Development Control Sub-Committee

29th June 2011

Agenda Item 4

Ward: ALL

Key Decision: Yes / No

Report by the Executive Head of Planning, Regeneration and Wellbeing

Planning Applications

The Committee is requested to consider the following planning applications in accordance with the power contained within section 70 of the Town and Country Planning Act 1990 which states:-

(1) Where an application is made to a local planning authority for planning permission—

(a) subject to sections 91 and 92 (time limits), they may grant planning permission, either unconditionally or subject to such conditions as they think fit; or

(b) they may refuse planning permission.

(2) In dealing with such an application the authority shall have regard to the provisions of the development plan, so far as material to the application, and to any other material considerations.

1 Application Number: WB/10/0852/OUT Recommendation - Members views are requested on this interim report.

Site: Teville Gate

Proposal: Outline application for the demolition of existing buildings and erection of a mixed use development comprising multi screen cinema, restaurants and cafes, foodstore, hotel, health and fitness centre, offices, multi-function conference and exhibition centre, two residential towers containing 229 apartments together with 19 apartments on a new residential frontage to Teville Road and 12 apartments on a new residential frontage to Broadwater Road, 967 car parking spaces together with a new partially covered pedestrian arcade, landscaping and urban realm and access arrangements.

2 Application Number: WB/11/0249/FULL Recommendation - WB/11/0249/FULL – & WB/11/0250/LBC APPROVE

WB/11/0250/LBC – APPROVE

Site: The Burlington Hotel Marine Parade

Proposal: Resubmission of WB/10/0596/FULL and WB/10/0564/LBC for retention of signage and re-positioning of some existing external lighting.

1

Mr C Blatchford WB/10/0852/OUT Hanson Capital Management Limited CEN JA Location : Teville Gate Worthing

Proposal: Outline application for the demolition of existing buildings and erection of a mixed use development comprising multi screen cinema, restaurants and cafes, foodstore, hotel, health and fitness centre, offices, multi-function conference and exhibition centre, two residential towers containing 229 apartments together with 19 apartments on a new residential frontage to Teville Road and 12 apartments on a new residential frontage to Broadwater Road, 967 car parking spaces together with a new partially covered pedestrian arcade, landscaping and urban realm and access arrangements

Not to Scale

Reproduced from OS mapping with the permission of HMSO (c) Crown Copyright Licence No LA100024321

1. INTRODUCTION

The above application proposes a complex high-density, mixed-use development on the former Teville Gate shopping centre site. Major development proposals such as this clearly require careful and detailed scrutiny and there are a number of matters that still need to be resolved in relation to highway matters and Section

106 contributions including affordable housing. Further negotiation is still required to resolve these matters, however, it is considered important that the Planning Committee resolves a number of key issues at this stage to give the application and potential operator’s confidence to continue with the project. In particular, this interim report seeks Members views on the principle of a large foodstore on the site and the design, scale and massing of the scheme having regard to the previous permission for tall buildings on this site.

The planning application would need to be reconsidered once all the various negotiations have been completed and this is likely to require amendments to the planning application and/or addendums to the current Environmental Statement (ES), which will require further publicity and consultation. The development will require a detailed Section 106 agreement relating to the provision of necessary infrastructure contributions and the scheme would need to be re-assessed once Heads of Terms have been agreed. This report, therefore, seeks Members’ views on the scheme, as currently submitted, to assist in the negotiation process.

2. THE SITE AND SURROUNDINGS

The application site extends to 1.718 hectares (4.245 acres) and lies in a pivotal position at the intersection between the coastal railway line and the A24 leading into the town centre. The site has a gentle fall from north to south of approximately 1.5 metres. The site lies approximately 150 metres to the east of Worthing’s main railway station and 0.9 km north of the seafront.

The development site includes the now partially demolished 1960s Teville Gate shopping centre, which includes the multi-storey car park for 344 cars located in the northeast corner of the site. There are two main elements to the multi-storey car park. The higher section incorporating six decked parking levels is situated in the north east corner of the site. The lower section extends to the south, parallel with Broadwater Road, and contains a retail store occupied by Comet on the ground floor with three levels of parking above. The grey concrete skeletal form of the multi storey car park dominates the main approach road into the town. It provides a stark and unattractive frontage to Broadwater Road at a point where there is a clear transition from the residential development to the north of the railway line to the more commercial and civic buildings leading into the town centre. The lack of any active frontage is exaggerated by the long blank façade of the Morrison’s store on the opposite (east) side of the road.

The eastern boundary of the site, formed by Broadwater Road is dominated by the busy dual carriageway which is elevated from grade in the south to a height of approximately 4.5 metres above the level of the site as it rises to bridge over the railway which lies to the north of the site. The width of the road, together with the level of traffic, creates a fairly inhospitable place for pedestrians being dominated by vehicles, highway barriers and street furniture. To the south west of the site a new block of flats Norfolk House has been built incorporating retail units on the ground floor although these units have remained vacant since the development was completed. The flats rise to 7 storey’s in height adjacent to the roundabout junction with Newland Road.

On the Teville Road frontage, the site includes the four-storey office building, “Burfree House”, which used to be occupied by “Steeles” car showroom on the

ground floor with offices above. The flat roof office block is architecturally bland in appearance and the car storage and sales areas (which still continue) in front of the building, gives the frontage a cluttered and unattractive appearance. The intention of the original 1960s shopping development was to ‘funnel’ pedestrians into the pedestrian street running diagonally through the site with small-scale retail units with flats above on either side. Apart from the Comet store, there are only four small retail units remaining with only two currently occupied one as a Pharmacy and one as a bedding shop. The existing public realm is very poor with a lack of any active road frontages. The access road to the car park which loops around the frontage of the site, together with the poor urban townscape and profusion of metal highway barriers around the site effectively creates an ‘island’ site with little visual connection to the railway station beyond or the town centre to the south.

To the north of the site there is the service yard which serves Morrison’s foodstore to the east with service access beneath the bridge via Railway Approach. Opposite Teville Gate House there is an attractive knapped flint two storey building (Sandell House) which used to be the original railway Station building. This is Grade II listed building dating back to 1845. The former Station building is attached to Capella House, a modern three storey office building. Further to the north of the railway line, there are single storey car repair workshops and a three storey block of flats, Carlyle House occupying a backland location. Teville Gate House, a three-storey office building forming part of the original Teville Gate development is now included in the enlarged development site as well a building to the rear previously used for auctions.

Immediately to the west of the site on the Teville Road frontage is an MOT and tyre/exhaust repair centre (Kwik Fit). Further to the west is Colliers a kitchen showroom which has buildings backing onto the site. To the west of Teville Gate House is the Grand Victorian Hotel a Grade II listed building. Various single storey buildings adjoining the sites western boundary have been converted to form a night club.

To the south of Teville Road there is a mixture of two and three-storey traditional Victorian terraced cottages. A 4 storey development of flats occupies the former Rivoli Public House site on the western side of Chapel Road at its junction with Teville Road.

3. SITE HISTORY

The Teville Gate Shopping Centre was built in 1969 and originally comprised of 26 retail units (extending to 3,530 sq m), six of which were approved with flats above and the remaining 20 with storage at first floor level, a retail kiosk and a multi storey car park (344 spaces) with a large retail unit below (1,115 sq m). This was originally a supermarket but is currently occupied by Comet. The total retail floorspace originally provided on the site was approximately 4,600 sq m.

Planning permission has been granted for two separate leisure related schemes on the site. Full planning permission was granted in 1999 for demolition of the multi-storey car park and redevelopment with a two storey leisure and retail complex including a nine screen multiplex cinema (with a total seating capacity of

up to 2,100 seats), two restaurants (1,131 sq m), a new retail unit (1,387 sq m), new multi-storey car park and surface car park (WB/98/00788/FULL refers).

Outline planning permission was granted on 16 July 2001 for a two-storey leisure development proposing the demolition of the front part of the existing Teville Gate centre, including the retail unit occupied by Comet and part of the multi-storey car park above (WB/01/00410/OUT refers). The development included the erection of a two-storey building, which would accommodate four restaurants at ground floor level (1,565 sq m) together with an eight-screen cinema on the first floor. A single storey element was proposed to the rear of Burfree House, which would provide a leisure unit including D2 and A3 uses, potentially for occupation by a health and fitness operator. This permission has now lapsed.

In June 2006 an outline planning application was submitted for the demolition of the retail units and multi-storey car park on the site and the erection of a new public swimming complex with associated health and fitness centre, multi-screen cinema, indoor bowling centre and bingo club, ancillary restaurants, shops and cafes, two residential towers (one at 18 levels and a second at 11 residential levels) containing 235 apartments together with 25 apartments on a new residential frontage to Teville Road, 635 basement car parking spaces together with a new partially covered pedestrian arcade, landscaping and access from Teville Road. Planning Committee resolved to grant planning permission in July 2007 subject to a section 106 planning obligation. Planning permission was eventually granted in 2010 following the completion of the legal agreement.

4. REVISED PROPOSAL

This revised proposal is to demolish all the existing buildings and to redevelop the site for a mixed use development comprising the following key elements:

o Two residential towers one at 17 residential levels and a second at 14 residential levels containing 229 apartments (1, 2 and 3 bedrooms) together with 19 apartments on a new residential frontage to Teville Road and 12 apartments on a new residential frontage to Broadwater Road. o Class D2 leisure floorspace in the form of a 9 screen multiplex cinema totalling circa 3,520 sqm or circa 1,375 seats. o Class A3 food and drink uses comprising circa 4,000 sqm floorspace at ground, first and second floors. A range of restaurants, cafes and other eating and drinking outlets is proposed with a focus on operations complimentary to the main leisure uses and reflecting a family orientated leisure offer. o A foodstore totalling 8,510 sqm gross (circa 4,830 sqm net).The applicant indicates it is in advanced discussions with Sainsbury to operate the store. o A conference and exhibition centre totalling circa 3,435 sqm. o A health and fitness club (circa 1,385 sqm). o A 88 bedroom hotel fronting Railway Approach o 4 floors of offices totalling 2,780 sqm fronting Railway Approach. o 967 car parking spaces to serve the proposed uses and to provide public spaces to replace those within the existing Teville Gate multi-storey car park. Parking to be provided in two areas (a below ground car park of circa 400 spaces) and decked car parking totalling circa 560 spaces. Access is proposed from Teville Road and Railway Approach.

o Enhanced public realm including to Railway Approach and a new Arcade and Piazza. o Access improvements including the signalisation of adjoining roundabout junctions and improved accessibility for pedestrians and cyclists.

The revised layout contains a number of the key elements of the previous approval with the pedestrian access running diagonally through the site, two residential towers and a mix of retail and leisure uses including cafes and restaurants. The multiplex cinema (9 screens) remains as do a significant number of A3 units of various sizes (restaurants and cafes). The number of residential apartments remains the same at 260 although greater emphasis has been placed on improving the quality of the accommodation creating larger, more spacious, apartments (to create a high quality ‘city living’ concept).

The key differences are the incorporation of the large foodstore, an hotel, conference hall/exhibition space and the provision of a replacement multi-storey car park rather than underground parking. There is, however, one deck of basement car parking serving the foodstore (400 spaces) accessed as before from Teville Road. The replacement multi-storey car park would utilise the existing service road via Railway Approach with a ramped access serving upper decks. The multi-storey car park would have three decks providing, in total, 567 car parking spaces. The multi-storey car park would effectively be hidden on three sides by other elements of the scheme. The top floor of car parking for 44 spaces would also enable direct access to the conference hall/exhibition space.

The revised scheme has been designed on a regular grid pattern with the two residential towers reconfigured and realigned. The previous scheme incorporated two lozenge shaped towers with curved glass running parallel with the diagonal walkway. The revised design provides two towers on a north south axis with an ‘elliptical’ form slightly broader then before but 7 metres shorter in length (now measuring 55 metres). The eastern tower has been repositioned further northwards and the western tower slightly further south. The revised tower design incorporates open balconies with glazed screens on the southern ‘prow’ whilst the rear portion has less glazing and a randomised façade treatment of aluminium rainscreen cladding. Overlaid in a regular grid pattern would be coloured squares which are intended to be illuminated at night. The northern stern, using the ship analogy, is curved with south facing balconies providing the transition between the two elements of the tower. The top 3 floors on each tower are to be set back from the ‘prow’ with a glazed southern section and the top floor penthouse fully glazed.

The repositioning of the towers provides a larger public realm area in the south- east corner of the site. A circular pavilion is provided within this area of open space (The Piazza). This south-east corner of the site is raised approximately 1.5 metres above existing pavement level to provide a degree of spatial separation and to create the opportunity for planters and new trees to create a sense of enclosure. This also has the benefit of removing unsightly pedestrian barriers that wrap round the south-east corner of the site. Pedestrians are lead around the central pavilion with wide staircases and ramps leading down to road level. Although the application is in outline form the only matter to be reserved is landscaping. Nevertheless indicative plans have been submitted showing areas of planting around the site including terraces and roof top gardens. An indicative scheme is also submitted showing a revised highway arrangement for Railway

Approach and public realm improvements including an opportunity for a large piece of public art.

On the ground floor western half of the site the large foodstore dominates, having a frontage onto Teville Road of 70 metres which tapers to the north of the site to 45 metres with an overall length of 100 metres. Access to the foodstore would be via travelators from the basement car park barriers would control access and egress from the car park. A mezzanine above the store would provide restaurant/ café. The entrance would be on the east elevation as would the entrance lobby for the western tower. To the rear of the foodstore, there are three A3 restaurants/cafes, a car park lobby and entrance to the hotel. Servicing to the foodstore would be via Railway Approach through two roller shutter doors. On the eastern side of the walkway (arcade) would be further A3 food and drink establishments with access to the nine screen multiplex cinema.

Above the foodstore entrance would be a health and fitness facility and fronting Teville Road, three floors of residential flats. The multiplex cinema bridges across the two commercial and leisure levels forming a covered arcade which should be 35 metres long. On the northern elevation of the arcade, it is proposed to have a large video display screen which it is indicated could be used to promote events within Worthing Gateway and within Worthing itself for pedestrians leaving the station and heading from the town centre. The southern elevation of the arcade would be formed by two glazed bridges connecting the eastern and western elements of the scheme.

The 88 bed hotel located on the north elevation is located over five floors with the majority of bedrooms formed on the top floor wrapping around a triangular rooftop garden. Either side of the hotel on the lower levels would be B1 offices on three floors. The conference and exhibition centre would sit above the decked car park set back 22 metres from the Teville Road frontage. A projecting covered screen incorporating solar panels (providing power to run external lighting) would provide an attractive outside area in addition to a with a large south facing, landscaped terrace. A south facing terrace is also provided adjacent to the health and fitness facility. To increase biodiversity and the setting of the residential towers green roofs are provided above the Arcade and on the Broadwater Road and Railway Approach frontages.

The previous permission on the site retained the roundabout junctions and although it sought to improve the Teville Road pedestrian crossing, the public realm improvements outside the confines of the site were limited due to the existing road layout and infrastructure (although a contribution was to be made to improve Railway approach). The previous scheme created a high quality arcade through the site but was compromised as the scheme did not include Teville Gate House and the existing roundabouts were retained serving the site.

The revised scheme now proposes to signalise the roundabout junctions with Teville Road and Newlands Road and to significantly enhance pedestrian movement to and from the site. New or re-positioned pedestrian crossings are now proposed on each arm of the signalised Teville Road/Chapel Road junction as well as a new crossing over Broadwater Road to the north of the Newland Road junction. The scheme, as originally submitted, proposes an ‘all red phase’ to the signals to allow all pedestrians to cross at the same time using straight across routes. Whilst the applicant had hoped that a more radical solution might

be possible to remove all highway clutter and barriers around these junctions, the current plans seek to remove all barriers around the site boundary at the Teville Road/Chapel Road junction and replace these with raised planters and trees to create a landscaped frontage and improved public realm. However, this aspect of the scheme will have to be revised as the Highway Authority has expressed concern at the increased waiting times for pedestrians to cross and the knock on effect on congestion and the free flow of traffic through these junctions. At the present time the applicants Highway Consultant has submitted various options including returning all or some of the pedestrian crossings to more traditional staggered crossings.

5. APPLICANT’S SUPPORTING STATEMENTS

Environmental Statement (ES)

A full Environmental Statement (ES) is submitted in support of this application, which analysis, in detail, the likely environmental effects of the development. An Environmental Impact Assessment (EIA) is required as the development falls within Schedule 2, Category 10B of the EIA regulations, as an urban development project which, due its scale, nature and location has the potential to give rise to significant environmental effects. The EIA considers the environmental effects of the development during construction and operation, once the scheme has been completed and proposes ways to prevent, reduce and, where possible, offset significant adverse effects. The ES presents the methods and findings of the EIA process.

The ES and supporting appendices are, therefore, central documents in assessing the environmental impact of the proposed development and a full set of these documents is available in the Members’ room. The principle studies, which have been undertaken as part of the EIA are:

Appendix 2.1: EIA Scoping Report; Appendix 2.2: Scoping Opinion; Appendix 9.1: Transport Assessment (Volume 4); Appendix 10.1: Air Quality Assessment Data; Appendix 11.1: Descriptions of Noise and Vibration Units; Appendix 11.2: Noise Survey Procedures and Results; Appendix 11.3: Assessment Methodology and Significance Criteria; Appendix 11.4: Road Traffic Noise; Appendix 12.1: Preliminary Environmental Risk Assessment; Appendix 13.1: Flood Risk Assessment (Volume 5); Appendix 14.1: Archaeological Desk Study; Appendix 15.1: Daylight, Sunlight and Overshadowing Drawings; Appendix 15.2: Daylight and Sunlight Results; and, i) Air quality, noise and vibration assessments; ii) Flood risk assessment; iii) Archaeological assessment; iv) Daylight, sunlight and overshadowing study; v) Pedestrian wind conditions desk study; vi) Transport Assessment (TA); vii) Townscape and Visual Impact Assessment (VIA); viii) Urban design, Architectural and Tall Buildings Statement.

Appendix 16.1: Pedestrian Wind Conditions Desk Study.

The Environmental Statement includes a summary of the residual environmental effects that are anticipated during demolition and construction, and on completion of the Development. Residual effects are those effects, that may be either adverse or beneficial, that would remain following the implementation of the various mitigation measures. The following is an extract from the Environmental Statement which summarises the potential residual effects of the proposed development.

A number of other supporting documents are also included with the ES:

Planning Statement, prepared by Blue Sky Planning; Design and Access Statement, prepared by Russ Drage Architects; Retail Statement, prepared by White Young Green; Transport Assessment, by Waterman Transport and Development; Statement of Community Involvement, produced by Brian Rickart Limited; Sustainability Statement, prepared by Waterman EED & Waterman Building Services; Sustainable Energy Report, prepared by Waterman Building Services.

The conclusion or summary of some of these reports are set out below. However, given the complexity of this scheme Members are encouraged to view the supporting statements which are available in the Members Room.

The Design Access and Tall Buildings Statement concludes that,

“The design of these proposals has been undertaken in the light of, and with reference to CABE and English Heritage's Guidance on Tall Buildings July 2007. This document has also been a point of reference in discussions, workshops and reviews with Worthing Borough Council and the SERDP. It is therefore appropriate to conclude this Urban Design Architecture and Tall Buildings Statement by once again evaluating the final proposals relative to the EH/CABE criteria as outlined in the following sections.

The Relationship to context and Historic Context

Extensive urban design appraisals were undertaken by both the Design Team (as summarised in the accompanying summary document Urban Design Analysis and by Planit Group who also undertook the visual impact assessment element of the Environmental Statement. The design has therefore been brought forward

in the context of a robust understanding of context, topography, scale, height, urban grain streetscape and existing built form.

The preparation of the consented scheme which underwent a full environmental assessment itself, including a visual impact assessment, has helped to feed back into the redesign process and assist in bringing forward the updated, current proposals. It is precisely the understanding of the schemes relationship to context that has enabled a comprehensive rethinking of the proposals whilst adhering to the Local Authority and HCM's aspirations for the site. A full account of the visual appraisal methodology and the resulting appraisal is included within the Environmental Statement.

In relation to specific CABE/EH points:

Scale

It has been generally established and agreed in the Town Centre Masterplan, and as demonstrated within the consented proposal that the site is appropriate for a development of a suitable density and height given its gateway location, relationship to the main arterial route into Worthing from the north and the overall accessibility of the site which lies adjacent to the station and town centre.

Any building over 3 or 4 storey’s will inevitably be 'tall' in the context of Worthing, however the current 77.5 m and 60.2 m (approximately 26 and 20 storey) elements of the scheme are placed within a deep site effectively surrounded by large scale, busy transportation infrastructure that currently separates the site visually and physically from the town.

The scale and massing of the new proposals responds to the gateway nature of the site, the scale and infrastructure dominated nature of their setting, and to changing viewpoints throughout the town. The relatively small volume of the towers enables the generation of a slender, elegant profile and the stepped, tapering profile of the towers, their reduced length and extended height responds to their perception in east/west views.

Height

Like scale, the height of the proposals has been determined in relation to the scheme's local and broader context. It is the local views that have proved to be the most sensitive and which largely informed the design of the consented scheme and which established the principles that form the current proposals. The final height was judged on the basis of; the tower's visual impact as the backdrop to views from surrounding streets and open spaces, the need to avoid any adverse environmental impact or loss of residential or other amenity, and the generation of a scheme of appropriate aesthetic proportions.

The comparison between the current proposal and the consented scheme demonstrates that the highest point of the scheme (the western tower) is approximately 3.7 m higher than the consented building. The eastern tower is approximately 12.0 m taller than its consented equivalent. In addition both towers have an additional plant enclosure at roof level that adds a further 4.3 m to their overall height whilst further articulating the silhouette and profile of the scheme. This comparison is illustrated at Figure 36.

The changing scale of the buildings facing the main street frontages address and respond in an appropriate manner to the enclosure of Teville Road, Broadwater Road and Railway Approach. However the scheme also includes a new street and public realm, reconnecting the town to the station with a pedestrian scaled sense of enclosure making a valuable addition to the townscape of the town centre.

On the whole the heights established within the consented scheme have been used as a benchmark in the design of the latest proposals, the one exception being the new Conference Centre. Here the building is approximately 8.0 m higher than the Cinema roof that occupied a similar location within the consented scheme. However the curved nature of the roofscape with low eaves, set backs from the main street elevations, and a highly modelled western gable elevation help to create a suitable scaled civic building that is largely non-visible from the surrounding streets.

Urban Grain

The proposals establish a new urban block (extended due to the inclusion of Teville Gate House) with new public realm generated in response to the existing urban form and which will consequently help to mend a large hole in the fabric of Worthing.

Streetscape and Built Form

The team's understanding of streetscape and built form have been reinforced in the generation of the latest proposals which have developed the ideas established in the consented scheme and the findings of their urban analysis and urban design objectives.

The proposals include new meaningful areas of high quality public space, new active frontages and key urban landmarks in the form of new building nodes, corners and features. These are connected by the new Arcade to become part of the fabric of Worthing. In addition a resident population and public activities will be established that will stimulate continuous life and activity.

Effect on Skyline

The Worthing skyline contains few significant 'tall' buildings, and to this extent these proposals will have an important effect on the town's skyline.

From a long range the VIA work demonstrates that the new 'cluster' will be visible, clearly acting as a landmark, but will not be detrimental to coastal views, views along the coast or to Worthing from the South Downs. At close range the modelled, sculpted nature of the towers and the roofscapes of the other components that make up the scheme present a new and varied profile when seen from key view points. The towers present a clear visual marker for the new activities and spaces within Teville Gate and increase legibility of the route to the Railway Station.

Listed Buildings

The new scheme's relationship to the station, Railway Hotel and the listed cottages to the northern side of Railway Approach has been carefully considered. Whilst their setting and backdrop will inevitably change, the establishment and reconnection of Railway Approach as a pleasant and active space within Worthing will dramatically improve the public's access and enjoyment of these buildings and facilitate a wholesale improvement in their overall setting and the quality of public realm.

The scale of the new Railway Approach elevations has been modulated in relation to the scale of the listed buildings, and the use of masonry in this area reflects the character of Railway Approach as a whole.

Historic Parks, Gardens, Open Spaces, Views Prospects and Panoramas

A visual analysis of the proposals reveals that the tallest sections of the development will be visible from the south facing slopes to the north, marking the edge of the Sussex Downs. This includes views from Cissbury Ring and Highdown Hill, where the development is viewed within the context of the surrounding urban area and will provide a striking new landmark within the town centre.

Along the flatter coastal plain, the ribbon of built form that extends along the coast tends to restrict clear views of the Worthing skyline, which are probably best viewed from the beaches to the east and west of the town. From these seaside locations, the tower elements will provide a new vertical landmark against the town skyline.

The urban area of Worthing includes a number of public spaces and parks that provide a leisure and recreation function. The taller elements of the scheme will be clearly visible from the local parks of Victoria Recreation Ground, Homefield Park and Manor Sports Ground but will not adversely affect the setting of these open spaces. Nearer to the sea front, lie the more ornamental gardens of Steyne Gardens and Beach House Park. Views out of these open spaces are restricted by mature tree cover, which entirely screens views of the development.

Views from Worthing’s promenade are focused along the seafront and out to sea, with minimal views inland. Worthing Pier will however, afford views back towards the town and lies on axis with the development site. Some glimpsed views of the development will be possible from the southern end of the pier providing a directional marker for the site, but not dominating or adversely affecting the setting of the pier.

The two towers are most clearly perceived on approaching the site along the north/south axis of Broadwater Road. A key principle of the design has been to create a landmark development that marks the gateway into the town centre from the north. The development provides a strong sense of arrival and through its architectural quality, re-defines the image of a degenerated site.

Relationship to Transport Infrastructure

One of the proposals is to increase connectivity and the permeability of the site and the adjacent Railway Station for pedestrians and the public in general. The site lies at the geographic 'centre' of Worthing, and is therefore accessible to the largest number of people by the shortest possible routes. New routes within the site, and the improvement of routes around the site, add to the connectivity together with improved legibility from within the town.

Waterman's transportation and highways Engineers have produced a Transport Assessment Report (TAR), which has been submitted in support of this application. The TAR assesses the effect of the proposed development on the local highway network and the accessibility to the Site for pedestrians, cyclists and public transport. It also assesses the current usage of the public car park at the Site. The scope of this report has been discussed and agreed in principle with WSCC Highways Department and WBC.

The main conclusions of this report are as follows:-

The site is suitably located relative to the local and strategic road network. The site has good pedestrian and public transport accessibility. Bus accessibility will be further improved with the provision of a new bus lay-by, shelters and seating on Teville Road, and by the remodelling of Railway Approach to be both more pedestrian permeable and to accommodate the planned Coastal Transportation System when their proposals are more fully developed. The existing pedestrian/cycle link through the site will be significantly improved in terms of lighting and surfacing and will be relocated to run along the eastern side of the proposed building on the site. The proposals provide for better cycle access with improved cycle facilities at the proposed signalised junction on Teville Road. The proposed parking and servicing provision is considered adequate for the size of development proposed and is in accordance with the adopted standards. To promote sustainable transport choices in line with National and Local Policies, a Company Transport Plan is proposed, which will encourage the use of alternative means of transport other than the private car. The proposals include new signalised highway junctions and extensive remodeling of the highway network in response to initial junction capacity assessments. This has the added benefit of facilitating new straight across pedestrian crossings, greatly improving the accessibility of the site and public transport. Within the proposed 967 spaces, 150 public car parking spaces related to the station are to be retained on the site, which is considered adequate based on the existing parking demand.

Architectural Quality, Scale and Form

Scale and Form

The current proposals have evolved following a fully iterative design and evaluation process involving the full HCM team. At the heart of this process has been the objective to create a new, high quality, landmark building for Worthing which will have significant regenerative benefits for Teville Gate and the town as a whole.

As discussed in 11.01 the form and scale of the scheme has been at the forefront of the consideration of alternatives for the site. The HCM Design Team believe that the relationship of the proposal to its surrounding local neighbours at street level and the opportunity to create an elegantly proportioned and dynamic residential building rising up from the larger floorplate street level uses, reflects their high quality objectives.

Ongoing appraisal and testing have established that the building height has less impact from a wider viewpoint but that its impact as a backdrop to certain close range views has been a major determining factor in the final form of the building.

Skyline and Silhouette

Despite the light, facetted and modulated elevational appearance of the building it is recognised that at certain times of day, and in more distant views the building is likely to appear as a darker, silhouette where form and profile will by key factors. The tapering, pointed elliptical footprint of the towers is intended to generate an exciting, slimline profile, and to exaggerate verticality and slenderness, but also to articulate the form of the building by the manner in which light is reflected from its surface.

The skyline of each tower has also been modelled with a transition between the full floorplate and a more fully glazed reduced footprint 'penthouse' level which responds to, and reinforces the tapering nature of the plan form. At roof level a sculptural plant enclosures ensures a suitable cap to the scheme and the avoidance of roof level clutter.

Materials and Elevational Composition

The desire to generate a lightweight, ‘slippery’ visual form for the towers resulted in the decision to clad the building in glass for vision areas and pressed metal panels for the majority of the façade. High quality aluminium rainscreen panels will take up the curved form of the building and complement the more reflective glazed components.

The exposed coastal location has dictated the use of robust, self-finished no- maintenance materials which together with simple, flush and robust high quality detailing will ensure that the buildings continue to live up to their landmark status throughout their lifetime.

The strong geometry of the plan form is articulated in elevation by the use of a more fully glazed south facing ‘prow’ to the towers, together with a more randomised, cladding treatment to the north. These two complementary treatments help to articulate the vertical emphasis of the towers, and respond to changing views of the scheme from different locations in the town. The overall smooth, radiussed surface of the building is articulated by both its flowing form and the simple manipulation of planes. In this respect, horizontal bands of windows, balcony zones and the continuous 'neck' are recessed to varying degrees, reinforcing the horizontal 'stratified' nature of the building.

Contribution to External and Internal Public Spaces

These proposals seize the opportunity to generate accessible and useable new areas of public realm. The new south facing 'Piazza', Teville Road and Broadwater Road frontages, and Arcade are enclosed by new active frontages containing:

The new foodstore Main entrance to the Cinema and main restaurant floors Entrance lobbies to the residential towers Main public car and cycle park entrances Pavilion café and roof terraces

These activities are supported by a new, comprehensive hard and soft landscape scheme including tree and shrub planting, water features, lighting and new public seating areas. Tree planting will help to redefine public circulation areas, and reintroduce a missing element of green within the Worthing streetscape.

The Effect on the Local Environment

The proposals have been brought forward in response to the findings of the EIA which included microclimatic studies and a traffic assessment as well as general design objectives as follows:

Wind

A review has been undertaken of the anticipated wind conditions within the proposed development. The buildings themselves help to protect the site from the prevailing SW wind, and the public realm would be suitable for its intended use, providing sheltered areas suitable for sitting during the summer months. Whilst the roof terraces by their nature would be expected to be windier, with suitable landscaping and screening large parts of the terraces would be suitable for sitting during summer months.

Daylight and Sunlight

The development has been designed to minimise the impact upon daylight availability at surrounding residential property as well as within gardens and areas of open space.

An assessment of the effect on daylight and surrounding properties concluded that the majority of residential properties continue to receive daylight levels that meet or exceed BRE guidelines for daylight availability. However 6 rooms within Norfolk Mansions would be below the desired level. However, the daylight levels received by these rooms is not primarily as a result of the proposed Worthing Gateway development but can be attributed predominately to the balcony design of the property itself.

Traffic

The traffic generated by the proposed development can be safely accommodated on the upgraded local road network. The proposal include for a signalised

junction to facilitate improved pedestrian movements and accessibility to the train station.

Noise

The site has been assessed for its suitability for residential uses, and it was concluded that with a suitable glazing and ventilation strategy, which can be imposed as a planning condition, the internal living conditions would be in accordance with British Standards.

The potentially most widespread noise impact of the development is due changes in road traffic noise. However, it is estimated that for most road links the effect would be less than 3 dB and therefore be imperceptible. The greatest increase in noise levels would occur along the main access points to the site, namely a small stretch of Oxford Road and Railway Approach, which may have a minor adverse effect on the small number of residents on these routes.

The potential impacts of noise upon the existing and proposed noise-sensitive receptors from the commercial/leisure elements of the development can be controlled through the adoption of a noise management plan. Additionally appropriate specification of building services plant would limit the effect of noise from this source. Servicing and delivery would be managed to ensure that the noise effects would be negligible. These mitigation measures can be addressed by appropriately worded planning conditions.

In conclusion, subject to the imposition of design aims described above, no substantial adverse noise effects will arise from the development proposals.

Air Quality

The development would include the use of modern heating plant which would have improved efficiencies and low emissions as a result of tightened legislation. The detailed specification, and installation, of this plant would be in line with requirements of current Building Regulations. Consequently, it is considered that no unacceptable effects on air quality at local existing and proposed receptors would occur as a result of this plant.

The likely effect of traffic generated by the development has been assessed using detailed dispersion modelling. This has identified that the traffic would have a negligible effect on nitrogen dioxide or particulate matter (PM10).

Flood Risk and Drainage

In accordance with government guidance, a Flood Risk Assessment (FRA) for the site has been undertaken. The site is at low risk of flooding, however, given that the majority of the site would comprise hard landscaping and buildings it is important to ensure that the development does not give rise to an increased risk of flooding offsite. The development has been designed to attenuate surface water run-off via the use of green roofs, rainwater harvesting and surface water attenuation tanks. This would significantly reduce existing surface water run-off rates, thereby safeguarding against surface water flooding, even accounting for climate change.

Archaeology

An archaeological desk study has been undertaken, which identified that the site has only a limited potential for archaeological as a consequence of the Site having been affected by building works during the past 150 years with most archaeological remains likely to have been disturbed, fragmented or removed altogether. Any remaining archaeology at the Site is therefore likely to be of local importance only. The construction of a basement, would remove any remaining archaeological deposits at the Site. However, an appropriate programme of investigation and would be implemented to ensure remains are not removed without record.

Ground Conditions

Due to the historical uses on the site, there is potential for contamination on the site. A site investigation would be undertaken prior to construction to determine the exact composition of the soil, and identify the need for treatment. However, the construction of the basement area of the proposed development would remove any potential contaminated soils, ensuring suitability for its proposed use. Any materials taken offsite would be treated and handled in accordance with legislative requirements.

Night Time Appearance

A subtle scheme of solar powered night-time building lighting is proposed using belts of low energy, long life (25 year) LED luminaries. These will provide a 'glow' to a regular array of ‘dots’ that form a grid over the surface of the towers to unify the otherwise random pattern of illuminated windows within each tower. The more fully glazed 'prow' of each tower and the penthouse levels will be more fully illuminated by internal lighting and reinforce the night time appearance of the building.

Contribution to Permeability, Linkages and Legibility

These proposals reconnect Worthing Station to the town centre and reclaim a lost and valuable site to become a new place within the fabric of Worthing. The location of new public facilities, activities and spaces, together with a new resident population will establish a 'critical mass' on the site that will generate life and use for most of the day. This will further encourage the use of the new route through the site, and hopefully act as a catalyst to extend the influence and activities from the town centre towards the station to help reactivate Chapel Road.

New active frontages, streetscape and public realm will revitalise Teville Road and Broadwater Road and the new highway crossings will enable greater pedestrian permeability, accessibility and enable the removal of the east-west underpass and railway bridge staircase along the northern boundary of the site, to become a major new connection to the station from those living north of the railway.

The proposed treatment of key nodes and corners within the scheme reinforces the legibility of routes and public spaces, and the town as a whole as a consequence of the new towers which highlight Teville Gate and the station.

Provision of a High Quality Environment for those who use the Building

High quality city living is a primary objective of the proposals. All residents will enjoy spacious, efficient living accommodation in a major landmark building each with stunning panoramic views over Sussex.

In addition to the town centre location this new resident population will bring life and vitality to the new public spaces within the development on a 24 hour basis, augmenting the visitors using the new leisure facilities and pedestrians en-route to and from the station.

A new character and sense of place is established though the new buildings, active frontages and the major additions to the surrounding public realm will create a high quality environment for all those who use the buildings within the proposal.

Sustainability

The Sustainability Report which accompanies this application gives a summary of the sustainability objectives inherent in the design and those aspirational issues to be explored and developed during the detailed design stages of the project. The key issues may be summarised as follows:

Community

The local community has been extensively consulted and generally supports the proposals. The scheme provides new public realm, leisure facilities and a major new community facility. The proposals will regenerate a rundown part of the town centre and provide a new resident community will become established on the site. The Piazza and pavilion café offers a high quality meeting place for community interaction which is currently lacking in the area. The form of development takes account of the desire to create well connected and overlooked public spaces for safe pedestrian movement throughout the day.

Urban Form and Design

The site meets the strategic planning guidance for a landmark development, and re-uses a valuable town centre brownfield site. The form of development has evolved as a direct response to a detailed urban analysis and consideration of alternative solutions considering height, scale, massing, visual impact etc., as highlighted in this document. The proposals reactivate and revitalise a lost sector of Worthing Town Centre. The design has been informed by an ongoing consultation process with the Council, key stakeholders and the community. New areas of extensive public realm are central to the proposals. The proposals provide a high density scheme in an area which very good public transport accessibility. The scheme delivers a mix of uses including a variety of

residential and commercial unit sizes. This will provide for a mixed residential community as well as opportunities for new local retail facilities and other services to be accommodated within the proposals to complement those within the existing community.

Impact of Buildings

The new residential elements of the scheme are being designed to meet Code for Sustainable Homes Level 4 as a minimum, with commercial spaces meeting BREEAM – Very Good, with the opportunity for tenants to upgrade to Excellent. These sustainable design standards, together with the new Building Regulations requirements, will help ensure optimum environmental performance.

Transport

The site sits at a major public transport interchange and provides replacement car parking for the existing public car park serving the station and town centre. The proposals include for a signalised junction to facilitate improved pedestrian movements and accessibility to the train station and enhanced pedestrian footpaths within and around the scheme.

The development enhances an existing public transport node and improves public accessibility of the site and hence public transport infrastructure.

A new bus lay-by and shelter are proposed, together with measures to allow WSCC to facilitate the proposed Coastal Transport System when their proposals emerge at a later date.

New car parking meets the needs of the public and the new resident population together with new servicing and off road loading/unloading facilities.

The proposals also include for cycle parking for residents, employees and visitors. Up to 400 new secure cycle parking spaces and improved cycle provision at junctions are proposed.

The site lies at the geographic centre of Worthing adjoining the town's major residential areas enabling easy access for employees and those using the site's new facilities. The proposals also include a mix of uses which allow people to live, work and play in one location.

Energy

Building and site configuration has been designed to optimise passive design measures. A localised CHP facility is proposed with a district heating system servicing the residential towers and commercial uses on the site. Photovoltaic panels are proposed to supply subtle night time building illumination, and to light the interior of The Arcade by day. An energy efficient plant and equipment including the residential heat and hot water distribution system is proposed.

Water

The development has been designed to attenuate surface water run-off via the use of green roofs, rainwater harvesting and surface water attenuation tanks. This would significantly reduce existing surface water run-off rates, thereby safeguarding against surface water flooding, even accounting for climate change. The proposals include water efficient fittings and fixtures to minimise demand of potable water supply. Rainwater harvesting is proposed to irrigate the new soft landscape proposals.

Natural Resources and Waste

Local, recycled, low environmental impact materials including FSC timber, where possible. The scheme has been design to maximise natural daylight. A waste strategy has been prepared for the scheme to ensure adequate storage for recyclable materials and ease of use and servicing thereby promoting sustainable waste behaviour.

Ecology

New landscape proposals significantly increase the number of trees in the area, complementing the extensive areas of new public realm. Two new areas of living roofs and a green wall are proposed to enhance biodiversity on the site.

Business

A great opportunity exists for new local businesses within the new retail/food and drink spaces or complementary community facilities. The proposals will help extend the town centre to reactivate currently under utilised zones of street frontage, encouraging new business to become established.”

The Retail Statement concludes that,

“The application proposal seeks planning permission for the construction of a new foodstore, with associated car parking, delivery yard and vehicular access and highway improvements; forming part of a wider mixed-use development known as Worthing Gateway. The application site already benefits from an extant consent for a similar regeneration scheme with a retail element which clearly provides a strong fallback position for the applicant. The extant consent and the existing retail use on the site therefore mean that the ‘uplift’ in the proposed level of retail floorspace applied for is significantly less that than which has been assessed. Therefore the assessment is considered robust, and the conclusions made as a result are clearly based on a ‘worst-case’. In any event, in granting the extant consent on the site, the Council have clearly already accepted some level of impact as a result of a convenience store proposal in this location.

A new Sainsbury’s store would significantly improve the retail offer in this part of Worthing and would bring significant investment to the local area, stemming the leakage of retail expenditure to more distant destinations, and reducing the distances residents are required to travel. A large proportion of those in the central zones of the catchment area currently do their main food shopping at the Sainsbury’s store at Lyons Farm and the Tesco in West Durrington. Clearly with

a brand new foodstore in a central location surrounded by a high quality mixed- use development, Teville Gate is likely to divert a number of these shoppers, saving not only vehicle journeys, but also retaining locally generated expenditure much closer to the defined town centre.

An up-to-date household survey has demonstrated considerable overtrading of a number of main food shopping stores within and on the edge of the catchment area. This provides a good level of both qualitative and quantitative capacity for a new foodstore. The impacts described in Section 5 all leave the stores trading at a good level, and above company average in most cases. For example, the Tesco store in West Durrington is currently trading significantly above average, and even after taking account of a -6.55% impact on its turnover at 2017, it may still be overtrading by more than 50%. Furthermore, when cumulative impact with the committed new foodstore on the site of Country Fayre Garden Centre is assessed this does not reveal any levels to cause concern. The lack of any significant overlap between catchments of the two proposed foodstores, and the different offer they are likely to provide means that should both come forward, not only is there sufficient capacity to support both; there will be no significant adverse impacts on any other store or centre as a result.

Notwithstanding the proposal’s out-of-centre location, it has been demonstrated that there are no sequentially preferable sites in Worthing town centre that could accommodate a store of the size proposed, or anything workably smaller, having regard to flexibility. In any event, the application site is allocated for this type of mixed-use development, demonstrating that the Council considers such development in this location appropriate.

The application scheme seeks to make the most efficient use of previously developed land in line with the principles of sustainable development contained in PPS1 and PPS4. The proposed design will engage with the site and its constraints much more successfully than the existing use does and will enhance the character and appearance of the site and surrounding area. It will provide an appropriate ‘gateway’ to Worthing from the north. The requirements of PPS4 relating to the efficient re-use of previously developed land for such developments have therefore been met.

Due to the high potential for linked trips between the proposed store and the town centre, it is considered that local consumer choice will increase as residents will have the opportunity to visit Worthing Town Centre while carrying out their main food shop.

Furthermore, as the intention of the supermarket is not to compete with the High Street shops; and as the proposals will not have a detrimental impact on their turnover; the scheme will not have a significant adverse impact on local consumer choice. For the reasons set out above, we consider the development will have an overall positive impact.

It is considered that the proposed development is in accordance with relevant national and local planning policy, and with the recommendations made in the Council’s Retail Study.”

The Transport Assessment concludes that,

“The Site is well located relative to the local and strategic road network; The Site has good pedestrian and public transport accessibility due to its location although there are existing pedestrian and cycle road crossing conflicts; Public transport accessibility is good and provision will be made for West Sussex County Council to include their aspirations for their bus based Coastal Transport System at a later date; Additional bus facilities will be provided on Teville Road; There will be the provision of new pedestrians facilities on the A24 enabled by the construction of two new traffic signal junctions on the A24 to replace the Chapel Road and Newlands Road roundabouts; The junction assessment shows that the existing double roundabout arrangement adjacent to the site on the A24 should be replaced with the proposed traffic signal layout. This will significantly improve pedestrian facilities and accessibility to the town centre; Compared to the Do Nothing scenario the proposed improvements to the A24 junctions will ensure there is no overly significant affect on traffic whilst delivering much needed safety and accessibility improvements for vulnerable non car modes. These highway improvement proposals have been the subject of a Stage 1 Road Safety Audit (RSA1). The findings of the RSA1 generally supported the proposals and no significant issues were raised; Pedestrian access across Teville Road will be greatly enhanced due to straight across crossings and an all red pedestrian phase; The existing pedestrian and cycle link through the Site will be significantly improved in terms of lighting and surfacing; One of the net results of these proposals will be to significantly enhance the access between the town centre and the railway station for pedestrians and cyclists; The proposals provide for better cycle access including on site cycle parking; The proposed car parking and servicing provision is considered adequate for the size of development proposed and is in accordance with the adopted standards; In addition to the retail, leisure, office and residential provision some 150 public car parking spaces are to be retained on the Site, which is considered adequate based on the existing parking demand; To promote sustainable transport choices in line with National and Local Policies, Outline Travel Plan is proposed, which will encourage the use of alternative means of transport other than the private car; The junction analysis shows that although a number of existing junctions in the study area will experience marginally worse congestion as a result of the development. However, these junctions would still experience capacity problems in the future even without any development proposals at Worthing Gateway. In conclusion, it is considered that there are no reasons in highway or traffic terms why the proposed development should not be granted planning consent.”

6. CONSULTATIONS

Southern Water (Atkins Limited) comment as follows:

“The exact position of the public sewers must be determined on site by the applicant before the layout of the proposed development is finalised.

It might be possible to divert the public sewers and water mains, so long as this would result in no unacceptable loss of hydraulic capacity, and the work was carried out at the developer's expense to the satisfaction of Southern Water under· the relevant statutory provisions. Consents will be necessary for excavations in proximity to water mains.

Should the applicant wish to divert the public sewer apparatus:

1. The sewer requires a minimum clearance of 3 metres either side of the sewer to protect it from construction works and allow for future access for maintenance. More space may be required for large diameter or deep sewers. 2. No development or new tree planting should be located within 3 metres either side of the centreline of the public sewer. 3. No new soakaways should be located within 5m of a public sewer. 4. All other existing infrastructure should be protected during the course of construction works.

Alternatively, the applicant may wish to amend the site layout, or combine a diversion with amendment of the site layout. If the applicant would prefer to advance these options, items (1) - (4) above also apply. In order to protect drainage and water apparatus, Southern Water requests that if consent is granted, a condition is attached to the planning permission. For example:-

The developer must advise the local authority (in consultation with Southern Water) of the measures which will be undertaken to divert the public sewers, prior to the commencement of the development.

The developer must agree with Southern Water, prior to commencement of the development, the measures to be undertaken to divert / protect the public water supply main. Our initial investigations indicate that Southern Water can provide foul sewage disposal to service the proposed development. Southern Water requires a formal application for a connection to the public sewer to be made by the applicant or developer.

We request that should this application receive planning approval, the following informative is attached to the consent:

"A formal application for connection to the public sewerage system is required in order to service this development".

Alternatively; If the existing development discharges surface water to the existing sewerage system, then a discharge from the site may be permitted. If the applicant wishes to investigate this option, the applicant will be required to provide a topographical site survey and/or a CCTV survey showing the existing connection points, pipe sizes, gradients and calculations confirming the proposed flows will be no greater than the existing flows received by the sewer. Any excess surface water should be attenuated and stored on site. Where flow attenuation is proposed and the sewerage in question is to be offered for adoption, the sewerage undertaker should be involved in discussions with all relevant parties to agree the ownership/responsibility for the facility.

The applicant should be advised that a wastewater grease trap should be provided on the kitchen waste pipe or drain installed and maintained by the owner or operator of the premises.”

The Crime Prevention Design Advisor for Sussex Police comments that,

“The Safer Places document from the ODPM, (2004) offers a good practice guide for the creation of well designed and safe places through the planning system. The Crime & Disorder Act 1998 heightens the importance of taking crime prevention into account when planning decisions are made. Section 17 of the Act places a clear duty on both police and local authorities to exercise their various functions with due regard to the likely effect on the prevention of crime and disorder. You are asked to accord due weight to the advice offered in this letter which would demonstrate your authority's commitment to work in partnership and comply with the spirit of The Crime & Disorder Act.

The level of crime at this location is high when compared to the rest of Sussex and although I do not have any concerns with the proposal, I was disappointed to note that the Design and Access Statement submitted in support of this application failed to mention the crime prevention methods considered in the design and layout. Guidance on Information Requirements and Validation (CLG 2010), Section 6, Paragraph 132, states, "PPS1 makes clear that a key objective for new developments should be that they create safe and accessible environments where crime and disorder or fear of crime does not undermine quality of life or community cohesion. Design and access statements for outline and detailed applications should therefore demonstrate how crime prevention measures have been considered in the design of the proposal and how the design reflects the attributes of safe, sustainable places set out in Safer Places - The Planning System and Crime Prevention".

In an endeavour to reduce the opportunity for crime and the fear of crime I offer the following comments.

I ask that consideration be given to the implementation of the Seven Attributes of Safer Places which will assist in planning crime prevention and promoting community safety for the development which can be incorporated into the design and layout.

The residential dwellings to aspire to achieve Secured By Design accreditation. I direct the applicant’s attention to our website www.securedbvdesion.com for further information on design and layout as well as physical security. Car parks throughout the development to apply for the Park Mark Safer Parking Scheme. www.parkmark.co.uk

Lighting throughout the development to conform to 8S5489-1:2003 and should be commensurate with any proposed CCTV system considered.”

The Environment Agency comments,

“The proposed development partly overlies the London Clay Formation and the Lambeth Group; the latter is classified by the Environment Agency's Groundwater Protection: Policy and Practice as a Secondary Aquifer. Both

formations are underlain by the Seaford Chalk Formation which is classified a Principal Aquifer. Due to the structure of the geological formations it is likely that groundwater may be encountered under artesian conditions which may require control during construction works. Therefore groundwater at this location is sensitive to activities which may lead to deterioration of groundwater quality.

We consider that planning permission should only be granted to the proposed development as submitted if the following six planning conditions are imposed as set out below. Without these planning conditions, the proposed development on this site poses an unacceptable risk to the environment and we would wish to object to the application.”

The recommended planning conditions relate to a risk assessment of ground contamination; a remediation strategy; no infiltration of surface water drainage into the ground; foundation design; and a scheme for de-watering of the site.

The Environment Agency also provides advice to the applicant in relation to ground source heat pumps, flood risk, Teville Stream and pollution prevention.

The Highways Agency (HA) comments that,

“Transport Assessment

The HA have been involved in pre-planning application discussions regarding the trip generation associated with the site. The majority of trip rates were agreed between The HA and Waterman Transport and Development Limited (WT) before the TA was submitted. However, there is still some concern that the trip rates associated with the ‘Restaurant’ proposals may be underestimating the potential number of trips generated by this land use.

There are some discrepancies between the predicted net change in trip numbers as a result of the proposed development, as outlined in the TA, and the number of trips used within the strategic SATURN Model – Worthing and Arun Strategic Transport Model (WASTM). From the information provided in the TA it appears that WASTM may be underestimating the number of development trips. Clarification of this should be provided by WT.

Little information regarding the development of WASTM is available within the TA or any appendices provided by WT. The HA have not undertaken a review of the model and therefore cannot confirm whether it accurately represents the operation of and traffic flow on the strategic road network (SRN). It is recommended that the HA have the opportunity to review the model before any of the results presented within the TA are accepted.

An analysis has been undertaken of the results from the model at face value. WT indicate within the TA that following discussions with the HA it was concluded that full junction capacity assessments were not required at this stage, rather a comparison of the traffic flows at the junction without and with development in the assessment year were initially requested.

Current HA protocol indicates that a capacity assessment should be undertaken if an extra 30 or more two way trips are generated at a junction or on a link as a result of development proposals. Following a review of the ‘without’ and ‘with’ development comparison, the TA demonstrates that in most cases over 30 extra trips are predicted to be generated as a result of the proposed development at the following four junctions:

Offington Roundabout; Lyons Farm Signals West; Lyons Farm Signals East; and Grove Lodge Roundabout.

Due to the absence of two way turning movement traffic flows it is unclear from the TA what increase in trips on the A27 links is predicted. WT should provide further information regarding the flows on the A27 links without and with development (including junction turning movements) to determine whether capacity assessments are required on these links as well as at the junctions.

The HA recommend that junction and link capacity assessments are undertaken where an additional 30 two way trips are likely to result from the development proposals, to demonstrate whether the impact of the development is expected to result in the junction or link being over capacity and ‘worse off’ following development than had development not taken place. If this is the case then measures to mitigate the impact of the development should be proposed by WT.

Travel Plan

Details should be provided within the Travel Plan regarding the funding that is available for a Travel Plan Coordinator and how long that funding will last. Recently issued HA protocol indicates that for commercial developments a Travel Plan Coordinator should be funded for the life of the development, while for residential developments they should be funded for at least 5 years post full build out.

The three month travel survey, detailed within the travel plan, will be used to establish mode share targets. However WT should provide initial targets prior to this survey to provide a focus for the Travel Plan in its first few months.

Further information is requested regarding the approach to the three month survey (and any subsequent surveys). Further details regarding the composition of the surveys (traffic counts and face to face surveys), the length of time and daily time periods during which the traffic counts will be undertaken and the intended funding of the surveys should be provided.

A more extensive list of initial measures should be provided to further encourage sustainable travel. In addition measures that could be implemented should the Travel Plan fail to meet its targets should also be detailed. The HA would like to be involved in any future monitoring discussions to determine whether further action is required to meet the agreed targets.

As a result of the above I have attached form TR110 directing that planning permission for the Teville Gate development should not be granted for a specified period of time. This will allow time for the issues raised above to be addressed. Where the strategic road network is shown to be over capacity and ‘worse off’ as a result of the proposed development suitable mitigation measures may need to be secured which minimise trips at source. In the event the residual vehicular impact still results in the strategic road network being ‘worse off’ consideration may need to be given to improvements to the road network either through minor

physical upgrades to existing roads or the provision of new or expanded roads, or the implementation of demand management measures.”

Following receipt of further information, the Highways Agency now directs that a travel plan condition should be attached to any grant of planning permission.

English Heritage has commented as follows:

“I understand that the preceding application, WB/06/0549/0UT, has not been determined. My colleague Graham Steaggles wrote to you on this matter on 4 September 2006. His main conclusion was that the towers would not be significantly visible in views of importance, and this view would apply also to the current scheme although such high-rise development should always be set in the context of a Tall Buildings Policy.

At that time the shape of the scheme was slightly different, as it included a swimming pool. This meant a relatively broad, but less intensive treatment on the north-eastern side. The present design has dropped the pool, and the lower part of the development has increased overall to accommodate the successor uses. This would tend to increase the density in relation to the listed station building and, as Mr Steaggles had already remarked, the block would be influential on the visitor experience both by rail and road, suggesting a greater scale than would be appropriate to most of central Worthing. Thought should perhaps be given to reducing the impact of the block along Railway Approach and Broadwater Road.”

Tourism South East comments as follows:

“Thank you very much for consulting Tourism South East regarding this planning application. Tourism South East is the tourist board for the South East of England. We are tasked by SEEDA to promote, support and develop the tourism sector in the region. As part of this activity we are expected to comment on all plans and strategies that affect the sector. As such we are more than happy to offer our observations on this application and we hope that the following comments will be useful.

Our principal concern when we consider any proposal to add to the provision of short stay tourist/visitor accommodation is that there is enough demand for the increase. In 2008 Tourism South East, in partnership with the Coastal West Sussex Partnership; the Five Town Network; and Worthing Borough Council, commissioned a study in the hotel sector in order to establish whether there was sufficient scope to increase provision in Worthing.

The study found that there was potential to add an upper tier budget hotel or a three star hotel in the town and identified Teville Gate as a suitable location.

The application specifies an eighty-eight bed roomed hotel. Under normal circumstances we would contend that this was too large and would not be appropriate for Worthing considering current levels of supply and demand. However, we need to recognise that this proposal is part of a much wider application.

The accompanying proposals to provide a conference/exhibition centre, various retail, business and leisure uses as well as 229 residential units will drive up demand for visitor accommodation. The development as a whole will improve the

desirability of Worthing as a place to live, work and visit. Therefore we believe that there is a suitable business case for building the hotel and associated developments.

We would like to see a condition attached to the application that would ensure that the hotel and conference centre were both constructed before the residential units are completed. In the past when similar developments have been approved in other parts of the country it has often been the case that the residential units have been constructed first and the hotel and other tourist facilities have not been finished.

Tourism is a key driver of local economies and plays a vital role in providing support to other sectors through the supply chain and by providing necessary facilities (meeting/conference rooms and accommodation for visiting customers/clients). A thriving tourism economy also improves local areas in terms of the desirability as places to live and work. Like other south coast towns Worthing suffers from high levels of residents commuting out to other areas on a daily basis. A development such as this one is an ideal means to attract businesses and employers to the town.

Tourism permeates all sectors and the provision of visitor accommodation is a key aspect in supporting the wider business sector. Three quarters of visitor spending goes to enterprises outside the accommodation sector - to shops, pubs, restaurants, garages, train operators, museums, cinemas and theatres etc. These enterprises in turn support other businesses across a wide range of sectors.

For these reasons we are more than happy to support this proposal for an eighty eight bedroom hotel and a conference and exhibition centre at Teville Gate as part of the broader redevelopment of the site.”

EDF Energy has raised no objection to the proposed development.

The Environmental Health Manager comments as follows:

“There is no mention of PPS23 in Section 4 of the planning statement. PPS23 relates to Planning and Pollution Control, particularly air quality and contaminated land and should be mentioned (although it is mentioned in the Environmental Statement).

A. Air Quality

Turning to Chapter 10 of the Environmental Statement on Air Quality (which does refer to PPS23), I make the following comments.

Chapter 10.48 incorrectly identifies the locations of our two continuous particulate (PM10) monitors. These are located at Grove Lodge (A27) and Falmer Close, Goring. As the data within Table 10.8 confirms, the area around Teville Gate has in the past, shown exceedances of the Air Quality Objective for Nitrogen Dioxide (NO2). Exceedances were recorded in 2006 and 2007. We now have monitoring data for 2008 and 2009. Data for 2008 showed a drop in levels to 37μg/m3, however all monitoring sites recorded a fall in levels during 2008.

However data for 2009 shows that an annual mean of almost 45μg/m3 was measured on the south side of the Teville Road/Chapel Road roundabout (monitoring site N28), well in excess of the annual mean objective for NO2.

Since the Air Quality Assessment was produced by Waterman, the Council has completed its Progress Report for 2010. This is based on our air quality monitoring data from 2009. Even when the measured level for site N28 is adjusted to give a façade level, representative of relevant (residential) exposure, the figure is 42.4μg/m3, still above the objective for annual mean NO2. Data for 2010 appears to show the exceedance has continued. As a result the Council is having to progress to a Detailed Assessment of air quality in the Teville Gate area. This is likely to result in the area being declared an Air Quality Management Area (AQMA), meaning the Council is legally obliged to take measures to reduce levels of NO2 in the area. Worthing Borough Council and West Sussex County Council will be required to pay for traffic management measures that must be avoided or provided now by the developers, rather than use public money at a later stage. The majority of the air quality problems in the area are produced by traffic emissions, particularly slow moving traffic. Therefore we need to ensure that any development in the area does not contribute to an increase in traffic congestion in the area. It is clear from the Environmental Statement that the proposed Teville Gate development will increase levels of NO2 in the area. The air quality assessment modelling predicts a decrease in levels both with and without the development in 2014 and 2026. I must believe that the model used (ADMS roads) assumes that advances in vehicle technology will lead to these reductions. There is much evidence to show that air pollutant modelling lacks the accuracy and resolution to definitively classify the impact of a development scheme as either significant or not. The importance of meteorological data in modelling often provides wide fluctuations in output data that renders the assessment and quantification of scheme modification and mitigation scenarios irrelevant and incapable of assessing the aggregation of development schemes within an area. The report shows the development will lead to increases in pollutants in the area, but concludes that introducing residential uses to the site would be negligible. I am concerned that the word residential is used here. Does this mean that the commercial uses have not been included in the model? Nevertheless the development will increase pollution in the area. Furthermore, Receptor 4 (116 Chapel Road) is close to the annual mean 3 objective for NO2 in 2014 (36μg/m ). Further our monitoring is showing levels are actually increasing, not decreasing. It is therefore clear that the development will contribute to air pollution levels in the area. It is also clear therefore that mitigation is required to off-set these increases. The inclusion of a travel plan is welcomed. However this alone will not be sufficient. The development needs to include some or all of the following mitigation, to ensure that a development of high quality yet sustainable and with minimal impact on air quality. Many of these should be incorporated into a sustainable transport scheme, although some could form part of the travel plan. The development should be based on the principles of low car/low emissions. For air quality reasons ((including the possible causation of an AQMA), the developers must make every attempt to minimise car based trips A Sussex wide Low Emissions Strategy will shortly be published and the development should adhere to the principles of Low Emissions.

Public Electric Vehicle (EV) recharging points. A network of public EV charging points is currently being rolled out across Sussex. These will shortly be integrated into a national EV charging point system. The development should provide a number of public EV points which can link into this local and national network. By the time the development is completed there will be a considerable increase in the choice of electric vehicles, many with extended ranges, so the provision of ev charging points in the development is vital. One example of the use of EV points is in relation to the cinema, where reduced price tickets could be offered for those with an electric vehicle, which they can charge whilst watching the film. If charging for car parking spaces, apply different charges for electric vehicles. Public transport electronic display information (bus & rail) within one or more parts of the development. This will provide convenience and choice for visitors. The promotion of public transport over private car journeys is essential. Cycle facilities, both cycle routes to and from the development (incorporated into the existing cycle network) and safe and secure cycle storage within the development (incorporated into the travel plan). A survey of pedestrian needs (If not already fully considered) followed by improved pedestrian access into and out of the development to access the town centre and local facilities (e.g. improved pedestrian crossings, off street access to Worthing station etc. Supermarket. If the store is to provide a local delivery service, then consideration should be given to the use of electric vehicles for deliveries to local homes. Charging points (fast charge) may be provided by the store for use by the delivery vans. Also the promotion of public transport to and from the store should be encouraged. As there is already an Air Quality Hot Spot here, as noted in our air quality reports, a permanent NOx and PM10 monitoring site should be installed in a suitable location in the vicinity of Teville Gate, paid for by the developers. This must include both capital costs and running costs for up to 10 years.

Many of these measures could be achieved through Section 106 agreements and I would welcome discussion on this.

B. Demolition and Construction – air quality

Policy 17 of the Core Strategy refers to Sustainable construction methods and states that new developments need to set out how they deal with pollution. This includes noise and dust. Paragraph 10.69 of the Environmental Statement talks about the use of “appropriate” measures to control particulates and air pollution. The term appropriate must be defined; although this can be agreed at a later date through a condition attached to any permission granted requiring a scheme for the control of dust.

C. Noise & Vibration

Paragraph 11.62. This states that following consultation with WBC it was agreed that the development should be designed to meet the reasonable standard within BS8233:1999. I am not aware of anyone within Environmental Health agreeing to this. In fact we would not agree to this and recommend that the “Good” standard within BS8233:1999 is the design criteria.

Therefore the proposed mitigation measures outlined in the report to achieve these levels are incorrect. Further, a forced air ventilation system will probably be required in order to meet these criteria. I agree with the mitigation measures for the construction phase, as outlined in Paragraphs 11.86 to 11.90. These could be controlled through a condition attached to any permission granted, requiring a scheme for the control of noise from the site during demolition and construction.

I do not agree with the conclusions reached in Paragraph 11.91 for the reasons outlined above (re. BS8233:1999). Therefore I recommend that a condition be attached to any permission granted for a sound insulation scheme for the residential parts of the development (similar to standard Condition C.11.A),

‘Notwithstanding any indication given on the plans and supporting information that have been submitted, prior to the commencement of the use hereby permitted, the residential parts of the development shall be sound insulated in accordance with a scheme submitted to and agreed in writing by the Local Planning Authority. The development shall then be implemented in accordance with these approved details and a test to demonstrate compliance with the scheme shall be undertaken prior to the development being commissioned.’

Similarly, schemes for the control of noise (to include sound insulation of the various commercial parts) from the commercial parts of the development in particular (but not exclusively) the cinema and the supermarket should be attached as conditions to any permission granted ‘Notwithstanding any indication given on the plans and supporting information that have been submitted, prior to the commencement of the use hereby permitted, schemes for the control of noise from the commercial parts of the development hereby permitted [cinema] [leisure venues][supermarket] shall be submitted to and approved in writing by the Local Planning Authority. The development shall then be implemented in accordance with these approved details and a test to demonstrate compliance with the scheme shall be undertaken prior to the development being commissioned.’ I do not consider service and delivery noise has been properly assessed (paragraph 11.100) – no data is included. Therefore this aspect of the development should also be subject to a scheme for noise control prior to opening for business. Individual mechanical plant noise can be controlled when further details are submitted.

In conclusion whilst not objecting to the outline application, there are a number of matters that require attention. Many of these can be achieved through the imposition of appropriate conditions, however, some particularly those relating to air quality would benefit from appropriate Section 106 agreements.”

The South Downs National Park Authority comments that,

“The proposed towers, although well outside of the South Downs National Park, would be prominent in view from within the National Park. This is because they would be significantly higher than surrounding development within Worthing and would breach the coastal horizon/skyline in views from within the National Park. Accordingly, I object unless the previous proposal for development of this site is still extant.”

The Worthing Society comments that,

“I notice the changes to the 2006 outline application for this site and the inclusion of the redundant office block on Railway Approach.

An Anchor foodstore is proposed to assist the viability of the proposal and no doubt market forces will shape the effect this will have on the scheme and town centre, bearing in mind the recent planning consent given to the foodstore on Newland Road.

It is not for us to question the viability of this ambitious scheme but its mass will have a considerable impact on the neighbourhood. We welcome any improvement to the urban realm with better linkage from the station to the seafront but the increased swirl of traffic could further cut this site off from the town centre.

I am pessimistic about the residential element, with 229 of the total 260 apartments contained in two tower blocks. Tall landmark tower blocks added nothing to the townscape of seaside towns such as Brighton where they quickly lost their gloss. This is a massive scheme and observation of other mixed use developments show that the residential element can quickly become shabby. Car parks, goods areas, precincts, the base of towers will all need supervision to prevent them becoming unsocial areas.

Bearing in mind the history of the site, I expect that, with adjustments, outline permission will be granted but should this development ever proceed urge Officers to work towards minimising the impact with wide pedestrian ways and landscaping.”

Worthing Astronomical Society comments that,

“External lighting can be directed downwards on to the development and the periphery without trespass or overspill upon neighbouring properties and open spaces. Also the lighting intensity is no more than necessary in order to fulfil the task of illumination, for period of time that are no longer than necessary. Thus not wasting limited fossil fuels.

If these conditions are imposed correctly no sky glow would be created and waste of resources kept to a minimum along with lower operating cost. Thus being in accordance with the Worthing Plan 2003 and as subsequently reflected in the draft of the Worthing Borough Council’s Core Strategy and Local Development Framework.”

The Cinema Theatre Association comments that,

This development is to take place in close vicinity to the Grade II* listed Dome Cinema (Marine Parade, Worthing: TA Allen, 1911) that has just been comprehensively restored brining the splendour of the early years of film back to Worthing. Worthing has the historic Dome Cinema an exceptional and rare cultural asset. Being able to go and see a film in such a splendid venue just on the seaside has proved a great attraction and the Dome is run as a viable business.

The large leisure complex puts this at risk as it includes a multiplex cinema. Once the multiplex is in place the one screen Dome Cinema will soon become obsolete and will most probably have to close for film use. According to Planning Policy the original use of a listed building is considered the most desirable option as it usually assures that the original fabric of the building is maintained. If cinema use becomes financially unprofitable an adaptive reuse will follow in the best-case scenario. This certainly should be taken into consideration when the plans for the new cinema and leisure complex in direct vicinity of the Dome Cinema are assessed. Multiplex schemes are increasingly leading to the loss of local one screen cinemas and because of this the Cinema Theatre Association firmly objects to the application above. Re-establishing film performance in this venue after the cinema has become obsolete is most unlikely and cinema use will be lost to the listed building. It would be a real shame if the viability of the historic cinema were put at serious risk due to this redevelopment.

The Cinema Theatre Association therefore strongly objects to the application in its current form. The multiplex component of the redevelopment should be eliminated as the cultural requirement for film in Worthing is already being met.”

The County Council Archaeologist comments that,

Further information has been submitted by the applicant, concerning the potential of the site to contain World War 2 structural remains and early prehistoric deposits, together with proposed associated archaeological mitigation measures. This information addresses the County Council's concerns set out in previous comments on this application. No objection on archaeological grounds is now raised to the proposals, subject to suitable archaeological safeguards, provided for by planning condition.

No development shall be carried out on the land until the applicant, or their agents or successor in title, has secured the implementation of a programme of archaeological works in accordance with a written specification and timetable which has been submitted to and approved in writing by the Local Planning Authority.

Reason: The site is potentially of archaeological interest.”

The District Valuer has been asked to comment on the viability of the scheme and the ability of the scheme to meet normal s106 development contributions and 30% affordable housing. He concludes that,

“Following our detailed research we are of the opinion that the viability assessment of the policy compliant scheme, including affordable housing (80 units) and a section 106 contribution of £1,000,863 is not viable and shows a deficit of approximately £5,918,923 on the basis of a profit of 12.5%.

This compares to the profit shown by the applicants for the overall scheme of 12.77% on the basis of a scheme with no affordable housing on site.

We have also considered the amount of affordable housing that could be provided on site for the scheme to be viable which equates to approximately 20 units or all units in the Teville Block. This only equates to approximately 7.5%

However the key issue with regard to the delivery of this scheme is the food store. It is the major anchor for the scheme and without it I do not believe that the overall scheme will be delivered and the regeneration of this site will be delayed considerably. All other uses are important but the food store is the key.

Recommendations:

On the basis of our assessment above we are of the view that the policy compliant scheme is not viable and is only viable with a substantial reduction in the level of affordable housing on site. The alternative is to consider a commuted sum in lieu of the onsite provision.

If the Council are prepared to reduce the section 106 contributions and the policy level of affordable housing to assist viability we would recommend including either a review mechanism to review viability at certain stages during the development or an overage clause in any section 106 agreement on the basis that the developer achieves an overall profit level in excess of 15%. Any “super profit” should be shared 50/50 with the developer in order to provide an incentive.

Delivery of the Scheme: On the basis of our assessment the Food Store is the key element to the scheme and unless this anchor is resolved the scheme will not be delivered under the current market conditions.

However I would stress that a meeting with both the Council and applicant together with their agents needs to be arranged in order to resolve a number of issues including:

Acquisition Costs including car parking Detail of other build costs Professional fees Section 106 costs Sales values including car parking”

7. REPRESENTATIONS

A total of 24 letters of objection have been received to the application on the grounds that:-

i) The development will be out of character for the area, being far too high and bulky. ii) Whilst active uses on the ground floor are welcome and useful for safety issues, it should include community uses, a small late opening supermarket and a newsagent. The retail on the existing site never worked as it is too far from the town centre retail and Worthing has a good supply of useful district shopping centres. iii) Whilst housing and/or offices on this site seems appropriate, the developers fitted far too much on the site and it is a gross overdevelopment. iv) There is no need for the landmark towers which are out of character with the smaller scale buildings in the vicinity.

v) The town already has two cinemas and plenty of nightclubs and other leisure uses, these are, therefore, unnecessary. vi) Whilst the site is an eyesore, a more modest scheme in keeping with the area would provide a much better solution for the town. vii) Traffic flows around the site are already very high and the possible amount of extra traffic based on the parking figures would cause excessive problems to the area. viii) Worthing has mainly 2 to 5 storey buildings and the proposed towers, one of 24 storeys will totally dominate the area and cause overlooking. ix) Local schools are oversubscribed; it is therefore surprising that the application states there will be minimal impact on local services with all the extra people living on the site. x) The additional traffic and activity will have an adverse impact on the area. Parking is a significant issue for local residents already. After 6.00pm, it becomes very difficult to find parking spaces in adjoining roads. it is suggested that surrounding roads should be made resident parking only and possibly an arrangement whereby residents could use the parking facilities provided on site free of charge. xi) It is questioned whether the supermarket will be open 24 hours and, if so, what will the traffic management arrangements be regarding lorries and other vehicles. In this respect, there should be a restriction on the hours in which lorries can operate. It is also questioned whether there will be a restriction on liquor licences on the proposed bars and restaurants proposed within the development. xii) Given the height and scale of the development, it is suggested that an independent assessment of wind turbulence should be submitted. xiii) There should also be controls on the hours of working when the development starts. xiv) The large number of apartments proposed (260) will put further stress on the already stretched infrastructure of the town centre, which it is understood is already a deprived area. xv) It is questioned how the town fares against other towns in the locality in terms of leisure and sports facilities. This would assist in determining how the proposed development meets the need of the Worthing residents rather than the needs of financial investors. xvi) It is highly unlikely that the number of parking spaces will meet the needs of a supermarket, 1200 seat conference centre, hotel, new residential apartments and multiplex cinema. The lack of parking spaces and/or the cost of these spaces will encourage many people to park in the surrounding roads to the further detriment of local residents who often have to drive a considerable distance to find a place to park. xvii) The existing junction at Teville Gate is already near to meltdown at peak times and is a disincentive to come into Worthing to shop or work. xviii) Tall buildings can create significant problems arising from deflection of strong/high winds and failure to address this problem could have a significant effect on the value of surrounding properties. Should this type of development go ahead, if the Worthing town centre/retail offer to benefit

the main entrance to Worthing railway station should be re-sited to the east allowing direct visual walking access to the railway station to the town centre via Chapel Road? xix) A better development for Worthing albeit probably less attractive financially for the developer would be for the site to become part of the new silicon valley of high tech companies being created in Brighton and the surrounding area which would be a real boost to the town and its economy. xx) The town is already well equipped with supermarkets with Morrison’s, Lidl and Waitrose in close proximity. The proposed development could result in one of the existing supermarkets closing which would have an adverse impact on the town centre. The Chief Executive of Barratt Developments recently commented that “fixation with volume density in developments out of context with what is appropriate for a community”. The plan to maximise the potential of Teville Gate appears to reflect that culture. Teville Gate needs regeneration not regeneration overkill. xxi) The height and scale of the twin towers would signify an unbalanced and disproportionate presence on the existing skyline causing significant overlooking and give unwelcome intrusion into people’s already diminished personal space. xxii) The towers will be for residential use with family apartments including children. PPG17 refers to the need for open space for play vital in childrens’ social development. It is questioned where such provision for children living in tower blocks on a multi-faceted development close to three busy roads. There are lessons to be learned from other towns and cities which promoted tower block residential occupation to the detriment of social order and cohesion. xxiii) The application states that the development would not increase noise levels, however this would be nonsense given the significant daytime and night-time activity generated by the mixed use development. xxiv) The range of restaurants, cafes and other eating and drinking outlets proposed on the site is significant and it will be important that there are conditions to restrict the opening and any liquor licences granted must be carefully assessed having regard to the hooliganism and social problems caused by excessive drinking. xxv) If the development proceeds, the traffic management plan should determine beforehand the routes to be used by vehicles, hours of working and controls on dust and vibration. The greatest impact of the development at every level would be on the nearby community who would be subject to noise, dust, heavy traffic, vibration for close to four years. xxvi) The enthusiasm for establishing an iconic statement for Worthing should not push the local community to the periphery of the planning strategy. The site would benefit from a more balanced regeneration involving a streamlining of the volume density proposals and reducing the scale of the towers so that they blend in successfully with Worthing’s current skyline, rather than dwarfing it. xxvii) The twin towers are now being considered as an icon in the planning process - an icon for what, for whom, and for what purpose? Recognition of respect for the scale of surroundings where development is proposed

has to note as major factors in planning decisions. The 1950s and 1960s tower blocks were built as icons for post war Britain where the recognition and respect for the character of cities were bypassed, as was the understanding of the human element in the form of communities on the receiving end of alien constructions. The social consequences of the neglect of these factors in the planning and decision taking in those early decades are now on record. xxviii) Reference is made to the development bringing new residents into Worthing. However, it is questioned whether Worthing has enough problems in coping with already over-stretched infrastructure. xxix) The regeneration of Teville Gate will have far reaching consequences and its impact will be felt particularly by residents in heavy congested areas already subject to relentless drive for redevelopment. Pressure brings with it increase car use, more carbon emissions, more pollution, more noise and stress on social and community cohesion. xxx) There is concern about the proposed closure of the subway under the Broadwater Bridge. The Transport Assessment states that the subway has poor lighting and lacks ramps to provide an on the level route. Whilst this is agreed, the suggestion would be to improve it, not close it. The subway provides for a segregation of pedestrians and vehicles and it seems a retrograde step in the 21st century to remove this, it should be enhanced by providing a cycle lane giving a much safer route to the station forecourt for cyclist from the east. We should encourage cycling by pupils travelling to and from and a way for cyclist to safely cross Broadwater Road would contribute to this objective. xxxi) It is questioned how the development will create and maintain 1,000 jobs at the site. xxxii) Rather than pedestrian priority crossings, slowing the traffic flow at the main gateway to the town, there should be covered bridges with environmental control for all weathers with no pedestrian access to the busy road junction. Additional traffic queuing in Teville Road for the delay caused by South Farm Road rail crossing should be catered for. xxxiii) The site is not a gateway to Worthing unless you are using the station. In addition, most motorists and pedestrians use other roads which bypass Teville Gate when they are entering or leaving Worthing town centre. xxxiv) The buildings and designs are ideal for large cities or new towns such as Crawley, Croydon or Milton Keynes where concrete jungles already exist. xxxv) The height and design of the development is not in keeping with the town and they will over-shadow the town sticking out like sore thumbs. The design is also not in keeping with the mix of architecture currently within the town, i.e. Regency, Georgian, Victorian and Art Deco styles which glorify the times of grace, elegance and grandeur. xxxvi) Teville Gate would be an ideal location for a modern bus station with shops, cafes, apartments etc. It is suggested that the applicant should talk to Stagecoach and swap sites which could be a better deal for all, with elegant buildings could be built enhancing Worthing’s seafront. xxxvii) A local hotelier has expressed concern of the proposal for a new hotel on the site. There does not appear to be any independent study to justify the need for additional rooms and it is suggested that Worthing already has 20

to 30% more rooms than it needs and cannot absorb such an increase without the loss of other accommodation providers in the town. The Council has previously indicated that Worthing’s occupancy is 55% at least 10% below the regional average and that was during the “good years” It is not considered that a new pool and multiplex are tourist attractions as most towns of Worthing’s size already have these facilities and so, therefore, cannot be seen as destination draws in themselves. xxxviii) There is no need for the hotel, supermarket, conference facility or cafes. It is apparent that the existing theatres are not bringing in sufficient money and, therefore, it is questioned why the Council should be bringing in more competition when existing businesses are struggling. A more appropriate development would be something the town really wants and needs - a permanent competition size ice rink, a leisure pool so that a proper swimming pool can be built at the Aquarena and a small permanent area that local artists and crafts people can showcase their work, a covered market area may be even a covered bandstand and viewing area. Perhaps most suitable for that particular place would be a pleasant landscaped and seated area for those weary shoppers making their way back to the train and, of course, plenty of cheap parking to get people to come to the town in the first place. xxxix) The Environmental Impact Study has been carefully worded to play down the impact of the 24 storey tower block but admits that these towers would change the skyline from virtually every point, the coast, the town and the downs. It states that the views would be mitigated from the cost by their slender design but there are several rendered views showing the building side on and they are simply huge. High rise if definitely the way forward in terms of a clever use of Brownfield sites but it is the scale I take issue with. 24 storeys in an area where most buildings are no more than 5 will have a serious detrimental effect. xxxx) The development would have an adverse impact on existing cinemas in the town, the Connaught and the Dome, and there is concern that this type of development is often filled with multi-national chains and would therefore lack character and more importantly significant investment in the local economy. It is suggested that a percentage of units could be given over to local independent businesses and perhaps special rates offered if necessary.

South Broadwater Residents’ Association comments that,

“We are a residents’ association representing approximately 1600 residents to the immediate north of the railway line. Our Chairman has asked me as a Committee Member who has looked at this application to write on various issues.

Whilst a redevelopment of this eyesore is welcome we do have some concerns, the first being the height of the towers which we feel unacceptably dominate the surrounding properties for some distance from the site leading to loss of amenity. A study has been carried out for the developer concerning overshadowing particularly for the residents of Bridge Road. However, it was carried out for October and it has been calculated with the lower sun in winter months the overshadowing will be three times worse in December. Despite being set back the apartments will nevertheless still overlook surrounding properties.

Secondly we feel that despite being within WSCC allowances, the parking provision will be in reality insufficient for the number of residents (where will residents who don’t have a parking space park?) and if all the facilities are in full use the surrounding streets are going to be used as either over-spill or by people wanting to escape having to pay.

Next the Committee were strongly of the opinion that the replacement of roundabouts by traffic signals plus the introduction of a further pelican crossing on Broadwater Bridge is in reality going to lead to traffic chaos with long tail backs particularly with the all-red idea. Traffic needs to cross from Broadwater Bridge to Teville Road and from Chapel Road to Newlands Road. Whereas now the level crossing at South Farm Road can cause tailbacks at rush hour to Chapel Road at least the traffic wanting to continue over the bridge can filter round as can south-bound traffic from Broadwater Bridge. In addition to this there are proposed traffic signals at Hertford Road to allow traffic to enter the basement car park. Queuing especially from westbound traffic will make matters even worse.

The next point is regards drainage of the site. Apparently the Teville Stream can’t be found as it is assumed to be contained within the sewerage system. However Davison’s Field and the gardens in Mansfield Road in East Worthing are flooded by the stream in heavy rain. Further one of our members who used to live in Teville Road when there were houses and gardens on the current site well remembers the stream flooding gardens in the late ‘40’s. There is also continual flooding of the subway in Worthing Station.

We also raise the apparent differences between what Waterman Transport and Development Ltd appear to propose and what Atkins Southern Water’s agent’s letter which states ‘The proposed development would be considered premature until such time adequate sewerage infrastructure could be provided’. They also say it would be several years before it could be provided. Waterman shows the connection point to the sewerage system (one assumes to foul manhole no 7305 which could cope with the proposed flow) apparently on the other side of Broadwater Road.

Finally under the Local Plan Policy S11 states that a change of use at Ground Floor from a shop to other uses may not be permitted unless ‘the proposal causes no significant adverse effects for the occupiers of neighbouring properties and the proposal does not intensify car parking problems.

We maintain that the sheer size of the scheme will on both counts”

Central Worthing Residents’ Association comments that,

In general the CWRA approves the revised proposals for the development of Teville Gate. The area has been in a run-down state for too long and presents a poor image of Worthing. The provision of a Sainsbury’s foodstore will enhance the shopping choice for residents, and a multi-screen cinema complex will widen the entertainment facilities within the town though it is likely to have an adverse impact on the survival prospects of the Connaught Theatre and the Ritz Cinema. The hotel, conference and exhibition centre, health and fitness club, appropriate restaurants, cafes and offices will all provide a welcome increase in facilities as

well as additional job opportunities. There are mixed views on the merits of high rise towers of residential apartments - they will certainly not be iconic for all observers - but it is recognised that the development may not prove financially viable without them

There are, however, matters of serious concern regarding the proposals, notably Car Parking and the reorganisation of the road junctions and traffic control. Whilst the number of on-site parking spaces has been substantially increased from the original 2006 application it is acknowledged that demand will still exceed supply at times e.g. on Saturday mornings and evenings. Furthermore, the mixed requirements for parking will necessitate charging even if parking bay scheme are instituted by the foodstore and cinema. Inevitable, this will lead to users seeking free on-street parking nearby unless major steps are taken to prevent this. The application fails to address this matter and seriously misinterprets the existing provision in sections 2.27, 2.29 and 2.33 of Transport Assessment document 9.1. There are already acute problems with on-street parking for residents throughout the area and it will be essential that all parking zones within the ‘5 Minutes Walking Isochrones’ of the site are changed to, for example, Resident permit holders only from 9am to 9pm.

The claim (Planning Statement paragraph 5.41) that removing both roundabouts at both the junctions with the A24 and replacing them with pedestrian operated, full red, traffic lights crossings ‘will ensure that there is no significant affect (sic) on traffic’ is, to put it mildly, somewhat surprising. It is backed up by detailed analysis the validity of which depends very much on input data! Has account been taken of the fact that a substantial amount of traffic turns right through these junctions - from Broadwater Road into Teville Road, from Newland Road into Broadwater Road, from Chapel Road into Newland Road and from Teville Road into Chapel Road? The roundabouts facilitate such manoeuvres; the proposal would make some almost impossible at certain times of the day and lead to much more that ‘marginally worse congestion’. Has the effect of the South Farm Road railway crossing on congestion along Teville Road been taken into account, to say nothing of the addition of traffic lights at Hertford Road to allow entry into the proposed basement car park? Whilst the proposals would certainly enhance the access between the Town Centre and the railway station for pedestrians and cyclists they would most likely bring road traffic to a complete standstill for prolonged periods.

Other issues of noise, vibration and disturbance to residents living close to the site on Stanhope Road, Hertford Road and Teville Road need to be checked out both during construction and on completion of the project. It should also be pointed out that loss of sunlight for several properties on December 21st will be far worse than as indicated on March 21st - shadows are nearly 3 times longer in midwinter!.”

A total of 18 letters of support have been received raising the following comments:- i) The development would be fantastic for Worthing; it would completely transform the area and encourage people to use the town for recreation and shopping, rather than travelling to Chichester and Brighton.

ii) The town is in great need for a 9 screen cinema and having it so close to the station will be perfect, especially for young people. iii) Housing in the town centre is important and hopefully it will ease the traffic on the A27 as people will be centred on the town centre. iv) Teville Gate is currently an eyesore and is the first impression visitors get of Worthing if they come here by train. This needs to be built and quickly. v) The plans for the site are exciting and it is hoped that permission will be granted so that Worthing will receive much needed new facilities. It would provide new and better facilities for families with young children. One resident is particularly excited by the prospect of retail, restaurants, cafes, hotel and a health and fitness centre. vi) The proposed design is elegant and can do nothing but benefit Worthing. vii) Development is essential for the commercial future of the town. Competition is fierce and there is a huge opportunity to capitalise on the overspill for more expensive areas such as Brighton and Chichester and establish Worthing as a Sussex premier town. viii) The current site an eyesore and an embarrassment, giving a very poor first impression to visitors to Worthing. ix) Worthing is definitely in need of a modern cinema. Although the Dome and Connaught do a good job, they cannot compete with the comfort and viewing experiences of modern multiplexes. Many residents will travel to Chichester and have a meal out after the film. This money should be spent in Worthing rather than helping to support Chichester’s economy. x) The inclusion of new cafes and restaurants will hopefully attract middle market brands such as Café Rouge and Browns, rather than just fast food and pizza outlets. This could have a knock on effect on the rest of the town. xi) The proposal for a modern hotel and conference centre is an excellent idea and will hopefully attract new visitors to the town. xii) Teville Gate, together with the new Aquarena, will mark Worthing out as a place with potential and will hopefully be the catalyst for further investment in the town. xiii) The proposed twin towers could be a great feature provided they are built of materials that maintain their attractiveness over many decades. xiv) The submitted plans are fantastic and would enhance the whole town bringing new, well needed, and custom for traders and extra employment. xv) The development will help bring Worthing into the 21st century and get rid of one of the most appalling gateways to a town on the south coast xvi) The development will provide jobs, housing and parking and also a range of leisure activities which are important in a seaside holiday town. xvii) It is a very imaginative use of a very dreary area and would attract people from outside the town. It is important that the Council takes the opportunity of supporting this proposal without delay. With the economic future which lies ahead for the country, if this opportunity is not taken quickly, it will be lost forever and Worthing’s decline will be irreversible.

In addition, 7 letters of no objection have been received subject to the following reservations:- i) If the development is to proceed, it is important that there is sufficient resident parking for so many new dwellings and it will be important to ensure that there is a definite route from the station to Teville Gate to draw visitors and ideally there should be no supermarket but the space used for affordable small units for local traders, unique shops and specialist suppliers. This would bring trade to the town in droves. ii) There are significant difficulties with parking in the area. It is suggested, therefore, that any planning permission should include provision for all the new flats to have residents’ parking within the 967 parking spaces. iii) Although parking is provided within the development, the public will be tempted to park in nearby roads for the odd hour or two preventing residents from parking in their own streets. This happens already and can be extremely difficult to park weekdays, after 6 and weekends when the public use it as a free car park being close to the town centre. The solution to this would be to make nearby residential roads, Lennox Road, Gordon Road, Ashdown Road and Sussex Road a residents parking permit only. Whilst it might incur an extra cost to the residents, it is likely that there would be a willingness to pay for the right to park outside residents’ own homes. iv) Whilst the development is a major improvement, it is questioned why a supermarket is required when the town centre already has three large supermarkets in close proximity. If one or more of the existing stores were to go out of business as a result, this would be detrimental to the town. v) Colliers, a business operating from Teville Road since 1935 hopes that the proposed development will re-energise the area and attract further investment into the town centre. It, however, wishes to make sure that the rear of its property which borders the site maintains access for fire exit and maintenance purposes. The first floor window at the rear which will overlook the entrance ramp for the new development would not be obscured and ensure that these offices do not suffer from noise pollution. It further states that the development will generally cause significant disturbance to the area, traffic congestion, parking restrictions and noise which will in turn adversely affect our trading. vi) On behalf of the owners of Kwik Fit Properties, it is submitted that their client has no objection to the principle of the development but serious concerns are raised with regard to traffic on the surrounding road network and the implications of the proposed access ramp to the basement car park and its associated works to the highway. In this respect it is concerned that the development will seriously prejudice the operation of the motorist centre with queuing traffic likely to block access to the motorist centre, it is suggested that the ‘Keep Clear’ box is of insufficient size and the access needs to be modified in order to facilitate access for other vehicles. Highway consultants on behalf of Kwik Fit have provided further supporting information in relation to this concern. (The applicant has adjusted the right hand turn lane to seek to address these concerns).

vii) Concern has also been expressed by Bunce and Co that the development may affect existing vehicular access to its yard, as the access emerges in from the north end of Chapel Road. It is submitted that the access is already difficult and narrow but the layout of the new road would make it even more difficult. In particular, the proposed toucan pedestrian crossing close to the north edge of the access will force vehicles to only travel south. It is also submitted that entering the yard will be much more difficult. It is suggested that relocation of the crossing further north or south of the vehicle access may assist but must be retained in order to facilitate pedestrian access to the east side of Chapel Road. A balance of needs between pedestrians and the existing vehicular access to the yard is required. It also submits that street drainage in this area is also a regular problem and needs careful consideration in the design (the position of the pedestrian crossings has yet to be resolved).

8. PLANNING POLICY CONTEXT

As Members are aware planning applications have to be determined in accordance with the provisions of the Development Plan unless there are material considerations which dictate otherwise. For the purposes of determining this application the relevant Development Plan policies are the recently adopted Core Strategy and the Regional Spatial Strategy (RSS) for the South East of England (known as the South East Plan). Whilst, Members are aware that the Localism Bill intends to revoke the RSS’s a recent Court of Appeal judgement has clarified that there would be ‘very few cases’ where it would be appropriate to give any significant weight to the proposal to revoke regional strategies given the need for Parliamentary approval and the need for a strategic environmental assessment (SEA) to be carried out to assess the environmental impacts involved with the revocation of each regional strategy.

Core Strategy

A key strategic objective for Worthing’s recently adopted Core Strategy is the regeneration of the town centre and central seafront areas. A number of key sites are identified including Teville Gate to make a significant contribution to realising the town’s economic growth potential and new jobs will be created through the delivery of retail and other commercial development. Regeneration proposals will also help to contribute towards meeting Worthing’s housing needs by ensuring the delivery of mixed use development sites. The Core Strategy seeks to promote new investment and encourage the delivery of enhanced public spaces, improved connectivity and a high quality cohesive environment that is accessible to all. This will help to underpin the future economic prosperity of the area and reinforce Worthing town centre as the principal centre for retail, culture, art, tourism and leisure. The Core Strategy identifies the following key outcomes:

The vitality and viability of the town centre is improved through an increase in activity levels; improved economic performance and visitor numbers; A distinctive, attractive and safe urban environment with high quality public realm is created; Key assets within the town centre and seafront area are maximised;

The key objectives and vision of the Town Centre and Seafront Masterplan are delivered with particular emphasis placed on bringing forward mixed use developments on key sites (Teville Gate, Grafton Site, Aquarena, retail heart); Connectivity between the town centre and the seafront is improved; New, high quality retail and leisure space is created which helps to deliver a more competitive urban centre; There is an increase in cultural and arts events and exhibitions.

Teville gate is identified as an Area of Change and the following extract from the policy sets out the principle objectives for the site and main development principles:

“This site is of strategic importance and its redevelopment provides a real opportunity to significantly improve the entry into the town centre and to set high standards of design and development. The mix of uses will address many of the aspects of Worthing’s overall spatial vision. The provision of modern leisure, retail and residential development (approximately 260 dwellings) will add to the economic viability and regeneration of the town. Improved transport integration and pedestrian access will help to form a strategic link between the railway station and the town centre.

Teville Gate will provide significant new mixed use redevelopment incorporating leisure, residential and supporting retail uses Redevelopment should maximise the site’s proximity to Worthing Station and compliment the town centre offer Development should be of high quality with the ability to accommodate a tall building Good pedestrian and cycling linkages to the town centre Recognised constraints in the local sewerage system must be addressed The redevelopment of this site should not prejudice other regeneration sites coming forward on adjoining land.”

Importantly the Core Strategy Area of Change policy for the site indicates that any retail element on the site should not directly compete with the retail offer of the primary shopping area in the town centre.

In the retail section of the Core Strategy reference is made to the capacity for further comparison floorspace up to 2017 of 43,000m2 although it highlights limited capacity for new convenience goods floorspace. The Core Strategy has not reviewed town centre boundaries and shopping zones, however, it acknowledges that should the new retail core extend the primary shopping zone and/or Teville Gate development comes forward then these would be reviewed at that time.

South East Plan

Within the South East Plan, Worthing town centre is identified as a Primary Regional Centre. It is not identified as a centre likely to undergo the most significant change during the plan period. Policy TC2 and 3 stress the importance of supporting the function and viability of town centres and that the role and regeneration of the town centres should not be undermined by an intensification of out of centre shopping centres. Policy TSR5, ‘Tourist Accommodation’ states that the need for hotel developments should be

considered in locations with links to transport interchanges or visitor attraction, and seek measures to increase access for all by sustainable transport modes.

Policy SCT5 requires local planning authorities to provide sufficient housing and for Worthing indicates an annual average house building of 200 dwellings per year and 4,000 in total up to 2026. Other relevant policies include: SP3 Urban Focus and Urban Renaissance, SP4 Regeneration and Social Inclusion, CC1 Sustainable Development, CC4 Sustainable Design and Construction, CC6 Sustainable Communities and Character of the Environment, CC7 Infrastructure and Implementation, Policy H3 Affordable Housing, H4 Type and Size of New Housing, H5 Housing Design and Density, T4 Parking, T5 Travel Plans. In addition, there are relevant policies relating to National Resource Management (NRM 1, 5, 9, 10, 11, 12, and 13).

As such, the application should be principally assessed against the above Development Plan policies and Government Policy in Planning Policy Statement 1: Delivering Sustainable Development; PPS4: Planning for Sustainable Economic Growth and PPG13: Transport. The Knight Frank Economic Research Report: Employment Land Review and Coastal Districts Retail Study prepared for the Local Development Framework are also pertinent to the consideration of this proposal.

9. PLANNING ASSESSMENT

The Economic and social benefits of securing the early redevelopment of the Teville Gate site are well documented and this objective remains a key priority for the Council. The decline of this 1970s shopping centre, particularly over the last ten years, has received national notoriety with the pedestrian street being voted the “worst in Britain” in a radio 5 show. As shops have closed, the site has attracted graffiti, vandalism and become a ‘no go’ area for local residents at night and a haven for crime and anti-social behaviour. In view of the site’s importance as a gateway location, highly visible to those entering the town by road and rail, its current neglected appearance continues to have a seriously detrimental impact on the visual amenities of the area and the economic wellbeing of the town centre.

The difficulty has been that despite the grant of various planning permissions, the site remains undeveloped because schemes have not been commercially viable. The principle of a mixed use and high density development incorporating leisure, retail, cafés and residential uses has been accepted by the grant of permission for the previous scheme on this site in 2010. However, even this high density scheme is not now viable irrespective of whether the Council decided to relocate the Aquarena to the site. Even before the credit crunch and subsequent recession the previous permission was only of marginal viability and required a reduction in the normal s106 contributions and affordable housing thresholds.

The applicant remains committed to delivering this mixed use development notwithstanding the very difficult economic climate. The applicants architect has refined the scheme to ensure that the high rise component is more economic to build and internal flat layouts have been improved to be more commercially viable, at the same time as trying to ensure that the towers do not lose any elegance or aesthetic appeal. The emphasis with the revised scheme has been

on deliverability and it is noted that the less commercially attractive uses such as the bowling and bingo have been dropped from the scheme. In addition, as noted by the District Valuer, it is clear that the inclusion of the foodstore is critical to ensure the viability of the scheme and this will be a material consideration in the determination of this application. The inclusion of the foodstore in itself, however, does raise policy concerns and would generate a significant increase in traffic and activity to the site. The scheme promotes a number of town centre uses and these, together with the foodstore proposed, have to be considered in accordance with Development Plan Policy and PPS4.

This report therefore highlights the main changes to the scheme and whether the proposed development complies with current planning policy. The main issues to be resolved with this revised application are:

o The acceptability of leisure and retail provision against the tests set out in PPS4: Planning for Sustainable Economic Growth, including impact on existing centres; o The acceptability of the revised scheme in design, scale and massing terms having regard to CABE/English Heritage guidance on tall buildings, heritage assets and the landscape visual impact assessment; o The impact of the development on the local highway network and the sites accessibility for all modes of transport and; o The ability to mitigate the impact of the development on local infrastructure through the use of development contributions and the scope to meet affordable housing requirements.

As stated at the outset of this report negotiations are continuing with the Highway Authority regarding the impact of the development on the highway network and pedestrian accessibility. In addition, further negotiations are required in connection with the viability of the development and the scope for the scheme to meet normal development contributions and affordable housing requirements. This interim report therefore seeks Members views on the acceptability of the scheme in relation to the first 3 issues, as far as it is possible at this stage, to assist the negotiation process. The deliverability of the scheme is clearly important and continuing delays determining the application could jeopardise the schemes viability. An early view on the revised scheme at this stage would greatly assist the negotiation process.

(i) The acceptability of new retail provision against the tests set out in PPS4: Planning for Sustainable Economic Growth, including impact on existing centres.

Government policy on leisure and retailing continues to place great emphasis on focusing such uses in town centres and other centres, as appropriate, to deliver more sustainable patterns of development; reduce the need to travel, especially by car and respond to climate change; promote the vitality and viability of town and other centres as important places for communities with the aim of offering a wide range of services to communities in an attractive and safe environment and remedying deficiencies in provision in areas with poor access to facilities; and to foster competition between retailers and enhanced consumer choice. This policy objective is carried forward in both the Council’s Core Strategy and the South East Plan.

In addition to the over–arching policy EC10 in PPS4 which, encourages a positive and constructive approach towards planning applications for economic development (including retail/restaurant and leisure uses such as proposed), PPS4 requires town centre uses in out of centre locations to be assessed under policies EC14; EC15; EC16; and EC17, covering supporting evidence; the sequential test; retail impacts; and weighing up considerations. The relevant parts are reproduced below and the application considered against each, informed as appropriate, by the Council’s retail consultants’ appraisal of the application. It is important to note that quantitative need is no longer a test under the new PPS for determining applications.

PPS4: Tests

Supporting Evidence; EC14.3 A sequential assessment (under EC15) is required for planning applications for main town centre’s uses that are not in an existing centre and are not in accordance with an up to date development plan. This requirement applies to extensions to retail or leisure uses only where the gross floor space of the proposed extension exceeds 200 square metres.

EC14.7 Assessments of impacts should focus in particular on the first 5 years after the implementation of a proposal and the level of detail and type of evidence and analysis required in impact assessments should be proportionate to the scale and nature of the proposal and its likely impact. Any assumptions should be transparent and clearly justified, realistic and internally consistent.

Sequential Test: EC15.1 In considering sequential assessments required under policy EC14.3, local planning authorities should: a) ensure that sites are assessed for their availability, suitability and viability. b) ensure that all in-centre options have been thoroughly assessed before less central sites are considered c) ensure that where it has been demonstrated that there are no town centre sites to accommodate a proposed development, preference is given to edge of centre locations which are well connected to the centre by means of easy pedestrian access. d) ensure that in considering sites in or on the edge of existing centres, developers and operators have demonstrated flexibility in terms of:

i) scale: reducing the floorspace of their development; ii) format: more innovative site layouts and store configurations such as multi-storey developments with smaller footprints; iii) car parking provision; reduced or reconfigured car parking areas; iv) the scope for disaggregating specific parts of a retail or leisure development, including those which are part of a group of retail or leisure units, onto separate, sequentially preferable, sites. However, local planning authorities should not seek arbitrary sub-division of proposals.

EC15.2 In considering whether flexibility has been demonstrated under policy EC15.1.d above, local planning authorities should take into account any genuine difficulties which the applicant can demonstrate are likely to occur in operating the proposed business model from a sequentially preferable site, for example where a retailer would be limited to selling a significantly reduced range of

products. However, evidence which claims that the class of goods proposed to be sold cannot be sold from the town centre should not be accepted.

Retail Impact: EC16.1 planning applications for main town centre uses that are not in a centre (unless EC16.1.e applies) and not in accordance with an up to date development plan should be assessed against the following impacts on centres: a) the impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal b) the impact of the proposal on town centre vitality and viability, including local consumer choice and the range and quality of the comparison and convenience retail offer c) the impact of the proposal on allocated sites outside town centres being developed in accordance with the development plan d) in the context of a retail or leisure proposal, the impact of the proposal on in- centre trade/turnover and on trade in the wider area, taking account of current and future consumer expenditure capacity in the catchment area up to five years from the time the application is made, and, where applicable, on the rural economy e) if located in or on the edge of a town centre, whether the proposal is of an appropriate scale (in terms of gross floorspace) in relation to the size of the centre and its role in the hierarchy of centres. f) any locally important impacts on centres under policy EC3.1.

Weighing up considerations: EC17.1 Planning applications for main town centre uses that are not in an existing centre and not in accordance with an up to date development plan should be refused planning permission where: a) the applicant has not demonstrated compliance with the requirements the sequential approach (policy EC15); or b) there is clear evidence that the proposal is likely to lead to significant adverse impacts in terms of any one of impacts set out in policies EC10.2 and 16.1 (the impact assessment), taking account of the likely cumulative effect of recent permissions, developments under construction and completed developments.

EC17.2 Where no significant adverse impacts have been identified under policies EC10.2 and 16.1, planning applications should be determined by taking account of: a) the positive and negative impacts of the proposal in terms of policies EC10.2 a. and 16.1 and any other material considerations; and b) the likely cumulative effect of recent permissions, developments under construction and completed developments.

EC17.3 Judgements about the extent and significance of any impacts should be informed by the development plan (where this is up to date). Recent local assessments of the health of town centre’s which take account of the vitality and viability indicators in Annex D of this policy statement and any other published local information (such as a town centre or retail strategy) will also be relevant.

Policy Designation

One of the problems of applying the rigours of PPS4 to the site is that Teville Gate was previously designated as a District Centre in view of the extensive retail and other uses existing on the site. Its designation was removed in the 2003 Local Plan given ‘the fragmented nature, the likelihood of redevelopment and the fact that it does not really perform as a local shopping centre in its own right’. If this designation had been retained, this would be regarded as a town centre site in policy terms. Without this policy designation, the site is regarded as ‘out of centre’ for retail purposes as defined by PPS4, as it is further than 300 metres away from the primary shopping area of Worthing town centre. One of the key aspirations of the development is to address the fragmented nature of the site reconnecting the site with links to the town centre and railway station.

Leisure and commercial town centre uses

Before assessing the acceptability or otherwise of the increased retail floorspace on the site it is important to consider the acceptability of the other leisure and commercial uses on the site (including A3 uses) against PPS4. The site is defined as ‘edge of centre’ under PPS4 for ‘other town centre uses’, as it is within 300 metres of Worthing’s town centre boundary. The applicant’s retail assessment does not consider these other uses and strictly speaking these uses also have to pass PPS4 tests set out above. The difference is that leisure uses are specifically promoted in the recently adopted Core Strategy, the level of leisure floorspace is less than the previous scheme and a similar amount of A3 floorspace is proposed. In considering the previous application (under the policy tests of PPS6) whilst some concerns were identified in relation to the extent of leisure uses proposed, it was accepted at that stage that there were no sequentially preferable sites that could accommodate the range of leisure uses proposed (previously public swimming pool, bowling and bingo). In reaching this conclusion it was accepted that there was considerable synergy with linking the leisure uses on the site and the economic and regeneration benefits of the scheme would outweigh any residual concerns. It is worth noting that the application was referred to the Secretary of State but it was not considered that the scheme raised issues of more than a local significance and the scheme was therefore not called in for determination.

The current scheme alters the mix of uses but the economic regeneration benefits remain and there remains a strong synergy between the different uses proposed. The restaurants and café uses will be clearly supporting the Hotel, conference/exhibition space and multiplex cinema. Whilst, it is not clear whether an hotel operator would run the conference and exhibition space this is obviously an option. Your officers would have some concern about the potential for existing A3 uses to relocate to the site from the town centre, however, it is considered that the mix of uses proposed would draw investment and new operators to the town without having an adverse impact on the town centre.

In assessing retail impact under Policy EC16.1 it is considered that the leisure uses now proposed are of an appropriate scale in relation to the size of Worthing town centre and therefore the scheme would not have an adverse impact on the town centre. In this respect it is fully expected that the proposed development would retain more expenditure within Worthing and increase opportunities for the site to draw more footfall into the town centre with linked trips. Whilst, it is noted

that the Cinema Association objects to the application on the grounds that the multiplex cinema would affect existing cinema provision within the town centre it does not seem to have regard to the significant number of residents that currently choose to travel to Chichester and Brighton Marina to visit multiplex cinemas and retaining this expenditure within Worthing would be a boast to the town centre vitality and viability.

In terms of the Hotel’s presence in the scheme this has been supported by the ‘Hotel and Visitor Accommodation Futures’ report commissioned by the Council in 2008. Although Tourism South East expresses some concern at the size of the Hotel, given current supply and demand in the town, it recognises that as part of a wider mixed use development it would drive up demand for visitor accommodation and improve the desirability of Worthing as a place to live, work and visit. The provision of a Hotel on the site would also comply with policy TSR5 of the South East Plan which recognises the benefits of locating accommodation close to transport interchanges and visitor attractions. The conference facility and exhibition space is also a very exciting addition to the scheme. Members are aware that the lack of such a facility has been a concern for some years and the Hotel Future’s report in 2008 also highlighted the scope for Worthing to re-establish itself in the ‘associations meetings’ market, given renewed conference and marketing activity by the Borough Council. As the Regeneration Manager comments the conference market has been hit by the current recession but a flexible facility could attract a variety of different functions and the exhibition space used for craft and wedding fairs etc. The Conference has been designed with vehicular access adjacent to the facility and could even be used for car shows etc. The town and surrounding area still has a number of large International Companies who could make use of such facilities and be able to make use of the adjoining Hotel with scope for other Hotels within the town centre also have a knock on benefit. The scope for a large, flexible exhibition space could be a significant addition to the town and add to the attractiveness of the town as a visitor destination.

It was accepted with the previous scheme that the redevelopment of this gateway site would be a catalyst for change which would trigger significant investment in the wider area including the town centre. The scheme itself would represent a £150 million investment by the applicant and would, in itself, demonstrate significant confidence in the town as a place to invest and create new business opportunities. The scope for providing additional employment on the site should also not be underestimated in terms of benefitting the local economy. The applicant estimates the scheme would generate in the region of 820 jobs when fully operational with an additional 160 or so jobs created within the local economy. In comparison the current potential employment on the existing site (if vacant office floorspace on the site was to be reoccupied) would be in the order of 280 jobs.

As part of a comprehensive mixed use development on the site it is considered that the leisure and commercial elements of the scheme are policy compliant and would significant enhance the local economy.

Retail Uses

Although the extant planning permission for the site included 2,322 m2 of A1 retail floor space (of which a maximum of 1,000 m2 could be used as food

retailing) and Teville Gate used to have a total of approx 4,600 m2 of retail floorspace, the current application would result in a significant increase. As such the application has to be considered under PPS4. Although, the Core Strategy refers to the scope to include an element of retail on the site this is only on the basis that it is supporting retail and does not compete with the retail offer of the town centre.

The application proposes 8,054 m2 (net 4,832 m2) of which 3,624 m2 would be convenience (food) and 1,208 m2 comparison goods. To assist reviewing the applicants Retail Assessment the Council has employed its own retail consultants (GVA Grimley). GVA has submitted a draft response to the Retail Assessment and the applicant has responded to the points of concern. It is anticipated that a final response to the applicants Retail Assessment will be available at the meeting.

In line with established practice, while there is no longer any policy requirement to demonstrate a need for the scale of convenience floorspace proposed, the applicant’s consultants have included a Capacity Assessment in an attempt to demonstrate the need for additional convenience and comparison goods retail floorspace. In this respect, it is recognised that consideration of need, both in quantitative and qualitative terms, is relevant to consideration of the sequential approach by determining what scale and form of foodstore is required as a pre- requisite to assessing whether there are any alternative more central sites on which to accommodate the store. There is also an acceptance that need/capacity may also be relevant to the consideration of impact on existing centres. In this respect, if there significant surplus expenditure in the area, the impact of the proposals is less likely to be significant.

Need/Capacity

The council’s Retail Consultant has commented in its draft response that the submitted retail assessment adequately covers the range of key policy tests set out in Policy PPS4, however, some concerns have been raised about its assessment of capacity, sequential assessment and impact on the town centre. Regarding capacity there is some concern that the level of surplus capacity in 2017 exceeds the findings of DTZ Retail Study commissioned by the Council in 2010. In response, the applicant’s retail consultants argue that their assessment is more up to date then the DTZ study (which was based on the earlier 2005 Retail Study), that catchment areas are different and the data used for each assessment is not from the same source. Whilst, there is some disagreement in connection with the level of capacity, the 2010 DTZ Retail Study did identify scope for approximately 2,550 m2 of additional floorspace by 2016 to meet surplus capacity. On balance, therefore, your Officers accept the applicant’s figures that there would be sufficient capacity for additional convenience goods floorspace within the identified catchment area particularly as need or capacity is not now a test in determining applications for new retailing.

Sequential Site Assessment

As set out above, Policy EC15 requires local authorities in considering Sequential Assessments to ensure that sites are assessed for their availability, suitability and viability and that all central options have been thoroughly assessed before

less central sites are considered. Your Officers had agreed the scope of sequentially preferable sites in advance with the applicant’s retail consultants and the main sites considered are the Grafton site, British Gas site, Stagecoach site and Union Place South. All these sites are identified as Areas of Change in the Core Strategy and refer to the scope for mixed use development; however, all of these sites have a number of constraints that would limit their scope to be either available or suitable to accommodate the proposed foodstore.

In considering these sites the applicant adopted a size requirement for foodstore at approximately 4,000m2 to reflect the size of the store it considers necessary to provide a viable main food shopping alternative to meet the need that it identifies within Worthing. Given the particular site constraints of the Stagecoach site and the Grafton site, it is not considered that either of these sites would be available or suitable for the provision of a foodstore. The Stagecoach site is in a sensitive location adjacent to a conservation area and immediately adjacent to two listed buildings, the Dome Cinema and Chatsworth Hotel. In addition the Core Strategy identifies this site as an opportunity ‘to complement the connectivity between the seafront and the retail sector and would suit a combination of ground floor small scale retail uses comprising of shops, cafes and cultural uses such as galleries which would support the area as a cultural quarter.’ In the circumstances this site would be suitable as an alternative town centre site.

The British Gas holder site has been allocated for a number of years for non-food retail but has not come forward because the site has not been de-commissioned and there are a number of access constraints. As a result the Core Strategy whilst still referring to the scope for a mixed use scheme refers to the 2009 Housing Land Survey which concludes that the site would be more suitable for a mix of dwellings including flats and town houses in the medium-term due to the need to resolve access and potential contamination issues. This site is not suitable or available and it could be argued that the site is ‘out of centre’ in any event for retailing as the majority of it is more than 300 metres away from the primary shopping frontage.

The one site that is potentially suitable in size and with fewer constraints is the retail core site identified in the Core Strategy as Union Place South incorporating Union Place car park, the Police Station and the Guildbourne Centre to the south. The site is identified as offering the best current opportunity for comprehensive new high street retail, leisure and residential development. The applicant’s retail study only referred to the Union Place NCP car park and Police Station and, therefore, incorrectly resolved that the site would be too small to accommodate the size of store required. Since that time, the applicant’s retail consultants have re-assessed the site but argue that the Development Brief and subsequent 2010 DTZ Retail Study focus on the delivery of non-food retail floorspace on this site - “a new development capable of delivering larger size retail units which will attract higher quality retailers and improve the primary retail offer”. It is submitted, therefore, that the Council’s aspiration for this site is very different to the proposal at Teville Gate for a ‘medium sized foodstore’.

Given the size of the Union Place South site, it could be argued that a foodstore, together with larger more flexible retail units could still be created to deliver the Council aspiration for a new retail heart for the town. Nevertheless, the applicant also argues that the Union Place South site is not available for development

within any reasonable timescales and, in this respect, the applicant’s consultants have referred to the significant number of different land ownerships which make up the retail core site and that it would take many years, even with the use of Compulsory Purchase Order powers, to acquire a site large enough to seek the comprehensive redevelopment of this area of the town centre. Whilst, the recently adopted Core Strategy endorses the Council’s aspiration to create a new retail heart for the town and this site would be sequentially preferable to Teville Gate, on balance your Officers do accept the concerns about the availability of this site in the short to medium term given the complexities of land ownership and site assembly. In addition, it is intended that the new retail heart would ideally be anchored by a department store rather than a foodstore.

Impact

The Council’s retails consultants are broadly satisfied with the projected turnover assumptions for the new store and the likely trade draw from other stores in the catchment area. In this respect, it is accepted that “like affects like” and that the large foodstore proposed would have the most direct impact on other large foodstores performing a main food shopping function. In this respect, it is submitted that most trading impacts are below 10% of the respective stores turnover at 2017 and that at 2012 there are only three stores which will feel an impact of more than 10%: the Morrisons store (- 6.23%); Sainsburys at Lyons Farm (- 18.54%); and Tesco in West Durrington (- 12.72%). As it is submitted that the Sainsbury and Tesco stores are significantly over trading, both these stores are predicted to continue to trade well above their benchmark turnover figures once the proposed store at Teville Gate is open and trading. The applicant’s retail consultants have also considered the impact on smaller stores within the catchment area but the impacts are negligible.

It is clear from the submitted Retail Study that one of the benefits of the proposed store is a reduction to car travel and journey times for residents in a catchment area by providing a more accessible modern retail destination within a wider mixed use development. In this respect, the greatest impact on trading will be on the operators store at Lyons Farm and therefore it argues that more local residents will be able to shop closer to home with the additional benefit of more liked trips to the town centre. It is interesting to note that the household survey shows that around 11% of all main food shopping trips takes place outside the catchment area, including Sainsburys in Rustington and the Tesco Extra in Shoreham. It is expected that a good proportion of these trips would be diverted back to stores in the catchment area. The Council’s Retail Consultant remains somewhat concerned about the impact of the proposed foodstore on existing stores in the town centre and further information has been submitted to try and address this concern in terms of trade diversion and the current performance of these stores. Members will be updated at the meeting on these points.

The cumulative impact of other convenience stores opening in the area has also been considered. In particular, 2,800m2 of convenience floorspace has been approved at the Country Fayre Garden Centre in Ferring. This would slightly increase the impact on two stores in Worthing, namely Morrisons and Tesco in West Durrington but it is submitted not to any significant effect.

In terms of a comparison goods to be sold at the new foodstore the predicted turnover from 1,200m2 of floorspace would be approximately one quarter of the

convenience goods turnover (£9.21 million at 2012). Although, the submitted retail study accepts that the comparison element of the new foodstore will not offer a full town centre selection of non-food products there is likely to be some overlap in the types of goods sold and as a result it is likely that some trade diversion will occur. This is especially likely when the customer is undertaking a main food shopping trip in the proposed store and chooses to purchases a complimentary comparison item in the same trip. It is submitted that the comparison offer would provide a consequent benefit to customers from increased choice and competition which will contribute positively to the Worthing catchment area. In this respect, the retail study mentions the existing Comet retailer on the site at present, attracting a number of shoppers from the catchment area. In terms of impact in relation to comparison goods, it is relevant to have regard to the existing retail floor space on the site and the 2,000 m2 previously granted on the site.

Your Officers are relatively satisfied with the evidence in relation to the impact of the new foodstore on existing stores within and out of centre subject to the final comments of the Councils retail consultant. Of perhaps greater concern is the potential impact of the development on ‘existing, committed and planned public and private investment in the town centre’. In this respect, the Council’s retail consultants have expressed some concern at any adverse effect the Teville Gate development may have on planned investment on Core Strategy sites considered suitable for accommodating mixed use development with an element of retail. Your Officers are not particularly concerned with regard to any adverse impact on smaller sites within the town centre where residential development will be the predominant use, particularly on seafront sites such as the Grafton and Stagecoach sites where the residential element is likely to be the enabling element to ensure these sites are developed.

There is some concern, however, at the potential of diverting investment away from the Union Place South site. It is clear from the District Valuer’s report on the viability of the Teville Gate scheme that the provision of a foodstore is critical to the commercial viability of the scheme. In a similar way a foodstore could act as an important ‘enabling’ element to bring forward the retail core site – Union Place South. This is a risk and is of some concern. Nevertheless, given the timescales for delivering the retail core site in a comprehensive manner, it is not considered that the redevelopment of Teville Gate site should be delayed in view of the negative impact that the current appearance of the site has on the approach into the town and the economic wellbeing of the area. The regeneration benefits of securing the sites early redevelopment are overwhelming in the current financial climate outweigh any residual policy concerns. The hope and expectation is that the site would be the catalyst for further inward investment and increased footfall into the town to ensure its continued viability. The foodstore is an integral part of the wider mixed use development but importantly is critical to its commercial viability.

In assessing the impact of the Teville Gate development on Worthing Town centre your Officers are reassured by the recent performance of the centre despite the recent recession. The Retail Gazette recently reported that ‘Stirling and Worthing buck trend for retail gloom’ following Springboard’s High Street Index for March which revealed that Stirling in Scotland and Worthing in West Sussex had reported year-on-year footfall increases of 29.4 per cent and 17.6 per cent respectively during the month. The success has been put down to both

towns benefiting from a mix of local initiatives and focusing on their town’s individualism to attract people into their town centres. As the predominant retail use of Teville Gate will be convenience (food) shopping it is not considered that this would have a ‘serious adverse affect’ and the positive economic benefits of the scheme ensure that the development would not conflict with the tests of PPS4.

(ii) Design, Scale Bulk and Massing Issues

The Design and Access Statement submitted in support of the application explains in some detail how the scheme has evolved following a lengthy iterative design process which has involved your Officers, the South East Regional Design Panel and English Heritage as well as public consultation exercises. The principle design objectives of the previous permission have followed through in many respects and improved by the incorporation of Teville Gate House. As the principle of tall buildings has been established on the site, it is not proposed to revisit this assessment as such but it is important to analyse whether any of the changes in the design, height, scale and massing of the proposed development conflicts with the CABE/English Heritage guidance on tall buildings and the relationship of the enlarged site with adjoining buildings and heritage assets.

Leisure and Retail Elements

The revised scheme is higher than that previously approved with the new conference centre extending approximately 8 metres higher on the Teville Road frontage and the new elevation onto Railway approach extending to 6 storeys in height replacing the existing 3 storey office block, Teville Gate House. In the context of Worthing even the lower floors of the development can be regarded as tall, however, the revised scheme has sought to mitigate this height when viewed from street level.

On the Teville Road frontage the architect has sought to maintain a similar scale of building to the previous approval recognising the need to step down the height of the development to defer to the lower domestic scale of buildings on the south side of Teville Road. As before, the development also steps down in height towards the Kwik Fit premises to the west of the site. The overall height of the Teville Road frontage extends to approximately eight storeys in height (having regard to the height of the ground floor retail and top floor conference facility). However, a series of setbacks ensures that the overall scale of the building is not visible at street level and the highest element of the conference centre roof is set back approximately 25 metres from the road creating an attractive south facing terrace and break out space for the Conference facility. The actual frontage elements of the scheme extend from 11 metres to 16.5 metres in height. The following photomontage views compare the previous approval (left) with the current proposal.

It is acknowledged, however that from more distant views the conference facility would be visible as a new civic facility. At the increased height the conference facility would be prominent from various viewpoints rising above lower scale development. However, the proposed design incorporating low eaves and a curved roof design would create an attractive profile with the extent of setback avoiding any overbearing effect onto Teville Road. The western elevation is also an improvement on the previous scheme which presented a rather plain side elevation of the multi-plex cinema.

The Teville Road frontage is further enhanced by projecting forward the fourth level of the western tower projecting forward as a ship’s ‘prow’ providing the opportunity for signage announcing arrival at ‘Worthing Gateway’. A series of colonnades along the southern frontage and into the site create attractive walkways, although it will be important to ensure some controls on how the foodstore use this large area of glazing to avoid large poster signs etc. The scale of development and high quality design together with the provision of a new landscaped frontage along this southern elevation would significantly enhance the quality of the townscape in this location. The use of render and glass with a horizontal emphasis would create a light contemporary feel to this elevation, particularly when compared with the rather harsh and bland elevation of Burfree House which, in itself, extends to the equivalent of a five storey residential building, albeit set back further into the site.

The scale of development along the Broadwater road frontage is again higher than before but this is not an issue on this elevation given the width of the road at this point and the scale of the existing car park and Morrisons store to the east. The emphasis has again been on creating an active frontage replacing what is currently a ‘dead’ grey frontage onto the principle access into the town. The revised design is also now set back approximately 6 metres from Broadwater Bridge which does help provide breathing space and an opportunity to improve the setting of the eastern elevation of the scheme. Pedestrians are currently ‘penned in’ crossing the bridge walking between metal barriers. An exciting element of this revised scheme is the opportunity to enable direct pedestrian access off the bridge to a covered colonnade at first floor level leading to a glazed shop front giving access to the first floor restaurant level. In addition, wide steps leading down from Broadwater Bridge would provide an east/west connection through a three storey glazed atrium to the Arcade, completely transforming this eastern elevation and improving pedestrian accessibility into the site.

The previous scheme would have created views into the proposed swimming pool and the provision of the health and fitness facility floating over the pool would have created a dramatic approach into the town. The revised scheme would create similar views into the active leisure element of the scheme and as the architect describes provides a new front door to the scheme on the Broadwater Road frontage. Above the colonnade walkway on the east elevation will be three floors of residential accommodation with a landscaped roof. To the rear would be the cinema roof set back 6 metres from the Broadwater Road frontage. The cinema roof would be very prominent approaching the site and it is pleasing to see that it has been given a bold curved form to reflect the form of the interior auditoria and curved with a high quality pre-patinated copper and zinc cladding. Given the prominence of this element of the scheme the use of high quality materials is essential.

The addition of Teville Gate House into the scheme provides an opportunity to dramatically improve the link between the station and the town centre as indicated previously. As importantly it allows the scheme to be ‘complete’ providing a new frontage to the three principal elevations and address a number of the shortcomings of Railway Approach in urban design terms. The existing office, whilst of a low scale, does not address the street being set behind a parking area and at a lower level. In addition the reverse circulation and width of Railway approach creates a very poor urban environment confusing for pedestrians and motorists. As a result the site is also effectively separated from the Station.

The scale of development has been adjusted during the pre-application negotiations to set back the top floor of the Hotel element of the scheme to try and reduce its overall height and mass when viewed from Railway Approach. This was also to help ensure that the development would not be overbearing or detract from the setting of the listed buildings to the north and west (former Station building and Grand Victorian Hotel). The overall height of the north elevation extends to 23 metres dropping down to 17.5 metres adjacent to the Grand Victorian Hotel. However, this apparent height is reduced by the set back to the top floor for the Hotel and by incorporating lower projecting brick clad balconies which will provide a colonnade walk along this northern elevation.

English Heritage has raised some concern about the scale of this northern elevation and your Officers recognise the potential impact on the setting of adjoining listed buildings. The development would be approximately 10 metres away from the single storey nightclub entrance attached to the Grand Victorian, however, a distance of approximately 23 metres away from its principal two storey element. The scale of the new development will, to some extent, diminish the presence of the Grand Victorian in the streetscene (given its height of 12.5 metres) although the visual prominence of its copper clad, gothic inspired tower will remain, particularly when emerging from the station albeit with a backdrop of the new residential towers. The proposed ramp to the decked car park adjoining the single storey elements of the building would be set some distance from the road and would not in itself harm the setting of the listed building from principal views to the building. Whilst, there is no doubt that the setting of this listed building will fundamentally change it is not considered, on balance, that this would be harmful given the high quality design of the scheme and the existing urban setting. This view is supported by the Councils Design and Conservation architect (see Consultation section).

The former station building opposite the site is of a very low scale (8 metres) and is attached to Capella House a 3 storey office building which extends to 11.5 metres in height. However, it is recessed from the road and although the proposed leisure and commercial element of the scheme would in many respects dwarf the scale of the listed building it would be located 30 metres away. The applicant has considered the scope to provide more of a set back to the top floor of the Hotel, however, any reduction in the level of floorspace proposed could affect the viability of the project. The design approach of introducing brick to this elevation is supported reflecting the materials of surrounding buildings although great care would need to be taken to ensure the most appropriate colour and texture is chosen. There is scope to further enhance the setting of the building by undertaking the paving and landscape improvements to Railway Approach. These works are essential to mitigate the impact of the development on this heritage asset as well as provide the necessary public realm improvements linking the site to the railway station. At the present time the applicant has confirmed that the highway aspects of improving Railway Approach would be included in the scheme costs and the further public realm enhancements would need to be included as part of the S106 development contribution.

The Residential Towers

Given the size of the application site, surrounding land uses and the height of the existing car park structures, there has been policy support for a bold architectural statement of the site. The principle of two tall buildings on the site has previously been accepted; however it is appropriate to review the current scheme for two taller towers given their increased height, different design and alignment. The following headings are those taken from CABE /English Heritage guidance:

The relationship to context, including natural typography, scale, height, urban grain, streetscape and built form, and the effect on the skyline

The previously approved towers on the site were 62 metres in length and lozenge shaped with a curved form. Despite some concern in connection with the visual impact of the towers when viewed from the east and west, it was considered that the use of high quality materials, in particular the decision to clad the building

entirely in glass for both opaque, spandrel and vision areas was considered to create a light and seamless building with the varying degrees of recessed elements creating the impression of different layers to the towers. In this respect it was considered that, particularly when viewed from the east, the previously approved towers would appear as a group of different towers in light of the faceted nature of the design with the rounded glazed end sections being far more transparent than the more solid vertical circulation elements. Overall, it was considered that the two towers would appear as a cluster of buildings, although it was accepted that their overall length reduces the ability of the development to have a strong vertical emphasis.

As previously indicated, in reviewing the previously approved scheme, the applicant’s architect has sought to look at improving the efficiency of the building by reducing the number of lifts and relying on a single staircase. The revised scheme now proposes two towers of a reduced length (55 metres) and a very different form. The footprint of the towers has now changed to a tapered elliptical form with a pointed southern ‘prow’ and more rounded north facing stern. The alignment of the towers has also changed. Rather than being parallel to the diagonal pedestrian route through the site, they are now located on a north south axis with the western tower moving slightly further south and the eastern tower further north. In terms of height the western tower is approximately 3.7 metres higher than the previous scheme whilst the eastern tower is approximately 12 metres taller. In addition, an enclosed plant room has been added increasing the overall height by a further 4.3 metres. The towers would now measure approximately 77.5 metres and 60.2 metres high (effectively 26 and 20 storeys high).

The revised design reduces the level of glazing and now incorporates a 60/40 ratio between cladding panels and glazing. The reduction in glazing is significant from the previous scheme; however, the cladding panels proposed are still effective in trying to create a lightweight and sleek elevational treatment. It is also clear that the reduction in glazing is also to help make the scheme more cost effective to build. It is not considered that the change in alignment of the towers or the increased height alters the previous assessment that the site could accommodate buildings of this scale and height. The Visual Impact Assessment (VIA) accepts that the prevailing character of the town is low rise and the relatively flat terrain will mean that any significantly high structure is likely to have a substantial significance on certain views. As before, therefore, it is not possible for the development to have any particular positive relationship with any relevant typographical feature or other tall buildings. The application effectively creates its own cluster and it is essential for the visual impact of the development to be carefully analysed from a variety of viewpoints. The VIA concludes that the revised scheme will make a new and positive contribution to Worthing skyline. However, it recognises that this is a subjective view and the VIA concentrates in categorising the significance of any change in view or townscape as well as identifying mitigating factors.

Impact on the wider landscape (distant views)

The sites location, broadly at the centre of the built up area, does help to reduce the wider impact of the proposed development. As before, the Visual Impact Assessment has considered elevated views over the town from the higher ground of the Sussex Downs, including views from Highdown Hill and Cissbury Ring, where the scale of the built form within the town can be readily understood. Notwithstanding the increase in height of the two towers, the VIA again considers that any adverse visual impact would not be significant. Your Officers support this view. Although an increase in height of more than 12 metres is significant, when considering more distant views it is the overall profile of the building and impact on the skyline that is significant and in many respects the reduction in length of the towers allied to an increase in height creates a more attractive profile giving the towers slightly more verticality and elegance. The buildings will ‘break the horizon line alike other tall buildings in the town which could be considered significant although as new landmark buildings equally it creates greater status to the prominence of the town centre when viewed from the Downs.

As before the VIA considers that the greatest visual impact would be from Highdown Hill as it would partially interrupt the sweep of the coastline, particularly looking towards Brighton and the building would be prominent against the skyline. Nevertheless the VIA assesses this visual impact as moderate significance and your Officers agree with this assessment. From Cissbury Ring and Lamley’s Lane the development will be viewed more in context with the existing urban area and your Officers agree with the assessment that it would not significantly impact on the character of the view from these locations and any impact is of minor significance.

Impact on the historic environment and landscape quality areas.

Since the last planning application, the South Downs now forms part of National Park and Members will note that some concern has been expressed by the National Park, albeit that this objection is only maintained if the previous permission does not remain extant. It is not considered however that the views from the National Park are of a substantial significance and similarly it is not considered that the revised design would affect views from the urban area looking towards the South Downs. Any harm to views looking towards the Downs is mitigated by both the alignment and profile of the towers. The principle view of the South Downs from the top of Chapel Road, for instance, is not affected as the photo montage taken in front of the town hall illustrates and the VIA suggests that the towers could have a positive effect in terms of ‘channelling views towards the Downs’.

In terms of listed buildings the VIA assesses the impact of the development on the Grand Victorian Hotel, the Town Hall and from Worthing Pier. Views from the Town hall and the Pier have not changed significantly and it is not considered that the view of the towers from the end of the Pier is significant or would have any wider impact on the historic seafront. Whilst, the towers would be significantly taller than the prevailing scale of buildings along the seafront this would only be appreciated from the end of the Pier and it is not considered that views to the towers would dominate or undermine the existing character of the seafront. The VIA assessment that the visual impact would be of moderate significance is supported. The VIA does state that a more direct visual impact would be on the statue on the war memorial as this would be viewed with the backdrop of the residential towers rather the skyline.

Although the VIA refers to the former railway station building and Ace House in Bridge Road, there is no assessment of the impact on these buildings. The VIA does assess the impact on the Grand Victorian Hotel and accepts that the visual impact will be of ‘substantial significance’, in this respect it refers to establishing a new setting for the listed building albeit that the simple clean lines of the development it submits would not conflict with the intricate vertical features of the listed building. As indicated earlier it is not considered that the towers would materially harm the setting of this building. In addition it is not considered that revised height, profile and siting of the towers affects the previous assessment that the towers would have any significant affect on former Station building or Ace House although both buildings would experience a substantial change to their current setting.

Localised Impact

The greatest visual impact would be quite clearly from surrounding residential roads particularly to the east and west of the site where the full width, bulk and massing of the development will be seen. The most dramatic impact of the development will be seen from Newland, Teville, Chapel and Broadwater Roads where there are longer views to the site and these are all considered to be of a ‘substantial’ significance in the VIA. Other viewpoints from surrounding roads would be also of ‘substantial’ significance and the view from the Co-op car park demonstrates the full visual impact of the east elevation. How successful the building mitigates this visual impact on the skyline for more localised views is dependent on its form, scale and massing as well as the quality of architecture and detailing.

The architectural quality of the building including its scale, form, massing, proportion and silhouette, facing materials and relationship to other structures. The design of the top of a tall building will be of particular importance when considering the effect on the skyline.

As stated previously the principle of two landmark buildings or towers has been accepted. By their very nature tall buildings will contrast substantially in height from the majority of buildings within the surrounding area. The submitted photomontages of the revised residential towers rising from the generally low rise surrounding buildings will result in a dramatic change to the skyline surrounding the site. Landmark buildings are, as a result, the most difficult type of higher building to design and sensitively integrate into a townscape. A landmark building has the ability to add interest and drama to the skyline. Its purpose on the Teville

Gate site is to draw attention to this important gateway and major public transport interchange as well as providing a focus and creating a positive and memorable image for the regeneration of the town. Generally landmark towers are designed with sculptural features and relatively slim profiles. They are often tiered and stepped where necessary to reduce any overbearing impact or dominance in the skyline.

When viewed from the north or south the towers retain their generally narrow form which helps to mitigate their impact and the increased height gives the development the intended landmark feature with significant verticality. Although a dramatic change to the skyline and a step change in the scale and height of building form it is considered that the views of the development primarily from Chapel Road and Broadwater Road would be acceptable in the context of the overall benefits of the scheme referred to earlier. The changed profile of the southern elevation does give, in your Officers opinion a more elegant feel to the towers when compared with the more rounded and fully glazed towers previously approved.

The greatest concern with the previous scheme related to the localised impact particularly from east/west views. At the start of the design process with the Regional Design Panel on the earlier scheme many years ago the initial adverse reaction was partly due to the slab or ‘wall’ like appearance of the building from east/west views. During the design process leading up to the submission of the previous planning application the overall length of the towers was reduced by 9 metres to improve the proportion of the buildings when viewed particularly from the west and this latest scheme again reduces the overall length of the towers by 7 metres to improve their slenderness and verticality. The previous scheme sought to use glass to create a transparent and seamless feel to the development to reduce its overall visual impact from more localized views. The architect for the revised design has sought to use pressed aluminium rainscreen cladding to again reflect the ‘slippery’ profile of the towers. The projecting open balconies of the southern elevation does help to reduce the overall length of the towers and your Officers had wondered whether a similar approach to the north elevation might also help to create more of a vertical building and create a lighter feel to the structure.

In response the architect has stressed that an important part of the design philosophy is that the more fully glazed and balconied southern element is seen to be emerging from the more solid, clad northern ‘shell’ (shell being reflected in the curved form and cladding material). Furthermore he submits that the tower design is both directional and reflective of the scheme opening up towards the seaward aspect. Your Officers recognise the importance of contrasting elements of the scheme which will change the appearance of the towers when viewed from different parts of the town and the design approach is understood. It is important to note that the revised design has been assessed by the Regional Design Panel and the scheme has evolved taking on board comments taken from the Design Panel at various stages. In this respect considerable thought has gone into the different cladding forms possible and the introduction of coloured squares which would be illuminated at night reflects comments made by the Panel to take on a ‘playfulness or lightness’ traditionally associated with seaside towns. Whilst your Officers still have some slight reservations about the extent of more solid cladding the general design concept of the towers, the revised form does give the

towers a more elegant shape and profile and the design overall is of exceptional quality.

The building will have a profound effect on Worthing’s skyline, however, to reduce the visual impact of the east/west view the scheme architect has sought to create a sleek building which by virtue of its angled profile and modeling will change in appearance from different viewpoints. Your Officers accept that the architectural form will result in the building, particularly from the east, appearing as a series of different towers in light of the sculptured nature of the design, the set back top floors and the contrast between glazed and solid elements of the scheme. Clearly even narrower towers would have less impact on the skyline than the current proposals. However, it is important to recognise the need to achieve a viable development on the site to secure the mix of leisure and retail uses and maximize the development potential. Previous schemes for leisure uses have failed and an important factor in this case has been the commercial brief to achieve this level of residential units on the site.

Often plant rooms, aerials and masts can disfigure the roof of higher buildings. The current design incorporates the plant rooms within a curved plant room enclosure to ensure that the clean and simple planes of the building are maintained. The exposed location of the site has dictated the use of robust, self- finished materials, which require little maintenance; however, it would be important to ensure that there is a long-term maintenance programme for the building as well as for public spaces around the building.

The relationship to transport infrastructure, aviation constraints and, in particular, the capacity of public transport, the quality of links between transport and the site, and the feasibility of making improvements, where appropriate. Transport is important in relation to tall buildings because of the intensity of use, as well as density, that they represent.

The applicant was able to demonstrate that the level of traffic generated by the previous development proposal would not require the signalisation of the two roundabouts adjacent to the site (junctions with Teville Road and Newland Road). At the time the County Council had argued that signalisation would be beneficial in terms of improved accessibility of the site for pedestrians and cyclists.

The current proposal will generate significantly greater vehicle movements and from an early stage the applicant has been keen to enhance the pedestrian accessibility of the site. As a result the revised scheme has evolved with an acceptance of the signalisation of both roundabouts. The scheme architect with encouragement from the South East Regional Design Panel has explored a number of radical options to enhance the public realm around the site by de- cluttering street furniture, barriers and signage. The need to improve the pedestrian link to and from the station from the town centre has been an important Masterplan objective and the provision of a quick and convenient straight crossing for pedestrians is important to ensure that this island site is re- connected with the principal route to the town centre. Whilst, agreement on a more radical solution based on the success of Oxford Circus was contemplated, it was clear at the pre-application stage that this could not be easily achieved through the application process. As a result the application and TA seeks to justify wide straight crossings on each arm of the new signalised Teville

Road/Chapel Road junction with improved surfacing and an all red phase to enable all pedestrians to cross at once.

Unfortunately, no agreement has been reached as yet with the Highway Authority on this arrangement and despite many months of negotiation. The difficulty is trying to reconcile the desire for improved pedestrian movement with the need to ensure the free flow of traffic. Both are laudable objectives. The development will add to congestion in the area and it is important that the development does not cause such congestion that deters visitors to the town centre. Equally it is important that improved pedestrian links are made between the site and the town centre to encourage linked trips and maintain the vitality and viability of the town centre.

The Highway Authority is currently assessing 5 alternative designs for these junctions and has indicated that it hopes to provide an update at the meeting. The options range from a ‘do nothing’ scenario to all staggered pedestrian crossings. The preferred option by the applicants is to at least secure a straight crossing at Teville Road to improve the accessibility of the site. Whilst straight crossings would create a more pedestrian friendly environment improving crossing times and removing unsightly barriers etc the Highway Authority is concerned that this would have an adverse affect on congestion at the junctions. In addition if pedestrians have to wait too long to cross then there could be safety issues with pedestrians trying to cross without waiting for the lights (the maximum waiting time is generally regarded as 2 minutes).

Whilst, the development will attract a significant number of trips to the site (the TA estimates approximately 10,000 arrivals and departures in any 24 hour period) the applicant has also demonstrated that even without the development the existing roundabouts would fail (capacity exceeding saturation point) in 2016. In this respect at the Newlands Road junction there would be 176 vehicles queuing on a single lane arm stretching back 850 metres. The TA has also identified existing capacity issues at the Teville Road South Farm Road junction even without development traffic and it is difficult to see how this junction could be improved in view of the limited highway land available.

The level of parking proposed for this high-density mixed-use development has provoked concern from local residents. This is, perhaps, not surprising given that parking is currently at a premium in this town centre location. Clearly, it will be important to balance the level of car parking provided on this sustainable site, to avoid additional on-street parking pressures, whilst at the same time avoid an over-provision, which increases vehicle movements and does not attract sustainable methods of transport.

In summary, the foodstore has parking for 400 cars (basement parking) whilst the multi-storey car park is proposed to have 180 spaces for the residential apartments, 237 for the other uses and 150 public car parking spaces (primarily for commuter parking). In assessing the appropriate level of car parking for the site, the TA has used the County Council’s 2003 parking standards. These standards recognise that for mixed use development the total provision should be assessed by an analysis of parking accumulation and not just a simple addition of the maximum standards. This is because the later would lead to over provision due to the staggered demand over the day for different uses. The accumulation parking levels have been based on agreed top rates with the

County Council and only assure 10% reduction for linked trips for the foodstore (this is likely to be higher in this location). The TA identifies that the maximum parking requirements would be 2044 whereas the accumulated requirement would be 1011 and the application proposes 967. Given the good public transport accessibility of the site in relation to buses, taxi ranks and the proximity of the railway station, it is considered that the level of car parking provision is reasonable. The foodstore operator also comments that it is satisfied that 400 spaces would be sufficient for a store of this size.

It is not clear at this stage what charging regimes would be in place for the parking provision for staff and visitors to the leisure and other facilities on the site. This would be subject to further negotiation with the different tenants of the building and potential car park operators, such as the NCP. As with the previous multiplex cinema permissions on the site, a condition could be imposed on any planning permission requiring the 150 car parking spaces to be reserved for public/commuter car parking.

In support of the application a draft Travel Plan has been submitted. As originally submitted the plan was considered to be light on detail and did not, for instance, include commitments to subsidise a car club or formal car sharing as well as other measures to encourage more sustainable modes of transport to the site. The plan has been the subject of considerable negotiation with the Highway Authority and various improvements have been made, however, as negotiations are still continuing regarding the s106 contributions and the overall viability of the scheme it is not clear at this stage whether the development can finance some of the Travel Plan measures including improving public transport buses to the site in the evenings and weekends. Members will be updated at the meeting.

The effect on the local environment, including microclimate, overshadowing, night time appearance, vehicle movements and the environment and amenity of those in the vicinity of the building.

This criterion assesses the immediate impact of the development in relation to such matters as wind turbulence, noise reflection, daylight, sunlight and overshadowing. Of significant importance is the impact on residential properties surrounding the application site. As with the previous scheme, the ES concludes that the majority of surrounding properties would experience negligible residual effects from the development in relation to daylight, sunlight and overshadowing. A minor adverse effect is anticipated for six rooms within Norfolk House but this is attributed to the design of this development with windows set back behind projecting balconies.

In relation to overlooking concern has been expressed that the height of the towers will result in significant loss of privacy for surrounding residential properties. Whilst, this is an understandable concern the layout of the towers facing predominantly east/west and the distance away from adjoining residential properties does mitigate the level of overlooking. The perception of being overlooked will be significantly increased but not to the extent that a refusal of planning permission could be justified. Properties immediately to the south of Teville Road would be 58 metres away from the towers, whilst Carlyle House to the north would be in excess of 100 metres. The closest residential development will be the flats in Norfolk House, which would be approximately 40 metres away; however, this is further away than the previous proposal. The main concern from

overlooking would be between the towers where the closest window to window distance would be 14 metres, however, the stagger in the towers and the avoidance of living rooms facing each other at this point helps mitigate the level of overlooking.

It is accepted that the construction of new tall buildings can, in certain circumstances, have potential to make significant alterations to the local wind conditions. These changes can affect both pedestrian comfort and safety and affect the overall suitability of the site for pedestrian use. The ES assess potential impact from the wind for the arcade seating areas and other open areas but concludes that any adverse affect would be negligible for the intended use of different parts of the site. The seating around the Pavilion is considered suitable during summer months and would be sheltered to some extent by proposed landscaping.

In relation to noise and vibration, the ES indicates that there could be temporary minor adverse impacts; however, it notes that any impacts are likely to be local and short term. The ES also sets out a number of mitigation measures to reduce any serious loss of amenity. It is accepted that the most widespread noise impact of the development is likely to be from increased traffic noise and service delivery vehicles. However, the assessment considers that the changes on the most affected roads, primarily a small stretch of Oxford Road and Railway Approach would be approximately 5.9db(a) which it concludes would not be considered significant in this urban environment.

Clearly, the level of retail, restaurants, cafes and bars on the site could have an adverse impact on noise and disturbance to local residents. In addition the large break out area to the south of the conference facility could have the potential for causing considerable disturbance to residents to the south of Teville Road and would need to be carefully controlled by planning conditions and through the normal licensing controls.

In relation to air quality, the assessment considers dust and exhaust emissions from construction plant and vehicles as well as other plant operating on the site. It recognises the need for environmental management controls in relation to dust and plant operating on the site but the overall conclusion is that the impact on air quality would be negligible.

The Environmental Health Manager has expressed some concern at some of the conclusions of the ES and the lack of a robust assessment of the likely affects of noise from service vehicles, plant and equipment, sound insulation and vibration and he recommends further conditions to control these matters. Regarding air quality in the area he recommends a condition/or a s106 requirement to install monitoring equipment on the site for a period of 10 years after the development has been completed to be paid by the developer.

The sustainability of the proposal: any tall building proposal must be sustainable in the broadest sense, taking into account its physical, social, economic and environmental impact based on whole life costs and benefits.

It is important that any tall building should be designed in line with sustainable development principles, taking into account its physical, social, economic and

environmental impact based on whole life costs, benefits and adaptability to future changes in lifestyles. The sustainability planning report submitted with the application sets out in detail the policy and legislative background to sustainability issues and puts forward a number of recommendations for the Teville Gate development to ensure that it uses less energy (be lean), uses renewable energy (be green) and supplies energy efficiently (be clean).

Your Officers are pleased to see that there is a commitment to meet level 4 - Code for Sustainable Homes as a minimum and for commercial floorspace to meet BREEM standard - Very Good with scope for individual tenants to meet the Excellent rating. The provision of a Localised Combined heat and Power (LHP) for residential and commercial uses, photovoltaic panels in the conference centre roof for night time illumination and sustainably sourced materials will all help meet these targets. Efforts have also been taken to enhance biodiversity with the provision of new planting areas and roof top gardens wherever possible.

The remaining two criteria of CABE/English Heritage guidance relate to public realm issues:

The contribution that the development will make to external and internal public spaces and facilities in the area, including the provision of a mix of uses, especially on the ground floor of towers, and the inclusion of these areas as part of the public realm. The development should interact with and contribute positively to its surroundings at street level; it should contribute to diversity, vitality, social engagement and ‘sense of place’ and,

The contribution made to the permeability of a site and the wider area; opportunities to offer improved linkages on foot, and, where appropriate, the opening up or effective closure of views to improve the legibility of the city and the wider townscape.

As stated under the Site Layout section of this report it is considered that the scheme layout together with the mix of leisure and commercial uses at ground floor level will make a significant contribution towards improving public realm creating new active street frontages. The site will become a major destination and offer the opportunity to forge strong pedestrian links between the railway station and the town centre. The revised scheme extends the public realm benefits and the signalisation of the two roundabouts adjacent to the site will improve accessibility for pedestrians and cyclists (although the final design of these pedestrian crossings is as yet unknown).

The final landscape details are to be submitted as a reserved matter but the initial public realm proposals submitted by the applicant are of a high standard and would transform the quality of public realm in and around the site helping to meet the Masterplan aspiration of a strong pedestrian link from the railway station to the town centre. The inspiration behind the enhanced public realm theme of a river flowing from the station (source) down through the site to the Piazza (mouth) is an exciting concept and it is really positive to see the scheme embracing the opportunities for public art to contribute towards creating visual markers and way finders through the site. Even though the site now has extended its frontage along Railway Approach the public realm strategy recognises the importance of a major piece of public art to act as a focal point or ‘lynchpin’ at the end of Railway Approach connecting the Station with the Piazza.

It will be important that these initial ideas are carried through into the final design and it is hoped that the applicant could work with local artists to develop these ideas and create a ‘visual narrative of Worthing’ leading down into the town centre.

At the present time the enhancements works are to be included as part of the s106 development contributions and given the concerns about the ability of the scheme to meet normal development contributions there is concern that these works may not be funded. As it is considered that these works are also considered essential mitigation measures to enhance the setting of listed buildings in Railway Approach your Officers consider that the scheme should commit to these off site works as part of the overall development. Whilst it is accepted that this may reduce the funds available to meet other normal development contributions the provision of enhanced public realm making the site more accessible is an integral part of the overall development.

The design of the Pavilion building is also an important aspect of the river theme and is designed to provide a visual and physical hub within the public piazza area. The central café is designed to appear as a water wheel or turbine with the blades acting as vertical brise soleil during the day and illuminated at night. In this respect the form and design of the Pavilion creates and enhances the circular flows and desire lines of pedestrians towards steps and ramps leading to the various crossing points around the site. The raised nature of the Piazza and proposed landscaping would help to transform the visual appearance of the site. Given the very high density of development proposed it is essential that every opportunity is take to create pockets of green space within the development not only to enhance public areas but also to enhance views of new residents of the two residential towers looking down onto the roofs of the leisure and commercial elements.

In assessing the current proposal in relation to CABE guidance, it is apparent that the criteria are largely met in relation to wider landscape impact, impact on the historic environment and the significant benefits in terms of public realm and improved pedestrian circulation. This scheme would not have an adverse impact on surrounding residential properties and would not have an adverse effect on the microclimate in relation to issues such as wind turbulence, noise reflection and overshadowing. The mixed use development is complex in form but of a high architectural quality. Although the lower leisure and commercial floors are still

high in contrast to the scale of surrounding developments the size of the development allows for taller elements to be set back from road frontages to ensure that the scale of development relates sympathetically with the streetscene and the development would not be unduly overbearing in scale form or massing. There is some concern regarding the impact of the development on listed buildings to the north and west of the site, however, the separation distances and ability to enhance the setting of these buildings through improvements to the public realm would mitigate an adverse impact.

The visual impact of the two residential towers, particularly to the east and west, are clearly more substantial and the taller elements of the scheme would have a profound effect on the skyline. The revised design is in some respects more solid and less transparent with the reduction in glazing but overall the design is an improvement and does have a more elegant and refined appearance with its projecting ‘prow’ and ‘playful’ patterned cladding. The provision of such a large building on Worthing’s skyline is obviously controversial and will dramatically alter local views, nevertheless it is considered that the overall regeneration and leisure benefits of this scheme and the support from the SERDP justifies the scale of these residential towers.

Whilst the advice from CABE and English Heritage has been followed in relation to supporting justification and criteria, it is important to stress that this guidance also advocates the importance of a plan led approach to the location of tall buildings and that tall buildings should only come forward as part of a planned exercise in place making rather than an ad hoc speculative way. Whilst English Heritage did not object, in principle, to tall buildings on the site or to the submitted design, it previously expressed concern that it would be premature for such a proposal to receive any approval until the wider issues of a precedent for tall buildings had been fully considered and debated as part of a plan led approach. This concern is appreciated and your Officers would certainly be concerned about this development setting any precedent for buildings of this height and scale in the town. Nevertheless, your Officers did not consider that the lack of a clear policy on tall buildings should prevent the previous scheme being supported.

Your Officers do accept that further work on the design and height of new development on Core Strategy sites is an important next step and now that the Core Strategy has been adopted this will be taken forward to inform other sites coming forward. The benefits of this development in relation to the town’s economy, housing provision and improved leisure facilities outweigh any residual concerns in relation to the scale and height of the development and the current lack of a tall building strategy for the town. The following quote from CABE/English Heritage guidance is particularly relevant that any new tall building “should produce more benefits than costs to the lives affected by it”.

Section 106 Planning Obligations

The applicant has indicated that given the current financial climate and previous concerns about the viability of earlier projects the scheme would not be able to meet the 30% affordable housing requirements for this site or meet all the development contributions a development of this scale would normally provide. As a result the applicant has agreed an ‘open book’ approach where the viability of the scheme can be assessed to ascertain the extent to which the development

can ‘afford’ to meet affordable housing requirements and other development contributions. A viability assessment has been submitted but remains confidential in view of commercial sensitivity particularly surrounding agreements reached with individual operators. The District Valuer has been consulted to advice on the submitted viability assessment and his conclusion is set out under the consultations section of this report.

At the present time the applicant is not proposing any on site affordable housing and has suggested that if the public realm enhanced works are undertaken in Railway Approach then this would leave only £1.5 million for any off site affordable housing contributions as well as contributions towards Travel Plan requirements, bus contributions, education and open space. Although, the District Valuer requires additional information and the full extent of development contributions is not known, it is clear that a degree of flexibility will be required if the Council is willing to support this scheme.

With considerable uncertainty regarding the Country’s economic recovery a number of development schemes are on hold and your Officers are keen to ensure that this important regeneration scheme is brought forward as soon as possible. Any planning obligation could require additional contributions if the scheme exceeds a normal return on profits in the future. This would help to give the Council some re-assurance that if there is an upturn in the economy the scheme still provides the appropriate level of contribution to address any additional strain on local infrastructure as a result of the increased population generated by the development. In terms of affordable housing your Officers are keen to encourage some on site accommodation (shared ownership was previously provided on the Teville Road frontage with a contribution towards social rented off site).

10. CONCLUSION AND INTERIM RECOMMENDATION

There can be little doubt that there is an urgent need to redevelop Teville Gate. The site’s rundown appearance, even with the demolition of the majority of the former shops, seriously detracts from the main approach into the town by road or rail. The current development proposal would make significant improvements to public realm within the site, provide a significant number of residential apartments in a sustainable location and greatly improve leisure and cultural facilities for the town. Of great importance is that the redevelopment of the site for this mix of uses is anticipated to act as a catalyst for further regeneration in the area.

It is clear, however, that for this development to be implemented it requires the inclusion of a large foodstore to ensure its viability. Although, the Councils retail consultant has expressed some concerns about the applicants Retail Assessment particularly in relation to the impact on other town centre development sites, your Officers consider that, on balance, the impact is not significant given the current health of the town centre and the significant spare capacity for additional comparison (non food) retailing. In addition two of the 4 sequentially preferable sites are in seafront locations where the primary use will be residential accommodation with more limited scope for retail uses. The British Gas Holder site has a number of constraints and as a result has limited potential for a significant level of retail floorspace (in any event most of the site is out of

centre for retail purposes). The one site of concern regarding the potential for diverting investment and delaying its delivery is the retail core site (Union Place South). However, to accord with the requirements of the recently adopted Core Strategy this site requires significant site assembly and cannot be regarded as being deliverable within the short to medium term. In addition, this site is regarded as the key site for delivering larger more flexible non food retail units to re-establish the town as a regional shopping centre. It is not considered that the provision of a foodstore on the Teville Gate site would, therefore, significantly affect the ability of the Council to deliver this aspiration in the longer term.

The overall design of the proposed development is of a very high quality and great thought has been given to integrating a complex mixed use development in a sympathetic manner. The principle of tall buildings has been previously established on the site and despite the current proposal being a denser scheme, incorporating higher commercial and leisure elements and higher residential towers; it is not considered that the development would have a greater visual impact on local residents or the wider landscape. The impact on heritage assets has been assessed and although adjacent listed buildings will have a dramatically different backdrop it is not considered that this in itself would be harmful to their intrinsic character or setting. The improvement to Railway Approach is considered an integral part of the scheme to improve the links between the station and the town centre and will enhance the setting of the former Station building to the north of the site. The benefits of the scheme are numerous and overall the scheme will transform the approach into the town and create a thriving mixed use development which will assist the overall economic wellbeing of the town.

At this stage key issues regarding the impact of the development on the highway network and the precise design of signalised junctions and pedestrian crossings have yet to be resolved. It is hoped that at the time of the meeting the Highway Authority will be in a position to comment on the various junction designs submitted by the applicant. The applicant is still keen to incorporate an enhanced pedestrian crossing for Teville Road as a compromise solution (as originally submitted the scheme proposed an all red phase to facilitate maximum pedestrian movement to and from the site). This compromise solution does appear to address capacity issues although it does result in longer waiting times for pedestrians at certain times. As there is still a need to undertake negotiations regarding s106 contributions Members are requested to give their preliminary views on the following matters: i) Assuming that an appropriate highway solution can be found to deal with the impact of traffic on the local highway network, can the principle of a foodstore on this site be supported in addition to the other mixed uses proposed having regard to the advice in PPS4; ii) The design, height, scale and massing of the revised scheme and; ii) Note the current position regarding negotiations on the s106 agreement and provide any initial comments regarding the priorities for development contributions and affordable housing provision.

11. BACKGROUND PAPERS

Observations of the Head of Health, Housing and Community Safety Observations of the Highway Agency Observations of the South Downs National Park Authority Observations of the Environment Agency Observations of West Sussex County Council Observations of the Conservation Area Advisory Committee Observations of Southern Water Observations of EDF Energy Observations of English Heritage Observations of the Crime Prevention Design Advisor for Sussex Police Observations of the Design and Conservation Officer Observations of the District Valuer Observations of Tourism South East Observ a tions o f The W orth in g So ci ety Observations of the Worthing Astronomical Society Observations of the Cinema Theatre Association

29th June 2011

2

Collins Planning Services Ltd WB/11/0249/FULL and Mrs Alina Rizzoni WB/11/0250/LBC HEE JMO

Location : The Burlington Hotel Marine Parade

Proposal: Resubmission of WB/10/0596/FULL and WB/10/0564/LBC for retention of signage and re-positioning of some existing external lighting.

Not to Scale

Reproduced from OS mapping with the permission of HMSO (c) Crown Copyright Licence No LA100024321

1. THE PROPOSAL AND THE SITE

The application site comprises the Burlington Hotel, a Grade II listed building in an Italianate style by G A Dean, dating from 1865 (originally ‘The Heene’). The listed building occupies a prominent seafront corner site at the junction of Marine Parade and Wordsworth Road. Together with the adjacent listed Heene Terrace, it forms part of a cohesive urban set piece within the surrounding townscape. Attached to the rear (northern) part of the Hotel, fronting Wordsworth Road, is the Imperial China Restaurant. This building originally formed part of the Hotel until planning permission was granted for a change of use to a restaurant in 2000.

The site lies within the Marine Parade and Hinterland Conservation Area. The character and appearance of this part of the Conservation Area is largely derived from the 19th Century form of development in a grand Victorian interpretation of Regency architecture, including balconies, canopies, columnated entrance porticos and stucco decoration.

Planning and Listed Building Consent is sought for the retention of the vinyl signs applied to the ground floor glazing and retention of 11 external floodlights (involving some re-positioning of the existing lamps and wiring).

2. PLANNING HISTORY

The existing 11 no. floodlights and remaining vinyl signs are unauthorised. The current application results from discussions between the applicant and Council’s Officers, including the Council’s Conservation and Design Architect, following the refusal of earlier planning and listed building consent applications in September 2010 (WB/10/0564/LBC and WB/10/0596/FULL) on the following grounds:-

WB/10/0596/FULL

1. The floodlights as installed constitute an unsympathetic and prominent alteration, which by reason of their utilitarian design, manner of their fitting and siting on the building, insensitive to its architectural features, are harmful to the visual integrity and historic character of this grade II listed building and fail to either enhance or preserve the character or appearance of the Marine Parade and Hinterland Conservation Area. The development is therefore contrary to saved Local Plan policy BE1, Submission Core Strategy policy 16 and national planning policy contained in PPS:5 .’Planning for the Historic Environment’.

WB/10/564/LBC

1. The floodlights as installed constitute an unsympathetic and prominent alteration, which by reason of their utilitarian design, manner of their fitting and siting on the building, insensitive to its architectural features, are harmful to the visual integrity and historic character of this grade II listed building. The development is therefore contrary to saved Local Plan policy BE1, Submission Core Strategy policy 16 and national planning policy contained in PPS:5 ‘Planning and the Historic Environment’.

2. The red vinyl lettering applied to the upper sashes of the narrow, arched windows on the west elevation, and the squared-headed window adjoining to the north, appear unduly dominant owing the manner of their display and unsympathetic design which fails to respect the proportions of the individual windows and their sub-divisions and together with the overall number of signs on windows in this elevation is considered to detract from the visual integrity and historic character of this grade II listed building. The development is therefore contrary to saved Local Plan policy BE1, Submission Core Strategy policy 16 and national planning policy contained in PPS:5 ‘Planning and the Historic Environment’.

The above retrospective applications (WB/10/0596/FULL and WB/10/0564/LBC) were submitted as a result of an enforcement investigation following a complaint about the external lighting initially received in 2009.

3. A SUMMARY OF THE APPLICANT’S DESIGN AND ACCESS STATEMENT

“The works the subject of this application have a minimal impact on the appearance of the listed building comprising the installation of external light fittings to highlight the features of the listed building and increase its visibility. The external lighting emphasises the prominent location of the building within the conservation area.

The submission involves moving some of the existing light fittings and re-routing the external wiring to conceal this wherever possible. The works are an important part of moves to increase the viability of this listed building. In this day and age it is essential for a hotel to be highly visible in order to attract customers and therefore safeguard the future of the building. The installations have been carried out in a sensitive manner that highlights the features of the listed building, marking it more prominent in the townscape and encouraging more people to use the building.

It is important that this listed building continues to be used in the way that it was originally proposed and that the hotel is allowed to update aspects of the building in a sensitive manner that respects the context and historic value of the building.”

4. CONSULTATIONS

None.

5. REPRESENTATIONS

A strong objection has been received on behalf of the proprietor of the Imperial China Restaurant (adjoining to the north) commenting that the external coloured lighting is not acceptable (in blue or any other colour), on a listed building. It is argued that the application(s) should be refused and if necessary enforcement action taken to remedy the breaches of planning control and listed building consent. When the extension above the restaurant was built some years ago serious consideration was given to the work and every effort was made to ensure that the work was in keeping with the main Listed Building.

No comments have been received from the Conservation Area Advisory Committee (CAAC) in respect of the current applications, but CAAC previously expressed concerns over the number of vinyl signs and reserved judgement on the lights.

The current applications have been referred to Committee for decision by Councillor Joan Bradley.

6. PLANNING ASSESSMENT

The display of the vinyl signs and installation of external lighting constitute alterations for which listed building consent is required. The installation of the external lighting materially alters the appearance of the building and therefore constitutes development requiring planning permission. Although it is apparent that the external lights have been in existence on this building since c.2002, immunity from enforcement action has not been assumed through the passage of time owing to the listed status of the building.

The relevant consideration is whether the current proposals address the grounds for refusing the earlier applications with regard to their effect on the historic character of the listed building and its features of special architectural importance, and on the character and appearance of the Conservation Area.

All advertisements are intended to draw the attention of passers-by and are essential to commercial activity. It is accepted that some form of advertisement is warranted if the viable use of the building as a Hotel and associated facilities, including Gio’s restaurant/bar, is to be secured in the long-term. However, advertisements on Listed Buildings should not detract from the integrity of the building’s design, historic character or structure, and should not spoil or compromise its setting.

In refusing the earlier retrospective application, it was recognised that the concept of applied lettering onto the windows is a relatively discreet form of advertisement compared to the alternative of a hanging sign or individual letters applied to the external wall of the building. However, it was considered that the red lettering on the paired, narrow, arched-top windows and the traditional squared-headed window on the west elevation was unduly dominant in that the particular form and extent of lettering failed to respect the narrower proportions of those windows (compared with the larger, arched windows), detracting from their visual integrity. Following the refusal of the earlier application and discussions on site involving the Council’s Conservation and Design Architect, the signage on the above-mentioned arched-top windows and the square-headed window has been removed in its entirety. Only the applied lettering ‘Gio’s’ in the top segment of one of the large arched-top windows on the west elevation, and two of the arch-top windows in the south side of the enclosed verandah and on one bottom pane in the west side of the enclosed verandah, remain in situ. The resulting effect is considerably subdued and is considered satisfactory.

There is no objection in principle to the external floodlighting of historic buildings. Where this is sensitively designed to respect the historic character and architectural features of a building it can add to their visual interest and complement commercial function.

In this case, the existing lamps, when illuminated, cast a vertical blue light which illuminates the cornice band and underside of the eaves (rather than any specific feature on the building) on the south and west-facing elevations, together with the entrance to the nightclub on the south side. In refusing the earlier retrospective applications, no objection was raised to either the principle of the external lights, or to the blue colour of their illumination. The main concerns related to the design of the lamps, and their method of attachment and

positioning on the building. In particular, the siting of the existing up-lighters is not sensitive to the architectural features of the building and the lamps themselves are rather ‘bulky’ and utilitarian in appearance. They have been poorly fitted, with wiring cutting across, both horizontally and vertically, the rustication on the ground and first-floor.

Following discussions on site, the current applications seek to address the concerns about the siting of the lamps on the west elevation by re-positioning 2 existing lights so that all 4 light fittings would be aligned on the string course adjacent to the bottom edge of the first-floor balconies. This would achieve a more balanced appearance with the lamps sited symmetrically on either side of the balcony features. The wiring would be re-positioned horizontally along the top edge of the string course where its visual impact would be minimised.

On the south elevation, it is proposed to re-site the 2 no. lights currently positioned on either side of the first-floor canopy, to new positions just above the eaves of the canopy. At present, the prominence of the existing lights is emphasised by their relatively exposed positioning and trailing wiring. The proposed re-siting of the lights in juxtaposition to the canopy will result in a less cluttered appearance and allow the wiring to be concealed by the existing downpipes on either side. It is also proposed to lower the other 2 lights on this elevation so that they sit on the top of the string course separating the first and second floors (with the wiring running horizontally along the edge) thereby having a slightly less exposed position than at present.

It is proposed to retain the existing decorative lights on either side of the entrance to the single-storey nightclub element, and the flood lamp positioned over the entrance door of the latter. The siting of the decorative side lights appears slightly awkward on the narrow mullions of this façade, but from their condition, it would appear these have been in existence for many, many years.

Conclusion

The re-positioning of the lamps will result in an improvement compared to the existing situation, albeit that the re-use of the existing light fittings is not ideal. However, during the course of discussions with officers the applicant has made it clear that the cost of replacing the existing light fittings with new (either smaller or more sensitively designed fittings), is prohibitive in the current economic climate.

Up-to-date national policy contained in PPS5 states that where a proposal has a harmful impact on the significance of a designated heritage asset which is less than substantial harm, the local planning authority should weigh the public benefit of the proposal (for example, that it helps to secure the optimum viable use of the heritage asset in the interests of its long-term conservation) against the harm and recognise that the greater the harm to the significance of the heritage asset the greater the justification will be needed for any loss.

In this case, both the external lighting and the remaining vinyl signs support the commercial viability of the existing Hotel, which is the optimum use of the listed building. It is also pertinent that neither the lighting nor the applied lettering will result in permanent harm to the fabric of the listed building. All things considered, whilst the existing lighting fittings themselves may not be the most sensitive type of flood lamp, it is considered that providing they are re-sited in a sympathetic

manner, as described, refusal would not be justified as proportionate to the harm caused to the visual integrity or historic character of this Listed Building.

7. RECOMMENDATION

WB/11/0249/FULL

Planning permission be granted subject to the following conditions:-

1. Works to be carried out within 2 months of date of decision. 2. Approved plans

WB/11/0250/LBC

Listed Building Consent be granted subject to the following conditions:-

1. Works to be carried out within 2 months of date of decision. 2. Approved plans

8. BACKGROUND PAPERS

Letter of representation from a third party.

29th June 2011

BACKGROUND PAPERS

Statutes and Orders Planning and Compulsory Purchase Act 2004 Planning (Listed Buildings and Conservation Areas) Act 1990 The Town and Country Planning Act 1990 Planning and Compensation Act 1991 The Town and Country Planning (Use Classes) Order 1987 (as amended) The Town and Country Planning (General Permitted Development) Order 1995 (as amended) Crime and Disorder Act 1998 Human Rights Act 2000 Licensing Act 2003 Planning Act 2008

Development Plan Policy Saved policies of the Worthing Local Plan 2003 (Regional Planning Guidance for the South East (RPG9 now referred to as RSS9)

Emerging WBC Planning Policy WBC Core Strategy Submission version April, 2010 : Worthing Borough Council WBC Planning Contributions SPD

Planning Policy Guidance PPG2 : Green Belts PPG8 : Telecommunications PPG13 : Transport PPG14 : Development on unstable land PPG17 : Planning for Open Space, Sport and Recreation PPG18 : Enforcing planning control PPG19 : Outdoor Advertisement Control PPG20 : Coastal planning PPG24 : Planning and noise PPG25 : Development and Flood Risk

Planning Policy Statements PPS1 : Delivering Sustainable Development PPS : Planning and Climate Change – Supplement to Planning Policy Statement 1 PPS : Eco-towns – A supplement to Planning Policy Statement 1 PPS3 : Housing PPS4 : Planning for Sustainable Economic Growth PPS5 : Planning for the Historic Environment PPS6 : Planning for Town Centres PPS7 : Sustainable Development in Rural Areas PPS9 : Biodiversity and Geological Conservation PPS10 : Planning for Sustainable Waste Management PPS11 : Regional Spatial Strategies PPS12 : Local Spatial Planning PPS22 : Renewable Energy PPS23 : Planning and Pollution Control PPS25 : Development and Flood Risk PPS25 Supplement : Development and Coastal Change

Circulars Circular 03/07 : Town and Country Planning (Control of Advertisements) (England) Regulations 2007 Circular 04/06 (ODPM) : Planning Inquiries into Major Infrastructure Projects : Economic Impact Reports Circular 01/06 (Communities and Local Government) : Guidance on Changes to the Development Control Circular 10.05 : Permitted Development Rights for Antennas Circular 06/05 : Biodiversity and Geographical Conservation – Statutory Obligations and their Impact within the Planning System Circular 05/05 : Planning Obligations Circular 03/05 : Changes of Use of Buildings and Land – The Town and Country Planning (Use Classes) Act Circular 04/00 : Planning Controls for Hazardous Substances Circular 07/99 : The Town and Country Planning (Development Plans and Consultation) (Departures) Direction Circular 02/99 : Environmental Impact Assessment Circular 09/98 : Town and Country Planning (playing fields) (England) Direction 1998 Circular 10/97 : Enforcing Planning Control : legislative provisions and procedural requirements Circular 11/95 : Use of Conditions in Planning Permission Circular 15/92 : Publicity for Planning Applications Circular 05/10 : Changes to Planning Regulations for Dwelling Homes and Homes in Multiple Occupancy Circular 03/09 : Cost awards in appeals and other planning proceedings

Supplementary Planning Guidance WBC Adopted Parking Standards – March 2003 Infrastructure Requirements for New Development in West Sussex Parts I and II Total Access Demand Methodology and Stage 1 Safety Audit and Travel Plan Guidance : West Sussex County Council Outdoor Recreation Space Survey 1999 : WBC

General Tree Preservation Orders – A Guide to the Law and Good Practice : DCLG 2006 List of Buildings of Special Architectural or Historic Interest : Department of the Environment Protected Trees : A guide to Tree Preservation Procedures ODPM 2004 B55837 : Trees in Relation to Construction

Good Practice Guides Crowded Places : The Planning System and Counter-Terrorism Safer Places : The Planning System and Crime Prevention Guidance on the permeable surfacing of front gardens Looking after our town centres The Validation of Planning Applications : guidance for local planning authorities Best Practice Guidance on Listed Building Prosecutions Good Practice Guide on Planning for Tourism Planning for Town Centres : Guidance on Design and Implementation tools Diversity and Equality in Planning : A good practice guide Review of guidance on hedge height and light loss Planning and access for disabled people : a good practice guide

Manual for Streets : Dft 2007 Places, Streets and Movement : A Companion Guide to Design Bulletin 32 – Residential Roads and Footpaths Planning Policy Statement 25 : Development and Flood Risk – Practice Guide Good Practice Guide on Planning for Tourism By Design : Urban Design in the Planning System – Towards Better Practice PPS5 : Planning and the Historic Environment – Best Practice Guidance Greater Flexibility for Planning Permissions – Guidance Guidance on information requirements and validation Site layout planning for daylight and sunlight : A Guide to Good Practice BRE 1991 Safer Places : The Planning System and Crime Prevention : ODPM 2004 Development Management : Proactive Planning from pre-application to Delivery Masterplan for the Town Centre and Seafront : WBC 2006 West Sussex Design Principles : West Sussex Design Commission 2007 By Design : Urban Design in the Planning System – Towards Better Practice Better Homes by Design : A Companion Guide to PPG3 Access for All : WBC – November 1992 Design Wise – Design Principles of Shopfronts and Signs : WBC – September 1994 Design Guidance – Altering or Extending your Home : WBC – June 1998 Scheme for the Preservation and Enhancement of the Seafront and Hinterland Conservation Area : WBC – November 1994 Landscaping Guide – Supplementary Planning Guidance for Developers – WBC 1998 Good Practice Guide on Planning for Tourism – May 2006 Planning and Access for Disabled People – A Good Practice Guide : ODPM 2003

Studies and WBC Local Development Framework – Evidence Base Coastal Districts Retail Study – September 2005 Core Strategy Submission Draft – Evidence Base East Worthing Access Road (EWAR) February 2006 Economic Research for Employment Land Employment Land Review (ELR) Financial Viability Affordable Housing Study Housing Market Bulletins Housing Needs Survey – 2004 Housing Strategy Infrastructure Delivery Plan (Draft) April 2010 Open Space, Sport and Recreation Summary Note 2009 PPG17 Study Retail Study 2009 Strategic Flood Risk Assessment (SFRA) January 2008 Strategic Housing Land Availability Assessment Strategic Housing Market Assessment Study of Economic Viability – Viability of Affordable Housing Sustainable Energy Study Urban Housing Potential Study – June 2004 WBC and WSCC Transport Statement of Common Ground Worthing Desktop Biodiversity Report Worthing Gap and Landscape Capacity Study Worthing LDF Strategic Transport Study Conservation Area Appraisals Worthing Local Interest Buildings Study 2003