A new beginning?

The end of the beginning

a new beginning for North Lodge ParkAt this morning’s NNDC Development Committee (Thursday 15th December) the planning application for developing part of North Lodge Park to provide a car park and new toilet facilities was refused, by 8 votes to 2, because it contravened several of the council’s core policies.

The decision was rather a surprise for us, but not unwelcome, and we must thank those councillors who spoke out against the proposals, and proved that a strong, evidence based argument is worth putting effort into.

We are pleased that councillors listened to arguments from the community, and think that a small celebration is allowed. It’s only a small celebration, because if the council had engaged with the community before submitting the application we could today be celebrating a bright future for the Park.

So the hard work starts now, to build bridges to avoid this new unexpected twist causing a lull in the future developments for the Park. We believe that if the park is invested in people will be attracted to it with the positive knock-on effect to the economy of the Town

Our ideas for a community trust are well advanced, and we hope to discuss these with NNDC early in the new year. If we can, and we believe we can, create a working proposal we’ll be able to have a proper celebration. We’ll then need your help to make the plans happen. The Park will not run itself and we’ll need many more of you to step up to the tasks.

But this evening it is time to relax, have a small celebratory drink, and lubricate the vocal chords for….

Carols in the Park

There is more reason to sing out at this weekend’s carol singing in the Park (2pm on Saturday) – hope to see many of you there.

Carols in the Park

Parks give life to communities, they create safer neighbourhoods, they provide green spaces in towns and cities, help children learn and promote public health.
What do people think about their local parks?
It’s not just us who are concerned about the future of Parks, and how to make them sustainable while local authorities have their budgets squeezed. In July the House of Commons Community and Local Government Committee launched an inquiry into public parks to examine the impact of reduced local authority budgets on these open spaces and consider quoteconcerns that their existence is under threat.
Over 13,000 people from across the country responded to their survey, supported by over 400 people and groups submitting written evidence. Clive Betts MP, chair of the committee commented: “The responses and comments we received have shown very clearly just how much people care about their parks”. You can see the results of the survey online. The committee has held its last session and will be reporting next year.

There is lots of research about the future of parks in the community, some of it referred to by the inquiry. I’d certainly recommend reading the CABE report Community-led spaces, A guide for local authorities and community groups which you can find on our website. There are no easy answers, but with some forward positive thinking from the stakeholders, and some hard-work from communities there are workable solutions.

Community Trust
In our 2 surveys we asked for views on the future of North Lodge Park, and whether a Community Trust would be an appropriate option. We received good support for the suggestion from you, and in the background we have been looking into options for this, which are coming together.

In early November we had a meeting with the district council and received a positive indication that, providing we could find a workable financial plan and a governance regime that gave a trust managing body sustainability, they would give a proposal for a community trust due consideration.
PF/16/1251
As one of our submissions to the car park determination process we submitted a paper on The Value of North Lodge Park as a Whole which discusses the wider economic value of North Lodge Park. This is an example of how we have tried, without success, to engage in a dialogue with the district council, to discuss the future of the Park and how the proposed car park development could be made more appropriate for the Park.

Unfortunately the district council has been unable/unwilling to discuss any aspect of the proposal with us for fear of compromising the planning process; there has been little acknowledgement at NNDC that any of the points we have made have any merit to them. We are really disappointed (and very frustrated) by this way of working which has left no space for any dialogue to improve the proposals.

Our MP Norman Lamb has offered to chair a meeting with the community and NNDC to review the process. Meanwhile, we have to raise our concerns as far as we can within the planning process.The problem is that, without any dialogue nor recognition that the proposals could be improved, we had to object to the proposal.

carparkspaceThe image is taken from the submitted plans and, yes, if all the bays are filled the only way out of your car will be through the roof. The result of small spaces, and other design faults, will be confusion and less cars parked as they juggle for enough space. Every-time we look at the proposals more issues appear – it would be funny if it wasn’t such a serious issue.

It remains our belief that there is a real risk that the proposed designs will lead to the creation of a car park that is inappropriate, dangerous to users, particularly children, and unsuitable for the disabled. We summarised our concerns to the development committee this week, we have also submitted concerns to the Overview and Scrutiny Committee to ask them to review whether the application has followed due process.

The planning officer, Mr Watson, in his report for the Development Committee (who meet next Thursday, 15th December, to review the application) has produced 19 pages on the application, missing some key points, and recommending 14 significant conditions (including revised plans and details, confirming the submitted plans aren’t appropriate!) including many of the issues that we have raised that should have been covered by the original application. The conditions show what a poor proposal this is, and will result in such substantial changes the development committee will actually be discussing a proposal that will need to be superseded! Somehow he concludes (probably with his fingers crossed): It is clear that the issues associated with this application are very finely balanced.

thumbsUnfortunately he further concludes that the potential economic benefits to the east end of Cromer (which he admits there is no evidence for), the potential economic benefits arising from the increase in footfall through the Park (which are not defined) and the increased potential for social interactions with increased footfall in the Park sway the argument and he recommends the application is approved. We will be attending the Development Committee and hope to be given the chance to speak to challenge his conclusion.
Christmas in the Café
To give our café volunteers time with their families over the festive period the café will be closed from the end of Thursday 22nd December until Tuesday 3rd January.- with the exception of Boxing Day (10-1 to support the swimmers) and New Year’s Day (midday – 6 to support people coming for the fireworks).

This Saturday (17th) afternoon, from 2pm, come along and join us singing carols in the Park. Last year it really brought Christmas cheer to the Park with all your lovely voices.
Charity
As we announced at the AGM, way back in March, we thought it prudent for the Friends to become a registered charity, and you will recall that we updated our constitution at the time to facilitate the change. Over the last few months we have been working with The Guild in Norwich, and can report that we are now a registered charity (Registered Charity Number 1169907). Apart from now having to report to the Charity Commission, and ensure a clear focus on our objectives, there isn’t much we need to change as we have been managing the association ‘as though it were a charity’ from the outset.

Hope to see many of you either before the festivities really start, or during the break. On behalf of the committee, may I take this opportunity to wish you all a Merry Christmas and best wishes for the New Year. 2017 here we come!

 

Barry Meadows
Humbug manufacturer

Development Committee Email

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.

Regards

Barry Meadows
Secretary, Friends of North Lodge Park

Noth Lodge Park gardens

Goodbye summer, hello autumn

The elephant in the room
The proposed car park planning application continues to take much of our time, time we would rather spend on positive plans. Over the past month we have continued to challenge the NNDC planning process in an attempt to understand why due process isn’t being followed by the planning system and to raise our concerns regarding the design of the proposed car park – the design really isn’t fit for purpose.Since we first raised our concerns NNDC have been cobbling together some un-substantive reports and are adamant they are doing all they have to do to get the permission they seek. What they could never deny is that the application has been rushed together, not been thought through and does not meet best practice.

Bodpave as installed in the NNDC Overflow car park

Bodpave as installed in the NNDC Overflow car park

Let us hope the car park they are intent on building is not of similar poor quality. Have you seen the plastic grid car-park at NNDC’s own offices?

There is still time to comment on the application. The consultation period for the application has been extended to 8th December (to allow for the ‘consolidation’ of comments) and the hope is that when the proposal (finally) gets to the development committee (scheduled for 15th December) sense will prevail and the application will be refused.

NNDC have made it clear that no revenue from the car park will go towards the Park. If you only support the application if revenue monies will go to the Park you need to object to the application – caveats in any comments will not be considered in the process.

You can see details of our design concerns in the news section of our website– there are 19 points of concern, all of which we think need to be addressed before the car park design is suitable.

Life is too short for traffic.
One of our major concerns is the impact of the car park on traffic flow around Cromer, which is difficult at the best of times. The introduction of a new car park on a route where through traffic is discouraged will have a major impact on traffic flow however it is decided to route it (there are no details on this in the application).

Traffic into Cromer from the east, from Norwich and Overstrand, is currently directed down Norwich Road, and discouraged from using Overstrand Road (although we all know many cars ‘jump’ the bus lane into Cromer). We have asked the following questions but not received answers:

  • How will traffic be directed to the car park?
  • How will cars leave the car park?
  • How will cars unable to find a space in the car park be directed to other car parks?
  • How many on street parking spaces will be removed to enable traffic flow to the car park and what is the impact of this on the justification to improve the viability of the east end of Cromer? (The only published justification for the car park is increased parking spaces for the east end of Cromer, but if Overstrand Road, Cromwell Road and Cliff Avenue are all to lose free on street places there will actually be a reduction in total available spaces.)

The Statuary Highways Assessment of the proposal stated that before any works are commenced a full traffic plan is required – we just hope it is produced before the development committee assess the planning application as it is key to the success of the proposal.

It’s not a vacant brownfield site
Incorrectly the planning application calls the old children’s play area a vacant brownfield site (National Planning Policy Framework specifically excludes parks from the definition of Brownfield Land.) and makes no mention of the fact the site is open space, public realm and in a conservation area.

In addition, the dilapidated state of the existing area is being used as justification for this proposal on the basis that it is an improvement (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) implying that there aren’t any other options that would be an improvement. Both NNDC’s in-house consultees, the conservation officer and the landscape officer, have quoted the state of neglect as part of their account of justification of the car park

What would you prefer to see there, that would be an improvement to how it looks? Examples:

  • A Multi-use games area would be an improvement, and provide a space for teenagers to use
  • dodgems in North Lodge ParkA cycle riding road system for learning to ride and for fun cycle based activities (the old bandstand could be a cycle repair centre)
  • The concrete could be replaced with grass for informal games
  • A crazy golf circuit could be created
  • The old dodgem based cars could be dug out of store
  • The bandstand could be returned to its designed use for concerts or outdoor theatre
  • A roller skating rink (ice skating in the winter?)
  • A wildflower meadow, maybe with a bug hotel, bird feeders, hedgehog house etc to attract wildlife
  • A plant nursery
  • A ‘food for free’ community garden

What ideas do you have?

Play Park
The exhibitions of the Play Park proposals at the end of October went very well with over 250 of you passing through and almost 100 evaluation forms completed. The vast majority of you were really supportive, and you liked some elements in all the proposals. We’re really pleased that Cromer Junior School are also providing feedback on the play elements.

We’ve analysed your comments, and fed the results into our assessment of the proposals. There was no clear choice that matched all the criteria. We have asked 2 of the suppliers to update their proposals to take into account our feedback and have asked for these to be returned by the end of November so that we can submit a planning application this year. Our priorities for the project now are fund-raising and resolving the maintenance/sustainability of the proposed play park.

Crepes and Cakes
Don’t forget the cafe in the Park will be open right through the winter, six days a week (closed Mondays) from 10am to 4pm.

It’s your community cafe so please let us know what you would like to see in the cafe, and how you would like it to develop. The team of volunteers, in the cafe and baking the wonderful cakes, work so hard to keep the cafe open and the quality high. On your behalf I pass on all our thanks to them for their efforts – it would be even better if you popped into thank them yourselves. And why not volunteer yourself? We’re always looking for new helpers to join the team.

Gardens
And the park wouldn’t look so good without the small army of volunteer gardeners who beaver away in all weathers. Again, on your behalf I pass on all our thanks to them for their efforts.

Hope to see you all soon

 

Barry
Elephant Trainer (failed)

Detailed car park design flaws

There are a number of flaws in the design of the proposed car park that make it not fit for purpose. The table below consolidates our concerns which have been entered in the planning system.

Issue Comments
Parking spaces are too small

  • The spaces are smaller than the NNDC recommended car park space size
  • why hasn’t this design taken into account the council’s own standard?
 Take a look at the scale plan of the car park and the way car images are placed in the spaces. It would not be possible to open the doors if two cars park side by side.The results will be:

  • bad parking, such as across spaces;
  • risk of car damage from cars manoeuvring close to other cars;
  • risk of car damage from knocked doors;
  • drivers will park elsewhere
No pedestrian routes

  • NNDC policy is that pedestrian routes should be clearly defined and not restricted by vehicular movement requirements, but there are no separate pedestrian routes in the proposal
  • why hasn’t this design taken into account the council’s own standard?
 After parking a car the passengers and their bits and bobs need to alight and move from
the car park. As a beach car park in summer this will include lots of children and lots of bits and bobs. In the summer there will be cars constantly moving round the car park looking for spaces. The result will be:

  • risk to children waiting for their family to be ready to move on
  • conflict between pedestrians, wheelchairs and cars with a risk of injury
  • drivers, especially with children and pushchairs/strollers will park elsewhere to minimise risk
No pedestrian access to Overstrand Road

  • the only justification for the car park is to improve the vitality and viability of the east end of Cromer
  • if this really is the justification why hasn’t this been given priority?
 The only pedestrian exit from the car park is at the north-west corner into the Park, from where pedestrians will walk through the Park and into town missing the east end of the town.

  • The design is not fit to match this justification.
Pedestrian access to Park

  • exit from the car park is via a small opening at the north west corner, much too small to cater for the expected flow of pedestrians, wheelchairs and cycles.
 Take a look at the scale plan of the car park and look at the only pedestrian exit and ask why no-one has thought about how to accommodate the flow of pedestrians to and from the car park.

A narrow exit such as proposed would cause pedestrian, wheelchair, pushchairs to ‘tail back’ into the car park causing further unnecessary risk to pedestrians.
Car Park entrance

  • a new entrance from Overstrand Road is proposed
 Take a look at the scale plan of the car park and look at where the entrance to the car park is, just to the west of the exit lane; without clear signage (not just a bodpave insert) drivers could easily enter on the exit lane causing holdups.
Whilst the ‘sweep analysis’ shows cars entering from the east and leaving to the west (which they can’t do on the current road system), there is no sweep analysis for car circulating, and the plan suggests this could be difficult
Bodpave surface

  • Bodpave is a reinforced plastic grid that can be infilled with gravel to provide a durable surface

 

Bodpave as installed in the NNDC Overflow car park

Bodpave as installed in the NNDC Overflow car park

 Take a look at the NNDC overflow car park, behind the Police Station on Holt Road in Cromer, which was made with this system and is currently unusable because it is coming apart.Whilst Bodpave can be successfully used in parking bays, on traffic routes where vehicles turn sharply (as in a car park) it can be problematic (as is seen from the NNDC overflow car park).

The gravel surface isn’t really suited for a conservation heritage site where a more
formal look is more appropriate.

The gravel surface isn’t ideal for wheel chair use.
Bodpave signage

  • limited space in the car park will result in on ground signage using plastic inserts
 Take a look at the NNDC overflow carpark, behind the Police Station on Holt Road in Cromer, which was made with this system and see if you can see the plastic inserts that mark out the spaces and think about how significant direction arrows will be.

The design of the car park is such that there is not space for other signs so the only way drivers will know there is a one way system is through the plastic inserts.
Other signage / street furniture

  • there is nothing in the design to indicate where signs and bins will be
 There will be a need for other signs in the car park, such as to indicate to pedestrians how to get out of the park, where the pay meters are, and where the cycle park is. Additional furniture such as waste bins are proposed for the planted areas, ie behind where the cars will be parked so impossible to use
Pay meters

  • the pay meters are planned to be at the end of the planted area in the middle of the car park
 The pay meters will be placed opposite the entry point to the car park where pedestrians waiting to pay will be most at risk
No motorcycle spaces

  • NNDC standards state: Parking for motorcycles, mopeds and scooters should be provided in all new non-residential developments at a rate of 1 space per 20 car parking spaces with a minimum of one space
  • why hasn’t this design taken into account the council’s own standard?
Entrance 6ft barrier

  • to stop commercial vehicle and camper vans a height restrictive barrier is to be installed across the entrance
 The barrier will be a heritage design, spanning about 6 metres, about 8 feet from the ground (ideal height for people to swing from)

  • How long will it be before a roof-box or roof-cycle will accidentally knock into this requiring expensive repairs
Restrict vehicles to Park

  • the proposal will encourage more cars onto Overstrand Road looking for parking
 The park driveway will be mistaken for the car park and vehicle numbers in the park will increase.

There is already a problem with unauthorised vehicles, driving too fast, parking in odd places and turning where children are playing. There is no proposal in this design for how this will be addressed.
NNDC standard on cycle parking is that it should:

  • be secure, under effective surveillance and conveniently located to the entrance … with safe and direct routes to the surrounding road network;
  • it is difficult to see how this standard has been adhered to
 The cycle parking has been moved in the latest design to be adjacent to the pedestrian exit from the car park into the Park

  • why is the cycle parking at the back of the car park which will encourage cyclists down the Park drive rather than through the car park (the Bodpave surface isn’t good for cycles)
  • what is there to separate cyclists from pedestrians exiting the car park?
Excavations near trees

  • NNDC policy: a Tree Survey/Arboricultural Implications assessment is required where there are trees within the application site, or on land adjacent to it that could influence or be affected by the development (including street trees). Information will be required on which trees are to be retained and on the means of protecting these trees during construction works.
  • why hasn’t this policy been enforced?
 The proposal is to excavate the current surface and replace with a Bodpave and gravel covering. This will require excavations of at least 500mm less than a metre from mature trees in the Park. An independent arboricultural assessment would determine the impact of this on the trees and influence the design.
Entrance to new toilets

  • sloped access to toilets should be at least 1:20 for a ramp to rise to the necessary height
 Unfortunately there are no measurements on the plan but an estimate shows the ramp to the toilets to be too steep.
The lower end of the ramp is in the middle of pedestrian exit to the car which will
cause risk to wheel chair users, and pedestrians.The small turning area at the bottom of the ramp would make it difficult to turn wheelchairs and mobility scooters safely.
Potential of bats in building

  • Legislation states: local planning authorities must fully consider a proposed development’s impact upon protected species as they are a ‘material consideration’ in the determination of planning applications. In the context of bat surveys, where there is a reasonable likelihood of protected species being materially impacted upon by a development, surveys must be carried out before a planning application is determined. 
 NNDC acknowledge bats fly around the Park but, contrary to legislation, no independent bat survey has been completed, although a planning officer has stated: “it is recommended that the removal of the roof covering (felt) be executed under a Method Statement to ensure that, on the small chance a bat is discovered, proper procedure is followed.”

There has been no independent assessment of the impact of cars, their lights, noise and pollution on the bats in the Park.
Disturbance of bats and their habitats is illegal.
Assessment of noise and pollution

  • Government advice is: Noise needs to be considered when new developments may create additional noise and when new developments would be sensitive to the prevailing acoustic environment.
 Creating a car park in a quiet park in a residential area will increase traffic,
particularly slow moving traffic which causes the most pollution and noise.Increased pollution in a recreational area, particularly where children are playing, is a major consideration and an assessment of this should be undertaken to, at least, see if there are any mitigating design features that could alleviate the impact.
Lighting assessment

  • the lighting is all placed within the planted areas lighting will be behind parked cars or hidden by plants
 There has been no assessment of the effectiveness of the lighting plan, nor the
impact on local residents, or wildlife (including protected species such as bats).Lighting schemes can be costly and difficult to change, so getting the design right up front is critical; there is no independent assessment (other than a manufacturer’s proposal) that the planned lighting scheme is
appropriate.
Traffic analysis

  • there are no details about proposed traffic movement around Cromer as a result of this proposal
  • Why wasn’t NNDC Property Services asked for a traffic assessment before the application was validated?
 Traffic flow around Cromer is difficult in the summer; this proposal is for a car park on a route where traffic is discouraged so there will need to be a significant change to traffic flow to facilitate use of this car park:

  • how will carsget to and from the site, and onto other car parks?
  • What will the impact be on current on-street parking (for example, how many (free) on street spaces will be lost to enable the car park?)
  • What additional street furniture will be needed round Cromer?

Answer to these questions are a key part of the decision process and should have
been part of the original submission.

Highways have stated that “no works shall commence on site … until a detailed scheme for the off-site highway improvement[s]…”

 

 

OBJECTION TO PF/16/1251 Change of use of former tennis court/play area to public car park (48 spaces) with new access from Overstrand Road & conversion and alteration of former potting shed to form new public toilets in North Lodge Park

We have formally lodged our objection to the planning application PF/16/1251 for a car park and new toilet facilities on the old children’s play area in North Lodge Park.The reasons for our objection are that it appears that North Norfolk District Council (NNDC) have submitted this planning application, without considering the Park as a whole, without addressing national planning policy and without addressing its own Core Policies. Furthermore, against the spirit of Localism and National Planning Policy, NNDC have put forward a proposal without consultation with the community.

 

OBJECTION TO PF/16/1251OBJECTION TO PF/16/1251 Change of use of former tennis court/play area to public car park (48 spaces) with new access from Overstrand Road & conversion and alteration of former potting shed to form new public toilets.

It appears that North Norfolk District Council (NNDC) have submitted thisplanning application, without considering the Park as a whole, without addressing national planning policy and without addressing its own Core Policies. Furthermore, against the spirit of Localism and National Planning Policy, NNDC have put forward a proposal without consultation with the community.

There are a number of material planning considerations that are grounds for our OBJECTION to this application.

Summary

In applying to itself for planning permission NNDC have not produced the validation requirements that any other developer would have to prepare.

The reports and surveys that are usually required to make an application valid are necessary so that the impact of the proposed development can be judged, so the public can understand the implications of the development and so the Planning Authority can make an informed decision.

Without assessing the impact it is impossible to determine whether these proposals would have a detrimental impact on the special character of North Lodge Parkand the surrounding area.

We do not believe the application should have even been registered without an arboricultural impact assessment or an ecological survey. Moreover, the fact that in spite of the applicant being a member of North Norfolk District Council’s property services team, at Part 8 of the application form the box that declares whether the applicant is connected with the Council has been ticked “no”.

We are concerned that NNDC have been mis-representative with this proposal.

The Design and Access Statement and press release refers to the site as Brownfield Land. The National Planning Policy Framework specifically excludes parks from the definition of Brownfield Land.

The planning application form states the site is currently vacant. This is incorrect.

The site is still open and used by the public to learn to ride bicycles, skateboard and informal play. Earlier this year NNDC erected signs forbidding skateboarding.  Part of the site has in recent years and continues to be used as a waste transfer station. Although no planning permission, Certificate of Lawlessness or Environment Agency permits exists for this use, NNDC have stated that it is permitted as it has been used for over 10 years. Part of the site is being leased to a Contractor for a construction site compound. It is not a vacant site.

If the area subject to this change of use application was not being used by a commercial waste operator and building contractors it could be more successfully used for recreational activities and events.

The application does not consider the designations that have been put in place by the Local Development Framework to protect this land.

Rather than Brownfield Land the designations that are ignored in the Planning Application are the fact that it is Open Space, Public Realm and in a Conservation Area. There are a number of planning policies relevant to these designations and the application either contravenes or does not demonstrate compliance with 11 policies of NNDC’s Core Policy and at least 9 clauses of the National Planning Policy Framework. These are examined in further detail below.

The design of the proposal is of low quality.

A plastic grid in-filled with an unspecified aggregate with plastic inserts, no specified kerbing and no margins or paths might be appropriate for an informal parking area but is not a considered formal design within a structured park and Conservation Area. No positions for signage, lighting, bins or street furniture have been proposed in the layout.

The proposal ignores the Council’s own standards

As well as ignoring its own Design Guide recommendations the Council have ignored their own published parking standards resulting in more spaces in the area than it can comfortably accommodate. The proposed parking spaces are smaller than would be permitted on a commercial development and there is no parking for motorcycles.

We do not believe the justifications promoted by the applicant are material considerations

The dilapidated state of the existing area is being used as justification for this proposal 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.

Another justification promoted by NNDC is to increase the footfall to the East End of town but to achieve this a pedestrian entrance in the South West corner of the proposed car park would be required.

A surprising justification is to address a “wider concern that the town’s Victorian North Lodge Park was suffering from declining numbers of visitors”. The quality of the open space, its facilities and events attract visitors, and over the last 12 months the Park has been brought to life around the hub of the Café by the community which is currently being ignored by the District Council.

 

The Friends of North Lodge Park conducted a survey in March and April of 2015 that received 747 responses. The survey report concluded:

“The overwhelming view is that the special character of the Park as a beautiful, peaceful green space in the heart of Cromer should be safeguarded, and that the lawns and flower beds of North Lodge Park are an important asset to the town. Nothing should happen that is not in keeping with this special character. Respondents often spoke passionately about their fond memories of the Park throughout their lives and how it provides an ‘oasis of calm’, particularly at times when the town is very busy during the summer months.”

A further more detailed survey at the beginning of 2016 supported this conclusion

North Norfolk District Council know that introducing a car park into North Lodge Park is be an emotive subject with the Community and it is surprising that such a poorly documented and unsubstantiated application has been submitted that only addresses one aspect of the Local Development Framework and makes little attempt at addressing any material considerations that would justify a permission.

Any proposal for car parking in the Park needs to consider the Park as a whole, as a co-ordinated approach to this area of Public Realm and as a means of protecting and enhancing the recreational use of the Park.

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”.

As the planning authority, NNDC’s own planning department must consider the relevant development plan policies and the decision must be taken in accordance with the development plan unless there are material considerations that indicate otherwise.

The details of our concerns can be viewed here.

 

Play Park Option Exhibition

play park options exhibition

The two surveys conducted by the Friends of North Lodge Park identified the lack of children’s play in the Park as a priority to be addressed.

As part of the cafe licence it was agreed the Friends would put forward plans for a children’s play area, on the old bowling green, funded in part by profits from the cafe.

Over the past month 5 suppliers have been contacted and asked to bring forward designs against the following criteria:

  • an innovative design, unique to the area, that will make the Park, and Cromer, a destination for play
  • a design sensitive to the surroundings, the heritage of the Park and nearby residents
  • low level play to not obstruct the vistas across the space
  • inclusive play for all, upto age 10/12
  • a budget of £100,000

By the end of October the supplier submissions will be ready for public viewing, for you to look at the options and help decide which, if any, proposal to take forward to the next stage.

Invitation to view options for a children’s play area
in North Lodge Park

Friday and Saturday
October 28 and 29
11am – 3 pm

Sea View pre-school
North Lodge Park

 

There is still much to do to make the project a reality, including fund-raising, and agreeing a sustainable maintenance plan, but we are aiming for implementation next year.

Poll no-win for North Lodge Park

Cromer parish meeting.
Last Friday’s Cromer parish meeting, of approx 80 registered electors, voted to request a parish poll asking the following question: Do you wish to see any part of North Lodge Park to be converted into a car park? Yes or No. This question is being forwarded to the Returning Officer at NNDC who will decide whether or not there will be a parish poll.

Discussions at the meeting showed the strength of feeling the community have for North Lodge Park, and how strongly the community want it to remain a special place at the heart of Cromer. Both our surveys have shown this to be the community’s highest priority for the Park.

Our view
We, the committee for the Friends of North Lodge Park, do not wish to see more parking in the Park. Ideally, we would like to get rid of all parking. We also want to see the Park put on a sustainable footing for the future, which requires a significant guaranteed revenue stream. No matter how often or how loudly anyone says “NNDC should be funding the park properly”, without new money we do not think there is any chance of anything beyond minimal maintenance for the foreseeable future because of the significantly increased financial constraints on local Government. .

As a committee, we have had to make a difficult decision. We would much rather the area proposed for the car park is used again for children’s games and educational activities; but we know from our surveys that a significant percentage (50%) of you would support a small car park provided it enabled the rest of the Park to be safeguarded and enhanced.
We do not support the current car park proposal, and have written to NNDC with our considered view that the current proposal has no benefit to the wider park. We have asked NNDC to work with the community to develop a long term plan for the whole Park.

Poll no-win for NLP
Therefore the Friends of North Lodge Park committee have adopted the policy to be prepared to accept a limited car park if – and only if – this benefits the whole park; we did not support the motion for a parish poll.

We believe holding this parish poll is a lose-lose for the Park.parishpoll-extract

  • In the event of a yes vote, or a significant yes vote, NNDC may feel they have the town’s support for the proposed car park without any benefit going to the Park
  • In the event of a no vote (which is not enforceable):
    if NNDC abides by the result, will there be new money for the Park or will it continue on a minimal maintenance basis?
    if NNDC rejects the result, will the proposed car park will be installed with no benefit to the wider Park?

 

Summary
The Friends’ objective is to protect and improve the whole of North Lodge Park. With the invaluable help of volunteers the cafe has become a successful community hub, the gardens around the cafe brought back to life, and there have been a range of successful events in the Park. But unless more people come forward to help, managing the whole park with volunteers may not be sustainable.

North Lodge Park will require significant funding which is unlikely to come from NNDC. A car park may prove to be the only realistic revenue source. So while opposed to the current planning application, your committee does not believe the option of a revenue-producing car park in North Lodge Park should be completely discounted. It should at least be used as a basis to discuss how North Lodge Park can be funded and managed in the future.
The Friends committee are passionate about bringing the Park back to be a Park we can be proud of. We spend hours of our time on your behalf working in the cafe and Park so know the issues. We live and work North Lodge Park. Should we not be trying to find a revenue source that will make the Park sustainable? If not a car park what other revenue source could there be (I repeat, it is unlikely to come from NNDC)? Would you be willing to put your hand deep into your pocket to replace revenue that a car park could generate?

We need to find a way to have a sensible debate within the community and with NNDC. We do not think the proposed parish poll is the way to do it.

48 Spaces and new toilets

proposed toilets in North Lodge Park

The car park proposal
North Norfolk District Council have submitted plans for a car park in North Lodge Park, with conversion of the old bandstand to public toilets.

In summary the proposals are:proposed car park in North Lodge Park

  • a 48 space car park, with 6 disabled spaces, wholly on the old children’s play area (‘concrete area’);
  • conversion of the old bandstand into public toilets;
  • no trees to be removed and additional trees planted;
  • a new opening onto Overstrand Road to facilitate car entry and exit with styling to match the existing entrance;
  •  ‘heritage style’ height restriction bar;
  • surface to be shingle style in a plastic grid;
  • lighting to be low level;
  • no other improvements to the rest of the Park.

There are a number of points to be addressed to improve these proposals, such as

  • one objective is for the car park to serve the businesses at the east end of Cromer, but there is no easy way for pedestrians to exit the car park onto Overstrand Road and to that part of town;
  • there is a lack of clear pedestrian routes through the car-park;
  • the rear transfer areas to the disabled spaces conflict with the routes for cars;
  • the number of parking spaces restricts available roadway in the car park which suggests vehicular movement round the area will be difficult
  • there are no details about intended traffic flow to and from the proposed car park, nor details of signage outside the Park and the impact on traffic movement in Cromer is unclear;
  • implementation of measures that reduce traffic into North Lodge Park itself through the current entrance from Overstrand Road should be within this project .

Putting the proposals in context

How would it benefit our Park?
The old children’s play area (sometimes known as ‘the concrete area’), where the car park is proposed is not a brownfield site: it is a core part of the recreational space in the Park. The area has been left to deteriorate for a number of years, used for a waste transfer facility and more latterly a builders’ yard, but previous to that it has always been an area of recreation. Key questions to answer are; “Is a car park the best use of this part of the Park considering the Park as a whole and how would it benefit our Park?”

Policy Questions
On paper the current proposals seem to be counter to many of the council’s core policies (see footnote). These NNDC Core Strategypolicies can be summarised to say that any development of an open space must improve that space. It could be argued that the car park is an improvement to the current state of the old children’s play area. But that’s a bit like saying putting a new uPVC front door on a dilapidated Listed house is an improvement while the rest of the house falls down. The car park is like the new front door while the rest of the Park continues to deteriorate.

The whole park
NNDC policies support our strong belief, that the Park needs to be seen as a whole. NNDC are developing plans to work with a strategic partner for the long term sustainability of the Park (with a Prior Information Notice, PIN, providing information and seeking ‘bids’ from anyone interested in ‘managing’ North Lodge Park). We would like clarity on how NNDC see this project in the context of those plans for the proposed management of North Lodge Park. The income generated by a car park would fund the Park and take away future costs and liabilities from NNDC.

Summary

It could be argued, particularly by the 50% of respondents to our latest survey who said that you could accept – with caveats – a car park in North Lodge Park, that if a car park is inevitable then this proposal is about as good as we’ll get from NNDC. However, apart from providing parking for the Park, thereby increasing accessibility and footfall, these proposals take from the Park rather than give. These are proposals for part of the Park without the context, costs and benefits of plans for the Park as a whole.

This is a big decision for Cromer, and we need more information to make it an informed decision. We have written to NNDC requesting the fuller picture and will keep you informed..

Do let us know what you think. More importantly let NNDC know!
Barry Meadows

Footnote: NNDC policies that the car park proposals seem to be counter to.

  • NNDC’s Policy EN5 Public Realm states: Within areas designated as Public Realm proposals will be expected to enhance the overall appearance and usability of the area, and a co-ordinated approach to management will be encouraged;
  • Core Strategy Policy CT1 Open Space designations states: Development will not be permitted except where it enhances the open character or recreational use of the land;
  • NNDC’s policy EN8 Protecting and enhancing the Historic Environment states: Development proposals … should preserve or enhance the character and appearance of designated assets … and their settings through high quality, sensitive design. Development that would have an adverse impact on their special historic or architectural interest will not be permitted.

North Lodge Park proposed car park and public toilets

Initial response to NNDC regarding the plans for a car park and new public toilets in North Lodge Park

To: Cllr Rest, Steve Blatch Copy: Cllr Lee, Cllr Cox, Cllr Yiasmi, Cllr Pearce

12 September 2016

Proposed car park and public toilets at North Lodge Park, Cromer

Thank-you for sharing the proposed plans for car parking and public toilets in North Lodge Park. As agreed, Robert and I shared the plans with the Friends committee last week.

Implementation of the proposed car park in North Lodge Park will dramatically change the use of a significant part of this important and much loved Park. Acceptance of the development is a major decision for the community, one that should be made with all the right information, and put into context with the long term future of the Park.

The Friends of North Lodge Park know, through formal surveys and engagement with the community, that there remains significant opposition to a car park in North Lodge Park. However, we know that opinion has moved since the 2007 referendum, and there is some acceptance of a small car park development in the Park, on the old children’s play area, but with many caveats including the proviso that a proportion of the revenue generated is used for the benefit of the Park.

These proposals take away part of the recreational opportunity in Cromer, which council policy states is under supplied, without giving anything back.

On paper the current proposals seem to be counter to many of the council’s core policies (see footnote). These policies can be summarised to say that any development of an open space must improve that space. It could be argued that the car park is an improvement to the current state of the old children’s play area. But that’s a bit like saying putting a new uPVC front door on a dilapidated Listed house is an improvement while the rest of the house falls down. The car park is like the new front door while the rest of the Park continues to deteriorate.

North Lodge Park has been seen as a drain on the resources of NNDC since they assumed ownership on behalf of the community in the mid 70s, with many attempts over the years to reduce the financial burden. In parallel to these car park proposals NNDC are developing a Prior Information Notice (PIN) to work with a strategic partner on the future of North Lodge Park, to improve the Park whilst reducing its cost to the council. It is our view, supported by the council’s core policies listed above, that these two projects cannot be separated. Development of North Lodge Park needs to be seen as a whole.

To enable us to have a sensible debate on these proposals we ask NNDC to engage with the community, and openly discuss the future of all of North Lodge Park. Please can you tell the community how the car park proposals fit with the PIN opportunities and how the revenue from the car parking will be used to sustain and enhance the quality of the whole Park

 

 

Barry Meadows
Secretary, Friends of North Lodge Park

 

 

Footnote: NNDC Core Policies related to the car park proposal

NNDC’s Policy EN5 Public Realm states: Within areas designated as Public Realm proposals will be expected to enhance the overall appearance and usability of the area, and a co-ordinated approach to management will be encouraged;

Core Strategy Policy CT1 Open Space designations states: Development will not be permitted except where it enhances the open character or recreational use of the land;

NNDC’s policy EN8 Protecting and enhancing the Historic Environment states: Development proposals … should preserve or enhance the character and appearance of designated assets … and their settings through high quality, sensitive design. Development that would have an adverse impact on their special historic or architectural interest will not be permitted.