BY EMAIL to
[email protected] COPY BY POST
John Davies Planning Service Birmingham City Council PO Box 28 Alpha Tower Suffolk Street Queensway Birmingham B1 1TU 1 August 2009 Dear Mr Davies Objection to Planning Application number C/02504/09/FUL relating to 94-101 Cheapside, Digbeth, Birmingham, B12 0PU I strongly object to the above proposed change of use from residential (Use Class C3) to hostel (Use Class Sui Generis) on the following grounds: 1. Loss of privacy and intrusion to local community Like other residents in the Digbeth Rea Village area, I have made the Irish Quarter/Rea Village area my home on the understanding that the balance of residential and commercial buildings would make it a unique city village for permanent residents. The proposed change of use is incompatible with the unique character of the local area and there is neither available nor planned additional infrastructure to support the change of use to a hostel (such as specific services (e.g. tourist information) and other general public services (e.g. transport, policing and environmental health)). Therefore the proposed change of use is contrary to policy 3.7A of the Birmingham Unitary Development Plan (Adopted 2005), which is concerned with improving quality across the city and states that “A key element in achieving this will be to take advantage of the opportunities provided by proposals for…redevelopment to create high quality new environments and improve what already exists” and policy 3.14D which is concerned with provision of a safe and pleasant living environment. The proposed change of use would mean that the site will become temporary accommodation to a large number of low-budget transient visitors who make little or no positive (financial or other) contribution whatsoever to the area or the city. Further, use as a hostel would be incompatible with future plans to enhance the
1
Digbeth area for use as social and higher-end residential accommodation and higherend retail leisure facilities for the local community, for example, that highlighted under the Birmingham Big City Plan (see http://consult.birmingham.gov.uk/portal/ps/birmingham_big_city_plan/bcpwip?pointI d=685#section-685). The proposed hostel use is uncharacteristic and over-intensive use of the site, providing cramped and inadequate living accommodation. The proposal would require the significant adaptation of family-sized dwellings of apparently sound, brand-new condition luxury apartments. The development would harm local character and local residents' amenity. The proposal would therefore be contrary to Policies 3.1, 3.2, 3.8, 3.10, 3.14-3.14D, 5.19A, 5.20, 5.28. 5.38 of the Birmingham Unitary Development Plan (2005), Places for Living (2001) and the 45 Degree Code which have both been adopted as Supplementary Planning Guidance, Planning Policy Statement 1 (PPS1) and Planning Policy Statement 3 (PPS3). Furthermore, hostel use would result in an inappropriate and piecemeal development, which would compromise the comprehensive and appropriate development of the wider Digbeth area and would therefore fail to make the most effective or efficient use of previously developed land contrary to policies 3.8 and 3.10 of the Birmingham Unitary Development Plan (2005), PPS1 and PPS3. The development by virtue of its layout would fail to provide a satisfactory, safe and attractive environment for future users of the site and would be contrary to policies 3.8, 3.10, 3.14. 3.14A-D of the Birmingham Unitary Development Plan (2005), "Places for Living" (2001) and PPS1. In particular, hostel use is incompatible with the local character of the community as an urban village community and only serves to weaken rather than reinforce that character under policy 3.14D. The proposal conflicts with numerical standards contained within 'Places for Living', adopted by the Birmingham City Council as Supplementary Planning Guidance that seeks to protect both existing and future occupiers' amenity. In addition to the usual residential developments in the local area, there are at least two elderly residential schemes directly next to the site, namely, Father Joe Taaffe House and Cherish House. The proposed use for young transient occupants and any (perceived or actual) problems (such as increase in crime and pollution) associated with the occupancy of the site as a hostel is incompatible with policies 3.14D and 3.16 of the Birmingham Unitary Development Plan (2005). 2. Visual amenity, layout and density of the building
2
The existing building is designed and constructed as 28 (one and two bedroom) luxury apartments, which is consistent with other residential developments in the immediate vicinity both in terms of visual appearance and use. If the site is to be used as a hostel, it is inevitable that the frontage of the building would need to be adapted or changed. For example, because the existing frontage was constructed as a residential block with a showroom-style glass-fronted retail space on the ground floor, it is likely that visually unattractive bold external signage will be needed to advertise the location of the hostel business in an area otherwise comprising of predominately private residential blocks and small businesses. It is also likely that part of the existing glass frontage will be boarded-up (as is the case for the applicant’s other Journeys Group Hostels). There may also be other changes to the currently visually neutral frontage given that the ground floor of the building is to be converted to be used for retail, kitchen and bedroom use. Indeed, it would appear that the applicant’s other hostels are indicative of a propensity towards garish colour schemes, boarded-up frontages and bold signage, which is not in keeping with the existing low-key residential environs (see attached photographs of other Journeys Hostel signs and boarded-up frontages). Therefore the proposed change of use is discordant and incongruous to the property and the surrounding street scene and detrimental to the visual amenities of the area contrary to policies 3.1, 3.8, 3.10 and 3.14D of the Birmingham Unitary Development Plan (2005). By reasons of scale, mass and external design, the intensive use of the proposed hostel detracts from the architectural appearance of the property and would adversely affect the visual amenity and character of the surrounding area. The proposed development would therefore conflict with 'Places For Living' Supplementary Planning Guidance, and is also contrary to paragraphs 3.8, 3.10, 3.14A, 3.14C, 3.14D, 3.17, 5.38 and 5.20 of the Birmingham Unitary Development Plan (2005). It would not provide adequate living conditions for prospective occupiers, and it would prejudice the proper planning of the area. As such, the development also conflicts with the policies 3.13, 3.14, 3.16A of the Birmingham Unitary Development Plan (2005) and with the provisions of the adopted Supplementary Planning Guidance, Places for Living, and PPS1 and PPS3. The proposal does not anticipate provision of any smoking shelter. Whether one is to be provided later or no provision at all, resulting in hostel occupants smoking in the streets, by reason of its siting, design and scale, this would be detrimental to appearance and setting and the visual amenity of the local area. This development would therefore be contrary to policies 3.8, 3.10 and 3.26 of the Birmingham Unitary Development Plan (2005). 3. Inadequacy of parking, traffic generation and endangerment to highway safety 3
The proposed change of use to a hostel will increase disproportionately both pedestrian and vehicular traffic to the local area, without consideration of the needs of pedestrians and local traffic. This is contrary to policies 3.13 and 6.39 of the Birmingham Unitary Development Plan (2005). If the building were to be used for the currently permitted Class C3 use, the number of residents (in the 28 one and two bedroom apartments) will be significantly lower than the proposed 256 hostel occupants. This is an excessive and unacceptable increase to the occupancy of the building given the inadequacy of available parking facilities, the increased traffic generation and the endangerment to highway safety. While the existing use of the building includes 12 parking spaces, the proposed hostel use of the building reduces the number of parking spaces to zero. This is extremely nonsensical. Even, in the unlikely event that all hostel users use public transport (as opposed to private vehicles) to arrive at the site, it is certain that both suppliers and the twelve full-time staff will require both vehicular access and parking. There is already an acute shortage of parking in the local area and a disproportionate increase in the number of vehicles and traffic will undoubtedly add to that problem. Furthermore, an increase to the problems of illegal parking (in terms of double parking) and trespass (parking on private land) are highly likely. There is only one car park in the immediate vicinity which is owned and operated by the Paragon Hotel for use by its guests. The on-street parking in the local area is already heavily used both by local residents and commuters working in the city centre. This means that there is scant additional car parking capacity available for hostel occupants, staff or suppliers, and not only are there no proposals for additional car parking, but the applicant intends to reduce the number of existing car park spaces by twelve to nil. The immediate vicinity of the site is an accident black spot. There have been numerous and frequent traffic accidents on Alcester Street and at the crossroad junction between that street and Cheapside, which is a junction with extremely poor visibility (hence the “stop” signs at the junction on Alcester Street). The increase in traffic volume resulting from the high-density occupation of a hostel is likely to add that problem. The applicant has not demonstrated that it has considered the issues of parking and traffic generation, let alone how it would alleviate those issues. This is contrary to policy 3.1 Birmingham Unitary Development Plan (2005), the provision of a safe environment for local residents. 4. Noise and disturbance resulting from hostel use There are already existing issues with criminal activity, noise pollution, and street littering in the local area. For example, there are problems with noise pollution from the local entertainment venues such as the Sapphire Banqueting Suites, the Rainbow Public House. The high incidence of theft and burglaries in the area are recognised in the crime figures and by the local police liaison officers.
4
High-density occupation in a hostel by transient low-budget travellers is very likely to add to some if not all of those existing problems and increase the already strained policing and litter control resources. Noise pollution is a particular concern as late night noise from tourists will undoubtedly generate problems for the local residents. A large number of tourists coming to an area with a high density of licensed premises may also to contribute to that problem, as well as to the problem of drunk and disorderly conduct and the possibility of fire alarms being triggered in the building. Café and retail use of ground floor, irrespective of whether late night opening occurs, will result in noise, disturbance, smell and litter. Such use should generally be confined to shopping areas or areas of mixed commercial development, which is not the case here. Therefore, the proposal is incompatible with policy 8.7 of the Birmingham Unitary Development Plan (2005). The increased pollution and detriment of the amenity of the occupiers of dwellings in the vicinity is contrary to policies 3.1, 3.8, 3.10, 3.14E and 8.7 of the Birmingham Unitary Development Plan (2005). The lack of provision of increased noise insulation for the high-density occupation means that the proposed change of use is contrary to policy 3.14E of the Birmingham Unitary Development Plan (2005). In addition, the proposals do include additional facilities to cope with storage of the high volume of refuse from a hostel business, contrary to policy 3.12 of the Birmingham Unitary Development Plan (2005). Unsightly litter and smells are likely to attract rodents and to cause visual offence to local residents. 5. Unfounded grounds for the application The applicant does not provide evidence of “the lack of short stay overnight “touristtype” accommodation in Birmingham” or of any unmet demand in that type of accommodation that it states in support of its planning proposal. That lack of supporting evidence is contrary to policy 3.14D of the Birmingham Unitary Development Plan (2005) that the proposed use addresses a local identified need. Indeed, there are already more than adequate existing hotel and hostel facilities as well as planned hotel and hostel facilities approved by Birmingham City Council, both in the immediate vicinity and within a one mile radius or less of the site. These include (to name but a few only): 1. The Paragon Hotel, 145 Alcester Street, Birmingham, B12 0PJ; 2. St. Anne’s Hostel, 112 Moseley St, Birmingham, B12 0RY; 3. Birmingham Central Backpackers Hostel, 58 Coventry Street, Digbeth, Birmingham, B5 5NH; 4. The Old Crown, 188 High Street, Deritend, Birmingham, West Midlands B12 0LD; 5. St Paul's House Hostel, 444 Moseley Road, Birmingham B12 9AN; 5
6. The Connaught Square development (planning approval was given by Birmingham City Council in 2007 for construction next to Digbeth Coach Station fronting High Street Deritend) which will include a 180-bed hotel incorporating 36 serviced apartments; 7. Hotel Ibis Birmingham on Bordesley Circus, 1 Bordesley Park Road, Bordesley, Birmingham B10 0PD; 8. Formule 1 Birmingham Bordesley Circus Hotel, 3 Bordesley Park Road, Small Heath Highway, Birmingham B10 0PD; 9. Allison House Backpackers Hostel, Allison St, Birmingham West Midlands B5 5TH; 10. Arc Apartments, The Arcadian Centre, Hurst St, Birmingham B5 4TD; 11. Kensington Hotel, 785 Pershore Road, Birmingham, B29 7LR; 12. Rotunda Serviced Apartments, 150 New Street, Birmingham B2 4PA; 13. Stay Birmingham Apartments, Southside, Apartment 278, St. John's Walk, Birmingham B5 4TL; 14. Premier Apartments Birmingham, Dean House, 38 Upper Dean Street, Birmingham B5 4SG; 15. Hotel Ibis Birmingham City Centre, on Ladywell Walk, Birmingham B5 4ST; 16. Radisson SAS Hotel Birmingham, 12 Holloway Circus, Queensway, Birmingham B1 1BT; 17. Ramada Encore Birmingham City Centre, Ernest Street / Holloway Head, Birmingham, B1 1NS; 18. Comfort Inn Birmingham, Station Street, Birmingham, B5 4DY; 19. Holiday Inn Birmingham City Centre, Smallbrook Queensway, Birmingham B5 4EW; 20. Nitenite Hotel Birmingham,18 Holliday Street, Birmingham B1 1TB; 21. Britannia Hotel Birmingham, New Street, Birmingham, B2 4RX; 22. Etap Hotel Birmingham Centre, 1 Great Colmore Street Birmingham, B15 2AP; 23. Hatters Hostel Birmingham, 92-95 Livery Street, Birmingham, B3 1RJ; and 24. Focus Foyer Hostel, William Booth Lane, Birmingham B4. I trust my objections will be put before the Planning Committee in due course prior to a decision being made on this application. I should be grateful if you would kindly keep me informed of the progress of the planning application. Many thanks. Yours sincerely
6
7