Below is the full objection to the planning application at 39 Deansgate (Speaker’s House) submitted by Deansgate Labour Councillors Marcus Johns & William Jeavons.
Objection to the planning application referenced 126328/FO/2020 for the erection of a 17-storey building at 39 Deansgate, Manchester, M3 2BA
This letter outlines my objection to the planning application (the Proposal) which has been submitted with the reference number highlighted above in my capacity as the local Councillor for Deansgate Ward.
This objection centres on four key points:
- That the Proposal causes undue harm to the neighbouring residential building (No 1 Deansgate) and its residential amenity
- That the proposal causes undue harm to nearby listed buildings and conservation areas
- That the proposal harms the existing townscape
- That the proposal amounts to overdevelopment
Impact on neighbouring residential property
The proposed distance between the Proposal and the existing building of No 1 Deansgate is between 16 and 18 metres. While it could be argued that this is appropriate for the existing separation distance or at ground level, it is important that it is contextualised within the façade closest to No 1 Deansgate which has a height of 105.5 meters to parapet according to the Applicant’s drawings.
This sheer, tall face is overbearing on the residential property (which is a harm of this Proposal in and of itself as discussed later) and creates a number of additional concerns. It raises the problem of extensive overlooking of residential property and into residents’ living spaces. This would be of significant detriment to the privacy of those residential properties in No 1 Deansgate and the Proposal fails to have regard to this, failing to meet Policy DM 1 (Development Management) of the City Council’s Core Strategy. I note, and agree with, the concerns around the poor mitigation proposed by the Applicant for loss of privacy which are highlighted in the objection provided by Gateley Legal on behalf of the No. 1 Deansgate Right to Manage Company Limited (the Community Objection) which has been submitted to you (pp. 8-9).
Similarly, the Proposal has a significant impact on light for those residential properties with an aspect on the south side of No 1 Deansgate, causing harm to their residential amenity. The Applicant’s own daylight and sunlight assessment highlights that there will be a ‘noticeable’ change for 5 rooms (all of which are in separate apartments). Reducing levels of daylight and sunlight is a harm and given the scale and massing of this development would cause harm to the residential amenity for all those living in property on the southern aspect of No 1 Deansgate.
I further note the concerns raised in the Community Objection about the lack of a microclimate study on the effect the Proposal would have on the dynamic façade of No 1 Deansgate. This is a significant omission by the Applicant whereby there is the potential for significant harm (and indeed permanent damage) to a neighbouring building which has not been appropriately assessed.
In Summary, the Proposal would cause significant harm to the residential amenity in the neighbouring No 1 Deansgate.
Impact on listed buildings and conservation areas
The Proposal site lies within the St Ann’s Square Conservation Area and is immediately adjacent to the Parsonage Gardens Conservation Area. The Applicant’s Heritage Statement points to 19 Listed Buildings whereby their settings could be affected by the Proposal.
St Ann’s Square Conservation Area is characterised by a high number of landmark and listed buildings, such as the Grade I listed Church of St Ann and the Grade II listed Royal Exchange. The square itself is predominantly low rise, with interesting and historical architecture of a low-rise datum around its east, south, and west.
The western side of the Square is of an eclectic, historic, and notably low-rise nature. It is of particular importance for the determination of this Application. The Heritage Statement notes further that the listed buildings in view (including the Grade I listed Church of St Ann) make an “intrinsically positive” (p. 51) contribution. It is important to emphasise that St Ann Square’s historic and aesthetic worth is not merely derived from a single viewpoint but the layout of the square, the retention of the historic building line, its low–rise roofline, and eclectic yet historic style.
The setting of the Church of St Ann cannot only be considered in light of viewpoints that contain the Church itself, but must include viewpoints from the Church, from nearby the Church, and the overall nature of the space around the Church.
The Proposal causes considerable harm to these. It is overbearing, overly massive, and terminates the feeling of structure within the square which is attributed to its layout and consistent roofline. The Heritage Statement admits that the Proposal “would introduce a dominant modern vertical element into a low-level building line which is otherwise largely 18th century in character which would be compromised…” (p. 52). I agree.
However, the Heritage Statement then says: “although the sense of enclosure (i.e. immediate setting) would be retained” (ibid). This is patently untrue from the proposed viewpoint provided in the Heritage Statement. The viewpoint clearly shows a looming effect over these heritage buildings, disrupting the sense of enclosure and drawing the eye towards modern design and away from the historic character of the square. It intrudes upon the setting of these specific buildings, the Square overall, and the Conservation Area in its totality – generating a major adverse impact.
The Proposal would also generate severe and obvious harm to the Grade II* Listed Barton Arcade. Not only is the Proposal planned to be physically attached to this Listed Building, but also it looms over a key heritage asset in our city. It is worth noting that the internal impact within the Barton Arcade is not considered by the Applicant and that this is likely to cause further harm to a key heritage asset, as highlighted in the Community Objection.
Viewpoint 6 of the Heritage Statement demonstrates the significant harm caused by the Proposal to the setting of the Grade II Listed Royal Exchange Building. It is an attractive and iconic viewpoint in Manchester that the tower of the Royal Exchange stands against an uninterrupted backdrop from the open pedestrian space at this location on Market Street. The Proposal would severely diminish the value of the heritage asset, its setting, and reducing the experience and appreciation of the pleasing aesthetics it provides to our city.
Similarly, the Proposal is domineering over Police Street and the heritage assets contained nearby – as highlighted by Viewpoint 7 of the Heritage Statement. It creates an aesthetically poor backdrop to views of historic assets, some of which (such as the corner of 15-17 King Street) are of an unusual architectural style within the City and deserving therefore of extra consideration.
On balance, the Proposal causes undue harm to the St Ann’s Square Conservation Area and the listed buildings within it.
The Parsonage Gardens Conservation Area’s characteristics are of historic Victorian and Edwardian architecture of high quality, centres on Parsonage Gardens which is a peaceful and attractive green space.
The scale and massing of the Proposal is such that is overbearing on the Parsonage Gardens Conservation Area, as clearly shown by Viewpoint 5 of the Applicant’s Heritage Statement. Within this view, the building stands alone – dominating the sleek corner of No 1 Deansgate that is currently visible and overriding the heritage architecture on display. It is dominating. The Heritage Statement’s judgement of ‘negligible adverse’ impact is a clear understatement under even the most casual scrutiny of this viewpoint.
There is clear harm caused by the Proposal in the proposed viewpoints to the nature of the Parsonage Gardens Conservation Area.
Overall, this Proposal causes severe harm to two key Conservation Areas in Manchester City Centre and harms the setting, character, visual amenity, and the experience and appreciation of listed buildings and heritage assets in the area.
The National Planning Policy Framework (NPPF) gives great weight to conserving listed buildings (para 193). It is a clear aim of the NPPF that the visual compromise to the setting of listed buildings is avoided. The Planning (Listed Building and Conservation Areas) Act 1990 requires the Local Planning Authority to have “special regard to the desirability of preserving the building or its setting or any featured of special architectural or historic interest which it possesses” (Section 66). Furthermore, it states special attention shall be paid to the desirability of preserving or enhancing the character appearance of that [conservation] area” (Section 72). Additionally, Manchester’s Adopted Core Strategy requires that development should have regard to effects relating to built heritage (Policy DM 1), all development in the City Centre should preserve or enhance heritage assets including listed buildings and conservation areas, noting the need for a coherent and integrated physical environment (Policy CC 9), and development must be designed so as to support the Council in preserving or where possible enhancing the historic environment, the character, setting of areas and buildings of acknowledged importance including listed buildings, registered parks and gardens, and conservations areas (Policy EN 3).
In light of the policies highlighted above, significant weight should be given to the adverse impact and incoherent environment which this Proposal would have on and would create within and nearby to the Conservation Areas and Listed Buildings mentioned above. I contend that this impact alone would be sufficient for the Application to be rejected.
Impact on the townscape
Notwithstanding the harm to nearby heritage assets, the Proposal is overbearing and incongruous with its surrounding townscape. This represents an adverse impact on the character of the area in contradiction to the adopted Guide to Development in Manchester Supplementary Planning Document and Guidance.
In this regard, it is principally the Proposal’s scale and massing which are overbearing on their surroundings and incongruous within their setting.
The Proposal’s Design & Access Statement illustrates the domineering nature of the Proposal with respect to the significantly increased height of the Proposal when compared to the existing area (surrounding building heights plan, p 18). The Design & Access Statement then reinforces this with illustration 3.8.1.A which highlights that the scale of buildings along Deansgate is fairly consistent low-mid rise with No 1 Deansgate and Beetham Tower providing bookends.
The Proposal is taller than No 1 Deansgate, and creates a displeasing effect to the townscape whereby the roofline on Deansgate’s eastern side would rise in a sleek fashion with a sloping roof along No 1 Deansgate, increase sharply for a significant blocky mass (the Proposal), and then drop off sharply for the lower rise datum of the middle section of Deansgate’s eastern side until the Beetham Tower to the south.
This disrupts the current bookend effect, by creating a large blocky mass in a heavier and blunter style than No 1 Deansgate. The Proposal interrupts the coordinated effect provided by the similar blue colour scheme and glass material palette of No 1 Deansgate and the Beetham Tower rising above a mid-rise building line with a predominantly brick palette. It further interrupts the sleek shapes used by those buildings to reduce their ‘heaviness’ in the context of Deansgate – the Beetham Tower with its slender profile and blade, and No. 1 Deansgate with its light steel frame, visible overhang, and angled profile. The Proposal is not only overbearing, but it disrupts a pleasant and seemingly coordinated building line which is bookended currently in an aesthetically pleasing way.
It is also important to note that litany of errors in the Townscape & Visual Impact Assessment which have been noted by the Community Objection and must be addressed by the Applicant prior to determination.
In summary then, the Proposal, its scale, and its massing would impose significant harm on the existing townscape, its character, and its sense of place.
Furthermore, the Proposal’s site sits within the Ramada Complex Strategic Regeneration Framework (the SRF) which was adopted by the Council’s Executive on and therefore became planning policy. The SRF only takes the view that “current mix commercial and retail uses represent the preferred ongoing uses for this site.” The SRF requires the proposals’ “height will need to be determined through contextual appraisals and townscape analysis of the site.”
In light of the appraisal in the preceding and current sections of this letter, I consider that the height and massing of this Proposal are inappropriate for the context and townscape within which it is proposed.
The current building on the site is a nine–and–a–half storey building, while the Proposal is for a 14–storey building. The design maximises the delivery of floorspace on the site with heavy massing and large scale.
The Applicant does not seek to justify why this high level of scale and massing is necessary for the financial or economic viability of the Proposal, and as I highlight below, it is unclear that the high level of scale and massing provides relevant benefits which outweigh the harm caused by the Proposal.
It is too broad from all viewpoints, and its irregular shape gives a highly unpleasant view of an imposing building leaning toward the viewer from the immediate north (especially within No 1 Deansgate).
The Proposal is a significant expansion from a setback building of nine storeys to a building of 17 storeys which occupies the full width of the plot and indeed is an irregular quadrilateral shape in order to occupy said full width. Not only does this massing significantly increase the harm outlined above but amounts to overdevelopment in and of itself. The Proposal is an excessively intensive use of the site on which it is proposed, overbearing within its context, and would create sightlines where the Proposal sits in a heavy and visually displeasing manner.
Concerns over cited key benefits
The Planning and Tall Building Statement points to 9 benefits – three of which are significant (and have been emphasised in bold by the Applicant in Section 9.12). These are:
- 723-731 FTE net additional jobs
- £2.3m per annum in business rate contributions
- £1.9 million increase in local expenditure
The existing economic context—and not that which existed when the Application was written—should now be considered. This context is one of economic decline. The COVID19 pandemic and related lockdown have created a severe recession and all indications are that a protracted period of economic depression is in store.
Social distancing measures have led to a shift from office–based working to working from home en masse. It is contextually illiterate to consider that there will not be permanent changes to the local (and indeed global) office market resulting from this.
The 2015 Employment Density Guide is simply no longer a relevant guide in determining the amount of employment that will be generated by development. Not only have there been significant changes in the economic context during a period of growth, but also the COVID19 pandemic and changes to working from home related to it have distinctly altered the assumptions and data on which the guidance rests. There is significant uncertainty of the permanence of this shift and a dramatic collapse in demand for office space in light of this has taken place. As such, the Proposal’s estimated operational job figures should be of no relevance to the determination of the Application having been superseded by events.
The Planning Statement asserts that the Proposal will result in £2.3 million per annum which assumes a rental rate of £33/£35 (office/retail) per sq ft. There is no attempt to justify these assumed values. Even had there been some justification, the severe changes to the economic context and office market as a result of COVID19 would have brought those assumptions sharply into question—hence these figures hold no confidence.
The Applicant also emphasises increased local expenditure of £1.9 million per annum. This is based (according to Section 6 of the Planning Statement) on a 2015 report on UK Working Day Spend (uprated by inflation by the Applicant), multiplied by a 220-day working year, multiplied again by the 723-731 FTE jobs projected and discussed above. As I have argued above, I do not think that the 723-731 FTE are meaningful in determining the benefit of this application. Furthermore, the 2015 report cited by the Applicant is now 5 years old and refers to spending patterns during a very different stage of the business cycle. Once again, given the prevailing context of economic damage caused by the COVID19 pandemic—and particularly the danger this has posed to people’s incomes (suggested by significantly increased Universal Credit claimants and the number of workers currently registered on the Government’s Job Retention Scheme), such a report and calculations derived thereof can no longer be considered relevant to the determination of this Application (or indeed any other).
In addition to the benefits which are emphasised in Section 9, Section 6.15 points to “meeting an identified need for high quality office space.” For the reasons which I have listed above relating to the FTE job calculation, I argue that the changes brought about by COVID19 would suggest that any identification of need is simply irrelevant and unrealistic. It is not clear that there is need for a 18,283 sq m landmark office building at the current time or that this will be the case for a number of years.
In summary, there are clear methodological problems with the benefits cited in the Planning Statement and this calls into question their appropriateness in determining this Application.
The Application should be rejected for the four key reasons which have been outlined in this letter. I have discussed the undue harm the Proposal would cause to neighbouring residential property, to listed buildings and conservation areas, and to the townscape, and that the Proposal amounts to overdevelopment. I have also questioned veracity of claimed benefits within the Application. On balance, the harm caused by this Proposal outweighs any benefits that it would provide.
I would ask therefore that that the Council rejects this Application.
Labour Councillor in Deansgate Ward