Planning Statement St Lawrence CE (VC) Primary School, Gnosall On Behalf of the Cabinet of Staffordshire County Council
10 September 2014
Planning & Development
QUALITY MANAGEMENT
Prepared by: Cameron Austin-Fell
Authorised by: Joe Murphy
Date: 10 September 2014
Project Number/Doc Ref: JBB8230.C2848
DISCLAIMER
The opinions and interpretations presented in this report represent our best technical interpretation of the data made available to us. However, due to the uncertainty inherent in the estimation of all parameters, we cannot, and do not guarantee the accuracy or correctness of any interpretation and we shall not, except in the case of gross or wilful negligence on our part, be liable or responsible for any loss, cost damages or expenses incurred or sustained by anyone resulting from any interpretation made by any of our officers, agents or employees.
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RPS cannot accept any liability for the correctness, applicability or validity for the information they have provided, or indeed for any consequential costs or losses in this regard. Our efforts have been made on a "best endeavours" basis and no responsibility or liability is warranted or accepted by RPS.
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The material presented in this report is confidential. This report has been prepared for the exclusive use of Stafford Country Council and shall not be distributed or made available to any other company or person without the knowledge and written consent of Stafford County Council or RPS.
Planning & Development
CONTENTS
1 INTRODUCTION ...... 1 2 SITE AND LOCATION ...... 3 3 PROPOSED DEVELOPMENT ...... 5 4 NATIONAL POLICY & GUIDANCE ...... 8 5 SPORT ENGLAND POLICY AND GUIDANCE ...... 14 6 THE DEVELOPMENT PLAN ...... 16 7 THE PLANNING BALANCE ...... 21 8 CONCLUSIONS ...... 26
APPENDIX 1 – STAFFORDSHIRE COUNTY COUNCIL NEW SCHOOL FAQS ...... I
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1 INTRODUCTION
Introduction
1.1 This planning statement has been prepared by RPS Planning and Development (RPS) on behalf of the Cabinet of Staffordshire County Council (SCC) in support of a new 1.5FE primary school in the village of Gnosall.
1.2 A full planning application has been submitted to Staffordshire County Council (SCC) for the application site of 4.39ha, proposing the demolition of existing school buildings, including the swimming pool, to be replaced by a new two storey primary school, hard standing and associated infrastructure.
1.3 The school is to be redeveloped as part of the Priority Schools Building Programme, run by Interserve on behalf of the Education Funding Agency (EFA).
1.4 This statement appraises the proposal for the replacement primary school against the national and local policy framework in Stafford Borough Council (SBC), which determines that planning permission should be granted on this site. In the preparation of the submission, RPS has considered a range of technical evidence which has been prepared by an extensive consultancy team.
Plans and Reports
1.5 This statement should be read in conjunction with the following:
Application Forms and Certificates
Design and Access Statement (incorporating 1. Statement of Community Involvement, 2. Heritage Statement and 3. Foul Sewage and Utilities Assessment) (September 2014);
Transport Statement and Travel Plan (September 2014);
Site Plans and Drawings
Arboricultural Survey Report (October 2013);
Preliminary Ecological Appraisal (August 2013);
Bat Presence/Absence Survey (June 2014);
Flood Risk Assessment (September 2014);
Environmental Acoustics Report (September 2014);
Geoenvironmental Desk Study (June 2013);
Factual Report on Ground Investigation (November 2013); and
Project Management Plan.
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Pre Application Discussions and Application Validation
1.6 The proposal has been informed by pre-discussions with officers from SCC. The applicant, SCC has maintained open and ongoing dialogue with SBC in the preparation of this planning application. The proposals for the redevelopment of St. Lawrence’s primary school has been taken through various stages of democratic involvement, to ensure that Councillors, Officers and the public have been made aware of the site selection process and important changes relating to the proposed development.
1.7 As part of pre-application discussions, Sport England was invited to comment on the proposals in 2013. They responded in October 2013, expressing concern that the loss of the changing rooms as part of the development may trigger statutory involvement, as this involved the loss of community facilities for the adjacent sports pitch. Clarification has since been sought from Trish Edwards, the Head of St. Lawrence CE Primary School, who has confirmed that the changing rooms are limited only to the swimming pool and do not serve the sports pitches. In this context, RPS considers that the proposed development does not trigger statutory involvement from Sport England.
Applicant
1.8 The Applicant, SCC is the higher tier Authority in Staffordshire, responsible for education, child and adult care, transport and highways and certain planning functions. As the education provider for the District, SCC retains ownership of St. Lawrence Primary School and is entrusted to manage the school in an efficient and viable way.
Structure of Planning Statement
1.9 The remainder of this statement is structured as follows:
Section 2 describes the site and its surroundings;
Section 3 addresses the site history;
Section 4 addresses the application proposals;
Section 6 demonstrates how the proposed development relates to national policy;
Section 7 demonstrates how the proposed development relates to Sport England policy;
Section 8 demonstrates how the proposed development relates to the development plan;
Section 9 addresses the planning merits and overall Planning Balance;
Section 10 provides overall policy conclusions.
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2 SITE AND LOCATION
Background
2.1 Gnosall is a large village with a population of around 3,783, located in the south-west of Stafford Borough, which is located adjacent to the A518 road linking Stafford to Newport. Gnosall has developed as two distinct areas, bisected to the north and south by the former Stafford-Newport railway line and the floodplain of the Doley Brook.
2.2 In 2012 Stafford Borough Council undertook a revised settlement assessment and audit of services and facilities. The document identified that Gnosall is well served by a range of services and facilities, including a number of convenience shops, two medical facilities, three educational facilities and a half hourly bus service to Stafford and Newport.
2.3 In terms of the settlements within Stafford Borough, Gnosall is considered one of the larger, more sustainable villages, which supports the larger towns of Stafford and Stone.
Site Location
2.4 The site is bounded by the Gnosall Memorial Village Hall to the north; a car dealership to the north west and agricultural land in all other directions. The land to the north of the school on Lowfield Lane is currently being developed to provide 30 new houses. The southern edge of the site is bordered by a disused railway line which is now a public right of way. The application site measures approximately 4.39 hectares in area in total.
2.5 The existing school consists of a two story building with a total footprint of 2,141m2. The southern and western edges to the site are densely vegetated/woodland areas with the remainder of the site consisting of hard standing and grassed areas. There are railings/fencing forming the boundary of the site. The school is not sited in a conservation area.
2.6 In March 2014 the swimming pool within the site was designated by Gnosall Parish Council as an Asset of Community Value (ACV), following nomination in February 2014. The designation as an ACV permits the designating body a moratorium period to bid for the ACV should the landowner wish to dispose of the land. The moratorium provisions only apply to disposals and in the context of this application, the moratorium rules do not apply.
2.7 Figure 1 below includes a site plan of the existing site boundary, along with the location of buildings on the site.
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Figure 1 – Existing Site Plan
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3 PROPOSED DEVELOPMENT
The Application Proposal
3.1 This section addresses the detail of the planning application. The principal components of the proposal are described in detail below and supported by technical reports and plans submitted as part of this application. Further details about the proposed development are provided in the Design and Access Statement.
Full planning application for the demolition of existing school buildings (including swimming pool) and development of a new two storey Primary School building, hard standing and associated infrastructure.
3.2 The cabinet of Stafford Borough Council are proposing to replace the current school at St. Lawrence CE primary school with a modern, two storey primary school on the 4.39 hectare site.
3.3 It is proposed that the site can be accessed from the existing junction on Lowfield Lane. A transport assessment undertaken as part of the planning application for this proposal determines that the junction has sufficient capacity to accommodate the impacts of the proposed development.
3.4 The design of the landscape and external environment for Gnosall St Lawrence Primary School has been informed through careful consideration and respect for the existing landscape elements and tree cover, maintaining as much as possible the existing biodiversity of the site. The impact on existing trees will be minimal.
3.5 Figure 2 below outlines the layout of the proposed redevelopment of the school, which indicates the location of the new buildings and playing fields.
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Figure 2 – Proposed development
3.6
Layout and Scale
3.7 The new school will be organised into suites comprising: key stage classrooms, multipurpose hall, administration and support. The development of a strong spine concept for navigation around the school allows classrooms, group rooms, ancillary spaces and open break-out areas to be controlled in a single core to aid the learning process and enhance communication. Safe and secure pupil entrances are provided to ensure they are comfortable and appreciate their surroundings.
3.8 The Nursery is provided via dedicated entrance complete with canopy. The Reception, Key Stage 1 & 2 has a covered entrance with a new external link to the playground areas. The main entrance is clearly defined, accessible and welcoming allowing staff and visitors to enter the school in a safe and controlled manner during and outside of the school day via a secure lobby.
3.9 The library is located opposite the main entrance to act as a focal point and is an opening and welcoming space off the circulation corridors. Full height ceiling following the roof line is provided in the main corridor of the first floor. In relation to the building, the height has been kept to a minimum to ensure it is not over imposing on the surrounding buildings. Therefore low pitch roofs to the main school and a flat roof to the hall are proposed.
3.10 The building design utilises materials and components that reflect the local context and introduces a modern interpretation to create a twenty-first century community facility to inspire learners to achieve their best, challenge themselves and enjoy their learning. The brick and render facade treatments provide a link with the local vernacular.
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3.11 The single story sections are limited in height to the minimum to provide suitably high class room ceilings. The two storey hall is of simple design with a low parapet wall and has been highlighted with coloured render to act as a focal point to the entrance area of the school and reflect Gnosall St Lawrence adopted brand colours. This contrasting use of materials, with the simple eaves treatment, reduces the buildings impact on the surrounding area whilst differentiating it from the surrounding residential buildings, reinforcing its community use.
3.12 The adoption of natural ventilation supplemented with mechanical ventilation reduces the impact on the teaching space of any external noise. The scale of the building is limited to effectively meet the client’s requirements with space for the future expansion into a two form entry building.
Key Benefits
3.13 The proposed redevelopment of St. Lawrence CE primary school will lead to a significantly improved primary school, capable of meeting the immediate needs of Gnosall and the surrounding area. The building will be designed to high standards of energy efficiency, reducing the energy requirements of the building and carbon footprint.
3.14 The building will also be designed to accommodate modern technologies in the classroom, ensuring that pupils have access to the necessary resources to learn in a functional and secure environment.
3.15 A section of the proposed development has been designated as a community zone, which along with a disabled toilet is accessible by the main entrance. This will provide an accessible community space which will enable a range of after-school activities which will benefit the pupils and the local community.
3.16 The proposed development has been designed to a 1.5 form entry; however it has been designed in a way that it can be extended in the future to a 2 form entry primary school. The building is therefore capable of responding to future change in the area, without significant displacement.
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4 NATIONAL POLICY & GUIDANCE
4.1 This section addresses the national planning policy position, in terms of the National Planning Policy Framework (NPPF), and online Planning Practice Guidance (PPG).
4.2 Central Government has clarified that all development proposals that can be demonstrated to be sustainable forms of development should be considered favourably in the first instance with a presumption of approval from local planning authorities.
National Planning Policy Framework (NPPF)
4.3 The NPPF is built around the presumption in favour of sustainable development. The planning application documentation taken together demonstrates that the proposals constitute sustainable development.
Presumption in favour of Sustainable Development
4.4 The NPPF confirms that proposals which accord with the Development Plan should be approved without delay. Where the Development Plan is absent or silent, or relevant policies are out of date, planning permission should be granted for sustainable development unless any adverse impacts of doing so would significantly outweigh the benefits when assessed against the policies in the Framework taken as a whole, or where specific policies in the NPPF indicate development should be restricted.
4.5 The application documentation demonstrates that any adverse impacts of granting planning permission for the proposed development would not significantly and demonstrably outweigh the benefits of the development when assessed against the NPPF policies. The NPPF does not contain policies that indicate development in this location should be restricted.
4.6 The remainder of this section is structured under the NPPF policy headings relating to the delivery of sustainable development under the policy presumption in favour.
Building a Strong, Competitive Economy
4.7 Paragraphs 20 and 21 of NPPF outline that Local Planning Authorities should plan proactively to meet development needs of business and support an economy fit for the 21st century to help achieve economic growth. Further, in order to do this, authorities' planning policies should recognise and seek to address potential barriers to investment, including a lack of infrastructure, services or housing. The development proposals will deliver much needed modern educational infrastructure. The construction phase of the project will also provide new local employment.
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Promoting Sustainable Transport
4.8 NPPF Paragraphs 29 to 39 indicate that Local Planning Authorities are, through local plan policies, to encourage the delivery of sustainable modes of transport to reduce the need to travel by car. Developments should be encouraged which are located in sustainable locations reducing the need to travel, and maximising sustainable forms of transport. When determining local parking standards a range of issues should be taken into account including accessibility, type and use of development, and public transport opportunities.
4.9 Specifically, Paragraph 32 requires that all developments which would generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. The application includes a Transport Statement and Travel Plan within the supporting documentation. The document demonstrates that the proposed development maximises opportunities for sustainable modes of travel and that safe and suitable access to and from the site can be achieved, and set out proposals for transport improvements in the area. It is considered that the residual cumulative impacts of the development will not be severe or outweigh the wider benefits of the proposals and, therefore, planning permission should not be refused on transport grounds under NPPF Paragraph 32.
4.10 The application site is in a sustainable location as it is the site of an existing school, is located within the residential area where the majority of its pupils live, and is located close to existing bus routes. Accordingly, the proposals will contribute towards reducing journey lengths and the need to travel.
Requiring Good Design
4.11 The thrust of the NPPF is that good design is a key component of sustainable development and that all sustainable development should contribute positively to making places better for people. This can be achieved using a high quality design approach to public and private spaces as well as to buildings.
4.12 NPPF paragraph 58 lists key criteria for planning decision takers to ensure that developments:
function well and add to the overall quality of the area;
establish a strong sense of place, using streetscapes and buildings to create comfortable places to live, work and visit; optimise the potential of the site to accommodate development, create and sustain an appropriate mix of uses (including incorporation of green and other public open space as part of developments) and support local facilities and transport networks;
respond to local character and history, and reflect the identity of local surroundings and materials;
create safe and accessible environments; and
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are visually attractive as a result of good architecture and appropriate landscaping.
4.13 The design concept for the development of the site meets these NPPF objectives as explained in this Design & Access Statement. Design principles have been formulated and applied to the proposals which will ensure there is a strong sense of place which responds to the local character of the area, resulting in a visually attractive environment whilst optimising the potential of the site to accommodate development.
Promoting Healthy Communities
4.14 The NPPF at paragraph 69 encourages developments to facilitate social interaction and the creation of healthy and inclusive communities through safe and accessible environments and developments, clear and legible pedestrian routes, and high quality public open space, which encourages the active and continual use of public areas.
4.15 Paragraph 70 states that to deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should plan positively for the provision and use of shared space, community facilities (such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments and ensure that established facilities and services are able to develop and modernise in a way that is sustainable, and retained for the benefit of the community. The proposed development facilitates such an approach.
4.16 At Paragraph 72 the Government attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities. Local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement, and to development that will widen choice in education. They should give great weight to the need to create, expand or alter schools; and work with schools promoters to identify and resolve key planning issues before applications are submitted.
4.17 Paragraph 73 confirms access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision. The assessments should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area, and information gained from the assessments should be used to determine what open space, sports and recreational provision is required.
4.18 Paragraph 74 of the NPPF includes the criteria for identifying open space and recreational land, including the provision for releasing land that is no longer appropriate or is not fit for purpose. The Paragraph requires that local authorities undertake assessments of open space and recreational land, to understand the current capacity and demand of the spaces and facilities, in addition to those
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surplus to requirements. It is considered that the removal of sports facilities may be appropriate if the loss is replaced by equivalent or better facilities in terms of quantity and quality in a suitable location.
Meeting the Challenge of Climate Change, Flooding and Coastal Change
4.19 NPPF paragraph 93 states that planning plays a key role in reducing greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy.
4.20 This Planning Statement accompanying the application demonstrates how the principles of sustainable development have been considered in the design of the proposed development.
4.21 The NPPF requires the preparation of Flood Risk Assessments (FRAs) for larger developments. The FRA which accompanies the application has assessed all potential sources of flooding which could impact the proposed development and the flood risk of the site is deemed to be negligible.
Conserving and Enhancing the Natural Environment
4.22 NPPF Paragraph 109 states that the planning system should contribute to and enhance the natural environment, including protecting and enhancing valued landscapes, geological conservation interests and soils; recognising the wider benefits of ecosystems; and minimising impacts on bio- diversity and promoting net gains in bio-diversity.
4.23 NPPF Paragraph 118 attaches weight in planning decisions to whether biodiversity is encouraged in and around developments and states that permission should be refused where loss or deterioration of irreplaceable habitats would result unless the needs and benefits of the development outweigh the loss.
4.24 Biodiversity issues are covered in the Preliminary Ecological Appraisal and Bat Presence/Absence Survey which support the application. The assessment shows that there is no reason to suggest that any ecological designations, habitats of nature conservation interest or any protected species will be unacceptably adversely affected by the proposals.
4.25 Paragraph 109 also indicates that the aim to meet development needs should be to minimise pollution and other adverse effects on the local and natural environment. The application has also considered noise and contamination issues and the assessments have concluded that the development will not cause or be subject to unacceptable impacts. As a result the site is suitable for the proposed use with respect to the natural environment.
Conserving and Enhancing the Historic Environment
4.26 NPPF Paragraph 128 states that in determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected with the level of
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detail required being proportionate to the importance of the assets. In this case, the application site is not located within a Conservation Area.
Taking Planning Decisions
4.27 NPPF Paragraph 168 states that local planning authorities should approach taking planning decisions in a positive way to foster the delivery of sustainable development. Paragraph 187 goes on to state that authorities should look for solutions rather than problems, and decision-takers at every level should seek to approve applications for sustainable development where possible. Local planning authorities should work proactively with applicants to secure developments that improve the economic, social and environmental conditions for the area.
4.28 The NPPF is a material consideration in decision taking from 27 March 2012 (Paragraphs 196 and 212 refer) and the presumption in favour of sustainable development should be applied in this context (paragraph 197 refers).
National Planning Practice Guidance
4.29 On March 6th 2014 the Government launched the Planning Practice Guidance (PPG) web-based resource which builds upon the key principles of the NPPF. The following are considered of relevance to the development proposals.
Design
4.30 The Guidance states good quality design is an integral part of sustainable development, and the PPG recognises that design quality matters and that planning should drive up design standards across all forms of development. A core planning principle for plan makers and decision takers is to always seek to secure high quality design.
Open Space, Sports and Recreation Facilities
4.31 Paragraph 37-001-20140306 of the PGG recognises the importance of open space and recreational land and the benefits that they offer in supporting sustainable communities. The PPG advises that Council’s undertake an assessment of the open space and recreational needs in the Borough, referring to Sport England guidance.
4.32 Paragraph 37-003-20140306 of the PPG acknowledges that Sport England are not a statutory consultee, however Councils are advised to consult Sport England where a development may involve the loss of any sports facility.
Flood Risk
4.33 The PPG supersedes the technical guidance note published alongside the NPPF in 2012. The PPG advises how Flood Risk Assessments (FRAs) should be prepared to ensure that development assesses the likely risk to a development site and follows avoidance, managing and mitigation
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measures as appropriate. The guidance advises that proposals make use of flood mapping provided by the Environment Agency, to provide an FRA appropriate to the scale and type of development and follow the standing advice on flood risk when preparing an assessment. An FRA has been prepared as part of this assessment.
Summary
4.34 The analysis of the proposals against the relevant provisions of the NPPF and PPG demonstrates that the application proposals are consistent with national planning policy and guidance. Accordingly, it is considered that the Planning Authority should apply the principle in favour of sustainable development and resolve to grant planning permission in the absence of any adverse impacts which significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF.
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5 SPORT ENGLAND POLICY AND GUIDANCE
5.1 This section outlines Sport England’s planning policies and guidance for development involving the loss or change of use of sport or recreational facilities.
5.2 Sport England are a statutory consultee in relation on planning applications affecting playing fields. They are also a non-statutory consultee in relation to other developments involving other sport related developments.
5.3 The proposed development at St. Lawrence’s Primary School, Gnosall involves the demolition of the existing swimming pool to make way for a new, larger primary school. The proposals do not affect the adjacent playing fields, however it is anticipated that Sport England will respond to these development proposals as a non-statutory consultee.
5.4 Sport England have published a guidance note which considers the context of development in relation to sports and recreational facilities. This has been framed in the context of the planning objectives of Sport England, both of which are outlined below.
Sport England Aims and Objectives
5.5 Sport England aim to promote sport and recreation as a key tool to encourage healthier, more active lifestyles in the contribution towards sustainable communities. This is achieved through establishing the following planning objectives:
1. Protect existing facilities: Sport England seeks to help protect sports and recreational buildings and land including playing fields. Sport England expects these to be retained or enhanced as part of any redevelopment unless an assessment has demonstrated that there is an excess of provision and they are surplus to requirements, or clear evidence supports their relocation. Sport England is a statutory consultee on all planning applications affecting playing field land and will object to such an application unless one of five exceptions applies.
2. Enhance the quality, accessibility and management of existing facilities: Sport England wishes to see the best use made of existing sports facilities through improving their quality, access and management. Sport England has developed a wide range of supporting advice on understanding and planning for facility provision, including efficient facility management such as community access to school sites.
3. Provide new facilities to meet demand: Sport England seeks to ensure that communities have access to sufficient high quality sports facilities that are fit for purpose. Using evidence and advocacy, we help to guide investment into new facilities and the expansion of existing ones to meet new demands that cannot be met by existing provision.
5.6 Sport England has embodied these objectives within the recently published Guide No.3: Development Management.
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Sport England Guide No.3: Development Management
5.7 The Guide No.3: Development Management was published in July 2014 and represents Sport England’s advice in relation to planning decisions involving developments which involve open space and or recreational land.
5.8 The guidance proposes that development proposals should be informed by robust and up to date assessments of need. This will assist in determining the right approach for sports and recreational development in the right places.
5.9 Through robust assessments of need, Sport England aim to protect important sports facilities from inappropriate development, enhance existing facilities and provide new facilities that are fit for purpose.
5.10 The guidance highlights the opportunities to enhance the quality and frequency of participation in sport through combining education and community uses, operating through dual use arrangements. These can offer significant benefits to the school and the local area by making spaces available for the community.
5.11 As part of their evidence base for the Plan for Stafford Borough, SBC commissioned a number of assessments to understand the quantum and quality of open space, green infrastructure, sports and recreational facilities needed to support the targets for growth. These evidence base documents are referred to in Section 6.
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6 THE DEVELOPMENT PLAN
6.1 This section addresses the local planning policy position in terms of development plan policy, supplementary planning guidance/documents and emerging policy documents and evidence base.
Plan for Stafford Borough (2014)
6.2 The Development Plan comprises the policies of The Plan for Stafford Borough 2011-2031 which was adopted on 19 June 2014.
6.3 The Plan for Stafford Borough is a new planning policy document which will manage where new development (such as housing, shops and green spaces) can take place over the next 20 years. It contains a vision, spatial principles and specific policies which will guide development across the Borough. The site is not specifically allocated on the Proposals Map.
6.4 The main policies relevant to the determination of the planning application for the demolition of existing school buildings and the construction of a new school building and associated facilities are set out below.
Spatial Principle 1 (SP1) – Presumption in Favour of Sustainable Development
6.5 When considering development proposals, the Council will take a positive approach that reflects the presumption in favour of sustainable development contained in the NPPF. It will work proactively with applicants and communities jointly to find solutions which mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area. Planning applications that accord with the policies in this Local Plan (and, where relevant, with polices in neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise.
6.6 The proposals would be sustainable development in that they will secure development that improves the social conditions of the area through modern school facilities.
Spatial Principle 3 (SP3) – Stafford Borough Sustainable Settlement Hierarchy
6.7 The majority of future development will be delivered through the Sustainable Settlement Hierarchy based on the following areas:
1. County Town of Stafford
2. Market Town of Stone
3. Key Service Villages of Eccleshall, Gnosall, Hixon, Great Haywood, Little Haywood / Colwich, Haughton, Weston, Woodseaves, Barlaston, Tittensor and Yarnfield.
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6.8 The application site is located within Gnosall which is a Key Service Village. The supporting text of SP3 indicates Gnosall has the largest population outside of Stafford and Stone, a significant health facility and good transport links to Stafford, and Newport in Shropshire. Its historic core is designated as a Conservation Area. Although there are some retail services and facilities at Gnosall, there is a lack of local employment in the settlement, leading to out commuting for work to Stafford, Newport and beyond.
Policy Stafford 1 – Stafford Town
6.9 Stafford has the role of the County Town at the head of the Sustainable Settlement Hierarchy set by Spatial Principle SP3, and the strategy for Stafford town will seek to enhance its role by increasing both the range and quality of services and facilities. The strategy includes increasing and improving the provision of open space, sport and recreation facilities through new green infrastructure and by addressing specific qualitative and quantitative deficiencies.
6.10 Policy Stafford 1 states that new development at Stafford will support the provision of a new indoor swimming pool and new indoor multi-use and specialist facilities through the Strategic Development Locations and CIL/S106 contributions.
Policy E8 Town, Local and Other Centres
6.11 This Policy indicates support will be given to maintaining and enhancing the functions, vitality and viability of the hierarchy of town, local and other centres. It also states support will be given to proposals and activities that protect, provide for, retain or enhance existing town, local and other centre assets. Loss of an existing facility will be resisted unless it can be demonstrated that the facility is no longer needed, or it can be established that the services provided by the facility can be served in an alternative location or manner that is equally accessible by the local community.
6.12 The development would result in the loss of the community use swimming pool, however as demonstrated later in this statement it is considered that there are alternative facilities available and accessible within the County Town of Stafford and at nearby Newport.
Policy T1 Transport
6.13 This Policy requires new developments to produce Transport Assessments and Travel Plans, where appropriate, including maximising the use of public transport, as well as facilitating the provision of safe and well integrated off-street parking.
6.14 Accessibility is addressed within the Transport Statement and Travel Plan which accompanies the planning application.
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Policy T2 Parking and Manoeuvring Facilities
6.15 This Policy seeks to ensure adequate parking is provided for all new development. Parking and alignment are addressed within the Transport Statement and Travel Plan which accompanies the planning application.
Policy C7 Open Space, Sport and Recreation
6.16 Support will be given to sport and recreation by retaining, protecting, supplementing, or enhancing all types of sport, recreation and open space facilities, in order to address deficiencies of both indoor and outdoor facilities outlined in the Open Space, Sport & Recreation Assessment and any subsequent revisions. Development that results in the loss of existing open space, sport and recreation facilities will be resisted unless better facilities in terms of quality, quantity and accessibility can be provided or that redevelopment would not result in a deficiency in the local area.
6.17 The development would result in the loss of the community use swimming pool, however as demonstrated in this statement it is considered that there are alternative facilities available and accessible within the County Town of Stafford and at nearby Newport.
Policy N1 Design
6.18 This Policy seeks to secure enhancements in design quality on all new developments to meet the principles of use, form, space and movement. The application proposals for a modern school building have been designed to a high quality.
Policy N2 Climate Change
6.19 All development must incorporate sustainable design features to facilitate a reduction in the consumption of natural resources, improve the environmental quality and mitigate against the impact of climate change. Proposals must take particular account of the need to ensure protection from, and not worsen the potential for, flooding.
6.20 Climate change is addressed elsewhere with this Design and Access Statement and the application is supported by a Flood Risk Assessment which demonstrates the proposals will not worsen the potential for flooding.
Policy N4 The Natural Environment & Green Infrastructure
6.21 This Policy seeks to protect, conserve and enhance the natural and historic environment and irreplaceable semi-natural habitats, such as ancient woodlands, and ancient or veteran trees.
6.22 The application is accompanied by a Preliminary Ecological Appraisal, Bat Presence/Absence Survey and Arboricultural Survey Report which demonstrate there is no reason to suggest that any ecological designations, habitats of nature conservation interest, any protected species, or trees of high value will be unacceptably adversely affected by the proposals.
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Concluding Comments
6.23 The analysis of the proposals against the relevant policies of the Plan for Stafford Borough 2011- 2031 demonstrates that the application proposals are consistent with all relevant policies.
Evidence Base
SBC Green Infrastructure, Greenspace and Sport and Recreation Provision Strategy (2013)
6.24 The SBC Green Infrastructure, Greenspace and Sport and Recreation Provision Study (SGIS) has been produced to identify the current provision of green infrastructure and recreational land, in accordance with the Plan for Stafford Borough and the NPPF.
6.25 The evidence base document considered the locations for development in the Plan for Stafford Borough, creating a strategy for an enhanced green infrastructure network in the Borough. Of the further recommendations of the study, a more detailed assessment is needed to identify locations for an additional 25m swimming pool in Stafford.
SBC Open Space, Sport and Recreation Assessment Update (2013)
6.26 The SBC Open Space, Sport and Recreation Assessment Update (SOPA) was produced to update the Council’s 2009 Planning Policy Guidance 17 audit of open space and recreational land. The assessment of land in the SOPA has been undertaken in accordance with Paragraph 74 of the NPPF, which reviews the quantum, distribution and quality of the existing open space, sport and recreation provision. As a response to the assessment the document makes recommendations on the future requirements in the district to support the Plan for Stafford Borough.
6.27 In terms of the provision of indoor swimming pools, the SOPA identifies a significant shortfall in water space equivalent to nearly 300 sq m, which equates to a 4 lane 25m pool. In conjunction with the SGIS, it is proposed that the most suitable location for the new facility is in Stafford, which presents the most sustainable location for development.
Gnosall Neighbourhood Planning
6.28 On the 16th May 2013 Stafford Borough ended a six week consultation on the designation of the Gnosall Neighbourhood Plan Area Designation. The Council has since approved the designation of the Neighbourhood Plan area on July 4th 2013, which follows the existing Parish boundary. The Parish have yet to proceed with a Neighbourhood Plan or other local initiatives permitted under the 2011 Localism Act and 2012 Neighbourhood Planning Regulations.
Summary
6.29 The analysis of the proposals against the relevant provisions of the NPPF, the PPG and the relevant policies of the Plan for Stafford Borough 2011-2031 demonstrates that the application proposals are consistent with national planning policy and development plan policy. Accordingly, it is considered
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that the Planning Authority should apply the principle in favour of sustainable development and resolve to grant planning permission in the absence of any adverse impacts which significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF.
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7 THE PLANNING BALANCE
7.1 This section addresses the principal planning issues of the proposed scheme. RPS has identified the following issues:
I. Need for new education facilities;
II. Conformity with NPPF and local policies; and
III. Conformity with Sport England policies
I. NEED FOR NEW EDUCATION FACILITIES
7.2 The St. Lawrence CE Primary School has been included within the Government’s Priority Schools Building Programme. This presents a rare opportunity to provide a brand new school for the area of Gnosall, to meet the expanding needs of the village and provide an energy efficient building, resilient to future change.
7.3 As noted in SCC’s FAQ, in Appendix 1 of this statement, the condition of the current building is very poor. The primary school currently operates in the shell of the former Heron Brook High School built 50 years ago and is in serious need of renovation. SCC have undertaken cost analysis of the work needed to upgrade the building, which is far greater than a replacement building.
7.4 Appendix 1 also highlights a 26% increase in the number of children born in the catchment area within recent years. This increase in children of primary school age has meant that not all those who have applied to St. Lawrence CE primary school have been able to attend. Notwithstanding the current condition of the building, a larger school is required to meet the immediate need for school places in the area.
7.5 A new school is therefore needed to support the requirements of a modern education establishment and provide sufficient capacity to meet the needs of the expanding catchment. As a result of initial feasibility, design proposals for a 1 form entry school have since been amended to a 1.5 form entry school. This will increase the capacity for each year group by 33%, from 30 pupils to 45 pupils. This is expected to meet the immediate and future needs of the catchment area. In addition, the building has been designed in a way that it can accommodate future extensions to the building, with little disruption, should the need arise.
7.6 The new school is estimated to cost around £2.2m, of which a significant proportion will be delivered through EFA funding. This is a significant opportunity for SCC and Gnosall, who would be difficult to deliver without Government funding.
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II. CONFORMITY WITH THE NPPF AND LOCAL POLICIES
7.7 The Design and Access Statement (DAS) and supporting technical documents have demonstrated that the development has been designed to a high standard, ensuring that the considerations of the end users have been key to the final design strategy. The proposed development is consistent with local policy, supporting the role of Gnosall as a Key Service Village in the Plan for Stafford Borough. The below section addresses in more detail any conflicts related to the loss of recreational facilities.
7.8 Paragraphs 73 and 74 of the NPPF relate to the provision of high quality open spaces and opportunities for sport and recreation. Planning policies and planning decisions should be informed by robust and up to date assessments of the need for sports and recreational facilities, identifying deficits or surpluses of space through a quantative and qualitative assessment.
7.9 Specifically, Paragraph 74 of the NPPF requires that “open space, sports and recreational buildings and land, including playing fields, should not be built upon unless:
An assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or
The loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or
The development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.
7.10 The proposed redevelopment of the St. Lawrence Primary School involves the demolition of the swimming pool, which was built as part of the former Heron Brook High School. The need for a larger 1.5 form entry school has led to proposals which can no longer accommodate the swimming pool within the site. RPS considers that the impacts of this loss are not significant in the context of Paragraph 74 of the NPPF and the local demand for the pool can be met through other arrangements.
7.11 It has been highlighted at Paragraph 4.28 of the SBC Green Infrastructure, Greenspace and Sport and Recreation Provision Study (SGIS) that the swimming pool at St. Lawrence CE Primary School is “only 16.7m x 7.2m, is showing its age, and requires upgrading”. The building housing the swimming pool is, unlike the rest of the school, timber framed. This building has lasted this long by virtue of its siting within the school, however it is becoming increasingly clear that the building is no longer fit for purpose.
7.12 The Council recently undertook a feasibility study which calculated the costs of retaining the pool as part of the development proposal. This considered the costs of decommissioning and emptying the pool as part of the school redevelopment and creating a new plant room and changing rooms;
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required to replace the existing facilities. The feasibility study was only able to account for known issues and did not cover additional issues which may arise as a result due to the age of the pool. The feasibility study concluded that at a minimum, the costs of undertaking this work would be in excess of £500,000.
7.13 It would therefore be unviable for the new school to accommodate the swimming pool. The limited catchment that it serves and the costs of redevelopment would be outside of the remit of the EFA and would represent poor value for money for the residents of Staffordshire. The Council would be responsible for the running costs and future maintenance of the swimming pool, which given its age, will require escalating investment to ensure that the pool can function to health and safety standards. It is considered a more appropriate use of Council resources to ensure that modern, high quality facilities are maintained in suitable and accessible locations, rather than support services which will place greater strain on the Council in the longer term.
7.14 The local authority, SBC is however looking to increase the provision of open space and recreational facilities in the Borough which will, over time, more than compensate for the loss of the local service. SBC has utilised Sport England’s Facilities Model Planning Analysis to establish the demands for sport and recreational facilities in the Borough. Paragraph 13.69 of the SBC Open Space, Sport and Recreation Assessment Update (SOPA) indicates that there is increased demand for more indoor swimming pools in the Borough, with the greatest need in Stafford town.
7.15 Policy Stafford 1 – Stafford Town is the key policy in the 2011 Plan for Stafford Borough to deliver strategic growth in Stafford. In terms of the required open space and recreational land needed in Stafford, the principal requirement is a new indoor swimming pool which will be delivered through the Strategic Locations for Development. The provision of a new 25m swimming pool in Stafford will provide appropriate facilities in a sustainable location easily accessible from Gnosall. In accordance with the Plan for Stafford Borough, contributions towards the new swimming pool will be sought through planning contributions, through the emerging Community Infrastructure Levy (CIL) in the Borough.
7.16 The creation of additional facilities in Stafford will provide local residents of Gnosall and surrounding villages with a range of accessible and modern swimming facilities. Presently, there are two alternative swimming pools accessible to residents of Gnosall by around 30 minutes by public transport. Newport swimming pool is 6 miles from Gnosall and can be reached by the 481 bus, which passes through the village every 30 minutes during the Monday to Saturday and every hour on Sunday, taking residents to Newport in 15 minutes. Equally, Stafford Leisure Centre is 33 minutes from Gnosall on the same bus in the opposite direction. The existing swimming pools in the area, combined with the new swimming pool planned in Stafford offer suitable capacity to meet the needs of the residents of Gnosall in a coordinated way, ensuring the longer term financial sustainability of the swimming pools.
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7.17 To ensure that St. Lawrence primary school is capable of meeting high standards in education delivery it needs to be overhauled to reflect the changing needs of the village and catchment area. Owing to various statutory requirements including, avoiding both the flood plain and sports fields and allowing the school to continue to operate in situ during the building process, the demolition of the swimming pool, which has been identified by the Council as being in a poor condition, cannot be avoided.
7.18 The NPPF requires that all planning policies and planning decisions are led by the presumption in favour of sustainable development. Paragraph 14 of the NPPF is clear that development should proceed without delay unless the “adverse impacts of development significantly and demonstrably outweigh the benefits”. It has been demonstrated that granting permission for a new school will significantly benefit St. Lawrence’s school and the surrounding area. Though there will be a loss in recreational facilities through the demolition of the existing swimming pool, alternative pools have been identified in Newport and Stafford. These are more modern facilities, easily accessible from Gnosall, capable of serving the local community. The benefits of redeveloping St. Lawrence primary school therefore significantly outweigh the adverse effects of the development.
III. CONFORMITY WITH SPORT ENGLAND POLICIES
7.19 Sport England are a statutory consultee with regards to planning applications which involve the loss or prejudice of land used for playing fields. This application does not involve the loss or change to playing fields, however it does involve the demolition of the swimming pool associated with the primary school. As such, Sport England will be a non-statutory consultee as part of the planning application and this section will determine the suitability of the proposed development in accordance with Sport England Guidance.
7.20 This Planning Statement has accounted for guidance produced by Sport England in the determination of planning applications. In particular, RPS has considered the ‘Planning for Sport Guide No.3: Development Management’ document and the Sport England Aims and Objectives.
7.21 Sport England seeks to protect existing sports and recreational facilities, unless it has been demonstrated that they are surplus to requirements, or clear evidence supports the relocation of the facility. The Sport England Guide No.3 recognises that local sports provision should be informed by assessments of need. The Guide No.3 advises that the assessment of need should ensure that the right facilities are located in the right places, which should be fit for purpose with long term sustainability strategies.
7.22 As demonstrated in earlier sections, the swimming pool associated with St. Lawrence CE Primary School does not correspond with this guidance. Whilst the site may have been appropriate in its former capacity as a secondary school, it is no longer fit for purpose, nor is it financially viable to
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maintain. Whilst this is a loss in provision, the impact is not considered significant in the wider context of the gains in education provision.
7.23 Paragraph 4.19 of the SGIS reflects upon the current provision of swimming pools in Stafford Borough to meet local demand. In addition to the two 25m public swimming pools in Stafford and Newport, it is noted that “the overall contribution of these [school and commercial] pools in meeting local demand is very limited and can be ignored for planning purposes”.
7.24 This is important in understanding the importance of the swimming pool in the context of meeting local demand. Within the Borough, only Stafford and Stone are large enough to accommodate pools of 25m.
7.25 RPS acknowledges that there will be a slight quantative loss in the provision of recreational facilities, however SCC consider that is not financially viable nor technically feasible to retain the swimming pool as part of the proposed redevelopment of the school.
7.26 RPS therefore considers that SBC’s wider strategic approach to plan for a new swimming pool in Stafford town to be delivered through the allocated strategic locations for development represents an approach consistent with the Sport England Guide No.3, which should be pursued as an effective way to deliver recreational facilities in the Borough, which will compensate for the loss of facilities at Gnosall.
SUMMARY
7.27 Overall, the benefits and opportunities of the development clearly outweigh any disadvantages. This Statement sets out the benefits which can be summarised as follows:
The delivery of a modern high quality 1.5 form entry primary school;
Redevelopment to the same standards as BREEAM Very Good, reducing overall energy use and carbon footprint in the school;
The creation of a multi-functional community space within the primary school;
The development of a flexible building which is capable of extension and resilient to future change; and
Retention of school sports pitches for community use.
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8 CONCLUSIONS
8.1 This full planning application has been submitted to SCC which seeks consent for demolition of the existing school buildings, including a swimming pool and the constriction of a new primary school. The planning policy assessment undertaken has had regard to the NPPF, guidance from Sport England and local planning policies. No conflict with up-to-date development plan policy has been identified.
8.2 A full technical assessment of the proposed development has been undertaken, including transport, flooding and drainage, contamination, ecology, and arboriculture which demonstrate there are no overriding constraints to delivery of the proposals.
8.3 The approach towards development has been comprehensively considered to ensure high standards of design and a careful consideration of the permeability and functionality of the building. The proposals have been sympathetically designed to the appearance of the surrounding area to protect the landscape and the character of the playing fields. The redeveloped primary school will allow pupils and teachers of St. Lawrence CE primary school to continue to attain high standards of performance and will ensure that the building is future-proofed to account for future change. In addition, the proposed development will include areas which can be accessible to the public out of school hours. It is expected that such spaces will be able to accommodate evening classes and other community events, ensuring that the primary school becomes a more widely used community asset.
8.4 It is clear that the proposed development will bring significant benefits to the village of Gnosall, ensuring that the village is capable of providing high quality education facilities, which meet the needs of the modern classroom and provide sufficient capacity to meet the future needs of the village.
8.5 In accordance with Paragraph 14 of the NPPF, the proposed development delivers significant social and economic impacts on Gnosall, providing the village with a redeveloped high quality primary school. The loss of the existing swimming pool has been considered as part of Section 7 of this Planning Statement, however the impacts of this loss are not considered significantly adverse in the context of alternative facilities in the area and additional facilities proposed in the Plan for Stafford Borough.
8.6 There are no reasons why this development should not be approved, without delay, in accordance with local and national policy.
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APPENDIX 1 – STAFFORDSHIRE COUNTY COUNCIL NEW SCHOOL FAQS
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Frequently Asked Questions about the school
Why are you building a new school in Gnosall?
St. Lawrence CE (VC) Primary School is included in the Government’s Priority Schools Building programme. This is a rare opportunity to provide a brand new school for the children of Gnosall to continue to receive a first class education on their doorstep – now and as the village grows.
Why are we building a new school, why can’t it just be improved?
The condition of the existing school building is very poor and the cost of improving the school is far greater than building a new one.
Why do we need a new school?
The current school was designed to meet the needs of secondary children 50 years ago. The new school will be built to ensure that it is able to support the delivery of a modern education. The developers are working with the Governing Body and Head teacher to ensure that the new school absolutely meets the needs of the current children attending the school but is also flexible and able to adapt to any future requirements.
How many children will attend the new school?
The school intake will increase from 1 form entry to 1.5 form entry - increasing from 30 to 45 per year group, increasing the total number of reception to year 6 pupils from 210 to 315.
Why do we need a larger school?
From the birth data available the number of primary school age children in the catchment area has seen a 26% increase in the number of children born. This has meant that some children who have wanted to attend Gnosall St Lawrence CE Primary have been unable to.
Will the school be able to meet the future housing demands in Gnosall?
Yes; the school has been designed so that it could be extended with little disruption to the school in the future. Staffordshire County Council has a legal responsibility to provide sufficient high quality school places in the area.
How is the new school being paid for?
The new school is being funded by the Education Funding Agency (EFA). Seven schools in Staffordshire were submitted to the EFA for funding; three were successful, one being Gnosall. Staffordshire County Council has also agreed to fund the additional 0.5form entry to increase the school size to meet the demand for school places.
How much will the new school cost to build?
The new school will cost in the region of £2.2m a huge investment which will provide an environment for an excellent education that can be enjoyed by many future generations.
Will it cost more to run the new school?
No, as the new school will meet current building requirements it will be substantially more energy efficient and improved insulation and ventilation will ensure that the teaching environment will be comfortable throughout the school year.
Will there be any nursery provision?
Yes; the new school is being designed with a purpose built pre-school provision which will accommodate 32 two and three year old pupils each year.
Will any of the playing fields be lost due to the new school?
The new school will ensure that the car park, hard play areas, playground, and green space are retained.
Will the new school have a kitchen?
Yes; there will be a full cooking kitchen with a direct serving point on to the hall.
Will children have to move off site whilst the building work is being undertaken?
No; one the biggest challenges have been to ensure that children will not have to move off the current school site. Children will continue to be taught at the school during the building works.
How has the location for the school build been chosen?
The final location of the new school has been reached following numerous construction considerations including: environmental factors and flood risk, highway/parking risk and requirements, future proof for increased demand, operational and technical requirements, service/utility requirement/disruption, contamination on site and geology, construction and deliveries, site safety, and the phased demolish programme.
All construction considerations have had to ensure that the health and safety of children already attending the school is paramount and that the school can continue with the least amount of disruption.
When was the decision made about which option would go forward to the pre- planning consultation?
The decision was made after the full appraisal of the options; mid July.
The appraisal advice for the school location recommends a two storey school at the East of the site which will require the pool to be demolished.
Who is leading this development?
The Education Funding Agency is leading this project in collaboration with the school and the county council.
The EFA have commissioned Interserve as the developers.
When will the community be consulted on the redevelopment of the school?
The Public Consultation in respect to the redevelopment of St Lawrence CE Primary School will be held on Thursday 21st August, 3:30-6pm at the Grosvenor Centre (High Street, Gnosall, ST20 0EX) by Interserve developers.
What happens at the consultation event?
The planning consultation is based on the best location for the school following consideration as outlined above and the community will have an opportunity to comment.
When will the planning application be submitted?
Following the consultation; the planning application will be finalised and submitted September 2014
When will the new school be ready?
Subject to planning permission which may require conditions or changes, the new school will be ready in approximately 18 months time.
Frequently Asked Questions about the implication for the pool
Will the new school have a new pool?
No; pools are not included in the priority Schools Building programme.
Who owns the land around the pool and the pool, given that the community contributed money to building the pool and, later, the pool building?
The County Council owns the land, pool and school building.
Would the school be in a position to run the pool if it became an academy?
The school would still not receive any capital or revenue funding for the pool.
What about the registration of the pool as an asset of community value?
This is only relevant if the County Council decides to sell or lease the pool.
What was the outcome of the technical pool feasibility study?
The feasibility study covered decommissioning and emptying the pool during the redevelopment process, creating separate plant and changing rooms (both of which would need planning permission) and reopening the pool to current standards. The study also highlighted significant risks with separating the pool and that due to the age of the pool; it is difficult to assess what work would be needed to bring it up to the required standard. The cost of the work was estimated at being well over £500,000.
Where will school swimming lessons and other swimming lessons be provided?
Entrust Swimming Services supports schools with the provision of their swimming requirement, transport and timetable. Swimming Services would help to relocate swimming lessons to other facilities, such as Stafford Leisure Centre, unless the schools choose to make their own arrangements.