Comments on the planning officers’ report for application 07/0809/ADV (the signage application)

Summary

  1. The report is based on an inaccurate (because incomplete) reading of the relevant design guidance. The assertions in the report about compatibility with local guidance are wrong; it is not compatible with the local design guidance.
  2. The recommendation for approval is based on an inaccurate and thus misleading characterisation of the existing signage in the area.
  3. One of key grounds for recommending approval appears to be unsubstantiated, aesthetic judgements on the part of the planner or planners about the attractiveness of the proposed Tesco shop front relative to other shop fronts. While not wishing to question the planners’ personal taste, we do question what part this type of judgement should have in the EAC’s planning decision.

The Detail of the Report

Having read the planning officers’ report on this application, we have a number of comments on what we regard as its significant flaws, including a number of errors of fact. For greater clarity, the comments follow the structure of the report itself, with comments referring to the report’s numbered paragraphs. We would also ask you to re-read the objections document concerned with this application, which we sent you before Christmas (please let us know if you would like another copy).

Planners’ Taste as a Basis for Planning Decisions

Paragraph 8.3

The planner states that

The signs proposed by this application, in my opinion, would improve the appearance of what is currently an unattractive building […] The old signs, which have been removed, were much more strident than the quieter, more subtle signs that are now proposed. […] I cannot but say that what is proposed would be a significant visual improvement over the current appearance of the building, or that when the ground floor was last occupied.

This highly personal, aesthetic opinion, unsupported by any detail, seems a curious basis on which to make a planning recommendation. Clearly, we have no wish to enter into a dispute with the planning officer about their personal taste, but we question whether it is an appropriate basis on which to decide a planning issue which will impact on a significant proportion of a Local Centre.

In particular, we do not consider it a sound basis for either the planners’ recommendation or possible approval by councillors in the absence of

  1. any supporting detail about the proposed or previous frontages and signage, or of
  2. any clearly defined design criteria specified in the report, against which councillors could measure these assertions when considering the recommendation.

Dissimilarity From the Co-op Signage

Paragraph 8.4

The planner says that:

The proposed signs, in my view, would not be dissimilar to those of the other larger store in the Local Centre, the existing Co-op to the east, in terms of size and style. That this property is set slightly further back from the carriageway than the Co-op between two buildings that stand slightly forward, would probably help, a little, to limit any impact upon the street scene.

These assertions of similarity with the Co-op sign are incorrect. This is because the proposed Tesco signs, unlike that of the Co-op, comprise an internally illuminated box fascia and an internally illuminated hanging sign. The Co-op has neither of these things.

It should also be noted that like the 163-167 Mill Road site, the Co-op is set back from the carriageway; in addition, the Co-op sign is partially screened by trees, which the proposed sign would not be.

The proposed sign would thus be far more obtrusive than the existing Co-op sign because unlike the Co-op sign:

  1. It would be an internally illuminated box fascia;
  2. It would be accompanied by an internally illuminated sign;
  3. It would not be partially screened by trees

8.4 is, additionally, a curious statement given the assertions in 8.3 that the proposed signage would improve the appearance of the immediate area – if this is true, why is any positioning that might limit their impact on the street scene to be welcomed? This is inconsistent, and suggests a recognition that, in fact, the new signage might not be the design benefit to the area that the planner suggests in 8.3.

Incompatibility with Design Guidance

Paragraph 8.6

The report states that

Paragraph 14 of The Cambridge Shopfront Design Guide (Nov 1997) refers to illumination and states that ‘illuminated box fascias will not be acceptable’. The guide does not specify whether it relates to internal or external sources of light

This seems to us to be a misreading of the guidance. Paragraph 14 of the guidance states that

Illuminated box fascias will not be acceptable. Strip lights which fit within the cornice or architrave, individually lit lettering and a small number (two on most shopfronts, three on very wide frontages) of slim, elegant spotlights can be successful. On hanging signs, the illumination should be discreetly attached to the bracket.

This list of the types of illumination that are acceptable indicates very strongly that other types are not. The sense that this gives that internally illuminated box fascias are not acceptable is confirmed elsewhere in the guidance, where is says that:

When Advertisement Consent is required, the signs and advertisements will be judged against the following policies from the Cambridge Local Plan 1996, together with the additional guidance contained within this document: […]

BE 20 Internally illuminated box fascia and projecting signs will not be permitted where they would adversely affect the character of the building concerned, or the street scene, or both. [our emphasis]

Although the 1996 Local Plan has been superseded, this section appears not to have been. The current Local Plan simply refers back to the 1997 design guide on matters of shopfront design. Since the 1997 guidance on box fascia illumination in turn rests on this statement, it seems that this is current state of local guidance on the subject (certainly, the planning officers’ report mentions no other guidance on this question which might have superseded it). Therefore, contrary to the planning officers’ report, an accurate reading of the guidance clearly shows that internally illuminated box fascias are not permitted under current guidance.

Since the wording of the application would, if approved, permit an internally illuminated sign more than 15 metres long we remain concerned about the impact on the night-time appearance of this part of Mill Road, which would be radically altered by such a sign, as well as by the effect of light pollution. As we said in our original objection, there is no comparable signage on this part of Mill Road and to claim that it would not significantly affect the appearance of the area is thus incorrect.

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