Proposed Submission Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document

Comment - The site is adjacent to the New Wolsey Theatre.

New development adjoining cultural facilities such as your theatres, pubs and music venues, need to ensure that any new residents will not be disturbed by the usual operation of that facility to the extent that Council would be required to take action, e.g. issue a noise abatement order. Given the age and construction of many older community and cultural buildings, it is often difficult to install noise mitigation measures to deal with these issues, which affects the sustainability and viability of the cultural venue.

Item 123 of the National Planning Policy Framework makes it clear that the operation of existing businesses, such as cultural facilities, should not be restricted as a result of new development, supported by the PPG on Noise. The loss of a valued community or cultural facility as a result of changes in the area would conflict with NPPF guidance at item 70 which states that planning policy should protect existing cultural facilities.

There is a recent Planning Inspectorate decision (Reference APP/ X5990/A/12) to refuse consent for conversion of offices to residential adjacent to the London Palladium Theatre, and another decision (Reference APP/K5600/A/14/2222551) to dismiss an appeal for the creation three residential units on the upper levels of the building containing the Finborough Theatre, London (Royal Borough of Kensington and Chelsea).The Inspectors concluded in both cases that there would be harm to future residents living conditions in respect of disturbance from theatre activities and that the long term operation of the theatre would not be safeguarded, as per the NPPF.

The theatre should be noted as a constraint to ensure that noise, vibration and access issues are considered in the design.

The Theatres Trust supports this Policy as it reflects guidance at item 70 of the NPPF which states that planning policy should protect existing cultural facilities.

However, it is a concern that it only covers facilities in the main town centre area. This type of policy is normally included as a core strategy or a general development policy.