Addendum to Synopsis

Planning Application Reference Number 08/00255/O
Norwich City College, Ipswich Road, Norwich. NR2 2LJ.


INTRODUCTION

By way of this addendum to our original synopsis we wish to raise the following further concerns and other points relating to the original and revised Outline Applications to demolish and redevelop the entire City College campus.

GENERAL (The Format of the Revised Outline Application)

The revisions to the Outline Application to redevelop the College campus consist of a further six documents. They are :- a covering letter, two spirally bound A4 size books plus one larger format spirally bound book (a total of a further 87 pages) and revised and amended Arboricultural and Tree Constraints drawings.

We would ask that this addendum written in response to the revised Outline Application be read as an addition to our original synopsis and we therefore make no apology for not revising the original in accordance with the revised proposals. The reasons for this approach will be explained as necessary within this addendum. The one exception is :- title heading 5 (xi) Arboricultural Assessment which has been updated within our original synopsis in accordance with the revised proposals.

CRC consider that the major proposals within the revised Outline Application are the omission of the car park deck, constraints relating to the intended use of the inner ring (link) road and the proposed provision of a primary vehicular access at the Southern end of the campus with the Northern access downgraded to an emergency and occasional managed service access.

Notwithstanding, CRC contend that these amendments do little to address any of the neighbours’ and residents’ concerns and in fact do not respond to or amend, but to the contrary retain, the immense density and scale of the overall redevelopment, retaining not only the essence but the total design concepts of the initial scheme, set out in the original Outline Application Masterplan (see illustrations and text pages 58 and 59 D.&A.S.).

Please note that title headings and number references from our original synopsis remain in sequence within this addendum. Therefore although most comments within this addendum are new and additional they can be referenced to the text of the original synopsis by the reader. Where CRC have no additional comments :- title headings, numbering and supporting text have been omitted to avoid confusion and repetition.

We have also neither considered it necessary to duplicate text references to the D.&A.S. and supporting documentation within the main Outline Application, as they are referred to in full within our original synopsis, nor have we duplicated references to current planning law or other legislation. However, where appropriate CRC have referenced the source of new and additional material.

PART I (References to Local Plans applicable to this Application)

LOCAL Planning Policy

We have not considered it necessary to duplicate references to Local Plans as we have referred to them as fully as possible where applicable in our original synopsis.



Part ii (CRC Revised Addendum)


1. Environmental Assessment

General:-
CRC reiterate that they find it extraordinary that such a large proposed redevelopment does not require an Environmental Impact Assessment. As we have further cause for concern based on the following we quote :-‘The campus ground level rises front to back by some 4 to 5 metres and opportunities for levelling the ground will allow for the visual impact of buildings to be reduced and for access by the disabled to be improved.’ (see page 54 4.5 para 6 D.& A.S.) The implications of this statement have only recently become clear. We refer to the existing survey and level drawing (see page 38 D.&A.S.).

The existing ground level above ordnance datum in the North West corner at the frontage of the site is recorded as +30.9m. The existing ground level at the North East corner at the rear of the site is recorded as +35.3m. A rise of 4.4m (14.5ft.) from front to back.

The existing ground level at the West central frontage of the site is recorded as +28.9m. The existing ground level on the central East boundary of the site is approximately 33m (interpolated). A rise of approximately 4.1m (13.5ft.) from front to back.

The existing ground level at the South West corner of the frontage of the site is recorded as +29.5m. The existing ground level at the South East corner at the rear of the site is recorded as +34m. A rise of 4.5m (14.75ft.) from front to back.

We can therefore assume that a conservative average notional rise from the frontage of Ipswich Road to the rear of the site along the length of the Eastern boundary is approximately 4m (13ft.). In order to obtain the cubic capacity of spoil to be removed from the site, we again refer to the survey drawing (see page 38 D&A.S.) and we suggest the following equation: - 400m (1300ft.) length of site x 190m (620ft.) width of site x 4m (13ft.) height of rise from front to back of the site divided by 2 = 150,000 cubic metres (rounded down). Therefore 150,000 cubic metres of spoil will have to be removed in order to comply with the design concept. 1 cubic metre of consolidated topsoil weighs 1.7 tonnes (B.S.Topsoil, a division of British Sugar plc.). Therefore the approximate weight of spoil to be removed is 150,000 x 1.7 = 255,000 tonnes.

The authorised maximum load weight of an articulated bulk carrying H.G.V. is 25 tonnes. Therefore to remove the spoil from the site it will require 255,000 divided by 25 = 10,200 loaded trips from the site x 2 for empty return trips. This makes a total of 20,400 H.G.V. trips to and from the site. However, please note that smaller unarticulated bulk carrying H.G.V.s can only carry 16 tonnes. Therefore using these smaller H.G.V.’s. the number of trips each way will be increased by 56%. This increases the total to 15,940 x 2 = 31,880 trips.

We suggest that the above will have an immense environmental impact and an enormous carbon footprint impact, not only within the site and surrounding areas but also similar serious impacts on a considerably wider area of Norwich itself. A large proportion of this spoil has been contaminated with over 60 years of oil and petrol spillage from the car parking areas. A large area behind the Norwich Building is known to be contaminated with residual asbestos and there will be areas of chemical and waste spillage resulting from the 60 year period usage of the site by the College.

CRC cannot therefore concur that this Outline Application does not require an Environmental Impact Assessment. Further we have not considered the impact of nuisance, noise, dirt, dust and associated airborne chemical pollution on neighbours’ amenity and lifestyle and the effect on their properties of these industrial scale works. Please note our comments and supporting figures neither include for the digging out of existing concrete bases, foundations and footings or the demolition of existing buildings, nor the loading and removal from the site, of all the debris resulting from these works and the heavy plant and machinery that of a necessity will be required on site. Therefore we suggest our figures are conservative and err very much on the side of caution. Preparation for new building work will probably require as much as an average excavation over the site, to a depth of some 0.3m (1ft.) thus increasing the number of trips to remove the spoil even further.

We have not considered the impact of nuisance, pollution etc. to neighbour’s amenity and lifestyle or the effects on their properties resulting from the new building works. There will be ongoing and continual delivery of machinery, concrete, steelwork, building elements, materials and associated plant to the site and nuisance from the building works themselves during the six year construction period.

With reference to the contaminated ground we quote :- Planning Policy Statement 23 : Planning and Pollution Control (2006) ‘This statement advises that any consideration of the quality of land, air or water and potential impacts arising from development, possibly leading to impacts on health, is capable of being a material planning consideration.’ (see page 45 para 6 D.&A.S.) Further we refer to the Environmental Protection (Duty of Care) Regulations 1991 and would also suggest that the removal of this spoil could be in contravention of current English and European landfill legislation.

We would also suggest that our figures bring into disrepute any data within the two Transport Assessments neither of which have taken into consideration the traffic implications related to the building works. These assessments are therefore unrepresentative of future H.G.V. and vehicular movements within the surrounding area and therefore erroneous and flawed.

CRC are concerned that if funding for phase 2 is not forthcoming the amount of excavation around the central retained buildings, at the rear of these buildings, will result in the site being on two different levels. The back of the Norwich, Blakeney and Cromer buildings will be between 1.2m(4ft.) and up to 2.5m(8ft.) above the excavated and completed Phase 1 development.

All of the forgoing raises the serious question as to how the College will function, during this proposed redevelopment programme, or if the funding for Phase 2 does not materialise.

CRC consider that, although the argument for the principle of the College redevelopment is a noble and worthwhile goal, the price to be paid by the College, students and residents within Town Close ward, for the six year construction programme will be too high a price to pay.

On any of the above facts alone, CRC believe that this Outline Application should be refused.

2. THE PRINCIPLE OF THE DEVELOPMENT
(Points of concern to the principles relating to the Outline and Revised Outline Applications)

CRC are concerned that when added to the original Outline Application documentation (see page 1 of our Synopsis) that the massive amount of complex information and detail will obscure without due process of thought, much of what should be considered thoroughly within a Detailed Planning Application. Thus the full Outline Application, if approved, will set a precedent that will see a considerable number of areas of concern not properly discussed or considered. For instance the following :- positions, heights and massing of buildings, positions of accesses, inner link road, car park, energy centre and landscaping amongst other considerations will all have been approved and set in stone within the outline proposals. This goes much further than establishing the principle of the development and as such will negate most considerations relating to the reserved matters leaving only external appearance and materials to be approved within a later full Detailed Planning Application.

On this basis alone, CRC believe that this Outline Application should be refused and be the subject of a full Detailed Planning Application.

(v)CRC remain concerned that there is still no provision within the revised proposals for marshalling points on the campus in the event of fire, for practice fire drills or any other emergency, certainly during the construction period and heavily restricted thereafter.

(vi) CRC and many others remain concerned at the loss of the Norwich Building. We believe that this iconic and important building, part of the City’s heritage, should be retained as the landmark Building it is and be the IDENTITY of the City College campus now and within any future redevelopment.

(viii)CRC remain concerned at the loss of the College residences (Southwell Lodge) as it is generally known and accepted that within the City student accommodation is at a premium and inadequate to meet demand. This lack of supply creates a demand within the City for residences to be turned into H.M.O.’s. (Homes of Multiple Occupation) which can result in a detrimental effect on an area.

3. Effect on Neighbouring Property

(ii) CRC are concerned by the restrictions of use of the inner link road to the North end of the site and the effect this will have on the vehicular access and parking for those attending the ‘Town and Gown’ facilities. ‘…….the campus redevelopment may provide a range of additional facilities including a swimming pool and a performance theatre’ (see page 8 para 4 Transport Assessment Addendum July 2008). If these facilities are to be accessible to the public, how will this be achieved, without compromising the downgrading of the Northern access and inner link road?

(v) CRC remain concerned at the impact of the proposed new 4 storey vocational block F and that this building will allegedly contain car workshops that will be open to the general public. This will introduce testing - i.e. revving of engines, roller shutter doors and all other nuisances associated with a general motor repair shop. We reiterate that proposed engineering workshops, car repairs, metal working etc. have to be the subject of a Detailed Planning Application. We again reiterate that this proposed block F replaces a residential building (Southwell Lodge) which we understand to be a change of use which should also be the subject of a Detailed Planning Application.
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.

(ix) Although CRC are pleased that the decked car park has been reduced to a surface car park, we are still concerned that this will still affect the rear of most houses on the West and part of the South side of the site, and with the proposed inner link road there will still be traffic noise, reflected traffic noise (as the noise reverberating from the retaining walls, block F and tutorial blocks will produce a reflected echo), pedestrian noise, artificial light, exhaust and headlight pollution during the daily 14 working hours of the campus. At night and in early winter mornings there will still be light pollution from the car park lighting and reflected light pollution from car headlights.

(xi) CRC remains concerned, as do the residents affected, about the impact of pollution and associated noise pollution from the proposed energy centre. The College indicated they would consider, within the revised Outline Application, relocating to the centre of the proposed redevelopment, but this has been omitted from the revised application.

(xii) CRC are pleased the Northern access road will be downgraded, thus reducing disturbance and pollution to the Northern and part of the Eastern boundaries of the site. The remainder of the Eastern and Southern sides of the site, however, will still be affected and CRC remain concerned by the impact of the proposed new inner link road on the amenity of these neighbours to the College. There will still be vehicle, motor cycle and moped noise, reflected traffic noise, exhaust pollution, pedestrian noise and at certain times headlight and reflected headlight pollution and artificial light pollution during the daily 14 working hours of the campus.

(xv)Within the revised Outline Application the proposed surface car park will have a capacity for 345 cars. However, a recent count of cars on the current campus produced a figure in excess of 750 cars. Therefore with the anticipated 25% growth of the College CRC suggest that the car parking arrangements after completion of the works will be inadequate. CRC also remain concerned by the environmental implications, rat running and the anticipated illegal parking, extending within and beyond the immediate area during the construction period. This will be particularly acute during phase 1 of the works probably affecting and reaching as far afield as Eaton and elsewhere.

The College has now admitted that, at least during this phase of the redevelopment there will be no ‘on site’ car parking and that no alternative sites are available.

4. Effect On Surrounding Area

(i) CRC reiterates that Ipswich Road as 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.

(ii)CRC reiterate our previous concerns as to road safety in the general Ipswich Road area outlined in this paragraph within our synopsis and we are still concerned as to whether these proposed new junctions can be designed to Local County Council Highway Authority standards. This concern particularly applies to vision splays and junction visibilities conforming to standards laid down in TD42/95 especially as these accesses will not only be for the use of motor vehicles but also H.G.V.’s. buses and coaches. We again ask for clarification of these standards both from the Highway Authority and the Head of Planning Services.

5. THE OUTLINE APPLICATION (Design and Access Statement)

(v) TRANSPORT ASSESSMENT:-
CRC reiterate that Ipswich Road, as an arterial route, is busy, and CRC understood as did many others that one reason for the initial deferment of the original Outline Application were the traffic implications, hazards and conflicts brought about by the proposed introduction and positioning of the Southern most vehicular access to the site. We quote :- ‘Much thought has been put into the access arrangements that are still in the process of being revised and agreed. Suffice to say that NCC will only agree to arrangements that are considered not to prejudice highway safety for all modes or the functioning of Ipswich Road as a Strategic Route into the city.’ and ‘NCC will only agree to access arrangements that are considered not to prejudice highway safety for all modes or the functioning of Ipswich Road as a Strategic Route into the city and meet current design standards. The access arrangements are still in the process of being revised and agreed.’(e-mail dated 16th June 2008 from Norfolk County Council in reply to questions from CRC).

CRC reiterate the introduction of a primary vehicular access at the Southern end of the campus between existing junctions, the retention of a pedestrian crossing, albeit repositioned, and the introduction of a speed camera, along with a bottleneck immediately within the access road itself, does nothing to allay our fears that this area is a major accident designed to happen.

CRC had hoped that in the interests of safety being paramount, this access would be moved much further to the North. Obviously this cannot be achieved without compromising the Masterplan for the redevelopment.

CRC are concerned at the proposals for ‘Access by vehicles to the area in front of the Norwich Building will be limited to College buses, coaches, taxis and for pick up and drop off. Car parking in this area will be limited to 20 disabled spaces.’(see covering letter dated 17th July 2008 and Transport Assessment Addendum July 2008). There therefore appears to be at peak times, a conflict with the 20 short term parking spaces to the opposite side of Ipswich Road for pick up and drop off for children attending Town Close Preparatory School, with probably large numbers of coaches, buses etc. at the same time attending the College site. We suggest that these are conflicting hazards and have done nothing to improve road safety.

(vi) DEDICATED vehicle route:-
CRC and neighbours are still very concerned by the proposed revised inner link road. Although as proposed within the revised Outline Application this road is to be restricted as to its use, this will still introduce a new road into the area and will undoubtedly have to be reinstated as an inner ring road due to the proposed primary single main access at the Southern end of the site inevitably proving to be unable to cope and accentuating the many conflicting traffic hazards. This road will be unadopted (confirmed by e-mail dated 16th June 2008 from Norfolk County Council in reply to questions from CRC) and therefore will not be subject to Road Traffic Acts as to parking etc. Further we quote :- ‘……….a small number of new HGV movements may be generated by the proposed energy centre. For the purposes of this assessment, it is assumed that there will be a maximum of 4 HGV movements per day in each direction, which will be scheduled to avoid the peak periods.’(see page 14 para 4 and page 15 table 8.5 Transport Assessment Addendum July 2008). Therefore the following questions arise. It has been understood that the road adjacent to the Energy Centre is the proposed position for the material and refuse skip for the Vocational Block F. If this is not the case where will this skip and the noise nuisance that relates to it’s use, be situated? Given that usage of the Northern end of the inner link road is to be downgraded and if the skip is positioned adjacent to the Energy Centre, where is the turning hammerhead for H.G.V.’s accessing the site?

(vii) Car parking:-
CRC and neighbours are still very concerned by the position of the proposed car park. Given that there is an anticipated but unsubstantiated predicted growth of 25% in College numbers, the restraints of the site will ensure that the design of this car park will have to allow for any future expansion upwards. Also there is concern regarding the statement. We quote :- ‘Motorcycles and Mopeds – In order to encourage the use of motorcycles/mopeds, the College will : Provide secure parking for up to 250 motorcycles and mopeds.’ (see page 20 9.2.2 Transport Assessment Addendum July 2008). This facility is to be situated adjacent to the car park resulting in, at full capacity, a minimum of 500 motorcycles and moped trips a day. This will exacerbate engine noise pollution, reflected engine noise and exhaust pollution.

(viii) Flood risk assessment:-
We reiterate our concerns as stated within our original synopsis. Further we understand that during the heavy rain recorded in Norwich during early August that the road gullies on Grove Walk could not cope and there was a back surge of both surface and foul water which flooded over the rim of a downstairs toilet to at least one residence situated on the West side of Grove Walk.

(ix) SUBSIDENCE
CRC are concerned that due to the ‘bad ground’ and the amount of excavation required along the Eastern boundary of the site (see Environmental Assessment within this addendum) and as the stable angle of repose for this type of ground will be no more than 30degrees; the ground along this boundary, and also part of the Northern and Southern boundaries to neighbouring properties, will have to be retained. We suggest that the probable solution will be the use of interlocking steel sheet piling driven into the ground prior to the spoil excavation and removal. CRC reiterate our concerns relating to the breaching of storm water drains and culverted underground streams during these works and also the long term effects on the local water table. CRC are also concerned at the resulting consequences and the effect on the structural stability to neighbouring houses and the effect this will have on insurance premiums to these properties.

7. Points Arising
We are pleased that the Planning Committee has been allowed the opportunity to make a preliminary site visit. However, CRC consider it imperative that the Planning Committee are now allowed the opportunity to make a further site visit in order that questions from Committee Members can be clarified and the immensity of the proposals can again be more fully addressed from within the constraints of the site. This will also allow for the vehicular traffic and pedestrian hazards at the Southern end of the site to be discussed in further detail and in-situ.