It is with deep regret that the officers of Look! St Albans felt obliged to write the following letter of objection to the planning application 5/2020/1773 for the City Centre Opportunity Site. They have limited their objection, as per the constitution, to process and not regarding the design. It is for residents to make their own representation to the planning department firstname.lastname@example.org quoting the above reference.
“Look! St Albans – Our Community Voice on Design does not have the remit through its constitution to comment on the design of any planning application.
As officers of Look! St Albans we must limit ourselves to objecting to the misleading statements regarding the process to be found in both the Design and Access Statement and Statement of Community Involvement. Both documents infer that the early community engagement that was undertaken by the applicant informed and retains relevance in this and the previous planning application for the CCOS site. The applicant has made it abundantly clear that they rejected that work by the community and therefore it is misleading at the very least to say that work informs this application before you.
We think it is worth recapping the reason why Look! St Albans was formed post the City Centre Steering Group, which enabled the community with the support of the Council and its Head of Planning in 2012 to work with the Prince’s Foundation for Building Community.
The principal reason was that for too long arguments and poor quality design had characterised attempts to find a viable solution for this site (the site of this planning application) at the heart of our City. Our joint objective, supported then by the Planning Department, was that the St Albans community had a wealth of knowledge and understanding of and pride in our City, and we jointly wanted these benefits to be used positively in determining the built environment and surrounding open spaces for this site.
To that end the Steering Group and The Foundation engaged with the local community to co-createdesign codes for the City Centre. The codes are not a full suite but are sufficient to promote durable, loose fit adaptable buildings and open spaces using materials conducive to longevity.
This planning application before you is the result of an ill-advised design competition, not the community-led charrette nor the Community Design Review that preceded this application. The competition was open to abuse, and invited and received minimal participation from the community and it is therefore highly regrettable that the Council as landowner and developer has chosen to proceed on this most important site in St Albans on that basis.
Despite repeated requests the actual design brief for the recent design competition that formed the basis of this planning application has not been made public knowledge.
Many of those who took part originally in the Masterplanning charrette of 2016 were motivated by a spirit of joint endeavour and sense of pride in what the community could achieve collectively. Those who took part are now left dispirited by the total disregard of the outcome of that process, intended for the betterment of this site.
The charrette itself and the outcome were finalists in The Royal Town Planning Institute Awards in excellence in planning both nationally and regionally in 2017. Those in the facilitation team who led the process are recognised experts in their fields.
Indeed many of those who took part in the Masterplanning design charrette have made their feelings known to us, but it is up to the individuals to make their representations to this application in the usual way which we shall encourage them to do.
These comments should come as no surprise to the applicant as we have expressed these directly to them before this planning application was submitted.
We comment below on the relevant planning policies and guidance in relation to this planning application:-
National Planning Policy Framework states:-
128. Design quality should be considered throughout the evolution and assessment of individual proposals. Early discussion between applicants, the local planning authority and local community about the design and style of emerging schemes is important for clarifying expectations and reconciling local and commercial interests. Applicants should work closely with those affected by their proposals to evolve designs that take account of the views of the community. Applications that can demonstrate early, proactive and effective engagement with the community should be looked on more favourably than those that cannot.
129. Local planning authorities should ensure that they have access to, and make appropriate use of, tools and processes for assessing and improving the design of development. These include workshops to engage the local community, design advice and review arrangements, and assessment frameworks such as Building for Life. These are of most benefit if used as early as possible in the evolution of schemes, and are particularly important for significant projects such as large scale housing and mixed use developments. In assessing applications, local planning authorities should have regard to the outcome from these processes, including any recommendations made by design review panels.
National Design Guide states:-
17 Local communities can play a vital role in achieving well-designed places and buildings and making sure there is a relationship between the built environment and quality of life. Communities can be involved in design processes through approaches such as co-design, design workshops and other engagement techniques, so that places and buildings reflect local community preferences, improve their quality of life and fit well into their surroundings. The design-related chapters of the planning practice guidance explain these and other design processes.
Design concept: The basic design ideas on which a proposal will be based, often expressed in a combination of words and visual material.
- In 2016 Look! St Albans was asked by the Council as landowner to host a Masterplanning design charrette for the entire City Centre Opportunity Site with the expectation that the landowners “would bring back individual planning applications for further work by the community on the design detail.” This the applicant chose not to pursue further.
- The recommendations for further testing beyond the Masterplanning stage are referenced in this planning application in the Design and Access Statement page 19 under “key charrette headings.” This ‘cherry picks’ some of the recommendations of the charrette report. The applicant fails to address how these recommendations were addressed in the progress of the design and where they can be found in this application. In addition the applicant fails to address all the recommendations headings, and also how these were addressed in the design process and where they can be found in this application.
- The full recommendations for further consideration, page 23 of the charrette report, are as follows:-
- Character and Appearance
- Landscape-led Placemaking
- Adaptable & delightful buildings and Spaces
- Materials, detail and finish
- Progressing the CCOS Placemaking initiative -Technical work
- Place quality ambitions & Construction cost per m2 assumptions
- Planning Application Content and Detail
- Team and commitment to Vision and Ambition
The last point is demonstrably lacking in this planning application.
The way some of these recommendations are addressed in the Design and Access Statement indicates to usa clear lack of understanding of how to use the Masterplanning charrette process and conclusions. To quote from the report (which the applicant commissioned in addition to the charrette outcome):- “A design charrette is a fast paced process with the ability to develop, explore and assess design ideas and concepts from a range of perspectives and work through complexities collectively. Unearthing and then addressing detailed technical questions during a charrette without having the necessary detailed studies to hand, highlights some of the limitations. Working with highly experienced facilitators with considerable technical expertise and a broad range of local stakeholders is one way of mitigating some of these limitations, however, design charrette design concepts need to be further tested through detailed technical studies.” The applicant has failed to give anything but a cursory mention to these recommendations, nor has it given any details of how they were incorporated in the plans.
- The applicant held a Community Design Review in January 2019. The resulting recommendations are not set out in the Statement of Community Engagement for this application. It is therefore impossible to know whether they influenced this application.
- The condemnation by the community of the previous planning application and its subsequent withdrawal were due in no small part to the disregard of the recommendations that came out of the earlier community engagement, thereby engendering a lack of trust between Council and community.
- The Statement of Community Involvement states that the work which the applicant undertook prior to the competition does inform this planning application, but is misleading. See page 13 of part 1 of the Design and Access Statement.
A ‘Design and Access Statement can aid decision-making by enabling local planning authorities and third parties to better understand the analysis that has underpinned the design of a development proposal.’ The applicant has failed to give sufficient information in this document to third parties, such as the local community to see if, where and how their work has been incorporated into the plans. It is deeply disappointing that all the hard work, and indeed labour of love of the community, has been brushed aside by the landowner and its development team.
It remains to be seen what the final form is of any new legislation is, but it is quite possible that by the time a planning application for CCOS North is submitted, it will be necessary to comply with the community engagement – not just community consultation – requirements that will be imposed by both Building Better, Building Beautiful and Building for the Future. It will be a great pity, affecting a prime area of central St Albans to its detriment for decades to come, if the two separate parts, CCOS South and North, are not designed using similar processes, one community-led incorporating the community’s own design codes, and the other with next to no community involvement. The outcomes are quite likely to be very different.”
Officers of Look! St Albans Our Community Voice on Design
Vanessa Gregory Chair
Mel Hilbrown Vice Chair
Chris Debenham Treasurer
James Gregory Secretary