Hastings & St. Leonards on-line community newspaper
How the proposed extra care home will look - this is the original seven-storey version (Statement of Community Involvement).

How the original seven-storey building would have looked (image from the Statement of Community Involvement).

An application of low standards

Local residents interested in commenting on planning applications which affect them will have become aware as they make their way through the developer’s documents of various common shortcomings – the poor quality of the English, sometimes to the point of incomprehensibility, inaccuracies, inconsistencies and misrepresentations in the project descriptions, and in some cases the absence of important details. Bernard McGinley turns a critical spotlight on the proposed project at 21 Upper Maze Hill in St Leonards and finds plenty to alarm him.

Bad design does not necessarily mean an administratively poor planning application, though the two can often go together. In the case of the application for 21 Upper Maze Hill however (see HS/FA/16/00427), the quality of the application is pitiful: a low-grade, counterproductive effort by the owners and would-be developers, Regal Care Trading Ltd and Penson.

The planning website of Hastings Borough Council (HBC) has many documents from these applicants. They frequently have false assertions and platitudinous, inaccurate, rambling, garbled, misspelt, contradictory and subliterate details. What follows is a selection, with indented, entirely verbatim quotations. (Log dates are in brackets.)

Application Form

Park Beck as it is now, "of little architectural merit", according to the applicant (photo: Bernard McGinley).

Park Beck as it is now, “of little architectural merit”, according to the applicant (photo: Bernard McGinley).

The Application Form (logged 6 June 2016) sets the tone on the supposed need for demolition:

ᐅ  The existing care home and residential building has fallen into disrepair and is of little architectural merit, It is clear that works carried out on the building have been carried out with little attention paid to the aesthetic character of the building. (Part 9)

Of the scores of objections, not one agrees with this.

Heritage Statement

Take a deep breath:

ᐅ   The Church of St John The Evangelist is a Grade II listed building 252.6ft away from the site and this has been taken into consideration in the design of the Extra Care home, care was taken to ensure the design was based on good design practice and incorporated sensitive design features in keeping with good design principles of the listed building and although some of the materials used were different to that of the church care was taken so that the materials were warm and felt comforting to the residents and the neighbours the setting was also considered when designing the scheme and care was taken so that the building did not to impair anyones view of the Church. (Section 3, page 2)

This drivel inspires no confidence in the applicants. Meanwhile the Grade II* church has been pointedly omitted from the SUNLIGHT/DAYLIGHT VSC CUTBACK documents.

ᐅ  The building has been developed over the years and has now has none of its original features, because of this we believe the existing building does not add anything positive to this area which is why we are looking to develop the site and introduce a new building of real architectural value. (Section 4, page 2)

The building is certainly Victorian, as the Victorian Society has confirmed. The rest is insolence.

ᐅ  The depth of foundation will be around 150mm. (Section 10, page 5)

This is less than 6 inches. Modern standards are much deeper.

Design and Access Statement (DAS)

There are two, summer and autumn.

ᐅ  One extract from the later document describes the building’s condition as ‘Medium’.


Circa 1930’s with fragmented modern extensions & adapations.

This contradicts wrong statements elsewhere, such as ‘The home is a large Edwardian building’ (Part 15 of the Application Form), and ‘the existing building is an Edwardian building’ (2.2 ‘Site Context’, DAS p7).

Section 0.4 (‘Design Response’) has this:

ᐅ  As with the existing building the proposed building’s footprint extends across the full width of the site and extends beyond the site to the rear.What is not being said is that the front building line of Upper Maze Hill will be extended by this proposed development. (This is seen in the plans.)

Section 2.3 states:

ᐅ  The site presents a typical suburban street scene of predominant architectural style is circa 1920’s and 1930’s.

Not so. See also above.

Section 4.2 (‘Massing and Street Scene’) has

ᐅ   The scale of the proposed new building is in line with the other buildings on the Upper Maze Hill.

This is clearly false.


The summer and autumn ‘street view’ elevations are radically different, both in massing and in gradient. (The earlier version is in red outline.) Finch Mansions (on the left) is depicted with fewer storeys than it actually has. (The superimposition of images from developer documents is contained in the objection letter from Robert Blizard dated 24 October.)


ᐅ These are unsatisfactory, quite apart from being sideways. The drawing labelled PROPOSED ELEVATION STREETVIEW (17 August) shows just that. The drawing labelled PROPOSED STREETVIEW (19 October) purports to show the same. The differences are preposterous. Massing and gradient are so misrepresented and massaged as to render the scene unrecognisable The later document is a caricature of a sketch, not a serious illustration of Upper Maze Hill. (The drawing is also in Section 4.2 of the DAS, and on p8 of the Statement of Community Involvement). The depiction of Finch Mansions with a missing storey is misleading as well as unprofessional.

Planning Statement

Like the Design and Access Statement, there are two.

Par 4.17 states

ᐅ  The application proposes development at a density of 192 dwellings per hectare (dph), with other high density developments to either side.

What are these high density developments?

Par 4.30 of the Planning Statement is assertive to little purpose.

ᐅ   The proposed building would make an efficient use of land, have a frontage orientation to provide an attractive streetscape and to best take into account the effects of solar gain. The existing building’s deteriorating condition and appearance does not sustain nor enhance the character of the conservation area; however, the proposed development would enhance the character of the Marwick Terrace Conservation Area.

Again, this is not an assessment with which any of the residents who commented on the application agrees.

Par 4.31 is a brazen misrepresentation:

ᐅ  The use of the scale, form, height, mass, and density of the proposed building avoid any adverse impact on the amenity of neighbouring properties.

Objectors have not been fooled — yet again, no-one agrees with this.

Par 6.3 is false in claiming compliance:

ᐅ  It is considered that the proposal would be compliant with the planning policies contained within the development plan and wholly compliant with the aims and aspirations of the NPPF [National Planning Policy Framework].But there is no discussion of pars 128 and 133 of the NPPF, and especially the question of substantial harm. (Par 58 on quality is also ignored.)

Par 6.4 of the Planning Statement is similarly untenable.

Statement of Community Involvement

As is... (photo: Bernard McGinley).

As is… (photo: Bernard McGinley).

On paper it’s feelgood:

ᐅ  We do not feel that there will be a loss of amenity to our neighbours and feel that the design adds to and enhances the properties on Upper Maze Hill . . .


We believe these proposals are very site sensitive and will add, enhance and provide work and accommodation to the people of St Leonards, Hastings.

Not one local resident has supported this application however. might be (image: Proposed Elevations 445-262).

…as might be (image: Proposed Elevations 445-262).

ᐅ  The applicants state that they consulted properties likely to be affected by the development to seek opinion. Caple Gardens, abutting the west of the site, had only No 4 notified — when that property was unoccupied. Therefore none of the residents of Caple Gardens was consulted. Buildings such as 19 and 20 Upper Maze Hill got one letter, though they are clearly multi-occupied.

Schedule of Amendments

On 20 October changes were announced. The number of proposed apartments was changed from 52 to 35. By ’improved visual impact’ the applicants seem to mean ‘less worse’.

HBC Planning Department

The unsatisfactoriness extends to the Council. Does the application meet the criteria for validation? Was accurate resubmission requested?

The administrative faults are many:

ᐅ  Drawings are shown sideways, despite requests for correction. This amounts to an obstruction of many people wanting to be informed about the application.

ᐅ  The labelling of the documents is defective. Three different ones are called SUNLIGHT/ DAYLIGHT VSC CUTBACK. Four are called BUILDING REG REPORT. There are two PROPOSED ELEVATIONS, and three (SUPERCEDED)PROPOSED ELEVATIONS. These duplications – of title or text – are confusing, whether intended or not, and at odds with the Council’s assertions of openness and transparency. A numbering/reference system would help.

The planning department at HBC has a persistently poor reputation, for achievements such as the Bunker (in Hastings Country Park), selling out the Archery Ground (twice), and the dubious abuse of ‘delegated powers’. Its standards provoke concern. Even the Information Commissioner was unimpressed in a recent case (ref FS50619716).


Park Beck deserves better from its owners than the chutzpah to suggest that their neglect is a reason to knock it down. The building also deserves better from HBC, who have a duty to protect the Conservation Area.

The blusterings in these documents are not professional, not persuasive and often not comprehensible. Schoolchildren could produce a better application than this. It is not compatible with the planning policies that apply to this part of St Leonards, and fails to address important ones such as ‘substantial harm’ (see ‘Planning Statement’ above) and Conservation Area status. The spirit of place would be severely damaged if HBC approved this application.

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Posted 21:33 Sunday, Nov 20, 2016 In: Home Ground


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  1. Bea Rogers

    But we must not just give up, expecting the worst (that is a self-fulfilling prophecy). One important element is pressure on the Council as a whole to get qualified professional planners in at all levels of the Planning Dept, and make sure there are enough of them to scrutinise applications. The other element is for the councillors on the Planning Cttee to get some training and support in their proper role, which is making the decisions (not leaving it to the officers, whether through “delegated” powers or by just accepting their recommendations when there is strong public concern). It might help if they allow more time for objectors to make their case to the committee, and ensure a proper debate there rather than accepting a half-baked party line.
    Another issue is the display of plans to the public. Making them available even at just one point (the Information Centre) is really important. The present excuse for consultation based on jumbled and unlabelled online documents is contributing to the confusion and pessimism around public consultation.

    Comment by Bea Rogers — Thursday, Nov 24, 2016 @ 10:47

  2. Zelly Restorick

    As the years pass and the more I discover about life, the more I think that the society we live in is a facade, an illusion.
    One is aware that much is happening behind the scenes, that things ‘aren’t right’, but we seem to not have any power to change them. Will Mr McGinley’s highly researched words have any effect?
    If we see this area of planning as a minute microcosm of what is happening locally, nationally and internationally, what are we left with?
    When any one of us researches a single aspect of life, there are so many different contradictory ideas, the head spins and we have no idea what to believe and which way to turn.
    We are however all a part of this – and cannot step outside and say: nothing to do with me. Maybe humanity’s current state of existence reflects who we are as humans?
    Corruption, spin doctoring, marketing, advertising, false assertions, bureaucracy, jargon, propaganda flow throughout every sphere of our lives; they’re not the monopoly of local and national government departments.
    If one bends the truth as an individual, maybe this is echoed all the way up and all the way down the chain of human existence?
    Is each one of us caring, compassionate, loving, altruistic’, reasonable, fair, honest, rational, generous and magnificent in every aspect of our lives? Me thinks not.
    Maybe, underneath all the rhetoric, most people are just trying to keep their own head – and that of those they care about – above the water, supporting certain issues and interests that are close to their hearts.
    One man’s win is another’s loss. One man’s dilapidated building is another’s historic landmark. One man’s financial crash is another’s boon.
    We may see ourselves as highly evolved citizens of an advanced civilisation, but are we? Really?
    Surely we are still an embryonic race that has much much much to learn.

    Comment by Zelly Restorick — Wednesday, Nov 23, 2016 @ 16:15

  3. Graham

    I agree they are hopeless. I have spotted errors in every application I have had the misfortune to read. One had over 150 errors and still got through. Even worse once developers get their permission they do what they like and building control do nothing to stop them. Despite numerous complaints to HBC and the local government Ombudsman they do nothing to put things right. They are a complete disgrace.

    Comment by Graham — Tuesday, Nov 22, 2016 @ 23:16

  4. Ms. doubtfire

    Excellent article.
    Objectors ‘have not been fooled’ – but hey lads hey – the Planning Committee WILL be seriously fooled…they will not make head nor tail of any of this and thus this lovely old building will fall.
    Shocking, shameful and sinful.
    Enough is enough – this council needs to take a close look at the quality of its planning department. As Mr. McGinley correctly states, its standards provoke concern – they do indeed.

    Comment by Ms. doubtfire — Monday, Nov 21, 2016 @ 11:58

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