The Hastings Country Park Visitor Centre as is.
A room with a view to lowering standards
Severe modifications are being proposed to the unbuilt visitor centre in Hastings Country Park. Will the new design benefit the Country Park? Bernard McGinley takes a wild guess, and finds the application still wanting.
When a new visitor centre for the Fairlight end of the Country Park was discussed by the Hastings Borough Council (HBC) planning committee, one councillor looked forward to the prospect of a drink on the terrasse. The application was approved in March 2015. But the councillor won’t now have that sundowner, because the terrasse has been abandoned. Costs have escalated and there are “budgetary constraints”.
Instead a new building is proposed, under a new application. The planning reference is HS/FA/17/01018, confusingly described merely as a ‘variation of condition 13 (approved drawings)’ of the previous application, HS/FA/14/01033.
The substantial changes include loss of the roof garden, reduction in height, reduction in window sizes and changes to cladding. These significantly change the appearance of the building, for the worse.
Other changes in the proposals include a doubling of the forecourt width, from 4.2 metres to 8.4 metres, and metal rollers for the shutters instead of sliding timber — quite an inner-city vibe.
A bike store design is now included, which is to be on the other side of Lower Coastguard Lane, near the Grey Owl memorial with its ironic finale about ‘the protection of the wilderness’. But as this was not part of the original site, the present application cannot be considered as a variation to the previous one. (HBC’s overcasual use of the ‘minor variations’ route was supposed to have ended around 2014.)
Additionally, this bike store site across Lower Coastguard Lane is entirely in Fairlight, not Hastings – so this application becomes a planning matter for Rother District Council.
The applicant is HBC itself. Being HBC they describe this application as ‘some minor changes to appearance and structure’. However the ‘FA’ in the reference stands for ‘Full Application’. Hence it is unclear whether the new application is being treated as a variation to plans or as a fresh and full application. The argument for treatment as a full application is clear, for it to be considered on its merits given the many changes. This would also include a requirement to reconsult the original consultees.
That was then
The rationale for the visitor centre was discussed and endorsed by the Council at its Cabinet meeting of 6 October 2014, item 34: ‘The new facility was intended to provide an improved visitor experience…’
The Council was to work in partnership with Groundwork South to seek grant aid to ‘deliver’ the visitor centre. (The remarkable award of a Green Flag to Hastings Country Park in 2016, and again in 2017, may have helped.)
Front view of new visitor centre as originally conceived (image from case documents, South and West Elevation).
The 2015 visitor centre elevations can be seen here and here.
The first application attracted scores of objections, many lengthy. Objectors included Fairlight Parish Council, who complained in detail about the proposal., pointing out that it lacked
sufficient architectural merit for its very sensitive site. It is also placed too far forward, too near houses and is too large. Hastings Country Park is not a large area and cannot readily absorb a Visitor Centre of this scale without detracting from the landscape value.
The Fairlight Preservation Trust and the Friends of Hastings Country Park also objected, as well as many residents of Hastings and Fairlight.
Factors such as the Area of Outstanding Natural Beauty (AONB) were cited, and that the proposal adversely affected the Strategic Gap between Hastings and Fairlight, the gap being a stated concern of Rother District Council.
The Revised Design and Access Statement (DAS) drew concern for its lack of a light pollution assessment and noise impact assessment, and for newsworthy statements such as:
The proposal will not result in a loss of open space [p18]
and:
The Borough Council will continue to encourage the maximum use of these facilities and will be generally supportive of planning applications for additional community facilities.
However, the principle of a new visitor centre was broadly accepted — but not this particular proposal, ten times the size of its predecessor, and with the detail in the Revised DAS about it being a venue for ‘weddings and parties’, a purpose at odds with the peaceful enjoyment of the exceptional countryside where the High Weald meets the sea.
This is now
The new application does not provide a new DAS, and consists largely of revised drawings.
The new visitors centre, following ‘minor’ variations (image from case documents, Proposed South & West Elevation).
The 2018 elevations can be seen here and here.
The new application is still open for comments, with a deadline of 2 February.
The current permission (for the old design) expires on 6 March 2018. There was comment in HOT at the time of the decision and after. The ‘weddings and parties’ detail led to the inference that the visitor centre was to be a function-suite-by-stealth.
Without the possibility of drinks on the terrasse, a common view is that the extensive redesign of the visitor centre has given it a portakabin feel.
There’s an additional planning application, HS/CD/17/01101 for the discharge of conditions for the original application. (That planning permission expires on 6 March 2018.) However, in matters such as sewerage, surface water, drainage details, hard landscaping, and materials, the relevant information has not been provided. How can the conditions be discharged when the relevant documents have not been submitted? As seems to frequently happen here, sloppy procedure by the applicant is indulged by the administrator’s validation process.
Decision pending
The previous design was far from striking or subtle. But it had an upstairs gallery, and pillars for a colonnade of sorts. Instead, the revised version looks like an apology for something much better that does not exist. A sensitive site deserves and should expect something better — but this is Hastings, as the old saying goes.
Keeping the grass in order – the Country Park belties.
What and when the planning committee will decide remains at present unknowable. Chapter 11 of the government’s National Planning Policy Framework (NPPF) is full of principles about conserving and enhancing the natural environment (paragraphs 115, 123 and 125 for instance). So too is the Local Plan, with policies such as EN7 on protecting and enhancing the landscape, notably the High Weald AONB, DM1 on Design Principles and HN9 on Areas of Landscape Value. Unless these policies are bromides, there are grounds to reconsider and to make an improvement. Precedent does not suggest that outcome however.
Concerns remain that the Country Park is under threat, despite the good work of its volunteers. Many people (this contributor included) supposed that Hastings County Park was a public asset, held in trust, thanks to Major Sayer and many others. (The Hastings Chronicle says much more.) But if Little Warren Cottage can be sold off, as it was in 2014, with little publicity, and then expanded, how much of the rest of the Country Park is safe?
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13 Comments
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Natural England raised an objection to the original septic tank proposal saying that “such discharge may have a negative impact on the nearby SSSI/SAC, in particular, by damage to bryophytes, which are a notified feature of the SSSI”. The septic tank was removed from the proposal but has been reintroduced and Natural England has not been consulted about this change.
The Environment Agency classifies the area as a Groundwater High Vulnerability Zone so is highly vulnerable to pollutants discharged at ground level by a septic tank.
Comment by Russell Hall — Thursday, Feb 22, 2018 @ 08:08
HBC are currently planning to reintroduce a septic tank for the building. A septic tank was originally considered for the building but was opposed by Natural England and the Environment Agency. The foul water was then changed to be discharged to the sewer network.
The latest application for the building does not explicitly mention a septic tank anywhere. However a recent application to discharge planning conditions included plans for a septic tank. Natural England and other consultees have not been reconsulted. I fear that HBC are attempting to reintroduce the septic tank without following proper process and without consulting consultees. Waste water from the septic tank will be drained into the area around the visitor centre. This area is a Site of Special Scientific Interest.
The ONLY references to the septic tank were provided in the discharge application HS/CD/17/01101. This application discharged condition 4 on drainage using a new plan that was not approved in the original permission nor approved by a minor amendment. A discharge application cannot grant permission for changes to the approved plans. The new plans for a septic tank must be approved by use of a minor amendment. Fundamental changes to drainage have been made by the back door misusing proper planning procedure.
The discharge application has sought by sleight of hand to reintroduce the septic tank. No consultation with consultees took place. Not only is this in conflict with the recommendations of Natural England and other consultees but a discharge application cannot introduce new plans that contradict the approved plans and then approve them. Condition 4 on drainage has not been legally discharged as the septic tank requires approval either by a minor amendment or a full planning application.
The Non Material Amendment to vary condition 4 is also an abuse of process. It removes all references to foul drainage despite the fact that the original application was amended to include connected foul drainage. As such this is a material amendment, conflicts with the original condition and also changes conditions imposed because of consultee objections to the original application.
It is now clear that the minor amendment, discharge and NMA all seek to revert back to using a septic tank by sleight of hand and misuse of process. This is against the express objections of consultees during the original application.
Natural England objected in the original application to the use of a septic tank in the strongest of terms:
Foul Sewage – Details of the equipment to be used and of the intended location. The septic tank referred to application documents would normally discharge to a shallow drainage field and would, therefore, required assessment as to whether an Environmental Permit would be required from the Environment Agency. Any such discharge may also have a negative impact on the nearby SSSI/SAC, in particular, by damage to bryophytes, which are a notified feature of the SSSI.
The reversion to use of a septic tank conflicts with the original planning permission and the objections received from consultees such as Natural England. At no point has approval been sought from consultees for the reintroduction of the septic tank. Natural England have not been reconsulted and a permit has not been sought from the Environment Agency.
The three recent applications for the visitor centre are an absolute shambles. There has been serious misuse of procedure and a failure to consult key consultees. It is time to recognize that such a confusing process is unacceptable and to introduce a new fresh and full application where all issues can be investigated in an open and transparent manner with full consultation.
To continue with the current process risks bringing the already jaded reputation of our planning department into disrepute.
The planning department should be setting an example of proper planning procedure and not relying on three contradictory and invalid applications to rush through changes to the visitor centre. There has been serious abuse of process and this will no doubt set precedents for developers to abuse in the future.
Should the current procedure continue there is a risk that the permission for the visitor centre will be illegal and that the decision could be challenged at judicial review.
Comment by Christopher Hurrell — Tuesday, Feb 20, 2018 @ 18:16
The Friends of the Country Park who have campaigned many years for a new visitor centre have serious concerns about this application
The Friends state:
“I write as Chairman of the Friends of Hastings Country Park Nature Reserve. Our committee discussed this application at a recent meeting and we have serious concerns. The changes of design and materials proposed represent a significant downgrade in terms of quality and aesthetics. Metal shutters will give the building a particularly grim aspect in what is a highly sensitive location. It is in everyone’s interest, we believe, that any new visitor centre at the Country Park is built to the specification that the location deserves, and that the process of decision making is transparent. Changes of this magnitude need proper scrutiny from public and planners alike, and the rationale behind them should be explained in full.”
They believe the decision making process should be transparent and have proper scrutiny. I believe that the only way to do this is for the application to be reconsidered as a fresh and full application and not in the current confusing manner as a minor amendment..
Comment by Chris Hurrell — Tuesday, Feb 13, 2018 @ 18:42
My comment on this article should have made it clear that I was referring to another ‘amendment/modification’ proposed for this visitor’s centre which was lodged under application: HS/NM/18/00059 – this refers to what the planning department refer to as a non material modification. There is no way this application could be described as a non material modification. Furthermore the applicatin form wrongly states that Murray Davidson is not an employee of Hastings council and he was not consulted over this application.
If readers wish to see this further attempt to rush things through it would be useful to look at this application under HS/NM/18/00059 where objections highlight what is so wrong.
Comment by Ms.Doubtfire — Tuesday, Feb 13, 2018 @ 12:05
The council have agreed this application under the infamous Delegated Powers system. As Chris Hurell points out the incorrect section of the planning act has been implemented in the presentation of this application. This application should have been submitted as a full new application because there is no way it could be classified as a Non Material Minor Modification. Goal posts appear to have been shifted here.
An issue which remains of great concern is the application form itself. This document declares that the applicant is Mr. Murray Davidson and further declares that he is NOT a council employee. This is an incorrect statement because Mr. Davidson remains in the employ of the council.
One has to wonder whether it is really worthwhile raising these issues or objecting because it does appear that whatever this council wants, this council will get.
Comment by Ms.Doubtfire — Saturday, Feb 10, 2018 @ 09:18
The High Weald AONB consider that this application would be better served if done as a fresh and full application rather than as a minor variation. They have commented in their role as consultees as follows:
“Whilst this application is advertised as being a variation of a condition, it is clearly a significant change in the design and specification of the proposed Visitor Centre.
It is for Hastings Borough Council to satisfy itself that this type of application is legally appropriate for the changes proposed.
However, I am concerned that one practical implication of the process chosen is that there is no documentation with the application which explains the proposed changes or their rationale.
If dealt with as a fresh full planning application it would have been accompanied by a Design and Access Statement, Planning Statement and Landscape Assessment which would have set out the justification for the proposed design and how this conserves and enhances the High Weald AONB.
In the absence of such information it is difficult to see how Hastings Borough Council can meet its responsibilities in respect of AONBs.
Section 85 of the Countryside and Rights of Way Act 2000 requires local authorities to have regard to ‘the purpose of conserving and enhancing the natural beauty of AONBs’ in making decisions that affect the designated area.
The National Planning Policy Framework paragraph 115 requires great weight to be given to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty. The conservation of wildlife and cultural heritage are important considerations in all these areas”
Comment by chris hurrell — Friday, Feb 9, 2018 @ 12:19
If you have comments please post them on the Hastings Council website under the planning application. They will not be considered otherwise.
Comment by andrew mier — Monday, Jan 22, 2018 @ 08:46
If this is to go to the planning committee for a decision and not as a delegated decision, there need to be some more objections as at the moment there are only four and at least five are required under HBC’s new rules to enable this application to be heard by the planning committee.
Comment by Ms.Doubtfire — Friday, Jan 12, 2018 @ 12:48
There is no way in legal planning terms this application can be described as ‘minor modifications’. This is the old chestnut used so frequently by our planners in this town to get round legislation and the requirement to present a new planning application. Minor modifications suggest a ‘tweaking’ of original plans….this is not the case here. This new design is completely different to the original plans.
Why oh why do our elected councillors close their eyes to what is going on within our planning department? What is happening in this town?
The Local Elections are coming up in May – may I suggest residents put their mark where it means something? At the present time our so called elected members appear to have little say on anything that is proposed for Hastings & St. Leonards. We didn’t vote them in for this did we??
Comment by Ms.Doubtfire — Friday, Jan 12, 2018 @ 10:36
The Coastguard Cafe is up for sale. If the council want to have more facilities available for visitors they can buy or lease the cafe and develop it without encroaching on precious HCP.
Once again it seems that Hastings Borough Council are not in tune with the wishes of its residents. I will be looking forward to discussions on a whole range of planning topics during the run up to the forthcoming council elections.
Comment by Eye on the ball — Thursday, Jan 11, 2018 @ 16:22
Does the revised DAS really say ‘The proposal will not result in a loss of open space’? Yes it does, and a few pages later (page 29) it is confirmed that the proposed building is ‘located with an arable field’.
Why is the applicant telling porkies?
Why is the local planning authority accepting them?
This building is NOT GOOD ENOUGH FOR HASTINGS.
Comment by Andy Ammo — Thursday, Jan 11, 2018 @ 14:14
This ‘Portakabin’ has no architectural merit whatsoever, it will be a blot on the beautiful landscape.
It seems to me that meals and refreshments are adequately provided for by the Coastguard Café and the inclusion of the ‘café’ within the centre will damage their business.
Countryside Act 1968 Section 7 – ‘Provided that a local authority shall not under this section provide accommodation, meals or refreshments except in so far as it appears to them that the facilities therefor within the country park are inadequate or unsatisfactory, either generally or as respects any description of accommodation, meals or refreshments, as the case may be.’
It seems to me that the facilities just 150 metres away are adequate generally.
Comment by John B — Thursday, Jan 11, 2018 @ 12:11
The proposed changes have transformed what was a poorly designed inappropriate building into something resembling an oversized portakabin toilet.
The building continues the tradition established by the infamous Rocklands bunker in Ecclesbourne Glen.
Is this the best we can expect for such a sensitive location?
Comment by Chris Hurrell — Thursday, Jan 11, 2018 @ 11:32