7th April 2021 Planning Committee – Additional Representations



Site Address

Application No.



Unit 3, Goldstone Retail Park, Newtown Road, Hove, BN3 7PN


Objection from the Hove Station Neighbourhood Forum:


The Hove Station Neighbourhood Forum objects on the grounds of increased disturbance to the existing and future residents.


Planning permission has been granted for the KAP-Peugeot development with 148 flats, immediately adjacent to the goods-in yard.


Extract from the Hove Station Neighbourhood Plan Part One (Regulation 16, December 2020) Section 4 Policies, Subsection 4.2 Employment, Policy 9, page 56)


“…it will be important to carefully control additional noise emissions especially from sources such as delivery traffic. This will become an important issue in making Hove Station Quarter a success. It will be essential that times for noisy industrial activities are clearly defined. For example, the replacement of containers of waste should not take place before 8am on weekdays and be prohibited on Sundays. Controls of noisy activities will be sought through planning conditions linked to the grant of planning permissions. The World Health Organization's Environmental Noise Guidelines shows strong evidence that noise pollution is a top environmental hazard to both physical and mental health and it is therefore essential to control it as far as possible.”

The Noise Impact Assessment is insufficient:

(1)   Even low level noises can cause disturbances. This is best described by a resident’s comment: "If you hear a vehicle pass by in the street, you might notice the noise it makes, and then it's over. But if you hear a noise coming from the retail park, you get anxious: will it last for a minute or an hour or all day?"

(2)   Acoustic tests  measure typical noises from standard procedures. But in practice, noise disturbance in the real world is unpredictable:

·      a lorry of a different specification arrives, the delivery staff may need to strike the locks stridently, in order to open the tailgate.

·      The delivery staff may feel the need to shout to their colleagues.

·      Some lorries’ reversing alarms emit white frequency sounds (“ssh-ssh”) while other lorries emit piercing sounds (“beep-beep”).


The accumulation of noise disturbance has negative effects on health and wellbeing.

The Forum takes the view that any extension of delivery hours must be opposed.


Comments from Environmental Health (received 26 March):


I write with regards to the above and the proposed “Variation of Condition 13 of

application BH2020/00549 (External alterations to front and rear elevations

including installation of new plant. Alterations to part of customer car park to

provide trolley storage, covered cycle parking and car parking for disabled and

parents. Use of Unit 3 for retail (A1)) to change the servicing hours to 07:00-

21:00 Monday to Saturday and 08:00-18:00 on Sunday.”


I have now fully examined the “Noise Impact Assessment” document submitted

by K Acoustics Ltd,  for the Proposed Lidl Food Store, Goldstone Retail Park, Hove,

Reference: 8197/FD and have discussed the findings contained within the report

and soe queries I had with Mr Blake Lucas – the director of the company.


Two noise surveys were completed at the site. The short term survey was

completed for 1 hour on 10th January 2020 to determine the noise climate on

Goldstone Lane. The long survey was completed over the weekend starting on

17th January 2020 to assess the equivalent and background noise at the

Nearest Sensitive Receiver (NSR). 


I believe that sufficient data was collected in order to make a thorough and

robust assessment of the existing noise climate and a full understanding of the

noise levels associated with such a proposal (and therefore, what and how any

additional noise will impact on NSR’s) has been completed by the consultant

that carried out the noise impact assessment.


The Noise Impact Assessment concluded that:


After assessing the proposed site operations, we would consider noise

associated with the proposals to be acceptable in terms of environmental noise

emission to both the existing and proposed sensitive receivers in the area. As

such, the proposed extension of daytime hours is considered acceptable.”


We would consider that noise from the proposals will achieve the aim of the

National Planning Policy Framework (NPPF) and development noise will not

cause any change in behaviour or attitude.”


After discussing some concerns with the author or the assessment and the

director of the acoustic consultancy that produced the assessment, I now have

no reason to disagree with the conclusions drawn to.


The correct standards, methodology, practise, policy and guidance have been

applied throughout the assessment. 


As such, please accept this email as formal confirmation that I have no further

comment or concerns about application BH2021/00282.


An email has been received from Councillors Brown and Bagaeen:


A copy of the correspondence is attached.


Councillor Bagaeen has separately expressed his support for the scheme.  A copy of the correspondence is attached.


Following the publication of the report, an additional 18 objections have been received. No additional issues have been raised that have not been covered within objections noted in the report.



24 Holland Road




Additional comment from Environmental Health (25th March):


Suggested informative relating to the management plan required by condition 7:


The MANAGEMENT PLAN shall include the following with a view to protecting the amenity of surrounding residents and other users of the property.


1 Signage will be placed at the entrance of the property identifying the person or agency responsible for managing the property and an emergency contact number.


2 All house rules will be displayed throughout the property. House Rules form part of the rental agreement with guests and can be enforced through all major letting platforms, including Airbnb, HomeAway and Booking.com.


3 An 11pm curfew for the outdoor areas, shall be displayed on an external wall of the garden.


4 No gatherings of guests shall take place outside after 11pm.  Exempt for smokers.


5 No hot tubs or related facilities shall be provided for the use of guests in outside areas.


6 Signage will be placed at the entrance of the property identifying the person or agency responsible for managing the property and an emergency 24 hr. contact



7 The external spaces to be used by overnight guests only and will not be hired out

for events.


8 Guests making same-city bookings will be asked to clarify the purpose of their stay, with reservations cancelled if the Host believes there is likelihood that their House Rules may be breached.


9 Amplified music will not be permitted in the external areas at any time.


10 Guest numbers will be limited to the maximum number of occupants allowed by

planning condition.


11 Windows and doors giving access to the outside shall be closed and remain closed after 11pm.


12 No outside bar area shall be provided.


13 No food delivery services shall be allowed at the property after 11pm.


14 The owner shall demonstrate and maintain throughout membership of a private 24 hr rapid response noise patrol staffed by licenced SIA security personnel. A contact telephone number for the service shall be made available to local residents via a letter drop.


15 Notices shall be displayed at exit doors requiring guests to respect neighbours.


16 Management information will also be provided to guests upon arrival. This will be

regularly updated and provide valuable information to tenants of the property such


·         Landlord/Host or their managing agent’s contact details (including emergency contact number)

·         House Rules

·         Fire procedure

·         Evacuation procedures

·         Smoking policy

·         Policy of Anti-social behaviour


An informative to this effect has been added to the recommendation.


Two (2) additional objection representations received from the Brunswick Town Association and the Friends of Palmeira & Adelaide Residents Association, raising the following points:

·         lack of information as to whether the proposal is an HMO, a B&B, a hotel or a party house

·         no details of management

·         no record of rubbish disposal

·         contrary to QD27

·         potential for this to be a party house


These points are already summarised in the Officer Report.