... A consistent theme running through these letters is our concern at the height, scale and bulk of the two largest proposed blocks, named A and B. We have repeatedly suggested that these buildings would have to be substantially scaled down to lessen the impacts on the conservation area; we are disappointed that this further opportunity to revise the scheme has not resulted in a significant change in the height or bulk of these elements of the proposed development.

Block A does not appear to have been changed since we last saw it and therefore my previous comments still apply. It is noted that the top floor of Block B has been redesigned by flattening it out to help reduce its impact very slightly on the views from the high-level streets and properties within the surrounding conservation area. Taken in isolation, this change is an improvement (though it is arguable that in itself this change would make the proposal acceptable in terms of its impacts on the conservation area),

... but it is the combined effect of the two large buildings, Block A and Block B, that causes the degree of harm to the heritage asset that is objectionable. Simple tinkering with the roof form of one of the buildings is not sufficient to overcome the key point of my objection set out in my earlier letter. As stated in my comments of 8 December 2011, reiterating those of 1 August 2011 and 16 October 2009, "These buildings in particular remain out of scale with the immediate site and the wider surroundings and...will have a significant harmful impact that will detract from the character and appearance of the conservation area", that being characterised predominantly by substantial detached and paired villas of 2-3 storeys set in large garden plots. The overall height of the tallest block remains as it was shown in the previous revised proposals and, allied with the bulk of the buildings, would result in
intrusion into views to, from and across the site thereby detracting from the heritage
significance of the conservation area.

It is disingenuous to argue (applicants letter) that the existing Hastings College building is the benchmark for new development and anything that has "no greater impact on heritage assets than the existing building on the site" would, by implication, be acceptable. PPS5 Planning for the Historic Environment, under which the proposals would have been assessed previously, was clear about the need for new development within conservation areas to make a positive contribution to local
character and distinctiveness (ref. HE7.5). Replicating a form of development that is inimical to the character of the area, on the basis that it does not make the harm any worse than it is, is contrary to both the spirit and letter of this policy. The intention of this policy has been carried forward into the recently published National Planning Policy Framework at para.131: In determining planning applications, local planning authorities should take account of:
· the desirability of new development making a positive contribution to local character and distinctiveness

In light of this, it remains the case that the development as proposed would, in my opinion, fail to enhance the character and appearance of the conservation area. The Council should makes its decision on the applications in the light of this national policy advice.

See Complete Letter

NATIONAL PLANNING POLICY FRAMEWORK

In the wake of the new and controversial National Planning Policy Framework, Sephen Gray has written the following commentary:

Stephen Gray's Commentary