From:                                         Alistair Lewin <ALewin@oxford-architects.com>

Sent:                                           05 May 2017 16:52

To:                                               Eatough, Richard

Subject:                                     RE: The Butler PH, Chatham Street, Reading, applications 170590/FUL and 591/LBC

Attachments:                          15191 Planning Validation Checklist - dec16.pdf; 15191_P02_AExisting GF.pdf; 15191_P10_A Proposed GF.pdf; 15191_P11_A Proposed FF.pdf; 15191_P23_Existing FF.pdf; 15191_P24_Precedent Study.pdf; Butler Planner Response 05.05.17.docx; BUTLER'S WINE VAULTS - 1113435_ Historic England.pdf; No Locally run accommodation within 500 m.jpg; Photographic Record - 28.04.17.pdf; Proposed 'Heads of Terms' 05.05.17.docx

 

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Dear Mr Eatough,

 

Following on from your previous email please find attached our response along with additional supporting documentation.

 

If you have any further comments or questions please do not hesitate to contact us.

 

Kind regards,

 

Alistair

 

 

 

	Alistair Lewin
	The Workshop	T:  01179581500
	254 Southmead Road	D:
	Bristol. BS10 5EN	F:  01179581501
	www.oxford-architects.com

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Dear Mr. Lewin,

 

I refer to your planning and LBC applications for The Butler PH Chatham Street in Reading and apologise for the delay in replying to you, but I am afraid the submissions are far from clear.  With your previous submissions/confirmations, your applications have passed our Stage 1 validation (National) requirements.  However, the submissions are currently a long way short of being able to passed for Stage 2 validation and are therefore these applications are invalid.  I explain why below.

Description of development:

This is unclear for both applications.

In the planning application, it is not clear what the existing (established planning) use of the site is, nor is it clear what the proposed use of the site is.  My supposition, on the basis of what has been submitted, is that the current use may be that about half of the site is B1c light industrial (tyre fitting), the other half A4 drinking establishments (pub).  In proposed use terms, the hotel (it looks more akin to a motel) would be the dominant use and the pub would be relegated to an ancillary use.  Is this your understanding of the proposal?

The LBC description should summarise the extent of the works required to the listed structures as a result of the proposal (see below).

Please clarify/amend the descriptions accordingly.

I would refer to you our adopted Validations Checklist for stage 2 validation requirements.  The following information is required.

 

Planning statement

A planning statement, setting out a full discussion of the various applicable planning policies (3x plans in the Council’s LDF and associated SPDs) is required.  For instance and as a starting point, the site is within allocation site RC4a in the Reading Central Action Plan, which is an allocation for residential development.  How does your proposal intend to comply with this, because to my reading, it does not.   There needs to be a comprehensive assessment against all relevant planning policies with clear reference to the use/works proposed and explanation of the planning balance taken.

There is insufficient information in the DAS about sustainability.  The DAS says that the B Regs will be met, but does not say how and clearly there are going to be tensions between the requirements of the Regs and the fabric of the LB.  The proposed rationale needs explaining.

The planning statement needs to explain existing and proposed transport impacts with reference to trip rates, our policies/SPD, the uses involved, etc. in a transport statement.

The planning statement should also explain the suitability of the site for the intended use in terms of air quality.  You are introducing sensitive receptors (hotel bedrooms) into this site, which is within the Council’s Air Quality Management Area (AQMA).  The Council’s EHOs may latterly require  an air quality assessment to be submitted.

The planning statement also needs to demonstrate suitability in terms of noise to the sensitive receptors.  A noise statement may latterly be requested.

The planning statement (or separate document) may also need to include an ecology survey, for instance, in relation to any unused roof areas of the building(s) which may have bat roosts.

The planning statement needs to include Heads of Terms for a s106 agreement, relating to (but perhaps not limited to) the control of hotel/motel functions and how improvements to the pub will be delivered as part of these proposals.  I would suggest that you are essentially trying to present this as an ‘enabling development’ in order to offer certain benefits to the Listed Building, but without having set out the necessary delivery mechanisms for ensuring such – whatever they are – will be secured.

 

Heritage statement/assessment:

The other key area of information missing is a suitable heritage statement.  This needs to be a comprehensive heritage assessment in accordance with NPPG/NPPF guidelines and as set out in our validation checklist.  The DAS includes a heritage statement but this is not sufficient in terms of assessing the merits of the Heritage Asset, identifying significance of the asset (and parts of the asset) and the impact of works to be undertaken.  Supporting information should also justify why the works are suitable in terms of the advantages and disadvantages to the LB and significance in terms of the character/fabric/setting of the Listed Building.  How are the buildings going to be refurbished?  What works will be undertaken?  Many parts of this development are going to be part of the Listed Building: either ‘curtilage listed’ or listed by being physically attached to the LB.  A full schedule of works should also be submitted for the LBC application, including setting out all detailed works and use of materials.

 

Summary of advice:

I am, of course, glad to see that this proposal would appear to have a minimal impact on the setting to the LB, but the impact on the fabric and the suitability in planning terms is far from clear.  As an informal comment at this stage this appears to be a poor proposal, not a bit like what was discussed at pre-app in 2015 and poorly presented. 

My advice is that you may need specialist planning and heritage input to tie this all together, if you are continuing with these applications.  However, my personal opinion is that these proposals may not be supportable anyway, and would strongly suggest withdrawal and for a detailed pre-application to take place if you wish.

I will need either a response on all the matters above or a confirmation of withdrawal within 28 days, please.  Otherwise, these applications will be filed as ‘returned’, meaning that the applications have effectively been returned to you and no further progress or a decision will be made on them.

 

I look forward to hearing from you.

Regards

 

 

 

Richard Eatough

Principal Planning Officer

Planning Section | Directorate of Environment and Neighbourhood Services

 

Reading Borough Council

Civic Offices, Level 1 North

Bridge Street

 

Reading

RG1 2LU

 

0118 937 3338 (73338 internal extension)

Email: richard.eatough@reading.gov.uk

 

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