Peterborough City Council Chamber during the meeting. JW is on the extreme left.
Further to my discourse in support of the call-in at the Strong and Supportive Communities Scrutiny Committee meeting on 19OCT16 in the Peterborough council chamber (transcript below) I have made enquiries in support of my contention that the scheme as envisaged is not deliverable, since it is not -and cannot be made to be- compliant with building legislation.
In response to my submisson, recorded by Russian RT5 television and various camera phones, Cllr Seaton declared that I was mistaken regarding my reference to HMOs (Houses in multiple occupation), since none were envisaged. Whilst I did not have the opportunity to challenge his response in chamber, I would refer you to the tables of items 5.9.2 and 5.9.3 of the published Report of the Service Director for Adults and Communities, published for, and germane to the debate that evening – that the very basis of financial forecasting with regard to income from this proposal rests on there being 98 households in place of the 74 presently constructed without there being additional properties constructed. Whilst conversion of a house into 2no self-contained flats does not per se create an HMO, the construction of self-contained dwellings does rather suppose that each has its own kitchen and bathroom. therefore, either a single 3-bed house (for example) has to accommodate an additional kitchen and bathroom in the same footprint, whilst retaining suitably sized living and sleeping accommodation for each household OR it is an HMO with shared facilities. I had assumed that new dwellings were not being created to increase households from 74 to 98 (that is to say by approximately 25% in the same development, which would have been subject to population density controls at the time of its construction) and, to corroborate my contention, checked with Peterborough ‘Planning and Building Control’late this morning.
Introducing myself as a party “acting on behalf of Cllr Johnson (who represents the ward in question)”, I requested sight of Planning and Building Control submissions for Nos 19 and 25 St Michaels Gate, Parnwell. I was denied access as these were said to be subject to the Data Protection Act – however, stating that if I could not have sight of the documentation, would the officer confirm whether a ‘full plans’ or ‘building notice’ had been submitted for alteration works to numbers 19 and 25? The response was in the negative. In case I had been given inaccurate information concerning address numbers I asked whether other notification had been received concerning other addresses, perhaps since August – or certainly within the last two years. No; the only records referred to statutory test certificates relating to gas safety and electrical installations. I have also checked for planning permission submissions online over the same period. It is -I would contend- a matter of record that neither the previous nor the present owners of the St Michaels Gate development have, nor their agents, have applied to convert dwellings or increase the volume of same, or carry out any substantial works in compliance with construction and safety legislation as contended in my submission before the committee. I can therefore state that figures relating to the income from 98 dwellings are a fiction; a fantasy that has not been tested and may be considered invalid in the real world. If the decision was made on the basis of such projected income, it was very rashly made.
Transcript of spoken submission to committee meeting held on 19OCT16:
“Mr Chairman, Councillors, Council officers, residents of St Michael’s Gate and other good people of Peterborough…
My name is Jonathan Wilde and I am here representing the South & East Branch of Peterborough’s Labour Party, which encompasses Parnwell in the East ward. My Colleague, Jo Johnson has covered many issues relating to the current proposal, but my contribution comes from my 34 years in property as a building designer, construction surveyor and project management consultant.
I have visited St Michaels Gate twice recently, and am aware that some five properties have been vacated; two of which I understand having received a measure of alteration works increasing the number of bedrooms within the original building footprint. From my reading of the proposal, the intention was to ‘house’ people –families, chiefly, one would hope in family units – NOT to create HMOs as a means to cram as many people as possible into the smallest conceivable space!
It is my professional opinion that the development of 74 houses was at the time of building approval, constructed in accordance with the Parker Morris standard for square metreage (or square footage under the Public Health Acts, if you will), allowing 11.0m² for main double bedroom, 10m² per additional double and 7.5m² per single bedroom, with one 10th that floor area as glazing, half of which to be openable for natural ventilation.
Kitchens, Kitchen Diners, Lounges and bathroom provision being predicated on an appropriate scale; the greater the number of occupants the more extensive such provisions need be. Simple arithmetic will demonstrate that two singles, compliant with this standard are not possible to derive from one double bedroom, and it is doubtful that the alteration works so far carried out are fully compliant with Regulations under the Building Act 1984 as amended by the Deregulation Act 2015.
If the homes are to be considered as HMOs, housing persons not of the same consanguinity, then additional fire regulations come into play with regard to fire separation, means of escape with additional lobbies equipped with self-closing fire resisting doors and installation of integrated fire detection systems. An annual Fire Risk Assessment is a statutory requirement for HMOs under the Regulatory Reform (Fire Safety) Order 2005.
Such works would, in the opinion of any building professional, be considered ‘substantial, altering the character and nature of the building.
‘Substantial’ works is a defining characteristic of work notifiable to the Local Authority’s BCO. I have yet to receive assurance that the works are compliant. I would doubt they can be – but, I have not been party to any inspection.
I have not touched on the Town & Country Planning aspect of the proposal since the ‘use class’ as residential dwellings has not changed, but I would call into question permitted densities of occupation per Hectare if the intention is to create a preponderance of HMOs within this development.
I move that the proposal be reconsidered and placed before full council on the grounds that the means to provide the desired housing solution have not been fully considered in terms of impact assessment (I refer here to my colleagues’ comments), cost and more importantly compliance with safety regulations and the protocols of building legislation.
I thank you for your time and indulgence in hearing my submission.”