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Ms. Jeanette Walsh, Head, Planning Control,
Brighton and Hove City Council.
April 22nd, 2013.

Dear Ms.Walsh,

RE: BH2012/04048 – The Brunswick Development Amendment to Condition 70

The above application has raised many significant technical planning matters, deficiencies and unanswered questions – and again exposes the highly contentious nature of this development, its legitimacy and desirability to proceed.

It has been well documented that this is by no measure a ‘minor’ amendment in a technical sense. Prof. John Watts and Robert Powell, as the original architect for the Marina and architect and town planner respectively, are both eminently qualified to raise genuine and proper concerns. They should not be ignored for the sake of expediency. As Chairman of the Kemp Town Society, I urge your most generous consideration to the objections based on their detailed critiques. Allowing the amendment will regrettably permit perhaps the most serious planning error to be inflicted on Brighton for generations to come. The photos tell the real story.

BHCC as the Marina Freeholder has a vested interest in consenting to the amendment and therefore both responsibility and liability to protect its asset. As Councillors, it carries additional personal culpability. The following questions need to be asked and answered.

Building the car park below sea level will increase the costs of the development by a considerable margin. It is the most expensive part of building construction. It is by no means a minor change.

1) What financial feasibility has been offered to justify the additional cost of the amendment? Do you know what these costs are?

2) Has the committee seen the full financial feasibility with the projected marketing price of the units with the scheme before and after the changes?

3) Have these unit prices been commercially tested? It is expected they will have to command London prices to cover their development costs.

4) What measure of (financial) guarantee has been given by the developer should the development become commercially unviable during the course of construction?

5) What would BHCC do if they surrender it and BHCC is forced to exercise its rights as landlord to take over the development? Have you checked BMA Part V Sec 58?

6) What use will the vacated space be put to in Buildings A to D?

7) What is the commercial gain in shifting the parking into buildings F1 and F2.

8) What evidence has been provided that the removal of the concrete wave barriers and installation of the new tidal barrier has been properly costed? What are these costs?

9) The piling for these buildings will take many months, if not more than a year. What has the developer offered the community in return for the noise pollution and disturbance from the drilling and pile driving?

10) Where is the traffic report? The increased traffic from the 496 spaces competing with the increased bus services on the same access road must be necessary. Other public users of the Marina to access the same road to the multi-story car park has not been assessed.

11) What study has been found acceptable to permit the excessive shadowing from the block F1and F2 over the most commercially viable part of the Marina’s existing promenade?

In addition, it should be minded that this development fails to:

1) preserve the primary purpose of the Marina – by the safe relocation of the RNLI station and loss of over 80 berths

2) provide housing which is proportionate to the scale of the existing Marina buildings

3) protect sea and sky views of others in the Marina

4) integrate in a holistic approach with other plans which will eventually re-emerge for the larger commercial areas of the Marina – as demanded by the City Plan D2.

5) maintain sea views from the Conservation Areas of the adjacent Beach

6) Preserve Brighton’s seafront heritage.

It is our position, that without professional and independent auditing from a fully recognised Construction Cost Management firm with experience of construction in a location exposed to the high winds and waves, this amendment under consideration must be questioned as part of the overall financial feasibility.

Brighton and Hove Council can ill afford to take such a project over should it fail.

Therefore without full comfort to the foregoing questions, the amendment should be rejected.

Thank you for your time and consideration to these matters.

Yours sincerely,

signed

Paul Phillips, Chairman

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