Synopsis
Planning Application Reference Number 08/00255/O
Norwich City College, Ipswich Road, Norwich. NR2 2LJ.
INTRODUCTION
By way of this synopsis we wish to raise the following concerns to the application to demolish and redevelop the entire City College campus. We are particularly anxious about how the proposals will affect neighbours and residents to Grove Walk, Ipswich Grove, parts of Cecil Road and parts of Ipswich Road. Also the surrounding areas including the remainder of Ipswich Road, Cecil Road, and Grove Walk will be affected.
Grove Road, Grove Avenue, Town Close Road, Lime Tree Road and Ipswich Grove amongst others will experience the adverse environmental impacts and traffic implications that the proposals will have during and after the construction programme probably affecting the whole of Town Close ward and also further afield.
GENERAL (The Format of the Outline Application)
The Outline Application to redevelop the College campus consists of six spirally bound A4 size books plus one larger format spirally bound book (a total of 257 pages) including two 'Appendices' on encrypted computer discs, 3 drawings and a completed Planning Application form, all put together by five individual professionals and consultants. Therefore in our synopsis, we will refer to the published “City College Norwich, Planning Application, Design and Access Statement”(as the D.&A.S.) and all other documentation by title submitted to the Planning Department as making up the ‘Outline Application’.
CRC (College Redevelopment Concerns)
CRC represents a group of residents with boundaries to the College formed to address neighbours and other residents’ fears and anxieties to the proposed redevelopment of the campus.
CRC BRIEF
CRC wish to state like our neighbours and other local residents that we are City College, education and student friendly and at the same time are supportive in principle, of the upgrading and modernisation of the campus facilities for the benefit of our young people. We acknowledge that the campus in some areas falls short of what is expected in 2008 and beyond for our local students. However, the enormity and scale of the proposals unveiled at the ‘Consultation Open Days’ held by the College caused great concern, anxiety and stress to residents.
CRC do not consider it within their brief to question either the national and regional planning strategies, social and economic issues, the “hoped for” student growth or the educational data supplied in support of the Outline Application. Therefore, we will only refer to Norwich City Council Local Plans and planning issues within this synopsis. However, the following points arise:-
(i) The opportunity for the young and people of all ages to enjoy an excellent education and further education in modern facilities is a goal that together we should all strive to attain for everyone. However, that should neither mean the relaxation of planning policies, regulations or British standards, however well intentioned, nor an excuse to support a worthwhile dream within the confines of a restricted island site that could easily turn into a nightmare for all concerned. The proposals therefore should be balanced between, not only the effect on the residents amenity and quality of life during the construction programme and thereafter, but also to consider the effect of the building works on the College staff, tutors and students. We are therefore very concerned that the enormity, proximity and duration of the six-year demolition and construction programme will cause disruption and have a detrimental effect on the quality of the education standards that the College will be able to provide during their redevelopment.
(ii) We are informed that existing student levels are below the capacity of the College by some 25% so why the need to expand and increase the floor area of the College by 70%? This increase does not include the proposed 5 atria spaces or the car park. (see page 3 1.2 para 3 D.& A.S.) Further if the floor area of Southwell Lodge, which is currently residential accommodation, is deducted from the existing floor area then the proposed overall increase of educational floor area is 86%. We therefore question some of the assumptions within the D.&A.S. that attempt to justify this scale of expansion.
(iii) We are concerned that the proposed increase in floor area does not equate with the anticipated growth of student numbers. There are no substantiated figures within the D.&A.S. to support the assumed growth or what the actual attainable increase in student numbers might be. As stated by others we quote:-
There has been a small increase of some 460 student enrolments from 2002/3 to 2007/8
However, during the same period, in the 19+ age bracket there has been a reduction of some 6,600 student enrolments meaning a decline overall of some 6,140.
(Please note: these figures exclude those not classed as FE. The excluded categories include “Higher education students, work based learning students, and people on Adult and Community Learning programmes, which are funded through the County Council” to quote an LSC analyst. Yet it is very unlikely that these numbers are significant enough to offset this decline e.g. Those in Work Based Learning totalled 280 in 2006/7 and the current total of fulltime HE students is 314 Degree, and 337 HND. At time of writing, these figures need to be confirmed with the College itself.)
One of the stated reasons for expansion “is the Government requirement that for all young people to the age of 18 to be in some form of education or training” (see page 7 para 12 D.&A.S.) Yet those categorised as NEET across Norfolk totalled only 1,432 in 2007 (“Norflok – Our 14 to 19 Plan 2007 to 2010”). So this in itself would not be sufficient to reverse this decline. Therefore a need for College expansion has not been properly identified.
(iv) With the recent predicted downturn in the economy affecting house building, are the figures of a projected increase in population of 50,000 in the Norwich area by 2025, (see page 9 2.2 para 2 D.&A.S.) used to justify some of the Colleges’ need for expansion, still relevant now or out of date?
(v) What plans does the College have if these projected student numbers are not reached? Or even exceeded?
(vi) Within the traffic impact analysis there is an aim of reducing the need for staff and students to visit the campus, by using technology within the home environment. This laudable goal of reducing traffic by allowing students to do more from the home or workplace is again inconsistent with the massive scale of the proposals.
(vii) We question whether there has there been a determined consideration given to alternative brown-field or green-field sites where a totally modern College could be designed and built starting from a blank canvas. We quote:-
“The educational case for the retention and development of City College is not in question. Consideration has been given to relocation of the College, but College Governors considered and rejected this option on the grounds of CCN’s strategic location, accessibility by public transport, non-availability of other suitable sites, cost and time.” (Page 54 4.2 para 3 D.&A.S.) Therefore we do not believe this alternative option for relocation of the campus has been given the thorough investigation it deserves.
What consideration has been given to off campus facilities, on smaller satellite sites, again either brown-field City centre sites or green-field sites, thus reducing the density of the proposals on the College campus? An email to CRC received on Thursday 1st May 2008, from the College Principal Mr Dick Palmer states:- “There are a number of new policy initiatives from the Government that will impact on our student numbers. The education leaving age is set to rise in 2013 from 16 to 18. There will be 17 new Diplomas introduced over the next 3 years, potentially meaning a substantial rise in the number of 14 –16 year olds at City College (where they are likely to come for at least one or two days a week, alongside their own school, to access the facilities necessary for the teaching of many aspects of the Diplomas).” (see CRC website http://collegeredevelopmentconcerns.blogspot.com/ for a full copy of this email).
Could these smaller sites in proximity of the College campus be an option? We suggest these proposals would meet the requirements of and be in accordance with Local Plan EMP18.
We are particularly concerned that the proposal conflicts with the following policies of Norwich City Council Local Plan namely EP1, EP2, EP5, EP7, EP9, EP13, EP14, EP17, EP19, EP20, EP22, HBE8, HBE12, HBE19, NE3, NE8, NE9, SR6, SR14, TRA3, TRA4, TRA5, TRA7, TRA8, TRA10, TRA11, TRA12, TRA13, TRA14, TRA15, TRA16, TRA18, EMP1, EMP2, EMP16, EMP18 and in particular with EMP19. (see appendix sheet 3).
Note:-
For the benefit of our neighbours who do not think metric and in order that they should have a better understanding of the dimensions referred to in metres (m), we have therefore, following the metric dimension, bracketed a straight imperial conversion figure in feet.
PART I (References to Local Plans applicable to this Application)
LOCAL PLANNING POLICY
Reference must be made to local planning policies quoted above and we have reproduced them as fully as possible, where applicable, in the appendix of this synopsis (see attachment sheet 3).
City of Norwich Replacement Local Plan 2004
The Local Plan has four broad objectives at its heart which are based on the principals of sustainable development, and these are:-
Effective protection of the environment
Prudent use of natural resources
Social progress which recognises the needs of everyone
Maintenance of high and stable levels of economic growth and employment
(see page 47 para 4 D.&A.S.).
PART II (CRC Synopsis)
1. ENVIRONMENTAL ASSESSMENT
General:-
Some planning applications need an environmental assessment on the effects a proposed development would have on the environment. This is then assessed by the Council. Such environmental statements should have a non-technical summary and it is this that should be referred to by those who may be affected by the proposals.
Please note that the Local Authority replying to an enquiry stated formally on 25th Jan 2008 that:- “no Environmental Impact Assessment would be required for the college redevelopment.” (see page 50 para 3.4 D.&A.S.). This is contrary to and in conflict with Local Plan EMP19.
The CRC Committee find it extraordinary that such a large proposed redevelopment does not require an Environmental Impact Assessment. The proposals involve at least 6 years of demolition and construction for 12 proposed new multi-storey buildings, 5 connecting atriums, a new energy centre, a new two storey car park, a new inner ring road with 4 new accesses and egresses to Ipswich Road, a considerably enlarged footprint with an anticipated increase in student and college growth of 25%, some buildings with a higher roof line than the existing, situated on contaminated “bad ground” within an island site with no further expansion available other than upwards, bounded on three sides by extensive established residential housing and on the fourth side by a Conservation Area. We suggest this is contrary to and in conflict with Local Plans EMP1, EMP2, EMP19 and EP5.
This statement by the Local Authority does not take into account the area of the campus, particularly to the rear of the Norwich Building, cordoned off from the rest of the campus because of soil contaminated with residual asbestos (see page 20 part para 5.2.2. Geo-environmental Report), nor does it equate with the belief of many local residents that an earlier history of the area as a refuse site of the City, means the campus and surroundings are allegedly Made Ground from rubbish landfill. Further no account has been taken of past or future pollution from petrol, oil and waste spillage entering a known major aquifer and thus into the local watercourses. This is contrary to and in conflict with Local Plan EP17.
We ask for clarification and the reasons why there is no requirement for an Environmental Impact Assessment from the Head of Planning Services.
2. THE PRINCIPLE OF THE DEVELOPMENT
(Points of concern to the principles relating to the Outline Application)
(i) The conflict the proposals will have within an island site on the surrounding neighbourhood bounded on three sides by established residential development and on the other by listed Georgian buildings including Town Close Pre-prep and Preparatory School all situated within a tree lined Conservation Area (see page 24 D.&A.S. for an aerial photograph of the College within it’s setting). This could be considered contrary to and in conflict with Local Plan HBE8.
(ii) The general concept and scale of the proposed footprint, an increase of floor area of up to 86%, the density, height and the dominance of the proposed new buildings, including atria, the construction of a new road and car park, represents over-development of this island site within an established setting. This is contrary to and in conflict with Local Plan HBE12.
(iii) The proposals will have an adverse environmental effect, traffic and visual impact on commuters, the local community and neighbourhood during construction and also thereafter following completion of the redevelopment. The proposal is at odds with the Local Plan policy which seeks to preserve and enhance the environment and amenity of residents. The proposals are generally contrary to and in conflict with Local Plans EP1, EP2, EP5, EP7, EP22, HBE12, EMP1, EMP2, EMP16, EMP19 and probably HBE8.
(iv) The loss of trees covered by Tree Preservation Orders (TPO’s) and other important healthy, young and mature trees. This is contrary to and in conflict with Local Plan NE3.
(v) The loss of “on site” open space during construction. This is especially relevant to the whole of the proposed construction programme during which the site will be divided between a college campus and a building site, leaving only the North end of the site for contractor’s accommodation etc, (see 4 (ii) of this synopsis.) There will therefore be no “on site” open space for the six-year construction programme. Furthermore in the interest of safety has the Fire Officer overseeing this application commented on the fact that due to these restrictions there will be no areas available for marshalling points on the campus in the event of a fire, for practice fire drills or any other emergency, certainly during the construction period and heavily restricted thereafter. This is contrary to and in conflict with Local Plans EP5 and EP7. We ask for clarification on this important issue from the Head of Planning Services.
(vi) The loss of the Norwich Building, an iconic local landmark (see page 17 D.& A.S.). With the exception of the “back corridor” and rear extension there should be wider consultation as to whether the main building should be listed and preserved. This is a heritage issue that deserves a wider examination and review than just the local community. We quote:-
“The local community will be involved in consultation when a planning application is received (in accordance with the provisions of the Council’s Statement of Community Involvement, q.v.) and can comment at that stage on the potential for heritage interpretation measures to be provided.” (Heritage Interpretation. Supplementary Planning Document Adopted version, December 2006 page 19 section 39).
The demolition of the Norwich Building is contrary to and in conflict with Local Plans EMP1, EMP2, EP18, EP19, EP20 and HBE8.
We can confirm that an application for consideration for Spot Listing the Norwich Building, the front curtilage and the entrances and railings has been submitted to English Heritage.
(For those wishing for further information concerning the history of the Norwich Building and its Architect see CRC website http://collegeredevelopmentconcerns.blogspot.com/ )
(vii) We are concerned at the choice of materials proposed for the facades of the new buildings especially the elevations fronting Ipswich Road which we understand includes a proposed cantilevered canopy. “A range of high quality external materials are envisaged comprising, glazed curtain walling, metal cladding timber, render, etc, all employed in a contemporary manner to produce a crisp, exiting, well detailed series of campus buildings.” (see page 63 5.11 para 2 D.&A.S.)
We believe these materials and the general concept to be inappropriate and show an un-imaginative approach opposite a Conservation Area.
(viii) The loss of the College residences (Southwell Lodge) where we understand £0.3m has recently been spent on refurbishment. “Residential accommodation currently exists on campus with the ability to rent out 108 rooms. However, only 30 rooms are currently occupied………” (see page 53 4.3 para 2 D.&A.S). This is contrary to and in conflict with Local Plan EMP19.
(ix) We are concerned that the redevelopment, during construction and after completion, will have a blighting effect on the neighbourhood as set out under The Town and Country Planning (Blight Provisions) Order 1990.
(x) We are concerned that the proposals will have a detrimental effect on the County Council Public Transport Policy. We ask for comments from the County Council concerning these issues.
(xi) The loss of light due to the height of the proposed development. We refer to the Rights of Light Act 1959.
(xii) The loss of night sky due to light pollution. We refer to the Clean Neighbourhoods and Environment Act 2005. “This applies to artificial light emitted from premises so as to be prejudicial to health or a nuisance.”
“Light pollution definition in the DEFRA guidance.” We quote:- “Any form of artificial light which shines outside the area it is intended to illuminate, including light that is directed above the horizontal into the night sky creating skyglow (which blocks out the night time stars) or which creates a danger by glare.”
(xiii) We refer to the “Infringement Of Right To Be Heard.” We quote:-
"It is fundamental both to European Community and U.K. law that parties have a right to be heard in matters that affect them" (ECHR Article 6; Human Rights Act 1998, Schedule 1). We submit that as interested parties in the re-development of the College campus, we have been denied the right to be heard enshrined by legislation.
3. EFFECT ON NEIGHBOURING PROPERTY
(i) The impact of the proposed buildings at the North end of the site include blocks B1 & B2 which will be the tallest buildings on the site at a maximum of 25 m (82ft) (see page 61 D.&A.S.). These buildings will therefore be 7.4 m (24 ft) higher than the ridgeline and 10.67m (35ft) higher than the parapet of the main Norwich building. These blocks are positioned 80m (262ft) from the rear of the properties on the south side of Ipswich Grove. Is it general planning policy or simply Norwich City Council planning policy to permit an increase in building height above an existing ridgeline? Especially if Phase 2 does not get built (see page 63 para 3 D.&A.S.). Further we are reliably informed that these blocks will contain a Hotel, Leisure Centre, Theatre and Swimming/Plunge Pool. This is not solely educational based but a change of use and should therefore be the subject of a full detailed planning application not an outline application. We ask for clarification of The Town and Country Planning Act 1990 as to the law on these points from the Head of Planning Services.
(ii) There will be a loss of privacy due to overlooking into the habitable rooms and gardens from the above blocks along most of the South side of Ipswich Grove. Due to the height of these blocks there will also be a loss of daylight and natural sunlight to these rooms and gardens. The “Town and Gown” facilities, which require further additional clarification, will especially in the evenings, add to the traffic pollution, noise nuisance, require extra car parking spaces and will also result in the loss of night sky to residents. Also at night, there will be loss of night sky due to light pollution from windows and the connecting atrium.
Note:- on completion of the proposed redevelopment between these blocks and the houses there will be a road carrying up to an estimated 5250 vehicles plus 250 motor-bikes, cyclists and pedestrians a day (see page 18 para and fig. 5.2 and also page 51 para 11.1.5 of the Transport Assessment which states that during the recent existing Travel Pattern Survey 4200 vehicle trips were logged in one day). Allowing for an anticipated increase of 25% in staff and student numbers it is not unrealistic to expect a similar increase in vehicular movements of up to 5250 a day. This is all generally contrary to and in conflict with Local Plans EMP1, EMP2, EP5, EP6, EP7, EP9, EP22, HBE12, SR6, TRA3, TRA4, TRA5, TRA14 and TRA18.
(iii) The impact of the proposed new building block C (no maximum height is given). We therefore assume that this block will probably be at least as high as the ridgeline of the existing main Norwich building.
(iv) There will be a loss of privacy due to overlooking into the habitable rooms and gardens from the above block along most of the East end of the South side of Ipswich Grove. Due to the height of this block there will also be a loss of daylight, natural sunlight and sunsets to these rooms and gardens. The same will apply to some properties to the Northern end of the West side of Grove Walk. At night there will also be loss of night sky due to light pollution from the windows.
Note:- on completion of the proposed redevelopment between block C and the rear of these houses there will be a road carrying up to an estimated 5250 vehicles plus 250 motor-bikes, cyclists and pedestrians a day. (see 3 (ii) above). This is all generally contrary to and in conflict with Local Plans EMP1, EMP2, EP5, EP6, EP7, EP9, EP22, HBE12, SR6, TRA3, TRA4, TRA5, TRA14 and TRA18.
(v) The impact of the proposed new 4 storey vocational block F which will be a maximum of 18 m (59ft) tall, 0.4m (1.3ft) higher than the existing ridgeline to the Norwich building. Block F will be situated immediately to the rear of properties to the North side of Cecil Road and set back some 34m (113 ft) from the rear of those houses (see page 61 5.5 para 7 D.&A.S.). This block we are reliably informed will be vocational i.e. workshops (bricklaying, engineering, metalwork etc.) The noise that will ensue from plant, machinery and engineering from these operations is contrary to and in conflict with Local Plans EP7, EP22 and EMP2.
We also wish to raise concerns that a total of 7№ Noise Abatement Notices under the Environmental Protection Act 1990 section 79(i)(g) Noise Nuisance have been served on the College since 2000 (one such notice dated 24th July 2000 relates to the existing workshops situated on the eastern boundary of the site). All these notices are currently in force.
With regard to these workshops (the Norfolk Building built 1997), conditions attached to the planning approval were neither enforced by the Planning Department, nor complied with by the College management their staff or technicians, hence the need for the issuing of the notice. We ask for clarification of the Town and County Planning Act 1990 from Head of Planning Services for an explanation regarding this lack of responsibility from his department in enforcing these conditions.
We understand that the Notices will expire with the redevelopment of the campus. If similar conditions are attached to any subsequent approvals can the Head of Planning Services confirm that they will be rigidly enforced by his department?
For the neighbours effected, these nuisances were an unacceptable intrusion, into the amenity and quality of their lives. The residents fear that the noise pollution and nuisances will be repeated, during construction and after the new workshops, car park and other facilities become operational.
We understand that engineering workshops (i.e. car repairs, metalworking etc) have to be the subject of a detailed planning application. Further this new block F replaces a residential building (Southwell Lodge) which we understand to be a change of use. We again ask for clarification of The Town and Country Planning Act 1990 as to the law on these points from the Head of Planning Services.
(vi) There will be a loss of privacy due to overlooking into the habitable rooms and gardens from the above block F along most of the North side of Cecil Road. Due to the height of this building there will also be a loss of daylight to these rooms and gardens. At night there will also be loss of night sky due to light pollution from windows and the connecting atrium. For an impression of the impact and height of block F on these houses see attached sheet 2.
Note:- on completion of the proposed redevelopment between block F and the houses there will be a road carrying up to an estimated 5250 vehicles plus 250 motor-bikes, cyclists and pedestrians a day. (see 3 (ii) of this synopsis). Also note block F is positioned nearer to neighbouring houses than any of the other proposed blocks (with the exception of the car park), however, it is also the lowest. Blocks B1 & B2 for example will be 7m (23ft) higher (i.e. just under half as high again). This is all contrary to and in conflict with Local Plans EMP2, EP6, EP9, EP22, TRA3, TRA4, TRA5, TRA14 and TRA18.
(vii) The impact of the proposed multi-storey tutorial blocks A1, A2, B3 and G (no designation has been given to the blocks to the rear of the above (see page 60 D.&A.S.)).
However, we quote:- “… from the rear of houses on Grove Walk the majority of the buildings will be some 80m (262ft) away …” (see page 61 5.5 part para 2 D.&A.S). On completion of the proposals as they stand, between the rear of these tutorial blocks, which are assumed to be 4 storeys high and the rear of the properties on Grove Walk, there will be an inner ring road carrying up to an estimated 5,250 vehicles, plus 250 motor-bikes, cyclists and pedestrians daily. This does not include delivery vans, lorries, H.G.V’s and probably busses and coaches. There will also be a car park which will be in continuous operation for more than 14 hours daily, holding an anticipated 750 cars, 4 car lengths wide with 2 central access lanes. The distance from the East side of the car park, to the rear of the properties, will therefore be a minimum of only some 30m (98ft) of which a minimum of 11m (36ft) will be screening. The remaining distance approximately 19m (62ft) will be residents rear gardens (see illustration page 79 D.&A.S.) Therefore we suggest, contrary to the statement in the D.&A.S., there will be a significant detrimental impact on the amenity of local residents. This is Contrary to and in conflict with Local Plans EMP2, EP6, EP9, EP22, TRA3, TRA4, TRA5, TRA14 and TRA18.
We ask the Head of Planning Services for his comments.
(viii) There will be a loss of privacy due to overlooking into the habitable rooms and gardens from the above blocks along most of the West side of Grove Walk. Due to the height of these blocks there will also be a loss of daylight, natural sunlight and sunsets to these rooms and gardens. At night there will also be loss of night sky due to light pollution from windows and the connecting atriums. These houses will also be affected by the new car park and new inner ring road (see 3 (ii), (ix), (x), (xii) and 4 (xii) of this synopsis). This is contrary to and in conflict with Local Plans EMP2, EP6, EP9 and EP22.
(ix) The impact of the proposed new two storey car park the top deck of which will overlook the rear of most houses on the West side of Grove Walk and with the new inner ring road there will be traffic noise, pedestrian noise, artificial light, exhaust and headlight pollution from 7:30am until past 9:30pm continually ongoing from morning through to evening as vehicles arrive and leave the campus (see 3(ii) of this synopsis for relevant references to the Transport Assessment).
(x) There will be a loss of privacy due to overlooking into the habitable rooms and gardens from the car park along most of the West side of Grove Walk. Due to the height of the proposed car park, tree screening and tutorial blocks there will be a loss of daylight, natural sunlight and sunsets to these rooms and gardens. Initially, however, the screening will be ineffective. Therefore at night and in early winter mornings there will also be light pollution from the car park lighting and car headlights. Later as the screening matures, due to the proximity of the eastern edge of the car park to the rear of neighbours boundaries, a minimum of 11m (36ft), the tree screening will become a nuisance especially to residents who are gardeners. For the full impact and the effect on the amenity and quality of life of the residents see illustration on page 79 D.&A.S. This is all contrary to and in conflict with Local Plans EMP2, EP5, EP6, EP9, EP22, NE8, NE9, TRA3, TRA4, TRA5, TRA14 and TRA18.
(xi) The impact of the proposed energy centre has not taken into consideration the neighbouring properties by way of probable continual running, emitting constant noise and probable exhaust pollution. All at the bottom of resident’s gardens in the South East corner of the site thus affecting houses adjacent to the Grove Walk and Cecil Road junction. This we are reliably informed will also be the area that waste from the workshops will be deposited into skips which in turn will also be delivered and collected by lorry. This is contrary to and in conflict with Local Plans EP5, EP7 and EP22.
(xii) The impact of the proposed new inner ring road to the rear of gardens to Ipswich Grove, most of Grove Walk and Cecil Road (between the junctions of Ipswich Road and Grove Walk). There will be pedestrian noise, traffic noise, exhaust pollution and at certain times headlight pollution and artificial light pollution, from 7:30am until past 9:30pm continually ongoing from morning through to evening as vehicles arrive and leave the campus. (see 3(ii) of this synopsis for relevant references to the Transport Assessment). This is contrary to and in conflict with Local Plans EMP1, EMP2, EMP16 and EMP19.
(xiii) The demolition of modern buildings and facilities some more than fit for purpose and the extravagance of public funds that this involves. The College has spent £1.8m since 2003 on updating the campus for the disabled (see page 9 2.2 para 11 D.&A.S) The impact of the time scale of the demolition and debris removal and the noise, pollution and smells that will ensue during these operations. This is contrary to and in conflict with Local Plans EP5, EP7 and EP20.
(xiv) The impact of the above, an estimated period of six years of demolition and construction involving heavy plant with the ongoing delivery of building components and materials, unloading and returning empty lorries and the noise, pollution and smells that will ensue during these operations. This is contrary to and in conflict with Local Plans EP5, EP7 and EP20.
We reiterate that we are concerned that the redevelopment, during construction will have a blighting effect on the neighbourhood as set out under The Town and Country Planning (Blight Provisions) Order 1990.
(xv) With the exception of Ipswich Grove we are already the subject of vehicular “rat runs” the impact of the proposals will increase this nuisance including noise and exhaust pollution increasingly during normal as well as unsociable hours. This is contrary to and in conflict with Local Plan EP22.
(xvi) Environmental damage caused by vehicles during and after building works. This is contrary to and in conflict with Local Plan EP17.
(xvii) The impact of construction particularly of phase 1 will exacerbate safety in the whole area. Due to health and safety and other contractual legislation the construction site will be "hard hat." Contractor's accommodation, delivery, storage of components, materials and contractors plant will expand the "hard hat" contractual building site during construction, impinging on most if not all of the campus. It is our expectation that during the whole of the building works (ie; six years) the North end of the site will be used by the Main Contractor for the above purpose. As a result during construction “on site” parking will be severely restricted probably only to an area at the front of the main Norwich building for college staff, students, visitors and as a pick-up/set-down for disabled users and others. This is contrary to and in conflict with Local Plans EP5, EP7 and EP9.
Further during the construction period because of security reasons, there will also be loss of night sky due to light pollution at the North end of the site, affecting the residents of Ipswich Grove.
An email to CRC received on Thursday 1st May 2008 from the College Principal Mr Dick Palmer confirms both 2(iv) of this synopsis and 3(xvii) above and that no alternative car parking arrangements have been agreed at this time. Mr Palmer also confirms that the new car park is currently planned for completion at the end of Phase 1 (2012) (see CRC website http://collegeredevelopmentconcerns.blogspot.com/ for a full copy of this email).
(xviii) The loss of security to those properties with rear boundaries to the College by exposing them to the risk of burglary via the proposed open College campus. (see page 69 para 5.12 Ipswich Road Frontage D.&A.S.) Similar incidents have been reported to houses on Cecil Road where access has been gained to these properties via the Hewett School playing fields. This is contrary to Local Plan HBE19.
We believe that not only all of the foregoing are contrary to and in conflict with Local Plans EP22 and EMP2 but will also affect the amenity and quality of life of residents and also permanently change the character of the surrounding residential and Conservation areas.
4. EFFECT ON SURROUNDING AREA
(i) The impact that the proposed new re-positioned accesses/egresses to/from the new inner ring road will have on safety on much of Ipswich Road. The proposed position of the new access/egress from the South of the College site, between the junctions of Cecil Road and Town Close Road with Ipswich Road, are a dangerous hazard and have not been seriously considered, as the proposed position is in close proximity to the existing access/egress to Town Close Preparatory School positioned to the North West and diagonally opposite on Ipswich Road from the College’s proposed new access/egress. Further the new repositioned access/egress at the Northern end of the site to Ipswich Road are equally a hazard, as the proposed position is also almost directly opposite the access/egress to Town Close Pre-Prep School. The proposals will further prejudice highway safety on a busy main arterial route and could therefore endanger life to pedestrians as well as motorists and their passengers or other road users.
(ii) Commuters and residents of the surrounding area are already subject to heavy vehicular traffic on Ipswich Road, in particular during the morning rush hour and parental school runs to Town Close Pre-prep School and Town Close Preparatory School, also the same applies to the late afternoon rush hour. The proposed development will make this arterial route to and from the city centre even more dangerous than it already is for small children, students and adults alike. We reiterate these are hazards that could cause accidents of a serious nature. As stated by others the repositioning of the Southern most pedestrian crossing between Town Close Road and Cecil Road to the North enforced by the proposed new position of the Southerly access/egress of the proposed ring road will bring into conflict, children and young people walking to and from school, with vehicular traffic involving them in to two extra road crossings in an already congested and hazardous situation and area. Also the impact of the proposals will increase the nuisance including noise and exhaust pollution during normal and unsociable hours and the road will become even more hazardous during the demolition and building construction phases, which we understand will be a period of 6 years. We are also concerned as to whether these proposed new junctions can be designed to Local County Council Highway Authority standards particularly as to vision splays etc. We again ask for clarification of these standards both from the Highway Authority and the Head of Planning Services.
(iii) It should also be noted that within very short distances of the College campus and in addition to Town Close Preparatory School and Town Close Pre-prep School there are 3 other schools:-
· The Hewett School
· City of Norwich School
· Norwich High School for Girls
There are therefore many young people walking and cycling to and from school, as well as parents and students driving in the area.
We reiterate that we are concerned that the proposals will have a detrimental effect on the County Council Public Transport Policy. We ask for comments from the County Council concerning these issues.
We reiterate that all of the foregoing will affect the amenity and quality of life of residents and also will permanently change the character of the surrounding residential and Conservation areas.
5. THE OUTLINE APPLICATION (Design and Access Statement)
(i) CONTEXT:-
The impression given by this section is ambiguous and directed in a way which could be considered unfair, to the point of being misleading. In many instances the information supplied within the D.&A.S is at variance and contradictory, not only within it’s own covers but conflicting with information in the other accompanying Assessments.
Any number of City College buildings are visible from most neighbours houses regardless of whether trees are in leaf or not. Increases in the height of buildings would, therefore, have a considerable detrimental impact to the whole area and we reiterate this would change its character for the worse. We again repeat that we are concerned that the redevelopment, during construction and on completion, will have a blighting effect on the neighbourhood as set out under The Town and Country Planning (Blight Provisions) Order 1990. We also understand the Local Authority have a statutory duty to preserve and enhance the environment and amenity for all residents.
The photographs of the pavements to Ipswich Road outside the City College are also unrepresentative. These pavements are narrow and become extremely crowded with students to the extent that during most of the day when the College is open one is virtually forced to walk in the road rather than the pavement. We quote:- “The multi-modal surveys carried out at the College in December 2007 recorded approximately 12,600 person……… trips in one day.”(see page 19 para 5.3 Transport Assessment). We believe these figures speak for themselves and the photographs portray a misleading picture of the true context, both outside and within, of what is considered to be an excellent learning facility.
“The main Norwich building is now some 55 years old and in need of substantial and expensive repair. The pantile roof………”(see page 32 part para 4 D.&A.S.). We would suggest that these are not pantiles but Spanish tiles and therefore part of the architectural merit of the building. Such errors, omissions in detail and the ambiguous photographs and comments relating to the College, the campus and surrounding area suggest that the D.&A.S. is incomplete in context, factually inaccurate and therefore flawed.
(ii) CONSULTATION:-
We consider the ‘Consultation’ process to have been the cause of great misunderstanding, to be erroneous and therefore also flawed.
We attended the open day’s ‘Consultation’ period, held at short notice from Thursday 10th January, till midday Saturday morning the 12th January 2008. CRC and residents consider that this was insufficient time for working people, families with children and the elderly, in such a short space of time, to arrange to attend these ‘Consultations’. It has come to our attention that many residents were unaware of the open days and until recently some residents were also totally unaware of the proposed redevelopment. In the true sense of the word these were not ‘Consultations’ at all, as a community we were just informed of the Colleges’ proposed intentions. The information from College staff was diverse and contradictory and the block model was the cause of great anxiety and concern. To be fair to the College, CRC do believe that the presentation of a model was an excellent idea and something that the general public could more understand than architectural floor plans, sections and elevations. The model showed the maximum massing and density in three dimensions, which enabled residents to understand the scale of the redevelopment and the impact it would have on their lives.
College staff did not inform those attending that the completion of a questionnaire would be used in an analysis within the D.&A.S. nor explain that residents were being ‘counted in’ and ‘counted out’. However, some people report that they saw no evidence of a ‘count’ being completed. Therefore, from information and comments from residents we consider that the graph and pie chart (see pages 50&51 D.&A.S.) are inaccurate and open to question.
“A model of the site was available throughout the consultation event, which showed the access and parking arrangements. The public consultation responses received did not reveal any significant issues related to access to the site.” (see page 51 para 3.7 D.&A.S.). We would suggest that most residents concerns were directed at the density of the proposals and the siting of the car park and within the time scale of the ‘Consultations’ were neither made aware of the inner ring road or the fact that there would be re-arrangement and alterations to the accesses to Ipswich Road, nor to the major highway re-arrangements and alterations to Ipswich Road itself.
We again refer to the “Infringement Of Right To Be Heard.” We quote:-
"It is fundamental both to European Community and U.K. law that parties have a right to be heard in matters that affect them" (ECHR Article 6; Human Rights Act 1998, Schedule 1). We submit that as interested parties in the re-development of the College campus, we have been denied the right to be heard enshrined by legislation.
We reiterate that the analysis is flawed, unrepresentative of residents’ views and should be judged on the number of objections received by the Planning Department from residents.
(iii) GEO-ENVIRONMENTAL REPORT:-
The assessment is a desk study report based on previously published reviews and assumptions that included a site walk over undertaken on 11th January 2008. We quote:-
“A qualitative geo-environmental risk assessment has been carried out using the plausible linkages assessment. Possible sources of contamination have been identified from recent activities on the site and this is considered plausible pollutant pathways may exist. Likely sources of contamination are however considered to be limited to potential infiltration of oil or fuels from car parking or vehicle maintenance, infiltration from waste storage areas and possible asbestos in the shallow soils from previous demolition phases.”
“An assessment of geotechnical risks has identified the following hazards could be present at site: lateral and vertical changes in ground conditions; high groundwater (perched groundwater); Made Ground; presence of existing sub-structures.”
“The ground conditions at the site are expected to be suitable for the construction of shallow foundations for low-rise, lightly loaded structures. More heavily loaded structures may require the use of piled foundations. CFA piling may be a suitable construction option, particularly if any evidence of shallow soil contamination is found during the site investigation.”
“The use of ground water in building cooling has been considered briefly. Abstraction from the Chalk may provide suitable yields.” (see page 2 paras 6,8,9&10 Transport Assessment)
“Surface water (on-site drains and adjacent issues)
No surface water features have been identified on site and in the immediate vicinity of the site.”
(see page 23 para 5.5.7 Transport Assessment.) For contrary information see Flood Risk Assessment (viii) para 3 of this synopsis.
The Assessment acknowledges points made elsewhere within this synopsis such as Made Ground, the presence of a major aquifer and possible sources of contamination. We therefore submit that, as acknowledged within the Assessment, a more thorough and detailed study should be completed prior to the granting of the Outline Application.
(iv) SUSTAINABLITY:-
As previously stated the Sustainability Statement summarises and includes among other issues, the key relevant national and regional planning policies, which we have previously stated it is not within our brief to comment on. However, where appropriate we have commented on issues relevant to our brief elsewhere in this synopsis.
(v) TRANSPORT ASSESSMENT:-
As stated by others we wish to express deep concern at the proposals for “two new priority controlled junctions.” Proposals likely to increase traffic would be contrary to current environmental concerns. We are also concerned by any proposals that prejudice road safety on Ipswich Road for those travelling in the area. Ipswich Road is an arterial route, is busy, hazardous and subject to speeding with many road and private drive junctions and also a bus and car lay-bys along its length.
There are hazardous stop-start implications on road safety that will be caused by the traffic streams along Ipswich Road by the 2 new priority controlled junctions. We draw particular attention to the Southern most junction proposed between Town Close Road and Cecil Road. There is only a distance of approximately 80m (262ft) between these two existing roads. Vehicles turning right off Ipswich Road into Town Close Road, the campus or Cecil Road in times of heavy traffic or rush hours, will not only be in a hazardous position and causing congestion, but be a hazard for others travelling with or against these turning vehicles. At the same time traffic from Town Close Road and Cecil Road turning right onto Ipswich Road will be held up causing further congestion and conflicting hazardous situations.
We again ask for clarification of these standards and the affect on County Council Transport Policy both from the Highway Authority and the Head of Planning Services.
(vi) DEDICATED VEHICLE ROUTE:-
We are concerned by the proposed inner ring road. Again as stated by others this would introduce a new road into the area. Ipswich Grove is a cul-de-sac although this road is incorrectly shown as a through road on the Traffic Plan (see page 85 D.&A.S.) and therefore not subject to ‘rat runs’ but for those living on Cecil Road and Grove Walk it will be akin to living on a roundabout and for those living on Ipswich Road it will be a hazard and a nuisance and affect all Town Close ward residents’ quality of life.
We are concerned that the inner ring road during construction and after completion will have a blighting effect on the neighbourhood as set out under The Town and Country Planning (Blight Provisions) Order 1990.
All be it that the scope of the geographical area reviewed by the Transport Assessment is within standard guidelines, the nature and purpose of the site and the proposed accesses cause us to submit that the Transport Assessment was unduly restricted in its geographical scope and did not look at other local traffic impacts within the area.
We reiterate our concerns that the proposals will have a detrimental effect on the County Council Public Transport Policy. We ask for comments from the County Council concerning these issues.
As such we submit that the present proposals are contrary to and in conflict with Local Plans EP5, EP6, EP9, EP14 and TRA3, TRA4, TRA5, TRA7, TRA10- TRA16 (inclusive) and TRA18. In particular this planning application does little to encourage the “model shift from car to walking, cycling and public transport” as required by policy TRA3.
With reference to paragraph 5.14 page 84 of the D.&A.S. We quote:- “one of the principles of the campus redevelopment is to minimise the interaction between pedestrians and motor vehicles. Therefore, the access arrangements have been developed with the aim of ensuring that pedestrian access is segregated.” This is utter nonsense, there will not just be interaction, there will be conflict between all pedestrians and all motor vehicles arriving and leaving the campus, (no design safety improvement on the existing situation). At the same time the College does not deny that this the inner ring road (single or dual carriageway?) will carry other vehicular traffic including delivery lorries, buses and coaches and during building works, construction traffic. Further an increase in Heavy Goods Vehicles is anticipated. We quote:- “As the College expands, the number of HGV trips is expected to grow proportionally to the development floor space.” (see page 36 8.2.2 para 4. Transport Assessment). Due to the inadequacy of the proposed design, every pedestrian approaching or leaving from either end of the College campus will have no alternative but at some point to cross this inner ring road. However, siting the car park to the frontage of Ipswich Road and incorporating bus lay-bys will allow pedestrian access at each far end of the campus to follow a route running behind the accesses/egresses resulting in no such conflict. No pedestrian will therefore have to cross this inner ring road, as they will be able to walk circumnavigating around behind it. The proposals as they stand are contrary to and in conflict with Local Plans EP6, TRA14 and TRA18.
Additionally siting the car park centrally and to the front of the campus could reduce the number of accesses and/or egresses from the 4№ as proposed to 2№ thus reducing the hazards and conflicts with other existing junctions on to Ipswich Road (explained in 4 (i), (ii), (iii) and 5 (v) of this synopsis).
(vii) CAR PARKING:-
We are concerned by the position of the proposed car park. We not only oppose the position of the proposed decked car park but the principal of a car park at all. We quote:- “The proposed campus redevelopment will include parking for up to 740 cars. The majority of this parking will be provided in a new muti-storey car park on the Eastern edge of the site………also……… The level of parking is approximately a third of the maximum provision calculated using the standards for Further and Higher Education land uses set out in PPG13.” (see page 31 3.4 part paras 1&2. Transport Assessment). We suggest this limitation of parking spaces is not a design or Green issue but due to the restrictive nature of the campus. However, many neighbours are concerned that the design of the car park will allow for future expansion upwards. The proposals as they stand are an infringement of PPG13 We quote:- “The parking standards set out in PPG13 for Further and Higher Education land uses allow for a maximum or 1 parking space per 2 members of staff and 1 space per 15 students which would permit the provision of up to 2050 parking spaces based on the projected staff and student numbers.” (see page 31, footnote 5 Transport Assessment).
We understand that positioning the car park to the rear of the site for aesthetic reasons has resulted in the necessity of the proposed inner ring road for access to and from the car park. Due to the restrictions previously referred to of car parking during construction of phase 1 (a period of some 3 years) perhaps the question should be asked as to the necessity of having a car park at all. Should phase 2 also be completed then due to the access to the site required by the Main Contractor and others during this second phase our expectations are that even then the car park will not be fully functional. This could then extend the non-operational period up to six years. Perhaps the example, set by Canterbury College which is car-free and therefore Green, should be followed by Norwich City College in implementing a totally Green Travel Plan. However the College caters for students from rural areas, poorly served by public transport, therefore we suggest that the proposed 37 disabled places should be retained but augmented by an area for vehicular pick-up/set-down for others. The proposals as they stand are contrary to and in conflict with Local Plans EP5, EP9, EP14, EP17, TRA3, TRA5, TRA10, TRA11, TRA13 and TRA16.
(viii) FLOOD RISK ASSESSMENT:-
We are concerned by any proposals which might result in additional flow of any kind into the ground in this area. The college campus is on relatively high ground but it is known that there is a very high water table and that a major aquifer runs through the area. The nature of the ground is such that relatively light rainfall takes an abnormally long time to drain away and in other areas drains away rapidly.
Researching the 1887 OS map of the area two small streams (“cockeys”) run from the Grove Walk end of the site to Ipswich Road. It is our understanding that these cockeys are now culverted and run underneath the college campus to Ipswich Road. It should be noted that a path running East/West from the West side of Ipswich Road to the rear of houses to Town Close Road between Town Close Preparatory School is normally muddy and damp. With reference to the Geo-environmental Report a fold out diagram to the last page of the report shows perched ground water over a clay layer with contamination from oil and fuel spills from the car park and road running freely into the ground with no road gulleys, drainage or interceptors. This also includes leakage from waste storage. It is our concern that these pollutants (as currently) will be carried by the ground water to the West side of Ipswich Road (underneath Town Close School) before finding their way into the local watercourses (see sheet 3 attached). This is contrary to and in conflict with Local Plan EP14.
We also understand that very large diameter storm water drains to Grove Walk run under the college campus towards Ipswich Road. We can find no reference to these drain runs in the Outline Application nor to the consequences to the houses to the West side of Grove Walk during periods of heavy rainfall should these drains be damaged or breached during the construction period. These houses generally all have ground floor levels lower than the gutter gulley levels of Grove Walk itself and are liable to run-off into their front gardens during periods of heavy rain. Should damage to these storm water drains coincide with heavy rainfall then it can be anticipated that some if not all of the houses to the West side of Grove Walk will be flooded. This is contrary to and in conflict with Local Plan EP13.
(ix) SUBSIDENCE:-
No reference is made in the Outline Application to problems of subsidence to residents’ properties within the surrounding area.
It is known that the campus and surrounding houses are situated on ‘bad ground’ and as a consequence, many residents’ houses have and suffer from subsidence resulting in structural movement to their houses. The remedial works have included both underpinning and piling.
During construction of a small access drive (half the width of the College’s proposed inner ring road) and probably no more than 80 m (262ft) long, from Cecil Road to Cromwell House Care Home, structural movement caused by subsidence from these minor works, to two adjacent houses on Cecil Road, led to the necessity of these houses being underpinned.
Further one house on Grove Walk has had to have remedial works carried out as a result of damage caused by the recent earthquake.
Within the last few weeks a void, the result of subsidence, has opened in Cecil Road beneath the surface causing a minor collapse of the road.
We believe that due to the falls across the campus from East to West that a great amount of ground works and excavations will be required to construct both the proposed inner ring road and car park. Therefore to retain the ground at the East side of the site prior to the construction of the car park there will probably be the need for sheet piling. Should this be required the resulting vibration on any adjacent houses will be catastrophic in terms of their structural stability. In the event that sheet piling is not considered necessary then as we have ‘bad ground’. We quote:- “A review of published geological information has identified that the site is expected to be underlain by Glacial Sands and Gravels, Norwich Crag and White Chalk. A surface layer of topsoil and Made Ground is also likely to be present. The Norwich Crag and Chalk are classified as a Major Aquifer and the overlaying granular deposits are likely to be in hydraulic continuity. The possible presence of clay layers in the granular deposits may allow the formation of shallower perched groundwater tables.” (see page 2 para 5 Geo-environmental Report) Therefore if this ground is not retained we could have resulting ‘slip’ of the top layer resulting again in the probability of catastrophic movement of residents’ houses.
The size, scale and height of the proposed redevelopment is such that deep piling in order to find ‘good ground’ will be necessary. Further, no account has been taken of vibrations, noise or pollution from construction techniques and heavy plant moving within the site on residents’ amenity and quality of life or the effect on their properties during building works. In view of the identified subsidence to neighbouring properties and that neither this risk nor any test boreholes have been taken we therefore believe the Geo-environmental report to be flawed.
5 storey buildings some up to 25 metres high, however lightweight in construction but designed to accommodate commercial loadings, will require substantial or piled footings and foundations on ground of doubtful bearing capacity. The fact that some people who should know better are advocating an increase of up to presumably 7 or 8 storeys shows their local knowledge and research to be limited. Buildings of this height we would suggest would no longer be lightweight structures.
The requirements set out in Local Plan EP2 address the above concerns.
(X) PHASE 1 HABITAT SURVEY AND PROTECTED SPECIES RISK ASSESSMENT:-
This is acknowledged as a desk top study which included a Phase 1 walk over site survey by two experienced ecologists that took approximately 4 hours, carried out on the 16th November, 2007.
Therefore we quote:-
“Breeding birds”
“All nesting birds are protected under section 1 of the Wildlife and Countryside Act 1981, whilst certain species are listed on schedule 1 and are protected by special penalties at all times. It is therefore recommended that if possible the works to be timed to avoid the nesting season (March to August inclusive). If this is not possible then any clearance works should be preceded by survey by a suitably qualified ecologist for the presence of nesting birds. If nesting birds are found, then it will be necessary to protect the nest (and a suitable buffer area around it) from disturbance until such time as the young have fledged and left the nest. It should be noted that some species may continue to nest outside of the core nesting period, so vigilance is necessary at any time of year.” (see page 18 part para 6.1. Phase 1 Habitat Survey and Protected Species Risk Assessment)
The only comments that we would add are that in summer evenings neighbours of the College who use their rear gardens witness flights of small bats (perhaps the Common Pipistrelle (Pipistrellus pipistrellus)) which we would suggest roost within the College boundaries. Therefore we quote:-
“Further Phase 2 surveys for protected species are recommended below. It is recommended that, where possible, these be completed prior to the submission of detailed planning applications, and certainly before site clearance and construction works commence on the site. If any of the following protected species are found on the site, specific mitigation measures may be required to comply with nature conservation legislation.”
“Bats”
“If any future development plans impact on buildings or trees that are considered to offer bat roosting potential, then an appropriate bat survey should be carried out. Daytime inspections to look for roosting bats and/or field signs of bats (droppings, urine staining, scratching etc.) in buildings and trees should be combined with bat emergence or re-entry surveys following best practice guidelines provided by the Bat Conservation Trust (BCT 2007).”
“Any loss or disturbance of a bat roost would require adequate mitigation and would need to be undertaken under a European Protected Species (EPS) License in order to derogate from The Conservation (Natural Habitats, & c.) Regulations 1994. Therefore, any bat surveys should be completed well in advance of development works to allow sufficient time to apply for a bat licence from Natural England.”
“Plants”
“A further botanical survey visit to be undertaken during late May or June should be considered to provide a fuller description and assessment of the woodland and other habitats present.”
(see page 19 para 6.2. Phase 1 Habitat Survey and Protected Species Risk Assessment)
Local Plans NE8 and NE9 are applicable.
(xi) ARBORICULTURAL ASSESSMENT:-
We are greatly concerned at the loss of trees covered by “TPO’s” due to proposed felling and the effect that excavations for the new inner ring road and other building work will have on other established trees in particular a 22m high Wellingtonia and a 15m Dawn Redwood. (According to the British Tree Register) where both trees are recorded, the 15m Dawn Redwood is the second tallest of its species in Norfolk. These trees are potentially at risk of harm from the proposals (detailed below.) Moreover there are omissions and errors in the tree survey involving a Cedar and a Cypress to the rear of number 82 Grove Walk. These trees are also potentially at risk of harm from the proposed car park, energy centre and skip hardstanding/reversing area respectively. It would also appear that a mature Oak tree and a mature Ash tree to the rear of no 60 Grove Walk are incorrectly positioned on the drawings. A Yew tree? situated in the centre of the site is apparently omitted altogether. We are therefore concerned that the Tree Survey has some important errors and omissions. Some of which, that are immediately apparent, we detail as follows:-
Figure 1: Tree Survey showing South Wing of East Lodge.
In the Tree survey, T21 is listed as a Juniper of category C (low grade).
Figure 2: Tree Survey – amended
This second diagram, drawn to scale, shows various missing trees
T21 is not a Juniper, it is a Holly (Ilex sp.). It is also a good quality tree, not a C grade.
Tree t5 above, which is not shown in the survey is a Yew (Taxus baccata), approximately 9m high (this is not the same tree referred to in 2(iii) of this synopsis).
Trees t2 and t3 are Cypress, approximately 9m high, planted in 1992.
These established trees are potentially at more risk than the planning application indicates because (1) the root protection zones need to extend further to the West for these undocumented trees. (2) The proposed road looks as if it will be set at a lower level than the existing ground:
Figure 3: Area of campus in blue circle shown below (from page 65 D.&A.S.)
Figure 4: Cross section through building F and proposed inner ring road.
The red line indicates current ground level (?). The bold black line shows excavation up to the boundary (dashed vertical), potentially threatening the existing (and undocumented trees) near to the boundary (see page 65 D.&A.S.)
We are concerned about the risk that the proposed perimeter road poses to the roots of the 22m Wellingtonia (Sequoiadendron giganteum) (T18) and also to the 15m high Dawn Redwood (Metasequoia glyptostroboides)(T20), a critically endangered species. According to the British Tree Register the 15m Dawn Redwood is the second tallest of its species in Norfolk.
Not only does the road pass through the Wellingtonia’s Root Protection Area, but also the road level will be significantly lower than the current soil level around the tree. See the previous cross section in Figure 7 (page 7) re. ground levels. The Wellingtonia is already on raised ground compounding the problem.
Wellingtonia roots and proposed road
Survey Accuracy
Land Surveys. An accurately measured topographical land survey should be undertaken. This should
Show the position of all trees, shrub masses, significant individual shrubs, hedges, and stumps within the site …
Show the location of trees on adjacent land, including highway trees, which may influence the site or have importance in the local landscape (Trees and Development Local Plan Adopted Supplementary Planning Document).
Holm Oak in centre of picture.
The impressive Holm Oak that stands near to the Wellingtonia appears not to be represented. It is within the area of group G5 but G5 only lists Holly and Sycamore.
There are also shrubs and a tree that stand to the North of the Wellingtonia/Redwood line of trees, that are not in the survey. These will be lost to the road, as proposed.
We believe there may well be other significant inaccuracies and omissions therefore we consider the Arboricultural Assessment to be flawed. Further the loss of trees covered by “TPO’s” and other important trees is contrary to and in conflict with Local Plan NE3, NE8 and NE9.F We therefore ask for clarification from the Head of Planning Services and the Tree Protection Officer as to why these inaccuracies and anomalies within the Arboricultural Assessment have not been questioned and addressed by Planning Services.
6. CONCLUSION
(i) This proposal conflicts with Local Plan policies, will create traffic and parking hazards along with traffic and pedestrian conflict both on and off the site. The proposals represent over-development of the site. The campus is an island site and therefore always restricted as to expansion and considered too small for purpose by the City Architects department in the early 1950’s means the proposals are very cramped. Privacy to our gardens and the rear habitable rooms of our houses will be lost. The severity of the overlooking with noise and pollution problems from the proposed car park and new inner ring road with the subsequent overlooking and resulting loss of privacy from the buildings can be best appreciated from the back gardens of the residents neighbouring the college (see attached sheet 2.) Please come and look for yourselves when you visit the site.
(ii) Almost all of the residents neighbouring the College (approximately 95% plus) and beyond object to this proposal and will have written to the planning authority independently. We believe this application as it stands at present should be refused, as it would be entirely inappropriate as proposed in principal and general concept, harmful in this location and have a detrimental affect on the amenity and quality of the residents lives. We would then urge the Planning Committee to ask City College to submit, with genuine public consultation from the earliest possible stage (Law-Planning Policy Statement 6), a detailed planning application based on a reduced proposal designed to blend sympathetically around the retention of the original Norwich building and in keeping with the surrounding residential and Conservation areas.
7. POINTS ARISING
In our view it is imperative that the Planning Committee are allowed the opportunity to make a site visit in order to assess the physical relationship of the proposed redevelopment with the existing road network and the lack of safety that the proposed new inner ring road accesses/egresses to Ipswich Road will cause.
To assess the relationship from within the campus and from back gardens of the impact on neighbouring properties and residents of the proposals concerning the height of all the proposed buildings, the resulting concerns we have relating to overlooking and loss of privacy. To also assess the position and proximity of the proposed car park and inner ring road to the neighbouring properties. The subsequent loss of light, sunlight, sunsets and night sky. The loss of trees covered by “TPO’s” and other important, healthy, young and mature trees and during the demolition and construction period the loss of “on site” open space.
8. ADDENDUM (Thetford Building)
We understand that a full detailed planning application reference number 08/00420/F has been submitted to the Local Authority. We are led to believe that this proposed new building will be a teaching facility and an exhibition centre (dual use?) with proposed deliveries by Heavy Goods Vehicles. We submit that this is an inappropriate use and the turning of large vehicles into and out of the site from Cecil road will be a hazard to pedestrians and other vehicles alike.
We are concerned that this modern conceptual building of some architectural merit and construction will look out of place within a Conservation Area. The contemporary style, scale and size of the building in this setting, is inappropriate set as proposed, between two Edwardian buildings in a residential area of similar architectural style. This concept is progressive for the students and the College alike, but we would suggest that it would sit more comfortably on a green-field site. CRC are very concerned that this modern concept will set a precedent, which we consider inappropriate within its setting, not only for the proposed new building, but also for the main campus redevelopment. This is contrary to and in conflict with Local Plan HBE8.
The Thetford building and its garden are located within a Conservation Area, which gives statutory protection to trees. However it is our understanding that most trees within the Thetford building garden will be felled. These include a mature Weeping Beech, a Western Red Cedar, a large Sycamore, a Holm Oak, a Birch, a Rowan and a shrub group. A Bird Cherry and several Hollies, important food sources for wildlife, will also be lost. We are concerned at all of these losses and in particular the Weeping Beech. This is contrary to and in conflict with Local Plan NE3, NE8 and NE9.
Attachment sheet 1
Current view from № 7 Cecil Rd towards College. The tree to the far left is 22m high.
Montage view from № 7 Cecil Rd towards College.
Pictures in this appendix have been digitally retouched to show an impression of an 18m (59ft) high building set back about 28m (92ft) behind 2 Cecil Road.
From the College’s tree survey, the fir tree on the left of the picture is 22m (72ft) high. The tree showing over the top right of the roof is 19m (62ft) high and set at about the same distance away as the proposed building. The impression is, as accurately as possible, shown as 18m (59ft) high, as in the College outline proposal.
The impressions are only intended to show the dimensions of the proposed building envelope and do not purport to show what the building will look like in terms of materials and form. Remember that block F is slightly higher than the existing ridgeline of the Norwich Building by 0.4m (1.3ft).
Attachment sheet 2
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