Make your objection valid
The following is a list of key bullet points taken from the planning consultant's letter. Despite the changes that have been made to the scheme these objection points are still valid. It is a big scheme and there are a lot of points, and not all may seem relevant to you, so please read and refer to those which concern you the most.
- The proposal will diminish the significance of the original 1850s Queen’s Hotel building as a locally listed landmark.
- The Council must be satisfied that the development preserves or enhances this designated heritage asset and we believe the scheme will cause harm to the character and appearance of the Church Rd Conservation Area.
- This is already the largest and most prominent building in the conservation area, and despite alterations remains legible as an 1850s hotel.
- The development should not undermine or diminish the quality of the conservation area, however if such a need has arisen then a considerable degree of public benefit must be evident to grant consent.
- The local listing of the Queen’s Hotel extends to the entirety of the main building including the 1970s extension and buildings not visible from Church Road. Therefore the site must be viewed as a whole, the 19th Century section cannot be considered in isolation.
- Although the 1970's extension detracts from the overall quality of the site, it does not dominate the site or the original historic core which represents an important marker in the early development of Upper Norwood. And is not immediately visible from Church Road.
- Removing the miscellany of architectural accretions, such as the canopies and additional stories) will benefit the appearance.
- The addition of the new 'spine' block to the south, combined with the book ending of the 1970’s block will be overwhelming and overbearing. The minor adjustments that have been made are insufficient. The bulk, scale and massing of the new elements will have a negative impact on the conservation area and further degrade the 1850's buildings.
- The new proposed extensions are at odds with the existing building, as well as the those that make up the conservation area. There has been minor development within the conservation area, but the collective significance of the historic buildings has been maintained. The visual influence and appreciable scale of the proposed hotel development would be of detriment to the conservation area.
- The objection is not with the use of contemporary architectural treatments, in that a pastiche option would not be appropriate, but with the lack of sensitivity in their proposed application. Development should be of the highest quality and respond logically and legibly to the existing historic site, the design and materials should be appropriate and reflect the context of the site.
- The scheme is more than three times above the density guide recommended for a comparable residential scheme.
- Addition of 196 or nearly 60% increase in rooms represents overdevelopment.
- A substantial area of subterranean development, including 114 (nearly 20%) underground rooms with many not having windows, is not a high quality design.
- The scheme requires louvred windows and privacy screens in an attempt to reduce overlooking neighbouring buildings , but this too demonstrates overdevelopment.
- The transport assessment for the site, and resulting assumptions and conclusions drawn from the data are questionable.
- Low public transport accessibility, TfL’s webCAT tools grades the site as a level 2 (where 0 is the worst and 6 the best connected) – but this application grades the site as 3.
- The number of vehicle trips generated by the hotel has been calculated using outdated data from the defunct TRAVL database, it was replaced by TRICS in 2014. It is also based on sites with a PTAL of 4 rather than 2. This data should not be relied upon to justify the proposed levels of parking as appropriate
- Traffic impact has been understated – a survey of the existing situation is needed, particularly given existing congestion on Church Road.
- Parking provision of 170 paid spaces for 530 rooms is not adequate and this could have detrimental impact on surrounding residents.
- It is proposed that there will between 16-24 service vehicle journeys per day, but these figures are inconsistent. More information is needed.
- No justification provided for the additional hotel usage, it is not located in a designated town centre, such an intensification of a hotel in a residential area goes against the established town centre hierarchy for Croydon and the London Metropolitan Area.
- The London Policy Plan states that new visitor accommodation should be focussed in town centres where there is good public transport access to central London and transport termini.
- The Sequential Test that has been carried out to justify construction outside of a town centre is outdated it relates to a previous development proposal from 2014.
- No provision of an impact assessment to consider the effects of the developments on the local area. This is required for development over 2,500m2.
Residential Amenity Impacts
- The development is within a mid/low rise detached residential area with generous open space between buildings.The increased scale and mass of the site will impact on privacy, overlooking and perceived sense of enclosure. Also loss of daylight and sunlight access.
- Croydon’s Core Strategy requires all new development to enhance local character.
- Design measures, such as recessed windows and louvres which common in constrained inner city settings have been proposed in an attempt to combat overlooking and proximity to other amenities.
- Daylight and sunlight would be reduced by 96% & 94% respectively in surrounding residential properties.
Basement and Car Park excavation
- It is proposed that the basement can be constructed without impacting the groundwater, subsurface or existing building conditions, but not demonstrated through surveys.
- There is no statement regarding the management and methods for safe and efficient basement construction or the impact on local residents.
- There is no information regarding the impact of construction and spoil removal on local residents and infrastructure e.g. the traffic congestion on Church Road.
We have received feedback from local Councillors that a number of objections already made have been quite argumentative in their nature. Many people will have their own reasons to object. We know that not everyone thinks the hotel has always been a good neighbour, and that it has made little effort to be part of Crystal Palace’s thriving local and business community. However, Croydon Council can only take certain points into account when deciding whether to give planning permission. We would encourage you to provide a constructive, well argued and measured response (however angry you might be!). A single sentence about your opinion of the hotel will suffice. The Planning Officers are overwhelmed by letters and will simply not fully consider objections that are not valid.
We are not supplying a standardised or form letter as these do not carry much weight, the Planning Officers would not learn how this development affects you and your community. Each person has the ability to contribute a unique perspective and information, giving greater weight to overall objection to the proposals. Similarly petitions are of limited value, as whilst they represent a strength of feeling, they only represent a single view point.
Some key points to consider
- Be constructive, what do you like? It is likely that something will get built so complement anything that you see as positive, e.g. Landscaping, unified appearance…
- Try and stick to facts rather than assertions.
- Avoid referring to the planners/ Council in a derogatory way.
- Try and object on grounds that can be tied to planning conditions, the internal design and guest experience are unlikely to be cause for the proposal to be refused.
- Planners are likely to take decisions on the strength of the evidence received, tell them why you are putting your view forward, give your reasoning.
The following link provides some really good detail on making a robust representation to the council: http://planninglawblog.blogspot.co.uk/p/how-to-object.html .
Summarised as follows
- Adverse effect on the residential amenity of neighbours, by reason of noise, disturbance, overlooking, loss of privacy, overshadowing, etc.
- Unacceptably high density / over-development of the site, especially if it involves loss of garden land or the open aspect of the neighbourhood
- Visual impact of the development
- Effect of the development on the character of the neighbourhood
- Design (including bulk and massing, detailing and materials, if these form part of the application)
- The proposed development is over-bearing, out-of-scale or out of character in terms of its appearance compared with existing development in the vicinity
- The loss of existing views from neighbouring properties would adversely affect the residential amenity of neighbouring owners
- [If in a Conservation Area, adverse effect of the development on the character and appearance of the Conservation Area]
- [If near a Listed Building, adverse effect of the development on the setting of the Listed Building.]
- The development would adversely affect highway safety or the convenience of road users [but only if there is technical evidence to back up such a claim].
The following points, on the other hand will not be taken into account in deciding on the acceptability of the development in planning terms :
• The precise identity of the applicant;
• The racial or ethnic origin of the applicant, their sexual orientation, religious beliefs, political views or affiliations or any other personal attributes;
• The reasons or motives of the applicant in applying for planning permission (for example if the development is thought to be purely speculative);
• Any profit likely to be made by the applicant;
• The behaviour of the applicant;
• Nuisance or annoyance previously caused by the applicant [unless this relates to an existing development for which retrospective permission is being sought];
• Concerns about possible future development of the site (as distinct from the actual development which is currently being proposed);
• Any effect on the value of neighbouring properties