Home
About
Community
Planning
Gardens & wildlife
History
Links

Crescent Road 2019-Appeal

How to make a representation on the planning inspectorate's website

In order to make a representation, you first have to register at https://acp.planninginspectorate.gov.uk/myportal/default.aspx giving name & address, email address and creating a password. 

You need the last 7 digits only of the appeal reference, so. enter 3231412 into the planning inspectorate's search engine at https://acp.planninginspectorate.gov.uk/myportal/default.aspx to find the appeal at 28a Crescent Road Brighton BN2 3RP.

Once you have found the appeal APP/Q1445/W/19/3231412, clicking SAVE & CONTINUE takes you through some tick box pages where you can describe yourself as an "Interested Party / Person" and identify the kind of comment as  "Interested Party/Person Correspondence". SAVE & CONTINUE again and you arrive at a page with an input box where you can copy & paste a pre-written represention or write your comments directly.

Weaknesses in the recent appeal statement

Below is a sample representation based on what I feel are the main weaknesses in the developer's recent appeal statement which is more thorough than the technical note belonging to the refused (Application BH2019/00072) supporting the removal of conditions 7 and 12 imposed on the approved car-free application BH2018/00433. Credit should be given to local resident Dominic for his research using the developer's own data on the true level of parking stress in Crescent Road (110%) and the eight streets surveyed in Round Hill (105%) -  not the 95% claimed in both the refused Application BH2019/0072 and Section 6.7 of the developer's  appeal statement.

The true level of parking stress in Round Hill

Comments opposing BH2018/00433, which will have been forwarded to you, include well researched critiques of the parking beat data submitted with BH2018/00433 - e.g.  a single parking survey performed at a quiet time of the year. Inconsistencies in the supporting document. Inaccuracies in drawing conclusions on parking stress from the data.

Section 6.7 of the developer’s appeal statement, contends that a Parking Beat Survey undertaken revealed local parking stress to be 95%, with 16 available spaces. This is followed by a catalogue of upheld appeal decisions where parking stress is over the recommended level, yet less than 95%. There are now many car-free developments in Brighton and Hove which would not have been granted permission without car-free conditions. If all of these put in applications for the conditions to be dropped, would The Planning Inspectorate uphold appeals against refusal in all cases in the name of consistency? The whole point of parking surveys allows a case-by-case approach. The criteria defined in SPD14 (Brighton and Hove City Council’s Parking Standards) also allows each case to be weighed up to establish whether a car-free planning condition is both reasonable and necessary. 

In the case of the Crescent Road development (BH2018/0433), the Parking Beat Survey mentioned in Section 6.7 was a single beat survey performed on 12th December 2018 on a single evening only. An understanding of the current parking demand near the site would be more credible if further surveys were conducted during the May Brighton Festival or during Pride weekend. The Lambeth Guidelines 2016 recommend “snapshot survey between the hours of 0030-0530 should be undertaken on two separate weekday nights”. Moreover, it is not clear on which date the survey was undertaken. Page 5 of the technical report paragraph 3.1 states “A formal Parking Beat Survey, using Lambeth Methodology, was undertaken between 1.30am and 3.30am on Wednesday, 12 December 2018.” But the summary table on page 5 paragraph 3.3 gives the date of the survey as “Tuesday 4th December 2018”.

Re-analysis of the developer's data relating to a single Parking Beat Survey conducted at quiet time of the year

Reanalysis of the survey data related to the December Beat Survey (see http://www.roundhill.org.uk/CrescentBullets.pdf) shows current parking stress across the surveyed area as a whole to be 105%. When the parking capacity totals are analysed correctly, parking stress in Crescent Road is at 110%.

The developer’s appeal statement provides remarkably little reference to SPD14  Brighton and Hove City Council’s Parking Standards was called for  within CP9 of the Brighton & Hove City Plan Part One and explains the zonal approach (offering a Parking Standards Zones Map) and criteria for deciding whether a proposal, which might otherwise be refused on transport grounds, could be approved as a car-free development.

 

Round Hill's need for the appeal decision to support BHCC's sustainable transport policies

Brighton & Hove City Council's Parking Standards SPD14

Application BH2019/00072 falls within the (purple) Key Public Transport zone, important in  deciding whether a planning condition is reasonable, as do two other current applications within 200m, which would both add to a unacceptably high level of on-street parking stress which exists now within Round Hill if approved. BH2018/0881 in Princes Road (adjoining Crescent Road) requests similar removal of a car-free condition (which could generate a demand for several extra on-street parking spaces). B2018/03222 at 3 Upper Lewes Road and 1A/1B Wakefield Road (within Round Hill) generates a demand for 3 extra spaces, drawing interesting comment from BHCC’s Highways. This comment, explains exactly why car-free planning conditions for new developments within Round Hill are necessary. It also focuses on SPD14, the very policy which fleshes out CP9 of Brighton and Hove Local Plan and the one omitted by the the developer’s transport consultant which should be fundamental to local policy background:

Interesting comment from BHCC’s Highways 

“————SPD14 suggests the consideration of the implementation of car free housing for developments where the impact of overspill parking is considered unacceptable. These impacts may include localised increases in demand for on-street parking which can cause highway safety risks and can have a negative impact upon the amenity of existing residents in the vicinity of the site, as competition for on-street spaces in a particular area may increase.

Where there is potential for overspill parking, a parking survey is normally utilised to determine whether there is capacity on-street for the additional demand within close proximity to the development.

In lieu of a parking survey, the Highway Authority utilises permit uptake data to assess parking occupancy levels within CPZs. Given the potential variance in uptake across a CPZ, where permit uptake is over 80% over the previous 12 months, no additional overspill parking is permitted without a supporting parking survey.

Permit uptake within Zone J over the 12 months averages 92%. Therefore, it is recommended that the all of the residential development is made car free and that this is secured by condition. Should the applicant wish to undertake a parking survey demonstrating there is sufficient capacity, or a parking demand assessment demonstrating there is no increase in demand compared to the existing use then the Highway Authority may reconsider. ———“

All these requests coming at the same time for extra on-street parking space (two by the same transport consultant) add up to more than a minimal effect within a key public transport zone. The appeal decision will create a precedent. Once parking stress has reached such a high level, consistent decision making requires a marker which favours sustainable transport policies.

I support BHCC’s decision to refuse BH2019/00072. The conditions are both reasonable in the context of proximity to buses and a local railway station and necessary in terms of amenity (the potential for more overspill further impeding access and making life less pleasant for pedestrians). Adhering to the conditions is important in a neighbourhood with such high parking stress, which is not accurately measured either in the appeal statement or the technical note included in the refused application.

This page was last updated by Ted on 01-Aug-2019
(registered users can amend this page)