Download the full briefing document here. It is summarised below.
Background to the development
The development site lies within the North East Quarter of Belfast City Centre, and straddles two Conservation Areas: City Centre and Cathedral Quarter. The almost 12-acre site was granted planning permission (Z/2010/1532/F) in 2012 by DOE for a mixed use scheme.
In 2015, the assets were acquired by Cerberus Capital Management, before being sold to Castlebrooke Investments in January 2016.
In October 2016, a planning application (LA04/2016/2327/F) was submitted proposing to vary conditions of the original Royal Exchange planning permission to enable a phased delivery. The Department for Infrastructure approved that application in January 2017. Phase 1a was exempted from that variance and work commenced on Lower Garfield Street and North Street in October 2017.
Pre-planning public consultation began in February 2017 for the outline and in July 2017 for Phase 1b, and the plans were met with a large degree of public concern. These concerns were articulated extensively during the consultation periods. Almost 4,000 letters of objection were sent in response to pre-planning consultation.
A number of planning applications have since been submitted to Belfast City Council in relation to the scheme:
LA04/2017/2575/DCA (Demolition of 30-34 North Street);
LA04/2017/2597/F (Demolition of building and temporary hard landscaping 30-34 North Street);
LA04/2017/2343/DCA (Demolition of buildings, Temple Court St Anne’s Cathedral Precinct & St Anne’s Court 39-65 North Street Belfast BT1 1NA);
LA04/2017/2345/DCA (Demolition of buildings, 3-5 and 9-13 Rosemary Street (BT1 1QA) and 2-22 and 30-34 North Street (BT1 1LA) Belfast);
LA04/2017/2341/O (Application for outline permission);
LA04/2017/2350/DCA (Demolition of buildings 16-24 Donegall Street (BT1 2GP) 13-31 North Street (BT1 1NA));
LA04/2017/2336/LBC (Listed Building Consent for alterations to building, 11 North Street Belfast BT1 1NA);
LA04/2017/2352/LBC (Alteration and 6-Storey extension of Assembly Rooms, 2 Waring Street Belfast BT1 2DX)
Our concerns are summarised below under the following headings:
- Consultation process
- Housing & Community
- City Economy
- Arts & Culture
- Built Heritage
- Good Design and positive placemaking
Having reviewed the detail of the pre-application community consultation (PACC) reports included with the various applications associated with this development, we have serious concerns that the extent and quality of the consultation fails to meet either minimum statutory requirements or industry best practice, and has further been misrepresented by the applicant in the PACC.
We argue that on this basis, Belfast City Council should decline to determine this planning application until further sincere and meaningful consultation has been conducted. We have raised these concerns directly with Head of Planning (correspondence 10 October 2017) and are yet to be informed of the Council’s decision.
Housing & Community
The residential provision proposed for the tower at the corner of Rosemary Street, Bridge Street and North Street is ‘around 150 apartments’ – this prioritises private profit over local concerns. The housing is confined to 1 & 2 bed apartments, and is all private with no social or affordable housing provision made. This goes against good planning principles of mixed tenure housing.
We want to see social housing integrated into the scheme as an integral part. Mixed tenure housing is important to creating balanced communities and shared spaces, as well as helping to alleviate the current housing crisis. Belfast City Centre is a shared space and we should work hard to ensure that a balanced, sustainable community is able to develop within the City Centre. This will support other commercial and cultural uses and help create safe and vibrant streets. This is the norm in many European Cities, and we should look to these and learn from them as examples of thriving and sustainable city centres.
The play strategy of the scheme will be “limited to doorstep play”, defined as “a landscaped space including engaging play features for young children under 5 that is close to their homes, and places for carers to sit and talk.” It is also proposed that “Roof garden and terrace areas of the proposed buildings will provide small open play spaces” and that “Throughout the public realm there will be the opportunity for ‘incidental’ playable spaces.”
These considerations are described in indicative illustrations with no figures or options appraisals, preventing thorough analysis of the proposed strategy.
The ‘incidental’ play spaces that will be developed later cannot be relied upon to contribute to the strategy. The housing provision within the scheme is not child friendly, and has not been designed to be so.
Questions to consider about housing and community:
What is the evidence-base upon which housing need for the City Centre has been assessed?
Why only 1 and 2 bed apartments with no outside private amenity space? Why has there been no consideration of the need for family housing and housing that would be suitable for older people and those with limited mobility?
How will putting the vast majority of residential development into one block help create lively and safe streets across this part of the City at different times of the day i.e. when the offices and retail close?
How does the proposal contribute towards the SPPS Core Planning Principles of improving health and wellbeing, creating and enhancing shared space, supporting sustainable economic growth, and good design and positive place-making?
If social housing currently provided on Donegall Street is to be removed, will it be replaced, and if so, where?
This scheme is only viable if demand for retail space increases. Belfast’s central retail core has a 17% vacancy rate on average. The scheme is retail-led and therefore extremely vulnerable to fundamental changes happening to this sector, such as online shopping. Lower North Street has 71.8% occupancy; Donegall Street Lower has 86% occupancy; Rosemary Street has 70% occupancy.
CQ is also home to dozens of arts and cultural organisations that will be impacted by this scheme. According to BCC Cultural Framework, Belfast City Council estimate that the return on investment in the arts is £8 for every £1 invested. (BCC Cultural Framework p.7) Rents and revenues are higher in retail units in historic areas; the restoration of historic buildings also represents good value for money. The construction industry and threatened traditional skills benefit from heritage-led regeneration. Developing not demolishing buildings represents the most sustainable form of development.
It is very important that we ensure there is a reliable evidence base to support the retail demand in this City, otherwise we are losing substantial heritage to create vacancies and problems in the future.
Questions to ask about City Economy:
Job creation – is the methodology clear as to how they arrived at the figure they claim? Has it been adjusted for job displacement?
How confident can we be of external investment of high street chain stores in the current uncertainty of Brexit? What adaptability is being built into this proposal to mitigate this risk?
Given the documented value of the arts and culture to the city economy, how will the displacement of arts and cultural organisations be offset?
How will the harm to existing tenants – one of which has been trading continuously in the area for over a Century – be offset? Will there be special tenancy agreements made available to allow existing tenants to return to the area once redevelopment has been completed?
Arts and Culture
Since the early 1990s, the arts have slowly but surely been the most vocal and visible contributors to the area. Alongside the Art College, the North Street Arcade was a mecca of newly established arts organisations and signature shops supporting the creative and cultural community. Little wonder that the MAC should choose to be here, along with Golden Thread Gallery, Belfast Exposed, PLACE, PS2 and some 45 other publicly funded arts organisations from Community Arts Partnership and Cathedral Quarter Arts Festival to Dance Resource Base and the Belfast Children’s Festival. This is the arts epicentre of the city, as the tens of thousands attending Culture Night annually in Cathedral Quarter signifies year after year.
A further wave of development has occurred with creative industries establishing themselves in CQ. So, as the restaurants and bars have become more numerous, so have those who depend on this cultural clustering for their livelihood.
The developers have not engaged adequately with the arts and cultural sector. The current occupancy rates of cultural activities in the area has been under-represented in the planning application’s supporting documents, thus underestimating potential impacts.
Questions to ask:
What information has been gathered to support the commercial-led rather than culture-led redevelopment of this area? Have culture or heritage-led options been given consideration?
How will the impact of this development on the local arts and cultural scene be mitigated by the developers. Will the developers enter into planning agreements to ensure right of return once the development is complete?
When will specific details of floor-space for so-called cultural provision be provided, including associated rent levels?
The site contains six listed buildings and lies across two conservation areas. It is a particularly sensitive area, performing a valuable and unique role for the city in creating a distinct identity, character, and sense of place for the city.
Article 104 of The Planning (Northern Ireland) Act 2011 states that in conservation areas “special attention shall be paid to the desirability of preserving and enhancing its character or appearance”. The SPPS states that in managing development within a conservation area, the guiding principle is to “afford special regard to the desirability of enhancing its character or appearance where an opportunity to do so exists”. It further states that “there will be a general presumption against the grant of planning permission where proposals would conflict with this principle”.
The proposed scheme erodes this character on a significant scale as a total of 16 buildings will be completely demolished, a further 5 demolished with retention of their facades, 2 listed buildings partially retained, and only 2 being kept in their entirety as a result, which directly contravenes both the 2011 Planning Act, and the SPPS.
Questions to ask
Has the developer engaged with potential funding bodies about financial assistance towards funding the restoration of North Street Arcade? This is particularly important given that we can now establish that the retail anchor does not have to be located on the site of North Street Arcade, and that alternative design options exist?
Has the developer considered the huge economic value over time that heritage brings to an area? If the developer was to have a long-term interest in the area’s development, perhaps they would be able to accrue a greater profit over time for their investment?
Has the developer fully considered the impact of the proposed new buildings on the settings of existing listed buildings, especially the overshadowing of the proposed tower on the historic assembly buildings?
Good Design and Positive Place-Making
Urban design is defined by the DOE (now DfI) as “the collaborative and multidisciplinary process of shaping the physical setting for life in cities, towns and villages” (DOENI, 2014). This means that it is important to understand both what the design is, and the process by which it came about. There is currently no clarity given by the developer as to how the current design came about.
Design principles have been specified by the developers as required for Design and Access Statements – but some of these miss the point. For example, the developer acknowledges that mixed use creates vitality, lively and safe streets, but not that this is only when the mix is appropriately spread across the development site. Putting all the housing together in one block does not achieve this. The design principles are being applied incorrectly.
Contrary to guidelines, this development shows:
• No evidence of a proper urban design analysis of the area and its city context
• No appreciation for the collective quality of the streets and spaces
• Reduction in size of Writer’s Square
• Extensive demolition.
Building heights are entirely out of context for the area:
• Block 2 is 2 storeys higher than was previously consented
• The tower block will be “up to 27 storeys”.
Questions to consider
Good design is as much about a process of collaboration, feedback, refinement, and evolution as it is about physical aesthetic. What is the evidence of how the design evolved; that it has taken into consideration the concerns of all the different stakeholders involved?
How has this proposal demonstrated a clear evolution of design ideas that address the current issues within this part of Belfast, namely dereliction and vacancy, lack of a variety of open and green spaces, lack of people living in the area, lack of stewardship of heritage and listed buildings?
Open spaces within cities are as vital as the buildings and people they support.
The scheme will result in a loss of valuable amenity space in the City Centre. The developers claim that “Writer’s Square is proposed to be extended further south” (Planning Statement, Section 3.14)
By our calculations, Writer’s Square is being reduced from 4,965m2 to 3,237m2, of which 625m2 makes up Donegall Street itself, so in reality it is being reduced to 2,612m2, or 53% of its current size. Whilst streets are an important element of public space, they should not be used to deflect from the reduction of amenity space within the City. We recognise the poor amenity value of Writer’s Square in its current state, however we would argue that this is a result of bad design, and should not justify its removal.
The project description states that a “Reconfiguration of Writers Square” is proposed. Given it is reducing in size by nearly 50%, we contend that this description is misleading.
The developer claims to be creating new ‘public spaces’ around Rosemary Street, however these are pseudo-public space that will not be in public ownership and therefore people’s rights to use it will be restricted which will impact on the cultural events that happen in this area through the year.
What’s the alternative?
The campaign to Save CQ is about more than simply objecting to redevelopment; it calls for a resurgent urbanism that celebrates and embraces city life. This new urbanism prioritises the essential infrastructure of life – bustling streets, housing, public space, employment, arts and culture, efficient public transport, walkability, childcare and schools, and a city economy that caters for local traders and small businesses as well as the large multinationals.
Good development must be appropriate to the city’s needs. It can and should meet the most audacious ambitions for what we want this city to be: distinctive, resilient, liveable, shared, and connected. The Cathedral Quarter, though in need of development, has an established place in the life of the city centre that makes it a lynchpin for delivering on those ambitions.
Save CQ for a Distinctive Belfast
The uniqueness and authenticity of a place is central to its success & attractiveness. Cathedral Quarter’s distinctive character comes from its rich built heritage, and from the independent businesses, cultural activity, & creativity that makes its home here. Development should see the significant heritage of the area as an asset. It should enhance the uniqueness of Belfast, rather than allowing it to become a generic city centre that could be anywhere.
Save CQ for a Resilient Belfast
The city’s economic activity should make it more liveable, more equal, more connected, and more shared. It should be diverse, resilient, and equitable.
Diversity of use is key to growing a resilient and inclusive economy. A retail-led scheme similar to what is on offer in other parts of the city centre leaves us vulnerable to global challenges such as the growth of online shopping. Development of Cathedral Quarter should facilitate existing independent traders & creative businesses by providing affordable flexible space for them to start up, collaborate, and grow.
Save CQ for a Liveable Belfast
Liveability is about the amenities and infrastructure that provide quality of life for everyone throughout their life. The development of the Cathedral Quarter offers an opportunity to showcase a cohesive, inclusive city. However, substantial infrastructure is needed to support a central city living environment. Development should progress the ambition to create a balanced city neighbourhood where families, couples, singles and the elderly can live in mixed communities.
Save CQ for a Shared Belfast
The Cathedral Quarter plays a significant, proactive role in facilitating shared community activities. It is at the very heart of Belfast’s shared cultural experience. Development of the area should enhance and embrace this role, and ensure the publicness & accessibility that supports shared space is maintained & expanded, and that use of the space does not become contingent on commercial activity.
Save CQ for a Connected Belfast
The Cathedral Quarter is key to restitching the city. Any development should demonstrate how it creates a balanced sustainable community and accommodates a variety of housing forms, tenures and sizes. It is essential to integrate development with surrounding inner city neighbourhoods. Any development of the area needs to enhance the active travel network into and around the city centre, to reduce dependence on private cars, and ensure people can move throughout the city as seamlessly as possible.
One of the lessons of the last half-century is how difficult it is to undo bad development. This major scheme will set the tone for a new era in city planning for Belfast, for good or for bad. It’s clear the future is urban, and it’s up to us to lay the ground for a better, more inclusive city.
We’re calling on stakeholders and elected representatives to hold developers to the highest standards of design quality, and to press for planning agreements that advance positive social outcomes.
What to do:
Become a member of the campaign
Send a letter of objection to Belfast City Council
If you are a stakeholder, seek answers from the developers to the questions we have outlined in this document.
Demand, by writing to the planning department or via elected representatives, that the council request independent reviews of the proposed designs via the Department for Communities Ministerial Advisory Group on Architecture and the Built Environment, or other similar body.
Demand independent structural review, via UAHS or other body, of buildings threatened with demolition.
Support the Cathedral Quarter community by becoming an advocate for planning agreements to offset harm and that provide for right of return for displaced tenants.