LW/02/2316 Construction of riverside walkway/cycleway, public
Newhaven viewing/seating promontory with kiosk, highway
04.12.02 improvements, 105 apartments, 6 x A1/A2/A3 units,
replacement boat showroom for Russell Simpson Marine,
reclaiming riverbank for car parking/boat storage, flood
defence works, new pontoon and dredging at Newhaven
1.1 The site is located south of West Quay phase 1. It comprises approximately
3 ha of land between the waterfront and Fort Road, and includes the Russell
Simpson Marine boat park and office/showroom, a scuba diving centre,
café, shops with floorspace above, existing boat berths and slipways, some
redundant buildings and structures and a promontory which is used for open
1.2 The proposal is seen as phase 2 of the West Quay development. The
proposal would constitute a mixed-use scheme including new residential
development, marina facilities, public access and retail uses, accessed by an
upgraded and realigned riverside road running between the south end of
phase 1 and Fort Road.
1.3 The proposal would provide:–
(a) A continuation of the new riverside walkway and cycleway from West
Quay phase 1 to link to Fort Road.
(b) Refurbishment of the promontory, which would be publicly accessible
as a viewing area, with seating and a snack/drinks kiosk.
(c) Realignment and resurfacing of Riverside Road between phase 1 and
Fort Road, with a mini-roundabout provided at the Fort Road junction.
(d) 92 apartments in three blocks, including 52 apartments in a v-shaped
“gateway” building having a maximum of 9 storeys sited adjacent to the
waterfront, and 40 apartments in two “marina” buildings having a
maximum of 6 storeys located in the centre of the site, together with
associated car parking areas.
(e) 6 shop units (for A1, A2 or A3 use) with 13 apartments above in a new
3/4 storey building at the Fort Road/Riverside junction, opposite the
(f) A new single storey boat showroom for Russell Simpson Marine linked
to their existing offices adjacent to Fort Road.
(g) Reclamation of an area of riverbank for winter boat storage and summer
marina car parking.
(h) A deeper dredged basin to accommodate larger boats and new pontoons
for 64 berths.
(i) A relocated scuba centre to part of an existing building next to the
(j) Delivery/parking lay-by for the new lifeboat station adjacent to the site
(currently under construction).
1.4 The residential element of the development (d and e above) would comprise
4 x 1-bed, 92 x 2-bed and 9 x 3-bed apartments, totalling 105 units.
2 Key Policies
2.1 A wide range of national, strategic and local policies are relevant to the
proposed development. Below is a summary of those that are considered to
be most pertinent in setting out the policy framework applicable to the
Planning Policy Guidance
2.2 PPG3 – Housing.
2.3 PPG13 – Transport.
2.4 PPG17 – Planning for open space, sport and recreation.
2.5 PPG25 – Development and Flood Risk.
East Sussex and Brighton & Hove Structure Plan 1991-2011
2.6 S1 – Sets out criteria aiming to create a sustainable environment.
2.7 S3 – Infrastructure to be available or to be provided to serve development.
2.8 S15 – A major integrated initiative to regenerate the economy and
environment of Newhaven will be pursued. This will include improving
leisure and tourism facilities and generally improving the town’s
environment, particularly its riverside.
2.9 TR36 – At Newhaven, provision will be made for developments which
encourage, inter alia, leisure boating.
Lewes District Local Plan
2.10 The site is situated within the Planning Boundary of Newhaven. As such
there is a general presumption in favour of development, subject to any
proposal according with other considerations and policies in the Local Plan.
2.11 NH6 – This is a site-specific policy which covers the application site,
together with land extending southwards around the marina and including
the Villa Adriana restaurant. The policy states that:–
“Land at The Marina, as defined on Inset Map No 2, is allocated for
residential development at a target minimum of 100 units subject to:–
(a) no loss in the number of existing berths as at December 1999;
(b) the provision of adequate parking to serve the berths;
(c) new development must include an appropriate standard of flood
protection (including safe access to the site) and provision for future
(d) compliance with appropriate District-wide policies.
In association with the residential development small-scale specialised
retail/food and drink premises and leisure uses associated with The Marina
activities would also be acceptable.”
2.12 RES4 – All residential development is required to make an efficient use of
2.13 RES9 – “Affordable housing will be sought within proposals for housing
development where there is a demonstrable current need in the locality.
The amount sought will depend on the following:-
(a) the level of need in the locality;
(b) site size and suitability;
(c) the location of the site in relation to services;
(d) site development costs;
(e) the need not to prejudice other planning objectives of the development
(f) the aim of achieving a successful housing development including
factors such as housing mix and, where applicable, subsequent
management of the scheme.
On allocated sites within the planning boundary, the Council will seek
provision of affordable housing in accordance with the target figures set out
in Policy RES2.”
2.14 RES2 – Indicates that planning permission will be granted for residential
development at, inter alia, The Marina, with a total target number of
dwellings of 100, with a minimum of 25 being ‘affordable’.
2.15 ST3 – Sets out criteria which new development will be expected to comply
with, including new development to respect the overall scale, height and
character of its surroundings, respecting the amenities of adjoining
properties and not resulting in detriment to the character and amenities of
an area through increased traffic levels, congestion or parking.
3 Relevant History
3.1 LW/90/0318 – Outline application for 457 units of residential
accommodation with parking, relocated facilities for fishermen, RNLI
facility and yacht club, new marina and support accommodation, retail,
public toilets, catering facilities and port control tower, private leisure
facility and public car park. Withdrawn.
3.2 LW/90/1746 – 302 units of accommodation, relocated facilities for
fishermen, RNLI facility and yacht club, new marina and support
accommodation, retail catering facilities, car parking, open space and site
for age concern day centre. Withdrawn.
3.3 LW/91/716 - 302 units of accommodation, relocated facilities for
fishermen, RNLI facility and yacht club, new marina and support
accommodation, retail catering facilities, car parking, open space and site
for age concern day centre. Deemed refused.
3.4 LW/98/1728 – Erection of 64 dwellings, relocation of fishing complex,
provision of public open space, 47 space public car park, pedestrianised
riverside walkway/cycle route. Approved and built (phase 1).
3.5 LW/00/642 – 14 houses (modification of LW/98/1728). Approved and
3.6 LW/01/0666 – New RNLI station with relocation and extension of floating
pontoon from landing stage 6. Approved and under construction.
4 Representations Received
4.1 Newhaven Town Council “welcome the application because of the
beneficial impact which might be expected on the regeneration of the town
as a whole. Concern has been raised by some local residents about the
height of the apartment blocks and the density of dwellings. However,
members recognise that there are no grants available to subsidise the public
amenities to be provided as part of the development and that consequently,
if the density of dwellings was reduced, these amenities could not be
provided to the same standard. It is considered difficult to quantify the
effects of the development on the local infrastructure, however it is noted
that at present school rolls in the town are reasonably low. Members
generally like the design of the buildings and feel that this type of
accommodation would complement other housing stock in the town and
would add to the mix of local residents.
The Town Council would, however, like to draw the attention of the
Planning Authority to the objections made by a number of local people,
which are –
The proposed buildings are out of keeping with Phase 1 and older
parts of the town.
The height of the proposed buildings; blocking views and light; also
possibly setting a precedent for other new developments in the town.
Concerns about Fort Road and South Road and their ability to cope
with increased traffic.
Possible increased parking problems in the Fort Road area.
Concerns about the ability of the local infrastructure, such as schools
and doctors, to cope with such a large influx of new residents.
The Town Council has received 23 letters of objection and 52 letters of
support for this application.”
4.2 Highway Authority does not wish to restrict grant of consent, subject to
conditions and a section 106 Agreement to secure the off-site highway
4.3 East Sussex County Council, as strategic planning authority, state that-
1. The proposal is welcomed and supported in principle as offering a
significant contribution to implementing structure plan policy to
regenerate the economy and environment of Newhaven, improve leisure
and tourist facilities and contribute to meeting the area’s housing
2. Although there is much to commend the proposal, there are a number of
concerns that should be addressed before any planning permission is
3. As a full detailed scheme, therefore, this particular application should
not be approved. However, a revised application, which resolved the
following issues, would be welcomed and supported.
a. the District Council should seek the provision of an appropriate
amount of affordable housing to comply with local plan policy;
b. a redesign of the scheme to reduce the heights of the buildings and
achieve a better internal layout to better fit in with their
surroundings and the AONB;
c. the applicant should provide a transport assessment demonstrating
how the development would deal with non-car modes of travel.
4. Any permission should be subject to appropriate conditions relating to
archaeological investigations and arrangements to minimise, reuse and
recycle construction industry waste and to manage waste arising from
the use of the development.
4.4 Southern Water raise no objection in principle, subject to a condition
requiring details of foul and surface water disposal to be agreed.
4.5 Environment Agency raise no objection in principle, subject to conditions
including the requirement of an investigation into ground conditions and
agreement of a scheme for flood defences.
4.6 Police Community Safety Department do not identify any major concerns
with the proposals.
4.7 East Sussex County Council Rights of Way Officer has no objection.
4.8 English Nature has no observations.
4.9 Newhaven Economic Partnership “support the principle of the
development. The continuation towards the marina is a natural progression,
building on the success of West Quay phase 1. West Quay is known for its
high quality development. Waterfront properties are very popular and the
scheme will add to the regeneration transformation taking place in
4.10 RNLI comment that a compromise has been reached with the applicant
concerning the provision of parking spaces and access to the lifeboat
4.11 Architects Advisory Panel liked the scheme and felt it appropriate both in
terms of materials and scale. Some concern was expressed that some
commercial uses should be incorporated within the gateway block to
encourage public use of the space alongside.
4.12 Design and Conservation Officer comments that, on the whole, the scheme
will improve the area and bring benefits. The effect on phase 1 in terms of
sunlight/daylight still needs consideration, and commercial uses within the
gateway block close to public areas would be welcomed. Subject to more
detail on these items, the scheme could be approved in its present form.
4.13 71 letters of objection have been received, the main planning grounds of
which are as follows:–
a. The proposed apartment buildings are too high and massive, and would
be totally out of character with phase 1.
b. Loss of light, overshadowing, loss of privacy and overlooking, and loss
of outlook would result.
c. The design of the buildings would be inappropriate.
d. The local infrastructure is inadequate to serve the development,
including medical facilities and the local road network and the local
approach to the ring road in particular.
e. Increased traffic would be generated by the development.
4.14 55 letters of support have been received, including 38 which are identical
but signed individually. The main thrust of the support is that the proposal
would transform the area, would be positive regeneration and would be
good for Newhaven.
4.15 A public meeting was held by the Town Council in March about the
proposal, attended by about 120 residents. Various views, both in
opposition and support, were expressed by residents at the meeting. The
views generally reflected the points raised in para.’s 4.13 and 4.14 above.
5 Material Considerations
5.1 The application raises several primary issues, which are assessed in
Regeneration of quayside
5.2 The proposal constitutes phase 2 of the regeneration of West Quay. In
principle, it would make a significant contribution to the town in economic
and environmental terms, as well as improving and upgrading the existing
marina facilities and public access for recreation purposes. In principle, the
mix of uses included within the application is welcomed.
Compliance with site specific policy NH6 (see para. 2.11 above)
5.3 Policy NH6 in the LDLP is applicable, because it specifically covers the
application site as part of a wider area extending around the marina to the
south. The applicant has been asked why a comprehensive development of
the whole area specified in the policy has not been proposed, and has
responded that the policy area is substantial, and in the interests of
regulating the project at a manageable level the scheme has therefore been
proposed in phases. The applicant has confirmed that, if phase 2 proceeds,
the intention would be to continue with a ‘phase 3’ of the development at a
later date. At this stage, however, the current application is to be
determined as it stands.
5.4 Policy NH6 allocates the policy area for residential development, at a target
minimum of 100 units. The proposed 105 units therefore accords with the
policy in terms of the contribution to the District Council’s housing land
supply. The implications of accommodating 92 of the residential units on a
relatively limited part of the site are considered in para. 5.10 – 5.20 below.
5.5 Policy NH6 indicates that the residential provision is subject to no loss of
the number of existing berths as at December 1999. The application would
result in a significant increase in the number of berths at the marina, from
approximately 240 in 1999 to approximately 300 as a result of phase 2.
5.6 Policy NH6 also states that the residential provision is subject to the
provision of adequate parking to serve the berths. As part of the proposal
there would be land reclaimed for winter boat storage and summer marina
car parking. This would involve a substantial importation of fill material to
reclaim land, which is between the back of the existing shops and the
existing slipway. The car parking area which would be created, would be
additional to the existing marina car park which is outside the application
site, and which is not affected by the proposal. It is therefore considered
that the policy is met in this respect.
5.7 Policy NH6 requires the new development to include an appropriate
standard of flood protection (including safe access to the site) and provision
for future maintenance. This issue is primarily a matter for the advice of
the Environment Agency, who have requested that a planning condition is
imposed on any permission for the development, to require a detailed
scheme to be formulated. At this stage flood protection measures have
been incorporated into the scheme, with the raising of ground levels across
parts of the site and the erection of walls, which is consistent with the
measures incorporated within phase 1. Having regard to the advice of the
Environment Agency, it is considered that the terms of policy NH6 are met
in this respect.
5.8 It is considered that the proposal complies with the requirements of NH6 (a)
– (c) of the LDLP. Clause (d) of NH6, which requires compliance with
appropriate general District wide policies, is considered in the following
Effect on character of area
5.9 The application site is presently under used land, and is considered to be in
need of upgrade and improvement. The land which formerly comprised
phase 1 was equally in need of improvement prior to redevelopment, but
that area has been transformed with significant benefits.
Scale and building heights
5.10 A consequence of the siting of the main three residential buildings (with a
total of 92 apartments) within a relatively small part of the site is that the
buildings would be relatively high compared to existing development in the
locality. Existing development includes the recent 3 storey houses, which
are immediately to the north and which form part of phase 1, together with
the generally 2 storey older and more modern housing which fronts onto the
opposite side of Fort Road. Also in the locality are the higher 5 storey flats,
which are beyond the 3 storey houses to the north, which also form part of
phase 1. The Sheffield Arms pub, at the junction of Fort Road and Gibbon
Road, is 3 storey.
5.11 Development directly opposite the Sheffield Arms would comprise six shop
units with 13 flats above. These would be contained in a part three and part
four storey building. This is considered to be acceptable in townscape
terms, particularly as the site is lower than Fort Road.
5.12 The tallest building within the new development would be the apartment
building adjacent to the river, which would be ‘V’ shaped and would step
up from 6 to 9 storeys (26m above the raised ground level). The two other
main apartment buildings, which would be set back from the riverside,
would rise from 5 to 6 storeys (18m). These buildings, and particularly the
‘gateway’ building next to the river, would clearly be the highest buildings
in the locality.
5.13 It is considered that in this location, away from the core of the town and
next to the river, there is scope to provide higher buildings than would be
acceptable elsewhere. The applicant has contended that the highest
building would be a focal point, a ‘gateway’ to Newhaven, and there is
considered to be force in this argument in terms of this location.
Effectively the development would tend to create its own character, distinct
from that of the town generally. While the County Council and some local
residents consider that the buildings would be too high, it is considered that
development of this scale would be acceptable. Views from the swing
bridge towards Castle Hill and the historic Newhaven Fort would be
interrupted to some extent, and the buildings would be visible from longer
views in the surrounding area. This is, however, considered to be
acceptable. It is not considered that there would be any material effect on
the Area of Outstanding Natural Beauty away to the north. It is of note that
the Architects Advisory Panel considered that the scale and height of the
development was acceptable in this riverside context.
5.14 The general design of the development would be bold and modern, and
quite different to the houses of traditional appearance fronting onto Fort
Road, the Sheffield Arms and the character and design of the buildings in
phase 1. Like the scale, it is considered that there is scope for a more
imaginative and modern style of architecture on this riverside site. In this
context the design and external appearance of the proposed buildings is
considered to be acceptable. Again it is of note that the Architects
Advisory Panel supported the proposal in terms of the design approach
which has been followed.
Effect on residential amenity
5.15 The main effect on the amenities of existing residents arises from the height
and bulk of the proposed buildings.
5.16 From the houses in Fort Road existing views across the site to the harbour
and marina would, to a significant extent, be restricted to glimpses between
the proposed buildings following development of the site. From the rear of
properties within phase 1, a loss of view would again result from the
proposed buildings. However, the loss of views from private properties is
not in itself a consideration which can be taken into account in reaching a
decision on a planning application.
5.17 It is not considered that any loss of light, overshadowing or overlooking
would be caused to the houses fronting Fort Road from the development, as
they are sited too far away for there to be any direct impact.
5.18 The effect on the closest houses within West Quay phase 1 would be most
significant in terms of the change to residential amenity. These houses
consist of terraces which back onto the site. From the rear windows of
these three storey houses, and from the back gardens, the immediate
outlook (rather than wider views) would be dramatically changed. The
closest part of the ‘gateway’ building would be sited ‘end on’ to existing
houses, at a distance of 16m to the garden boundary and 25m to the houses
themselves. The height of the ‘gateway’ building at this point would be 5
storeys (14m), with the building stepping up to its maximum height further
away from the houses. Similarly, the closest part of the nearest of the other
two apartment buildings would be 22m to the nearest garden boundary and
30m to the houses themselves, with a height of 5 storeys (14m). The new
buildings would therefore be relatively obtrusive compared to the existing
outlook over the site. While the effect on residential amenity should not
therefore be underestimated, this is a riverside development characterised
by a higher density of residential buildings. In this context, it is not
considered that ‘suburban’ amenity standards should necessarily be
5.19 Assessments of the level of overshadowing likely to be caused by the
proposed buildings onto existing houses in West Quay phase 1 have been
submitted by the applicant. These show that some overshadowing would be
caused during the autumn – spring (October to March) period, when the sun
is lower and shadows of the new buildings pass across the rear gardens of
those properties. During the summer, the shadows of the new buildings
would tend to fall short of the existing properties. Overall, it is considered
that some overshadowing is likely to be inevitable where development of
the scale and height envisaged is proposed. However, given the degree of
overshadowing, it is not considered that refusal of the application on this
ground would be justified.
5.20 Some of the new apartments would have windows which would face back
towards the rear walls of the houses in West Quay phase 1. However, no
significant windows would be in the end of the ‘gateway’ block at the
closest point of development to existing houses, and the windows in the
lower ‘marina’ blocks would be at an angle to existing houses. It is
considered that some overlooking and loss of privacy would occur to
occupants of the existing houses. However, again it is not considered that
the effect would be so significant as to justify refusal of the application, in
circumstances where a new riverside environment is being created.
5.21 The effect of traffic generated by the development has been subject to a
Transport Impact Assessment by the applicant and, subject to the provision
of the roundabout at the Fort Road/Riverside Road junction, the Highway
Authority raise no objection in principle to the proposals. Although
concern has been expressed at the impact of traffic along Fort Road, South
Road and onto the ring road and A259 by some consultees, it is considered
that a refusal on this ground would be difficult to justify, particularly as the
residential element accords with the site specific policy NH6 in the LDLP.
5.22 121 parking spaces would be provided, together with cycle storage
facilities, for the 105 apartments. This level of parking provision is
considered to be satisfactory.
5.23 Policy RES9 of the LDLP indicates that affordable housing will be sought
within proposals for housing development where there is a demonstrable
current need in the locality, with the amount sought depending on specific
criteria. Policy RES2 indicates that on this allocated site a minimum of 25
dwellings should be affordable, given a target number of dwellings of 100.
5.24 In this case no affordable housing would be provided within the scheme.
The applicant has submitted that an exception should be made to the normal
policy requirement, because (a) there are abnormal site development costs
arising from sewer and flood defence works (b) the costs of development
include wider public benefits which would not be possible if the costs of the
scheme were increased to provide subsidised housing and (c) unlike phase
1, there is no grant money or external funding available to support the
scheme. Overall, the applicant has submitted that, having regard to these
points, the margin of revenue over cost does not support the provision of
5.25 It is apparent that there is a demonstrable current need for affordable
housing within Newhaven. Therefore, there have to be exceptional
circumstances to justify affordable housing not being provided as part of
5.26 In order to test the applicant's claim that the margin of revenue over cost
prohibits affordable housing being provided, independent specialist
valuation advice has been undertaken as to whether the schedule of costs
put forward by the applicant is reasonable. The advice is that the schedule
is reasonable. On this basis the revenue over cost margin appears to be
significantly lower than that which is ‘normal’ for a development and the
case for not including affordable housing is made. This is on the
assumption that the proposal as a whole includes elements which are of
public benefit, and which would not normally flow from a development
(such as the public walkway/cycleway along the riverside and refurbished
5.27 It is also of note that the proposed residential mix tends towards smaller
units. The scheme comprises 4x 1-bed, 92 x 2-bed and 9 x 3-bed
5.28 If the proposal is accepted without affordable housing provision, then the
application will have to be advertised as a departure from the development
plan, because the policy requirement has not been complied with. As part
of this procedure, the Government Office for the South East (GOSE) will
need to be notified, and will have the opportunity to ‘call-in’ the application
for determination by the Secretary of State.
5.29 Residential development in Newhaven normally generates a requirement
for a financial contribution towards the provision of open space in the town.
In this case public access for recreation purposes would be materially
improved with the provision of the walkway/cycleway and the refurbished
promontory. In the circumstances, and given the public open space which
was provided as part of phase 1, it is considered that a financial contribution
need not be specifically required in this case.
5.30 It is not considered that the proposed additional six shop units would be
likely to have any material affect on the vitality or viability of Newhaven
town centre. The units should provide additional floorspace for the benefit
of residents of the new development and those already living in this part of
the town. At this stage, it is understood that the existing ‘Coral Cabin’
would relocate and occupy one or more of the units.
Effect of construction
5.31 This is a major development, which will involve the importation of
relatively large quantities of fill material to raise the levels of certain parts
of the site and to reclaim the riverside land for boat storage/parking. There
would therefore be a perceptible increase in lorry movements to the site. If
permission is granted, it is recommended that a condition be imposed
restricting the hours during which construction can take place, in the
interests of those residents living in the vicinity of the site.
5.32 The proposal is for a major development which would be a further
significant progression in the regeneration of the town, and particularly the
West Quay area. It is considered that the site, removed from the town
centre and with its riverside frontage, can accommodate a development of
modern architecture and of a higher scale than elsewhere in the town, in
order to create a new ‘landmark’ development for Newhaven. Although the
new buildings would affect the residential amenities of some of the new
houses in West Quay phase 1, in the context of the development as a whole
it is not considered that this impact would be so significant as to warrant
refusal of the scheme. The proposal would deliver the local plan housing
allocation, together with economic, maritime and public access and
recreational benefits. It has been demonstrated that the abnormal costs of
the scheme are such that it could not support the provision of affordable
housing alongside other public benefits. Approval is recommended.
That the Director of Planning and Environmental Services be authorised to grant
planning permission, subject to:–
A. Completion of the departure procedure in relation to the provisions of the
B. Completion of a section 106 Agreement concerning (a) the phasing of the
various parts of the development; (b) provision of the walkway/cycleway and
public promontory and arrangements for their future maintenance; (c)
provision of highway works, including a roundabout at the junction of
C. The following conditions: –
1. Prior to the commencement of development, details of the proposed phasing of
development shall be submitted to and approved by the local planning authority.
Where, under the following conditions, any details are required to be approved
prior to the commencement of development, this shall be construed as the
commencement of development on any individual phase as defined in the
Reason – To ensure that the development proceeds in a satisfactory manner.
2. MAT.73b - Approval of External Materials [ST3]
3. MAT.74 - Approval of Surfacing Materials [ST3]
4. LEV.69 – Levels [ST3]
5. FL.27 - Flood Defence Scheme [(a). Add “provision, implementation and
6. Details of all walls, fences and other means of enclosure shall be submitted to
and approved by the local planning authority prior to the commencement of
development. The development shall thereafter be carried out in accordance with
the approved details and an agreed phasing schedule.
Reason – To safeguard local visual amenity.
7. LS.57 - Hard and Soft Landscape Works [(i), Reason ST3]
8. H.35 - Parking and Turning of Vehicles [Reason (ii), ST3]
9. Details of lighting, street furniture (benches, seating etc), notice-boards,
surfacing and railings to the walkway/cycleway and promontory shall be
submitted to and approved by the local planning authority. These approved
elements shall thereafter be completed within an agreed time schedule.
Reason – To ensure a satisfactory development.
10. DR.24 - Submission and Approval of Drainage Details [ST3]
11. Details of the proposed cycle storage facilities shall be submitted to and
approved in writing by the local planning authority prior to the commencement of
development, and thereafter provided prior to the occupation of the buildings to
which they relate.
Reason – To help secure a satisfactory development.
12. Clean, uncontaminated rock, subsoil, brick rubble, crushed concrete and
ceramic shall only be used as infill material.
Reason – To prevent pollution of controlled waters.
13. Prior to being discharged to any watercourse, surface water sewer or
soakaway system, all surface water drainage from parking areas and
hardstandings shall be passed through trapped gullies to BS 5911:1982 with an
overall capacity compatible with the site being drained.
Reason – To prevent pollution of the water environment.
14. CONT.18* - Contaminated Soil Survey [(a) residential, ST3]
15. DEM.21 - Hours of Work During Demolition
[Insert “and lorry movements to/from the site”, Reason (ii),