessment.

168  Conclusion on the wind environment is unsubstantiated. Wind tunnel tests have not been done so the wind environment concerns are not dis-proved. 

Historic England is being ignored
174-212 The Impact on Heritage Assets, views and the conservation area: The largely subjective assessment is mysteriously warm and benevolent toward the development - this is in complete contrast to the evidence.
It is strongly condemned by the only specialist opinion involved: Historic England recommends the council should refuse the application. This stops the application dead in the water. The Officers have failed to provide alternative specialist expert advice that counters this advice.
Personal differences are not grounds to disregard the national body charged by Government to advise on national and local heritage - who state that the proposal "fails to meet statutory tests".
It is strongly condemned by the overwhelming voice of thousands of residents who petitioned, swarmed, wrote, emailed, and turned out in numbers to speak up against this.

219. Below standard room sizes and comments from the Design Panel are at odds with the assertion that "The residential accommodation proposed would generally provide a good standard of accommodation"

223. A FOI request has sought transparency on the Viability. We note the council is yet to respond.

259. The two archaeological conditions are not specified.
262: Wind microclimate is unknown because wind tunnel tests have not been carried out.

267: "The Environmental Statement along with the additional
information contained in the addendum to the Environmental
Statement presents a sound assessment of the likely impacts of the development." -  this is a very broad and sweeping statement of acceptance. Again mysterious warm benevolence toward the development. 




* Werther's Original - a caramel flavoured candy, often given to grandchildren.
Given all of the above, we don't believe the conclusions are sound, reliable or balanced. It would therefore NOT be wise to permit this development based on this report. 

We strongly encourage Council to REFUSE this proposal.


Here is one of the 512 letters of opposing this development - example letter