This building is not suitable for human habitation or residential conversion and the revised proposal cements that. Given the shape of the existing structure, several flats will receive only limited or even no natural light.

Contamination 

As you know, APPRA contacted elected members to inform them that a practical start had been made on site. Not only does this show contempt for Hull's planning department, but we also have serious concerns that possibly contaminated materials continue to be taken off site in an uncovered truck.

The extension to the former health centre is of an age where asbestos use was prevalent and yet no investigative report exists. Similarly, no tests have been done to residual radiation from the x-ray machines, no surveys of the building's superstructure have been submitted to prove the absence of RAAC concrete and so the applicant has failed to demonstrate that this conversion is in any way safe. As it stands the proposal is unfit for human habitation.

Waste

The applicant has now shown that he wishes to incorporate two external bin stores totalling 11,000 litres. No information has been provided as to who will be responsible for managing this and there is little information as to a recycling strategy.

The Avenues area has been blighted by large subdivided properties leaving their bins out, residents not recycling and contaminating waste facilities so that they remain uncollected and over-flowing.  A swept path analysis has been provided for a refuse lorry to enter the bin store adjacent to 81 Westbourne Avenue by performing a reversing manoeuvre around the roundabout. This is incredibly hazardous and cannot be acceptable to the local authority in any form.

Additionally, APPRA needs to bring to your attention that this is a locked and gated tenfoot. The applicant has clearly not considered this and with no accompanying waste strategy, it is unclear how he means for the bins to be emptied from this access way.

Similarly, the swept path analysis appears to show a bin lorry reversing into the main access adjacent to 85 Westbourne Avenue. Again, this is in close proximity to the roundabout and a vehicle of that size cannot reverse safely either from or onto Westbourne Avenue. 

Whilst your highways officer has updated their response, we would encourage this to be included in the further consultation.

The ‘refuse storage compound No.1’ directly fronting Westbourne Avenue is not acceptable to APPRA and the structure will have a negative impact on the conservation area. Instead, the applicant is encouraged to house all bins in an internal bin store in a purpose built development.  We therefore insist more information is provided as to the applicant’s waste strategy.

Parking

As referred to above, the tenfoot adjoining 79 Westbourne Avenue is gated and not accessible to the general public. A number of the parking spaces are therefore not able to be accessed. The applicant has not provided any details on how this all-rented scheme will be managed and so there is no information of how residents will be given keys and how this will be policed by the building’s owner.

There also appears to be no provision of any EVCPs (electric vehicle charging points) on this development. It is our understanding that this is compulsory on all new schemes in England.  The latest highways response acknowledges that some more spaces will have to be omitted to achieve the swept path analysis manoeuvres shown by the applicant. The number of spaces are already below what APPRA would like to see and yet more are to be lost.   As acknowledged by the highways officer, parking is in short supply in this locality and so the parking provision must be both extensive and easily accessible to deter any form of parking on Westbourne Avenue.

Highways

Linking into the two above further reasons for objection, it is APPRA’s belief that the site cannot be safely accessed for the number of vehicular movements that would be generated.  Extensive S278 works would be needed to the main access adjacent to 85 Westbourne Avenue and a new junction arrangement would be needed. At present, the highways officer acknowledges that two cars cannot safely pass entering/exiting this scheme. This is in addition to the tens of cars that already utilise this tenfoot for their existing right of access to their homes in Westbourne and Marlborough Avenues.  It is APPRA’s concern that a new junction arrangement would cause irreversible harm to the setting Grade II Listed fountain and that the site, as drawn, would put both motorists and pedestrians in danger.

Urgent revisions are therefore needed to the existing arrangements.

Open Space/BNG

The updated proposals still offer little in the way of useable open space and we are unsure if the council’s tree officer and ecologist have been allowed access to the site by the applicant.  Given there are still 32 apartments here, there is no meaningful open space. Whilst not apparent from the applicant’s revised drawing; the main proposed open space, which adjoins 112-118 Marlborough Avenue, is 80% covered by trees and their crowns. This includes a tree subject to a TPO. This space also directly adjoins family homes and no acoustic measures have been offered to mitigate the noise from a transient population of tenants.

As cited above a practical start on site has already been made and some trees and shrubs, not subject to protection from the conservation area, have already been removed.  All new sites in England and Wales must demonstrate a 10% net gain in biodiversity on top of the existing baseline. By removing shrubs and trees, the applicant is attempting to interfere with said baseline and BNG calculations.

Given that the parking provision has increased, there is no space to offer a net gain in biodiversity and the applicant has not provided any details on how he wishes to address this. As he already has a disregard for the existing ecology, APPRA insists this is resolved prior to any decision is made by the council.

Conclusion

APPRA continues to consider this to be one of the worst applications that it has ever been a consultee on. The reality is that the 1960s extension to the former health centre was never intended for human habitation and cannot be adequately converted under both current building regulations. 

A fully rented scheme would be detrimental to the area and create a transient population with little to no investment in our local community. 

Instead, we would encourage the applicant to withdraw the application and to work with the community as to what is and what is not acceptable.

As per our original response, we would support the demolition of all structures, save for 81 Westbourne Avenue, and a purpose built development of either family houses or retirement living apartments for sale. The applicant really is missing a trick in not offering purpose built M4(2)/M4(3) adapted apartments for sale to local residents. Avenue Ward has one of the highest average ages in the city and many residents are forced to leave the area when they wish to downsize.

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