How to file a planning objection (PA25/09482 / PA25/09483 - Pulse smart hubs at 4 locations within Penzance).

 Introduction

 This post explains how to object (or alternatively support) the application to install Pulse smart hubs with integrated digital screens at 4 locations within Penzance. 

Generic image of a Pulse hub unit

There are two applications – one for Planning Consent  (application   PA25/09482) dealing with the physical installations and one for  Advertising Consent  (ref PA25/09483 ) dealing with the impact of the proposed advertising only.

Your comments will be applicable to both applications and can be copied from one application to the other unchanged.  To be strictly correct the pavement obstruction issue is not relevant to the Advertising Consent comment.

 General Points

It is important each application appears unique so feel free to (politely) let rip about how you feel about the proposal but then ensure you mention the key points for each proposed locations and end with the list of planning policy references (see below).  This way you objection appears genuinely held  but also a ‘material (valid) planning objection’ that has to be considered by  decision makers.

Your comments should be politely expressed (for maximum impact). 

Use your own words and expressions.  My example at the end is a guide/aid not a bible.  A shorter objection can still be highly effective.

Numbers of objections count  so if you have a partner or friend with similar views encourage them to file an objection.

You should comment against each of the 4 proposed locations because not all have the same issues.

If you have recommended alternative locations (train station entrance, Harbour Car Park pay point) then suggest them (it gives more weight to your objection re current proposal).

There are some common points which can be mentioned before going into the detail of each site.  The proposed benefits of free wi-fi and phone calla is of limited benefit to Penzance given recent installation of free town centre wi-fi, the fact that nearly everybody carries a mobile phone.  Two of the 4 units are advertising to passing cars so the defibulator service is largely redundant. Only 5% of the advertising space is allocated to community use.

You should list the relevant planning policies at the end of your comments using my list (see example).  There may be other policies I have missed.

It is easier to prepare your text comments using Word or similar word processing app.  Why – because the Cornwall Council online form removes all formatting and offers only a small text window for editing meaning it is easy to get lost in your own reply.

You might want to review existing public objections online to get ideas – there are 11 objections so far.

Photomontages of Proposed Installations (taken from the application) 

Market Jew St (note pavement obstruction)

Wharf Road 

East Terrace

Western Promenade Road

Check List of Potentially Valid Reasons to Object

• Impact on the heritage and character of the town, especially the three units within the Penzance Conservation Area.
• Addition of avoidable street clutter and pedestrian obstruction (especially the Market Jew unit).
• Visual amenity and advertising (the screens are large and brightly lit). They will make the town a less pleasing place to live.
• Road safety aspect given the distraction of drivers entering Penzance from the east (the East Terrace unit) and driver entering Penzance from the Newlyn direction on Western Promenade Road (children crossing Western Promenade Road from the skate park to buy sweets and drinks from the Asda store behind the petrol station).
• The impact of avoidable light pollution on the West Penwith International Dark Sky Park.
• The health and wellbeing aspects are over-promoted when weighed against the imposition of large brightly lit adverts on the streetscape and degradation of the Conservation Area.

 Example Public Comment

I have drafted an example comment (objection) at the end of this webpage.  Use your own words.  It is a guide/aid not a bible.

 References to Relevant Planning Policy (include at the end of your comment)   

Cornwall Local Plan  Policy 24: Historic Environment (3rd bullet  point).  Maintain the special character and appearance of Conservation Areas, especially those positive elements in any Conservation Area Appraisal.

National Planning Policy Framework (NPPF)

Section 16. Title:  “Conserving and enhancing the historic environment”

Para 203 (f):  “ the desirability of new development making a positive contribution to local character and distinctiveness”.

Para 210. “In determining applications, local planning authorities should take account of”:

Sub para (c) “ the desirability of new development making a positive contribution to local character and distinctiveness”.

 

Section 9. “Promoting sustainable transport”

“Considering development proposals:”

Para 117. “Within this context, applications for development should:”

Para 117 (c)” create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards;

How to Comment. 

You can view the application and supporting documents by visiting Cornwall Council’s online planning register here  https://www.cornwall.gov.uk/planning-and-building-control/planning-applications/online-planning-register/ .   Search for the application using references  PA25/09482 & PA25/09483.

 To file a comment you first have to register with Cornwall Council (see link in planning portal when you try and make a comment).

Having already registered you can file a comment.  Your personal details will automatically fill many of the boxes of the online form.

Click on  ‘Comments’ tab

Click on ‘Make a Comment ‘

Complete authentication (enter code sent to your mobile phone)

Select 'Commentor Type'  (select ‘Member of the Public’)

Stance:  select “Object”

Reason: select ‘Residential Amenity’ (the form requires a box to be ticked)

Add your comments in the text box (best prepared in Word and cut & pasted into the text box).

Remember to submit comments on both applications.

You will get an email confirmation of your online comment submission.   

Please add a Facebook comment when complete – it will remind others to make a comment.

Example Objection

I wish to object to the installation of 4 Pulse advertising hubs in Penzance. 

The dominating 2.54 m high, futuristic, pavement mounted, display units will be highly intrusive in a small town environment like Penzance.  Three of the four units are proposed for installation within the Penzance Conservation Area where they will significantly detract from the appealing heritage setting.  The proposed units represent a pedestrian obstruction and avoidable pavement clutter, especially the unit proposed for Market Jew St (the town’s high street), a busy street with narrow pavements. 

The advertising screens are large and will feature bright, attention seeking, adverts which represent an intrusion upon the public and therefore a loss of visual amenity. 

Penzance is on the outskirts of the West Penwith International Dark Sky Park and the light from the proposed units represents avoidable light pollution.  Approval of the application would  be at odds with past precedent which has seen applications for illuminated external signage turned down for property in Penzance town centre.

Decision Makers are obliged to weigh disadvantages of applications against advantages.  The applicant refers to the public benefits the Pulse units offer which include free wi-fi and the ability to make phone calls including emergency phone calls.    Penzance has recently installed town-wide free wi-fi (a Future High Streets Fund project) and almost everybody today carries a mobile telephone on their person. The public benefits of the Pulse units are therefore tenuous.

Comments on specific sites:

Market Jew Street.   This town centre location inside the Conservation Area has narrow, busy pavements and the proposed Pulse unit will substantially narrow the  pavement further presenting an unacceptable obstruction to pedestrians, especially if disabled and in a wheelchair or on a mobility scooter.  The unit will be especially anomalous in this location.  The proposed unit will harm expensive improvements only recently completed under the Penzance Town Deal Sustainable Transport project to make the street more pedestrian friendly and aesthetically appealing.

 Wharf Road.  The proposed installation near the Wharf Road entrance to the Wharfside Shopping Centre is within the Conservation Area.  It represents significant pavement cluster and is out of keeping with the waterfront vibe of this location.  This unit would be less intrusive (but still effective) if installed next to the Harbour Car Park pay station approximately 50 metres away.

East Terrace.  This location at the back of the railway station has low footfall but faces incoming road traffic at the town’s eastern entrance.  It is located inside the Conservation Area.  The unit would represent  a stark visually anomaly.  There is a potential road traffic hazard having distracting illuminated signage on the approach to a complex junction where traffic can quickly back up at busy times  (I am referring to the notorious ‘Penzance Gyro’).

Western Promenade Road.  This installation is outside a petrol station forecourt on what is the western approach to Penzance town centre.  My concern with this location is that a large illuminated advertising screen is a distraction to drivers on a road which has many children crossing from the Wherry Town Skate Park  to buy food and drinks from the Asda convenience store .  Whilst there is a traffic light controlled  pedestrian cross some 100 metres up the road  children/youths routinely take the shortest route to cross the road.  The proposed installation also represents an avoidable blight on Penzance’s seafront.

The proposed application should be refused because all four proposed installations fail to comply with one or more planning policies (listed below) and the resulting harm is not outweighed by the relatively modest public benefits the units offer.

References to relevant planning policy: 

Cornwall Local Plan  Policy 24: Historic Environment (3rd bullet  point).  Maintain the special character and appearance of Conservation Areas, especially those positive elements in any Conservation Area Appraisal.

National Planning Policy Framework

Section 16. Title:  “Conserving and enhancing the historic environment”

Para 203 (f):  “ the desirability of new development making a positive contribution to local character and distinctiveness”.

Para 210. “In determining applications, local planning authorities should take account of”:

Sub para (c) “ the desirability of new development making a positive contribution to local character and distinctiveness”.

 

Section 9. “Promoting sustainable transport”

“Considering development proposals:”

Para 117. “Within this context, applications for development should:”

Para 117 (c)” create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards;