Multiple “Errors of Fact” in Planning Officers’ Report supporting Hub, say critics

The Southborough Environmental Action Movement (SEAM) says it has found multiple errors in the key report by Tunbridge Wells Planning Officers now being considered by councillors on the Tunbridge Wells Planning Committee, who vote on the Hub plans on Wednesday.

Brian Dury (pictured below) of SEAM said: “Having read Tuesday’s report from TWBC Planning Officers to the TWBC Planning Committee, we have found serious errors in the “facts” contained in that report which would invalidate the conclusion of the TWBC Planning Officers to recommend approval of the application. We will discuss the issues in detail before the Committee on Wednesday next week, but we are making you all aware now of some of the errors.”

brian-dury-2Meanwhile, the online petition against the current Hub plans that was organised by Mr Dury has now passed 1,200 people. For latest total see here:

Wednesday’s planning committee meeting at 5pm would normally be the end of the planning process. But because Sport England are maintaining their “outright objection” to the loss of soccer pitches on the Ridgewaye playing fields, the scheme can only be thrown out and not approved on Wednesday.

If Tunbridge Wells Planning Committee supports the application, the scheme will be reviewed in its entirety by central government planners. The civil servants in a unit within the government department dealing with local government (the National Planning Casework Unit) will decide whether to refer the issue to the Secretary of State for Communities and Local Government, Sajid Javid (pictured below).  And Mr Javid would then be the person to decide the fate of the scheme and the Royal Victoria Hall.


Update 10am Tuesday 8 November: The number of official objections on the Tunbridge Wells planning website continues to grow and has now reached 230 named individuals or organisations.  There are 34 supporters of the Hub scheme.  Objections make up 87%.  The portal is still open for comments.  You need to email and give your full name and address and include the application number: 16/06081 hybrid.

In a new submission placed on the Tunbridge Wells Planning Portal, SEAM, declares that factual errors have caused the planning officers to misapply their planning policies.

SEAM highlights Para 10.19 of the officers’ report which refers to the new local SALP Policy AL/S02, which requires efforts are made to consider retaining the Royal Victoria Hall. SEAM argues that: “the demolition of the RVH is a choice made by councillors who have a preference for a new modern building. It is not something that has been forced upon them by the condition of the building. Therefore the planning officers are wrong to accept in 10.23 that “the policy requirement for the applicant to explore opportunities to retain and improve the Royal Victoria Hall has been complied with and the reasons why this option has not been pursued have been clearly explained””.

SEAM also quotes from Para 131 of the National National Planning Policy Framework (NPPF) which says local planning authorities should take account of “the desirability of sustaining and enhancing the significance of heritage assets and….the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality”.

The Planning Officers’ arguments were published at length in an article on this blog on Tuesday and a piece explaining why the Southborough Society supports the Hub was published on Thursday. The following comments in italics are taken directly from the latest SEAM submission opposing the current Hub plans:


(1) “Iconic Building?”
Para 7.69 written by the TWBC Urban Design Officer says: “It is vitally important to create a sense of place and an identity for Southborough – a design of its time, iconic and stimulating.” The planning officers report contains no evidence that an “iconic” design has been achieved. And the idea that a building, which around 200 members of the public in their comments to planning have argued is wrong in mass, design and shape, can be made “iconic” simply by late variations to the cladding materials – as suggested by the TWBC planning officers – is clearly false.

The evidence provided in public comments from two independent architectural experts make it clear that the proposed design is a standard functional box of no architectural design merit.

hub-hallObjectors include:
(a) Michael Lees of the Tunbridge Wells architectural practice ARC-ML that specialises in masterplanning with clients from Berlin to Riga to London who says: “The poor quality design that has been submitted should not have got this far…The plan form of the proposed Hub building is gratuitous and gives form to “blocks” and a circular element which do nothing to give an important sense of place and enclosure to the associated public space around the building. Good design does not rely on gimmickry of this type.”

(b) Martin Jameson of London’s Serie architects with (clients in Singapore etc) and lecturer at the Architectural Association in London: “The design is weak. Clumsy massing – two boxes connected by a disc….Architects are now expected to work with existing buildings when taking on public work”.

Jason old RVH(2) Southborough’s Character

Para 10.57 of the planning officers’ report contains a fundamental error which underlies much of the reasoning in the report. It says that the Hub building will create a ‘sense of place within an area that currently lacks any coherent townscape character’.

Southborough town centre already has a distinctive local character. The buildings are largely brick built and Victorian and Edwardian. This character is recognised in para 4.5.4 of the TWBC Local Plan which specifically protects the commercial part of London Road because of features of architectural interest which contribute to the character of the local area.

p1100528(3) State of Royal Victoria Hall (RVH)

The planning officers’ appraisal states at 10.21 that the applicant has confirmed various issues including the following:
– Royal Victoria Hall has suffered “drains and walls collapsing”
– Various surveys highlighted various problems
– The current building is not flexible
– The seating is screwed down
– The building does not meet fire regulations
These 5 assertions are all incorrect.

No walls of the RVH have collapsed. Southborough Town Council (STC), who own the RVH, have supplied to Cllr Nick Blackwell the Boundary Wall condition report by the company BDR dated 17 April 2013. This clearly shows it is only the boundary wall and not any structural wall of the RVH that has any issues. The Royal Victoria Hall is generally agreed to be structurally sound and recent visitors all say it is in “remarkably good condition”.

According to Cllr Nick Blackwell, the issue with the drains concerns the plumbing of the 1970s toilets in the rebuilt front of the building, which is not structurally part of the main RVH hall. The drain issues will require some investment, but they have not “collapsed”.

The RVH was completely rewired five years ago, as explained in 2011 STC Annual Town Meeting Finance and General purposes committee (F&G) report, written by Cllr Peter Oakford (pictured below) who said: “The Victoria Theatre remains one of your council’s key focus areas and is an asset of our town that continues to thrive. The restoration has continued throughout the year with the re-wire and electrical work now completed at a cost of approximately £70,000, which was funded from reserves. The re-wire has designed to “future proof” the electrical requirements of the hall ensuring it will be ready for new equipment such as a PA and sound system, lighting etc.”


Mr Oakford went on to state in 2011: “A full fire safety audit has been completed; a new fire alarm installed and work is due to start replacing some of the ceilings in the back-up areas with fire proof materials. Some minor building works to the exterior of the building have been highlighted which will be completed this year.”

Cllr Nick Blackwell, who has been a member of the F&G committee on STC for the past two years, states that there has been no survey since 2011 that has identified any further essential works on the RVH demanding a substantial outlay.

The current RVH building has been used for dances, meetings and dinners over the past 116 years and so is clearly flexible.

The seating in place since the 1970s (which was partially screwed down) has already been removed as can be seen in recent photographs. (see below)

thumb_img_5505_1024 The health and safety inspector, David Menzies issued a risk assessment report, approving the new RVH movable seats in November 2014 and in his summary he says “this present arrangement allows STC to clearly demonstrate that they have eliminated the hazard associated with the use of the original folding seats by young children.” The hall was in use with these new seats for the December 2014 pantomime and fully insured with a small increase in premiums.

The building does still meet fire regulations. According to Cllr Blackwell, the RVH was passed by Jeffrey Lloyd of the Kent Fire and Rescue Service in June 2013.

(4) Views of Southborough Residents

Para 10.22 states that : “the local population voted overwhelmingly at the November 2015-January 2016 consultation exercise in favour of a new build”. This is incorrect.

The consultation in November 2015 offered just two design options:
(a) demolish the RVH (with outline plan worked up)
(b) Part demolish the RVH, including removing the balcony and cutting the seating capacity (with outline plan worked up)
(c) Unspecified other (no plan)
The people who wanted to retain a refurbished RVH in tact were not given that as an explicit option and so mainly felt they had been ignored and did not participate. The option to refurbish the RVH had been the most popular single option in the previous consultations.

An expert in consultations all over the world, Ian Gavin, of Water Aid gave evidence on the planning portal that this November 2015 exercise was a “manipulated consultation“.

img_0831In addition this wasn’t a “vote” of any sort. It was an event where supporters of the current scheme (Jonathan White and pro-proposal STC members) told any visitors coming through the door that “the better scheme was to completely demolish the RVH”. There was no alternative view available for consultation at the event.

At the official (November 2015) consultation, only 214 people (that is 58 % out of just 369 respondents) supported the RVH complete demolition “new build” option. Focussing on the residents of Southborough and High Brooms, as few as 182 people supported demolition (that is 63% of 289 STC residents). On the other hand, 3,000 people from Southborough and High Brooms signed the petition supporting keeping the RVH open in 2015. Ten times more people responded to the petition in 2015 than the consultation. The online petition in the past week launched by SEAM has made it clear that public views haven’t changed in the past year.

No “vote” took place as claimed in the planning officers’ documents. That would require a town wide referendum with campaign material from all sides sent for residents to consider, something that sadly hasn’t happened. 

(NB all above section in italics is taken directly from the SEAM submission and is NOT endorsed by Southborough News.  The full SEAM submission can be found on the Tunbridge Wells Planning website – search for 16/06081/HYBRID)

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