Letter to Brighton & Hove City Council on Queens Road planning application

Dear Emily (Case Officer) and cc Liz Hobden (Head of Planning),

Ref: BH2022/03428 Proposal: Erection of front extension at seventh floor to create 1no. new two-bed flat (C3) with roof terrace. Addition of an extra storey to create 2no. new two-bed flats (C3) with front and rear roof terraces. Infill existing lightwell at first to fifth floors to provide 200sqm additional office space (E). Erection of front extensions at fifth and sixth floors. Provision of enclosed stairwell to the northern side elevation. Re-clad windows at front elevation.  

I’m writing to share my concerns about planning application BH2022/03428 to develop the site at 125 Queens Road Street from commercial, business and service units into residential self-contained flats and office space. This is further to my representation regarding the prior approval application for the same site, BH2023/01234, which has since been withdrawn.  

Potential impact on local grassroots music venues   

I've been in contact with representatives from the live music industry in the city, who have expressed concerns about this application and its possible impact on grassroots music venues in my constituency. The concerns being raised by industry representatives, and many local residents, is due to the proximity of the site to three popular grassroots music venues, The Hope & Ruin, Rossi Bar and The Folklore Rooms.  

As the MP for Brighton Pavilion, I am acutely aware of the need for additional housing in the city, and also the preference for brownfield sites to be utilised for this purpose. However, I share the concerns of the Music Venue Alliance (MVA) and Music Venues Trust (MVT) about the potential risks a housing development could pose so close to established live music venues. I actively lobbied the Government about the need for better protections for live music venues and, I pushed for, and I support, the agent of change principle which is relevant for this application. As Brighton and Hove City Council will be aware, the agent of change has been incorporated into the National Planning Policy Framework (NPPF), which notes that:    

"187. Planning policies and decisions should ensure that new development can be integrated effectively with existing businesses and community facilities (such as places of worship, pubs, music venues and sports clubs). Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed."    

I note that the MVT have submitted an objection to this planning application and make some important points, including expressing concerns about the absence of any noise survey. Without a noise impact assessment (NIA), it cannot be said with any confidence that the proposal has given due consideration to the existing soundscape and impact of the proposed development on the local area – this is especially important given the presence of balconies and a roof terrace in the plans. The lack of an NIA also means that there is no documented acknowledgement of the three music venues nearby and undermines both national and local planning policy, given it conflicts with protections offered by the agent of change principle, as incorporated within the City Plan Part Two, as well as the NPPF.  

The local live performance and creative arts sectors are not only essential to Brighton & Hove’s tourism offer and night-time economy, they are a fundamental part of the city’s identity. Grassroots venues like The Hope & Ruin, Rossi Bar and The Folklore Rooms play an important role nurturing new local talent,  as evidenced through the city’s remarkable and proud export of successful local bands and artists. It is vital that councillors considering this planning application reflect the spirit of the agent of change principle in any planning decision in order to ensure that the futures of these venues are  not placed at any increased risk by new developments. When this application is discussed by the Planning Committee, I encourage councillors to ensure that the importance of these venues is taken into full consideration, and that the fabric of the city's music scene is properly recognised and sustained. Protections need to be in place to ensure that any new development does not create a potential noise nuisance issue which could later threaten the existence if live music venues.  

Fire safety   

Another further area of concern relates to fire safety. I note that the latest comment from the Health Safety Executive (Dec 2022) raises serious concerns about multiple aspects of the developers’ plans regarding means of escape and fire service access and facilities. It is important that these elements are carefully considered and scrutinised by councillors when considering these plans as, at present, from the information I have seen in the planning documents to date online, HSE as a statutory consultee are not satisfied the application meets the relevant fire safety standards.  

Yours sincerely,

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