If like us, you think this St William Berkeley Group application is unacceptable, please make your voice heard. It Will make a difference.

How to submit an objection

• Click on the links above to see a short and long list of objections that AGHAST has compiled. We will be posting our objection submission soon.

• It’s best to compose your own letter or email, but if you don’t have time or don’t feel confident, you can use our objection letter template to create a personalised objection letter.

• Letters of objection should be sent to Chris Swain, Planning Team Leader, City Development & Regeneration, Brighton & Hove City Council, Hove Town Hall, Norton Road, Hove, BN3 3BQ, quoting reference BH2021/04167 

• Alternatively you can send an email with your comments on the application to planning.applications@brighton-hove.gov.uk quoting reference BH2021/04167
  It helps to copy and paste your comments in an email directly to Members of the Planning Committee in case they don’t see all of the comments in the online portal. You can find the Members of the Planning Committee and their email addresses here:  Brighton & Hove council planning commitee contact details

• If you require a street representative to help you with your objection letter, or to collect a letter for postage, please email: protestforbrightongasworks@gmail.com

What other Brighton groups think about the St William Berkeley Group application:

https://www.kemptown-society.org.uk/latest-news/brighton-gasworks-submission/

https://www.brighton-society.org.uk/gasworks-planning-application-preview/

Here is a list of objections to inspire you

Letters of objection should be sent to Chris Swain, Planning Team Leader, City Development & Regeneration, Brighton & Hove City Council, Hove Town Hall, Norton Road, Hove, BN3 3BQ, quoting reference BH2021/04167 

If you are in a hurry just copy and paste a couple of the below objection points into the template objection letter and add a few words of your own and send the letter to the above.

List of possible objection paragraphs:

1. Much of the development in the immediate surrounds of the site is 2-3 storey residential dwellings, and will be dwarfed by the height and scale of development proposed. -The proposed development is of an excessive height, scale and massing, way beyond the 2,000 sqm / 85-unit scale of development which is indicated as appropriate in Policy DA2.-A poll of local residents undertaken by a local action group (AGHAST) showed that the majority were significantly concerned about pollution during the construction period. The height and bulk of the proposed dwellings will maximize the risk of deep excavations into contaminated ground (in order to build foundations).

2. The site is situated to the south and west of the South Downs National Park. This excessive conglomeration of tall buildings will damage views from Downs, and towards the Downs, negatively impacting the enjoyment of this Area of Outstanding Natural Beauty.

3. The tall buildings in the Berkeley proposal are not in line with the guidance from the city plan, which does not designate the area as suitable for tall buildings. The updated National Planning Policy (NPPF) gives even stronger weight to the need to follow local design guidance, meaning that proposals for the site should not include tall buildings.

4. The proposed 495 dwellings will result in an increased need for GP services in the local area, but no GP surgery is proposed for the site. Disappointingly, no community centre or gathering place is proposed either.

5. Insufficient understanding has been shown in the design to the highly particular microclimate of the site. Proximity to the front, on a corner or headland of the cliffs and the impact of other building around it, means this areas is affected by particularly localised very intense winds. The design proposed, will not alleviate this and will make it worse. Wind tunnels are already regularly strong enough to kill plants, make opening car doors and house windows physically difficult; property such as concrete walls, sheds and greenhouses, are regularly blown over. This development will make it not only less pleasant to live here but more physically challenging and unsafe for everyone living around the new build.

6. There is a lack of information available on Contaminated sites in Brighton & Hove, and the Brighton Gasworks site in particular. However, I am aware of the impact other similar developments have had/are having on Communities near other Gasworks site developments and I am concerned about this. The development of former gasworks sites for residential purposes is of such concern that an all-party parliamentary group was formed to look at it.

7. The high rise buildings lining the northern and eastern sides of the site will have an overbearing impact upon the residential properties facing these elevations. The massing of these high-rise buildings will destroy the outlook and sense of privacy from the windows and garden areas of these properties.-I do not believe that the development will be a pleasant place to live for future residents given the shadowing and lack of sunlight from the tall buildings and lack of outdoor areas for such high density.

8. I believe there are concerning issues arising from the St William Berkeley Group Contamination report and Remediation proposals, submitted with the planning application, which have not properly been addressed. The development of former gasworks sites for residential purposes is of such concern that an all-party parliamentary group has been formed to look at it.

9. The scale of buildings will impact negatively upon the setting of the listed buildings and conservation area to the west of the site. There is a strong presumption set out in the National Planning Policy (NPPF) to refuse schemes which would cause heritage harm.

10. These development proposals fail to "foster well-designed, beautiful and safe places" - one of the over-arching objectives of the National Planning Policy (NPPF).

11. There are 3 primary schools, one secondary school plus a school playing field whose playgrounds are within the 500m radius identified in Quod's 2020 Scoping Report as being subject to the release of (potentially toxic) dust during the remediation and excavation of the site. Research increasingly shows the hazards of air pollution on child development and respiratory illnesses. This level of risk with so many local children is unacceptable.

12. The proposal would be a major intervention that would have a significant impact on those designated heritage assets near the gasworks site, that is Lewes Crescent (Grade I), Chichester Terrace (Grade I), Arundel Terrace (Grade I), and Sussex Square (Grade I), the Kemp Town Enclosures (Grade II Registered Park and Garden), and the Kemp Town Conservation Area, and the linked Esplanade Cottages (Grade II), Old Reading Rooms (Grade II), and Temple (Grade II), and the Madeira Terrace, Madeira Lift and Shelter Hall buildings (Grade II*) and the East Cliff Conservation Area. -Berkeley St William's application lacks the exuberance and ambition that the best of Brighton’s seaside buildings exhibit. It would not, therefore, be a positive contributor to its context and in many respects, it would fail to take the opportunity the gasworks site presents.

13. The developer has a dubious track record, in Southall, of inadequate plans for and management of hazardous materials on the site. The years long campaign (Clean Air for Southall and Hayes) by Southall residents to stop the unfolding public health disaster around Berkeley's site there makes me fearful of the consequence of development here and I cannot have faith in the remediation plans sketched by the developer here, which appear to use the same approach that has so clearly failed in Southall.

14. The buildings would cause increased overshadowing, this is a fact regardless of whether the sunlight and daylight reports being submitted in support of the application demonstrate that Building Research Establishment (BRE) guidelines would be met.

15. Not enough parking is provided (179 spaces for 495 dwellings), it is clear that future occupiers are likely to own private vehicles at this distance from main transport hubs and should be provided with parking spaces within the development. There should be a minimum of one space per flat, disabled parking and spaces for the commercial uses proposed and visitor parking. Parking adjacent to the site is unmanaged and will become swamped.

16. MP Virendra Sharma set up an All Party Parliamentary Group to investigate the specific issues, which are largely contamination related, to the development of gasworks sites, shows clearly that not enough is yet understood about how contamination escapes such old industrial sites from land to air. Until this is better understood we should not be developing this site.

17. Berkeley present their designs as connecting the Downs and the sea, but in fact the tower blocks they propose will create an ugly visual barrier for those living in Whitehawk and further up the hill.

18. Berkeley's design is not carbon friendly. The built environment accounts for approx 36% of carbon emissions, and it is now time to turn BHCC pledges into positive actions by embracing lower rise designs with more environmentally friendly building materials. We need to reduce "embodied" carbon (the carbon used in the extraction, manufacture, transport and assembly of buildings) as well as the "operational" carbon (the energy we use for heating, lighting, cooling, etc.). The design of new developments should adopt a "fabric first" approach (with priority given to optimum surface area to volume ratios, orientation, sunlight/shading) and Berkeley's design is a long way from these principles.

19. I have no confidence in Berkeley St William's ability to safely manage the toxic chemicals buried underneath this site. They have not reassured the community about this and their outline plan is inadequate - there has been no clear disclosure (or even investigation?) of exactly what chemicals are buried there.

20. The design does not speak to or take account of proposals for the parcels of land on either side of the site currently owned by the Council. Any design for this site should be holistic and should be integrated with designs for those areas as well as the wider surrounding area.

21. In 2018, Brighton & Hove City Council pledged to be Carbon Neutral by 2030, by reducing carbon emissions, energy consumption, raw material extraction and drinking water usage. Berkeley's design is not a design that will help address the climate emergency.

22. The gasworks area already sits at a busy traffic junction, with queues of traffic coming down Wilson Avenue, on the Marina slip road and on the A259. Adding 495 new units will likely significantly increase traffic levels, and add to particulate pollution from traffic, endangering the health of existing and future residents. A less dense development, or fewer units, would have less impact.

23. Ninety percent of the planned 495 dwellings will be two or less bedrooms, more suitable for weekenders, holiday rentals and foreign investment. They will therefore by more likely to be marketed to overseas investors than to provide much needed homes for existing Brighton residents.

24. The gasworks site is a strategic location needed for staff overflow parking and the handling/storage of bulk materials/supplies - performing a vital role in the new Brighton RSC Hospital's operational and construction work. It functions as an essential "logistics" area for the RSCH construction works - e.g. lorry parking/call forward point for bulky deliveries, plant, glazing units, air handling units, etc. removing this will adversely impact existing residents and may impact the redevelopment of the much needed local hospital.

25. In the St William, Berkeley Group's Environmental Impact Assessment section 11.1 - Wind microclimate. Fig 11.1 the modelling image data does not show any data relating to the east side into the site i.e. residents of Cliff road and Marine Gate. This falls short and is worrying for residents of this area as it suggests that the wind impact here may be more severe.

26. Berkeley's proposed development of dense blocks will be crowded onto a 2 hectare site, with tall towers blocking sunlight and daylight between buildings, rendering any planned recreational space dark, windy and unfit for use.

27. The flats proposed, even if the so-called 'affordable' homes are included (80% market rents or shared ownership schemes), are likely to be unaffordable for people on average incomes in the area.
    
    Average household incomes:
    Whitehawk £29k
    Kemptown £36k
    Marina £35k
    Brighton & Hove £33.3k

28. National Planning Policy (NPPF) requires local authorities to identify heritage assets and consider the impact on them, to minimise any conflict between them and any aspect of the proposal. A new development on the Gasworks site should be of first class architectural quality and respect the height, scale, and character of the surrounding heritage assets the whole length of Marine Parade, from Brighton Piers in the west through to Roedean School in the east.

29. The City Plan does not include the Gasworks site within an area of the City where Tall Buildings (over 6 storeys) are permitted. The St William Berkeley Group proposal includes 10 building elements which range from 7 - 11 storeys and these buildings occupy two thirds of the entire built area. This represents a massive breach of policy.-There is no commitment to affordable housing in the plan. If approval is granted there is a high likelihood that the developer will then claim it isn’t viable to include affordable housing. This has happened on other recent large proposals.

30. There will be further disruption to the congested A259 heritage seafront road from additional traffic generated by the proposal both during construction and in its completed state. There will also be further disruption to Eastern Road and the adjacent roads including Kemp Town Estates, which are already at capacity in peak times. The additional volume of public and private vehicle usage will lead to an increase in pollution levels.

31. When asked how East Brighton could be improved, the most popular responses were:

• No tall buildings

• Additional local amenities

• Making the area more joined up

• Increased social and affordable housing
  
  

This design ignores these preferences. Ninety percent of the planned 495 dwellings will be two or fewer bedrooms, more appealing  to foreign investors and those looking to invest in holiday flats than to local residents.