Civic Trust response to Portland Square Planning Application

Mr C Hardman
Carlisle City Council
Planning Services
Civic Centre
CARLISLE
CA3 0AG
Dear Mr Hardman 7 June 2016

PLANNING APPLICATION Ref. 16/0359
PORTLAND SQUARE, ALFRED STREET, BRUNSWICK STREET, CARLISLE
Thank you for bringing this application to our attention.

We have considered the application with care and have been impressed by the level of detail supplied. Unfortunately, however, this detail is so great it tends to drown-out the basic planning, conservation and townscape issues involved. We here focus upon the latter only. Due to the restricted time available to us what follows may duplicate or miss some of the content within the application due to its complexity – if so we apologise in advance.

CHANGE OF USE
The application is self-characterised by the title “Regeneration of Portland Square”. We feel that the application is not strictly a regeneration activity as there is no end user or funding agency involved. It is simply an application for a change of use to make these historic buildings more saleable by the current owners, Cumbria County Council whilst also maintaining their fabric. We have no criticism of this intention per se, however, it could be more accurately and honestly described as it implies active inward investment which is not actually part of the scheme. The intent does nevertheless raise some issues of concern to us.

BEST USE
These buildings are magnificent large town houses c. 1860 – 70s, their development and construction therefore pre dates the automobile. Originally they represented the ideal location for the well-to-do of the City with easy access to the City Centre for work, as travel by speed and distance was restricting.

We do not know exactly when the properties started to novate from residential to commercial/ public use but we would hazard a guess that it would coincide with access for the well-to-do to the motor car and moving out to populate more rural and spacious accommodation in suburb villages such as Scotby, Wetheral etc., i.e. the 1920s onwards.

The natural instinct is to see the return of these homes to residential use as a rightful and laudable reversal of fortunes. However the crucial matter of their development without the car in mind and the well-to-do now ensconced in ever far reaching village habitats does not make such a return a ‘snug-fit’.

These properties were designed as houses and would, we agree, probably make best use as houses, however vehicle needs and resident profile are major concerns including the following factors:

Choking the area with additional cars will add to existing residential requirements, particularly overnight, and exacerbate by the loss of the natural interchange between office worker and shopper by day changing over to meet resident needs by night. We envisage preferential resident parking during the day will see inefficient use.
Car parking needs are further challenged by recent losses to public car park facilities in the area initiated by the applicant.
Proposals to reserve parking places for these properties only, is an aggressive restrictive policy when use during day periods would best be shared by the town community.
The proposed closure of Alfred Street and Brunswick Street to public access and use, we see, as raising serious functionality issues for the street network in the area and an unjustified sell off of an historic part of the public realm as well as setting a damaging precedent.
Where is the target market? We have concerns that whilst the properties may divide as shown they are still quite large and see problems ahead achieving the equity value needed for good quality conversion in order for them to go successfully to market. There appears to be no marketing and valuation assessment that justifies the approach.

We feel that the scheme, as presented, should not be approved in its present form because it is likely not to be deliverable financially even if it could physically. The loss to the public realm is considered too high a price just to deliver extra car parking as this is also simply shunting car parking problems elsewhere with Cumbria County Council being a benefactor in the process whilst also the instigator of current parking problems in the area by their closure of a public car park for its own HQ.

It is our opinion that planning consent for the new CCC HQ should have conditioned satisfactory alternative uses for its former accommodation, The Citadel and Portland Square, and sound alternative public parking as “conditions precedent” prior to commencement of its HQ building on Botchergate. As we understand this did not occur, we believe if this scheme were to progress it should only do so with “conditions precedent” delivering acceptable compensatory public parking within the area and use of Article 4 or legal agreement protection to prevent any subsequent alterations to change approved layouts as there is a fear that too many properties may become houses in multiple occupation with attendant negative townscape effect.

Our recommendations are therefore:
Abort the proposal to sell off part of the public realm – The Portland Square Garden should be retained as it was conceived by a four sided thoroughfare as this is its context, character and historic interest as well as a functional part of the City road network.
Encourage greater emphasis on a mixed-use approach for marketing individually not as a job lot as is implied by application – this would otherwise tend to reduce funds available for conversion and maintenance by potentially attracting a ‘developer’ tier to the disposal. This would probably be preferred by the applicant but not in the best interests of heritage asset protection.
Approve the final scheme only with a “condition precedent” requiring compensatory parking in the area to absorb the inevitable residential parking increase, particularly at night, and reduce the additional pressure on public parking that currently access existing businesses, services and residents.

We do hope you will be able to fully explore, and ameliorate our concerns with the applicant.

Yours sincerely

Carlisle and District Civic Trust