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Gloucester Centre Demolition (Objection) G#38285

By 1 April 2020December 14th, 20202020, Blog, Campaigns, Current, News, Objections
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Gloucester Centre Demolition Objection

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Gloucester Centre Demolition Objection

Revised Outline Planning Application

  • Ward Councillors request for comments to present to the Planning Committee
  • Local Residents response

Gloucester Centre Site Phased Demolition Full Planning Application

20/00411/PRIOR | Phased demolition of all buildings within the site | Gloucester Centre Morpeth Close Orton Longueville Peterborough PE2 7JU

Planning policy relevant to this application:

Quotes taken from Peterborough @Environmental Capital Winter 2019 E- newsletter

Declare a Climate Emergency:

Comments on planning application:

20/00411/PRIOR | Phased demolition of all buildings within the site | Gloucester Centre Morpeth Close Orton Longueville Peterborough PE2 7JU

Three Applications relating to this site

  • The separation of the three (so far) planning applications including the mitigation, demolition, and development lends itself to no coordination, leading to lack of joined up thinking, joined up design, joined up development control and joined up public scrutiny and feedback, no joined up resource efficiency and waste minimisation on site.
  • Will there be a separate planning application(s) for:
    • Tree/shrub/hedging protection, translocation storage, replanting, felling?
    • Tree felling to suit a new site layout yet to be tabled let alone approved?
  • Is this a ploy to simplify the applications, complicate feedback and enable discounting of points raised in one application related to both primary and secondary applications; and deter residents from giving any feedback?
  • Are the development parties running rings around the development control?
  • Are development control enabling this?
  • Or do Development Control have no teeth and no say in Permitted Development?
    • And resident have so say at all?
    • This is completely unacceptable and undemocratic

Due Process

  • The application was validated 18th March 2020
  • On the 31st March the local residents were advised by the OL Parish Council that the deadline for comments is 1st April 2020 (April Fools day prank?) or are the PCC rushing this through the system to try to avoid public scrutiny or feedback?

The Application

  • reference suffix: ‘/PRIOR’
  • Does this mean PRIORITY? PRIOR to a Full application? PRIOR to action?
  • Further Information: Application Type: ‘Prior Approval’
  • Does this mean it has been approved and the application is just a formality?

Covering letter:

  • ‘Prior Notification Application’ and ‘application for prior notification is submitted to advise of the proposed demolition’
  • Is this being processed as if ‘Permitted Development?
  • Due to the site having prior use is it being treated as a brownfield site and anything is possible or permitted without full planning scrutiny under ‘Permitted Development’?
  • ‘Buildings are considered surplus to requirements by NHS’
    • At the time of a global pandemic it seems to be premature to demolish existing NHS buildings that may be urgently necessary for hospitalisation, isolation or recuperation
  • ‘It is considered that permitted development rights are provided for’
    • Does this mean that the local residents have no say and the planners have no control over the demolition of this site?
    • It is unusual for planners to permit early demolition of a building, in case the development does not go ahead and normally force the demolition as close as possible to the establishment of a contract to build.
    • Considering there is a live planning application but no current site plan on the table;
      • how do we know this site will be developed?
      • how does anybody know if the proposed retention of selected trees will not clash with any proposed road, footpath, cycleway, SuDS ponds, Bat barn, Bat posts, housing plots and building locations?
      • Is there a risk that trees that are being proposed for felling, not needing to be felled when the developers layout finally arrives.
      • None are shown, there is no coordination, no joined up thinking, no joined up design, no joined up development control, no joined up public scrutiny, risk of on site errors and on site deliberate errors
      • Will there be a 4th planning application by an actual developer, to fell even more of the remaining trees because they clash with their housing layout?
    • Does this rushing through of this application enable the development parties do anything they want?
      • Does case law record that Permitted Development permits all manner of turning a blind eye on activity by development control and Developers know this and exploit this?
    • What bargaining happened in that meeting between development parties and development control?
    • “If you offer to do this, we will let you do that”?
    • or worse still
    • “If you do this, we cannot stop you”?
  • Phased demolition
    • There is no demolition plan on the planning portal
      • Please ensure it is posted in time for scrutiny and feedback
    • Where are the two phases depicted?
      • Please ensure it is posted in time for scrutiny and feedback
    • What protection has been proposed for the bat mitigation bat barn and the bat roost poles and flights into and out of them all?
    • Is the demolition planned to occur during the coronavirus restrictions?
      • Will the plant drivers be able to remain isolated in their cabs and continue working?
      • Will the Arboriculture Supervisor be prevented from visiting the site?
    • Do the phases clash with school holidays (if the coronavirus restrictions eases)
    • Do the phases clash with birds tree use, nesting, foraging?
    • Do the phases clash with bat tree-use, roosting, foraging, flight paths?
    • Do the phases clash with other protected wild life use of the site?
  • Site notification
    • During the coronavirus pandemic
      • Is posting a notice ‘essential work’?
      • This notice will not have come to the attention of the public, so due notice has not been served
      • Just another box ticking exercise with no substance?

Planning application form:

  • Question 4 Describe which buildings re to be demolished
  • Response: Refer to site phasing plan
    • There is not Demolition or Phasing plan as part of the Planning Portal submission
    • There is no current live site plan to compare with this application
  • Question 4 describe the proposed method of demolition
    • There is not mention of bat, bird or wildlife mitigation activity or provisions
    • There is not mention of or timing of decanting bats to mitigation provisions
    • 1c Closing of roads should be considered now it is the interest of local residents
    • 1c Routing of demolition arisings vehicles should be considered now, ditto
    • 1f What decontamination is anticipated?
      • 2a Asbestos removal, any other? Medical waste?
    • 1g Protection of trees, 5 Trees show tree roots will not be fully protected
      • If these trees fail will they be replaced by mature trees?
      • Can the partial protection of trees be extended to protect tree roots once the hard paving has been raised?
    • 3 Is any effort being put into reclaiming any construction materials for reuse? Resale or gifting into construction reclaim markets
    • 4 Onsite crushing
      • Where will the arising materials be stockpiled so as not to interfere with preceding mitigation, retained tree roots and subsequent hard, soft and wet landscape works?
    • 5 What materials will be used for infilling of voids if no excavations for foundations and below ground services are not to happen immediately
  • Question 4 Disposal?
    • This is the time to impose challenging environmental obligations
    • 6F2 can be used for temporary works so will be removed from site and disposed at landfill
    • 6F2 can also be used a permanent sub bases or roads and buildings
    • Type 1 can be used for permanent road sub bases
    • The proposals are simplistic without any detail allowing the development to do the least possible without further scrutiny
    • Set some challenging segregation targets for recycling centres and minimise permitted disposal
  • Question 4 Restoration?
    • Changes of level
  • Question 4 Rights of way?
  • Response: No
    • But the public cycleway and footpaths pass through the site
  • Question 4 Felling Trees?
  • Response: No
    • But the arboriculture report shows over 100 trees are affected the site
    • Over 60 are to be retained and protected
    • 5 are to be partially protected
    • 7 are to be relocated (but not where)
    • Over 40 are to be felled
    • In respect of the separate Bat Mitigation Planning Application
    • Question 10 Trees and Hedges: Are there trees or hedges on land adjacent to the proposed development site that could influence the development or might be important as part of the local landscape character?
    • Response: NO
    • This does not acknowledge the site boundary hedgerow and tree line, nor the adjacent proposed residential site that has nearly 100 mature healthy trees and many shrub areas in existence that are absolutely important as part of the landscape character and vital for the sustainability of the existing wildlife.
    • See also separate file on local residents comments about the surrounding trees adding so much to the area, a real impression of living in the countryside, reasons to come here, reasons to stay and reasons to leave if the trees are felled.
    • At least 4 of the existing trees are known to be home to insects that are food for the bats.
    • Unquestionably the remainder of the trees, bushes and planting support biodiversity, their loss will result in loss of biodiversity on this site.
    • See Separate file on observed wildlife on site and surrounding estate much of which disappear into the site’s planting for cover and foraging.
    • Other observed wildlife on the site includes: Foxes, Hedgehogs, Deer, Birds
    • What provision is being made for these?
  • Question 5 Site visibility
  • Response: No
    • But the site can be seen from the road, sliproads, verges, cycleway and footpaths.
  • Question 6: Pre-application Advice
  • Response: No
    • But the site is subject to:
      • An Outline Planning Application for housing
      • A Full Planning Application for Bat mitigation measures
    • Pre-application advice has been sought in the meetings between:
      • Development parties, development control and residents representatives?
      • Development parties and development control?
    • Absent Question 8: Protected and any unprotects wildlife Adaptation or Mitigation issues
      • There is not even a question in the standard template about
        • Presence of wildlife protected or otherwise
        • Avoidance of changes
        • Mitigation if changes can not be avoided
      • Blanket commitment in national or local plans and policy are useless if standard template application forms avoid the issues altogether,
        • get this issue sorted, or planning control looks and is incompetent

Arboriculture Report

  • Conveniently dated ‘March 2020’ not by date so audit trails can be as muddy as you like
  • What provisions related to Coronavirus Pandemic?
    • Protection, Felling or demolition without Arboriculture Supervision?
    • Is that possible what ‘crimes’ can be committed when nobody is looking
    • Trying to fix a ‘crime’ after the event is not easy, better to control it here
  • 3.1 Demolition Planning permission not listed
    • Since Tree felling is not mentioned in the application
    • Is Tree felling the subject to a separate planning application?
    • Wild life mitigation measures planning permission is not listed here
    • Protection of those measures and flight paths to and from them is essential
    • These provision are not located on the included site plan and so not coordinated
    • Will there be a separate site plan showing the mitigation measures, flight paths and their protection?
  • 4 Programme
    • TBC
    • This needs to be coordinated with the Agent’s supporting letter and planning application
  • 5 Prohibited activities
    • Is there any provision for modifying protection areas?
      • Increasing protection areas when pavement has been removed to protect roots
      • Any scope for protecting roots exposed by removal of pavement
    • 6 Limitations
      • Detailed report is not part of the Planning Application
      • Can it be posted on Planning Portal in time for public scrutiny and feedback
    • 1 Arboricultural Supervision and table 2-1
      • Since the loss of trees (as well as buildings) has led to bat and bird mitigation measures
      • Should the mitigation measures be referred to here and offered the same protection?
    • 3 Tree Removal
      • No mention of Bat habitat regulations?
    • Table 2-2 Tree removals
      • 23 No. trees listed for removal but the site plan shows 44+ No.
        • Why the discrepancy?
        • What ‘crimes’ will be committed with this discrepancy?
        • (21 No. trees could be felled unnecessarily)
        • Please ensure they correct the discrepancy before planning permission is given
      • Table 2-3 Tree Translocations
        • 7 No. trees are scheduled here but site plan shows 8 No.
          • Why the discrepancy?
          • What ‘crimes’ will be committed with this discrepancy?
          • (1 No. tree could be felled unnecessarily)
          • Please ensure they correct the discrepancy before planning permission is given
        • Where are the trees identified for translocation to be planted?
        • Is there a plan for the proposed development showing these locations?
        • Is there any commitment by Development Control to ensure they are used on site?
        • Is there any requirement to work to any standard for root ball size, shape, protection and maintenance and excavation shape and size and backfilling and restraint support until established?

2.5 Tree Protection Fencing

  • Protection to roots once paving is lifted?
  • Protection to bat mitigation measures?
  • All weather bat mitigation notices?
  • Inspections of protection after demolition until construction complete
  • Height not specified (below canopy or 6 feet?)
  • Access gate secured to same level (anti tamper)

2.6 Works within protected zone

  • What suitable ground protection will enable tree sustainability
  • Good topsoil to cover roots: this well need the fences extending to protect from erosion
  • ‘Removal of underground services’: title implies services can be removed, consider retitling ‘Disconnection of underground services’
  • Special considerations:
    • Thank you for making obligation to protect retained trees near demolition of buildings this is really appreciated.

Site Plan

  • Please note discrepancies between Table 2-2 (21 No.) Table 2-3 (1 No.) and site plan, noted above
  • What ‘crimes’ can be committed with discrepancies?
    • (22 No. trees could be felled unnecessarily)
      • Please ensure they correct the discrepancy before planning permission is given
    • No extension of the tree protection to protect the exposed roots and added topsoil
    • Existing cycleways and footpaths are not shown as protected at any stage of the works
    • No coordination with proposed development plans
      • Roads, cycleways, footpaths, SuDS, Building plots, houses, below ground services
    • No coordination with Bat mitigation proposals and flight paths and their protection

Comments by local residents

We have studied the proposal and we have some reservations.

  • A great deal of effort has gone into surveying the trees and hedgerows and listening to the concerns of local residents who wish to see them all retained, some in particular for their character and produce to support biodiversity, bats in particular.
  • It is a generous effort to make plans to save some of the trees and make alternative provisions for bats and birds (subject to disjointed other planning applications)
  • But in the absence of a current let alone actual development plan all of the good point remain at risk of erosion later.
  • No site layout coordination with:
    • Tree layout means trees may be felled unnecessarily
    • Trees may be retained in this application and a subsequent application may call for some or all of the remaining trees to be felled, wasting all this effort
    • Trees to be translocated may not have a place in the new plans
    • By ignoring other well established shrubs and bushes that form foraging grounds and protection to wildlife on the site
    • Bat and bird mitigation measure, flights into and out, inquisitive public interference; and their protection
    • SuDS for the proposed development
    • Rerouting of footpath, cycleway and its lighting to accommodate SuDS

Other planning application related to this site

  • We wish to refer you to our feedback on the Bat and Bird mitigation measure which fail to meet published recommendations which is detailed to enable corrections.

Maintaining Biodiversity on the site and surroundings:

  • We will continue to object to the proposed residential development, which proposes to demolish existing bat roosts and fells so many of the 96 mature trees, some of which are known to be bat foraging ground and food-source tree species.
  • However if the residential proposal gets bulldozed through the planning process unscathed, then we want some assurance that the documented and observed wildlife on the site and surroundings is to be maintained, enhanced and not just abandoned.
  • This includes all of the trees, hedgerows and shrubs and all the wild life that is support by them and their food chain.

GCD campaign group
Monday, 31st March 2020 – 1st April 2020

Important precedents

  • Peterborough claims to be “Environment Capital”
  • Peterborough City Council (PCC) has numerous Environmental and Biodiversity Policies
  • Peterborough Environment City Trust (PECT) expressed concern that PCC had not yet Declared
  • PCC has now Declared to the Climate Emergency Campaign on Carbon reduction and Biodiversity protection
  • PCC has adopted a Doubling of Biodiversity policy replacing existing policies

GBE Quotes

  • “Aspire to become, what you desire to appear”

Facebook Group Page

Campaign Email Account

  • Not everybody is on facebook, so another means to keep residents informed
  • Gloucester Centre Development Action Group: 6-8 active members
  • A dozen resident’s, not on face book, email addresses

Development Public Display

  • Held in Community centre remote from site in question
  • No Public Consultation, just display of intention
  • Representatives did not know the scheme, so could not answer residents questions
  • Leaflets ran out rapidly, so many residents had nothing to take away
  • Leaflets showed the existing not the proposed
  • The Proposed was on display
  • Feedback forms for residents to email or post
  • Pinterest Section Public Display

Residents House to House calls Notes

  • We visited all the surrounding estate streets and knocked on all doors, approximately 500.
  • We informed residents and asked for their comments and recorded them.
  • We have a very unbalanced infrastructure, due to the wonderful fast dual carriageway ‘parkways’ delivering many cars in rush hour to a wholly inadequate Oundle road, we get grid-lock and cars backing up onto the ‘parkways’ beyond the previous junction.
  • In doing so we discovered that there are actually 6 different rush-hour rat-runs criss-crossing the estate affecting all roads except cul-de-sacs.
  • Adding 100 more houses and their 200+ cars and directing them all through an already congested residential estate would just put so many more at risk:
    • School pupil cyclists, pedestrians young and old, parked vehicles.
  • See all the comments:
  • Gloucester Centre Site A08BRM230619 Residents Feedback PDF

Site Photographic Survey

Biodiversity observation by Residents

Planning Application (PA)

Residents Planning Objections

  • Go to Planning Portal to the Application
  • Other tabs include residents feedback
  • Well over 100 comments/objections were posted by residents
  • We still need more.

© GBE GBC GBL NGS ASWS Brian Murphy aka BrianSpecMan **
4th October 2019 – 14th December 2020

Gloucester Centre Demolition Objection

FaceBook Group Page

Gloucester Centre FaceBook

Gloucester Centre Residents FaceBook Page

Demolition Objection

Gloucester Centre Site Demolition Comment A00BRM010420 clean PNG

Gloucester Centre Site Demolition Comment


Development Public Displays

Leaflet Posting

Gloucester Centre Site A5 flyer

Residents Tree Survey

Residents Wildlife Survey

Development Outline Planning Application

Residents critique of Outline Planning Application

Gloucester Centre Site BuildingForLife12 A02BRM051019 PNG

Resident Objection A3 Poster  Campaign

Gloucester Centre A3 Objection Poster

© GBE GBC GBL NGS ASWS Brian Murphy aka BrianSpecMan **
1st April 2020 – 14th December 2020

Gloucester Centre Demolition Objection
See Also: 

GBE Case Studies

GBE Building Case Studies

GBE Case Study Objections

GBE Information

National Policy Framework

Local Plan

Local Plan Improvement Campaign

Climate Emergency Declaration

Climate Emergency Response

GBE Jargon Buster

© GBE GBC GBL NGS ASWS Brian Murphy aka BrianSpecMan **
1st April 2020 – 14th December 2020

Gloucester Centre Redevelopment Objection END

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