Gardens & wildlife

Carelet 2013 wants Area J spaces

The developer, Carelet, is attempting to use Round Hill's forthcoming residents' parking scheme in a new planning application BH2013/00139 to revive an unsuccessful planning application BH2010/00083 requesting permission for 6 three-storey houses on a site where it is impossible to make any provision at all for parking.

Carelet cannot provide a single parking space on their application site, so they are after on-street spaces within the expected CPZ even before

[1] the Area J extensions have even been implemented and

[2] the number of parking permits which can be allocated to existing residents is known.

To have ones cake & eat it
They are pushing the Case Officer both to recommend granting BH2013/00139 (the car-free version of their unsuccessful proposal for 6 three-storey houses) while sounding out whether the Council would be able to offer their prospective residents Area J residents' parking permits when the expected Round Hill CPZ is implemented. The latter will happen before any of their houses could be built.

Go BH2013/00139 and filter "document type" by changing "see all" to "correspondance" [Click green button APPLY] then view developer's LETTER DATED 11/03/13.

Have our residents' concerns been forgotten?
Round Hill residents helped to get Carelet's appeal against refusal (for BH2010/00083) dismissed by the government's planning inspector. We submitted our own community parking survey during the appeal process to counter the developer’s transport report.

In support of BH2010/00083, Carelet's transport consultant (see Appendix C of TECHNICAL REPORT Part 5 dated 11th January 2010) claimed surplus onstreet availability (i.e. parking space for its prospective residents) in locations such as the junction of Princes Rd & Mayo Rd which are known to create obstructions to service & emergency vehicles.

Under the expected CPZ, these areas would be yellow lined.

The developer's hope in re-presenting BH2010/00083 as BH2013/00139 is that an expected CPZ (not yet implemented) would create onstreet parking spaces for their prospective residents. However, the whole idea of a CPZ is to reduce parking stress and to make neighbourhoods safer. Nobody voted for an increase in parking stress.

Carelet affects the whole of Area J
BH2013/00139 concerns several neighbourhoods

In presenting BH2010/00083, Carelet identified suplus available onstreet parking space, not only in Round Hill, but also in both the London Rd Station (north) and London Rd Station (south) areas.

Proposals like BH2013/00139 which want to take from the same limited infrastructure, soon to be grouped together within the Area J scheme, concern several neighbourhoods.

Undermining the purpose of CPZs
We should all resist proposals like BH2013/00139, where the developer cannot offer any parking on the application site so they take from our finite amount of on-street space within our controlled parking scheme.

Granting such proposals would bring CPZs into disrepute:

(1) reversing the benefits of rationing car use within densely populated areas where residents have voted for parking schemes

(2) deterring some residents outside of schemes from voting for them, even when competition for onstreet parking presents significant risks in relation to safety and access.

No on-site provision at all for parking
Should the resuscitated proposal BH2013/00139 succeed, it would generate an extra demand for 9 onstreet parking spaces within the extended Area J scheme projected for early summer 2013.

This would borrow infrastructure from the neighbourhoods to both north and south of London Road Station as well as Round Hill since permits for the extended Area J would allow onstreet parking over the entire area.

The extra demand for onstreet space would make it harder for existing residents who live just outside Area J (to the north, east and west) to be accommodated into schemes.

Council Officers are currently delivering the extended CPZ in response to neighbourhood petitions as well as the results of a 5-week consultation.

The Council refused an identical application on three separate grounds. However, the developer's appeal was dismissed on transport grounds alone.

Planning inspector shares parking concern
A single ground for refusal (Local Plan policy TR1) proved sufficient to cause the planning inspector to dismiss Carelet's 2010 appeal.

To access appeal decision, go to BH2010/00083 , filter documents by changing "Show all" to "Appeal Decision", then click on green tab APPLY. Select icon in the "view" column.

It is therefore logical for residents objecting to Carelet's resubmission (BH2013/00139) for policy TR1 to be used once again for the reason for refusal.

In opposing BH2013/00139 we therefore need to focus objections on the genuine purpose for which our CPZ is intended i.e. reducing parking stress and not adding to it.

For Carelet to succeed with BH2013/00139, there would need to be two major gaps in the planning process.

1. The Council would need to twist the purpose of residents' parking schemes.

Granting schemes like BH2013/00139, which cannot offer any parking on site, in densely populated neighbourhoods, would not commend CPZs in the future for their intended purpose. Gaining the support and confidence of local residents whether they live within a scheme of just outside one would become very much more difficult.

2. The Council would need to misunderstand or deliberately ignore their own policy HO7 (referencing controlled parking) in The Local Plan. This is one of the main policies quoted by the planning inspector in arriving at her decision to dismiss Carelet's appeal against refusal. In brief, application BH2010/00083 (therefore BH2013/00139) does not involve car-free housing at all, so there is no policy provision made for these "borrowed infrastructure" proposals in the context of a CPZ.

The purpose of controlled parking zones
CPZs are offered as a solution to parking stress in densely populated areas. See our own residents' descriptions of difficulties they have experienced parking in the vicinity of their homes and as pedestrians.

The purpose of CPZs is certainly not to pave the way for deficient proposals dependant on borrowed infrastucture in already densely populated neighbourhoods. There is no logic to such an interpretation of CPZs since this would increase residents' difficulties. Any Council which attempted to distort the purpose of CPZs would quickly make them uninviting to all neighbourhoods which really need them e.g. for reasons such as safety on pavements & at junctions, access for refuse / emergency services, as well as residents parking.

This ground for refusal was upheld by the planning inspector who dismissed Carelet's appeal against refusal on 15th February 2011. To access appeal decision, go to BH2010/00083 , filter documents by changing "Show all" to "Appeal Decision", then click on green tab APPLY. Select icon in the "view" column.

Canvassing the Council to waive its policies

Carelet canvases to reverse benefits of CPZ

Go to BH2013/00139 and select "LETTER DATED 11/03/13" to see a letter to the Council from Carelet on some of the factors complicating a decision on their latest proposal. One of these is whether perspective residents should be entitled to parking permits if permission were given for 6 three-storey houses. This misses the point. It lifts pictures from the residents' CPZ campaign site to feign an understanding of parking stress in Round Hill.

How could a campaign which aims to reduce parking stress be used to support a proposal which would create a demand for 9 extra spaces in the vicinity of Princes Road where there will be less parking space anyway (with yellow line restrictions on all junctions connected to Princes Rd and Mayo Rd) after the CPZ is implemented?
The aim of the Area J parking scheme is NOT to allow developers to profit by increasing parking stress once again
"LETTER DATED 11/03/13" at BH2013/00139 turns logic on its head. Is there a resident in the whole of the proposed Area J who voted to reduce parking stress to allow developers to profit by reversing the benefits? Nobody wants to pay for residents' parking for the benefits to be removed straight away by a developer. It is worth noting that the permission granted for railway corridor housing to the rear of Springfield Road excludes prospective residents from entitlement to parking permits. However, the location of Carelet's application site makes it unsuitable for car-free housing. The Appeal Inspector who dismissed Carelet's appeal against refusal of 6 three-storey houses in early 2011 (on the basis of parking stress) made the right call. We urge the Council not to depart from refusal on the grounds that Carelet's proposal does not meet the travel and parking demands which it generates (i.e. 9 extra spaces).

Their application site cannot offer any parking at all; their proposal remains contrary to policy TR1 of Brighton & Hove's Local Plan. The site's location away from a street itself on very hilly terrain fails to satisy the second of the two main conditions set out in Local Plan Policy HO7 which define an application site's suitability for car-free housing.

Genuine car-free housing
To satisfy the conditions for genuine car-free housing under policy HO7 condition b. of The Local Plan the proposed development must be likely to remain car-free in the long-run.

See policy HO7 condition b. and the appeal inspector's reference to this policy below:

Carelet abandoned proposals for car-free housing on their application site after an appeal inspector made clear that residents in our neighbourhood have and use cars and it would not be possible to guarantee that a residential development in this hilly location could remain car-free in the long-run. See paragraph 16 of J Mansell Jagger's Appeal Decision [APP/Q1445/A/05/1178381]: Local residents are particularly concerned regarding traffic and pressure on parking in the area. I have to say that I share some of these concerns. It is not clear that the development could be guaranteed to remain ‘traffic free’ and that none of the residents would own or use cars. The existing residents rely heavily on on-street parking and any significant additional car usage would exacerbate the pressure for parking in the area, with the concomitant additional hazards to road safety stemming from possible indiscriminate parking and the circulation of vehicle drivers seeking a parking space. Prince's Road and several of the surrounding streets slope steeply and are not ideal terrain for cyclists or pedestrians. I note that the Highway Authority does not object, providing the details of the car club are pursued further, but the lack of a guaranteed traffic-free solution reinforces my view that the proposed development is unacceptable.

Parking stress reaches its peak
AFTER CPZ cut-off time
The most recent inpector to dismiss an appeal also acknowledged that parking stress in Round Hill was at its peak in the evenings. Many local residents voted against the CPZ since they thought that paying for permits would not guarantee a parking place near their homes within the Area J Scheme when they returned from work after the cut-off time of 8pm. See paragraph 19 of Isobel McCretton's Appeal Decision [APP/Q1445/A/10/2131115].

To access appeal decision, go to BH2010/00083 , filter documents by changing "Show all" to "Appeal Decision", then click on green tab APPLY. Select icon in the "view" column.

Nevertheless, the residents’ survey bears out the local concerns that demand for on-street parking is heaviest in the very late evening. More importantly, in my view it highlights the fact that, because of
the high demand, indiscriminate parking in places which could prejudice vehicle and pedestrian safety is already taking place: I observed several instances for myself within the study area during the daytime when going to and from my site visit.

This page was last updated by Ted on 07-Jan-2019
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