To: NNDC Development Committee
PF/16/1251 | Change of use of former tennis court/play area to public car park and toilet facilities
The Friends of North Lodge Park, by nature of our constitution to improve the Park, have a special interest in this application, and want to do all we can, if there is to be a car park created in the Park, to make sure it is an appropriate development.
While, ideally, we would rather not have a car park we understand the financial pressures at NNDC and would accept a car-park if was of a sufficiently high quality and benefited the Park as a whole. However, the plans as submitted do not ensure sufficient quality and will not benefit the Park. There is also a real risk that these designs will lead to the creation of a car park that is inappropriate, dangerous to users, particularly children, and unsuitable for the disabled.
During the 3 months of the planning process we have tried to engage with NNDC, have been willing to discuss and compromise, but have been left frustrated by the lack of space in the planning process for dialogue; there has been little acknowledgement at NNDC that any of the points we have made have any merit to them and so we had to object to the application.
We are writing to you directly because it has not been possible to get a response to our specific concerns and we have no other means of ensuring these points are considered during the planning determination.
It remains our strong belief, that these are questions that should be resolved before the plans are passed, to confirm there is evidence for a public interest justification and to improve the design of the car park and toilet facilities.
1. Is the design for the car park as proposed optimal, appropriate and safe?
The development of a part of North Lodge Park for non-recreational use is a major change. If the council is minded to make such a change we believe that the development should be the best for the space, appropriate and safe.
- One key justification for the car park is to improve the economic wellbeing of the east end of Cromer, yet there is no pedestrian access to Overstrand Road to facilitate this. To achieve this objective we would expect to see a pedestrian exit at the Overstrand Road end of the drive for pedestrians.
- We are pleased that priority has been given to blue badge holders, with a higher number of spaces than standard, yet the proposed (shingle based Bodpave) car park surface is not optimal for wheelchair users. We would expect pedestrian walkways to be a surface optimised for wheelchairs.
- We are pleased that the proposed toilet facilities include a fully accessible ‘changing places’ facility. The design of the slope for the ramp to the new toilet facilities doesn’t seem to meet national standards (the incline appears too steep, but without any measurements on the plans it is difficult to be certain). We would like to see the measurements to confirm this ramp does conform to national standards.
- The building being converted into the toilet facilities, built as a bandstand in the 1950s, is a key feature of the heritage of the Park. We would expect the finishing of the conversion to be higher quality than suggested in the proposal.
- A strict one-way system will operate in the car park, but it is suggested that no signs will be installed other that inserts into the surface, which are not prominent on the shingle based Bodpave surface. We would like to see alternative proposals for visual aids to guide drivers around the proposed one way system in the car park, especially at the entrance.
- A car park for the Park and beach will be used by families, with park/beach paraphernalia, yet the spaces are packed in with no waiting space nor pedestrian walkways (NNDC recommend pedestrian areas in new car parks, and parking spaces larger than those proposed). We would like to see safety considerations for pedestrians, especially children, in the design of the car park.
- The proposed car park space sizes are smaller than recommended by NNDC, and – as can be seen on the plans – are not adequate for modern cars. It is more than likely, with drivers parking to enable people to get out of vehicles and to avoid knocks, the markings for the spaces will not be followed resulting in ‘poor’ parking alignment and with many fewer then the suggested 47 cars at peak times. We would like to see more realistic space sizes, perhaps with some family parking spaces, suitable for a modern park/beach based car park. Some short term, free, half hour spaces, as with other town car parks should also be included.
- There is only one small pedestrian exit point, past the bottom of the ramp to the toilets, opposite the motorcycle parking, past the cycle parking. This exit leads onto the main driveway to North Lodge on a ‘blind corner’ for pedestrians who will be at risk from cars entering the Park. Whilst the size of the pedestrian exit was enlarged after we raised our concerns, we would like to see see it larger still, and safety considerations for pedestrians, especially children, in the design of the pedestrian exit from the car park and into the Park.
- There is only one pay meter in the design, at the northern end of the car park, with no pedestrian routes to it. A second pay meter was removed after we highlighted its dangerous position (directly where cars entered the car park). Without safe routes for pedestrians we would like to see further consideration of the placement of pay meters.
- The proposed lighting plan uses low level lights behind where cars park, and higher level lights in the proposed central band of trees. Whilst the proposed lights have low light pollution (according to the manufacturer, there has been no independent lighting assessment published), we don’t think they are an appropriate design for the heritage site and don’t think the illumination be sufficient in a full car park. We would like to see alternate proposals for the car park lighting, and an independent assessment of the proposals.
- A 6 meter (plus?) wide height restriction barrier is proposed to stop commercial vehicles entering the car park. Whilst we agree with the need to restrict access, we are concerned about the sustainable safety of such a barrier which could become dangerous, and would like to see other options, and a risk assessment of the proposal.
2. Does the proposal meet the requirements of the council’s core policies?
NNDC Core policies exist to maintain the standard of the heritage in the area and to protect open space. Once the recreational space is lost to non-recreational use it is lost. The decision to make such a change needs proper justification, with full disclosure, if core policies are compromised.
- Following our suggestion, the second revision of the Design and Access statement supporting the application acknowledges that North Lodge Park is a park, in the Cromer Conservation area, is designated as Open Space and is in the curtilage of a grade II listed building (North Lodge). The Council’s adopted Core Strategy Document states: “Applicants for planning permission should be prepared to demonstrate how the provisions of all relevant development plan policies have been taken into account”. In our objection2 to the proposal we listed many of the policies that should be addressed by this planning application. To date, our concerns have not been answered, and there is no published justification in the proposal for not giving due consideration to the council’s policies. We would like the council to justify why the relevant policies have not been addressed.
- The National Planning Policy Framework is clear: “Applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community”. No such consultation has taken place; the planning process – with no space for a two way dialogue – is not a consultation. We would expect to see a two way consultation on the proposals with the community.
- It is acknowledged by NNDC, that Cromer is short of green open space. NNDC Policy CT1 (Open Space Designation) states: “Development [of open space] will not be permitted except where it enhances the open character or recreational use of the land.” With the shortage of recreational space in Cromer, further reduced with the loss of Cabbell Park, we would like the council to publish its justification for the further loss of recreational space in Cromer (North Lodge Park) if this development goes ahead.
3. How can the justifications for the car park be considered material considerations when they are purely hypothetical?
- It is suggested that the car park would provide a benefit to the East End of Cromer. Every single shop & commercial premises from Jarrolds up to and around the corner of Overstrand Road is currently occupied with a wide variety of shops and services. The same cannot be said for the West End of Cromer where, for example, the old cycle shop adjacent to the main car park has been empty since 2015. The planning submission does not provide any evidence or substantiation how or what difference 27 additional parking spaces would make. Without any evidence or substantiation how can this be a material consideration?
- It is intimated that a car park could somehow make North Lodge Park a commercially viable asset to an investor. If this is a material consideration to be seriously considered then that investment proposal needs to be established and published before a loss to the Open Space should be permitted. North Lodge Park needs to considered and planned for as a whole, to do otherwise would be irresponsible management of a public asset and against the requirements of NNDC’s core policy on Public Realm. A material consideration cannot be based on pure conjecture and should not be used for the breaking up of a public asset.
4. Is the application a full and accurate representation of the proposal?
At all stages we have been directed to raise our concerns in the planning process, rather than with the officers concerned, where all comments, concerns, issues and suggestions are managed. The planning process relies on full accurate disclosure of all information regarding the application.
- The original description of the proposal incorrectly described the site as ‘brownfield’ which was removed after we raised our concerns, however the revised proposal, supported by several of the officer comments, continues to refer to the site as ‘vacant’ which it isn’t; we suggest this is a misrepresentation and should be corrected.
- In addition, the dilapidated state of the existing area is being used as justification for this development, within the proposal and supported by officers, on the basis that it is an improvement. The National Planning Policy Framework states that “…where there has been deliberate neglect, a state of dilapidation should not be taken into account in allowing permission for something that would otherwise be unacceptable…”. There are many other opportunities which would improve the site whilst retaining its recreational use. We suggest that this justification be removed from the application, and it should not influence the determination of the application.
- The 47 car park spaces proposed, whilst possible on paper, is unlikely to be achieved in reality as modern cars are too large to fit safely in the allocated spaces. If any financial justification has been made on the assumption of 47 cars this would need to be reviewed. We have not seen any financial justification.
- As indicated above, there is a suggestion in the proposal that the car park may help the “…vitality and viability of the eastern end of the town…”, but there is no evidence for this. There are more empty shops at the west end of Cromer, near the main car parks, than at the east end. The proposal acknowledges that at least 20 on street parking spaces will be lost on Overstrand Road so the actual increase in parking provision is minimal. In addition, it is likely that more on street parking spaces will need to be removed (Cromwell Road and Cliff Avenue) when actual traffic movements for the car park are analysed which could result in an actual loss of parking provision for the east end of Cromer (no traffic analysis has been published).
- Again, as indicated above, there is a suggestion that the proposal will address “…a wider concern that the town’s North Lodge Park was suffering from declining numbers of visitors…”. We would suggest that the decline in the visitor numbers is caused by lack of investment, and that during the last 18 months the Friends have been bringing life to the Park this significantly increased visitor numbers without a car park.
- Whilst there is some discussion about access in the proposal, there are no details about how drivers will be directed to and from the proposed car park, and the signage round town to facilitate this. NNDC’s policy CT5 requires planning proposals to be examined to ensure “…the expected nature and volume of traffic generated by the proposal could be accommodated by the existing road network without detriment to the amenity or character of the surrounding area or highway safety…”. If there is to be signage on the Norwich Road directing cars along Cromwell Road to the car park this could have a significant impact on traffic flow around Cromer which needs to be understood before this proposal can be determined.
- It is standard for such developments to be supported by an independent tree survey, the results of which may influence the design and approach. There has been no tree survey to support this application; after we queried why no tree survey has been undertaken a condition has been added to the application to ensure one is completed before any works commence. Without sight of the tree survey it is not possible to know whether the proposed development is appropriate.
- Whilst not acknowledged by the application, the planning officer has confirmed that bats are known to fly around the park, yet no independent survey from a licensed operator has been published. A planning officer visited the building with a torch and reported that a bat survey was not required. We don’t think this is independent nor complete. NNDC’s Policy EN9 states “…where there is reason to suspect the presence of protected species applications should be accompanied by a survey assessing their presence and, if present, the proposal must be sensitive to, and make provision for, their needs…”. Without the output from such an independent analysis we do not know the impact of this development on bats and their habitats; any disturbance would be illegal.
Secretary, Friends of North Lodge Park