20 Hawthorn Road
Clive Vale
HASTINGS
East Sussex
TN35 5HW
30 June 2014
County Archaeology
East Sussex County Council
Transport and Environment
County Hall
St Anne’s Crescent
Lewes
East Sussex
BN7 1UE
HAWTHORN AREA RESIDENTS ASSOCIATION
Dear Sir
Planning Application Numbers: HS/FA/12/00471, HS/FA/12/00952, HS/FA/14/00406/CB
Location: Rocklands Private Caravan Park, Rocklands Lane, Hastings, TN35 5DY
Proposed Development: Proposed Demolition of Current Holiday Let and Replacement of a New Holiday Let and
Variation of condition 2 (approved plans) of planning permission HS/FA/12/00952 - Minor amendment showing change of ground floor plan, additional and altered window positions, and extended balcony. (Retrospective)
I am writing this letter on behalf of members of Hawthorn Area Residents’ Association, and members of other
Residents’ Associations located in Hastings, East Sussex. It is our concern that planning permission was granted to the applicants Mr and Mrs Guilliard, and their agent John Waterhouse, planning application HS/FA/12/00952, because of false and misleading information supplied to the Local Planning Authority. There is also evidence that the author of a ‘Heritage Statement’ dated October 2012, Richard James BA, MIFA; Project No. 5735; Report No.
2012215 was supplied with a brief on the proposal that did not contain either accurate or full facts.
The enclosed letter and attachments, written to ‘English Heritage’ explains how the applicants and their agent, led Mr James into believing that the proposal for a two –storey holiday let was on the same footprint as the original, now demolished, bungalow, but was smaller in size. This is incorrect as the actual building, some of which was built without the benefit of planning permission is estimated to be 50% bigger than the bungalow it replaced. He was also led to believe that the proposed works would not affect the Iron Age Hill Fort –SAM12870 or would in any way disturb archaeological remains. Mr James also believed that there would be adequate screening from the Country Park and from Ecclesbourne Glen. The information provided to Mr James was misleading and inaccurate and did not make regard to the substantial changes that were made to the design, and footprint of the building, after the original application HS/FA/12/00952 had been approved.
I am writing to you as you were consulted on this application, HS/FA/12/00952 and on an identical planning application HS/FA/12/00471 that was refused under delegated powers on 19 July 2012. The two planning applications were identical; including submitted drawings that had already been refused so therefore should not have been resubmitted. The only difference was that the applicants were asked to provide additional information, subsequent to the refusal, so that an informed decision could be made. At the request of the
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development control manager the applicants submitted a comprehensive ‘Heritage Statement’ and details from the tourism board on how this proposed building was of benefit to the local tourism industry. You were also consulted on a retrospective planning application described as ‘minor amendments’ to a previously approved scheme.
In an email dated 29 May 2014, reference HS 12 471 rocklands, in respect of application HS/FA/14/00406 -
Variation of condition 2 (approved plans) of planning permission HS/FA/12/00952 - Minor amendment showing change of ground floor plan, additional and altered window positions, and extended balcony. (Retrospective) you stated ‘Although this application is situated within an Archaeological Notification Area. I do not believe that any significant archaeological remains are likely to be affected by the proposals. For this reason I have no further recommendations to make in this instance’.
On 18 Demember 2012 you wrote to Tim Cookson, Borough Planning Officer in respect of planning application
HS/FA/12/00952 reference: HS12 952 rocklands. The application submitted was to demolish an existing bungalow and to replace it with a two storey holiday let. In the letter you referred to the comprehensive
‘Heritage Statement, compiled by Archaeology South-East, and it is obvious from your response that you were very much influenced by the ‘Heritage Statement’ and that it had a bearing on your decision not to oppose it or offer any recommendations in the treating of this application.
In your letter you state ‘This statement details the recent history of the site, indicating that there has been a succession of building phases on a plot terraced into the rampart of the Iron Age hillfort. It is therefore unlikely due to this past disturbance that significant below ground archaeological remains will be disturbed by the proposed construction of the new dwelling.
This new application no longer included landscaping proposals for the garden area thus eliminating any archaeological impact in this area.
The Heritage Statement does however highlight that there will be a visual impact on the Scheduled Monument due to the increased height of the new building. In light of this English Heritage will need to be formally consulted for their recommendations…
Your comments made against application HS/FA/12/00952 and HS/FA/14/00406 in no way relate to your previous comments where you made several recommendations and offered a ‘suitably worded condition’ on an identical proposal, HS/FA/12/00471, which was subsequently refused on 19 July 2012 by delegated powers. Prior to this refusal you were notified about the proposed application to demolish the current holiday let (bungalow) and replacement of a new holiday let (two storey holiday-let). In your letter, dated 10 Jul 2012 you stated ‘The proposed development is situated immediately adjacent to a Scheduled Monument (although the proposed garden works fall within), as well as being within an Archaeological Notification Area, defining earthworks remains of an Iron Age Hill Fort and other remains on West Hill.
As these proposals affect a Scheduled Monument, English Heritage will also require consultation of this application.
In light of the potential archaeological interest of this site, it is my opinion, that it is important to follow requirements set out within NPPF (the Government’s planning policies for England) and ask the developer to submit a heritage statement. This statement is required before the application for planning permission is decided, so that archaeological issues can be fully considered with the planning decision is made…
‘In the event that planning permission is granted and in the light of the potential for loss and impact to heritage assets on this site resulting from development the area affected by the proposals, I recommend that as a minimum the permission should be subject to a programme of archaeological works condition. This would enable heritage assets to be preserved in situ where possible and where not, for a record to be made before their loss. These recommendations are in line with the requirements given in the NPPF (the Government’s planning policies for
England…’
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Your letter concluded with ‘I would therefore ask that the following condition be applied to any planning permission that is granted in respect of this application:
No development shall take place until the applicant, or their agents or successors in title, has secured the implementation of a programme of archaeological work in accordance with a written scheme of investigation, including a timetable for the investigation, which has been submitted by the applicant and approved in writing by the local planning authority and the works shall be undertaken in accordance with the approved details.
(Reason: To enable the recording of any items of historical or archaeological interest, as the developer is likely to disturb remains of archaeological interest, in accordance with requirements within the NPPF)’.
It is not clear from your response to the request for ‘Archaeological Consultation’ in respect of HS/FA/12/00952 and HS/FA/14/00406 whether you are stating that you have no further comments to make, other than your recommendations for application HS/FA/12/00471 or whether you have decided not to comment further as you are satisfied that the information supplied in the ‘Heritage Statement’ allayed any fears that you might have had in regard to the possibility that archaeological remains could have been disturbed by the proposed construction.
It has been established, and confirmed by the local planning authority, that the building has been extended without the benefit of planning permission. There is the possibility that the extension south-west corner to the ground floor may have breached the Iron Age Hill Fort and a drawing has been supplied by a tree consultant that states that a retaining wall has been constructed in the same area. This retaining wall is not included on any of the submitted drawings relating to this application. I am unclear why you changed your opinion on the more recent proposal because of negating landscaping to the garden area. As this originally was a like for like proposal to application HS/FA/12/00471 that was refused, I am not sure where you obtained the information from that the garden area was no longer to be landscaped. There is no documentation concerning landscaping to the garden area on either HS/FA/12/00471 or HS/FA/12/00952.
As the building has been increased significantly, and has moved away from the original plans, there is the possibility that they have now encroached onto the garden area. Recent photograph show that the land has been scalped and many trees and shrubs, that originally screened the building from Hastings Country Park and from
Ecclesbourne Glen, have now been removed. It is believed that trees and bushes have been removed to afford the holiday-let occupiers a better view of the Country Park and over Ecclesbourne Glen to the sea.
Although application HS/FA/14/00406 was refused unanimously by the planning committee there is the danger that the applicants will lodge an appeal against their decision. It is for that reason we thought that you should have the full facts about what the amended proposal entailed, as it has been played down as being insignificant.
Laws are put in place to protect our heritage and it is only right that decisions are made on correct information being submitted. The details of these proposals submitted by Rocklands Caravan Park are too sketchy and no actual measurements have been provided. Even the LPA are relying on measuring scaled drawings with scale rulers and coming up with inaccurate measurements. This is not good enough for our heritage which should be protected.
Yours faithfully
Lynne Okines
Secretary to Hawthorn Area Residents’ Association
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