8 week date Application No. Date of meeting Report No.
01.06.2007 GR/07/0188 10.10.2007
Gads Hill School Gads Hill Place Gravesend Road Higham Kent ME3 7PA
Demolition of existing school hall and outbuildings and erection of a part one and part two storey junior school and three storey senior school; conversion of the Listed Manor House (old school building) into a Dickens Visitor Centre on lower ground and ground floor and with four self-contained one bedroom flats on first and second floors involving the erection of a new glazed entrance link; erection of a maintenance shed and laying out of a service yard; formation of a car and coach park; improvements to Crutches Lane / Gravesend Road junction and improvements to the existing vehicular access to the school along Crutches Lane.
Gads Hill School Association
Recommendation:
No recommendation is being made at this stage and this report is submitted for members’ information on the application and its progress. Members’ views regarding a site meeting are requested.
1. Site Description
Gads Hill Place is located on the southern side of Gravesend Road (A226), approximately 1 km to the west of the Wainscot By-Pass (A289).
The site comprises Gads Hill Place and its associated school buildings, including the Gardener’s Cottage, stables and coach house, which together with the gardens, playing fields and car park covers some 12 acres.
The site is located at the junction of Crutches Lane with Gravesend Road with the main access to the school buildings being achieved from the car parking areas located to the rear of the building accessed from Crutches Lane.
The site is located within the Green Belt which is also an Area of Special Landscape Significance where new built form is considered to be inappropriate development.
2. Planning History
Gads Hill Place was built in 1779 by Thomas Stevens, a former mayor of Rochester. The historic significance of the site is well documented and was occupied by Charles Dickens from 1857 until his death in 1870. Whilst living at the house many of his most important works were written there. Dickens also made significant changes to the building including the addition of the drawing room, conservatory and tunnel under the road and adding to its special historic and architectural interest. This later led to its Grade 1 Listing in 1952.
The mansion house was acquired by John Burt in 1923 and opened as a school for girls in 1924. During WWII it moved to West Peckham returning in 1945. During the 1950’s
and early 60’s the site was the subject of several applications for the provision of mobile classrooms and extensions to provide additional education related accommodation. In 1966 permission was refused for the erection of a two storey extension due to its effect on the setting of the building.
In 1983 permission was granted for the formation of two access points onto Crutches Lane together with the provision of a car parking area to provide 38 parking spaces.
In September 1993 an application for Listed Building Consent was granted in order to replace windows in the southern elevation together with the replacement of the slated roof to the conservatory with a glazed roof.
No further applications were made until 2002 when an application was made to provide a temporary classroom unit which was granted until August 2005. Later in October 2003 an application was made for a pre-fabricated single storey building to provide 5 additional classrooms, offices and store rooms. This was also granted temporary permission for a 3 year period. These temporary permissions were subsequently renewed and now run concurrent with each other until 31 August 2008.
3. Proposal
The application envisages the provision of a new school within the confines of the existing site and the conversion of the existing Grade 1 Listed mansion house into a Dickens Visitor Centre with ancillary self-contained flatted accommodation for key worker teachers employed at the school. The school currently has 340 pupils but the proposal does not envisage any increase in pupil numbers.
The school currently occupies the mansion house, its outbuildings including the gardener’s cottage, coach house and stables and number of temporary mobile classroom units around the site. The mansion house is now in need of repair and refurbishment but does not provide accommodation to meet the requirements of 21 st century education. The rooms being too small, poorly lit and ventilated; and lacking the electrical connections for modern teaching methods.
The senior school will be immediately on the Crutches Lane frontage immediately adjacent to the mansion house and will encompass the Gardener’s Cottage, Stables and coach house. The building here will be essentially three storeys in height. It will have three teaching areas, graphics room, D & T room library, admin offices and toilet accommodation on the ground floor. The first floor will comprise 6 teaching areas, admin. office and further toilets whilst the second floor will have two science rooms, science prep. room, an ITC suite with ITC office and locker area.
The existing stable block and Gardener’s cottage will be retained and refurbished to provide staff room accommodation and caretakers store respectively.
The junior accommodation will be within a separate self contained two storey block located further down the Crutches Lane frontage adjacent to the existing school entrance access. The accommodation will comprise one nursery classroom, two infant classrooms, one reception classroom, one remove room, three junior classrooms, an admin/reception room, wc facilities together with shared accommodation comprising a sports hall/gymnasium, male & female changing facilities, school hall, dining room and kitchen/servery on the ground floor.
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The first floor will comprise a science classroom with preparation area, a music room with two practice rooms, headmaster’s room, and three admin. offices. There will also be male and female toilet facilities and viewing gallery.
The proposal also envisages the provision of a new car park for 100 vehicles which will be dual purpose for staff and parents together with visitors to the mansion house centre. It will also have the ability to accommodate coaches.
The proposal acknowledges that the principles of this development are considered to be inappropriate given its Green Belt location but the refurbishment of the Grade 1 mansion house, its conversion to a Dickens Visitor Centre and its long term maintenance and preservation are cited as ‘enabling development’ which justify overriding of long established Green Belt and countryside protection policies.
4. Development Plan
The application was considered on the basis of the Development Plans appertaining at the time. The Kent and Medway Structure Plan has now been formally adopted in July 2006.
In considering whether planning permission should be granted for any development, it is necessary first to consider s. 54A of the Town and Country Planning Act 1990. This provision requires that, in making any relevant determination under the Act, the determination must be made in accordance with the development plan unless material considerations indicate otherwise.
The Development Plans for the area in which the appeal site is situated are contained in the Kent and Medway Structure Plan July 2006 (which superseded the Third Revision of the Kent Structure Plan), the Gravesham Local Plan 1st Review 1994 and Gravesham Local Plan Second Review (Deposit Version) 2000.
The Kent & Medway Structure Plan Deposit Plan
The Kent & Medway Structure Plan was placed on deposit for the first time with a period of public consultation which ran from 15 September to 10 November 2003. Following the consultation period the Plan was modified and following its Local Plan inquiry was formally adopted as the Kent & Medway Structure Plan (July 2006) and the relevant policies are as follows:
Policy SS2
The Metropolitan Green Belt will extend about 15 miles from the edge of the built up area of Greater London, i.e. to the east of Gravesend, to the west of Rochester and West Malling, and to the east of Wateringbury and Nettlestead. It will also extend to the west of Paddock Wood and east of Tunbridge Wells. The detailed boundaries are established through local plans/development documents.
The boundary of the Green Belt at Dartford on the north side of the A2 is amended to exclude Eastern Quarry and St. Clements Valley from the Green Belt. New boundaries are being defined through the Dartford Local Development Framework. Within Green Belt there is a general presumption against inappropriate development. New building should be in accord with the provisions of PPG2 and Annex B of PPG3.
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Policy SS8
Housing development in the countryside will be subject to policy HP5.
Non-residential development in rural Kent other than at rural settlements should:
(i) be demonstrated to be necessary to agriculture, forestry, the winning of minerals, or other land uses for which a rural location is essential; or (ii) be the re-use, adaptation or redevelopment of an existing rural building or institution, where the change is acceptable on environmental, traffic, and other planning grounds; or (iii) provide a public facility for which a rural location is justified; or (iv) allow for business development in accordance with policy EP7(ii) or the business diversification of an existing farm in accordance with policy EP8.
Policy EN1
The countryside will be protected, conserved and enhanced for its own sake. This is important for the social, economic and environmental wellbeing of Kent. Development in the countryside should seek to maintain or enhance it. Development which will adversely affect the countryside will not be permitted unless there is an overriding need for it which outweighs the requirements to protect the countryside. Development so permitted should include appropriate mitigation and/or compensation.
Policy EN3
Kent’s landscape and wildlife habitats will be protected, conserved and enhanced. Development will not be permitted if it would lead to the loss of features or habitats which are of landscape, historic, wildlife or geological importance, or are of an unspoilt quality free from urban intrusion unless there is a need for development which outweighs these countryside considerations.
Where a need for development in the countryside is justified important features and characteristics will be retained. Proposals should reflect the need for conservation, reinforcement, restoration or creation of countryside character and provide for the appropriate management of important features and the wider landscape.
Where formal assessments of landscape character and quality identify landscapes of local significance, they should be designated in Local Development Documents.
Policy QL 1
(i) All development should be well designed and be of high quality. Developments, individually or taken together, should respond positively to the scale, layout, pattern and character of their local surroundings. Development which would be detrimental to the built environment, amenity, functioning and character of settlements or the countryside will be permitted. Existing built environment of high quality and character will be protected and enhanced. Innovative design will be encouraged where appropriate.
(ii) Local authorities and others will:
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(a) ensure that the distinctive character of towns and villages is conserved and improved
(b) apply the principles of the Kent Design Guide when determining planning application and preparing site-specific development guidance
(c) require, where appropriate, that a design statement accompanies proposals for development with accurate illustrations of the development in its surroundings
(d) develop design policies for their area based on an analysis of the quality, character and significance of the surrounding built and natural environment. This will include:
(i) identification of areas where local design policies will apply to take account of their special character;
(ii) provision of design guidance within development briefs and master plans for major development sites and areas of change.
(iii) The design of development should:
(a) consider the needs of all sections of the community (b) provide for a healthy, safe and secure environment (c) enhance the public realm (d) protect the amenity of residents (e) incorporate sustainable construction techniques as detailed in Policy NR1.
Policy QL8:
Listed buildings will be preserved and their architectural and historic integrity and the character of their settings will be protected and enhanced. Development which will adversely affect them will not be permitted. Changes of use will be permitted where these will provide the best reasonable means of conserving the character, appearance, fabric, integrity and setting of listed buildings.
Policy QL10:
Development for the purposes of protecting a heritage asset will be permitted only where this is the sole means of protecting and securing the long-term future of the asset. The scale of development shall not exceed that required to achieve this objective and be in a form that minimises dis-benefits.
Policy TP3
Local Planning Authorities should ensure that development sites are well served by public transport, walking and cycling, or will be made so as a result of the development. Travel plans should be established for larger developments that generate significant demand for travel to promote the use of these means of transport.
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Developments likely to generate a larger number of trips should be located where there is either a good choice of transport already available or where a good choice can be provided in a manner acceptable to the Local Transport Authority.
Gravesham Local Plan First Review
The Gravesham Local Plan First Review was adopted in November 1994. The relevant policies are as follows:
Policy GB1
Green Belt policies, as set out in the Approved Kent Structure Plan will be applied in the areas indicated on the Proposals Map.
Policy GB2
There will be a strong presumption against permitting new development in areas subject to Green Belt policies, other than in accordance with Approved Kent Structure Plan Policy MGB2.
Policy TC0:
The Borough Council will give priority to conserving and enhancing the built environment in both the urban area and the countryside. Particular importance will be attached:
(i) The design of new development (ii) The safeguarding and enhancing of conservation areas (iii) Environmental improvement schemes (iv) The preparation of a landscape strategy for the Borough
Policy TC1:
The Borough Council will not normally permit proposals for the new development which cause harm to interests of acknowledged importance. Applications will be considered in accordance with the following design principles:
(i) The scale and massing of the buildings should normally be in keeping with their surroundings
(ii) The design of new developments should accord with the principles of the Kent Design Guide and in the case of residential development, with Housing Policies H2 ad H3 of this plan.
(iii) The design of any alteration or extension shall respect the character and appearance of the existing building and safeguard the privacy and amenity of adjoining residents (iv) Materials used should be of good quality and sympathetic to the area concerned.
Policy TC2:
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The Borough Council will adopt the following approach to applications affecting listed buildings;
(i) Proposals which involve the demolition of listed buildings will not be granted consent unless the applicant is able to demonstrate substantial and overriding reasons why such consent should be forthcoming. In those few cases where the Borough Council is satisfied that there is no alternative but to grant consent for such demolition, all available means will be used to secure early and appropriate redevelopment.
(ii) In the case of applications for development involving alterations or extensions to listed buildings or affecting the setting of listed buildings, the primary consideration of the Borough Council will be the maintenance of the integrity of the original listed building. Proposals will also need to be sympathetic to the listed building in terms of massing, scale, appearance and materials.
(iii) Applications for the change of use of listed buildings will be considered on their merits, in relation to the land use policies set out in this Written Statement. A major consideration will be whether the character or appearance of the listed building will suffer as a result.
Policy TC4:
The Borough Council will, within the limits of available resources, continue to carry out studies and make available funds to assist:
(i) In the maintenance and improvement of listed buildings
(ii) In the environmental improvement of the Borough and particularly of its conservation areas
Policy C0
The Borough Council will give priority to conserving and enhancing the character and quality of the countryside. The development of ‘fresh land’ will not normally be permitted in the countryside, most of which is designated Green Belt. Emphasise will be placed on the redevelopment of land and the husbanding of undeveloped land in the urban area for residential and employment uses in order to reduce pressures for development in the countryside.
Policy C5:
In the following areas of local landscape significance delineated on the Proposals Map, development which will adversely affect the landscape quality of the area will be resisted, unless it can be demonstrated that there is no other suitable location:
(i) The North Kent Marshes (east of Denton as far as the eastern boundary of the Borough) (ii) Ebbsfleet Valley, Northfleet (iii) The dry valley feature, west of Wrotham Road, Gravesend (iv) Mid Kent Golf Course, Gravesend
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(v) The dry valley feature south of the village of Higham Upshire (between the ridge carrying Hermitage Road and the Dillywood Lane area)
Policy C19:
Non-agricultural pursuits will be permitted in the open countryside where it can be demonstrated that there will be no damage to features of acknowledged importance, including areas subject to countryside protection policies, the local residential environment and traffic safety. Environmental enhancement will be encouraged.
Policy P3
The Borough Council will expect development to make provision for vehicle parking, in accordance with the Kent County Council Vehicle Parking Standards, as interpreted by Gravesham Borough Council, unless justified as an exception. All vehicle parking provision should normally be made on the development site. In the case of proposals for development in Class B1, as defined in the Town and Country Planning (Use Classes) Order 1987, the Borough Council will expect car parking provision to be made at the standard for offices and will also require lorry parking and manoeuvring areas to be provided, unless the applicant is willing to enter into an agreement to restrict the uses to which the permission relates
Policy T1
The Local Planning and Highway Authorities will consider the impact on the transport system and on the environment of traffic generated by new development and will wish to ensure that all proposed developments are adequately served by the highway network identified on the Proposals Map.
Policy T2
The Local Planning and Highway Authorities will seek to channel all traffic travelling through Gravesham on to the primary road network and to channel traffic between and within residential, industrial and principal business districts of the Borough onto the district distributors.
Policy T3
The Local Planning and Highway Authorities will not normally permit any proposed development that generates significant volumes of commercial vehicle traffic, if it is not well related to the primary and district distributor network.
Policy T4
The Local Planning and Highway Authorities will not normally permit any proposed development outside the confines of the built up area that generates significant vehicular or pedestrian traffic.
Policy T5
The formation of new accesses or the intensification of use of existing accesses to the roads forming the highway network shown on the Proposals Map, will not normally be permitted, except where no danger would arise and where a properly
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formed access can be created in a location and to a standard acceptable to the Local Planning and Highway Authorities.
Gravesham Local Plan 2nd Review (Deposit Version)
Gravesham Local Plan 2nd Review (Deposit Version) was adopted for the purposes of development control on 8 March 2000. The first period for public consultation ran from 8 June to 21 July 2000. In view of the recent changes in government policy, the Borough Council has resolved to transfer work from the Local Plan Second Review to the preparation of a Local Development Framework (LDF). Progress has been made on the preparation of the LDF but until it is ready for deposit the Gravesham Local Plan 2nd Review (Deposit Draft) remains a material consideration in the determination of planning applications and planning and enforcement appeals. The relevant policies of the Gravesham Local Plan 2nd Review (Deposit Version) are as follows:
Policy RA1
Green Belt policies, as set out in the Development Plan, will be applied in the areas indicated on the Proposals Map.
Policy RA2
Within the Green Belt inappropriate development will not be permitted. The construction of new buildings is inappropriate and planning permission will not be granted unless it is for the following purposes:
i. agriculture or forestry;
ii. essential facilities for outdoor sport or recreation, for cemeteries, or for other uses of land which preserve the openness of the Green Belt and do not conflict with its purposes;
iii. limited extension, alteration or replacement of existing dwellings provided it is in accordance with Policies RA5 and RA6;
iv. limited infilling in existing villages, as identified in Policy RA9; or
v. redevelopment of major existing developed sites as specified in Policy RA7 (Hoo Junction).
Policy BE1 Townscape, Conservation and Design
The Borough Council will give priority to conserving and enhancing the built environment in both the urban and rural areas. Particular importance will be attached to:-
i. the design of new development; ii. the safeguarding and enhancing of conservation areas, including the protection of buildings, spaces and trees which contribute to the area’s special character and appearance; iii. environmental improvement schemes; and iv. safeguarding and enhancing the historic landscape. Policy BE7 Statutorily Listed Buildings REPORT NO. 5 9
Proposals will not be permitted for the following:-
i. the demolition or partial demolition of a listed building, except the removal of later modern additions which are of no historic or architectural interest, where there is no overall damage to the listed building or its setting and where no harm is caused to the setting of any other listed building, the character of a street-scene or the character of a conservation area. In those few cases where the Borough Council is satisfied that there is no alternative but to grant consent for demolition, all available means will be used to secure early and appropriate redevelopment of the site; ii. the internal or external alteration or extension or change of use of a listed building, if this would in any way adversely affect its architectural and historic interest, character, or setting. The primary consideration will be the maintenance of the integrity of the original listed building. Proposals will be expected to be sympathetic to the listed building in terms of massing, scale, appearance and materials. Applications for the change of use of listed buildings will be considered on their merits, in relation to the land use policies set out in this Local Plan Review. A major consideration will be whether the character or appearance of the listed building will suffer as a result; iii. the erection of a new building or other structure, or the use of land, where this would adversely affect the character or setting of a listed building; iv. the installation of UPVC, aluminium, or any other unsympathetic doors or windows, satellite or other antennae, advertisements, security shutters or other fitments, on a listed building, where they would adversely affect its architectural or historic interest, or its character; v. the removal of natural roofing materials from the roof of a listed building, and their replacement with alternative modern materials; or vi. the introduction of architectural features or materials removed and imported from another building, unless information is produced on the source of the feature or material.
The Borough Council will act to halt the further decay of listed buildings at risk and to encourage their sympathetic repair and re-use.
In cases where the demolition or partial demolition of a listed building is permitted, the proper recording of the building will be required before any changes take place.
Proposals for alterations or changes of use to listed buildings will not be permitted unless they are accompanied by sufficient information to enable a full and proper consideration of their effect. This will always include full survey drawings and, in some cases, photographs of the affected areas. In most cases, applications must be supported by a full justification for the works and further information on the economics of the proposals may be required.
Policy BE8 Buildings of Local Architectural or Historic Interest
Proposals to demolish, alter, or extend a building of local architectural or historic interest (in as much as they apply to the exterior of the building) will be assessed in the light of Policy BE7. The Borough Council will, in appropriate cases, protect
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buildings of local architectural or historic interest by the use of Article 4 Directions.
Policy BE12 Design of New Development, Extensions and Alterations
A high standard of layout, design and materials will be expected for all new development. The Borough Council will not normally permit proposals for new developments which cause harm to interests of acknowledged importance. Applications will be considered in accordance with the following design principles:-
i. the scale, massing, height, and proportions of the building should normally be in keeping with their surroundings; ii. the design of new developments should accord with the principles of the Kent Design Guide and, in the case of residential development, with Policies H3, H4 and H5 of this Plan and with the Borough Council's Residential Layout Guidelines, unless this can be shown to contradict (i) above (for high, medium and low density developments); iii. the design of any alteration or extension shall respect the character and appearance of the existing building and should normally be subservient to it in terms of scale, massing and height. The proposal should not adversely affect the privacy and amenity of adjoining residents or have a detrimental effect on the street-scene. In pursuance of this policy the following criteria will apply:- a. extensions should not cause undue overshadowing of neighbouring property and should allow adequate light and ventilation to existing habitable rooms within the building; single storey extensions should be designed so as to fall within a 45 degree angle from the centre of the nearest ground floor window of a habitable room or the kitchen of a neighbouring property. In the case of two storey extensions, the 45 degree angle will be taken from the closest quarter point of the nearest ground floor window of a habitable room or kitchen; b. side extensions may be added to detached or semi-detached dwellings where space is available unless this will cause a "terracing" effect. A minimum distance of 1 metre should normally be maintained from the boundary and any part of the extension above single storey level; c. planning permission will not be granted for flat-roofed single storey extensions, unless the proposed extension would not be generally visible from a public place. Planning permission will not normally be granted for flat-roofed extensions at first floor level or above, unless the main roof of the building is also flat or the extension is to an historic building and is consistent with the style, age and character of the main building; and d. planning permission will not normally be granted for loft conversions requiring dormer extensions which are large in proportion to the existing roof. Planning applications for extensions in roof spaces which front the highway will normally be refused where the proposed structure would damage the character of the existing building or the street-scene. iv. materials used should be of good quality, sympathetic to the area and, wherever possible, should be from sustainable sources; v. planning applications for new buildings or extensions should demonstrate the use of sustainable design principles, consistent with an acceptable standard of external appearance, and shall indicate how the privacy and amenity of future REPORT NO. 5 11
occupiers and neighbouring residents is to be respected in terms of both overlooking and loss of daylight/sunlight; vi. details of landscaping shall be submitted with the planning application, and should be of a high quality, incorporating native tree species wherever possible. Existing trees of amenity value should be retained; vii. adequate access should be provided to and into the building and areas accessible to the general public for wheelchair users, other people with disabilities, elderly people and those with young children; and viii. the proposal should have regard to Circular 5/94 (Planning Out Crime) or other subsequent Government advice on this subject.
Policy BE17 Enabling Development
There will be a general presumption against enabling development which affects the heritage asset 1 and which does not meet all of the following criteria:-
i. the enabling development will not materially detract from the archaeological, architectural, historic or landscape interest of the asset, or materially harm its setting; ii. the proposal avoids detrimental fragmentation of management of the heritage asset; iii. the enabling development will secure the long term future of the heritage asset, and, where applicable, its continued use for a sympathetic purpose; iv. the problem arises from the inherent needs of the heritage asset, rather than the circumstances of the present owner or the purchase price paid; v. financial assistance is not available from any other source; vi. it is demonstrated that the amount of enabling development is the minimum necessary to secure the future of the heritage asset, and that its form minimises disbenefits; and vii. the value or benefit of the survival or enhancement of the heritage asset outweighs the long-term cost to the community (that is the disbenefits) of providing the enabling development.
If the above criteria are satisfied the Borough Council will only grant planning permission if:-
viii. the planning application is in full rather than outline form and the impact of the development is precisely defined at the outset; ix. the achievement of the heritage objective is securely and enforceably linked to it, for example by a Planning Obligation; and x. the heritage asset is repaired to an agreed standard, or the funds to do so made available as early as possible and at least before completion.
The Borough Council will closely monitor implementation and, if necessary, act promptly to ensure a satisfactory outcome.
Footnote: 1 The heritage asset for the purpose of this policy is defined as any component of the historic environment, including scheduled monuments and other remains,
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historic buildings both statutorily listed or of more local significance, conservation areas and registered historic parks and gardens.
Policy NE3 Areas of Local Landscape Importance
Development within Areas of Local Landscape Importance shown on the Proposals Map will only be allowed if it respects the local character and particular landscape function of the area. Where development is allowed, its impacts on the landscape should be minimised.
Policy NE6 Trees and Landscaping within New Developments
Development on sites containing or directly adjacent to trees or hedgerows of amenity, wildlife or landscape value will only be allowed if these landscape features are protected and retained in the long term. All proposals for new development must incorporate new landscaping as an integral part of the scheme. All landscaping proposals shall accord with the principles contained in the Kent Design Guide.
Policy LT17 New Tourist Facilities and Attractions
Proposals for new tourist facilities and attractions within the following areas will be allowed where sufficient parking can be provided and where there is no unacceptable effect on residential amenity:
i. the Town Centre;
ii. around the Canal Basin itself;
iii. the Ebbsfleet Valley, close to public transport routes; and
iv. within the built confines of the villages (see Policy RA9).
Proposals for small-scale tourist facilities and attractions in other areas will be allowed where they meet the above criteria and do not contravene other policies in this Local Plan Review.
Policy T1
In considering development proposals, the Local Planning and Highway Authorities will consider the impact of the generated travel demand on the transport system as a whole and on the environment, and in particular, whether the proposed development:-
i. is appropriately related to the public transport network, or can be made so by the applicant, as the primary requirement; and ii. can be adequately accessed from the primary and district distributor network identified on the Proposals Map, as the secondary requirement.
Contributions towards the improvement of public transport provision and highways will be required, depending on the scale, location and local circumstances of the proposal. Major developments will be required to provide Travel Assessments, including a Parking Strategy and a Green Travel Plan.
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Policy T12
The formation of new accesses or the intensification of the use of existing accesses to the roads forming the principal highway and public transport network shown on the Proposals Map will not normally be permitted. However, exceptions may be made where it can be shown that:-
i. the flow of public transport and other traffic will not be impeded; ii. no danger would arise in highway safety terms; and iii. a properly-formed access can be created, in a location and to a standard acceptable to the Local Planning and Highway Authorities.
The planning application must be considered against these very clear restrictive policies and site constraints, together with any Human Rights issues or very special circumstances arising.
Policy T16 Car Parking Standards
Provision will be made for vehicle parking in accordance with the Kent County Council Vehicle Parking Standards, as interpreted by the Borough Council. Lower standards for non-residential development will be expected if the development is located at or adjacent to a transport node.
5. Reason for Report
The proposal is a major application effecting the character and appearance of the setting of a Grade 1 Listed Building involving new build development within the Green Belt and may be subject to call-in procedures by the DCLG as a departure from the adopted Local Plan.
6. Consultations and Publicity:
Formal consultation of statutory consulltees commenced at an early stage following the deposit of the application. It was felt particularly important to get feedback at an early stage from both English Heritage and the council’s own Conservation Officer in terms of the ‘enabling development’, the overall Conservation Plan and its implementation, and the feasibility study in respect to the proposed Visitor Centre.
English Heritage:
A preliminary response was received in July 2007 which acknowledged that the was always likely to be a conflict between development and conservation on this sensitive site but accepted that the scheme had been carefully drawn so as to minimise impacts on the setting of the Grade 1 listed house and to provide solutions to a range of direct impacts the conservation of the house. They therefore generally supported the proposal subject to the following:
1. Conditions should be imposed to ensure the agreement of details of all joinery, rainwater goods, materials, hard and soft landscaping, and works of making good to the listed building and internal detailing to the main house.
2. Details of the style of glazing to be used adjacent to the house would need to be agreed, in particular the new entrance building and mediatheque.
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3. The location of the maintenance shed
4. Expressing concerns about the location of the tennis court, although acknowledging that they already exist.
5. Ensuring that the linkage between the new school buildings and the impact on the listed house in terms of the justification for it are maintained.
The recommendation being that the application should be determined in accordance with national and local policy guidance and on the basis of the Council’s specialist conservation advice.
The Council’s Conservation Officer had concerns over the nature of this response and felt that a more detailed response was needed in regard to EH ‘Guidance on Enabling Development and Protection of Heritage Assets’. Further comments were requested.
The following additional comments were received on 3 September 2007:-
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In conclusion they felt that in terms of the ‘enabling development’ the benefits of the current proposal outweigh the dis-benefits. They do however acknowledge the proposal as a complex application but considers that a case for the new school could be made but, given the need explicitly in planning policy to preserve the setting of the Grade 1 listed building and to minimize development within the Green Belt, it is important that the supporting documentation carries sufficient weight. This additional information and documentation is itemised above.
These observations, along with those of the Council’s Conservation Officer were forwarded to the applicants agent for consideration. REPORT NO. 5 18
GBC Conservation Officer
The main justification put forward for the construction of the new school is the need for the preservation and enhancement of the Grade I listed building and a recognition that the existing school use is having an adverse impact on its character and appearance. In other words the application is submitted as ‘enabling development’. Another justification for this enabling development is a proposal to convert at least part of the house to a visitor centre, to act as a tourist attraction and an educational resource.
Although a competent appraisal of the existing building has been submitted in the form of a Conservation Plan I am not aware that this has been taken forward into a Management Plan, which I would have considered to be an essential document whether or not the school stays as it is.
Although a feasibility study has been submitted this does not necessarily incorporate a full business plan for the school. We know, for instance, that the school will rely to some extent upon money raised through an appeal and it is mentioned in the feasibility study that the priority for this will be for the new school building programme.
I have asked our External Funding Officer to look at the feasibility reports. He has a number of comments to make:-
The estimate of costs for the renovation works is too low. He estimates something more in the region of 1 to 1.5 million pounds for the renovation of the house and gardens and considers that to raise this sum outside the lottery heritage fund would be virtually impossible The on-going maintenance costs will be high. Fixed opening hours are needed. The flats are not a good idea in association with a tourist facility He thinks that the whole house should be opened up to visitors Estimated visitor figures seem high (19,480 for the first year) when a venue such as the Lullingstone World Garden is aiming for 20,000 visitors in its third year. Considers that it might be better to sell the house to the National Trust after the new school had been built and access problems resolved.
The feasibility study is not sufficiently detailed and although it includes a letter from the headmaster about finance, there is no figure given and there is also no copy letter from the bank that is referred to in that letter.
English Heritage’s policy for enabling development states that there should be a general presumption against enabling development which does not meet all of 7 criteria.
The first is that the development will not materially detract from the archaeological, architectural, historic or landscape interest of the asset, or materially harm its setting.
Although a great deal has been done in terms of building and landscaping design to accommodate the new school, a proposal of this scale must inevitably harm the asset, particularly where its association with the garden is such an important part of the character, history and interest of the house.
The second criterion is that the proposal avoids detrimental fragmentation of management of the heritage asset. This needs to be confirmed
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Thirdly, the enabling development should secure the long term future of the heritage asset, and where applicable, its continued use for a sympathetic purpose. Although I would fully support the use as a visitor attraction, I am concerned about the detrimental impact that the conversion of the upper floor into separate flats will have upon the character and appearance of the listed building. More information about the implications in terms of changes to the building in order to comply with the building regulations etc is needed in this respect.
The fourth criterion is that the problem should arise from the inherent needs of the heritage asset, rather than the circumstances of the present owner or the purchase price paid. The arguments put forward in this respect are fairly convincing, particularly as there is no intention to increase the school roll.
The fifth criterion is that financial assistance is not available from any other source. This is not particularly relevant to this case.
The sixth criterion is that it should be demonstrated that the amount of enabling development is the minimum necessary to secure the future of the heritage asset, and that its form minimises disbenefits. Again, I am not entirely convinced that this is the case.
Lastly, the value or benefit of the survival or enhancement of the heritage asset outweighs the long-term cost to the community (i.e. the disbenefits) of providing the enabling development. Again, I am not entirely convinced.
It will, of course, be for English Heritage to state whether they consider that the enabling development is justified in the light of this policy.
English Heritage also considers that, even if these criteria are satisfied, planning permission should only be granted if the impact of the development is precisely defined at the outset. This has been done by the submission of a full planning application, although my concerns about the lack of full information about the conversion works to the house are relevant here.
The achievement of the heritage objective should also be securely and enforcably linked to it, bearing in mind the guidance in Circular 1/97 (Planning Obligations)
Also, the heritage asset should be repaired to an agreed standard, or the funds to do so made available, as early as possible in the course of the enabling development, ideally at the outset and certainly before completion or occupation. Clarification is needed in this respect.
EH also request that the planning authority closely monitors implementation, if necessary acting promptly to ensure a satisfactory outcome.
Turning to the new development itself, I have particular concerns about the height and complexity of the proposed senior school building. Even though it is some distance from the house, there are some quite jarring elements, particularly on the northern elevation, that will, in my view, detract from the classical elegance of the main house. The small buildings, such as the stables and gardeners cottage, (also listed by virtue of their location within the curtilage of the main listed building) have been retained but are not well incorporated into the layout. The stable building appears to have no use allocated to it at all. Here, these buildings are swamped by the new development; again, with the
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introduction of modern elements such as the square timber boarded panels and square windows that really have no place in this intimate rural setting.
Kent Highway Services
The highway aspects of the potential redevelopment of Gads Hill School and associated conversion of the existing school building into a Dickens Visitor Centre have been discussed in some detail by the applicant (Gads Hill School Association and their representatives), the Highway Authority (KCC) and the Planning Authority (GBC) over a considerable length of time. The off-site and on-site highway improvement works included within the above planning submission reflect the results of these discussions and attempt to accommodate a majority of the requirements of all parties involved.
The principle of this proposal has been conditionally supported by KHS and there follows a summary of the required Kent Highway Services general conditions as outlined during negotiations, plus a concluding summary of how these issues have been addressed within the proposal:
General KHS conditions outlined during negotiations
1, It is understood that school pupil and staffing levels will remain at their current levels and that additional vehicle movements will relate only to the proposed Dickens Visitor Centre.
2, Significant on-site improvements to both pedestrian and vehicular movements must be secured in terms of a) safety, b) existing vehicle/pedestrian conflicts, c) on-site circulation and d) entry from and exit onto the public highway.
3, Specific off-site highway improvements must be secured to overcome a) significantly sub-standard sight-line visibility at the junction of Crutches Lane and the A226, b) the lack of pedestrian facilities serving the site within Crutches Lane and linking it with the footway network to the north and c) the lack of available sight-line visibility for vehicles exiting the site onto the public highway within Crutches Lane.
4, The principle of the shared parking facility is acceptable on the basis that the opening hours of the Dickens Visitor Centre will be restricted to avoid potential conflict between both parking demand and peak hour vehicle movements associated with the school site.
5, The application should be supported by the introduction of a speed limit reduction from 40mph to 30mph on the A226 Rochester Road.
Concluding KHS summary of proposals:
The general concepts as outlined above have been included within the applicant’s proposals with the apparent exception of the potential introduction of a speed limit reduction on the A226. Whilst the principle of the proposed off-site highway works are therefore supported, it is also strongly recommended that the applicant makes the appropriate arrangements for an independent Stage 1 Safety Audit to be carried out to accompany the proposed works within the public highway. This audit can be carried out by any accredited independent safety auditor but it should be noted that in order to speed up any future detailed approvals, it can be advantageous to employ a KCC approved auditor who is able to also carry out the detailed Stage 2 Safety Audit at a later date.
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With regard to the omission of any proposal to secure a reduction in speed limit on the A226, the following should be noted:
There is concern that whilst the applicant has gone some way toward justifying the current speed limit by way of a traffic speed survey of the existing road indicating a mean speed that appears to justify the proposed 90m sight line splay, the results of this survey also highlight a fluctuation in speed relating to the time of day and number of movements, with the lower range speeds being associated with peak hour movements. The proposals will result in significant percentage increases in vehicle movements at the junction during daytime off-peak hours when mean speeds are higher. In addition, the proposed alignment of the road and specifically, the improved junction visibility could also potentially encourage higher mean vehicle speeds.
Whilst it is acknowledged that existing sight lines are very sub-standard, it should also be considered that the appropriate sight-line measurement for a new minor access road onto an A class primary distributor road would be either 4.5m x 120m for a 40mph speed limit or 4.5m x 70m for a 30mph speed limit. The proposed arrangement is therefore sub-standard when compared to current criteria, even for a 30mph speed limit environment, and this is likely to be highlighted within any safety audit which is carried out. Whilst it is accepted that the process required to alter the speed limit includes a consultation and decision making process, the results of which are outside of the developers control, it is strongly recommended that a speed limit reduction scheme at least be incorporated into the proposals at this stage, including any appropriate accompanying measures, so that there is an audited scheme in place.
With regard to the proposed alterations to Crutches Lane, these appear to take into account the issues raised during negotiation and, subject to an accompanying Stage 1 Safety Audit and an appropriate planning condition to secure the visibility splays at the access, there is no principle objection. It is however noted that no indication of any required highway drainage measures have yet been included and it is likely that any detailed Section 278 scheme will need to cover this issue.
Finally, with regard to the on-site proposals, KHS are happy that the scheme caters for the proposed usage of the site in terms of both parking provision and vehicle movements, providing that 1) the appropriate planning condition limiting the operating hours of the visitor centre from 10am to 2pm during school days is included and 2) staffing levels and pupil numbers are to remain the same within the redeveloped school site.
Head of Regulatory Services:
Has raised no objections to the proposal subject to the following comments and that the hours of opening of the Visitors Centre being controlled by condition:-
Lighting
A written lighting report shall be submitted to the LPA outlining the method and means of lighting the external areas of the premises including the car parking area so as to minimise disturbance to nearby sensitive premises. The premise shall not be used until approval of the report is received from the LPA and all measures included in the approved plan have been put into practice.
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Impact Assessment for Noise
As assessment shall be carried out of the impact of the proposed development on the adjacent residential area, with respect to noise arising from the site, particularly the school classrooms. From the findings of this, a scheme detailing noise attenuation provided by the construction, including design and installation of windows shall be submitted to and approved in writing by the LPA prior to the commencement of any works on site. Reference shall be made to Planning Policy Guidance 24 – Planning & Noise when carrying out this assessment.
Control of Noise emitted from premises
The rating level of noise emitted from any plant and equipment associated with this development (other than from the exit or entry of road vehicles) shall not exceed the background noise level by more than 3dB. The noise levels shall be determined at the points nearest to adjacent residential premises. The measurements and assessments shall be made according to BS4142:1997.
Commercial Refuse Arrangements
Storage facilities shall be of sufficient capacity having regard to the quantity of waste produced and the frequency of waste collection. All waste shall be removed from the site on a regular basis by a licensed waste carrier and disposed of at a licensed waste disposal site.
Commercial Refuse Arrangements – Advisory Notes
Compliance with the Environmental Protection Act 1990 Duty of Care is essential. Advice on Solid Waste Management can be obtained from Waste Services
Works of Construction
Please add code of construction practice informative.
Higham Parish Council:
Throughout the consultation process and informal meetings with the school, the Parish Council have consistently emphasised its preferred siting is that shown in Option B of the Feasibility Study dated October 2005. The application proposal broadly adopts Option D shown in the same document. On the basis of this the Parish have submitted the following observations:-
HIGHAM PARISH COUNCIL
GADS HILL SCHOOL PLANNING APPLICATIONS PLANS:- GR07/10188 and 10189
We have considered the above referred to plans and have the following comments to make.
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We fully accept the need to cease using the Mansion as a school and thus if the school is to remain here, a new purpose built building will have to be accommodated on site.
We generally agree with the proposals to change the Mansion into a Visitors Centre but do have concerns on the planned period of opening each day. In the Design and Access Statement, it is proposed that the Visitors Centre be open from 10 a.m. to 2 p.m. daily, whereas elsewhere it proposes 10:30 a.m. to 3 p.m. The initial proposal is preferable as the latter closing time, shown elsewhere, could mean that the visiting public would be exiting the building and the car park at the same time as children from the Junior School would be walking towards the same car park to meet their parents, who would also be vying for space to park their cars at this time.
We have considered the four options for siting of the new buildings and feel that Option D is unacceptable both from its proximity to the Mansion, Carriage Room, Gardner’s Cottage and Stables, and to Providence Cottages, whose occupants would look out onto a three storey building just a few metres away across the lane. Of the options we feel Option B to be the best compromise, as it keeps the majority of the school away from Providence Cottages and the Mansion.
As the only building plans submitted are for Option D, we have not considered them. Option B does provide the opportunity to group the buildings into one area of the site and not to straggle them along Crutches Lane.
The recommendations for the improvement of the junction of Crutches Lane and Gravesend Road (A226) would seem beneficial but we do have concerns on the suitability of Crutches Lane for visiting coaches.
We do not agree with the provision of employee flats in the Mansion, the alterations required would have a significant detrimental impact on the building. It might be possible to locate them elsewhere, possibly on site.
We would want to see guarantees of no increase in the pupil numbers from the current 340 plus 30 pre-school children. We are concerned that the overall school buildings are increasing in size by over 100% to accommodate the same school roll as now. We understand the need to increase the size of classrooms to accommodate the current class sizes but each room should not be larger than the current DfES recommended size for the current class population. We would require clarification on the plans to increase the number of classrooms from 6 to 10.
We should also expect a guarantee that the temporary block of classrooms will be removed once the new building is occupied.
Publicity:
To date no publicity letters have been sent to local residents and occupiers. The proposal has been advertised by way of notice in the local press in respect to both the planning application and Listed Building application. These have described the development as having affect on the character and appearance of the listed Gads Hill Place and as a departure from the adopted Local Plan involving major development within the Green Belt. This has resulted in two letters of objection:
Dickens’ Country Protection Society
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Object on the grounds that the proposal is not in keeping with the existing buildings. In particular they object to the three storey senior school buildings and the glass walkway being clearly seen from Crutches Lane
Mr. M. Lockyer – 23 Dombey Close
Objects on the grounds that the extension would spoil the character of the house and surrounding area, will increase noise and congestion due to insufficient parking space and unnecessary of 4 flats into the House
Observations have also been made by Mrs Joan Dicks of the Dickens Fellowship with concerns about the protection of the listed building and requesting that the Fellowship be fully consulted when full consultation is undertaken.
7. Director (Regeneration and Regulation) comments
No recommendation is being put forward at this stage as officers are still in negotiation with the applicants and their agents to overcome conservation concerns about the proposal. These are included in the EH and Conservation Officer comments outlined in the main body of the Report. These essentially relate to the submission of a detailed Management Plan for the future maintenance and funding of the proposed Visitor Centre and Financial Appraisal relating to fund raising. Specific design issues are raised by both about the height and elevation treatment of the senior school and these will need to be addressed
The applicant’s agents were advised of all the comments received and have responded as follows:
I have to register my client’s concern at the length of time it has taken to resolve outstanding issues with the applications. My hope is now that we have the comments from Richard Morrice (EH), we will be able to make meaningful progress. The key to that will be meeting yourself and other Council and County Council Offices involved, and I look forward to a meeting being arranged very soon.
I want through this letter to explain what we have been doing to address the concerns and comments that have been made during the consultation on the applications. The matters referred to below are not listed in any particular priority:-
1. The need to prove that the visitor centre is achievable –
We have submitted documents setting out the business case which have attracted considerable comment. My understanding is that the Council needs firm assurance that the visitor centre will be viable as a business proposition in its own right. My response is that I would envisage the following broad sequence of steps: -
a. Completion of Section 106.
b. Grant of Consents.
c. Commencement of funding programme for the new school and visitor centre.
d. Completion of funding programme with targets met.
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e. Prior to letting of contract for new school building:-
i. GBC to be presented with updated costs for new school/visitor centre ii. Charitable Trust established to manage Gad’s Hill House iii. Trust to be granted Lease of Gad’s Hill House and immediate grounds at peppercorn rent. iv. Endowment sum to be paid into bank account of the Trust’s solicitors to enable the visitor centre to be created and to become operational.
f. The phased building works for the new school buildings and visitor centre commence.
I believe that if a mechanism of this nature could be incorporated into the legal agreement, this would provide the certainty the Council has been looking for that the visitor centre will be implemented. Without adequate funding for both the school and visitor centre, neither will proceed. Your response to this is sought. We can then give further attention to the business plan and management plan.
2. Design issues relating to the northern and western elevations –
Clarification is sought from GBC. Some concern has been expressed about the location of the new senior school building and how this relates to curtilage listed buildings on the site to be retained. We believe the proposed siting to be the right location for the senior school as it minimises the impact of the scheme within the green belt. I would appreciate your comments on this specific point. Also, the architects have sought to provide some breathing space around the retained buildings and a gradation in scale is achieved with the new development that meets planning and conservation objectives. The senior school building has already been reduced in scale and the roof space is now utilised – the point has been reached that if the scale is further reduced, the accommodation will need to be reprovided elsewhere. All of these issues will be best aired at our forthcoming meeting with Ms Brooker where, I am sure, agreement can be reached.
3. Visitor centre opening hours –
We agree to avoid clashes with school traffic in the afternoons so that visitor centre opening hours could extend from say 10:00 am up to 2:00/2:30 pm.
4. Increased coach usage –
There is no KCC objection to this.
5. Mansion flats –
English Heritage appears to accept the key worker flats in the mansion. In addition, they will provide an important income stream for the school in the future. We do not believe that the conversion of the upper floors of the mansion flats will have a detrimental impact upon the character, appearance or fabric of the listed building. This is supported in a preliminary report from the Ashford Borough Council on the building regulations impact. Again, all this can be tabled when we next meet.
6. New floor space compared with the old –
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Page 11 of the planning statement that accompanied the planning applications refers to six existing senior school classes when, in fact, there are eleven when those in the pavilion block are counted. There is not therefore an increase of five. The new school meets Government space guidelines.
7. Maintenance shed –
There is scope to amend the submitted drawings. Historically, this part of the site has accommodated various structures and glass houses. It is accepted though that there is a need to ensure that any development here blends with the whole and does not impair views.
8. Tennis courts –
These occupy the centre of the site and, on plan, it would appear they have a jarring effect upon views within the site. In fact, there is much within the site that distracts from the courts. Relocation of the courts has been considered, as has been ways of mitigating its presence for example by replacing the existing enclosure and improving planting surrounding the courts. If at all possible, the school would wish to avoid relocating the structure.
9. Highways –
The Highways Authority has given its in principle support to the improvements accruing from the scheme. KCC overlook that a Stage 1 Safety Audit has been completed and met, and that a 2.4 metre (inset) visibility has been agreed at the Crutches Lane/Gravesham Road junction.
Whilst you will, no doubt, still have much to say about what has (and not) been highlighted above, this letter is really intended to serve as a demonstration of intent that we shall do our utmost to meet your reasonable requirements so that consent may be achieved.
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Consultation expiry date: N/a at this stage
Recommendation:
No recommendation is being made at this stage and this report is submitted for members’ information on the application and its progress. Members’ views regarding a site meeting are requested.
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