Dear Torbay Council / Planning
In accordance with the Government Farrell Review recommendations 06, Torbay Coastal Heritage Trust; with its team of professionals, are engaging with the neighbourhood, and local communities in Torbay, and are acting as Civic Champions to improve design quality for the Torbay built environment.
Mr Derek Elliott Architect declared in the application form 18/10/2018, that he acts as the agent for the applicant alias Dr James Koh, previously known in Singapore as Mr. Koh Wee Meng. Company name for development: Fragrance UK – Torquay 2 Limited, Great St. Helens, London.
Mr Derek Elliott Architect is a principle shareholder in the business Kay Elliott Ltd, 5-7 Meadfoot Road Torquay TQ1 2JP advertising to attract potential clients “We design buildings, places and concepts that enhance financial value” Torbay Council are their client developing the environment.
Mr Derek Elliott as a member of the The Royal Institute of British Architects is bound by three principles of professional conduct quote:-
“Honesty, integrity and competency, as well as concern for others and for the environment.”
To satisfy his duty – advertised to the client developer – can cause serious conflict with conduct rules. To increase financial value will lead inevitably to overdevelopment of this site without concern for others, the environment or design competency.
Evaluating one of the documents by the architect “The Design and Access Statement” with open consideration. The architect’s statements in italics – followed By TCHT comment and critique.
Page 3. The Corbyn Head Hotel Introduction
“This document supports the application of planning permission for the redevelopment of The Corbyn Head Hotel, Torquay, on behalf of Fragrance UK – Torquay 2 Limited.
The purpose of this document is to assist Torbay Council and other interested parties in understanding and appraising the design. It outlines our design aspirations for a new hotel development on this key site. It aims to describe the scheme’s design principles and provides insight into its layout, composition and choice of materials.”
The content is a marketing document to promote enhancing financial value for developer.
Page 6. Context Site Photographs
“The demand and political support for holiday accommodation has seen the Corbyn Head Hotel
grow from a modest domestic scale building into an amalgamation of ad hoc extensions which create a 45 bedroom hotel of some 85m in length.”
Comment; It is accepted the principle of respectful quality redevelopment within the limitations of a very small site, but not as the submitted overdevelopment, disrespectful to neighbours.
Page 13. Planning Policy & Guidance
“The proposals accord with Local, Regional and National policy;”
This statement is dishonest in relation to many Torbay Council policies introduced 2010 including the key detail coastal Building Heights strategy, not considered as valid by agent Derek Elliott!
“Attracting new visitors from Britain and abroad” “Attracting new investment into Torbay Improving the quality of the accommodation on offer Improving hotel occupancy throughout the year”
The quality of accommodation designed will only attract those with a tight budget limiting spending. Not the star quality to attract the preferred tourists from all over the world, with ability to spend well, boost the Torbay local economy. Their design is for a budget hotel in a 5 star location.
Page 14. Proposals: Use & Amount
“The current proposals include:
- Internationally recognised 4* Full Service Hotel, with Spa and Rooftop Bar”
4* for service is alleged. The submitted designed building and its amenities are indisputably not to 4* standards expectations. The Pavilion Hotel submissions are also dishonest, stating a 5* proposal.
“• 175 guest rooms – including 10 wheelchair accessible rooms”
The increase from 45 to 175 guest rooms is very excessive for this small site, only 10 wheelchair accessible rooms is an inadequate percentage for anticipated disabled guests requiring parking.
“• Generous public areas including bar, restaurant, public function rooms and terraces overlooking the bay”
Facilities only adequate for a budget hotel. Existing swimming pool demolished no facilities to be adequate for 4* star alleged quality. A budget hotel with basic facilities.
- 94 parking spaces (including 5 disabled spaces) and coach drop off area
Access to the hotel vehicular and pedestrian access very cramped. Due to no easily accessible public car park in the vicinity. Legislated, Parking on site requires the full minimum 175 spaces (including minimum 17 disabled spaces) Additionally the stipulated requirement of 60 cycle spaces is omitted. No additional parking for non-residents stated as visiting the rooftop restaurant
- “Improved vehicular and pedestrian access along Torbay Road “
It is extremely difficult, long wait to exit to the main road with its regular constant flow of traffic.
The additional new entrance exit providing 2 no. has poor visibility to cope with the requisite 175 cars plus coaches entering and leaving the site constantly. Indicating overdevelopment.
- “Improved landscape to road frontage and new landscape with pedestrian connection to the northern end of the site.”
No improved landscape. Due to the overdevelopment, the existing mature landscaping will be removed and replaced part hard surfacing leaving reduced unsatisfactory strips for green planting.
- “Area schedule”
“The scheme provides approximately the following accommodation: 175 Guest rooms 4300m²
Spa facilities 150m² Public areas 1200m² Car parking 2500m² Approximate Total Net Area10000m² Excessive number of bedrooms with insufficient parking area. Proposals require balance redesign.
Page 15. Proposals Layout and Scale
“Different massing proposals were tested on the site to achieve the best fit for the location. The Design Review Panel agreed that the scale of the building in relation to local context seemed to be appropriate although they were not supportive of the breaking down of the mass into different volumes. It was suggested to treat the proposal as a more singular and consistent proposition
but not further sub-divided. It was also encouraged a more horizontally emphasised design to the front of the building in the line of Abbey Sands, gaining height towards the north-eastern end for a final ‘flourish’. Then a rooftop bar / restaurant would be very attractive in this location benefitting from good orientation and excellent views. The comments received from the initial Design Review Panel meeting led to the proposed design approach, which was welcome on the second DRP meeting, and the panel members offered their support for this project. It was stated that the proposal should provide an exciting, handsome and positive addition to this part of the seafront.”
The Design Review Panel minutes have not been made public to analyse the above statements
TORBAY DESIGN REVIEW PANEL TDRP — is erroneously stated as being independent!
The appropriate descriptive title is —TORBAY DEVELOPERS RESOLUTION PANEL TDRP
Reason: – Compared with other like panels and the Regional Panel, there is a veil of secrecy with the Torbay Design Review Panel, no brochure, no web site, no profiles of Panel members to inform, or means of communication. TDRP has not been set up as the CABE principles to be open, to act in the manner of the Regional Panel, with aims primarily the public interest and benefit.
TDRP is a developer’s / company resolution panel paid by the relevant Company, calling the shots!
In breach of CABE regulations to be Independent with no conflict of interest.
Over the years TDRP has become a connected syndicate. The developer chooses one of the architects affiliated with the best overall Council connections in Torquay. The architects instructed figuratively move from one side of the table to the other side; to benefit and obtain their colleagues approval. Both sides of the table are paid for their interests by the developer’s / company- fait accompli.
Quote:- “The strength of a design review panel’s advice lies in its independence, objectivity and ability to analyse a scheme within the context of wider good practice. “
The meetings were not according to National Design Panel rules – Independent. Policy Quote: –
“It is conducted by people who are unconnected with the schemes promoters, and decision makers, and it ensures that conflicts of interest do not arise.”
Serious conflicts of interest in relation to the promoter architect, for the developer, a Derek Elliott and Richard Maddock of Kay Elliott Ltd. Their membership over many years as associates deliberating together on the Torbay Design Panel seeking approval from their fraternity of architects. The original Torbay policy (significantly withdrawn from web site) should have been implemented to avoid these serious conflicts of interest. That is to be unequivocally Independent conducted by the South West Regional Panel, or the National Review Panel.
The developer against CABE principles has ensured the local Community is kept in absolute ignorance of the negotiations and results – secrecy enforced, cooperation of the Panel & Planning Authority delaying requisite publication. Enabling Planning approval to be recommended by the Planning Case Officer who attended these secretive meetings.
Whilst the Community is denied knowledge; especially of the initial secret meeting that promoted
the design with the conspicuous overdevelopment and inadequate Council parking requirements.
Page 16. Proposals Layout & Scale Relationship of the proposals with the adjoining development:
“- Separation distances with nearest properties
– Differences in topography
– Stepping down of the building towards the south
Amendments after Public Consultation and Daylight & Sunlight Assessment:
1) Reduce overall height of the building.
2) Recess top floors to improve daylight / sunlight on properties to the west and north.
3) Rearrange windows to the north to avoid overlooking onto development at Livermead Hill.
4) Reduce window sizes to the rear to improve privacy levels. Stepping down towards Corbyn Minimum 29.6 meters “
The above statements are to convey the impression of amendments in the Public Interest, to imply Public Approval. The amendments are not in accordance with the community’s concerns of overlooking; overbearing height and mass. Reducing window sizes does not reduce the number of 300 pairs of eyes that are designed to be accommodated overlooking the Livermead Hill residential area.
Page 21 Proposals Landscaping
The greatly enlarged footprint of the new building structure on plan requires the landscaping to be virtually nonexistent. A reduction on the existing landscaping is less than satisfactory as existing shrubs and trees are shown to be removed. Causing the overdevelopment of the site, re-building forward of the existing building line
Page 23. Proposals Appearance
“Opportunity to create common architectural language on prime waterfront sites framing the bay.
Corbyn Head Hotel Abbey Sands”.
Misleading statement – there is no common architectural language between Corbyn proposed and Abbey Sands; because of the fundamental principle to omit any balconies facing the bay, which is elementary to the successful design at Abbey Sands. A misleading statement in the document
additionally – Abbey Sands does not overlook overbear adjoining properties.
“The front volume of the building (facing East) features an elegant horizontally emphasised elevation that leads to a singular and consistent proposition, creating a landmark building.
It gains height towards the north-east finishing in a powerful curved end, maximising the sea views and contributing to Torquay’s architecture from this prominent location.”
The way of words as a means of idealising the building. As heroic, a token of ingenuity and mankind’s progress, etc. The reality lies the imperative to show the building out of context, as a monument, separate from streetscape, from awkward neighbours, from untidiness.
A false statement.
Page 26. Proposals Access
“The proposed hotel is easily and safely accessible by foot, cycle, public transport or car.
This would connect to the pedestrian landscaped access to the terrace at the upper ground floor level of the new hotel. Two access points will be provided from the A3022 Torbay Road, one
located at the centre of the site (exit only), and a secondary access to the south of the site (entrance only).”
The widening and provision of two access points is detrimental to the safety of pedestrians along Torbay Road. The expectations by Torbay Council of 175 cars seeking entry and exit on to a very busy road with its regular constant flow of traffic, will cause tail back within the site. Combined with the proposal to attract nonresidents to use the rooftop restaurant will cause tailback on the main Torbay Road. The employee requirement of 60 cycles is an additional hazard. The hotel is not easily and safely accessible as alleged.
“The service access to the northwest of the site, onto Livermead Hill will also be retained and improved. A total of 94 parking spaces are to be provided on site, five of which
will be dedicated for blue badge holders, and there will also be five electric vehicle charging points. There are also 12 cycle parking spaces provided within the car park areas.
New site exit lowered to road level. Exit only. ?
“The service access on the bend of the steep Livermead Hill is detrimental to adjoining residents. The greatly increased capacity of the Hotel will generate a large flow of large and small commercial vehicles, reversing at times into the residential road detrimental to safety and the amenities of the opposite low-rise properties.
The development proposals are 89 standard car parking plus five disabled parking total 94 spaces for 175 no. bedrooms. The Torbay adopted minimum requirement is 175 parking spaces. A deficit breach of a considerable number 81 parking spaces missing.
Hotel Disabled Torbay Parking Requirement:-p 297. 10% of the total allocation of parking spaces should be dedicated and appropriately designed for disabled people and provide for safe, easy and direct movement for those with mobility difficulties. Certain uses should also provide for parents with young children.
The development proposals are only 5 no. disabled parking, a statutory requirement is 17 no. spaces. A deficit breach of 12 no disabled parking spaces to meet Torbay Council Standards
Hotel Cycle Provision Requirement:-p 297 1 space per two employees. Cycle storage should be covered and secure and easy to use wherever possible and must form an integral element of the design of the development.
The development provision alleged is 12 spaces for a stipulated proposed employee number of 120 no.
The regulation no of cycle spaces 60 no. A deficit provision of 48 cycle spaces.
Additionally no parking is proposed for visitors to the rooftop restaurant.
Being very remote from alternative public car parks is not acceptable. To permit would lead to constant problems with overspill and indiscriminate parking in the main road and surrounding residential area, harming visual amenity, create hazards for traffic and pedestrians. compounded by the increased operational commercial vehicles. Affecting the quality of Life for the surrounding area and residents.
Principle of Development
The principle of redevelopment is supported by TCHT for a proposal that is respectful of the surrounding environment, neighbours, amenable with the policies of Torbay height and parking policies. A design that is creating character and distinctiveness.
The Public consultation exhibition is seemingly a public relation exercise. It had no intent to alter the ‘fundamental’ height and design; agreed at the developer’s initial formative secret panel meeting. The Case Officer present at this formative meeting does not reveal his conclusions to the community only to the Development Management Committee. As the Chairman publicly stated
‘Awarding Planning Permission earns money for Torbay Council.’
Significantly there is not a named ‘Planning Committee’ in Torbay, only Development Committee.
The vista of skyline trees and buildings surrounded by green spaces viewed from the Chelston Conservation Area,
will be lost with the dominant height and mass of development, inconsiderate to the identity of the built environment.
An amended application reflecting National and Local Planning policies, and above statements and objections requires serious consideration.
12 Trustees of -Torbay Coastal Heritage Trust
Resident in, Brixham, Paignton, Torquay, on behalf of the membership