A summary of Third-Party objections to CNM’s RPH site planning application as were presented to North Somerset Council during the consultation process:

The Royal Pier Hotel site as seen from above by a drone.

Local public opposition to these proposals has been extremely strong. Of the 477 public comments received by NSC throughout the consultation process 452 of these stood as objections and were heavily against this development as currently presented by CNM.

Weston-super-Mare Town Council

Weston-super-Mare Town Council has strongly objected to the proposed development scheme, indeed citing the opposition presented by BCG’s own petition. Although quite short in length, their considered input encapsulated all of the regularly-expressed major concerns very well:

OBJECTION:

The Town Council object on several grounds.

1) The height impact of the proposed new building is out of keeping and deemed to have a detrimental impact on the character and amenity of the Prince Consort Gardens.

2) The size of the units are not considered appropriate for residential apartments.

3) The parking provision is inadequate and will have a detrimental impact on off street parking in the vicinity.

4) A significant petition has been lodged by the Ward Councillor for the area.

Weston-super-Mare Civic Society

Weston-super-Mare’s Civic Society raised a more detailed objection to this application in three separate parts. The first of these, dated 13 December 2021, stated: “It is very strange that in the Landscape and Visual Impact Assessment various views are shown annotating the site location but do not show the impact of the proposed building.”

Due to the high level of opposition already being demonstrated, CNM organised in early February 2022 the release of a more recent supply of documents showing the visual impact of the proposed development as compiled by their lead architects Darling Associates Ltd and graphic visualisation consultants Nicholas Pearson Associates.

The second of the Civic Society objections stated on 20 February 2022: “In order to preserve the essence and elegance of the original and existing Victorian terraces any development of this site needs to be of a similar scale.”

The third added four days later in the form of a supplemental letter recorded that: “Further to the Design Review whilst agreeing with many of the findings of the Review Panel we note within the report reference is made to how the proposal ‘terminates an important piece of townscape’. The Civic Society view is that any building should not ‘terminate the townscape’ but allow the edge of the bay to flow naturally towards the sea and visually along to the Old Pier, as it is now. A less ambitious scheme is more appropriate.”

North Somerset Design Review Panel

Another appraisal of the updated scheme, dated 22 February 2022, was conducted by North Somerset Design Review Panel. This, in various places, stated: “Overall, the proposal needs a clearer architectural rationale”; “The proposal still appeared to be too bulky”; and “The Panel thought the eastern elevation was unsympathetic in scale to its neighbours, as demonstrated in the visuals.” Also: “Generally, there is still a need to understand the historic context in more depth and consider further the response of the building in three dimensions and how it complements the heritage context.”

Historic England

Historic England also weighed in quite heavily on the matter of CNM’s refreshed RPH proposals.

They submitted a further formal consultee comment on 11 March 2022. Various parts of their letter to NSC’s Principal Planning Officer state: “We wrote to you on 16 December 2021 in response to these proposals. We expressed broad support for the principle of the site’s redevelopment, but highlighted the need for additional information to be supplied to demonstrate the visual impact of the proposals. We also suggested that the proposed development lacked refinement and therefore could fail to respond to the character and appearance of the surrounding conservation area. We are now able to provide further comments, which should be read in conjunction with those of our previous letter.

“The site is within the Great Weston Conservation Area, and close to the Grade II* listed ruins of Birnbeck Pier, a site which has long featured on Historic England’s register of Heritage at Risk. There are many Grade II listed buildings nearby.

“In response to our concerns and those of other stakeholders, the applicant has now supplied a series of visualisations demonstrating the visual impact of the proposed development. The scheme has also been reviewed by a Design Review Panel.

“The additional information supplied and the analysis by the Design Review Panel confirms our view that at present, the proposals would fail to respond to the character and appearance of the Birnbeck Conservation Area by virtue of their design, scale, and massing. We endorse the comments of the Design Review Panel in their written critique of the proposals.

“The visualisations supplied confirm that the proposed development would have an overbearing impact in several key views. Views towards the Bristol channel from Prince Consort Gardens would be masked by the proposed building. The form of the proposed development would fail to respond to the adjacent listed buildings of Claremont Crescent. In longer views from the beach and Grand Pier, the stepped upper levels of the proposed development would visually coalesce and read as one mass.

“There are aspects of the proposals that we admire; in particular its materiality, and the proposed continuation of the rusticated stonework of the promenade walls to ground the building and assimilate it with its townscape context.

“However, a significant issue with the proposed development is, in our view, the lack of refinement in the land-facing elevation of the building. Here is an opportunity to extend the gentle curve of Claremont Crescent, and create attractive public realm which encourages the visitor towards Birnbeck Pier. But instead we have the two wings of the proposed development meeting at an awkward junction, alongside an underwhelming area of car parking. There are quite large areas of blank wall facing the highway screening bin storage areas, which fail to animate the building at pavement level. The geometry of the building should be revised to better respond to its context.

“The scale and massing of the proposed development remains a challenge. The building would significantly exceed the height of existing buildings nearby. In our view it would be advantageous for the building to be reduced in height to the point where its upper levels are roughly level with the horizon in views from Prince Consort Gardens.

“The proposals would harm the character and appearance of the Great Weston Conservation Area. National Planning Policy Framework paragraph 199, When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.

“Paragraph 200 goes on to advise that “Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification.” We can see that it is desirable to secure the redevelopment of this derelict site, but question whether the justification for harm to the conservation area is either clear or convincing.”

This letter, from Historic England’s Principal Inspector of Historic Buildings and Areas, then went on to make a series of recommendations:

“Historic England has concerns regarding the application on heritage grounds.

“We consider that the issues and safeguards outlined in our advice need to be addressed in order for the application to meet the requirements of paragraphs 199 and 200 of the NPPF.”

“If determining this application you should bear in mind the statutory duty of section 72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 to pay special attention to the desirability of preserving or enhancing the character or appearance of conservation areas.”

“Your authority should take these representations into account and seek amendments, safeguards or further information as set out in our advice.”

The Environment Agency

The Environment Agency submitted their own consultation reply on 25 April 2022 to the NSC planners on relatively technical grounds:

“The Environment Agency OBJECTS to this application as it is not supported by a Flood Risk Assessment (FRA) which adequately considers the flood risks at the site and to third parties. It must demonstrate that the development can be made safe for its lifetime (100 years), considering the impacts of climate change. We are therefore unable to determine if the development is in accordance with the National Planning Policy Framework (NPPF).

“An acceptable FRA is vital to making informed planning decisions. In its absence, the flood risks posed by the development are unknown. This is sufficient reason for refusing planning permission.

“The latest FRA by Hydrock Consulting (dated 16 July 2021) and the submitted development designs do not consider our comments from the previous planning application (11/P/0006/F) or our recommended conditions.

“While we removed our objection to the previous planning application, we did still have strong concerns regarding the tidal flood risk, the impact of climate change and wave overtopping at this development – particularly to the lower levels of the development.

“The FRA provides a general assessment of flood risk in this location, but it does not go far enough to discuss how the development design and layout may increase its exposure to flooding over its lifetime.

“This site lies on the edge of the coastline, adjacent to a sea defence, with an adequate standard of protection for today. However, climate change, must be addressed within the development’s design.

“The development proposal includes residential on the ground floor level, car parking and retail units at lower ground floor levels (-1 to -3). The lower ground floors also include the promenade level which could be subject to wave overtopping. The FRA does not mention how these lower levels and different uses within the development could be exposed to tidal flood risk, wave action and climate change.

“The FRA also does not include the still water tidal level or discuss how sea level rise will affect the building layout (using the guidance on gov.uk). The FRA does not discuss the effects of surge or weather conditions which will increase wave overtopping at the site.

“An assessment of breach and overtopping using the level 2 SFRA has been undertaken within the FRA, however this is located to the south of the development site. A site-specific assessment must be provided to address overtopping and breach directly at the development (both today and with climate change).

“The FRA must also address the extent of wind and wave action, wave overtopping and climate change. A wave overtopping assessment must be carried out to quantify the level of risk above the still tidal water level over the lifetime of the development. This will help to determine the level to set appropriate mitigation to ensure the safety of the users of the development.

“The FRA must also discuss safe access and egress from ground floor and lower ground floor levels. FD2321 Flood Risks to People Phase 2 (discussed within section 2.3.5 of North Somerset’s Level 2 SFRA) can also be used to assess the flood hazards, speed and onset of flooding and impacts of climate change at the site.”

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