Planning Design & Access Statement Amendments to extant planning permission (RR/2007/397/P as amended by later permissions) for a kitchen extension to approved conference centre, extension to existing accommodation block, amended design and location for approved accommodation blocks, toilet/shower block and tenting area, relocate approved car park, new coach passing places, provision of a range of outdoor activities including a new activity lake, creation of bunds with fencing and landscaping. PGL Pestalozzi, Ladybird Lane, Sedlescombe, Battle, TN33 0UF
June 2019 Client: PGL Travel Ltd Report Title: Planning Statement
Contents
1. Introduction ...... 1 2. Need for the Proposal ...... 4 3. Site Description and Context ...... 6 4. Planning History ...... 9 5. Proposal ...... 14 6. Consultation ...... 31 7. Planning Policy Context ...... 37 8. Conclusions ...... 50
Prepared By: Oliver Collins Reviewed By: Martin Taylor Status: Planner Status: Principal Draft Date: May/June 2019 Review Date: May/June 2019
For and on behalf of GVA Grimley Limited t/a Avison Young
Date: June 2019 Client: PGL Travel Ltd Report Title: Planning Statement
1. Introduction
1.1 This Planning Statement has been prepared by Avison Young on behalf of PGL Travel Ltd (PGL). The Statement is submitted in support of a planning application seeking permission for changes to the design of and layout of buildings to that previously approved by permission RR/2007/397/P (as amended by subsequent permissions) and provision of activity structures in connection with the use of Pestalozzi International Village, Ladybird Lane, Sedlescombe, Battle, TN33 0UF. By adapting the approved masterplan layout for the site, it is considered that the proposals will fit better with the business model of the new owners and integrate better into the surrounding landscape.
1.2 Currently operating as the Pestalozzi International Village, the site currently comprises of a residential training centre (Class C2) use. This application does not seek to change that use. The application seeks consent for the following:
‘Amendments to extant planning permission (RR/2007/397/P as amended by later permissions) for a kitchen extension to approved conference centre, extension to existing accommodation block, amended design and location for approved accommodation blocks, toilet/shower block and tenting area, relocate approved car park, new coach passing places, provision of a range of outdoor activities including a new activity lake, creation of bunds with fencing and landscaping’.
1.3 In connection with the use of Pestalozzi as a residential training centre for young people, there has been a history of activities and events at the site; indeed, PGL operated a summer programme at the site a number of years ago with similar activities taking place up to the present day. In addition to moving the previously proposed accommodation blocks to a different location with a different design, adding a kitchen extension in place of other approved extensions to the conference centre, and adding a tenting area for summer use, these proposals include a number of fixed activity bases to provide a focus for educational learning experiences for young visitors.
1.4 The Site falls within the administrative boundary of Rother District Council, to whom this planning application is made.
Avison Young
1.5 Avison Young is the world’s fastest-growing commercial real estate services firm. Headquartered in Toronto, Canada, Avison Young is a collaborative, global firm owned and operated by its Principals. Founded in 1978, with legacies dating back more than 200 years, the company comprises approximately 5,000 real estate professionals in 120 offices in 20 countries. The firm’s experts provide value-added, client-centric investment sales, leasing, advisory, planning, management and financing services to clients across the office, retail, industrial, leisure & hospitality sectors. The firm has recently acquired GVA to expand its presence in the UK.
1.6 Hotels & Leisure is the specialist tourism and leisure advisory arm of Avison Young, with extensive experience of providing agency, valuation, viability, need assessments, development consultancy, planning advice, applications, appeals and expert witness evidence at planning inquiries for property development in the tourism and leisure sector.
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PGL Travel Ltd
1.7 PGL have been operating holidays, tours and courses since 1957.
1.8 Within the UK, PGL operate at 14 existing locations which comprise of purpose-built activities and equipment including climbing towers, ropes courses, swings and water sports, within indoor and outdoor spaces.
1.9 The programme of activities offered builds children’s confidence and the popularity of such adventure holidays with school groups has grown in recent years. PGL have therefore been expanding their operations by acquiring new sites within the UK.
1.10 PGL is recognised by the major activity governing bodies and is licensed by the Adventure Activities Licensing Authority (AALA) for a range of outdoor activities. PGL is a founder member of the British Activity Providers Association (BAPA), the School Travel Forum (STF) and a Learning Outside the Classroom Quality Badge holder.
1.11 PGL are continually seeking opportunities to deliver their product to suitable new markets. The customer types that they anticipate visiting Pestalozzi are as follows:
• UK Schools – predominantly travel during the week. Products are offered for both Primary and Secondary schools, with the majority being primary schools, aged 7 upwards. Schools provide the majority (around 80%) of PGL centre guests.
• Uniform Groups – mainly travel at weekends/during school holidays.
• Indies – individual guests aged 7 to 17, predominantly dropped off by their parents or by one coach per week. This product is delivered during the Easter, May, Summer and October school holidays.
• Families – parents/guardians and their children travel together, arriving by car. This product attracts very low volumes and is delivered during the summer holidays.
• International Groups – the product delivered to these groups includes our usual activities but also language tuition and excursions to local points of interest. These groups can travel throughout the year, but mainly in July. Demand for this product is strongest in the South East of England.
• NCS (National Citizen Service) – travel each summer and during half term school holidays, the young people travelling under this Government sponsored scheme are aged 15-17 years.
Staff
1.12 PGL recruit from the local community and further afield. PGL offer accommodation for those that do not live within commuting distance and this is especially popular given the rural nature of some of their sites like Pestalozzi.
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Supporting Statements
1.13 This application is accompanied by this Planning Statement and the following supporting plans and statements:
• Application Form, including Certificates of Ownership
• Drawings (see 4174 Drawing Issue Sheet)
• Transport Statement, Travel Plan and Traffic Management Plan
• Flood Risk Assessment and Drainage Strategy Report
• Archaeological Assessment
• Preliminary Ecological Appraisal
• Arboricultural Report
• Landscape and Visual Impact Assessment
• Noise Impact Assessment
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2. Need for the Proposal
Background
Purpose
2.1 PGL specialises in providing activity course/holidays for young people between the ages of 7 and 17, making an important contribution in creating opportunities for young people. PGL centres offer experiences which engender confidence and a sense of personal achievement in a range of youngsters, who might not ordinarily be exposed to these challenges.
2.2 Due to increasing demand for these adventure holidays PGL are looking across the UK for new sites, particularly in the South East, to accommodate this need, of which the Pestalozzi International Village site with its established use as a residential training centre for young people, represents an ideal opportunity. It would complement their existing portfolio which already comprises a range of activity centres supported by extensive countryside estate grounds.
Need
2.3 Given its location, an activity centre based at Pestalozzi would primarily serve areas within South East, where it can easily serve locations such as Greater London and around the M25 corridor, Ashford, Canterbury and Dover, as well as Brighton, Portsmouth, Southampton and Bournemouth. These are areas where demand for residential outdoor education is strong and growing and existing PGL sites have to turn away enquiries during the summer term as they are already booked out. The proposal would therefore help support our client to satisfy the growing demand in this market and make this type of educational experience more available to children in the South East.
2.4 Various national tourism, health and sport strategies highlight the importance of the tourism industry to the UK economy, as well as the importance of providing accessible opportunities for children to stay active, have regular physical activity and improve their physical and mental health and these are discussed briefly below:
2.5 Visit England’s Strategic Framework for Tourism in England 2010-2020 and its associated industry action plans are the product of extensive consultation and collaboration with England’s tourism industry. It sets out the way in which the industry can work together to achieve a five per cent growth in value, year on year, over the decade. This will lead to an additional £50 billion in expenditure and the creation of 225,000 jobs.
2.6 The Strategic Framework’s 10 year vision is driven by four independent objectives. They are designed to capitalise on the growth opportunities of England’s visitor economy.
• Objective 1: Increase England’s share of the global visitor market;
• Objective 2: Offer visitors compelling destinations of distinction;
• Objective 3: Champion a successful, thriving tourism industry;
• Objective 4: Facilitate greater engagement between the visitor and the experience.
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2.7 The proposals directly address these objectives in that the provision of accommodation will facilitate an increase in England’s share of the global visitor market, provide high quality accommodation in a distinctive well landscaped and nature sensitive destination, and facilitate greater engagement between the visitor and their experience of the area.
2.8 In their Tourism Policy (2011) the Government note that:
Tourism is an often underestimated but tremendously important sector of the UK’s economy. It’s already one of our six biggest industries and our third-largest export earner. It accounts for almost £90bn direct spend each year, contains over 200,000 businesses and provides 4.4% of our nation’s jobs. Equally importantly, it creates wealth and employment in all parts of the country, not just the south-east, and it’s a cost-effective way to regenerate run-down communities. A thriving tourism industry creates beautiful places to visit all around the country, which also improves the quality of life for everyone who lives near them as well.
2.9 One of the principal aims of the policy is to:
Increase the proportion of UK residents who holiday in the UK to match those who holiday abroad each year. For longer stays (4 nights or more) this would mean 29% of travellers holidaying in Britain rather than just 20% today (creating 4.5 m extra domestic trips each year, £1.3 bn more spend and 26,000 new jobs). And if we can replicate this scale of improvement for shorter stays as well, we will create a further £750m of spend and 11,000 new jobs.
2.10 The proposals in this application will facilitate this aim to increase domestic tourism.
2.11 The Tourism Action Plan (2016) identified the five key themes, Tourism Landscape; Jobs and Skills; Transport; Common-sense Regulations and Great Welcome. The plan includes a series of new initiatives and measured which outline how the government will deliver on its vision to help Britain out-compete other major tourism destinations, welcoming more visitors than ever before and see more staycations as Brits holiday at home.
2.12 The proposals within a well landscaped setting providing jobs and a greater welcome from an established operator addresses four of these themes.
2.13 The need for developments such as has become all the more pertinent and vital due to recently publicised increases in childhood obesity and a growing desire to encourage more children to participate in sporting activities and outdoor pursuits. The Government’s ‘Childhood obesity: a plan for action’ report (June 2018) discusses this issue at length and highlights how childhood obesity is “one of the biggest health problems this country faces. Nearly a quarter of children in England are obese or overweight by the time they start primary school aged five, and this rises to one third by the time they leave aged 11. Our childhood obesity rates mean that the UK is now ranked among the worst in Western Europe.” This report also makes it clear that Local Authorities can “partner with leisure and sport facilities to offer accessible physical activity opportunities and confirms that regular physical activity has been linked not only to improved physical health but also improved mental wellbeing and academic attainment.”.
2.14 These proposals therefore address the objectives of local and national Government planning and health policy in terms of getting children more active, improving children’s physical and mental health and expanding out-of-class learning opportunities in areas such as the countryside.
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3. Site Description and Context
Site Location
3.1 The site lies in a sustainable location in Sedlescombe in the district of Rother, East Sussex. The site is located in Sedlescombe which is a village around 10km (6.5 miles) to the north of Hastings. The village consists of mainly residential development, as well as a hotel and restaurant, a primary school, a pump house historical landmark, a doctor’s surgery, post office, village hall and a pub. The proposal site itself lies to the south of the main cluster of the residential area. The main entrance for the site is accessed where the B2244 meets Chapel Hill and the B2244 then joins up with the A21 and provides access to Hastings to the south and Royal Tunbridge Wells 38km (24 miles) and ultimately London to the North West. Figure 1 below shows the location of the site in this context.
Figure 1: Location of site in context of surrounding settlements
Sustainable Location
3.2 The site is not reliant on the use of private motor cars, supporting journeys by bus, coach, train and on foot. Bus stops are located along Chapel Hill/B2244 near to the entrance to the park. This bus stop, along with another 3 minutes’ walk from the site entrance in the village provides services for the 349, 360, 383, B67, B74 and B75 routes towards Hastings Town Centre, Pebsham and Robertsbridge.
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3.3 The site is a 10 minute drive to Battle Railway Station. This station forms part of the Southeastern service to and from London and calling at Orpington, Sevenoaks, High Brooms, Tunbridge Wells, Robertsbridge and Hastings. Most of PGLs guests arrive by coach, significantly reducing the amount of traffic that would generated if they came by private car. The site is well located to bring guests by coach being so close and well connected to the A21 trunk road.
Site Context
3.4 Figure 2 below shows an aerial photo of our client’s site. The overall ownership extends to approximately 55 hectares (136 acres) as seen in the Site Location Plan (Ref: 4174-MP-100A). The northern part of the ownership surrounds Oaklands Manor, a small cluster of residential development. Sedlescombe Sports Field, the River Brede and other open green field land adjoin to the north. To the North West is the main residential area of the village of Sedlescombe. The eastern part of the application site is surrounded by woodland and greenfield land. The site is bounded by a small number of residential properties on Cottage Lane, well screened on all sides by an existing tree boundary, lying to the south. The western boundary of the children’s village borders residential properties, the Chapel on the Hill Sedlescombe URC Church.
Figure 2: Aerial Photo of Pestalozzi site and its surroundings (Google Maps)
3.5 In terms of flood risk from rivers and sea, the application site lies in Flood Zone 1 (Figure 3) meaning that it has a low probability of flooding. An area of land in the ownership of the wider estate to the north of the application site lies in Flood Zone 2 and 3 and therefore has a medium-high probability of flooding. There are
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no proposals affecting this land which is not included within the application area. A Flood Risk Assessment is submitted with this application.
Figure 3: Extract from Environmental Agency Flood Map for Planning
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4. Planning History
4.1 The following applications for the Pestalozzi site were found online on Rother District Council’s website:
Table 1: Pestalozzi Site Planning History
Application No Description Decision Decision Date RR/2003/3056/P Deposit of spoil on nearby land arising from extension of Approved 19/02/2004 Sedlescombe sports field car park, piping short stretch of ditch at edge of new car park area RR/2007/282/P Construction of Pestalozzi garden including a strawbale Approved 14/06/2007 classroom including rooflights, storage shed, greenhouse and formation of new vehicular access and pedestrian accesses.
RR/2007/3010/T Pollard twenty Lombardy poplar trees. No 12/12/2007 objection RR/2007/397/P Part demolition of existing and construction of replacement Approved 08/01/2008 buildings including improved conference, dining, administration & education facilities, accommodation including roof lights and associated works including parking and alteration to an existing access. RR/2007/378/P Outline: erection of 6 dwellings with alteration to an existing Approved 08/01/2008 access RR/2008/953/P Erection of Polytunnel Approved 24/06/2008
RR/2009/3089/P We propose to build a temporary climbing & abseiling tower Approved 24/02/2010 at this site. It will be 4m x 4m x 8m high made from wood & metal. The structure will have internal ladders, so staff & groups can access the top for set up & abseling. Two faces will have wooden scaffolding planks fitted to them to enable groups to abseil & climb. The other two faces will have camoflage netting fitted to allow the tower to blend in with the surroundings. The tower will also be fitted with a secure gate thus denying access when the tower is not in use. RR/2010/2134/P Variation of conditions 4, 10, 12, 13, 15 and 16 on Approved 15/11/2010 RR/2007/397/P RR/2010/2979/P Temporary abseiling tower Approved 22/02/2011
RR/2010/1264/P Proposed relocation of approved conference block to site of Approved 30/03/2011 approved administration block necessitating relocation of administration block following planning permission RR/2007/397/P RR/2010/1671/P Proposed residential development comprising of 6 no. Approved 31/03/2011 Detached dwellings with detached garages. Proposed access road and soft/hard landscaping proposals. Full approval sought following granting of outline approval for 6 dwelling development. RR/2007/378/P. RR/2011/2348/T Group of 18 poplars - fell. No 21/12/2011 objection RR/2012/1069/P Drawing no.3999.10 rev a to replace 3999.10 approved under Approved 21/06/2012 condition 17 of RR/2010/1671/P in relation to boundary wall RR/2012/2431/P Variation of condition 17 imposed on RR/2010/1671/P to allow Approved 11/02/2013 revised alignment and height of front boundary wall at plot 6. RR/2013/209/P Variation of condition in respect of approved plans - Approved 21/03/2013 amendments in relation to fenestration. RR/2014/1341/P Variation of conditions 4, 10, 13, 15, 16 & 20 of RR/2007/397/P Approved 26/08/2014 to allow phasing of development
RR/2014/2182/P Modification of section 106 to close the South Gate imposed Refused 22/10/2014 on planning permission RR/2007/378/P (Condition 6), RR/2007/397/P (Condition 8), RR/2010/1264/P (Condition 1), RR/2010/1671/P (Condition 4), RR/2010/2134/P (Condition 1) to allow the additional use of the South Gate between the hours of 07:00hrs and 20:00hrs for service vehicles, construction traffic and events traffic. RR/2014/70/P Variation of condition to close the South Gate imposed on Refused 23/10/2014 planning permission RR/2007/378/P (Condition 6), RR/2007/397/P (Condition 8), RR/2010/1264/P (Condition 1),
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RR/2010/1671/P (Condition 4), RR/2010/2134/P (Condition 1) to allow the additional use of the South Gate between the hours of 07:00hrs and 20:00hrs for service vehicles, construction traffic and events traffic. RR/2015/2292/P Modification to existing S106 planning obligation to remove Undecided 09/11/2015 restriction on the Escrow Account which limits withdrawals to 50% of the original deposit until practical completion of the Pestalozzi Works (as set out in the S106). RR/2015/861/DC Submission of details required by conditions 10, 12, 13, 15 and Discharged 03/06/2015 16 imposed on planning permission RR/2007/397/P – conditions 13 &15 subject to final report
4.2 Application RR/2007/397/P, approved in January 2008, provided a new masterplan for the area giving permission for part demolition of existing and construction of new and replacement buildings including improved conference, dining, administration & education facilities, two accommodation blocks and associated works including parking and alteration to an existing access. The approved Site Plan for the area is seen below in Figure 4.
4.3 There were 20 conditions on this permission and those requiring discharging have been mentioned below:
• The colour and texture of the external materials to be used on the bunk accommodation and estate management building was to be subject to the approval of the Rother District Council, with a sample of the proposed materials to be submitted for consideration pre-commencement.
• Submission of times of proposed planting pre-development to the Local Planning Authority
• The improved western access had to be laid out and constructed in accordance with East Sussex County Council standards and to the satisfaction of the Highway Authority pre-occupation.
• Vehicle wheel washing equipment had to be provided during any form of earthworks or excavations, to the approval of the local planning authority, to prevent contamination.
• Submission of a surface water regulation system pre construction of any impermeable surfaces draining to the system
• Scheme for provision and implementation of foul and surface water drainage works
• Contaminated land assessment and associated remedial strategy, with timetable of works
• Implementation of programme of archaeological work
• Submission of details of appearance of surface finish of proposed car park to be approved by local planning authority
• Submission of details of alternative position for bottle bank recycling area to be approved by the Council
• Submission of details of any floodlighting or external illumination to be approved by local planning authority pre-installation of new lights
4.4 The Council has confirmed the implementation of this permission in the recent pre-app letter stating that “it is considered by the Council that lawful commencement has been made on the development approved under RR/2007/397/P and the planning permission is extant”. The officer has also confirmed that the development undertaken was the minimum amount of development necessary to satisfy the ‘village’
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refurbishment requirements in the Section 106 agreement involving the cross subsidy received from the sale of the housing land granted planning permission under RR/2007/378/P. This letter also confirms that the above conditions were discharged.
Figure 4: Site Plan approved with 2007/397
4.5 A modification to a Section 106 updated in March 2011 (original document not online) reveals that the owner submitted a minor amendment application to amend the development by abandoning the extension of Sainsbury House (RR/2007/397/MA).
4.6 An application was approved in November 2010 to vary conditions 4, 10, 12, 13, 15 and 16 from permission RR/2007/397/P (RR/2010/2134/P). This was approved and involved the exclusion of works at Sainsbury House as the unit was refurbished but not extended and thus the conditions were not to be applied in that area anymore. This was approved with various conditions including submission of proposed times of planting, provision and implementation of a surface water regulation system, foul surface drainage works, a programme of archaeological work, timetable of works for all ecological and wildlife impact mitigation measures and a contaminated land assessment and associated remedial strategy. Approval was given subject to the remaining conditions 1-3, 5-9, 11, 14, 17-20 of the previous permission 2007/397/P which therefore remain in force. The approved Site Location Plan for the area is seen below in Figure 5.
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Figure 5: Site Location Plan approved with 2010/2134/P
4.7 An application was approved in March 2011 for the proposed relocation of approved conference block to site of approved administration block necessitating relocation of administration block following planning permission RR/2007/397/P (RR/2010/1264/P). A condition of this application stated that is was a modification to the earlier permission of RR/2007/397/P and thus conditions 1-20 still remain in force.
4.8 Application RR/2014/1341/P involved the variation of conditions (4, 10, 13, 15, 16 & 20) attached to RR/2007/397/P. This new permission has a condition which states that the old unamended conditions of the old permission (1, 2, 3, 5, 6, 7, 8, 9, 11, 12, 14, 17, 18 & 19) together with the amended conditions in the new permission all remain in force. Proposed times of planting and a provision and implementation of a surface water regulation system were additional conditions on this permission. The Site Plan for this application is seen below in Figure 6.
Figure 6: Site plan approved with 2014/1341
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4.9 An application was part approved for the submission of details required by conditions 10, 12, 13, 15 and 16 imposed on planning permission RR/2007/397/P (RR/2015/861/DC). The Council’s pre-app letter comments that there was an agreement of details in respect of conditions 10, 11, 12, 13, 15 and 16. It states that conditions 13 and 15 can only be fully discharged when final reports have been submitted to the local planning authority in accordance with the requirements of the condition.
4.10 There have been two applications to bring the South Gate into use (RR/2014/2182/P & RR/2014/70/P) and both have been refused.
4.11 Application RR/2010/1671/P gave detailed approval for 6 residential dwellings pursuant to outline permission RR/2007/378/P. The 17 conditions on this permission included the pre occupation provision of appropriate signage and information giving access details and agreed by the local planning authority in consultation with the Highway Authority. Other conditions related to a programme of archaeological work. These have now all been built as Oaklands Manor and extracts from the approved plans can be seen in Figure 7.
Figure 7: Pre-existing and new site plan approved with 2010/1671/P
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5. Proposal
Application Description
5.1 The application is submitted with the following description:
Amendments to extant planning permission (RR/2007/397/P as amended by later permissions) for a kitchen extension to approved conference centre, extension to existing accommodation block, amended design and location for approved accommodation blocks, toilet/shower block and tenting area, relocate approved car park, new coach passing places, provision of a range of outdoor activities including a new activity lake, creation of bunds with fencing and landscaping.
Proposed Use
5.2 The use of the site will be maintained as a C2 use class (residential training centre) accompanied by an improved range of outdoor activity equipment.
5.3 PGLs target customer group is school aged children between 7-17 years. In addition, PGL offers independent holidays for other groups of children and for families through the Family Active holiday programme. Courses offered are typically 3, 5 or 7 days in length with the shorter stays more popular between March-June and September-October and the longer weekly stays generally more popular over the summer period.
5.4 The PGL courses enable engagement in a variety of organised sporting/outdoor adventure activities which test both physical and mental abilities while helping to improve a young person’s social skills by engendering teamwork. For this reason, PGL intend to provide new outdoor activity structures.
5.5 While all activities would be based on-site, there will be an opportunity for day-trip excursions to local places of interest such as Bexhill, Hastings, Brighton and London. However, due to the type of development proposed (a residential centre) and its location, this will only occur occasionally as groups tend to make use of the on-site activities they have paid to use.
Capacity
5.6 The extant permission RR/2007/378/P allows for guest accommodation in the existing Sainsbury House and two accommodation blocks north of the Education Building (Songsten Khang & Trisong Ngonga) and two, as yet to be built accommodation blocks to the west of the Education Building. There are also a number of units of existing staff accommodation including the Chief Executive’s House, and the VW Houses. As with any landowner, PGL also have the permitted development right to use the surrounding fields for any temporary use, including camping for up to 28 days each year. This right relates to each discrete field and could be used in rotation to accommodate guests in tents on a different field at the site each month.
5.7 The submitted application allows for an average 6.32 sq m of floorspace for children and teachers in the proposed accommodation blocks, and for 16.81 sq m of space per PGL staff member in the existing refurbished and extended accommodation buildings. By applying these floorspace occupancy ratios to the existing and permitted buildings, PGL consider that the extant permission would allow them to host up to 493
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children and teachers and up to 84 PGL staff in built accommodation, and a further 200 children and 26 teachers in tents during the summer months. Any additional PGL staff requirement during the summer could also be accommodated in tents (see table below).
Table 2: Pestalozzi Existing and Permitted Accommodation Capacity (Summer with Tents)
Unbuilt Extant Permission Sq M Persons Use Block One 780 123 guests Block Two 780 123 guests Pestalozzi A 312 19 staff Pestalozzi B 361 57 guests Chief Exec’s House Extension 10 1 staff Existing Built Pestalozzi C (6) 375 dining Chief Execs House (7) 156 9 staff VW Houses (8) 235 14 staff Sainsbury House (1) 1195 189 guests Songtsen Khang Accommodation (5) 548 33 staff Trising Ngonga Accommodation (4) 148 9 staff Total built and extant 4900 Guest Total (teachers and children) in buildings 493 Staff Total in buildings 84 staff Guest Total (teachers and children) in Tents 226 guests Guest Total (tents and buildings) 719 guests
5.8 This application does not seek to increase this existing site capacity, merely to relocate that permitted capacity into buildings that better suit the PGL business model. It is proposed that the two accommodation blocks to the west of the Education Centre would no longer be built. Instead, two new guest accommodation blocks accommodating up to 480 guests (426 children, 54 teachers) would be sited to the north of the recently built conference centre.
5.9 The conference centre already has permission for three more extensions; one to the north, two to the south. These would not be built; instead, one of the proposed accommodation blocks would lie over the approximate position of one of the permitted extensions, and the existing conference centre itself, would be converted to a dining room through the addition of a kitchen which would be attached to the west of the centre lying just north of one of the permitted extensions.
5.10 An area for 53 tents accommodating up to 200 guests and 26 leaders/teachers is proposed to the south of the existing conference centre lying partially over the area of two permitted extensions to that centre. Each tent would be erected over a concrete base in late April/early May and taken down again at the end of September. The concrete bases would be dyed green to negate any impact on the landscape in winter. A toilet and shower block, including teacher’s lounge facilities, for camping guests would be erected at the centre of the camping area, just south of the two extensions that were permitted to the conference centre, and in a dip in the land to the north of the existing prayer hut.
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5.11 In addition, the existing guest accommodation in Sainsbury’s House, Songsten Khang and Trisong Ngonga would be refurbished as staff accommodation, with the (former) Chief Executive’s House and VW Houses remaining and refurbished as staff accommodation.
5.12 Overall, these proposed changes would provide a summer capacity for 706 guests (626 children and 80 teachers) and 140 PGL staff to sleep on site. This does not mean that there would ever be that many guests sleeping on site. Due to the nature of the business with group bookings, it is not possible for PGL to fill their sites to the available capacity. There is a requirement that not only are groups accommodated in their own rooms (rather than mixing school groups), but that girls and boys within those individual school groups are accommodated separately. This will naturally lead to a percentage of the bed spaces within rooms and tents, and a number of the rooms and tents themselves being left unoccupied at any one time. PGLs experience at other sites is that it has to provide approximately 10% more bed spaces than actually required.
5.13 As an example, PGL Bawdsey Manor (chosen as it also has indoor and tented accommodation, as well as a range of products) has a guest bed capacity of 584 and PGL sell to a capacity of 499. Figure 8 below shows their sales pattern in 2019 for PGL Bawdsey Manor:
Bookings for PGL Bawdsey Manor in March-November 2019
600 Bednights 500
400
300
200
100
0 18/03/2019 18/04/2019 18/05/2019 18/06/2019 18/07/2019 18/08/2019 18/09/2019 18/10/2019 18/11/2019
Figure 8: Booking figures for PGL Bawdsey Manor In 2019
5.14 The graph shows the peak season for PGL sites is as expected during the school summer term months of May, June, and July, reaching a mid-week peak of 400 - 500 bed nights, despite having an actual room capacity of 584. It can also be seen that even during this time use of the site at weekend’s falls to less than 50 to no more than 200 guests. As can be seen from the graph, demand does vary greatly through the year, with demand outside of these three summer term months resulting in between 30 and 300 guests sleeping on site and with the site being effectively closed during the winter months from the end of October into late February. Nevertheless, PGL does have the advantage of good quality accommodation and high standard activities and the aim is to offer an all year round operation where possible. No restriction on the seasonal operating period is therefore appropriate.
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Travel
5.15 The main arrival and departure days for schools and other groups are Monday, Wednesday and Friday – although at Pestalozzi it is envisaged that a small number of groups booking trips will start and/or finish on other days of the week. The small proportion involved means that this is not materially significant.
5.16 Coach departures and arrivals are generally mid to late morning, early and mid-afternoon and so outside of peak hours. Choices made by certain groups (for example to visit a local site of interest on the way to PGL) can lead to a small number of coach movements outside of these times.
5.17 International groups and a very small number of other groups do take excursions as part of their holiday package. These can also take place on days other than the main arrival/departure days (Mon/Weds/Fri) and these can involve early morning, mid/late evening movements.
5.18 Family and independent holiday arrivals and departures mainly take place on a Saturday; however arrivals on Monday and Tuesday as well as departures on a Thursday and Friday are also possible for a smaller number of PGLs holiday products.
5.19 On departure day guests would typically undertake their final morning activity and then have lunch before they leave site. Their coach would arrive between 10am-12pm; once the guests have eaten they would board and depart around 1pm-1:30pm. This window of time gives the driver a chance to rest before setting off again. Coaches will be parked in the car parking area. Normally, guests arrive between 3-5pm. There will be a small proportion of schools that might arrive later and/or leave straight after breakfast if they have a long way to go.
Child Supervision and Safety
5.20 All children are supervised day and night during their stay. School groups are supervised by both their own teachers and school staff at a ratio of 1:8. Youth groups such as brownies and cub scouts are supervised by their own leaders and parents at the same ratio. Individual guests would be supervised by PGL staff acting in “loco parentis” (in the place of a parent).
5.21 On arrival, children would join a small group of similarly aged children in the care of a Group Leader (or ‘Groupie’) to ensure that they are in the right place at the right time for meals, activities etc. Our Groupies are recruited for their exceptional interpersonal skills, chosen for their ability to care for and communicate effectively with children. Responsible for children’s social welfare, they would be the child’s main daily contact. Groupies would supervise their group of children at all times when not on an activity or in their rooms at night time.
5.22 During the day and early evening, children would be supervised by activity instructors during activity times and by their teacher, youth leader or Groupie during all other times. Children would be regularly head counted during their day and all PGL staff follow a set regime to check in on participants’ welfare and conduct.
5.23 During activities, the minimum ratio of PGL instructional staff to guests is 1:12.
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5.24 During the evening, children would be supervised until they are in their rooms ready for bed. During the night, there is a duty management team in charge of the whole centre, as well as specific teams looking after the individual children. These specific teams will be awake and available all night, conducting regular checks.
Activity Programme
PGL operate with managed groups of 12 guests doing up to 4 activity base sessions per day, two in the morning, two in the afternoon. Entertainment is arranged in the early evening. Figure 9 provides an example timetable of activities for groups. The timetabled use of activity bases would run from 9am until 5/5.30 pm with evening entertainment running until no later than 9.00pm.
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Figure 9: Example Activity Timetable
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5.25 The following sections provide a more detailed account of how a typical day at the centre would be structured.
How the day is structured:
5.26 A structured programme is agreed with all schools to keep children engaged and active. Each group is split into smaller groups of 12 pupils with 1 or 2 PGL instructors depending on the activity. PGL ask that teachers or groups leaders are present during activities to supervise those who are waiting their turn. PGL staff takes the role held by teachers. Therefore, the groups of 12 are well supervised at ratios above their normal school day experience.
Morning
5.27 Breakfast is staggered to reduce the amount of queuing; it typically takes a group c. 40 minutes from joining the queue to leaving the dining room. If there is any free time before or after breakfast the groups will typically be supervised by the PGL Groupie with support from their teachers. Tidying rooms, ensuring appropriate clothing is available for the mornings activities, answering questions about the day are typical activities.
Activity Sessions (9.00am to 12.00pm)
5.28 The activity timetable is managed so that groups take part in a variety of activities during their stay to meet their objectives for the trip. Sessions are typically 1.5 hours long – with two sessions each morning and afternoon. At the meeting point the Groupie will hand over the group to the Activity Instructor who will then lead the group to the relevant activity base.
5.29 Each session has an operating procedure. A typical session will have an explanation, demonstration and instructional aspect before participation, followed by a de-brief. All these aspects are led by the PGL Activity Instructor(s). Activities have varying levels of group participation. If the activity has periods of time where the whole group are not involved there are tasks set to keep guests engaged, under the supervision of the teacher.
5.30 Between sessions, groups are led from one activity base to another, via the meeting points by the instructor and under the supervision of the accompanying teacher. At the end of the session the instructor will hand back the group at the meeting point to the Group Leader with the accompanying teacher present.
Lunch (12.00pm to 2.00pm)
5.31 It typically takes a group c. 40 minutes from joining the queue to leaving the dining room. A ‘tuck shop’ visit is booked which typically takes 30 minutes. The remainder of the time is taken with changing clothes from the mornings activities and preparation. There are no activities at this time so the opportunity to use indoor spaces for ad hoc games is always available, led by a Groupie and supervised by teaching staff.
Activity Sessions (2.00pm to 5.00pm)
5.32 As per the morning sessions.
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Evening Meal (5.00pm to 7.00pm)
5.33 Typically it takes a group c. 50 minutes from joining the queue to leaving the dining room. The time is also often used by teachers to reflect on the day with the group and discuss learning outcomes. PGL staff also start to prepare the group for the following day before evening entertainment.
Evening Entertainment (7.00pm to 9:00pm)
5.34 PGL has a variety of indoor and outdoor team events delivered by Group Leaders and where appropriate including further Activity Instructors. PGL will also ask teachers to join the evening session. These sessions do not use the activity bases. They last about 1.5 hours and will take place in buildings and spaces away from any residential boundaries.
Bed Time (9.00pm/9.30pm)
5.35 Evening entertainment stops at 9.00 pm and the children return to their accommodation for bed. Given the average age of PGL guests, most pupils are tired and quickly return to rooms to sleep. Teacher rooms are interspersed amongst the children’s rooms to carry out supervision. Night support staff are available to support teachers in the rare occasion they are needed e.g. illness.
PGL and their Neighbours
5.36 PGL are an integral part of the communities in which their centres are located and enjoy a good relationship with them. The virtual tours available on the PGL website have aerial footage which provides a good indication of the types of locations their centres have and the proximity of their neighbours. For example,
• Barton Hall (http://www.pgl.co.uk/en-gb/school-trips/primary-schools/centres/barton-hall) and
• Little Canada (http://www.pgl.co.uk/en-gb/school-trips/primary-schools/centres/little-canada)
5.37 These properties have a large number of residential properties as direct neighbours, while the following are located on the edges of villages;
• Windmill Hill (http://www.pgl.co.uk/en-gb/school-trips/primary-schools/centres/windmill-hill) and
• Marchants Hill (http://www.pgl.co.uk/en-gb/school-trips/primary-schools/centres/marchants-hill)
5.38 Access to other centres is via villages and other populated areas. Indeed, one Centre operated by one of their competitors, Grosvenor Hall near Ashford in Kent, is an ex-Police Training Centre and has residential properties along its boundary, as can be seen from the front page of their webpage (http://families.kingswood.co.uk/locations/grosvenor-hall/).
5.39 At the start of 2019, PGL made contact with the Parish Council, the residents at Oaklands Manor and Oaklands Park, and a number of residents on Cottage Lane. The residents were invited to and attended a public exhibition and consultation event on Tuesday 14th May. PGL presented their proposals to the Parish Council at their meeting the same day. A second public exhibition was held with a wider group of residents, including people from the village, on 5th June. A number of amendments have been made to the plans to
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address comments made during these meetings. This is discussed in detail in Section 7 of this Planning Statement.
5.40 There are several measures that PGL hope to introduce at the Pestalozzi site that aim to encourage a positive relationship with the neighbours and the local community. These include but are not limited to:
• Green dyed concrete bases for the tented village that will negate any visual intrusion in the landscape;
• The fixed activity base structures will not be used in the evening;
• Amending the proposals in response to consultations and a noise assessment to move the activity bases to positions where they will have least impact on neighbours when they are in use;
• Relocating the permitted accommodation blocks further from adjoining residents; and
• Moving the permitted car park further away from adjoining residential properties.
Public Access
5.41 The majority of the Pestalozzi site does not contain any public rights of way. However, as seen in Figure 10 below, the northern part of the estate has a public right of way going through it, adjacent to the River Brede and the Sedlescombe Sports Field. The proposed development will not have any impact on this public footpath.
Figure 10: Public Rights of Way Map (Bing Maps)
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Proposed Development
5.42 The proposed development can be divided into three parts; replacement buildings and extensions; a seasonal tenting area, new activity bases.
Replacement Buildings and Extensions
5.43 The following provides detail of the scale and layout proposed within each building.
Guest Accommodation Block One (320 beds)
5.44 In place of one of the two-storey accommodation blocks given permission in the field to the west of the Education Building in the approved Pestalozzi masterplan, this application proposes an L-shaped two storey accommodation block on the site of a former building (now demolished) to the north of the conference centre that also has extant permission for the building of a maintenance yard (labelled as No 14 on the drawing Proposed Site Plan Ref 4174-MP-200P13).
5.45 This building will be clad in cedral, a timber composite material, in sympathy with the rural and wooded surroundings; the site for this building retains the trees and hedges that used to surround and screen the original building. The building will have a mix of teacher, guest and accessible rooms providing for up to 320 guests.
Guest Accommodation Block Two (160 beds)
5.46 In place of the other two-storey accommodation block given permission in the field to the west of the Education Building in the approved Pestalozzi masterplan, this application proposes a second two storey accommodation block directly to the north of the conference centre on land that has extant permission for an extension to the conference centre (labelled as No 15 on the drawing Proposed Site Plan Ref 4174-MP- 200P13). The accommodation block has been carefully sited to avoid any large established trees.
5.47 This will also be a cedral-clad building in same design as the accommodation block above. The building will also have a mix of teacher, guest and accessible rooms providing for up to 160 guests.
Pestalozzi Conference Centre Dining Hall Conversion and Kitchen Extension
5.48 The existing conference centre (labelled as 6 on the Proposed Site Plan Ref 4174-MP-200P13) will be converted to a dining hall with a new terrace on the south side. A new extension is proposed on the west side of the existing building to provide a kitchen (labelled as 16 on the Proposed Site Plan Ref 4174-MP- 200P13). This is in replacement for the permitted western extension of the conference centre in the Pestalozzi masterplan that still has extant permission.
5.49 The proposed kitchen extension will be clad in similar materials to the existing conference centre. There will be a small service yard to the west of the kitchen (labelled as No 16a) and a small service/maintenance yard to the north of the dining hall (labelled as No 17).
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Seasonal Tenting Area
5.50 A seasonal tenting area for 53 tents will be laid out in four clusters surrounding a timber clad toilet and shower block (labelled as No 13 on the Proposed Site Plan Ref 4174-MP-200P13). Each tent will be a beige coloured frame tent erected each May over a concrete base and taken down again at the end of September. The concrete bases will be dyed green to negate any impact on the landscape in winter. There will be 40 tents to accommodate 5 guests each and 13 tents accommodating two teachers each, giving a total of capacity of 226 guest children and their teachers. Figure 11 highlights an example from the PGL site at Bawdsey Manor of an existing tenting village.
Figure 11: Photos of example of Tenting Village
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Proposed vs. Existing Building Footprint
5.51 The table below reveals that the total un-built floorspace of buildings permitted by the current extant permissions is 2922m2. By comparison this application proposes 3626m2 of new floorspace, a net increase over the original permission of 704 sq m. Many of the proposed building are on the site of approved, but as yet un-built, buildings. It therefore follows that if the proposed buildings are permitted and built the previously approved building could not be physically built. In any event, once any part of the proposed application is built, if permitted, then this would supersede the previous permission within the application site and extinguish the right to build any of the currently extant buildings that had not already been built.
Unbuilt Extant Permission Sq M Block One 780 Block Two 780 Pestalozzi A 312 Pestalozzi B 361 Pestalozzi D 319 Ces House Extension 10 Estate Management Building 360 Total extant 2922 PGL Proposed Block One 2142 Block Two 892 Staff Accommodation Extn 72 Pestalozzi Kitchen Extn 330 Tent Village Amenity Building 190 Total new 3626 Net increase 704
5.52 Despite the possibility of PGL utilising the extant permission on the site, our client believes that the currently approved buildings would not provide the quality of offer provided at other PGL sites and would be likely to cause neighbouring residents greater disturbance than in this proposal.
Activity Bases
5.53 Within the Site grounds, the proposal would see the introduction of the following activity equipment structures:
• Swings
• Four-sided Abseil Towers
• Climbing Wall
• Five line Zip Wire
• Linear Ropes Courses
• Lake for canoeing, kayaking and rafting
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Swings
5.54 The swing involves two 13m high timber swing poles 7m apart and a 15m high timber hoist pole (Figure 12). The timber hoist pole will be no higher than the existing mature trees already situated on this part of the site, therefore successfully integrating into the surrounding landscape. The swing poles would be joined by a cross beam, secured by four guy wires and set in 2m deep concrete footings. The hoist pole would be secured by three guy wires and set into a circular hollow section (CHS) mild steel tube (0.9m2 ). Each guy wire would extend at 45o (+/-5o) to secure.
5.55 The swings would be sited back to back in pairs in order to each utilise the one hoist pole. The pairs would be sited to make use of trees to provide a setting as a visual backdrop. The swings are labelled as the letter ‘E’ on the drawing Proposed Site Plan Ref 4174-MP-200P13). Please see Drawing 4174-AA-204A for further detail.
Figure 12: Photos of example Swings
Abseil Tower and Climbing Wall
5.56 The abseil tower provides four faces for abseiling (Figure 13). Posts would be set in a square shape 3.5m apart, buried 2m into the ground and backfilled with compacted Type 1 material or concreted into place as appropriate for ground conditions. The tower would be clad in timber boarding with diagonal timber braces for support. The top platform would be surrounded by a proprietary steel guard rail system on two sides. Access to the top of the tower would be by a series of internal stairs with platforms from ground level. The top standing platform of the tower would be approximately 10.5m high with eaves 3m above. A four sided pitched roof would mean the tower reaches approximately 15.15m in height.
5.57 The double sided climbing wall would provide a structure for climbing activities (Figure 13). The wall itself will be approximately 10m in height with an additional 3m tall structure on top of the wall to which safety equipment and belay ropes can be attached. The wall will be supported by 4 wire rope stays connected to concrete anchor bases located out with each corners of the wall. Please see Drawing 4174-AA-202 and 4174-AA-201A for further detail.
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5.58 Both the abseil tower and climbing wall benefit from being located in the central core area of development and are surrounded by trees. The climbing wall and abseil tower are labelled as the letters ‘B’ and ‘C’ respectively on the Proposed Site Plan Ref 4174-MP-200P13).
Figure 13: Photos of example Abseil Tower (left) and Climbing Wall (right)
Five-Line Zip Wire
5.59 There would be one five-line zip wire on the site. Its alignment has been determined taking on board a combination of site topography and the preference to locate the equipment away from residential properties. Each of the five zip wires would extend from the starting platform. The platform would comprise of a four sided timber structure created from wooden poles with timber supports to create a rectangular shape frame. The ‘jump off’ for the Zip is located on the terrace on the south side of Sainsbury House. This is very close to the previously permitted zip wire tower that is still in situ.
5.60 Located on the northern part of the core development area, the zip wire would run in a north westerly direction, terminating at natural rise in the land on the other side of the valley. The zip wire is labelled as the letter ‘A to a’ on the Proposed Site Plan Ref 4174-MP-200P13). Please see Drawing 4174-AA-200A for further detail.
Linear Ropes Course
5.61 The linear ropes courses (Figure 14) would be constructed from two 13m high timber poles separated by approximately 5.6m with an extended steel beam at the top. In between these two poles would be two Vertical Challenges. This is a series of timber logs suspended on ropes with varying gaps between them. Either side of the Vertical Challenge would be a kick ball requiring a ‘leap of faith’ to traverse the gap. The linear ropes courses are labelled as the letter ‘D’ on the drawing Proposed Site Plan Ref 4174-MP-200P12. Please see Drawing 4174-AA-203A for further detail.
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Figure 14: Photo of example Linear Ropes Course
Shelters
5.62 All activity bases will be accompanied by a three-sided wooden shelter (2.5m x 3.5m) with a green box profile steel sheet roof which would act as a waiting area in times of inclement weather (example of shelter shown on the right of Figure 15).
Figure 15: Photo of example Shelter
Water Based Activities
5.63 A shallow lake will be provided for water based activities such as canoeing, kayaking and raft building. Eight wooden jetties (Figure 16) would be positioned around the lake to allow access/egress from the water.
5.64 As well as activities out on the lake there would be an opportunity to participate in raft building using a number of components such as large plastic barrels, ropes and poles.
5.65 The lake is labelled as the letter ‘F1’ on Proposed Site Plan Ref 4174-MP-200P13. Please see Drawings 4174-SP- 200P5 and 4174-SP-201P5 for further detail.
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Figure 16: Photo of example Jetty
Access and Parking
Access
5.66 The application site is accessed via an access road off the B2244 which leads directly to the A21 affording immediate access to the national trunk road system. All coaches will be directed by this route to avoid any travelling through the village. To ensure the safety of pedestrians from Oaklands Park and Manor a new footpath is proposed alongside the access road.
5.67 The western site entrance has already been widened in the implementation of the extant planning permission. To further improve access for coaches the proposals include several passing places. These would be located close to the western entrance on the southern side of the access road (A), adjacent to the Sedlescombe Sports Field (B), on the corner further down the access road (C), at the junction with the Oaklands Park development (extension of existing passing place) (D) and near the core development area (extension of existing passing place (E). These can be seen as shaded in ochre on Proposed Site Plan Ref 4174-MP-200P13.
5.68 This would help to ensure that a coach would not be required to reverse back out onto the highway, or the opposing coach would not have to reverse a long distance within the Site. Parking will be prohibited within the passing bays. This restriction will be signed and site management will monitor the restriction to ensure the bay is clear for its intended use.
5.69 The coach lay-by to drop off children is labelled as No 11 on the drawing Proposed Site Plan Ref 4174-MP- 200P13. Coaches will then proceed to the car park marked 12 to turn around to exit the way they came. There is no proposal to use the southern access.
5.70 As a part of this application it is proposed to relocate the previously approved car park to the west of the Education Building (in place of the approved accommodation blocks and multi-games area) so that it will be further away from the residential properties on Cottage Lane.
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Parking
5.71 The approved car park which it is proposed to relocate behind the Education building can accommodate 101 spaces. There will not be a need for this many spaces for staff and visitors, leaving adequate space for up to 13 coaches to park and turn. In addition, various other parking areas will remain close to staff accommodation buildings.
Lighting
5.72 No additional external lighting is considered necessary as a result of PGL’s proposals and so there are not proposed to be any alterations to existing lighting provision at the site which consists of low level bollard lighting. The only new lights will be those installed over new building entrances. PGL do not install lighting in or around their activity bases at their centres.
Employment
5.73 In terms of job creation, it is anticipated that PGL would require approximately 180 staff for the day to day running of the Site. It is expected that between 20-40% of those staff would commute on a daily basis, including those from the local village, while 60-80% would be employees from farther away who would be offered on-site accommodation.
5.74 These proposals will therefore make an important contribution to directly diversifying local employment. In addition, the site will have positive impact on the local supply chain and supporting wider employment and indirect spend. It is important to note that a live on contract does not mean that the contract will not be available to local residents. PGL aims to employ as much local employment and live off contracts as possible and appropriate for the site.
Construction
Programme
5.75 On the basis of PGL receiving a positive decision on this planning application, it is expected Phase 1 would commence winter 2019/20, subject to the discharge of any planning conditions restricting commencement of development. We would welcome the opportunity to discuss any planning conditions to seek to minimise the number of pre commencement issues if possible.
5.76 The initial works would be carried out so that the site is available for opening in May 2020. All work that has an impact on protected species will follow the recommendations set out in the accompanying Preliminary Ecological Appraisal. Works to complete the proposed masterplan will be likely to be undertaken during the period 1-2 years after opening.
Working Hours
5.77 Works to prepare the Site for opening will be carried out between normal daytime construction hours on Monday to Friday, and on Saturday mornings. There will be no working on Sundays or during Bank holidays unless agreed in writing with Rother District Council.
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6. Consultation
Pre-application enquiries
6.1 A pre-application response from Rother District Council was sent to our client on 7th Feb 2019. The letter discusses the proposal in full and highlights the Planning Officer’s response to the client’s initial enquiry. The main points included that:
• The site is located within the High Weald AONB and therefore great weight should be given to conserving and enhancing the landscape and scenic beauty in planning decisions. The proposed new buildings and other operational development would therefore need to be at a scale that would not harm the AONB.
In response, the proposed buildings are in replacement for building that have extant planning permission but have not yet been built, and, the replacement buildings are proposed in a more central location, set down in the landscape and behind existing tree planting; one of the accommodation blocks is directly over the site of a former demolished building, the other sits between that and the existing conference centre in the same approximate location as a permitted extension to that building.
• The site includes areas of designated ancient woodland (see Figure 17 below) which are protected by national planning policy (NPPF) and the impact of the proposals on the ancient woodland would be a material consideration in assessing any future application.
None of the replacement buildings, tents, or activity bases are proposed within ancient woodland.
• The Sedlescombe Neighbourhood Plan is now in force and has a specific policy for the land at Pestalozzi. The Policy allocates land for residential development overlaps onto the Pestalozzi site and the officer thought it was unclear how the proposals reconciled with this policy. The policy also links the occupation of some of the proposed new dwellings to Pestalozzi and the officer encourages our client to discuss this matter with the Parish Council.
One of the proposed guest accommodation blocks lies within the intended site for residential development. Staff accommodation is also being provided through the refurbishment of existing buildings on the site. A presentation of the proposals has been given to the Parish Council and this issue is addressed in the policy section below.
• The officer states that a specific use has not been granted relating to operations within a particular use class. The Council does not believe that the use of the site fits until C2 (residential institutions) and they suggest that the site is more likely to be Sui Generis. A formal Certificate of Lawful Use is suggested if the client believes that the site within any specific Use Class.
The established and proposed uses are both considered residential institutions that fit squarely within use class C2. This application seeks merely to amend the extant permission for this use by relocating the permitted footprint and car park, and providing a seasonal tenting area and activity structures.
• It is considered by the Council that lawful commencement has been made on the development approved under RR/2007/397/P and the planning permission is extant. They also provide confirmation that these conditions have been discharged. They state a subsequent application was received
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(RR/2014/1341/P) to vary conditions from the previous application and was approved in August 2014. The officer also discusses application RR/2015/861/DC which has been discussed above.
The extant permission is most likely RR/2015/861/DC as a section 73 variation of the preceding two permissions. Either way, this application is submitted as an application to amend the permitted masterplan for the site as set out by RR/2007/397/P as varied by the two subsequent permissions.
• The officer believes that the Section 106 agreement does not need to be amended. Schedule 8 is believed to be the only outstanding area to be addressed and East Sussex County Council will require submission of a Travel Plan. No reference has been found to prove that this has already been provided.
A travel plan is submitted with this application to clear up this point and can be a condition of approval.
• It is stated that the revised layout plan would not be considered as a minor amendment to permission RR/2007/397/P and therefore a new planning permission is required. The previous planning application would be a material planning consideration. According to the Council, a new legal agreement would need to be implemented to ensure that the remaining development authorised by the Pestalozzi 2007 permission could not also be implemented.
This application is submitted as standalone application to amend the previously permitted and extant masterplan for the site as set out by RR/2007/397/P as varied by the two subsequent permissions. A new legal agreement should not be necessary as, as soon as any development takes place in accordance with the new permission, the previous permission(s) will be superseded and no longer extant.
• Other issues mentioned by the officer include traffic movements and general highway implications, especially as the existing permission states that only the northern (western) access can be used and the impact of the use of the site on the amenity of neighbouring residential properties.
These matters have been considered in the submitted Transport Statement and Travel Plan and with the proposed provision of passing bays and a pedestrian footpath.
• There is a mention of the design of the buildings in the 2007 permission that are single storey buildings with low roofs to ensure that the buildings follow the contours of the sloping ground and would integrate better with the rural landscape. Other mitigation measures including new planting and sculptured landscaping that would conceal the car park were also proposed. It is suggested that as the land on the site is elevated and can be seen from the village of Sedlescombe and in the AONB, new buildings should be designed to minimise the impact on the landscape and incorporate appropriate mitigation measures. A landscape visual appraisal is said to be required with any application to demonstrate that the development would not harm the AONB landscape.
A number of the buildings in the extant permission, including the two accommodation blocks, were two storey. The proposed accommodation blocks that will replace them will also be two storey, however, they will be located in a less visually exposed location by being concentrated more centrally within the site screened by existing vegetation and existing buildings.
• The officer comments that the red line of the site does not accord with that relating to the Pestalozzi 2007 application, being a smaller area. The white area in the middle of the plan includes two tracts of land formerly indicated as being part of the Pestalozzi land. The officer states that it is unclear what the implications of the proposed surrounding development would be for these apparently isolated pockets of land including their intended future use.
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PGL do not own these areas of land which were sold separately to the adjoining residents by Pestalozzi. They will retain permission for any use deemed granted by the 2007 permission and its variations, but it is unlikely that any such use could be implemented now that they have been separated from the core facilities.
• Finally, the Council state that depending on the nature of the residential developments within the scheme, CIL payments may be applicable.
The CIL charging schedule does not indicate any charge for C2 residential institutional development. None of the replacement buildings proposed are for C3 dwellings. There is no increase in permitted floorspace against which to apply any CIL charge in any event.
6.2 The pre-application response suggests the following documents to accompany a planning application:
• Design & Access Statement
• Ecological Survey/Report
• Archaeological Report
• Drainage Report
• Transport Assessment
• Tree Survey/Arboricultural Statement (if the application proposals affects the ancient woodland within the site area)
• Landscape visual impact appraisal
Figure 17: Areas of Ancient Woodland within the Pestalozzi site
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Public Consultation Event – 14th May
6.3 On Tuesday 14th May, PGL hosted a public consultation event at the Pestalozzi Conference Centre where immediately adjoining residents and members of the Parish Council were invited to come and discuss PGL’s emerging plans for the Pestalozzi site. Figure 18 below shows some photos from the event.
Figure 18: Photos from the PGL Public Consultation Event – 14th May
6.4 Some residents at Oakland Manor and Park raised concerns regarding the location of the swings and these have now been moved accordingly further within the site.
6.5 Residents from Cottage Lane raised a concern regarding the close proximity of the (already permitted) car park. Therefore, this application proposes to relocate the car park behind the Education and Swiss Building with the originally approved car park to be replaced by a 2.5m high combined bund and fence and additional landscape screening.
6.6 There was a concern regarding the possible use of the southern entrance but this was alleviated by the confirmation by PGL that this will not be used in this proposal.
6.7 A final concern related to the proximity of the activity lake to the nearby residential properties. However, there will be substantial screening and the lake will be at a lower level cut 2.5m into the slope, with a further bund on top, as can be seen in the Section drawings refs (4174-SP-200P5 Lake Sections Sheet One & 4174-SP- 201P5 Lake Sections Sheet Two). This will act as a buffer to noise. It should also be borne in mind that the extant permission for the site allows for a new multi-purpose games area in this field (which would no longer be built) and for its continued use as a playing field.
6.8 Noise concerns highlighted by the residents are addressed in detail in the Noise Assessment and Management Plan submitted with the application.
Parish Council Meeting – 14th May
6.9 The consultation event above was followed by a presentation of the emerging proposals to the Parish Council. The proposals were generally favourably received pending the submission of this formal application.
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Public Consultation Event – 5th June
6.10 A second public consultation event was held on Wednesday 5th June that presented the proposals to a greater number of local residents and stakeholders. Over 50 local residents attended the public consultation event, with over 30 proposal survey responses received on the day or later via email or in the post.
6.11 There are many neighbours and local residents who are in favour of the proposals and agree with the principle of the application, with many just requesting a modification of the locations of activity structures to suit their needs better. Residents suggested that the proposed development had been considered and designed sympathetically, appreciated that there would be significant potential local employment opportunities and would bring more young people into the village and valued the sourcing of food and drink from local suppliers in the area. There were also residents that commented that PGL were making best use of the space and not turning it into a housing estate, neatening up the existing buildings and land and that they were happy that the majority of the space will remain green fields and building on brownfield areas. Many residents claimed that the overall benefits of the proposals outweighed the negative points.
6.12 The main issues brought up by the residents involved:
6.13 Comments on Transport:
• There were residents who felt there would be an increase of traffic onto the main roads surrounding the site and in the village and had concerns about the access for coaches to the main gate and that they believed that the road would need to be altered (around Chapel Hill) at the entrance to the site. These issues are addressed in the accompanying Transport Statement.
• There were also concerns about the routes of traffic to the site and it was suggested that it should be routed along Tollgate Road (B2244) and not through the village. This is incorporated within the supporting Travel Plan and will be additionally presented within PGL’s guidance for guests to not come through the village to the site. This guidance will be produced and sent out to all schools and other guests to inform visitors of the most appropriate route to the site, away from the village via the A21 and then via the B2244.
• Some residents were concerned that there would be large congestion on the roads and in village if all the school groups arrived on the same day and time, as well as individuals and day groups and wanted empty coach movements to be minimised as much as possible. This is addressed in the Travel Plan and Transport Manangement Plan submitted with the application.
• There was an idea suggested to move the already permitted car park to the western entrance of the site with a separate exit and entrance, with guest luggage shuttled up from the car park by smaller vehicles (electric powered) and guests walking up to the main complex. Although an interesting idea, this is not feasible due to the topography of the land and would cause significant traffic and build up onto the B2244. PGL’s proposals involve the improvement and introduction of vehicle passing places, the widening of the main access road and include the provision of a pedestrian footpath from the entrance to the main complex area.
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6.14 Comments on Noise and Pollution:
• There were various concerns regarding the noise levels and possible disruption that the proposals would bring. Residents felt reassured when explained PGL’s general timetable for activities and commented that, if followed, noise would be likely to cease at a reasonable time. This is addressed fully within the Noise Assessment and Management Plan submitted with the application.
• There was a concern regarding light pollution from security lights affecting the local properties on roads such as Chapel Hill. As discussed above, additional external lighting is not considered necessary as a result of PGL’s proposals and so there are not proposed to be any alterations to existing lighting provision at the site which consists of low level bollard lighting. The only new lights will be those installed over new building entrances. PGL do not install lighting in or around their activity bases at their centres.
6.15 Comments on the environment and wildlife:
• Some of the local residents believed that there would be a negative effect on the beautiful parkland environment and that the tranquil area which will be lost and were concerned about the proposals being located in an AONB. This proposal seeks to avoid any detrimental harm to the natural environment and aims to make best use and improve an existing outdoor activity site. This is further discussed in the accompanying Landscape Visual Impact Assessment submitted with the application
• There were other concerns regarding the preservation of local wildlife in the area, in particular the roaming geese in the village. As mentioned above, all traffic will be advised to avoid Sedlescombe village and come directly off the A21 onto the B2244 to the site. Local wildlife and trees area also discussed in the supporting Tree Report and Preliminary Ecological Appraisal submitted with this application.
• There was a concern regarding the management of the right of way and ancient woodlands on the site. Both of these areas will be untouched within these proposals and the right of way will remain open to the public unless there are significant health and safety concerns for the guests and children that require PGL to look into this differently.
6.16 Finally, there were concerns raised over the control of groups and night security for the tenting area. These residents were worried that the water being close to the tenting village would be a safety issue at night. The children will not be allowed to leave the site and enter the village or be able to wander around the complex and this will be ensured by full supervision by PGL staff and the school teachers. A PGL member of staff will also be allocated at night to monitor the children and ensure that all PGL’s rules and procedures are being followed and are in place.
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7. Planning Policy Context
National Policy
7.1 The revised NPPF, revised in February 2019, sets out the Government’s economic, environmental and social planning policies for England. Taken together, these policies articulate the Government’s vision of achieving sustainable development.
7.2 Paragraph 8 states that sustainable development is defined in terms of its economic, social and environmental roles:
• In economic terms, the development of leisure accommodation will add further and better quality accommodation to the area bringing in more and higher spending visitors. These visitors will bring spending into other parts of the District supporting local jobs and services.
• In social terms, some of the spending will be spent directly (by guests, their teachers, parents and staff), and indirectly (by local workers in receipt of wages from visitor spending), in local shops, pubs and cafes helping to maintain their viability as local social and community facilities. In addition, the children using the site will improve their health and well-being, challenge, social interaction and integration skills.
• In environmental terms, the site is sustainable with nearby public transport, pedestrian and cycle routes to nearby facilities. The proposed buildings replace buildings that have already been approved with buildings in less visually sensitive locations will also not cause any detrimental harm to the AONB.
7.3 In these terms, therefore, the supply of leisure accommodation would represent sustainable tourist and leisure development.
7.4 Paragraph 10 states that ‘at the heart of the Framework is a presumption in favour of sustainable development’. As paragraph 11 reiterates ‘plans and decisions should apply a presumption in favour of sustainable development.’ It follows that if the proposals meet the three roles of sustainable development as outlined above, then, there should be a presumption in favour of the development.
7.5 In order to deliver sustainable development one of the key objectives is to build a strong and competitive economy. In this context, paragraph 80 states that ‘significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development.’
7.6 Paragraph 83 relates to the supporting of a prosperous rural economy in order to create jobs and prosperity by taking a positive approach to sustainable new development. Objectives 3-4 of Paragraph 83 state that plans should:
‘…enable sustainable rural tourism and leisure development which respect the character of the countryside; and enable the retention and development of accessible local services and community facilities, such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship.’
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7.7 In making such a statement, the government is saying that there is no blanket restriction on tourism development in rural areas. If a rural tourism development is sustainable, as in this case, and respects the character of the countryside, as in this case, and enables the retention and development of an accessible local community facility such as a sports venue, as in this case, then the application should be approved.
7.8 Paragraph 84 states that plans should:
‘…recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. In these circumstances it will be important to ensure that development is sensitive to its surroundings, does not have an unacceptable impact on local roads and exploits any opportunities to make a location more sustainable. The use of previously developed land, and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist.’
7.9 Chapter 9 deals with promoting sustainable transport. However, paragraph 103 reminds us that ‘opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making’.
7.10 Paragraph 172 relates to the conservation and enhancement of the natural environment, stating that:
‘Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues.’
7.11 The application site is located within the High Wealden Area of Outstanding Natural Beauty. The proposed buildings will not be significantly greater in floorspace than those which have already been approved for the site, however, they will be positioned in less intrusive locations, well screened and better integrated with existing building complex. Therefore, the proposal will have a positive impact on the character of the landscape. This is further addressed in the supporting Landscape Visual Impact Statement submitted with this application.
National Planning Practice Guidance (NPPG) 2014
7.12 The NPPG states that when planning for tourism, local planning authorities should:
• Consider the specific needs of the tourist industry, including particular locational or operational requirements;
• Engage with representatives of the tourist industry;
• Examine the broader social, economic and environmental impacts of tourism;
• Analyse the opportunities for tourism to support local services, vibrancy and enhance the built environment; and
• Have regard to non-planning guidance produced by other Government Departments.
7.13 It also states that local planning authorities may want to consider guidance and best practice produced by the tourism sector pointing the reader to further guidance on tourism hosted on the Visit England website.
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7.14 The Tourism Planning Guidance on the Visit England website notes that in order to be commercially successful, tourism sites must be accessible to their target market for visitors:
‘Many small scale rural tourism developments are car dependant and the use of the car does not by default make the proposal unsustainable. Encouraging greater domestic tourism has the potential to support jobs and facilities in rural areas reducing out-commuting from those areas.’
‘Many accommodation businesses want it to be easy for customers to reach them by car. The NPPF recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban and rural areas.’
7.15 As noted earlier, the site is in a sustainable location near to the village of Sedlescombe which offers a number of amenities and the majority of guests will arrive and depart by coach.
Local Policy
7.16 Rother District Council currently has two main statutory planning documents. The first is the Local Plan and Supplementary Planning Documents which was adopted in 2006 and the second is the Core Strategy, adopted in 2014. The Council have submitted a Development and Site Allocations (DaSA) Local Plan to an Inspector and is due to be discussed at public hearings at the end of May 2019. In due course, this Local Plan review will update the policies from the 2006 Local Plan.
Figure 18: Local Plan 2006 Proposals Map
7.17 The Proposals Map, as shown above in Figure 18, shows that the application site is located within the High Weald AONB (green diagonal line to the bottom right). Flood Zone 3 and a Site of Nature Conservation
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Importance (SNCI) (green diagonal line to top right) are shown to the north of the application site either side of the River Bede.
Local Plan and SPD 2006
7.18 Policy DS1 discusses the District’s development strategy:
‘In determining whether development is appropriate in a particular location, proposals should accord with the following principles:
(i) priority is given to making best use of urban land, especially through the re-use of previously developed land/buildings;
(ii) it fosters sustainable and socially inclusive communities, including by supporting local services and helping meet local needs, such as for affordable housing;
(iii) it ensures a sufficient continuing supply of employment sites and premises to foster economic regeneration;
(iv) it ensures a good level of accessibility to a range of services and jobs by public transport, recognising that opportunities are more limited in rural areas;
(v) best use is made of existing infrastructure, including transport, community facilities and mains drainage;
(vi) it avoids prejudicing the character and qualities of the environment, particularly the High Weald Area of Outstanding Natural Beauty and undeveloped coastline;
(vii) it protects sites of recognised nature conservation importance, particularly of internationally and nationally important sites, as defined on the Proposals Map;
(viii) it protects historic parks and gardens and Battle battlefield, as defined on the Proposals Map;
(ix) it respects the importance of the countryside in terms of its distinct landscape character, natural resources, woodland and agriculture;
(x) it protects ancient woodland from development that would prejudice its ecological and landscape value;
(xi) it ensures that development is safe from flooding, including by restricting development in flood risk areas and not increasing such risk elsewhere;
(xii) it protects vulnerable countryside gaps between settlements, as elaborated upon by Policy DS5.
(xiii) it ensures a sufficient continuing supply of housing land in accordance with the Structure Plan housing supply requirement and the spatial strategy of the Plan’
(xiii) it avoids development on unstable land except where the proposal demonstrates that actual or potential instability can reasonably be overcome.’
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7.19 This application addresses these criteria; it provides for the re-use of previously-developed land, it fosters sustainable and socially inclusive communities, it ensures that the site continues to provide employment, fosters economic regeneration, provides good level of access to a range of jobs in a rural area, uses existing infrastructure, protects the character of the AONB and areas of nature conservation importance, respects the countryside and ancient woodland, and is safe from flooding.
7.20 Policy DS4 relates to development outside the development boundaries set out in the Proposals Map and states that:
‘Proposals for new development therein will be required to accord with relevant Structure Plan and Local Plan policies and, unless there is specific provision in these policies for the proposed form of development to be located in the countryside, the proposals will also be required to demonstrate that a countryside location is necessary for the development.’
7.21 The objective of PGL is to get children out into the countryside and given them a rural activity experience. The proposals clearly demonstrate that a countryside location is necessary for the development. The site already has long established use as an educational residential training centre for children.
Core Strategy 2014
7.22 Policy OSS3 comments on the location of development:
‘In assessing the suitability of a particular location for development, when both allocating land for development and determining planning applications, sites and/or proposals should accord with the relevant policies of this Core Strategy and be considered in the context of:
(i) The spatial strategy for the particular settlement or area, and its distinct character;
(ii) The capacity of, as well as access to, existing infrastructure and services, and of any planned or necessary improvements to them;
(iii) The local need for affordable housing;
(iv) Needs and priorities identified in approved Local Action Plans;
(v) The low carbon and renewable energy potentials of the site;
(vi) the character and qualities of the landscape;
(vii) Making effective use of land within the main built-up confines of towns and villages, especially previously developed land, consistent with maintaining their character;
(viii) Any constraints relating to land stability, contamination, air quality, agricultural land quality and coastal erosion, and the ability to satisfactorily address these;
(ix) The deliverability of development, including consideration of land ownership patterns and the viability of development;
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(x) The need for and access to employment opportunities.’
7.23 The location of the development utilised previously developed land within the current use class (C2 residential training centre). The site’s location also suits the character of the development which requires a countryside location for its outdoor adventure activities.
7.24 Policy RA2 refers to a general strategy for the countryside:
‘The overarching strategy for the Countryside is to:
(i) Maintain the farming capacity of the district, and support the agricultural industry, including diversification within farming;
(ii) Encourage agricultural practices, land-based economic activities and woodland management, and related agri-environmental schemes, that reinforce local distinctiveness, landscape character and ecology;
(iii) Strictly limit new development to that which supports local agricultural, economic or tourism needs and maintains or improves the rural character;
(iv) Retain traditional historic farm buildings by continued agricultural use or by appropriate re-use, in accordance with Policy RA4;
(v) Support rural employment opportunities in keeping with rural character and compatible with maintaining farming capacity;
(vi) Support enjoyment of the countryside and coast through improving access and supporting recreational and leisure facilities that cannot reasonably be located within development boundaries, such as equestrian facilities, compatible with the rural character of the area;
(vii) Support tourism facilities, including touring caravan and camp sites, which respond to identified local needs and are of a scale and location in keeping with the rural character of the countryside; and
(viii) Generally conserving the intrinsic value, locally distinctive rural character, landscape features, built heritage, and the natural and ecological resources of the countryside.’
7.25 This proposal seeks to contribute to the provision of outdoor recreational and leisure activities in the wider area. The client’s outdoor activities therefore necessitate a countryside location and the existing Pestalozzi site only requires minimal adaption to suits the needs of the new owners.
Policy RA3 relates to development in the countryside. It states that ‘Proposals for development in the countryside will be determined on the basis of (applicable sections only repeated):
(ii) Supporting suitable employment and tourism opportunities in the countryside, including by the conversion, for employment use, of farm buildings generally in keeping with the rural character, and by the sensitive, normally small-scale growth of existing business sites and premises;
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(iv). Ensuring that extensions to existing buildings and their residential curtilages, and other ancillary development such as outbuildings, fences, enclosures, lighting and signage, would maintain and not compromise the character of the countryside and landscape;
(v). Ensuring that all development in the countryside is of an appropriate scale, will not adversely impact on the landscape character or natural resources of the countryside and, wherever practicable, support sensitive land management.’
7.26 This application supports the continued use of the site for an appropriate employment and tourism use in the countryside, at an appropriate scale that does not compromise the character of the countryside or landscape or natural resources in accordance with this policy.
7.27 Policy CO4 discusses supporting young people and states that:
‘Priority will be given to making growing up, living and working in Rother attractive to young people and families, including through:
(i) Provision of housing options, including affordable homes, suited to the needs of young people, especially in Bexhill and the rural areas;
(ii) Accessible employment opportunities;
(iii) Continued investment in quality education and training facilities;
(iv) A good range of community, health and recreational facilities, including play areas, sports pitches and youth facilities;
(v) Prioritising investment in public transport and/or cycling to key services, such as education, health and leisure facilities;
(vi) Making safety and community integration a priority in urban design.’
7.28 The proposed application will give an opportunity for young people to partake in leisure activities and will bring in school children from different areas of the country, as well as offering the young people in the local area a chance to participate in day camps and other seasonal events. PGL’s general purpose is to allow young people to lead healthy lifestyles and get involved in outdoor pursuits.
7.29 Policy EC3 discusses existing employment sites, stating that:
‘Effective use of employment land and premises will be secured by undertaking a full review of existing and potential sites for employment use and allocating sites in the Development and Site Allocations Plan and/or Neighbourhood Plans. Until those plans are in place the following policy will apply:
(i) Land and premises currently (or last) in employment, including tourism, use will be retained in such use unless it is demonstrated that there is no reasonable prospect of its continued use for employment purposes or it would cause serious harm to local amenities;
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(ii) Permitting intensification, conversion, redevelopment and/or extension having regard to other policies of the Plan;
(iii) Facilitating access/environmental improvements, where appropriate;
(iv) Where continued employment use of a site/premises is demonstrated not to be viable, permit complementary enabling development as part of an overall scheme to make most effective use of the property for employment purposes; if a mixed use scheme is not viable, prioritise alternative community uses, affordable housing and then market housing, subject to local needs.’
7.30 As the Development and Site Allocations Plan is still with the Inspector (submitted in January 2019), this policy still applies. The previous owner of the site, Pestalozzi International Village, could not make the site viable, and therefore PGL have bought the site to continue to provide complementary development in the area, allowing for the continued use of the site and ensuring the effective operation of the residential training site.
7.31 Policy EC4 relates to business activities elsewhere within the District and states that:
‘Business activities will be promoted elsewhere within the district by the following:
(i) Continuing to give priority to the re-use and adaptation of suitable buildings in the countryside for employment, including for tourism purposes, in accordance with the Rural Areas policies;’
7.32 Policy EC6 discusses tourism activities and facilities and comments that:
‘Proposals relating to tourism activities and facilities will be encouraged where they accord with the following considerations, as appropriate:
(i) It provides for the enhancement of existing attractions or accommodation to meet customer expectations;
(ii) It supports active use along the coast, consistent with environmental and amenity factors;
(iii) It develops markets for local produce, particularly that which supports land-based industries and cultural assets;
(iv) It does not involve the loss of tourism accommodation, unless there is no prospect of its continued use;
(v) It increases the supply of quality serviced and self-catering accommodation;
(vi) Appropriate controls are in place that restrict occupancy to that for holiday purposes, whilst not unduly restricting operators from extending their season (subject to visual impact and flood risk considerations, where applicable); and
(vii)Compatibility with other Core Strategy policies.’
7.33 This application accords with policies EC4 and EC6 in that it allows for the re-use and adaption of existing buildings for tourism purposes, the enhancement of existing (and permitted) accommodation, and prevents the loss of tourist accommodation by retaining and enhancing the permitted use.
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7.34 Policy EN1 talks about landscape stewardship stating that:
‘Management of the high quality historic, built and natural landscape character is to be achieved by ensuring the protection, and wherever possible enhancement, of the district’s nationally designated and locally distinctive landscapes and landscape features; including
(i) The distinctive identified landscape character, ecological features and settlement pattern of the High Weald Area of Outstanding Natural Beauty;
(ii) The distinctive low-lying levels to the east of the district with particular regard to the landscape setting of Rye and Winchelsea;
(iii) Nationally designated historic sites including listed Parks and Gardens, Scheduled Ancient Monuments and the Registered Historic Battlefield at Battle;
(iv)The undeveloped coast;
(v) Open landscape between clearly defined settlements, including the visual character of settlements, settlement edges and their rural fringes;
(vi)Ancient woodlands;
(vii) Tranquil and remote areas, including the dark night sky;
(viii) Other key landscape features across the district, including native hedgerows, copses, field patterns, ancient routeways, ditches and barrows, and ponds and water courses.’
7.35 This proposal seeks to minimise any harm on the High Weald AONB and will integrate into the surrounding landscape. Various mitigation measures that are proposed include the placement of activities a good distance from areas of ancient woodland, placing the outdoor activities in areas of the site that are well screened and landscaped.
7.36 Policy EN5 relates to biodiversity and green space and states that:
‘Biodiversity, geodiversity and green space will be protected and enhanced, by multi-agency working where appropriate, to:
(i) Maintain and develop a district-wide network of green infrastructure where possible linking areas of natural green space;
(ii) Protect and enhance the international, national and locally designated sites, having due regard to their status;
(iii) Establish a major area of accessible open space at Combe Valley Countryside Park, between Bexhill and Hastings;
(iv)Enhance the nature conservation value and multi-functional nature of the Romney Marsh Biodiversity Opportunity Area;
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(v) Support opportunities for management, restoration and creation of habitats in line with the opportunities identified for the Biodiversity Opportunity Areas (BOAs) and targets set out in the Sussex Biodiversity Action Plan;
(vi)Continue to develop the wetland habitat at Bewl Water Reservoir, with compatible recreational uses;
(vii) Increase accessibility to the countryside from urban areas, especially in the Hastings and Bexhill fringes;
(viii) Ensure that development retains, protects and enhances habitats of ecological interest, including ancient woodland, water features and hedgerows, and provides for appropriate management of these features;
(ix) Require developers to integrate biodiversity into development schemes by avoiding adverse impacts from development on biodiversity or habitat, or where wholly unavoidable, provide appropriate mitigation against or compensation for any losses. In any event, developers will also be expected to consider and promote opportunities for the creation and/or restoration of habitats appropriate to local context.’
7.37 The proposal seeks to enhance the local biodiversity in the area whilst avoiding adverse impacts of development on the habitats of local species.
7.38 Policy TR3 involves access and new development:
‘New development should minimise the need to travel and support good access to employment, services and communities facilities, as well as ensure adequate, safe access arrangements. Development will be permitted where mitigation against transport impacts which may arise from that development or cumulatively with other proposals is provided. This will be achieved through the submission of a transport assessment, transport statement or travel plan, and where it is appropriate through:
(i) Ensuring that new developments in their design and layout prioritise the needs of pedestrians, cyclists and minimise the distance to local public transport nodes;
(ii) Working with the relevant agencies to seek funding for contributions for improvements to local infrastructure needed to facilitate highway capacity and safety and/or public transport accessibility and capacity, where this is necessary to serve the new development; and
(iii) Provision of electric vehicles charging infrastructure.’
7.39 The accompanying Transport Statement and Travel Plan demonstrates the mitigation against the impact of the development on local transport. Coaches will be routed to the site’s western access via the A21 and B2244; they will not pass through the village. Several passing places will be implemented as well as widening existing passing places to aid the general movements of coaches and other vehicles. A footpath will be added alongside the access road to ensure pedestrian safety.
7.40 Policy TR4 discusses car parking, stating that:
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‘Planning permission will be granted for development where the provision for parking accords with the following principles which will be elaborated upon in the form of Supplementary Planning Document. Proposed development shall:
(i) Meet the residual needs of the development for off-street parking having taking into consideration localised circumstances and having full regard to the potential for access by means other than the car, and to any safety, congestion or amenity impacts of a reliance on parking off-site whether on-street or off-street;
(ii) Provide for reduced parking provision where a high level of accessibility to jobs, services and facilities exists, or will be provided as a result of the development, including any offsite measures;
(iii) Ensure that the approved parking provision is retained for the future where that would be necessary to prevent harm to the safety or free-flow of the highway;
(iv) Include a number of parking spaces designed and signed for disabled people; and
(v) Provide for commuted payments towards providing and/or managing off-site parking, including on-street parking, where this is justified to meet the needs of the development.’
7.41 The car parking provision will meet the needs of the operations of the site, allowing for visitor, disabled and staff parking spaces. The larger car park has already gained planning permission in a previous application, but has now been moved to allow for greater screening on the boundaries of the site.
Neighbourhood Plan
7.42 The Sedlescombe Neighbourhood Plan formed part of the Development Plan for Rother District in April 2018 and is used when determining planning applications within the designated Neighbourhood Area of Sedlescombe Parish.
7.43 The Neighbourhood Plan has a specific policy for the land at Pestalozzi (Policy 3). The Proposals Map for the Policy can be seen below in Figure 19. The policy states that:
‘Proposals for housing development on land at Pestalozzi International Village, as shown on the Proposals Map, will be supported, provided the scheme:
1. Makes provision for 1 and 2 bed houses and flats, of no more than two storeys in height, a proportion of which will be made available as affordable homes giving first preference to eligible employees or volunteers in perpetuity;
2. Includes a viability appraisal that demonstrates the minimum number of open market dwellings required to cross-subsidise the refurbishment or replacement of the volunteers’ accommodation;
3. Incorporates a landscape scheme that mitigates any visual impact on the surrounding countryside;
4. Preserves the area of the site designated as Priority Habitat;
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5. Comprises appropriate works to improve Ladybird Lane provided they do not include any additional lighting;
6. Identifies and agrees an alternative location for the estate management facility; and
7. Demonstrates that any new access will have an acceptable impact on the character of the Brede Valley and demonstrated to be visually contained from public view points.’
7.44 The Parish comment that the “this policy supports in principle the redevelopment of a brownfield site that is well-related to the existing Pestalozzi International Village development. In doing so, it accords with policy OSS3 of the RLPCS in respect of making effective use of previously-developed land and Policy EC3 in the effective use of employment sites…Although outside the Sedlescombe Development Boundary, the proposal is small-scale and will not adversely impact on the landscape character of the countryside. Low- level buildings and structural tree planting to the north east will ensure that the development fits into the landscape… The site is situated along a quiet private lane within easy walking distance (approximately the same distance as recent developments at East View Terrace within the Development Boundary) of all the amenities of Sedlescombe Village as well as the public transport links to Hastings and Battle. The mixed housing and employment site will assist in reducing the need for travel.”
Figure 19: Sedlescombe NDP Proposals Map – Inset B
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7.45 The application proposals fit with the objective of Policy 3 which is to support the continued viability of an educational residential institution at the Pestalozzi site. That is precisely what the PGL proposals provide without the need for cross-subsidy from residential development. Instead, as can be seen from Figure 18 above, the proposed L-shaped replacement accommodation block sits within the site proposed for residential development while the VW Houses that are also within this site will be refurbished and re-used as staff accommodation, very much in keeping with the policy principles.
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8. Conclusions
8.1 In conclusion we consider our client’s proposal to be acceptable for the following reasons:
• PGL currently operate at various locations across the UK and have built a reputation for providing great quality adventure activities, courses and holidays. Their purpose is to offer children an opportunity to connect to nature and participate in outdoor adventure trips and activities that are based in the countryside.
• The existing and proposed use of the site will continue as a C2 use class as PGL would like the use to remain as a residential training centre in order to carry out their outdoor educational activities and provide overnight accommodation for young people.
• The application involves the modification of an extant permission for the site (RR/2007/397/P) and consists of three main areas; replacement buildings for those previously approved; a new seasonal tenting area and; new activity structures.
• The proposed floorspace and accommodation capacity will be similar to that permitted by the previous extant permission. The site will never reach full capacity due to the need to split guests by school or group and gender. Furthermore, PGL sites generally host far fewer guests at weekends and outside of their peak season in May, June and July.
• Traffic and noise issues have been fully considered and the plans have been modified in response to transport and noise considerations to minimise any impact on local residents.
• In terms of environmental impact, there will be less impact on AONB than implementing the approved extant permission and there won’t be any adverse impact on ancient woodland or biodiversity in the local habitats.
8.2 The application meets the national policy strategy set out in the NPPF as it constitutes sustainable development. It is also aligned with national policy that supports a prospering rural economy and conservation of the local and natural environment (Paragraphs 83, 84 and 172). The proposals also align with Local Plan and Core Strategy policies DS1, DS4, OSS3, RA2, CO4, EC3, EN1, EN5, TR3 and TR4. The proposal also conforms to the objectives outlined in Sedlescombe’s Neighbourhood Plan policy 3 as it allows for the continuation of the site as an educational residential training centre. The relocated accommodation block is also proposed to be located within the area proposed for residential development.
8.3 This statement demonstrates that the proposed development to allow for the modification of the original Pestalozzi masterplan can be delivered to meet the aspirations of the relevant policies in the Local Plan and current national planning policy and guidance in the NPPF. The application should therefore be approved in accordance with these policies.
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Contact Details
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