Comment on Northminster planning application ref. 21/01151/R4OUT

1

The Civic Society was consulted on the proposal before the application was submitted and some minor tweaks have been made as a result. However, our major concerns remain unresolved and are focussed around; the future of the market; the scale of the scheme; the impact on the Cathedral setting and; the inadequacy of car parking.

2.

Peterborough Investment Partneship’s pressing ahead with a redevelopment scheme now excluding any provision for a replacement Market, the absence of any arrangements for its relocation and the general lack of communication with stall-holders has met with strong criticism from them, from customers and the Civic Society. The continued existence of a general provisions market in the city centre is essential and there is an obligation on the Council to honour the terms of the charter. Until such a provision is actually in place no redevelopment of the site should be permitted. This application is therefore premature.

3.

Town centres are at the heart of communities, providing a focus for retail and other town centre uses, including leisure, commercial, office, cultural and community facilities. It is national policy to enhance vitality and viability of town centres.

4.

Government guidance under National Planning Policy Framework 2021 in section 7, (Ensuring the vitality of town centres) it states:

• a. 86. Planning policies and decisions should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management and adaptation. Planning policies should:
• i. define a network and hierarchy of town centres and promote their long-term vitality and viability – by allowing them to grow and diversify in a way that can respond to rapid changes in the retail and leisure industries, allows a suitable mix of uses (including housing) and reflects their distinctive characters;
• ii. define the extent of town centres and primary shopping areas, and make clear the range of uses permitted in such locations, as part of a positive strategy for the future of each centre;
• iii. retain and enhance existing markets and, where appropriate, re-introduce or create new ones; ...

5.

The Local Plan strategy is directed towards strong support for the city centre as a retail centre.

• a. Policy LP6: The City Centre - Overarching Strategy
• b. Peterborough City Centre will be developed and promoted to maintain its position as a centre of regional significance. Major new retail, cultural and leisure developments which will meet the needs of the city and its sub-region, as well as the local needs of a significantly larger city centre resident population, are encouraged. A Primary Shopping Area (PSA) is defined, which will be the highest level in the hierarchy of centres for retail planning in Peterborough.

6.

More than half of the application site is lies within the PSA and contains the general provision market which in normal times over 120 standard size stalls. This is the equivalent of a significant amount of convenience goods retail floorspace. Some additional retail space was lost when the multi-storey car park was demolished. A surface level car park has been opened (100 spaces) but the overall loss of about 650 spaces and the retail units has noticeably reduced pedestrian activity here and damaged the vitality of the Northminster area. The permanent removal of the market would exacerbate this situation and should the market be closed before a replacement site is in operation then a significant blow to the viability and vitality of the city centre is likely to be experienced. Together with other recent commercial failures the situation could become of serious concern. It is contended that by virtue of the extinguishment of the market this proposal is contrary to LP6 of the Local Plan and should be considered as a reason for refusal.

7.

A combination of a flat topography coupled with the lack of a really strong vertical accent leaves Peterborough Cathedral unable to make the kind of visual impact familiar from that made by most of the major ancient cathedrals. Peterborough's historic core and related skyline today is scarcely any greater in extent than it was prior to the arrival of the railways, constrained as it still is by river, railway and former monastic precinct.

8.

Leaving aside some exaggeration of relative scale, Bucks' 1731 engraving shows the cathedral looming very large indeed above the rooftops of the town. The crossing tower was then still topped by its octagon, while the N.W. bell tower still carried its timber spire, as did the tower of the parish church. These were then the skylines most vertiginous accents. These three are now absent but the Cathedral remains as the most dominant visual image of the city from a southern approach.

9.

The Embankment View. This crucial view of the Cathedral has been addressed through photographic images. One of the most important of these is from the Embankment. At para 3.2.1 neither of the ‘blue line’ outlines look credible, bearing in mind the comparative heights of the Nave roof and the proposed east block, 29.1m and 31.8m respectively. A true cross-section from the proposed scheme to the river bank in the S-E corner of the Embankment would resolve doubts about this assessment. Should our fears be realised then the east block at eleven storeys would be over intrusive in this iconic view of the Cathedral.

10.

Town Bridge Views. A similar point has to be made regarding the sequential views on the Town Bridge approach which have been enabled by the alignment of the Hilton hotel development on Fletton Quays. Here the taller west block at 39.8m can be seen rubbing shoulders with the West Front where the spires reach 48 7m. Again the ‘blue line’ would seem to be an under-estimate of the true effect. Should we be correct a 12 storey block would be too damaging to this very significant viewpoint. It should also be borne in mind that in the winter the softening/screening effect of the deciduous trees will be lost in both this viewpoint and those from the Embankment.

11.

The building mass and height is beyond all existing developments and approvals in the vicinity of the Cathedral. The sheer bulk adds to the enormity of the proposed building which overwhelms its neighbours. Even Bayard Place and the ABC Cinema are dwarfed by it. The 12 storey wing has a maximum height of 39.8m, compared with 29.1m for the Nave roof. The setting of the Cathedral from a north aspect will be seriously undermined and must be a major factor in the assessment of the application. The council choose to dismiss this concern when deciding to approve the Solstice 8 storey block, which is a veritable pimple compared with this one.

12.

The architects and town planners of the time when Peterborough was designated a New Town were generally not renowned for their regard for the historic environment but here they did realise the importance of the Cathedral and its setting to the future of the city centre. Moreover, they recognised that the 1960’s Hereward Centre and St Mary’s Court were excessively high and challenged the Cathedral’s dominance. Their reaction was expressed in policies to be followed in redevelopment and regeneration proposals. The gist of this can be found in a few paragraphs from the ‘Greater Peterborough City Centre Plan’ of 1971.

• a. 2.7 The Cathedral itself must, of course, remain the visual focus of the whole centre. To this end the maximum height of new buildings will in general be limited to the equivalent of five floors of offices, with further restrictions in some places to preserve particular views of the Cathedral.
• b. 2.8 The distinctive visual quality of the approach to the Cathedral from each point of the compass must be protected and where possible enhanced. ...From the new Market Square and Midgate to the north, the Cathedral will be glimpsed at intervals through the gaps to be left between new office buildings; ...

13.

On page 43, in a caption to a sketch by the civic design consultant, Gordon Cullen, it states:

• a. ...’and the best long and open views of the Cathedral are still from the south-east. They must be preserved by keeping to an absolute minimum further building in the open space.’

14.

All office developments in the area north of the Cathedral have respected the philosophy of the 1971 plan apart from Bayard Place and more recently the approved scheme for the Solstice site, which was approved despite strong objections from amongst others, Historic England.

15.

Since the 1970’s there has been a widespread increase in concern for the protection of what is considered a valuable heritage asset in the built environment. Any proposed development is measured and judged by its impact on and contribution to the urban scene. The proposed development at Northminster does not respect the setting of the Cathedral or the character and scale of its location in a number of respects.

16.

Of particular concern is the sheer bulk of the building. Not only is it higher than any other building in the vicinity and seven storeys higher than the maximum recommended, it extends to 100 metres north to south and 60m east to west. By comparison the adjacent Aragon Court has road frontages of 35, 45 and 60 metres and is 15m high.

17.

The applicants argue that the affect on the setting of the Cathedral and impact on important views of it are minimal by a series of cross-sections, graphical projections on photographs and street scenes. These in some cases demonstrate the very opposite.

• 1. The image used on the ‘Contents’ page of the Design & Access Statement shows how large the proposed building to be in relation to the Cathedral, a building of national heritage standing, and Peterscourt and the County Court building both heritage assets of value.

18.

Cross-sections 4 and 5 again show this relationship as well as how overbearing the proposal would be to the adjoining buildings such as Aragon Court, Northminster House and Monkstone House.

19.

We have produced an additional cross-section showing how the proposed blocks would loom over the Cathedral.

20.

The important view of the Cathedral Tower from Cattle Market Road has been explored at para 3.2.6 and in the D&AS. The deep canyon-like effect is not an attractive one and the illustration shows only six of the twelve storeys proposed. If the full building were shown it would be even less appealing. The street scene here would make Peterscourt look like a dolls’ house.

21.

One the most damaging impact on the setting of the Cathedral will be experienced in Stanley Park. Here the best, if not the only, decent view of the full extent of the east-west axis of the building, thus constituting an impression of its size, when seen from the north can be had from a large part of Stanley Park. Although this view has been compromised by a recent planning approval it remains as a valid consideration in this application process. It has not been covered in the Design&Access Statement but has been addressed in the Townscape & Visual Assessment. On page 28 it states that;

...’Effects towards the northern end of the recreation ground and along Crawthorne Road would be Low scale. Effects would be adverse due to the proximity of the building to the Cathedral in views where it is seen.’

22.

It is obvious that, due to the proximity of the proposal to the park and its scale that it will have major impacts on the setting of the Cathedral, very much to its detriment.

23.

The Heritage Impact Assessment (HIA) also covers this viewpoint and therein is a wireframe depiction of the proposed east block on one viewpoint (Fig 12. page 18). The photograph was taken in summer where trees screen the full impact of the proposed building. The outline of the proposed Solstice building is also shown and it pales into insignificance in the context of the Northminster scheme. In short the overbearing impact of this important view from Stanley Park is well demonstrated in this report, although we dispute the conclusion that the impact is neutral and that ‘the view from Stanley Rec will be unaffected.’

24.

With regard to ‘Cathedral Views’ specifically, there is a missed opportunity presented by the demolition of the multi-storey car park and future clearance of the market site; the presentation of the full east-west profile from fairly close up. This is recognised in the submitted D&AS but is largely only to be available to residents of the internal courtyard flats and customers of the commercial units overlooking Laxton Square. The submitted scheme also ignores a strong pedestrian link running between Brook Street and the Tesco passage to Broadway. This should be retained and used to provide a central walkway through the site to Laxton Square. There would be ample scope to provide glimpsed and full views of the roofline of the Cathedral through an interesting new public space ending in a splendid space focussed on the frontage of Peterscourt.

25.

These comments on the impact of the proposals on the townscape character of the area and the setting of the Cathedral have to be considered in the context of Nation Planning Policy Framework (NPPF) and the adopted Peterborough Local Plan, policies LP16 and LP19.

26.

Local Plan Policy LP16: Design and the Public Realm. The proposal does not pass the tests set out in this policy with regard to respect for the setting of the character and local distinctiveness of the area.

27.

Policy LP19: The Historic Environment. This policy places emphasis on the historic environment and the part it plays in the quality of life experienced by local communities.
‘The City Council will protect, conserve and seek opportunities to enhance Peterborough's rich and diverse heritage assets and their settings. All new development must respect, and enhance or reinforce where appropriate, the local character and distinctiveness of the area in which it would be situated, particularly in areas of high heritage value.’

28.

Particular emphasis would be placed on, amongst others; a presumption against development that would unacceptably detract from important views of Peterborough Cathedral by virtue of its height, location, bulk or design and; the protection of designated and non-designated heritage assets and their settings.

28.

The proposal would contravene this policy in that it would cause unacceptable harm to the setting of; the Cathedral, Peterscourt and the former County Court building.

30.

Policies related to development in the city centre reiterate the thrust of LP19 at; LP47, City Core Area, LP51, Riverside North Policy Area and LP53, City North Policy Area.

31.

The proposal must also be considered under the guidance on such matters from HMG to be found in NPPF. The relevant section is, 16. Conserving and enhancing the historic environment. It includes advice for when considering potential impacts of proposed developments affecting heritage assets;
Para. 202. Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use.

32.

The NPPF requires that harm to a heritage asset must be weighed against any public benefit. It is considered that the impacts upon those assets identified within these comments are significant, though less than substantial, para.202 of the NPPF is relevant. Although the harm is less than substantial the harm is significant and the level of harm to identified heritage assets is not justified and would provide grounds for refusal.

33.

The application includes a surface car park for 50 cars including provision for disabled drivers. This is in accordance with policy LP13, which is designed to discourage the provision of additional car parking in the city centre core area. It is felt that this policy should be set aside here in light of the local context relating to specific needs and level of demand, current provision and recent loss of spaces through the demolition of the multi-storey car park.

34.

The proposed 50 space car park is for residents of the development and their visitors. At an occupancy rate of say 2 persons per apartment that equates to 670 persons, the vast majority of whom will be adults. It is not credible that 50 spaces will be enough and it must be assumed that tens if not a few hundred would be seeking a space to park a car not too far distant. All the nearby residential conversions of offices to flats and the approved scheme at the Solstice include a generous provision of on-site parking. The nearest public car parks to the site are at Brook Street and New Road which together have 285 spaces. In a recent survey of occupancy the average number unoccupied was found to be 4. There were large numbers of available spaces in other city centre car parks but these were all south of the Cathedral precincts and too far from the application site to be considered suitable for residents of the scheme.

35.

There is local demand for spaces in the Northminster area from office, retail, food/drink outlets and entertainment workers and customers as well as from that generated by the customers and stall-holders of the market. One particular local establishment will find life difficult should this application be implemented as submitted, namely, the New Theatre. The loss of 750 spaces at the multi-storey car park in March 2020 was bad news for the theatre but the Pandemic restrictions have meant that its impact has not yet materialised. The installation of a surface car park for 100 cars for a temporary period, on the site will be of benefit, although many more spaces for a ‘full-house performance’ may be required. Brook Street car park is available in the evenings and is hardly adequate. The lack of any proposal to increase parking in the Northminster area will create difficulties for audiences at the New Theatre which will be further exacerbated by the proposed provision of 335 residential units with only 50 car parking spaces. The loss of the multi-storey means that there is so much less public car parking available for all city centre needs. Therefore, the application is premature in the absence of review and proposals for compensatory public parking in the Northminster area.

36.

The applicants should be required to supply evidence that the intended occupants of the apartments are not likely to be car owners and not likely to need to park in the locality. There are sufficient residential properties nearby, such as Touthill and Hereward Cross, to enable information to be collected.

37.

The proposed development would result in an increase in demand for car parking spaces not satisfied by on-site provision shown in the application. On-site provision should be adequate to accommodate predictable need. This reason would provide grounds for refusal.

38.

The site area stated in the application form is 1.1hectares (2.7acres) which includes that part of Laxton Square adjoining the market. The proposed 335 residential units give a density of 304 residential units to the hectare or 124 per acre, which is about twice the density of the four residential blocks on Fletton Quays.

39.

This is patently, considerably higher than experienced elsewhere in the city. The Northminster area already has significant numbers of small dwellings in converted office buildings, with more to come at Midgate House and possibly, Northminster House and Aragon Court. The concentration of such a large number of small dwellings in apartment form in one area is not generally thought to be desirable as it does not make for mixed communities. However there is nothing specified in the adopted Local Plan regarding density limits. However the relevant Local Plan policy LP47 states;
Northminster Opportunity Area
Development proposals within the Northminster Opportunity Area (LP47.5) should deliver a range of uses that provide high quality office development, approximately 150 dwellings and possibly student accommodation. Development in this area should protect and enhance any historic assets, including in particular the Cathedral Precincts and Peterscourt.
The council will support proposals to improve the market or, if necessary, work with market traders to identify a new location.

40.

Under this policy sites are identified on the Policies Map as Opportunity Areas for mixed use development which included;
LP47.5. Northminster –indicative number of 150 dwellings, with the note; To be delivered in accordance with a development brief or SPD for the area.

41.

Policy LP47.5 relates to the whole of the Northminster Area which is shown on the map as stretching from Broadway to St John’s St and the Cathedral precincts to Stanley Park. In effect the number of dwellings in the proposed development is more than twice the allocation for the whole of the area.

42.

Over-development on its own may not be sufficient as a reason for refusal, it is more akin to an indicator that a proposal is out of character with its surroundings and locale.

43.

There are a number of minor and some fundamental criticisms of and concerns raised in the supporting documents to this application.

44.

There is a blatant disregard for the public footpath, Market Way, which links the end of Brook Street to Broadway. This is an important route in the integration of the proposal to the locality which has been In existence since 1880’s.

45.

The ‘privatisation’ of Laxton Sq. Is to be regretted. This land was transferred/sold to PIP earlier this year. It is important to the general functioning of the city centre that some public control over an area, which was bequeathed to the City at the demise of the Development Corporation, is retained.

46.

Urban form at Laxton Sq. Is important. The proposal does not achieve a coherent definition at this space. The indicative scheme fails to bring Peterscourt into the space: an opportunity lost as more could be made by uniform treatment of ground/landscape here.

47.

The ‘improved ‘view of the Cathedral from Northminster (Rd) is at the expense of a longer active frontage onto Laxton Square. The benefits of a wider building here should be given further consideration.

48.

The Peterborough Civic Society has grave doubts about this application and registers its objection to the granting of consent for reasons of harm which would be done to vitally important aspects of city centre planning and regeneration.

• a. The Market. The demolition and removal of the City Market is unacceptable in itself and would harm the economic recovery and future vitality of the city centre due to the loss of retail trade.
• b. The Cathedral. The setting of the Cathedral would be seriously harmed by the sheer bulk and height of the proposed blocks and their close proximity to the Cathedral Precincts.
  Important individual views of the Cathedral, particularly those from the south, will be badly compromised by the height of the proposed blocks.
• c. Car Parking. The provision of on-site car parking to serve the development itself is seriously inadequate and will put pressure on local public car parks. This application is premature in the absence of a review of public car parking requirements in the Northminster Area.
• d. Over-development. The proposal also constitutes gross over-development not in line with policies in the Local Plan for the planned redevelopment and regeneration of the Northminster area as a whole.