Agenda Item 6
PLANNING COMMITTEE
Date: 19 July 2018
APPLICATIONS FOR PERMISSION TO CARRY OUT DEVELOPMENT OR TO DISPLAY ADVERTISEMENTS (PC 30/18)
Schedule by Head of Planning and Coastal Management
Number of items: 7
FOR THE PURPOSE OF THE LOCAL GOVERNMENT (ACCESS TO INFORMATION) ACT, 1985 THE RELEVANT BACKGROUND DOCUMENT IN RESPECT OF EACH ITEM IS THE PLANNING APPLICATION FILE, INCLUDING SUBMITTED PLANS, CONSULTATIONS AND LETTERS OF COMMENT, BUT EXCLUDING INFORMATION EXEMPTED UNDER THE PROVISIONS OF THE ACT AND IDENTIFIED AS SUCH. ANY REPRESENTATIONS AND ADDITIONAL INFORMATION SUBMITTED AFTER THE PREPARATION OF THIS SCHEDULE RECEIVED NO LATER THAN 24 HOURS PRIOR TO THE COMMITTEE MEETING WILL BE REPORTED VIA THE ALTERATIONS AND ADDITIONS REPORT CIRCULATED AT THE MEETING.
PLEASE NOTE THAT THE ORDER OF THE ITEMS LISTED MAY BE CHANGED AT THE MEETING TO ACCOMMODATE PUBLIC SPEAKING.
SHOULD ANY OF THE FOLLOWING APPLICATIONS BE SUBJECT TO A SITE VISIT, THIS WILL NORMALLY TAKE PLACE ON THE SECOND MONDAY FOLLOWING THE DATE OF THE MEETING.
I N D E X
Item Page Case Application Address No No Officer No 1 3 SM DC/18/0086/FUL Bank House, 177 High Street, Aldeburgh, IP15 5AN 2 12 SM DC/18/0881/FUL Johnnygate, Beach Farm Road, Thorpeness, Aldringham-cum-Thorpe, IP16 4NZ 3 19 JB DC/18/1636/FUL Land South of 24 Pound Cottages, Ipswich Road, Grundisburgh, IP13 6TP 4 28 SM DC/17/3742/FUL Land West of Electricity Sub-Station, Hacheston, IP13 9ND 5 66 IR DC/18/1027/FUL Home Farm, Halesworth Road, Heveningham, IP19 0EL
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6 73 JB DC/18/1596/FUL 16 Roy Close, Kesgrave, IP5 1JR 7 77 NG DC/18/2068/FUL 8 Birch Grove, Martlesham Heath, Ipswich, IP5 3TD
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1. ALDEBURGH – DC/18/0086/FUL – Demolition of existing outbuilding and garage. Erection of new dwelling (comprising basement and room-in-roof levels) with integral parking : Bank House, 177 High Street, Aldeburgh, IP15 5AN for Mr Richard Buss.
Case Officer: Stephen Milligan
Expiry Date: 27 July 2018
EXECUTIVE SUMMARY
Full Planning Permission is sought for the erection of a dwelling to the rear of 177 High Street, Aldeburgh. The development lies within Aldeburgh Conservation Area, within the physical limits of Aldeburgh as defined within the Local Plan, within Aldeburgh Town Centre and within the Suffolk Coasts and Heaths AONB. This item has come before members following consideration by the Delegation Panel, to enable the consideration of the issues of parking and impact upon Aldeburgh Conservation Area. The application is recommended for Approval.
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1. SITE DESCRIPTION 1.1. This application is for the erection of one dwelling on land to the rear of 177 High Street, Aldeburgh off The Terrace/Choppings Hill, Aldeburgh. The site contains a frontage wall and single garage.
1.2. This site lies within the physical limits of Aldeburgh, a Market Town as defined within the Suffolk Coastal District Local Plan: Core Strategy and Development Management Policies DPD 2013 (SCDLP) and within the wider AONB and Heritage Coast. The site is also within the Aldeburgh Conservation Area and nos. 175 and 175a High Street are listed buildings (Grade 2).
1.3. The site is within the designated Aldeburgh Town Centre but not within the primary shopping area.
1.4. The site forms part of the steeply sloping rear curtilage of 177 High Street. The site slopes downwards by approx. 5m west to east and has a frontage to The Terrace of approx. 10.5m.
1.5. The Aldeburgh Conservation Area Appraisal (SPD) identifies the site and other curtilage areas to the rear of the properties on the western side of the High Street, in its Appraisal Map, as an 'important open/green/tree space.' It states (p18 and 19):
"Trees, hedges, boundaries and street greenery are important elements of the conservation area, not only in public places, but on private land as well. A large proportion of green space within the Aldeburgh Conservation Area is within the boundaries of the private gardens running along the Western edge. Views of the gardens are best appreciated from Church Walk, The Terrace and Champion Road. Most open spaces within the Conservation Area have views out towards the beach and sea and overlooking Aldeburgh's townscape, settings and important landmarks".
"Gardens below and east of The Terrace. Provides a green buffer at the rear of buildings on the west side of the High Street and seen from The Terrace which enhances the linear form of the development and supports several fine garden trees, which are sparse within the conservation area."
1.6. The site has an attractive brick boundary wall on its frontage to the Terrace and provides some views of the rear of properties in the High Street from the Terrace and space around a mature Sycamore tree which historically overhung the site from the curtilage of 179 High Street to the south. The tree has been subject to crown reduction and has been trimmed up to the boundary of the site.
2 THE APPLICATION 2.1 The application seeks Full Planning Permission for a five storey two bedroomed dwelling of contemporary design. The dwelling is proposed to be built into the sloping ground at the rear of the High Street with two single aspect basement levels and three
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stories above road level. The property is proposed to have a single integral garage space accessed from The Terrace. 2.2 The building was originally designed as a four bedroomed property with double integral garage. The design was amended to a two bedroomed design with single integral garage following an objection from the Highway Authority to the intensification of the use of a substandard access. 2.3 There is no relevant planning history.
3 CONSULTATIONS 3.1 Aldeburgh Town Council – Objects to this application stating: ATC Planning Committee does not support this application. The re-designation of rooms within the proposed development does not answer concerns expressed by the Planning Committee at its meeting on March 6 2018. At that meeting, the Planning Committee recognised the development was in a sensitive area for parking and believed the scale and mass of the proposed building was too large for the site and represented over-development. The Committee voted against this application UNANIMOUSLY.
The comments from the meeting of March 6 2018 states: A member of the public, who owns an adjoining property, addressed the Planning Committee and said that while he was in favour of the development, he had great concerns about road safety – with particular reference to a garage opening nearer to Choppings Hill. The Planning Committee recognises that the development is in a sensitive area for parking and believes the scale and mass of the proposed building is too large for the site and represents over-development. The Committee feels that while the design is interesting, it should be much reduced and more inkeeping with the area. The Committee also drew attention to drawings showing the gradient of the roadway which it believed were inaccurate. The Committee noted correspondence from Suffolk County Highways objecting to this application.
ATC Planning Committee unanimously OBJECTS to this application as it sta ds.
3.2 Suffolk County Council – Highway Authority: recommends that permission be refused, on the grounds of insufficient on site parking, leading to additional on-street parking, which may result in parking in unsuitable locations. The Suffolk Guidance for Parking requires two spaces per dwelling. If the Local Planning Authority is minded to approve, conditions relating to storage of refuse/recycling bins is recommended and for the turning and parking of vehicles.
3.3 SCDC - Head of Environmental Services and Port Health: No objections.
3.4 Aldeburgh Society : raise concerns about the proposal, stating that the amended scheme is in breach of the Conservation Area Policy and represents and unwelcome and intrusive development in a sensitive location. The proposals is too big for the plot, and the scheme should be refused. Recommend a site visit is undertaken.
3.5 Office of Nuclear Regulation (ONR) : Do not raise concerns.
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3.6 Third Party Representations:
Nineteen Letters of objection have been received raising the following matters:
Impact upon the character of the area/Conservation Area, Impact to highway safety, Impact upon parking availability, Poor design, Overbearing impact/scale, Privacy and outlook from neighbours, There are springs/watercourses under terrace and construction will have deleterious impact upon neighbours, Severe impact upon neighbourhood during construction work with road closure, impact upon parking availability, and noise, Loss of views, Loss of open space, Impact upon important tree, Property will be second home/investment vehicle and unavailable to those in need.
Third Party Representations: Six letters of support have been received raising the following matters: The design is exciting architecture, It will improve an unsightly plot, It will provide employment during construction phase, It will provide a much needed house.
4 RELEVANT POLICIES
4.1 NPPF (Framework)
4.2 NPPG
4.3 Suffolk Coastal District Local Plan – Core Strategy and Development Management Development Plan Document (adopted July 2013) policies:
SP1a – Sustainable Development SP1 – Presumption in Favour of Sustainable Development SP15 – Landscape and Townscape SP19 – Settlement Policy SP22 – Aldeburgh DM7 – Infilling and Backland Development within Physical Limits Boundaries DM19 – Parking Standards DM21 – Design: Aesthetics DM22 – Design: Function
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DM23 – Residential Amenity DM27 – Biodiversity and Geodiversity DM28 – Flood Risk
4.4 The Area Policies and Site Specific Policies Development Plan Document 2017. The relevant policies are: Policy SSP2 – Physical Limits Boundaries Policy SSP28 – Aldeburgh Town Centre
4.5 The following Supplementary Planning Guidance/Documents: Aldeburgh Conservation Area Appraisal
5 PLANNING CONSIDERATIONS
Principle of Development
5.1 The proposal is for the erection of a dwelling which lies within the physical limits of Aldeburgh, a Market Town as defined within the Local Plan. The site lies within Aldeburgh Town Centre and within Aldeburgh Conservation Area. The proposal is for consideration against Local Plan policies DM7 and SSP28. The primary issues relate to impact upon the Conservation Area; impact upon highway safety and parking and upon residential amenity.
Impact upon Conservation Area and Visual Amenity
5.2 A key consideration in assessing the proposed development will be the impact on the character and appearance of the Conservation Area and whether it will be preserved or enhanced. Paragraph 126 of the National Planning Policy Framework states that account should be taken of 'the desirability of new development making a positive contribution to local character and distinctiveness' and 'opportunities to draw on the contribution made by the historic environment to the character of a place'. Paragraph 137 of the NPPF also states that 'Local planning authorities should look for oppo tu ities fo e de elop e t ithi Co se atio A eas…..a d ithi the setting of heritage assets to enhance or better reveal their significance.'
5.3 The site has an attractive brick boundary wall on its frontage to The Terrace with views of the rear of properties in the High Street from The Terrace and space around a large mature Sycamore tree which historically overhung the site from the curtilage of 179 High Street to the south. The tree does make a significant contribution to the area. The tree has been subject to crown reduction and has been trimmed up to the boundary of the site.
5.4 The current application is for an interesting bespoke design. The proposals were the subject of pre-application advice (DC/PREAPP/17/2416) when the principle of development of the site for a dwelling was supported. It was acknowledged that this was a site specific response to a town centre constrained urban setting and the general layout and accommodation proposed was supported.
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5.5 There are no important views either from or towards the site identified in the Conservation Area Appraisal, although the existing brick boundary wall to the frontage along The Terrace is noted as an important wall. The Appraisal also identifies the importance of the gardens that lie below and to the east of The Terrace, which
…..provide a green buffer at the rear of buildings on the west side of High Street and seen from The Terrace which enhances the linear form of the development and supports several fine garden trees, which are spa se ithi the Co se atio A ea .
5.6 The site does not contribute as much to the character of the Conservation Area, as those areas further to the north, where there is a greater sense of openness and green space between The Terrace at higher level and The High Street at the lower level. Just to the north of the site this degree of openness is considerably reduced by the presence of the terrace of three cottages, which together with the addition of Gallery House adjoining the northern boundary of the site and a further dwelling between Gallery House and the cottages, currently under construction, have created a stronger degree of enclosure to The Terrace.
5.7 In addition, there are already some modern flat roofed outbuildings currently occupying the site including a garage fronting The Terrace, all in poor condition, which along with the disused garden land on the rest of the site have a negative impact on the character of the area. Development of the site therefore presents an opportunity to positively improve and enhance the appearance of the area.
5.8 Given the topography and sensitivity of the site, this is a challenging site and the design is a specific response to its context and constraints, particularly the existing topography, with living accommodation at street level and above and bedroom and ancillary accommodation at the lower levels, whilst still retaining useful areas of external open space.
5.9 It has successfully incorporated the existing brick boundary wall into the design, utilising the existing openings and retains the existing tree to the south. Revisions have been made to the design to address a number of issues previously raised including a slight reduction in height to ensure a degree of stepping down of the roof scape along The Terrace, with the proposed eaves and ridge set lower than the adjoining Gallery House.
5.10 There is now a clear separation between the proposed dwelling and Gallery House so that it reads as a detached building, in character with the cluster of adjacent dwellings. The form of the building with a pitched roof, relates well to the surrounding character and along with a traditional slate roof, the façade incorporates a distinctive timber cladding with superimposed timber rain screen cladding, with the tones and colours of external materials being from a restricted palette.
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5.11 It is considered that it is a high quality, distinctive design which has positively responded to the site and its context. It will be a positive addition to the rich and varied townscape of Aldeburgh which will enhance the appearance of the site and the Conservation Area, subject to approval of external materials and detailed design of external elements.
5.12 The specialist advice of the Design and Conservation Officer is that the proposal will enhance the appearance of the site and the Conservation Area.
5.13 The proposal does not need to be considered against para 134 of the NPPF and it is judged that the proposal would provide a level of public/community benefit which would outweigh any (less than substantial) harm to the Conservation Area.
Highway safety and parking
5.14 Whilst impact upon the Conservation Area is one of the principal considerations/issues, there are also issues in respect of highway safety/parking and impact upon the residential amenity of neighbouring properties which determine whether overall the development is a sustainable development. The Highway Authority recommends refusal because the proposal involves a single garage space.
5.15 The scheme shows a single car parking space. The existing garage, which presumably served a property in the High Street would be lost and the level of parking provision for both the original High Street property and that now proposed would be below the minimum standards required under the current SCC parking standards. There is an acknowledged on-street parking problem in The Terrace and the level of under- provision would exacerbate this acknowledged problem.
5.16 However, the site does lie within the Town Centre, which is served by public transport opportunities. The current proposal is identified as a two bedroomed dwelling with parking standards being two spaces required, representing under provision by a single space. On balance in a town centre location such under provision is not considered to be of a magnitude to justify the refusal of planning permission.
5.17 The access and garage would not have on site turning and cars will either need to reverse into the garage or reverse out. Whilst this arrangement does give rise to safety concerns given its relationship to Choppings Hill and the junction of the Terrace with Hartington Road, the proposal replaces an existing single garage where this access arrangement was no different. The arrangement will be the same as existing and is not considered to intensify the use of a substandard access.
Residential Amenity
5.18 The close relationship to other flats/properties to south and east may be considered to result in adverse impact upon the privacy and light of these units, where there may as a result, be conflict with the requirements of DM23 of the Local Plan. No objections have been received from flats above properties in the High Street, the resident of Bank
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House supports the proposal. On balance it is not considered that a refusal is justified contrary to DM23. However, it is considered appropriate to remove Permitted Development Rights to safeguard the amenity of residents of adjoining properties.
Other matters
5.19 Concern has been raised with regard to the presence of springs within the cliff between the High Street and Terrace. These are not known to be present on the application site and this is not a reason to justify the refusal of planning permission in this instance.
5.20 There is an existing tree which has been subject to crown reduction which lies immediately south of the proposed dwelling. This tree had been consented for removal by SCDC but has not been removed. It is considered that care will be required at construction phase to avoid serious impact upon roots of the tree and the tree protection work will need to be made a condition of planning permission if approved.
5.21 The dwelling will be CIL liable.
Conclusion
5.22 The location of the dwelling within the physical limits and within the Town Centre is a sustainable location. The proposed development is considered to have a positive impact upon the character of the Conservation Area.
5.23 There is sufficient separation to neighbours to limit impact upon light/enclosure and privacy.
5.24 An objection has been received from the Highway Authority because of inadequate parking, but the site is located within Aldeburgh Town Centre where the sustainability of the location justifies a relaxation of parking standards in this instance.
5.25 The planning balance is in favour of the dwelling and it is considered to be a sustainable development and is recommended for approval.
RECOMMENDATION: APPROVE subject to conditions to include:
1. Time limit 2. Implementation in accordance with amended plans 3. Material/details 4. Parking provision and retention 5. Refuse storage/presentation 6. Tree protection/foundation design 7. Removal of permitted development rights 8. Construction Method Statement
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DETERMINATION:
BACKGROUND PAPERS: Planning Application File Ref No DC/18/0086/FUL.
Committee Date: 19 July2018
Site Visit:
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2. ALDRINGHAM CUM THORPE – DC/18/0881/FUL – Rebuilding of No 1 Old Homes Road ancillary to Johnnygate at Johnnygate, Beach Farm Road, Thorpeness, Aldringham-Cum- Thorpe, IP16 4NZ for Dr Deborah Kearns.
Case Officer: Stephen Milligan
Expiry Date: 26 July 2018
EXECUTIVE SUMMARY
Full Planning Permission is sought for the erection of a building attached to 2 Old Homes Road, Thorpeness for use for garaging, gallery and studio space ancillary to the property Johnnygate.
The development lies on the edge of Thorpeness Conservation Area, within the physical limits of Thorpeness as defined within the Local Plan and close to the Coastal Change Management Area.
This item has come before members following consideration by the Delegation Panel of SCDC because the issues of residential amenity. The application is recommended for Approval.
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1. SITE DESCRIPTION 1.1. The property lies within the physical limits of Thorpeness, as defined within the Suffolk Coastal Local Plan and within the Suffolk Coasts and Heaths Area of Outstanding Natural Beauty (AONB).
1.2. The site lies outside Thorpeness Conservation Area with the boundary of Thorpeness Conservation Area following the south-west and north-western boundaries of the property. The Local Plan identifies a Coastal Change Management Area and this lies in the vicinity of the proposed building and appears to encompass the eastern part of the proposed building.
1.3. The property has a neighbour 2 Old Homes Road which is an end terrace dwelling, two stories in height.
2 THE APPLICATION 2.1 The proposal is to build a part two storey part single storey building attached to No 2 Old Homes Road, in order to provide accommodation incidental to Johnnygate. The accommodation comprises a garage, gallery and studio spaces including wc and shower room. 2.2 The building is a replica of 1 Old Homes Road, a dwelling which formerly existed at the site.
3 CONSULTATIONS
3.1 Aldringham cum Thorpe Parish Council: raise no objections, stating:
“The Parish Council believe the proposal to rebuild No 1 in the style and size of the original property, using similar materials and conforming where possible to the original street scenes the most appropriate proposal for this site. However, we consider the use of planting and trellis on the balcony as screening to prevent overlooking of No 2 could be viewed as a temporary expedient and request that a more permanent solution should be adopted. We would also like assurance that the proposals to mitigate the risk of potential flooding are acceptable and will not require any changes to the heights or elevations of the building to comply with regulations before we can give an informed opinion on this application.
3.2 Suffolk County Council – Highway Authority: Raise no Objection, recommending a condition relating to the manoeuvring and parking of vehicles.
3.3 SCDC - Head of Environmental Services and Port Health: raise no Objections
3.4 Third Party Representations: Five Letters of objection have been received raising the following matters:
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Impact upon privacy of neighbour from window and roof terrace. Impact upon the character of the area/Conservation Area. Access is likely to be an issue. If this is truly ancillary to Johnnygate surely an extension would make more sense. Building adjoining to Old Homes could compromise the footings of the neighbouring property and the entire row. The proposal would make No 2 a mid terraced property. Overdevelopment of site. This will be yet another second home.
4. RELEVANT POLICIES
4.1 NPPF (Framework)
4.2 NPPG
4.3 Suffolk Coastal District Local Plan – Core Strategy and Development Management Development Plan Document (adopted July 2013) policies:
SP1a – Sustainable Development SP1 – Presumption in Favour of Sustainable Development SP12 – Climate Change SP15 – Landscape and Townscape SP18 - Infrastructure DM6 – Residential Annexes DM19 – Parking Standards DM21 – Design: Aesthetics DM22 – Design: Function DM23 – Residential Amenity DM28 – Flood Risk
4.4 The Area Policies and Site Specific Policies Development Plan Document 2017, policies:
SSP2 – Physical Limits Boundaries SSP42 – Coastal Change Management
4.5 Supplementary Planning Document – Thorpeness Conservation Area Appraisal – June 2010
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5. PLANNING CONSIDERATIONS
Principle of development
5.1 The proposal is for a building for use ancillary to the host property Johnnygate. The proposal is for consideration against Local Plan policies DM6 and DM21. The building is however attached to 2 Old Homes Road and replicates the former property No 1 Old Homes Road where the primary issues relate to impact upon the Conservation Area; impact upon residential amenity and Coastal Change Management.
Impact upon Conservation Area and Visual Amenity
5.2 A key consideration in assessing the proposed development will be the impact on the character and appearance of the conservation area and whether it will be preserved or enhanced. Paragraph 126 of the National Planning Policy Framework states that account should be taken of 'the desirability of new development making a positive contribution to local character and distinctiveness' and 'opportunities to draw on the contribution made by the historic environment to the character of a place'. Paragraph 137 of the NPPF also states that 'Local planning authorities should look for oppo tu ities fo e de elop e t ithi Co se atio A eas…..a d ithi the setting of heritage assets to enhance or better reveal their significance.'
5.3 The proposal has been considered by the Interim Design & Conservation Support Officer of SCDC who confirmed that the site was previously occupied by no 1 Old Homes Road, which formed the end property of the terrace (nos 1-6 Old Homes Road), but has since been demolished and this area now forms part of the curtilage of Johnnygate.
5.4 The o igi al te a e of fou C fishe a s ottages as e te ded ith a ga led addition at either end, to create a symmetrical terrace of six properties during the early C20 by Glencairn Stuart Ogilvie, as one of the first projects within the planned seaside resort village of Thorpeness. The photographic evidence submitted illustrates the four original cottages and the terrace of six, taken in 1912 after extension.
5.5 It is not clear when no 1 was demolished, but the end wall of no 2 is now rendered and painted and reads as a rather stark and blank façade on the boundary of the conservation area, having a negative impact on its character and appearance. The original terrace is two storeys of brick and flint pebble construction with a pantiled roof, contrasting with the black weatherboarding of the later extension.
5.6 The Conservation Area Appraisal for Thorpeness notes that the terrace makes a good contribution to the character and appearance of the conservation area.
5.7 Key considerations in assessing the impact of the proposed development are whether the character and appearance of the Conservation Area will be preserved or
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enhanced. The proposed development is intended to mirror the front elevation of no 6 and to be of a similar scale and form to the previous no 1.
5.8 The overall scale and form of the proposed extension has been informed by the character of the terrace and the previous addition. The design has been revised with the whole of the front gable to the north-east now being in black weatherboarding to match the existing gable at the opposite end of the terrace.
5.9 Overall, subject to deletion of the flue and replacement with a simple, traditionally detailed brick chimney, the conclusion is that the proposed development will enhance the character and appearance of the conservation area, especially through screening of the existing blank wall with its current harmful visual impact.
5.10 Revised plans have been received which propose a brick chimney stack as required by the Design and Conservation Officer. The subsequent design is considered to have a positive impact upon the character of this part of the village and is in compliance with policy DM21.
Flood/erosion Risk
5.11 The application site lies within Environment Agency Flood Zone 1 and is not identified as being at risk of flooding. The proposal is however in close proximity of the Coastal Change Management Area subject of policy SSP42. SSP42 states that:
All other new development, redevelopment, extensions to existing property and development or intensification of land uses will only be permitted where it can be demonstrated through the submission of a Coastal Erosion Vulnerability Assessment (CEVA) that it will result in no increased risk to life or significant increase in risk to p ope t .
5.12 The application has been considered by the Senior Coastal Engineer of East Suffolk who confirms that the relevant parts of Shoreline Management Plan (SMP) 7, i.e. maps in Appendix C, Annexe 1, Adopted Policy, map 11 shows that the application property extent may be affected by erosion in epochs 1 and 2. However by epoch 3 the SMP predicts there will be significant erosion of the curtilage of Johnnygate, albeit not extending as far inland as the site of the development proposed by this application. If a 30m risk zone is added to the SMP erosion extents the proposed development site is within the 100 risk zone and may also be within the 50 year zone.
5.13 Looking to the future, forecast coastal erosion and current coastal management policy is predicted to require that Johnneygate is demolished and removed. The implication of the ancillary use of the development is that the proposed development would also be removed at that time as it is an integral part of the Johnnygate property and not an independent property that might be retained and occupied beyond the life of Johnnygate. Removal of the development as part of the Johnnygate removal process is recommended to be made a condition of the application approval.
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Residential Amenity
5.14 The proposed building includes both a roof terrace and a full height window at first floor level facing south. The window would permit views into the rear garden of No 2 Old Homes Road.
5.15 The property already is overlooked by first floor windows in 3 Old Homes Road and the level of additional overlooking in this context is not considered to result in serious additional impact so as to justify the refusal of planning permission. The Agent has however confirmed that the window will be obscure glazed to head height to mitigate a o goi g o e s a out o e looki g .
5.16 The roof terrace has trellis privacy screens which restrict overlooking into the rear ga de of No . The Age t o fi s that the appli a t is p epa ed to ake this a solid timber panel with wires for planting, if this helps demonstrate that we do not want to o e look ou eigh ou s ga de . A solid pa el ould p e lude sig ifi a t o e looki g from the roof terrace. The retention of the screens can be made a condition of planning permission.
5.17 Cars currently park cars in the location of the proposed garage. By enclosing parking, with the garage entrance directed away from the boundary, this will reduce noise disturbance to the resident of No 2.
Other Matters/Considerations
5.18 In respect of foundation design, the agent confirms that they have employed a structural engineer to advise on a cantilevered foundation solution to keep away from the existing foundations of No.2 Old Homes Road. He has approached a party-wall surveyor to ensure that proper and appropriate precautions are taken to protect No.2 Old Homes Road during the works.
5.19 It is also confirmed that access to No.1 Old Homes Road will be from Johnnygate. It will not impact on parking in Old Homes Road. This applies during construction and when completed.
5.20 The proposal would increase the level of residential floorspace in excess of 100sqm. It is therefore liable under the Community Infrastructure Levy.
Conclusion
5.21 On balance the creation of a replica of 1 Old Homes Road is considered beneficial to Thorpeness Conservation Area.
5.22 Impact upon the neighbour is limited by design, privacy screens and fact that there is already limited privacy as a result of the relationship between Nos 2 and 3 Old Homes Road.
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5.23 There is no issue with flood risk. The risk posed by coastal erosion is greater for the host property Johnnygate and appears limited for the proposed lifetime of the development. The demolition of Johnnygate when necessary as a result of coastal erosion, will necessitate the removal of this building.
RECOMMENDATION: APPROVE subject to conditions:
1. Time limit of commencement; 2. Implementation in accordance with approved plans 3. Materials 4. Ancillary use to Johnnygate 5. Provision and retention of Parking/manoeuvring areas 6. Demolition of building when Johnnygate is required to be demolished as a result of coastal erosion.
DETERMINATION:
BACKGROUND PAPERS: Planning Application File Ref No DC/18/0881/FUL.
Committee Date: 19 July 2018
Site Visit:
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3. GRUNDISBURGH – DC/18/1636/FUL – Erection of a single detached dwelling and car port on Land South of 24 Pound Cottages, Ipswich Road, Grundisburgh, IP13 6TP for Lord Cranworth
Case Officer: Joe Blackmore
Expiry Date: 18 April 2018 (Extension of Time: 31 July 2018)
EXECUTIVE SUMMARY
Planning Permission is sought for the erection of a new dwelling and detached car port on land south of 24 Pound Cottages, Grundisburgh.
This item has been referred to the Planning Committee via the referral panel to enable the principle of development in the context of policy DM4 (Housing in Clusters in the Countryside) to be fully considered by the Planning Committee.
The application is recommended for approval subject to controlling conditions.
1. SITE DESCRIPTION 1.1 The application site lies to the east side of Ipswich Road and is an irregular shaped parcel covering some 0.16 hectares. The site sits on the corner plot at the junction of Ipswich Road and Park Road, currently forming the side garden of the property at Pound House. To the north, the site is bound by a residential property and, to the east,
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by the Grundisburgh recreation ground. There are a number of mature trees on the site - one of those being the Oak to the front of the site which is protected by Tree Preservation Order (no. 265 2017). The site also falls within a locally designated Special Landscape Area (SLA).
2. PROPOSALS 2.1 The proposal is to erect a detached dwelling approximately central on the plot. A detached double carport is proposed in a position adjacent the south side wall of the dwelling. Access is proposed off Park Road, to the south. The proposed dwelling is to be constructed of red brickwork and painted render, with the roof covered in red plain tiles. The dwelling would have a height of 6.9 metres - at the tallest point - and, along with the detached carport, would cover a ground area of some 170 square metres. For reference, the site area covers 1622 square metres. 2.2 Relevant Site Planning History: DC/16/4854/FUL: Erection of a single detached dwelling and a double carport; application withdrawn following concerns raised by officers over the design and potential tree impact.
3. CONSULTATIONS
3.1 Grundisburgh Parish Council: object to the application stating: The Pa ish Cou il o je ts to this p oposal to construct a large 4 bedroomed house with 3 en-suite bathrooms and a family bathroom on this site outside the adopted physical limits boundary of Grundisburgh.
The site is in a visually prominent position on the corner of Ipswich Road and Park Road. The open aspect of this area, with a number of important trees, including the village Land Mark Oak now covered by a TPO, makes a valuable contribution to this entrance to the village. It is a gentle buffer between the countryside and the built up area. To have any residential development on this site would immediately put valuable trees at risk.
The previous application on this site DC/16/4854/FUL was withdrawn by the applicant when the District Council made it clear that the application was to be refused at officer level. The Parish Council have consistently and successfully opposed any extension to the physical limits boundary along Park Road, a narrow country lane unsuitable for many of the vehicles that try to use it. This area is not well related to the centre of the village. The site, as the name suggests, was used up until the mid-eighteenth century as the village pound where stray animals were driven and confined. The majority of the properties around the site were built to house estate workers, employed at Grundisburgh Hall on the opposite side of Park Road. Most properties are still owned by the estate and rented with the exception of 6 Park Road, the old police house and 24 Pound Cottages the owners of which have both objected to the proposal.
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The Parish Council are concerned that the location plan, site plan, proposed site plan and the street scene are all incorrect, as 24 Pound Cottages was extended some eleven years ago. The property is now situated close to the boundary with this site as can be seen from the aerial photo included with this application. The aerial photograph clearly shows that there is no cluster of properties adjacent to the adopted physical limits boundary of Grundisburgh along Park Road. The physical limits boundary runs along the garden of 24 Pound Cottages. The application site, which until recently was part of the garden of Pound House is not an infill site within a continuous built up frontage. Beyond Pound House are the semi-detached cottages known as South View and Park View then the emergency access to the playing field. So the 3 properties cannot be considered to form a cluster a continuous built up frontage but a ribbon development, an historic group related to the Estate and Park land opposite. This proposal is therefore contrary to Suffolk Coastal Local Plan policy DM4. (a) The scale of development consists of infilling by one dwelling or a pair of semi-detached dwellings within a continuous built up frontage; (b) It would not cause undue harm to the character and appearance of the cluster or any harmful visual intrusion into the surrounding landscape;
A luste i this o te t: • Co sists of a o ti uous li e of e isti g d elli gs; • Co tai i g o o e d elli gs;
This single large dwelling cannot be justified in terms of meeting housing supply needs as Grundisburgh has a nil housing allocation 2010 – 2027, already the village has extended by 45 properties.
The proposed access to this site is very close to the junction with Ipswich Road. Vehicles turning into Park Road from the village would have no view of the access and valuable hedging would have to be lost to form an effective splay.
The Parish Council objects to this proposal and urges the District Council to preserve the valuable physical limits ou da of G u dis u gh.
3.2 Suffolk County Council - Highway Authority: No objections subject to conditions as proposed in the recommendation. 3.3 SCDC - Head of Environmental Services and Port Health: No objections. 3.4 Third Party Representations: Five letters of objection have been received raising the following matters: The site is outside the physical limits boundary and does not fall within a bona-fide luste ; No recognised need for housing in Grundisburgh; Danger this proposal will set a precedent for further ribbon development along Park Road; Development will have an adverse impact on important TPO Oak on the site;
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As the TPO Oak is very close to the highway, roots will encroach much further into the site than the Arboricultural plans indicate; Proposal will erode the rural character on the edge of the settlement; and Design is out-of-keeping with surrounding properties.
4. RELEVANT POLICIES 4.1 National Planning Policy Framework (NPPF)
4.2 National Planning Practice Guidance (NPPG)
4.3 Suffolk Coastal District Local Plan – Core Strategy and Development Management Development Plan Document (adopted July 2013) policies:
SP1A – Sustainable Development SP1 – Presumption in Favour of Sustainable Development SP2 – Housing Numbers and Distribution SP15 – Landscape & Townscape SP19 – Settlement Hierarchy SP29 – The Countryside DM3 – Housing in the Countryside DM4 – Housing in Clusters in the Countryside DM21 – Design: Aesthetics DM22 – Design: Function DM23 – Residential Amenity DM28 – Flood Risk
4.4 Suffolk Coastal District Site Allocations and Area Specific Policies Development Plan Document (adopted January 2017) policies:
SSP2 – Physical Limits Boundaries; and SSP38 – Special Landscape Areas.
5. PLANNING CONSIDERATIONS 5.1 Section 38(6) of the Planning and Compulsory Purchase Act requires that, if regard is to be had to the development plan for the purpose of any determination to be made under the Planning Acts, determination must be made in accordance with the plan unless material considerations indicate otherwise. The relevant planning policies are detailed in section 4 of this report.
Principle of Development 5.2 The site is located in the countryside however its northern boundary abuts the Grundisburgh settlement boundary. The relevant starting policy is DM3 – Housing in the Countryside, which sets out a number of criterion where housing in the countryside is permissible. Relevant to this development proposal is the reference to housing in clusters in the countryside, which is covered by specific policy DM4.
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5.3 DM4 sets out that infilling by one dwelling within a continuous built up frontage will be permissible, providing the site falls within a clearly defined cluster. A cluster, in this context, comprises: A continuous line of existing dwellings adjacent to an existing highway; Contains five or more dwellings; and Is located no more than 150 metres from the edge of an existing settlement identified as a Major Centre, Town, Key Service Centre or Local Service Centre (300 metres if a footway is present).
5.4 Grundisburgh is a Key Service Centre and the site is within 150 metres of the settlement. There is a continuous line of dwellings adjacent Ipswich Road and Park Road, one which the site would fall within whereby it would constitute infilling. Objections from local residents and the Parish Council suggest the site does not fall within a cluster because - for it to be so - the 'cluster' would have to include dwellings already within the physical limits boundary. However, the policy does not preclude dwellings located within the settlement boundary contributing to make up a cluster. On this basis the dwellings at: Fair View; Fairlands; 24 and 25 Pound Cottages (all within the settlement boundary) are in a row adjacent and the application site forms an infill plot between these properties and the property to the south at Pound House (which is outside the settlement boundary). This is considered to make up a cluster in the context of policy DM4. Furthermore, when looking at what the policy is aiming to achieve, it is clear that the objective is to permit new housing within a small group of existing properties whereby it would relate well to a sustainable settlement. In this regard, the proposal accords with the objectives of policy DM4 and the principle of development is therefore acceptable.
Impact on Trees and Landscape Considerations 5.5 The key tree on site is the TPO protected Oak (T2) which is a major local landmark tree. Officers consider this Oak to be highly prominent and significant in the location. Be ause of the Oak s p o i it to Ips i h ‘oad, it has to be assumed that the ground conditions under the road and footpath are likely to be hostile to root growth and therefore the tree will have relied on the undeveloped ground across the rest of the application site. The Arboricultural Impact Assessment and Tree Survey submitted with the application (amended following feedback from the Arboriculture and Landscape Manager) identifies the substantial root protection areas and how the dwelling and carport will be positioned outside these areas; a strategy to construct the access d i e a ith o-dig ethodolog is also p oposed.
5.6 The trees to be retained would be protected by the use of stout barrier fencing (in accordance with the requirements of BS 5837:2012) including any necessary ground protection. All fencing provided for the safeguarding of trees would be erected prior to any demolition or development commencing on the site, therefore ensuring the maximum protection.
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5.7 The impact on the TPO Oak is thus considered acceptable provided that the described arboriculture impact mitigation measures are secured and implemented by planning condition.
5.8 Whilst the direct impact of the development proposal is considered acceptable, it is important to note that it is quite likely that there could be future pressure to have the size of the tree crown reduced because of its sheer physical presence and proximity to the house position which will create a degree of afternoon/evening shading in the front of the house. Whilst the TPO remains in place the Council will be in a strong position to resist such pressures, a d the e is a ele e t of u e e a e fo potential occupants. However, it should be understood that if this space is established as residential/domestic garden space, the risk assessment will alter compared to its current undeveloped use and so applications for works to the tree will need to be assessed under that new use consideration. Whilst this is not deemed a reason to refuse planning permission, it is necessary to consider how the development of the site will change the future consideration of works to the Oak.
5.9 A number of other mature trees on the site are to be retained with the dwelling and carport constructed outside of their root protection areas.
5.10 The site falls within a locally designated special landscape area (SLA) where the policy focus is to only permit development that does not materially harm the special qualities of these SLAs. The site is an undeveloped gap on the edge of the settlement however the key positive landscape feature is the landmark Oak which, as described above, will be retained and protected through the development. This tree is so substantial it will also partially obscure views of the new dwelling from the southern approach into Grundisburgh. The built form of the southern edge of Grundisburgh is contained to the north and east of Park Road, and the site falls within this area. Because of this, a new dwelling in this location will not harm the much wider SLA and will simply read as an infill plot on the edge of the settlement. Thus, there is no conflict with policies SSP38 and SP15 of the Development Plan.
Design Considerations and Streetscene Impact
5.11 The dwelling would be of a scale well-related to the adjacent properties to the north, at Pound Cottages. This is because of the one-and-a-half storey form keeping the eaves and ridge level lower than these adjacent dwellings. The proposed dwelling is also appropriately sized for the plot, affording substantial areas of garden/amenity space whereby it would not be an over-development of the site.
5.12 In terms of its architectural quality, the proposed dwelling is not exceptional, but it is fairly traditional; responsive to its context; and of an appropriate scale. The half- hipped roof form to the front facing gable is not an ideal design feature, but it does mimic the hipped roof forms to the adjacent dwellings and bus stop, so it is not an alien design feature. Specific materials detail has not been provided and therefore further information by planning condition, in this respect, would be necessary to achieve a high quality finish.
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5.13 In terms of streetscene impact, much of this has already been addressed in the landscape considerations of this report (paras 5.5 – 5.10). Further to this, officers consider the proposed dwelling to be of an acceptable design quality that is well- related to its surroundings. In any event, the massive landmark Oak will somewhat obscure public views of the dwelling, which will help reduce any impact on the character of the streetscene.
Residential Amenity
5.14 With regard to the northern neighbour, the proposed dwelling would be over eight metres from this dwelling with a strong degree of intervening vegetation providing separation. Furthermore, there is no first floor side fenestration that would result in overlooking.
5.15 The dwelling would be sited fairly centrally within the plot, a considerable distance from the neighbouring properties. The dwelling is also not of an excessive scale that would be overbearing, and there is strong intervening vegetation and trees that will reduce impacts but, in any event, the physical relationship between the dwelling and neighbours is entirely acceptable in accordance with policy DM23 of the Development Plan.
Highways Safety
5.16 The Suffolk County Council Highways Authority has been consulted on the proposal and there are no objections on highways safety grounds. Officers consider that there is ample parking and manoeuvring areas contained within the site, and that the access onto Park Road will have good visibility in all directions (subject to the frontage hedge being maintained at no higher than 0.6 metres above ground level).
Land Contamination and Flood Risk
5.17 The application is supported by the required land contamination assessments, which find no human health risk. The Environmental Protection Team raises no objection. The site also lies in flood zone 1 where the risk of flooding is very low and therefore suitable for residential development. No conflict with policy DM28 – Flood Risk.
Planning Balance and Conclusion
5.18 Officers consider that the proposal accords with the Development Plan in respect of the policies related to housing in the countryside. Furthermore, notwithstanding that the site is located outside the settlement boundary - it is immediately adjacent to it (a key service centre) with pedestrian connectivity from the site to the village core. There is also a bus stop adjacent the site that is served by routes 70 and 70A, providing a Monday-Saturday service to the towns of Ipswich and Woodbridge. Therefore, occupiers of the new dwelling would not be reliant upon private motor vehicle to access shops/services, and the site is considered to be sustainably located for new
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housing. The proposal would also deliver some benefits: a contribution to housing supply; local economic benefit through short-term construction jobs; and support for local shops/services, once complete and occupied. From a single dwelling these benefits carry very modest weight, but they are benefits, nonetheless.
5.19 Whilst the development proposal could result in some pressure at a later date for works to the landmark TPO Oak, the construction of the dwelling itself would not result in direct harm to it and the proposed protection/mitigation measures are deemed acceptable by the Cou il s A o i ultu e a d La ds ape Ma age . As the landmark Oak will not be directly harmed by the development, its positive contribution to streetscene character and the edge of settlement location would be retained – also helping to screen the new dwelling from street view. The TPO in place also gives the Council a good degree of control over the future of this tree.
5.20 It is a material consideration that Policy SP2 (Housing Numbers and Distribution) of the Core Strategy is out-of-date and, notwithstanding that the Council can demonstrate a five year (+ 20%) housing land supply of 9.3 years, SP2 being out-of-date means that the tilted ala e of NPPF pa ag aph is e gaged fo de isio -taking. Paragraph 14 states that planning permission should be granted unless: (a) any adverse impacts of doing so significantly and demonstrably outweigh the benefits, when assessed against policies in the Framework as a whole; or (b) specific policies in the Framework indicate development should be restricted.
5.21 The proposal is considered to comply with the Development Plan, specifically policy DM4; deliver some small benefits; and represent sustainable development. There are not considered to be any significant adverse impacts arising that would indicate planning permission should be refused. Furthermore, there are no specific policies in the NPPF that indicate development should be restricted. Therefore, on-balance, officers consider the proposal to be acceptable.
RECOMMENDATION: APPROVE subject to the following conditions: 1. Standard time limit 2. Plans/drawings considered/approved 3. Details of external facing materials (roof and wall coverings) to be submitted and agreed pre-commencement 4. Vehicle access to be laid out in accordance with drawings; 5. Area to be provided for manoeuvring/parking vehicles to be provided pre-occupation of the dwelling; 6. The hedge along the highway frontage shall be reduced to 0.6m above the level of the adjacent carriageway pre-commencement of development; 7. Trees and hedgerows: to be retained as per approved plans; 8. Trees: protective fencing to be erected pre-commencement of development; and
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9. Contaminated Land: Action to be taken should unexpected contamination be found (standard condition). DETERMINATION:
BACKGROUND PAPERS: Planning Application File Ref No. DC/16/4854/FUL
Committee Date: 19 July 2018
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4. HACHESTON – DC/17/3742/FUL – Application for fast response embedded power plant at Land West of Electricity Sub Station, The Street, Hacheston, IP13 9ND for Mr Nicolas Martin, Aton Energy Development Ltd
Case Officer: Stephen Milligan
Expiry Date: 24 October 2017
EXECUTIVE SUMMARY
Planning permission is sought for a fast response embedded power plant to be sited adjacent to an existing substation in the countryside between Hacheston and Parham. It would consist of a number of buildings and plant, within a secure compound surrounded by acoustic fencing. Landscaping is proposed around the southern, western and northern sides of the compound to screen the proposals.
Local residents and Hacheston Parish Council have objected to the proposal on grounds of landscape/visual impact; impact upon the setting of Parham Old Hall; noise.
Officers consider that the public benefits of the scheme are sufficient to outweigh the less than substantial harm to the setting of the Grade 2 listed Parham Old Hall and the landscape/visual impact and the application is recommended for approval.
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1. SITE DESCRIPTION 1.1 The site lies within farmland on the northern side of the village of Hacheston, south of the village of Parham. The site is surrounded on its southern, western and northern sides by gently rising ground, with the land east an existing 132kV primary electric substation which is fed by 132kV overhead power lines. The land and existing sub station is accessed by a vehicular access and access road onto the B1116, with the junction some 400m east. The site and surrounding area is a designated Special Landscape Area. The land falls gently in an easterly direction with the River Ore lying on the opposite side of the B1116 some 515m east.
1.2 The nearest residential property is Parham Old Hall, a detached dwelling which is a grade II listed building. This lies 260m north-east. There are other residential properties on the opposite side of the B1116. A public footpath (E-427/001/0) runs east – west on the northern side of Parham Old Hall before turning to the north, on the northern side of the site. At its closest point the footpath is some 120m from the site.
1.3 There is a line of trees alongside the concrete access road, with intermittent hedging on the northern side of the ditch. The site has undulating arable fields to the north, south and west.
1.4 The site forms part of a larger arable field which stretches to the south and south- west. This field covers an area of 51.29ha (127 acres) and runs up to Easton Lane to the south. The highest part of the field is the north western corner at an elevation of approximately 40 metres (m) AOD and slopes gently eastwards to the eastern boundary at about 30m AOD. The north eastern corner of the field is the current site area and falls towards a ditch along the northern boundary at just below 25m AOD.
1.5 A line of major pylons extends from the substation site north westwards across part of the field and northwards into open countryside. A further 33KV power line extends south and then south west from the sub-station.
1.6 The site was previously part of a larger site for a proposed solar park in 2013 (SCDC ref C12/1899) consisting of solar panels to generate up to 25MW of electricity with transformer housing, security fencing and other works including landscaping. This proposal was dismissed at a public inquiry appeal, the inspectors decision was subject to all i by the Secretary of State (Sos), who agreed with the Inspector's findings. The main issues at this appeal were visual impact and the effect on the setting of listed buildings/heritage assets. It was concluded by the SoS that major/moderate adverse impact would be likely on the landscape for recreational users of rights of way and occupiers of Parham Old Hall. There was no guarantee that mitigation planting would occur or be maintained for the life of the development and it was concluded that significant weight should be given to the harm which would occur both to the landscape and the rural setting of Parham Old Hall which was stated to be significantly harmed.
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2. PROPOSALS 2.1 The proposed plant consists of an energy storage unit comprised of utility scale batteries and a substation. These will be connected to transformers, switchgear, and other high voltage equipment all enclosed within a secure compound. The external barrier to the compound will consist of an acoustic fence 3m tall on its southern and western sides, 4m to the north and east.
2.2 The proposal is for the installation of a 50MW reserve power storage and frequency response facility which will operate in support of National Grid and the regional electricity distribution network. There is no primary generation on site, with the response being delivered by grid storage batteries which import and export balanced quantities of energy from the grid.
2.3 The compound would be surrounded by acoustic fencing 3-4m high consisting of metal posts, concrete plinth with timber/acoustic boards.
2.4 Within the compound would be various plant. The invertors have the appearance of cuboid structures, 2.78m by 1.588m and 2.318m high. Transformers are 2.2m tall by 1.887m wide, 1.814m deep. The substation DNO building would be a small flat roofed building 6.24m by 3.7m wide by 3.7m tall. The flat roofed welfare building containing a sink and toilet facilities would be 3.658m by 2.471m and 2.471m high. The control room is a shallow pitched roof building 6.0m long, 3.28m wide by 4.05m high.
2.5 The main grid transformer and disconnector plant is set out in the south-eastern part of the site and is up to 5.7m tall.
2.6 There are three battery types. Type B1 batteries would consist of blocks 2.438m wide by 2.991m deep , with elements 1.988m long by 800mm wide on the roof and sides. Type B2 are rectangular and 3.9m long, 1.0m wide and 2.25m tall. Bank A batteries are housed in containers measuring 15.24m by 2.9 m high and 2.44m deep.
2.7 The battery and switchgear containers would be raised on pre-cast concrete plinths, the transformers on drip trays. The remainder of the compound would be gravelled with SUDs drainage.
2.8 The layout within the compound is designed with a central access track for easy access by lifting equipment and service vans.
2.9 From a security perspective the site would not be permanently staffed, but would have high definition security cameras and other intruder detection equipment installed. These will be connected to a security company for 24 hour monitoring with security lighting installed.
2.10 The scheme includes landscaping to northern, southern and western areas, with semi- mature hedging and trees to be planted on the northern side of the compound.
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2.11 The proposal is stated to provide the equivalent of three permanent jobs and twenty temporary jobs during design and procurement and construction phases and the equivalent of five full time jobs as a result of the installation, with site engineers and manager, said by the applicant to e e uited lo all .
2.12 The application was accompanied by a Design and Access Statement; Heritage Impact Assessment (HIA); and Landscape and Visual Impact Assessment (LVIA). Following the receipt of significant objections in respect of Heritage and Landscape matters and in respect of need/public benefit, further documentation was received, including revised HIA and LVIA , rebuttal documents and evidence of need and lack of alternative sites for the siting of the facility within the region.
2.13 In support of the application, the Design and Access Statement comments: The atu e of ele t i it ge e atio i the UK has u de go e p ofou d ha ges o e the last decade, and the continuing growth of renewables coupled with retirement of old coal generating stations has challenged the security of the electricity distribution grid. Three of key issues are: • I suffi ie t elia le apa it du i g peak de a d ti es t pi all i te workday evenings) • G eater statistical likelihood of unpredictable deviations in supply, particularly over short time horizons, due to fluctuations in wind and solar energy • Loss of s ste i e tia due to e e a les epla i g t aditio al otati g turbines in power generation
The proposed installation is designed to specifically tackle all three issues, and is planned in direct response to National Grid's call for additional fast response balancing plant. The UK government has recognised the need for additional reserve capacity to compliment the installed base of renewables, and DECC has designed the Capacity Mechanism as part of the Electricity Market Reforms to ensure the UK has sufficient capacity to sustain energy security, while at the same time permitting a large component of renewables in the power generation mix.
The proposed plant will participate in the Capacity Mechanism. The plant is predominantly built using the latest battery storage technology, with a smaller component of traditional generation to provide backup, located on a separate site in the UK. While the small off-site generation plant will run on fossil fuels, because the total hours of operation are very low, the carbon impact of this generation is correspondingly small (net carbon savings are over 98%). Without new facilities of this nature, it would not be feasible to continue to install more renewable power generation in the UK. The capital cost of this technology is the lowest currently possible for a fast response backup service, and therefore represents the lowest financial cost to the consumer for this crucial element of a renewable grid.
Because the plant is connected into the local distribution network, it avoids the losses associated with long distance transmission of electricity. This realises approximately
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5% efficiency savings. The plant will also serve to support the stability of the local grid in the SE region. The capacity is sufficient to provide a large proportion of Suffolk Coastal District's requirements, and will be deployed if the electricity system becomes stressed. This will ensure that the region will be contributing to maintaining grid security, rather than being a drain. The proposals will make it less likely that it will trip out during a system stress event. System stress events have been very rare for many decades, but are predicted to become more likely, particularly during the transition phase through to 2025 as the grid adapts and is updated following the closure of the old ge e atio of u lea a d oal po e statio s.
2.14 Further information has been provided, by the applicant, on the need for the facility in a national and local context and including a sequential assessment of alternative sites relative to other 132kV primary electric substations in the wider region. Other submissions have provided a rebuttal of original objections.
2.15 The applicant acknowledges an error within the original submission with reference erroneously to delivery/unloading of fuel. This relates to the previous application which included diesel generators which do not form part of the current application. 3. CONSULTATIONS
3.1 Hacheston Parish Council: object to the application
1. Setting of Heritage Assets
The SCDC must have special regard to preserving the character of a listed building or its setting. The power plant will impact the setting of the designated heritage asset, Parham Old Hall, and have a visual impact particularly for the buildings themselves. Mitigation measures to be implemented by Noriker Power Ltd. for visual impact do not fully mitigate that impact. Although these measures may appear reasonable from pictures taken in the summer when seen from ground level, there will be a visual impact on Parham Old Hall in that the site could be viewable from one or more upper windows of the property. Further, the plant may be visible from Moat Hall. Although some planting around the site is planned to mitigate a visual impact this will be for much of the year. HPC looks for this to be guaranteed to be effective in all seasons throughout the life of the plant and asks SCDC to set this as a planning condition.
2. Landscape and Visual Impact
The proposed development would detract from the character of the landscape and its industrial nature would further erode the rural character of the area. The current plant is a set of structures giving rise to a rather untidy appearance, and with acoustic barriers potentially looks like a solid structure from a distance. It would be clearly visible, especially with four hours of lighting on winter evenings. The site is within a Special Landscape Area and the Local Plan policy guards against development where a material detriment could arise which might detract from the
32 special landscape quality of the area. A precautionary approach is needed, which indicates an EIA is required.
3. Noise or Disturbance Resulting from Use
The Design and Access Statement states in s1.10: The ai i pa t of the site is a s all i ease in noise nuisance. It is therefore desirable that the facility is not placed within a major residential area. D&A If it is not suitable for residential areas, how is it that putting it in a quieter location near residences can be justified? The developers state here that their power plant will generate noise, and further, is a nuisance. Hacheston residents have been advised by a very experienced noise consultant regarding various assessments. He has identified a number of shortcomings and differences of opinion but his comments have been largely disregarded. It is clear that noise assessment is not an exact science and is based upon interpretation of standards, assumptions, experience and some degree of subjectivity.
Therefore no one knows what the actual noise impact of the power plant will be until it is actually operating.
Residents are not convinced that the levels of noise will in reality be as low as is suggested or that there will not be tonal aspects which will detrimentally affect quality of life.
Residents have been badly affected by developments in the recent past despite promises from developers, in particular the biomass plant and changes to the electricity substation itself. Promises from Noriker Power Ltd. are regarded in a similar light. For the substation, it took several years and considerable work for residents to have this rectified.
As Parham Old Hall is a listed building, the occupants are unable to mitigate the effect of noise pollution from the power plant by installing additional glazing.
The Environmental Protection Consultation response (SCDC EHO reference 17/03252/PLNAPP) for DC/17/1407 earlier this year recommended that conditions are imposed limiting the plant installed on the site to the one specified in the application, requiring acoustic and security fencing (see pt7) and that noise shall not exceed background noise levels at nearby noise sensitive receptors.
It is of great concern that whereas the opinion for DC/17/1407 specified conditions, the opinion dated 05/09/2017 for SC/17/3742 does not.
4 Other points
There is concern that there is not enough room to enable turning and manoeuvring of emergency vehicles in the event of a fire or explosion.
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The Appli atio fo e tio s ... A ea fo fuel u loadi g to e o ete with at h e t to i te epto . DC/ / Appli atio Fo , s Unloading fuels could have a fire risk. HPC would like to know for what purpose the fuel is eeded …
Noriker appear to be building in infrastructure to allow the import and storage of diesel which could allow them to make adjustments to add diesel generation in the future. However, HPC would like to hold Noriker to their agreement on 11/06/2017 stating this would never happen.
There is no separate security fencing (unlike DC/17/1407). Acoustic panels, although high, may not be very secure particularly when there are very valuable and potentially dangerous batteries inside. The solar park had to have high metallic special approved security fencing. The compound may attract criminals. A design change might be needed to rectify this.
The site is immediately adjacent to an area recognised for its UK Biodiversity Action Plan species. The site could have a potentially significant negative impact on wildlife species
1. Length of proposed development: The applicant has extended the proposed lifetime of the plant from 25 to 30 years.
2. Loss of Agricultural Land: The development would result in permanent loss of grade 3 agricultural land.
3. Construction: There is concern regarding the total number of HGVs using the B1116 over the construction period as a short-term consequence, each bringing its own noise and pollution which will have a negative impact on residents and local wildlife. Whereas for the previous application it was said that construction would take 3 months, now it appears to be 30 weeks. This is a long time and could become a nuisance if working hours are not set as a condition – as specified by solar park1 conditions.
4. The scale of operation is significant and the plant appears to be large. This is too big for a small, quiet, rural Suffolk village and would negatively impact the village in its countryside setting.
5. The northern footpath will be impacted in terms of noise and visibility.
6. Concerns remain over the installed batteries: are they renewable? Hazel Capital literature advised that the batteries have to be changed after 5 years. This will cause disruption and nuisance.
HPC are concerned that the development was screened under the EIA Regulations and that EIA was not required. The screening is flawed. HPC recommend that the screening opinion is withdrawn and EIA is required.
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In response to a second period of consultation following receipt of amended plans and further information, Hacheston Parish Council reiterate the above objections and e o e d the appli atio is efused.
3.2 Parham Parish Council comments : The Council have asked me to pass on that they feel that an environmental impact assessment needs to be carried out regarding the application in order for them to make an informed recommendation.
3.3 Suffolk County Council - Archaeological Service: No objection and no mitigation required. 3.4 Suffolk County Council - Highway Authority: It is noted that the diesel engine generators have been removed since the original proposal (DC/17/1407/FUL). Therefore, without the need for fuel deliveries, the permanent increase in vehicle use at the existing access will be negligible.
3.5 Suffolk County Council Landscape: With effective planting and aftercare controlled by condition, and the control of external lighting significant landscape and visual effects should be contained. It is noted however that the proposed planting falls outside both the blue and the red lines, this will need to be amended to ensure that mitigation can be delivered and controlled. These comments should not prejudice the detailed findings of the Suffolk Coastal District Council Arboriculture and Landscape Manager.
3.6 Suffolk County Council Ecology : Lighting at this development should avoid any spill onto retained hedges and trees adjacent to the site boundary, to prevent disturbance of bats commuting and foraging along these features. Otherwise the development is acceptable in ecological terms.
3.7 Suffolk County Council Fire and Rescue : Suffolk Fire & Rescue Service (SFRS) would encourage the provision of automated fire suppression sprinkler systems in any new development or a suitable automated gas suppression system, as it not only affords enhanced life and property protection but if incorporated into the design/build stage it is extremely cost effective and efficient. SFRS will not have any objection with regard access, as long as access is in accordance with building regulation guidance. We will of course wish to have included adequate water supplies for firefighting, specific information as to the number and location can be obtained from our water officer via the normal consultation process.
3.8 Historic England comment: Do not wish to offer any comments. We suggest that you seek the views of your specialist conservation and archaeological advisers, as relevant.
3.9 SCDC - Head of Environmental Services and Port Health: is satisfied that the noise from the proposed plant will be below the measured background levels at nearby residential properties and is therefore satisfied that noise from the proposed plant will not adversely affect the residential amenity at any residential properties. There are
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no adverse air quality issues in respect to this application. Therefore has no objections or comments to make regarding this application.
Following concerns/objection received from a local resident concerning tonal noise the following comment was received: I refer to the comments made by Paul Goring in his email of 5th October 2017, concerning the lack of frequency noise data submitted with this application and his assertion that without this data it is impossible to determine the noise impact of the development.
Initially I accepted the details submitted by the applicant; that there was little to no tonal noise, as this has been removed by design change which had been achieved through mechanical isolation of an internal vibrating component from the frame of the machine, which previously made the frame vibrate and produce noise. Hence, the removal of tonal noise had been achieved internally and not by external attenuation which made it more difficult to quantify on paper.
However in order to obtain more detailed information in this respect, I contacted the applicant and requested a more detailed frequency noise assessment of the equipment to be used at this site. I am satisfied that this indicates graphically that there will be no tonal noise which would incur a tonal penalty under BS:4142:14.
I therefore have no reason to question the accuracy of Table 6 of the acoustic report which indicates the noise rating level of the new plant is below the lowest measured background sound level at each of the nearest noise sensitive premises and in this respect have no objection to this development on noise grounds.
3.10 Suffolk Preservation Society: I its espo se to the p e ious appli atio the “o iet raised serious concerns regarding the inadequate assessment of the impact of the proposals on the rural setting and significance of Parham Old Hall, a grade II listed designated heritage asset, contrary to para 134 of the NPPF. The Society also questioned the effectiveness of the proposed infill planting along the northern edge of the site to screen the installation throughout the year.
The Society was therefore pleased to note that the resubmitted application included an appropriate assessment of heritage impacts. This concludes that the proposed installation will have minimal impact on the significance of Parham Old Hall, intervisibility being limited by the proposed and existing trees close to the northern boundary of the site and also within the curtilage of the Hall. Whilst the setting of a listed building is a complex concept which encompasses factors beyond that of intervisibility and includes the character of the surrounding area, whether or not it can e ie ed f o the asset Histo i E gla d s Good P a ti e Ad i e Note , it is therefore vital that a robust landscaping scheme is incorporated into the development. We note however from the submitted landscape strategy plan that the proposed on-site semi mature hedgerow is limited to a depth of 3 metres which we consider to be inadequate to effectively mitigate the visual impact of the substation on the landscape and the setting of Parham Old Hall. We are also concerned that the
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screening relies on existing structural vegetation which is on land to the north of the site and in different ownership. The Society therefore remains unconvinced that the proposed landscaping strategy will provide an adequate degree of screening of the 4 metre high acoustic fencing and 5.7m equipment within the compound, particularly in the winter months. We therefore urge the local authority, if it is minded to approve this application, to ensure that the on-site planted buffer is maximised in depth and to obtain an undertaking for its long term maintenance which does not rely on planting outside the boundary of the site.
3.11 Suffolk Wildlife Trust: Although the application site itself appears to be of relatively limited ecological value, it sits within a wider landscape which contains various sites designated for their nature conservation value and various habitats which support protected and/or UK Priority species. We therefore request that the following potential impacts are given weight in determining this application: Noise There are a number of potentially noise sensitive ecological receptors around the site (nesting barn owl within 200m and ancient woodland designated as a County Wildlife Site (CWS) within 600m). It is noted that since the previous planning application (DC/17/1407/FUL) the diesel generators have been removed from the scheme and that it is understood that the battery type and acoustic fencing proposed will significantly reduce the noise emitted when the site is operational. It is also understood that, when operational, the noise levels at the receptors identified in the noise assessment report will not be significantly above the existing background noise level. We recommend that, should permission be granted, regular noise monitoring is undertaken to ensure that these calculations are accurate and adhered to. Should noise levels be found to exceed the predicted levels, further mitigation measures must be implemented in order to bring operating noise levels below those predicted in the report.
With regard to construction noise, as at least some of the construction activity will have to take place efo e the pla t s pe a e t a ousti itigatio easu es a e put in place, we recommend that temporary acoustic fencing is used to mitigate this impact on nearby noise sensitive ecological receptors.
Lighting The Design and Access Statement (DAS) (Noriker Power, Aug 2017) states that the site will be unlit apart from winter workday evenings up until 8pm and that flood lighting will only be used if there is an alarm event or when required for maintenance work. The DAS goes on to state that flood lighting will be angled towards the ground to prevent light spill out of the compound. To confirm that this mitigation is achievable we recommend that sensitive lighting plan is provided so that it can be ensured that the lighting required for safe operation of the development can be achieved without resulting in an adverse impact on light sensitive ecological receptors.
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Air Quality We note that due to the removal of the diesel powered generators from the scheme there will now be no emissions from the proposed development. We therefore have no further comment on this element of the project.
Conclusion The proposed development requires a number of mitigation and monitoring measures in order to ensure that it operates as predicted in the assessment reports. We request that, should permission be granted, these mitigation and monitoring measures are secured and implemented via suitably worded conditions.
3.12 Third Party Representations: 24 Letters of objection raising the following points : Noise disturbance from the site. The technical details submitted with regard to noise are inadequate with frequency data omitted. Cumulative impact of adjoining electricity substation should be taken into account therefore requiring an EIA. Together the development forms a large industrial facility in a SLA. Boundary hedge and ditch is in separate ownership and cannot be subject of planting. Planting on the southern side of the ditch will affect maintenance. Site is in a Special Landscape Area and on rising ground, visible from a nearby footpath and would not be screened by landscaping for a number of years Detrimental effect on wildlife especially barn owls and Priority Species. Industrial development is inappropriate in a rural village- there are more appropriate sites than this for such a development Impact upon the setting of Parham Old Hall. No proof that development is needed Robust planning conditions need to be put in place in the event the development is approved Planning history of the site should be taken into account- solar farm was dismissed at appeal. EIA screening for DC/16/2190 found that a power plant at the site would have significant impact on ecology and adjacent listed building and it is illogical for EIA not to be a requirement with this application. light pollution Development is not part of Government's aim to reduce carbon- it's a loophole to develop profitable but unsustainable power generation The proposal requires a balancing exercise to weigh up public benefits verses potential harm and there has been no independent verification of the public benefits the economic benefit of the scheme is limited and it will be unlikely to support the number of jobs specified. There will be no local benefit which is against the principles of sustainability. if app o ed the s he e ould ep ese t the thi e d of the edge ith resultant future expansion. the proposal still refer to diesel storage indicating a future intention to introduce diesel generation on the site.
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traffic generation during construction phase and operation. The need for and viability of the proposal over the next 30 years is not proven. OFGEM has now introduced innovative new schemes which are designed to balance the National Grid. The social costs outweigh the benefits. The development is not sustainable. Residents do not know who will be the operator / owner of the proposal and their neighbour over its 30 year lifespan. The applicant, Aton Energy have been invisible during the application process. The Agent, Noriker, who have designed the site is unlikely to construct it or own or operate it. The funding company has been taken over by another company. Most likely the development will be owned / operated by a special purpose vehicle (SPV) company as yet unknown. These SPVs are re-financed and / or sold on as a matter of course potentially weakening their financial resilience. All this undermines any confidence that residents might have that a long-term relationship can be built and long-term commitments will be met.
3.13 A group of residents have commissioned independent evidence on matters of landscape, Historic Building and an assessment of need/public benefit. These are available to view in full via the public access system. These documents are critical of the conclusions drawn by the original submission and identify no significant need for the proposal or sufficient public benefit to outweigh the harm to the setting of Parham Old Hall and the landscape impact.
The comments state: Natio al G id ha e outli ed ho the i te d to a e d the (Firm Frequency Response) FFR tender process in the near future to encourage more tenders from (Enhanced Frequency Response) EFR schemes. The number of developers interested in these tenders is very relevant to whether the proposal for Wickham Market is essential. If the future target for fast storage is around 2GW as indicated in AR4, and backed up by other Applicant references, then this implies 40 X 50MW schemes across the UK (distributed across high demand areas in southern GB according AR4) or more smaller schemes if this enables greater access to suitable connection points. Given the supply pipeline demonstrated by the EFR tender, the FFR tenders and the evidence from Aurora Energy Research then whether one scheme proceeds or not cannot be critical to achievement of this future 2GW target. The Applicant cannot guarantee that it will be able to secure the contracts that enable it to provide the essential and valuable services it describes over the lifetime of the proposal. It cannot therefore guarantee the delivery of the public benefits it claims the proposal delivers. What can be guaranteed though is that the harm to the landscape and heritage assets will occur and will commence from the moment construction commences and continue throughout the 30 year life of the proposal. If the benefits cannot be delivered then they cannot outweigh the harm the proposal will cause. If this proposal is approved SCDC should attach the following conditions to the consent in addition to those that it might normally do so; • A o ditio that e ui es the Appli a t a d a futu e o e to su it to the oise testing regime previously proposed by HPC for Planning Application DC/17/1407/FUL.
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• A o ditio that e ui es the appli a t a d a futu e o e to set up a o - demand bond or escrow account with HPC in order to ensure the future condition and ai te a e of the p oposal s a ousti s ee i g a d la ds ape itigatio s he e. • A o ditio that e ui es the Appli a t a d a futu e o e to su it to HPC a annual report of the FFR contracts (or its successor) it has secured to deliver the claimed public benefits of the proposal. If no such contracts are secured for three successive years then the Applicant or any future owner will be required to decommission the proposal, remove it from the site and return the land to agricultural use. • A o ditio that e ui es the Appli a t a d a futu e o e to de o issio the proposal, remove it from the site and return the land to agricultural use at the end of its consented life.
4 RELEVANT POLICIES 4.1 NPPF (Framework)
4.2 NPPG EN - 1 Overarching National Policy Statement for Energy
4.3 Suffolk Coastal District Local Plan – Core Strategy and Development Management Development Plan Document (adopted July 2013) policies:
SP1a – Sustainable Development SP1 – Presumption in Favour of Sustainable Development SP7 – Economic Development in Rural Areas SP12 – Climate Change SP14 – Biodiversity and Geodiversity SP15 – Landscape and Townscape SP29 – The Countryside DM21 – Design: Aesthetics DM22 – Design: Function DM23 – Residential Amenity DM27 - Biodiversity and Geodiversity DM28 – Flood Risk
4.4 Site Allocations and Area Specific Policies Development Plan Document 2017 Policy SSP38 – Special Landscape Areas
5 PLANNING CONSIDERATIONS 5.1 Policy SP1 identifies the Core Strategy for the future of the Suffolk Coastal district is the achievement of sustainable development. The Strategy in this respect will be to (amongst other matters): (a) mitigate against and adapt to the effects of climate change; (d) ensure the provision of the appropriate infrastructure in order to support existing and proposed communities;
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(e) give priority to re-using previously developed land and buildings in and around built-up areas, where possible ahead of greenfield sites; (j) conserve and enhance the areas natural historic and built environment; (k) maintain and enhance a sense of place; and (l) create and promote inclusive and sustainable communities in both urban and rural locations.
5.2 SP15 states The policy of the Council will be to protect and enhance the various landscape character areas within the district either through opportunities linked to development or through other strategies. In addition to the protected landscape of the AONB, the valleys and tributaries of the Rivers Alde, Blyth, Deben, Fynn, Hundred, Mill, Minsmere, Ore, Orwell and Yox, and the designated Parks and Gardens of Historic or Landscape Interest are considered to be particularly significant.
5.3 The site lies within the valley of the river Ore and is a designated SLA. Policy SSP38 is relevant and states: The alle s a d t i uta ies of the ‘i e s Alde, Bl th, De e , F , Hu d ed, Mill, Minsmere, Ore and Yox and the Parks and Gardens of Historic or Landscape Interest identified in policy SSP37 are designated as Special Landscape Areas and shown on the Policies Map. Development will not be permitted in these areas where it would have a material adverse impact on the qualities of the landscape that make it special. Where development is considered acceptable landscape improvements should be included as a i teg al pa t of the de elop e t p oposal. 5.4 The NPPF Core planning principles includes: take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it; support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change, and encourage the reuse of existing resources, including conversion of existing buildings, and encourage the use of renewable resources (for example, by the development of renewable energy); contribute to conserving and enhancing the natural environment and reducing pollution. conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations;
5.5 Para 98 states: When determining planning applications, local planning authorities should: not require applicants for energy development to demonstrate the overall need for renewable or low carbon energy and also recognise that even small- scale projects provide a valuable contribution to cutting greenhouse gas emissions; and
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approve the application if its impacts are (or can be made) acceptable.
5.6 EN-1 Overarching National Policy Statement for Energy. This states: I E gla d a d Wales this NP“ is likel to be a material consideration in decision making on applications that fall under the Town and Country Planning Act 1990 (as amended). Whether, and to what extent, this NPS is a material consideration will be judged o a ase ase asis.
5.7 In respect of Hacheston, given the proposal is an energy infrastructure project, EN-1 is considered to be a material consideration.
5.8 As background it outlines The oad to and states: We a e o itted to eeti g ou legall i di g ta get to ut g ee house gas emissions by at least 80% by 2050, compared to 1990 levels. Analysis done on possible 2050 pathways shows that moving to a secure, low carbon energy system is challenging, but achievable. It requires major investment in new technologies to renovate our buildings, the electrification of much of our heating, industry and transport, prioritisation of sustainable bioenergy and cleaner power generation. And it requires major changes in the way energy is used by individuals, by industry, and by the public sector. 2.2.2 Delivering this change is a major challenge not least for energy providers, and the Government is working to ensure their efforts produce the major, rapid change the UK needs. Within a market-based system and with severe constraints on public expenditure in the near-term, the focus of Government activity in this transformation is clear. It should be on developing a clear, long-term policy framework which facilitates investment in the necessary new infrastructure (by the private sector) and in energy effi ie .
5.9 In Part 3 it refers to energy storage and states: The e a e a u e of othe te h ologies hi h a e used to o pe sate fo the intermittency of renewable generation, such as electricity storage, interconnection and demand-side response, without building additional generation capacity. Although Government believes these technologies will play important roles in a low carbon electricity system, the development and deployment of these technologies at the necessary scale has yet to be achieved. It is therefore likely that increasing reliance on renewables will mean that we need more total electricity capacity than we have now, with a larger proportion being built only or mainly to perform back-up fu tio s.
5.10 The guidance in EN-1 indicates a general need for technology such as energy storage and that this can compensate for the intermittency of renewable generation. As noted by objectors there is no guarantee that battery storage will definitely be charged from energy from renewable sources, but renewables are clearly a component part of the energy market serving the facility and it is reasonable to consider the proposal as infrastructure for the low carbon energy system.
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5.11 Part 4 In considering any proposed development, and in particular when weighing its adverse impacts against its benefits, the Infrastructure Planning Commission (IPC) should take into account:
its potential benefits including its contribution to meeting the need for energy infrastructure, job creation and any long-term or wider benefits; and its potential adverse impacts, including any long-term and cumulative adverse impacts, as well as any measures to avoid, reduce or compensate for any adverse impacts.
In deciding to bring forward a proposal for infrastructure development, the applicant will have made a judgement on the financial and technical viability of the proposed development, within the market framework and taking account of Government interventions. Where the IPC considers, on information provided in an application, that the financial viability and technical feasibility of the proposal has been properly assessed by the applicant it is unlikely to be of relevance in IPC decision making.
There is a presumption in favour of the conservation of designated heritage assets and the more significant the designated heritage asset, the greater the presumption in favour of its conservation should be. Once lost heritage assets cannot be replaced and their loss has a cultural, environmental, economic and social impact. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. Loss affecting any designated heritage asset should require clear and convincing justification.
Landscape effects depend on the existing character of the local landscape, its current quality, how highly it is valued and its capacity to accommodate change. All of these factors need to be considered in judging the impact of a project on landscape. Virtually all nationally significant energy infrastructure projects will have effects on the landscape. Projects need to be designed carefully, taking account of the potential impact on the landscape. Having regard to siting, operational and other relevant constraints the aim should be to minimise harm to the landscape, providing reasonable mitigation where possible and appropriate.
Outside nationally designated areas, there are local landscapes that may be highly valued locally and protected by local designation. Where a local development document in England or a local development plan in Wales has policies based on landscape character assessment, these should be paid particular attention. However, local landscape designations should be used in themselves to refuse consent, as this may unduly restrict acceptable development.
It is likely that strategic energy infrastructure development will have visual effects for many receptors around proposed sites. The IPC will have to judge whether the visual effects on sensitive receptors, such as local residents, and other receptors, such as isito s to the lo al a ea, out eigh the e efits of the p oje t.
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5.12 Landscape character and visual impact.
5.13 The application lies within the countryside between Hacheston and Parham and forms part of the Ore valley Special Landscape Area.
5.14 The Site lies within National Character Area (NCA) profile South Norfolk and High Suffolk Claylands (83) as defined by Natural England
5.15 The Suffolk County Landscape Character Assessment (LCA) identifies The Site as being situated within the Ancient Estate Claylands (1). Character typology 1 can be found in the eastern areas of Suffolk, with Rivers and tributaries draining in a southerly or easterly direction dissecting the landscape.
5.16 The supporting LVIA ide tifies that The Site sits within a shallow incised dip within the valley slopes and has a gentle fall, which drains eastwards down to the river Ore. As noted in the LCA for the Ancient Estate Claylands the rivers draining east and south di ide the plateau i to a se ies of fi ge s a d this la ds ape is fou d o those esidual areas of plateau. The access road to the existing substation and the Site is positioned alo g o e of these fi ge s .
The shape of the landform combined with the significant woodland blocks located to the west on the plateau and the mature vegetation to the east of the Site within the river corridor somewhat limit the inter-visibility between the Site and the wider area.
5.17 Overall, the Site itself has been assessed to make a positive contribution to the local landscape character although its proximity immediately adjacent to the electricity substation and the overhead powerlines does somewhat detract from the character of the area, somewhat reducing its contribution.
5.18 The LVIA concludes The “ite is o side ed to ake a li ited o t i utio to the lo al landscape character. The Site contains some attributes representative of the local landscape character but also incongruous elements that detract from the local landscape character.
The proposed development comprises the erection of a private substation compound and Distribution Network Operator (DNO) substation compound with associated security and acoustic fencing, overhead cables and power station infrastructures. The proposals also include a semi-mature native hedgerow and trees along the boundaries to provide landscape and visual enhancements.
Overall, on balance the Proposals for the Site are considered to have a Moderate Adverse effect on the landscape resource and local landscape character upon scheme completion, as the change in character will be apparent. However, various mitigation measures are proposed, including: • Provision of hedgerow and structural vegetation planting along western and southern boundaries. Species mix to match the existing hedgerow. The mix will
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include species such as, Hawthorn, Field Maple, Elder, Hazel, Ash and Goat Willow. • New hedging to be planted along the northern boundary following the existing mature trees and vegetation on the north side of the ditch to provide visual screening.
Overall, these measures will provide benefits that will help integrate the development into its surroundings and enhance the landscape character that is currently identified as lying within LCA Ancient Estate Claylands (1) within the Suffolk County Landscape Character Assessment. It is considered as a Slight Adverse effect in the long term.
The significance of the visual effects are highly localised due to the Site location within the incised landform which partially nestles in the surrounding landform. The visual effects range from generally Slight Adverse to Neutral Effect, although it has been assessed that users of a short section of footpath (close to the northern boundary of the Site) will experience a Moderate adverse effect on views and visual amenity during construction and immediately following implementation when walkers are particularly close to the Site, however this would reduce with distance.
Overall, once new mitigation planting has established to integrate the proposals and provide increased screening and softening of the built infrastructure, the overall significance of the effect is considered to reduce to a Slight Adverse to Neutral Effect.
It should be noted that for some views the effects are considered to be short lived, largely because they occur on transient routes – e.g. roads – in these locations the views are often quick or periodic glimpses through gaps in hedges whilst moving along a route. In some instances, the change is not the focus of the view or in line with the direction of travel and as a result the viewer would need to turn his/ her head to fully appreciate the change in view.
5.19 Objectors consider the visual effects arising fro the proposals are under played, with mitigation from planting limited by space, success of planting/limited growth rates etc not carrying the weight ascribed by the applicants. The impact upon views from the public footpath to the north are considered to be significant, by the objectors.
5.20 Officers consider that :
5.21 The site lies to the est of the e isti g su statio fa ilit o a a ea that is u e tl down to grassland in contrast to the surrounding arable crops. Visually the site is reasonably well contained towards the head of a shallow stream side valley that runs eastwards down to the main River Ore Valley. The site falls within a Special Landscape Area and Core Strategy Policy SP15 is notably applicable, referring as it does to the significance of the river valleys, including that of the River Ore, in their contribution to landscape character.
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The site and its surroundings are typical of the County landscape character type although exiting overhead electricity pylons and cables feeding into the existing sub- station detract from the rural scene.
5.21 The application site is visible from the PROW to the north and is considered in the LVIA to offer good to fair visual amenity.
5.22 The LVIA proposes using the management guidelines for the Ancient Estate Claylands LCT as informatives in planning the integration of the site into the landscape, including any mitigation works.
5.23 In considering the effects of the proposal on the surrounding landscape, the LVIA considers the site to be of Medium Susceptibility to accommodate proposed development: An established landscape where change of an appropriate nature could be absorbed without loss of key characteristics, individual elements or features and specific aesthetic or perceptual aspects or, overall landscape character.
5.24 The development proposals will result in direct permanent change to the landscape as resource in its own right as it changes from open grassed farmland to enclosed electricity infrastructure. In considering the significance of landscape effects, the presence of the existing sub-station is considered which means that the proposed facility will not form a distinct new element in the landscape. The impact on the SLA as a whole would be very limited and the overall significance of landscape effects is judged to be Moderate to Slight Adverse. That conclusion also takes note of the perceived benefit of the proposed mitigation measures, but I shall return to this matter later in this response. However, for now and allowing for the maturing of the new planting, the above conclusion moderates to Slight Adverse over time.
5.25 The anticipated visual impact of the proposal has been considered from a number of surrounding public access viewpoints together with the views from the nearest residential heritage assets and these are described in the LVIA report. In all cases the effects are considered to more harmful than Slight Adverse in the first year in winter, and these moderate to Slight Adverse or Negligible/Neutral over time as new planting matures.
5.26 According to the LVIA, the moderation of impacts and effects on the landscape is dependent on the successful planting of landscape mitigation measures along the western and southern boundaries as native species structural planting, and hedgerow planting along the northern boundary. However, from the pla s that I e see , the site boundary is drawn very tightly around the actual site fencing with the indicated new planting beyond this. For the anticipated mitigation measures to be effective in moderating the anticipated landscape and visual effects arising from this proposal, I will need to be convinced that the planting can be legally secured in the long term. Without it the p oposal a ot e o side ed a epta le.
5.27 Following receipt of a revised scheme increasing planting the officers concluded that as far as the revised landscape strategy plan is concerned..we have a workable
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solution now. The final devil will be in the detail of the planting specification, but that a e so ted out he the ti e o es.
5.28 The LVIA does acknowledge impact upon the landscape, with greatest visual impact experienced from footpath No 1 from north. The level of impact is considered to be significantly less than the impact from the 2013 solar farm proposal, which affected a significantly larger area with much of the land elevated above that of the application site.
5.29 SSP38 states that proposals will not be permitted in these areas (SLAs) where it would have a material adverse impact on the qualities of the landscape that make it special.
5.30 The proposed battery storage, within the context of the existing substation, represents an extension and intensification of the existing urban form rather than a standalone feature. In this respect the harm to the SLA is reduced.
5.31 The impact is further lessoned through the planting of screening around the proposed. This will soften the appearance as well as providing some benefits to biodiversity through the enhancement of habitat.
5.32 The main impact will be from footpath 1 from the north and with the acoustic fencing introducing a strong linear feature 4m tall along the northern side of the compound and with some plant visible above the fence line. It will take some time for the proposed planting to provide significant mitigation from this view point. There is a 3 – 5m belt of hedging and trees on the northern side of the compound which will provide screening.
5.33 The Slight adverse impact upon the SLA acknowledged by the LVIA becoming negligible/neutral over time is argued by objectors to be understated, but given the contained location of the site and extent of planting on the northern side, over time, it is not considered that the proposal will have a material adverse impact upon the qualities of the landscape of the SLA that make it special.
The effect on the setting of heritage asset(s)
5.34 The consideration of this matter has been the subject significant debate, and differences of opinion. A series of reports has been prepared from interested parties, ith o sultatio u de take ith Histo i E gla d, the Cou il s he itage officers. Finally, a consultants report was commissioned on behalf of the Council to give a conclusive overview on the matter.
5.35 As part of the application submission a Heritage Statement was included from Bob Kindred Heritage Consultants (BKHC) dated August 2017. This report was revised in October 2017.
5.36 As pa t of the o sultatio / e‐ o sultatio p o ess t o lette s ha e ee e ei ed from Historic England, both of which make no comment other than advising that the
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views of the Local Planning Authorit s o i -house conservation and archaeological consultants should be sought.
5.37 As a esult of eigh ou o sultatio , a i depe de t assess e t of the appli a t s August 2017 report was produced by WYG Heritage Consultants on behalf of third parties. The WYG document is dated October 2017. 5.38 Comments were received on the application from the Principal Design and Conservation Officer in October 2017.
5.39 In order to provide independent assessment of the impact upon heritage assets and the three responses identified above, a consultant was commissioned on behalf of the Council and those conclusions a e used to fo the offi e s fi al ala ed opi io o the matter as set out below.
The applicants Heritage Impact Assessment (BKHC)
5.40 This report principally considers the potential impact of the proposed development on Parham Old Hall, a Grade II listed building to the north east of the application site. Two additional heritage assets of Abbey Farmhouse (Grade II) and Moat Hall (Grade II*) are also considered on the basis that they were referenced in a 2013 Appeal relating to a solar farm in the locality.
5.41 This statement sets out that the site was specifically chosen for its limited visual impact due to the rolling topography.
5.42 In considering the setting the BKHC report references the (then) English Heritage do u e t “eei g the Histo i the Vie Ma . “i e the epo t as itte this document and the version of Good Practice Advice Note 3 referenced in the report have been superseded by the Historic England guidance The Setting of Heritage Assets – Historic Environment Good Practice Advice in Planning Note 3 (Second Edition) December 2017.
5.43 The curtilage of Parham Old Hall which is considered to equate to the garden of the property, is considered to be some distance from the application site (280 metres) but can still be described as neighbouring it whereas the other two identified heritage assets are not considered to have such a relationship to the site.
5.44 The report assesses the impact on the three identified heritage assets as follows The Grade II* Moat Hall is considered to be too remote and lacking in intervisibility with the site to warrant consideration (Para 5.11).
5.45 The proposals are assessed as having no discernible impact on the setting of Abbey Farmhouse given the degree of separation, the topography and orientation of the historic building in relation to the site as well as the extensive screen planting between the house and the Easton Road (Para 5.14).
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5.46 Parham Old Hall is assessed to have a limited visual relationship with the application site (Para 5.12). The rolling topography both hides and reveals the listed building at different points along the access road and public footpaths in the vicinity of the site. The report assesses that the effect of the proposals on the setting of the Hall in visual terms will not have a significant impact (para 5.27).
5.47 The report also considers the axial relationship of the Hall with the application site. It is noted that there are a number of modern additions to the western elevation and the rear elevation is not a principal elevation as it has only three small windows understood to serve the stairs and landing and a roof light with oblique views to the site (Para 5.33). The presence of existing and recently planted landscaping at Parham Old Hall is also noted as mitigating the potential impact (Para 5.36).
5.48 The report assesses the visual impact of the proposal on the setting of the Hall as ei g oadl eut al ut i the o di g of the NPPF pa ag aph is related to what would be considered to constitute less than substantial harm) (Para 5.36).
The comments of the Principal Design & Conservation Officer
5.49 The comments reference the earlier BKHC report (Aug 2017). It acknowledges that the key issue is the potential impact on the setting of Parham Old Hall. This is assessed as ei g a high‐status a o house i a se i‐isolated lo atio et ee the t o settlements of Parham and Hacheston. There is conjecture that building may have been larger and possibly moated.
5.50 The comments identify the setting as being comprised of the garden of the hall and the wider open agricultural landscape beyond to the north, south and west. It is argued that it is significant that the agricultural setting of the building has formed the setting since the building was constructed. The quality of the landscape setting is recognised by its designation as a Special Landscape Area. The key modern intrusion to this setti g is the e isti g su ‐statio .
5.51 There is a view from an original diamond mullion window to the rear elevation of the property which is assessed as being of high importance given that there have been views from this window across the rural landscape since the house was built. This is considered to be important as it is part of the o upie s of the uildi g s e pe ie e of the rural setting. The landscape setting is assessed as contributing to the special interest of the building.
5.52 The public footpath which runs immediately to the north of the Hall provides wide ranging ie s of the Hall i its la ds ape setti g a d the su ‐statio site ill ha e a clear visual impact within the views of the Old Hall from this path. The proposals are held to be alien and industrial in appearance which in conjunction with the existing substation would cumulatively interrupt the established rural setting.
5.53 In assessing the potential harm this is identified as being on key heritage values i ludi g histo i al alue, i espe t of the o eal e t of the histo i use of the la d
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at the application site; the aesthetic value of the organic form of the rural landscape and the relationship of the traditional building to it and the illustrative historical value of the Hall in respect of views from the Hall and the occupiers visual experience of its setti g .
5.54 The comments conclude that the proposals are assessed to cause less than substantial harm to Parham Old Hall and that this harm will be moderately high in magnitude. This less than substantial harm will need to be given great weight by the decision maker and balanced against any public benefits accruing from the development. No heritage benefits were identified as arising from the proposals.
Third party objectors (WYG) rebuttal report
5.55 The epo t iti ises the appli a t s He itage I pa t Assessment (HIA) prepared by the applicant on the basis it fails to consider any other heritage assets in the locality and therefore fails to comply with paragraph 128 NPPF (Paragraph 1.4).
5.56 In paragraph 1.11 the applicants HIA is criticised for misundersta di g steps ‐ of the Historic England guidance Setting of Historic Buildings – Historic Environment Good Practice Advice Note 3 (First Edition). This has been superseded by Edition Two but the steps referenced are still within the amended document. The HIA is criticised for having misapplied the requirement to be proportionate in the assessment and has limited the impact to the immediate setting only. The report therefore considers that the HIA has failed to adequately identify or assess the wider setting and its contribution to the significance of Parham Old Hall.
5.57 In paragraph 1.30 the WYG report takes issue with the consideration within the HIA of the axial orientation of the Hall. It considers that this is immaterial as the Hall is not part of a planned formal landscape but sits in an open rural landscape.
5.58 It criticises the HIA as not considering a number of viewpoints including ones from the application site itself and from within the Hall, the area west of the Hall and to the south along The Street.
5.59 The report is also critical of the HIA as it focuses on the visual impact and does not have regard to other influences on the setting.
5.60 The epo t o side s that the p oposals ha e the pote tial to e ha ful to the significance of the adjacent Grade II listed Pa ha Old Hall Pa ag aph . . The a ousti fe e e losi g the site is assessed as dou li g the ph si al p ese e Pa a . . The ke issue ho e e is the e a e atio of the isual i t usio of the e isti g su ‐statio i easi g the area of pla t a d e uip e t o the appli atio site .
5.61 The epo t o side s the le el of ha esulti g ill e less tha su sta tial ut states there is inadequate information provided to make an accurate assessment of where the impact would sit within the spectrum of this category.
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Points of common ground between heritage experts.
5.62 There appears to be no dispute between the heritage consultants over the following matters: There is no direct impact resulting from the proposed development to any heritage assets No conservation areas are affected by the proposals The development proposed is not within the curtilage of any of the identified heritage assets. The key heritage issue is the potential impact on the setting of Parham Old Hall. The physical surroundings of Parham Old Hall is a rural landscape setting. The proposals would not harm a specific designed landscape or formal view relating to the Old Hall.
Cou il He itage Co sulta t s epo t :
5.63 Given the variation in the opinions of Heritage consultants and the Design and Conservation Officer, and upon advice from Counsel an Independent overview on heritage matters was commissioned.
5.64 The assessment concludes that the p oposed de elop e t ill esult i less tha su sta tial ha . This assessment therefore concurs with the findings of the BKHC and WYG reports. Case law has established that this level of harm can be seen as being a spectrum with a high degree of harm at one end and minimal harm at the other. The proposal will have some impact on the setting of the Parham Old Hall. The topography and landscape context of the application site is argued to help screen the development and the site therefore has the capacity to accommodate the development without the plant being unduly visual dominant or intrusive. In particular it will not be conspicuous in the principal views of the Hall from the south and east.
The undulating topography means that views to and from a building vary as one moves round the area. The development will be visible in the views from the public footpath running west of the Hall. However, the mitigation measures and overall scale of the development mean that the compound and related plant will not in my opinion be so conspicuous or intrusive as to dominate or significantly impact upon the wider setting in which the Hall is located. The Hall will still be legible within the context of a wide and sweeping arable setting. Its visual prominence within the landscape will not be undermined by the proposals. On balance the proposals are therefore considered to fall at the lower end of the less than substantial harm spectrum.
5.65 The assessment concludes: In considering the current application proposals, the views of the three reports submitted which comment on the proposals have been summarised. The heritage impact assessment focuses on the potential impact on the setting of Parham Old Hall.
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5.66 I consider that the level of harm likely to result to this heritage asset would be less than substantial. The immediate setting and its context within a wide expanse of rolling agricultural fields will be unaltered and the principal views of the Hall will be unaffected. The integrity of the heritage asset would not be diminished and the elements which contribute to the significance and understanding of the Hall would not be lost or be materially less legible.
5.67 The development will be visible in some wider views of the landscape setting particularly when the screen planting is immature and in the winter months when the planting is more permeable. However, the visual impact resulting is not considered to detract from the heritage significance or appreciation of the Hall, which is the primary aim of the relevant heritage policies and guidance. For this reason, the proposals are assessed as resulting in less than substantial harm and that this will be to the lower end of the spectrum.
5.68 The Local Authority are under a duty to have special regard to the desirability of preserving a listed building, its setting and any features of special architectural or historic interest which it possesses. It has been identified that some harm will occur, albeit the level of harm is considered to be less than substantial, as a result of the development. The Local Authority must attach to this considerable weight and importance. With reference to the NPPF, because the level of harm has been identified as less than substantial and towards the lower end of the spectrum, any public benefits resulting from the proposals stand to be weighed against the level of harm identified.
5.69 The proposals have less impact upon the setting of the listed building than the solar park refused in 2013, given the lower lying position, sheer scale of the solar park on the rising land south and west of the current site and likelihood of success of screen planting proposed on the northern side of the facility.
Noise
5.70 The NPPF advises in paragraph 123 that planning decision should aim to avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development and mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise.
5.71 The applicants Design & Access Statement comments: The two sources of noise at the site are cooling fans and transformers. The closest residential dwelling outside the farm is 280m from the site boundary. The next nearest house is over 400m away across the B1116. At this distance the operation of the site is unlikely to be noticeable above the ambient noise, though some acoustic treatment is required to ensure there is no noise nuisance, even during the quietest times.
The site will run at full power on winter workday evenings November through February between the hours of 16:00-20:00, but typically running for only 30-60 minutes within
52 this window. Outside of these times the plant can run at any time, but will do so intermittently, and only very rarely at full power.
Most of the plant is sitting in a quiescent standby state for the majority of the time. Although the site is always operating, it only uses a small proportion of actual plant, other than for rare, and short term, events, that are typically triggered by a major power station tripping out, for example. When such an event occurs, the site is the first line of defence in maintaining grid stability. Within minutes, however, National Grid will dispatch other assets to cover any power shortfall. This allows the site to reduce output, so that it can again respond to any further major event.
Some example times and capacities: • Fo . % of the ti e fe e tha % of the Batte B s a e ope ati g • Fo % of the ti e out of the i e te s a e i a uiet, sta d state he o the frequency service.
The atte B s ha e ee su di ided i to g oups, ith the g oup ope ated less tha 0.5% of the time being of standard construction, while the group that is operated move than 0.5% of the time being specially constructed to a low noise design.
At our request, the inverters have had a design modification applied by the manufacturer, to remove the tonal component often associated with these devices. Tonal noise was a particular concern expressed by local residents. In addition, the standard acoustic package on the inverters will be used to reduce their fan noise component.
An acoustic barrier surrounds the whole compound. This is 4m high on the north and east sides, and 3m high on the west and south sides. The height is chosen to represent the best trade off between visual impact and acoustic protection.
A noise report was commissioned, and a monitoring assessment was undertaken by the o sulta t at th ee poi ts, ep ese ti g the th ee N“‘ s, i ludi g o e ithi the curtilage of the absolute nearest sensitive receptor, Old Hall. The target set by the EHO was no greater impact than existing minimum noise levels at each of the sensitive receptors. The minimum noise levels are very low, but the report concludes that the impact from the plant will be less than these target thresholds. The report was carried out to BS4142:2014. Concerns have been expressed by local residents, due to a historic issue with transformer noise from Wickham Market substation. It is important to note that the noise experienced, particularly at Garnett Gardens, was both tonal (and therefore more readily perceptible and potentially irritating), continuous, and originally 14dBA above background levels. It was still significantly above background levels after the first round of acoustic treatment. Only after the second acoustic treatment did it approach background levels. It is also noteworthy that the predicted noise effect under BS4142 was a good predictor of perceived nuisance.
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For the proposal, the tonal elements from transformers are extremely low by comparison. Well below the background levels. The main noise source, from fans, is atonal, and predicted to be less than background levels following BS4142.
5.72 SCDC Environmental Health officers have assessed the submitted information regarding noise generation and the EHO is satisfied that there will not be adverse impact upon the amenity of any local residents. HPC consider that conditions are necessary to allay fears that noise may still adversely affect nearby residents and it is considered reasonable in this instance to impose conditions to require the provision of the acoustic fencing and that noise emanating from the site shall not exceed the background noise levels at any nearby noise sensitive property.
Biodiversity
5.73 The site is not an area of ecological significance, though it lies within an area which supports UK Priority species. There is a woodland County Wildlife site some 500m west.
5.74 The site is currently recently planted grassland of low ecological significance and the proposed planting of trees and hedging around the development will result in some increase to the biodiversity value of the site.
5.75 Potential impacts are disturbance to breeding birds during construction phase and lighting during operational phase, but Mitigation has been proposed, including use of external lighting only when it is needed, and directing it away from the existing hedgerow. This mitigation would reduce the impacts of the development proposals upon the habitats and species present, with the submitted ecological report suggesting an overall Neutral impact. 5.76 A number of ecological enhancements have been proposed, which would improve the quality of the site for native flora and fauna, including vegetation management within the facility. Delivery of these enhancements would lead to an overall Neutral-Minor Beneficial impact. SWT has not raised objection to the proposed development.
The environmental, social and/or economic benefits of the scheme
5.77 The applicant has provided detail on the need for energy storage in both the rebuttal document and document prepared by TNEI Services Ltd – A specialist energy consultancy.
5.78 The TNEI document states:
The drive to decarbonise our energy system and the switch towards decentralised generation has meant that our grid network is having to evolve. The energy challenges now facing us are of security of suppl , edu i g a o e issio s to o at a ‐ made climate change and to cost increases that would have the greatest impacts on the most vulnerable members of society. Energy storage developments are essential in enabling the grid network to meet these challenges by:
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• p o idi g g id ala i g se i es that a oid et o k failu es ; • epla i g highe a o ge e atio that u e tl p o ides s ste ese e; • allo i g fu the utilisatio of i te itte t lo a o ge e atio ; a d • edu i g et o k ei fo cement costs.
The benefits of energy storage to the grid network are universally recognised. National Grid has already procured 200MW of frequency response services provided by battery storage plants and increasing volumes of up to 2 GW are forecast.
There is international recognition of the need to decarbonise energy generation and, as a result, of the value of flexibility in enabling the transition to a high grid penetration of intermittent low carbon technologies such as wind and solar energy generation. Flexibility is the ability to change generation and/or demand in a rapid, controllable way and advances in battery technology have now made this achievable.
It is clear that storage can be used to store excess energy from renewable generation at times of low demand. However, the benefits of storage extend far beyond this.
The challenge of electricity system planning is to simultaneously meet the three requirements of the energy trilemma .The electricity system must have low cost to consumers, a high security of supply, and a low carbon footprint.
Studies show that flexible energy resources will be key to achieving this. Battery energy storage is a prime example of a flexible energy resource, with the ability to rapidly p o ide highl ‐ o t olla le demand and generation. The hole‐s ste e efits of fle i ilit a e ealised th ough se e al g id et o k mechanisms, including:
• F e ue egulatio ; • “ ste ese e; a d • ‘edu ed et o k i est e t.
The frequency at which the UK electricity system operates is influenced by the balance between supply and demand and a failure to maintain the frequency within strict ou da ies ould lead to a atast ophi failu e a d the lights goi g out . No all , the system runs at a frequency of 50Hz and if there is not enough supply to meet the demand the frequency drops below 50Hz. Similarly, if there is too much supply for the demand, the frequency rises above 50Hz. National Grid has indicated that, if alternative solutions are not implemented, additional balancing services may be necessary up to 25% of the year by 2021/22.
Battery energy storage can offer very fast response to frequency deviations, as it can have an almost instantaneous reaction to receiving a signal: typically, in less than a second. This response is significantly faster than can be achieved by other technologies. This allows National Grid to manage frequency at times of lower system inertia, facilitating a lower carbon generation mix.
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National Grid has recently procured 200MW of frequency response services from battery storage plants and has indicated that an increasing amount of frequency response will be required.
So the need for frequency response services to maintain a working grid network and the public benefits in avoiding disruption to power supply and the resultant effects on amenity and essential services is clear.
5.79 The Government considers Battery Storage as important to the national interest. Energy Storage is identified as a strategic resource for the future balancing, security of supply and decarbonisation of the UK energy system. The main barriers identified with current regulation are:
• Net o k o e tio s; • Net o k ha gi g; • Fi al o su ptio le ies; • Pla i g p o ess; a d • ‘egulato la it .
5.80 Upgrading Our Energy System, Smart Systems and Flexibility Plan – BEIS, Ofgem
5.81 This document published in July 2017 follows the call for evidence published in November 2016, and outli es the Go e e t s ai s to ope the a fo e technology providing interactivity and flexibility, such as Energy Storage. The actions specific to Energy Storage will be:
• A e ie to atio alise t eat e t of E e g “to age a d a oid e essi e embedded benefits, double charging and market distortions. New publications are due to follow. • A e d the Ele t i it A t of to i lude a spe ifi defi itio fo E e g “to age as a distinct subset of energy generating assets. • The go e e t ill review the planning regime in order to simplify it, including planning guidance and the national planning thresholds for storage facilities. • Ofge ill o sult o the fo of a si plified ge e atio li e se fo e e g sto age during summer 2017, in order to exempt them from consumption levies. • Go e e t a d Ofge a e i estigati g he sto age a o-locate alongside with renewable generation, and its impact with CfD, feed in tariffs and renewables obligation schemes. • Go e e t ill seek to i p ove the connection process with modifications such as flexible connections. • Go e e t ill i te e e issui g fi a ial i e ti es fo DNOs to do o e to eet thei usto e s eeds.
Beyond addressing these barriers, the Government will invest in catalysing innovation.
5.82 The applicants have set out their case for the very special i u sta es required to justify the development. In summary the batteries are required to provide storage of electricity, increasing the flexibility of the Grid to respond to fluctuations in energy
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de a d. This i eased fle i ilit is e ui ed to suppo t the Go e e t s ta get of reducing carbon emissions which will be achieved through the decommissioning of carbon intensive plants and delivery of low carbon generation, i.e. wind and solar; low carbon generation being inherently inflexible in relation to when they generate electricity.
5.83 Smart Power, National Infrastructure Commission report, Mar 2016 states: A ke ole for storage technology will be to provide some of the grid stability services needed to keep the electricity system resilient to unexpected events, such as a power station failing. Pumped hydro storage is already a key provider of this type of service. Batteries and other storage technologies are also ideally suited to play this role as they can dispatch power extremely quickly, precisely matching the needs of the system. Battery technologies are already more effective than using existing power stations for some of these services, demand for which will grow as the electricity generation mix develops and an increasing share of generation comes from intermittent renewables such as i d a d sola po e .
P i a f e ue espo se e ui e e t [a t pe of a illa se i e] ould i ease 30-40% in the next 5 years, and by 2030 the response requirement will be between 3 a d ti es toda s le el.
5.84 Paragraph 98 of the NPPF requires Local planning authorities to recognise that even small scale projects for energy development provide a valuable contribution to cutting greenhouse gas emissions and states that LPA s should approve the application if its impacts are (or can be made) acceptable, unless material considerations indicate otherwise.
5.85 Co e “t ateg Poli “P a d “P a e also ele a t, setti g out the Cou il s aspirations with regards climate change and renewable energy.
5.86 Whilst the proposal is not for energy generation, it is accepted that it will support these aspirations through storing energy for release when it is needed, providing increased flexibility to the network and supporting the transition to low carbon and renewable energy. The benefits of Battery Energy Storage Systems have been accepted on a number of sites nationally with a number of examples sited by the applicants. An application for a 50 MW facility in Mid Suffolk (ref DC/17/02746) was recently approved. The proposal lies within a SLA.
5.87 Having established that there is a wider need/benefit from/for the proposed development, the next step has been to establish whether alternative locations for the proposed development are feasible and whether lack of alternative sites can justify the impacts upon the setting of heritage asset and the SLA. The applicant has provided information regarding the assessment of alternatives.
To e a le to o e t a atte e e g sto age s ste i to the g id it ust ha e a Point of Connection (PoC) that: i. is the right connection voltage i.e. up to 6MW can be accommodated at 11kv;
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Above this is 33kv up to 20MW and so on. ii. there is sufficient reverse power flow capability or demand nearby to accommodate the battery discharging. iii.there is suffi ie t oltage head oo to a o odate a atte ha ge/dis ha ge at sufficient speed to match the frequency response chosen i.e. a 25MW EFR project can go from -25MW to +25MW (total 50MW swing) in 0.5 seconds. iv. sufficient import capacity to recharge the battery, if on an energy shifting duty, or to provide symmetric (or nearly symmetric) frequency services.
There are two types of electricity network: transmission and distribution. Transmission networks carry electricity long distances around the country at high voltages. Distribution networks run at lower voltages and take electricity from the transmission system into homes and businesses. The transmission system is run by National Grid, which is responsible for balancing the system and making sure that the supply of electricity meets the demand on a second-by-second basis. The above criteria mean that projects of this proposed scale (50MW) at Wickham Market must connect to large substations at distribution level, called Bulk Supply Points (BSPs) or Grid Supply Points (GSPs) which is what the Wickham Market Substation is.
5.88 In order for an energy storage project to be developed, the connection to the Grid must be financially and technically viable. The key component in connection viability is distance from the connection point – the further away from the connection point, the less viable a project becomes for 2 reasons:
First, the further away from the connection point the energy storage facility is located, the greater the impact of voltage drop across the cable connecting it to the strategic substation. In turn, this reduces efficiency and increases energy losses and can entirely defeat the purpose of the project, rendering it technically nonviable;
Second, in financial terms, an energy storage facility more than around 1km away (by road) from its connection point is unaffordable due to connections costs being too great. This is because cable is costed per metre: 132kV cable costs approx £1,000/m to lay underground.
5.89 The applicant has worked closely with EPN to identify sites near to substations which have technical feasibility for a Battery Energy Storage System (BESS). When a site is identified and where there is sufficient available operational land, from a willing site owner and that has sufficient grid capacity, this results in a technically viable site location
5.90 For a battery to operate it must import as well as export. Obtaining a grid offer where import capacity is similar to export capacity is important and more likely the closer you are to a Bulk Supply Point (BSP) or Grid Supply Point (GSP) substation. This is because most existing circuits running out from substations have been built to accommodate demand, and therefore are already at high demand capacity. It is more likely that spare
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capacit a e fou d o a su statio s us a s, hi h a the e a essed usi g a new circuit dedicated to the BESS.
5.91 Consideration is also given to voltage swings. If export and import connections are offered in locations away from BSP or GSP, voltage swings are more likely to impact any other customers on the same circuit. When next to a BSP and GSP substation, as in this instance, voltage swings are less likely to affect the local area because current flows are distributed among many circuits.
5.92 The site selection process is guided by development control considerations laid out through the relevant national and local planning policy guidance (i.e. a sequential approach) together with the operational needs and requirements of the development proposals.
Stage 1: Developing appropriate site selection criteria based on European, national, and local planning policy and guidance together with operational and developer considerations guiding the locationary requirements of the development proposal. Stage 1 also involved a preliminary desk based identification of sites including a survey of these sites located within the vicinity of the area of search; Stage 2: Further shortlisting of sites against criteria in order to identify potential sites that would be available and appropriate for the development proposal; Stage 3: Further shortlisting of sites against criteria in order to identify potential sites that would be available and appropriate for the development proposal taking into consideration the following factors: i. Capability of grid connection; ii. Site size; iii. Land Available by willing land owner; iv. Unsuitable topography; v. Non-greenbelt land; vi. Best and most versatile land; vii. In sensitive areas as defined by EIA regulations; viii. Poor highway infrastructure; ix. Distance to substation; x. Flood Zones; xi. Sensitive Human Receptors; xii. Landscape and Visual Considerations; and xiii. Heritage Considerations.
5.93 In summary, there are very limited instances were grid capacity, site size requirements and land availability marry up such that there are very few locations within the entire country where such projects are feasible. The overarching requirements are due to technical and economic viability requirements:
•Fo a f e ue espo se atte to operate efficiently, it must be able to import roughly as much as it can export. Obtaining a grid offer where import
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matches export is much more likely the closer you are to a BSP or GSP substation • The e ust e a aila le i po t a d e po t g id apa it at a substation which is a rare commodity throughout the UK • Co side atio ust also gi e to oltage s i gs; if e po t a d i po t connections are offered in locations away from GSPs or BSPs voltage swings are more likely to impact the local area. • Upst eam grid conditions are also important, including the connection to National Grid, and there are many examples where local capacity exists, but a project is subject to apportioned costs of National Grid upgrades (typically if such reinforcement is required, the cost is greater than the total project cost), and these can cause delays of over 5 years. • La d a d spa e a aila ilit • Willi g la do e
5.94 It is confirmed that out of 14 regional substations potentially suitable as alternative sites for the proposal only 2 have any potential import/export capacity to accommodate an embedded energy storage facility: Ipswich has no land available, and suffers from upstream network constraints. Wickham Market is the only viable option available with enough capacity and suitable space.
5.95 It is worth noting that all of the 14 substations are located near sensitive designations such as an ecological, landscape, heritage or environmental designation, including 11 of them near Listed Buildings, while all of them are also in the open countryside or near sensitive environmental areas.
5.96 Due to the scarcity of suitable locations (less than 1% of the entire DNO substation network) across such a vast geographical area of the country, only Wickham Market is meeting the required criteria to make possible development of a BESS.
5.97 From our detailed analysis over 87 energy storage projects have been granted planning permission to date in the UK, 15% of the successful projects have been consented within greenbelt land, owing to the scarcity of viable sites in total and to the great i po ta e LPA s ha e atta hed to this iti al i f ast u tu e fo ai tai i g g id stability, and enabling greater grid flexibility required by the continued closure of fossil fuel power stations and greater proportion of intermittent low carbon renewable e e g ge e atio . 5.98 The Ha hesto eside ts o je ti g to the de elop e t o side that There remains doubt.. .as to whether facilities of this size are essential or whether the benefits can be provided by a smaller number of larger facilities or larger number of smaller capacity BESS. Given the remaining doubt about the necessity for the facility, it would appear unreasonable to conclude that there are special circumstances for the proposed development which outweigh the harm to the setting of the heritage asset and impact upo the “LA.
5.99 There is no evidence provided in respect of the size of the facility and whether the benefits can be provided by a smaller number of larger facilities or larger number of
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smaller capacity BESS. The application is proposed in its current form and as stated has been determined by a combination of capacity and viability. Given the technology is of recent development, the application pre-dates planning guidance, but it is clear from the Ofge epo t : Upg adi g ou e e g s ste , s a t s ste a d fle i ilit pla s that the intention is to treat battery storage facilities in the same way as electricity generation and that planning policies are to be updated/introduced to facilitate the technology.
5.100 EN-1 is a material consideration and provides a general presumption in favour of low carbon generation or infrastructure projects but identifies material considerations such as landscape and heritage impacts. In respect to the consideration of alternatives to a proposed development the guidance states:
Gi e the le el a d u ge of eed fo e e e g i f ast u tu e, the IPC should, subject to any relevant legal requirements (e.g. under the Habitats Directive) which indicate otherwise, be guided by the following principles when deciding what weight should be given to alternatives: ● the o side atio of alte ati es i o de to o pl ith poli e ui e e ts should be carried out in a proportionate manner; ● the IPC should e guided in considering alternative proposals by whether there is a realistic prospect of the alternative delivering the same infrastructure capacity (including energy security and climate change benefits) in the same timescale as the proposed development; ● he e (as in the case of renewables) legislation imposes a specific quantitative target for particular technologies or (as in the case of nuclear) there is reason to suppose that the number of sites suitable for deployment of a technology on the scale and within the period of time envisaged by the relevant NPSs is constrained, the IPC should not reject an application for development on one site simply because fewer adverse impacts would result from developing similar infrastructure on another suitable site, and it should have regard as appropriate to the possibility that all suitable sites for energy infrastructure of the type proposed may be needed for future proposals; ● alte ati es ot a o g the ai alte ati es studied the appli a t as reflected in the ES) should only be considered to the extent that the IPC thinks they are both important and relevant to its decision; ● as the IPC ust de ide a appli atio i a o da e ith the ele a t NP“ (subject to the exceptions set out in the Planning Act 2008), if the IPC concludes that a decision to grant consent to a hypothetical alternative proposal would not be in accordance with the policies set out in the relevant NPS, the existence of that alternative is unlikely to be important and relevant to the IPC s decision; ● alte ati e p oposals hi h ea the e essa de elop e t ould ot proceed, for example because the alternative proposals are not commercially viable or alternative proposals for sites would not be physically suitable, can be excluded on the g ou ds that the a e ot i po ta t a d ele a t to the IPC s decision;
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● alte ati e p oposals hi h a e ague o i hoate a e e luded o the g ou ds that the a e ot i po ta t a d ele a t to the IPC s de isio ; a d ● it is i te ded that pote tial alternatives to a proposed development should, wherever possible, be identified before an application is made to the IPC in respect of it (so as to allow appropriate consultation and the development of a suitable evidence base in relation to any alternatives which are particularly relevant). Therefore where an alternative is first put forward by a third party after an application has been made, the IPC may place the onus on the person proposing the alternative to provide the evidence for its suitability as such and the IPC should ot e essa il e pe t the appli a t to ha e assessed it.
5.101 It is considered that the evidence presented in respect of alternative opportunities for a development of the same size/capacity as that proposed at Hacheston by the applicant is in compliance with the above guidance and has been undertaken in a proportionate manner.
5.102 The development will contribute to the security of supply: maintaining a working grid network, avoiding disruptions to the supply of electricity and the public benefits this brings; and decarbonisation: enabling power to be kept in reserve until required to e a le o e e e a le e e g ge e ato s to o e o li e the e e a li g the UK s transition towards low carbon energy generation.
5.103 The need for and benefits of energy storage development weighs materially in favour of the proposed development. Studies undertaken by the applicant have proven that the site is viable in terms of the scale of development required and the availability of the essential grid connection. Analysis shows that there are likely to be no other viable connection options in the Norfolk or Suffolk areas.
5.104 This is weighed against the less than substantial harm at the lower end of the spectrum identified by the Independent Heritage Assessment.
6 CONCLUSION
6.1 The proposals are considered to broadly comply with the Development Plan policies SP1, SP15 and SSP38.
6.2 The proposal is in broadly in compliance with SP1 because the proposal will avoid disruptions to the supply of electricity and will enable power to be kept in reserve until required to enable more renewable energy generators to come online thereby benefitti g the UK s t a sitio to a ds lo a o e e g ge e atio ; this ill help to mitigate against and adapt to the effects of climate change (SP1(a).The proposal ensures the provision of appropriate infrastructure to support existing and proposed communities(d) and will enable a healthy economy (h). The contained nature of the site and the proposed screen planting will limit impact upon the landscape character of the SLA and the setting of Parham Old Hall, such that landscape and heritage assets are conserved. Whilst it is acknowledged that the proposal will not result in complete compliance with policy SP1, when considering section (j) enhancement of the
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landscape and historic environment, the proposals cannot comply as they fail to enhance landscape or heritage assets. Therefore it is considered that the proposal will be in broad compliance with policy SP1 and will be a sustainable development.
6.3 Policy SP15 similarly requires that development proposals will protect and enhance the landscape. In this case officers contend that with the proposed mitigation that the landscape will be protected, however there can be no case for these proposals enhancing the landscape, and as such it is only possible to say that the development is in broad compliance with Policy SP15.
6.4 A further policy SSP38 requires that development proposals should not create material adverse impact upon the qualities of the landscape that make it special. The LVIA acknowledges slight adverse impact upon the SLA, which becomes negligible / neutral over time as mitigating planting takes effect, in association with the contained nature of the site. The landscape of the SLA will not be subject to a material adverse impact from this development.
6.5 It is officers view that the proposals are in broad compliance with the local plan, it is not a requirement for all elements of the local plan policy to be complied with in their entirety. The matter at hand is whether or not the proposals can be viewed as being in compliance with the local plan when taken as a whole.
6.6 The HIA and heritage consultants acknowledge impact upon the setting of Parham Old Hall to be less than substantial and Paragraph 134 of the National Planning Policy Framework (NPPF) is engaged. This requires that the less than substantial harm caused to designated assets is balanced against the public benefits of the proposed development. Considerable importance and weight must be given to the conservation of the he itage asset he u de taki g this ala e, i.e. The Ba ell Manor Test .
6.7 Impact upon the setting of Parham Old Hall is considered to be less than substantial, with the immediate setting and context set within a wide expanse of rolling agricultural fields remaining unaltered and with principal views unaffected.. The intervisibility between heritage asset and development and impact upon public footpath is limited by distance, orientation, limited height of the development and its low lying position relative to surrounding land. In addition mitigating planting is considered to have the capacity to effectively ameliorate the development impact from both the footpath and listed building.
6.8 The development will contribute materially to the security of supply: maintaining a working grid network, avoiding disruptions to the supply of electricity and the public benefits this brings; and decarbonisation: enabling power to be kept in reserve until required to enable more renewable energy generators to come online thereby e a li g the UK s t a sitio to a ds lo a o e e g ge e atio . There are limited opportunities within the East of England Region for the provision of similar infrastructure, by virtue of the proposed scale and connectivity requirements. These factors give the proposed development greater significance.
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6.9 It is acknowledged guidance with the NPPF recommends that any harm created to a heritage asset must be afforded significant weight. As such a strong presumption is in place for planning authorities to resist development proposals which create harm to these assets. Officers are able to report that they consider the level of harm created to be less than substantial and that within that wide range the level of harm is considered to be towards the lowest level.
6.10 It is acknowledged that the NPPF guidance on heritage matters is engaged; however officers conclude that there is only a modest impact on heritage assets. Given the demonstrable wider benefits arising from this sustainable energy proposal then although the NPPF guidance is engaged it is considered that this guidance does not in itself merit refusal of planning permission.
6.11 The proposals are considered to be in accordance with the NPPF and the development plan when taken as a whole. Conditions can be imposed to ensure that the proposed development is acceptable within this context. The application is recommended for approval.
RECOMMENDATION: APPROVE subject to controlling conditions including the following: 1. Standard time limit 2. Plans/drawings considered/approved 3. Permission is granted for 30 year period after which development is to be removed. 4. Decommissioning method statement 5. Removal/restoration if not used for import/export of electricity for period of 6 months 6. Construction method Statement including hours, HGV movements 7. Ecological mitigation and enhancement 8. Landscaping 9. Landscape management plan 10. Noise levels not to exceed (background levels) 11. Colour of acoustic fence and maintenance 12. Lighting and CCTV 13. Detail of nominated representative for contact by local residents
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DETERMINATION:
BACKGROUND PAPERS: Planning Application File Ref No C/12/1899 and DC17/1407/FUL
Committee Date: 19 July 2018
Site Visit: 16 January 2018
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5. HEVENINGHAM – DC/18/1027/FUL – Alterations to convert existing single dwelling into 4 No. smaller dwellings at Home Farm, Halesworth Road, Heveningham, Suffolk, IP19 0EL for Mrs L Hunt Case Officer: Iain Robertson Expiry Date: 13 May 2018 (Extension of Time: 21 June 2018)
DC/18/1027/FUL – Home Farm, Halesworth Road, Heveningham IP19 0EL DO NOT SCALE SLA100019684
Reproduced from the Ordnance Survey mapping with the permission of the Controller of Her Majesty’s
Stationery Office © Crown Copyright. Unauthorised reproduction infringes Crown copyright and may lead to
prosecution or civil proceedings.
EXECUTIVE SUMMARY
Planning permission is sought to subdivide a former agricultural workers dwelling into four dwellings. It is proposed to retain the occupancy restriction on one of the dwellings with the other three properties being available to be let on the open market.
The property is situated on Home farm, within the Heveningham Estate, located in a rural location within a special landscape area.
This item has come before members as a departure from the Local Plan and the recommendation is one of approval.
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1. SITE DESCRIPTION 1.1 Home Farm is situated to the South of Heveningham Hall which is a Grade I listed building. The surrounding grounds are also designated as a Listed Parkland, the extent of which does not include the application site. The wider estate, including the application site forms part of the surrounding Special Landscape Area (SLA). 1.2 In 1976 planning permission was granted for the dwelling which is on the site which originally served as the main farm house at Home Farm, at this time the land was held separately to the Hall itself. An agricultural workers restriction was imposed on the permission. The property has since been extended in 1995 to create a seven bedroom property. 1.3 The property is situated amongst modern working agricultural buildings and also adjacent to a small group of historic residential properties which forms a small collection of buildings within this part of the Estate. Access to the site is achieved directly off the B1117 or via a farm track from Dunwich Lane. 1.4 Home Farm remains the main centre for agricultural, forestry and related estate activities, the residential properties on the property are occupied by both estate workers engaged in these activities and private tenants working in the local area. The Farm is concealed by extensive native tree planting which was part of the estates wider planting strategy. The ongoing woodland planting, timber harvesting and agricultural activities on the estate have cemented Home Farm as the essential core location from which these activities can take place. 2. PROPOSALS
2.1 The proposal involves dividing the existing seven bedroom property vertically to provide four properties, this would involve some limited changes to the external appearance of the building with the creation of new openings on the North and South elevations. This would provide 1 x 1 bedroom, 1 x 2 bedroom and 2 x 3 bedroom properties. At the time of my site visit the conversion had been commenced and was largely completed. The large garden area would become a communal space. Parking would be situated to the North of the property adjacent to a large modern agricultural building. 2.2 It is p oposed that P ope t hi h fo s the o e of the ai Fa house ill e permanently occupied by a member of the estate staff. To ensure the most efficient use of the building and avoid vacancy voids the remaining three properties are proposed to be occupied by either estate workers or private tenants on assured shorthold tenancies depending on the specific needs of the estate for staff accommodation at the time of letting. 3. CONSULTATIONS
3.1 Heveningham Parish Council: No comments received 3.2 Suffolk County Council Highways Authority: No objection subject to conditions relating to parking and manoeuvring area to be provided and retained.
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3.3 Suffolk Fire and Rescue: Recommend the use of sprinklers in accordance with building regulations.
3.4 Environmental Services: No objections subject to conditions
3.5 Third Party Representations: None received
4. RELEVANT POLICIES
4.1 NPPF
4.2 NPPG
4.3 Suffolk Coastal District Local Plan – Core Strategy and Development Management Development Plan Document (adopted July 2013) policies:
SP1a – Sustainable Development SP1 – Presumption in Favour of Sustainable Development SP2 – Housing Numbers and Distribution SP3 – New Housing SP7 – Economic Development in Rural Areas SP14 – Biodiversity and Geodiversity SP15 – Landscape and Townscape SP18 - Infrastructure SP19 – Settlement Policy SP29 – The Countryside DM3 – Housing development in the Countryside DM13 – Conversion and Re-use of redundant buildings in the countryside DM22 – Design: Function DM23 – Residential Amenity DM27 – Biodiversity and Geodiversity
4.4 The Suffolk Coastal District Local Plan - Site Allocations and Area Specific Policies Document (January 2017): SSP1 - New Housing Delivery 2015-2027 SSP2 - Physical Limits Boundaries SSP38 - Special Landscape Areas
5. PLANNING CONSIDERATIONS 5.1 Section 38(6) of the Planning and Compensation Act 2004 states that application should be determined in accordance with the development Plan unless material considerations indicate otherwise. In this instance, the development plan for the purpose of this application is the Core Strategy (2013) and the Site Allocations and
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A ea “pe ifi Poli ies Do u e t , togethe ith a sa ed poli es f o the Local Plan (Incorporating First and Second Alterations 2001 and 2006).
Principle and Economic Development considerations
5.2 The Spatial Strategy of the Local Plan seeks to direct new residential development to sustainable settlements with physical limits boundaries. Countryside locations such as this have limited access to services and facilities other than by the use of a car.
5.3 Development in the countryside is strictly controlled in accordance with paragraph 55 of the NPPF and the strategy for the countryside as set out in Policy SP29 Cou t side a d DM Housi g i the Cou t side , which includes other small scale, locally supported schemes.
5.4 Policy DM03 states that the conversion of larger buildings in the countryside will be allowed where this meets a recognised local need. The conversion of this building to 4 smaller dwellings does not meet the requirements of local need and is therefore considered to be a departure from the local plan.
5.5 The applicant explains that Home Farmhouse sits within the core of the estate for this reason disposing of the property as an agriculturally tied property by sale is not an option as full management ownership and control is needed and moreover the overarching desire is to keep the estate intact. With Home Farmhouse firmly established as a long term asset to the estate it has become necessary to make more efficient use of the existing house by subdivision to accommodate estate workers where required and generating income for the estate by rental to private tenants.
5.6 The agent has explained that typically estate staff who work within the forestry and agriculture teams are single person households, couples or young families, and consequently require housing sized accordingly with between 1 - 3 bedrooms. In its current form the existing property at Home Farmhouse is too large for these occupiers. This demand for 1 – 3 bedroom properties is also reflected in the local private rental market.
5.7 It is p oposed that P ope t hi h fo s the o e of the ai Fa house ill e permanently occupied by a member of the estate staff. To ensure the most efficient use of the building and avoid vacancy voids the remaining three properties are proposed to be occupied by either estate workers or private tenants on assured shorthold tenancies depending on the specific needs of the estate for staff accommodation at the time of letting. The requirement for estate workers accommodation is changeable and this proposed flexibility ensures that during those periods where accommodation is not required by the estate the properties do not remain vacant but can make a contribution to local rental housing stock.
5.8 There are historic buildings that require substantial investment and are also being restored as part of a rolling program and along with redundant isolated agricultural buildings being converted to holiday accommodation, following local planning policy
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guidelines (under separate planning permissions). This marks an established and g o i g di e sifi atio i the estate s e te p ises, he e s all s ale, high i est e t tourism is a being used to support the wider landscape improvements, invigorating local employment and income in rural Suffolk without destroying the intimate character of the estate and surrounding countryside.
5.9 The provision of 3 unrestricted residential properties in the countryside is contrary to key principles of Local Policies SP19 and SP29, which seek to steer new residential properties to sustainable settlements with good access to local services and facilities. However, Policy DM03 allows for the subdivision of larger properties in the countryside, where this would meet an identified local need. In this case although there is no recognised local need the applicant has provide compelling justification of the benefits this proposal would bring to the housing requirements within the estate.
5.10 In this case it is clear that there is no longer a requirement for a seven bedroom property in relation to agricultural workers on Home Farm or for workers on the wider estate and that the building has been underused for a number of years and vacant for the previous two years. Although there is no current planning guidance with relation to restrictive planning conditions for rural workers, Annexe A to the former PPS7 was clear that once such conditions have outlived there usefulness properties should not be not be kept vacant, nor should their present occupants be unnecessarily obliged to remain in occupation simply by virtue of planning conditions restricting occupancy.
5.11 This proposal would provide accommodation of an appropriate size for the needs of workers on the estate whilst allowing a flexible approach that enables the property to be fully utilised when not required by estate workers with short hold tenancies to private tenants and also retaining the occupancy restriction on a single property.
5.12 Other policies of the local plan such as Policy DM13 state that when buildings in the countryside are no longer required for their original purpose or become under-used, their re-use and conversion to appropriate alternative uses can represent a sustainable form of development. Although in terms of residential conversions this would usually require the buildings to be of historic merit, this could be considered in relation to the potential benefits of the proposal in relation to the future viability of the Heveningham Estate, which in turn also has significant value to the local rural economy.
5.13 Policies SP7 seeks to maximise the economic potential of the rural areas, particularly when this will secure employment locally. Paragraph 28 of the NPPF supports economic growth in rural areas in order to create jobs and prosperity, supporting the sustainable growth and expansion of all types of business and enterprise in rural areas, through conversion of existing buildings. The intensification of this residential use by allowing this property to be fully utilised will have economic benefits to this key local employer whilst enabling them to accommodate workers on the estate with suitable accommodation and is therefore considered to comply with the aims of these policies.
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Landscape impact
5.14 The farmhouse is concealed by extensive native tree planting which forms part of the estates wider planting strategy and therefore the existing building has minimal impact on the adjacent Listed Parkland and the wider Special Landscape Area. The proposed changes to Home Farmhouse do not introduce any new built form, and will utilise the existing access, and parking arrangements. The alterations to the building include minor alterations to the fenestration of the building. These are to the North and South elevations to provide additional door and window openings; the visual impact of these changes is very minor.
Residential Amenity
5.15 The subdivision of the building would bring future occupiers into closer proximity and due to the nature of the site and proposals, they would not have access their own private amenity areas but share a large communal outdoor space. The properties would require greater sound insulation between the properties which will be a requirement of the building regulations. It is considered that the proposal would not cause an unacceptable loss to the amenity of the future residents, and therefore the proposal accords with Policy DM23.
5.16 In the interests of safeguarding visual and residential amenity it is considered appropriate to remove permitted development rights for alterations and extensions.
Biodiversity
5.17 Natural England standing advice suggests when a survey should be required when protected species are present on or near the proposed site or are affected by the development. It is less likely that bats would roost in a building of this age and this development proposal requires minimal alteration would not affect the roof space in any case. Bats are the only species likely to use the roof space given and there are no records of bat roosts in the vicinity. Therefore, the proposals are considered acceptable in terms of maters of ecology and the scheme would accord with policies SP14 and DM2
Highways
5.18 There are no highway implications associated with this development, the existing access is established with good visibility and the intensification of the use of the access will be minimal. Adequate parking and manoeuvring space is provided and its retention will be required by condition.
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Conclusion: 5.19 The National Planning Policy Framework supports economic growth in rural areas in order to create jobs and prosperity, including promoting the development and diversification of agricultural and other land-based rural businesses.
5.20 In this case the large size of the property is impractical for occupation by a single household and since the farm has been brought within the ownership of the wider estate the existing premises has been underused or unoccupied.
5.21 It is considered that the rural economic benefit of this proposal would outweigh the harm caused by the provision of dwellings in an unsustainable location. When utilised as estate workers accommodation the location of the properties will reduce travel distance for the occupiers and reduce the impact of the proposal. The proposal will utilise an existing building and will therefore have no additional landscape impact.
5.22 Other material considerations such as residential amenity, biodiversity and highways matters have been considered within the report and it is considered that there will not be significant impacts arising from this proposal.
RECOMMENDATION: APPROVE - subject to the following conditions Standard time limit In accordance with approved plans Materials as submitted Occupancy restriction for unit two for estate workers only Manoeuvring and parking are to be provided and retained Unexpected contamination condition Removal of Permitted Development Rights for alterations and extensions.
DETERMINATION:
BACKGROUND PAPERS: Planning Application File Ref No DC/18/1027/FUL Committee Date: 19 July 2018
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6. KESGRAVE – DC/18/1596/FUL – Single storey rear extension and internal alterations at 16 Roy Close, Kesgrave, IP5 1JR for Mr Steve Pearsons.
Case Officer: Joe Blackmore
Expiry Date: 16 April 2018 (Extension of Time: 26 July 2018)
DC/18/1596/FUL - 16 Roy Close, Kesgrave. IP5 1JR
DO NOT SCALE SLA100019684
Reproduced from the Ordnance Survey mapping with the permission of the Controller of Her Majesty’s
Stationery Office © Crown Copyright. Unauthorised reproduction infringes Crown copyright and may lead to
prosecution or civil proceedings.
EXECUTIVE SUMMARY
Retrospective planning permission is sought for an extension to the dwelling at 16 Roy Close, Kesgrave.
This item has come before members because of a referral request from the Kesgrave Town Council, and to enable matters of design and neighbour amenity impact to be considered by the planning committee.
Officers consider that the design is of an acceptable quality and that the extension does not give rise to an adverse impact on neighbour amenity. The application is therefore recommended for approval.
1. SITE DESCRIPTION 1.1 The property is accessed from Roy Close and forms a broadly triangular shaped site at the end of the cul-de-sac. There is a single storey semi-detached dwelling on the site
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which is bounded on its three sides by residential properties: two of which are at Roy Close and the other, to the east, is accessed from Bell Lane. 2. PROPOSALS 2.1 The proposal is to add a single storey extension to the rear wall of the property. The extension covers a ground footprint of approximately 62 square metres. It is single storey in scale, with an eaves height of 2.5 metres and ridge height of 5 metres. The extension has a hipped roof form. At the closest point, the extension is 0.5 metres from the east side boundary. The extension is substantially built and near completion. Relevant Planning History 2.2 DC/17/5248/FUL: Single storey rear extension and internal alterations This application was withdrawn prior to determination. The reason for this was that officers were made aware - during the determination period - that the development had been carried out but not in accordance with the plans submitted under the application. The application was therefore withdrawn and a fresh re-submission made retrospectively (the application now before members).
3. CONSULTATIONS
3.1 Kesgrave Town Council object to the application stating: ‘efusal as e o e ded. Voti g as u a i ous fo efusal. The Co ittee is aware that it has previously objected to this retrospective scheme DC/17/5248/FUL due to it being overcrowded and too close to the boundary, although the boundaries are not very clear in the plans. It considered that the proposal for a single storey rear extension and internal alterations will have any adverse impact on the visual amenity and character of the area and would not appear to be in keeping with the area. The objections from a neighbour regarding overlooking were noted. It was also noted that the p e ious s he e has ee ithd a . 3.2 Third Party Representations: One letter of objection has been received raising the following key points: Extension is cramped and at an odd angle; Poor design and over-development of the site; and Proximity of extension to boundary will make maintenance of the building difficult.
4. RELEVANT POLICIES 4.1 Suffolk Coastal District Local Plan – Core Strategy and Development Management Development Plan Document (adopted July 2013) policies: DM21 – Design: Aesthetics DM23 – Residential Amenity 4.2 The following Suffolk Coastal Supplementary Planning Guidance/Documents are of particular relevance to the determination of this application: SPG16: House Alterations & Extension
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5. PLANNING CONSIDERATIONS Design 5.1 Policy DM21 of the Development Plan requires that extensions, generally, are well- related to the existing dwelling; subordinate in scale; and not overly-dominant. 5.2 In this regard, the extension is a sizeable addition to the dwelling that goes considerably beyond what could be achieved as permitted development. However, the ridge level of the extension follows that of the main dwelling; and the hipped roof form reduces the overall bulk of the roof structure, pulling the mass away from the site boundary. There is ample garden/amenity space to the north of the extension and therefore the extension does not amount to an over-development of the site. In terms of external finish, the walls will be rendered and painted. The roof is covered in artificial slate. 5.3 The overall form and composition of the extension is considered to be well-related to the existing dwelling; not overly-dominant in scale; and an acceptable scale development of the site. Thus, there is no conflict with the objectives of design policy DM21; nor the design guidance in SPG16. Residential Amenity 5.4 In respect of the concerns raised by the Town Council, there is not considered to be an issue of overlooking because the extension is only single storey with a relatively low eaves height. The single storey scale - in combination with intervening boundary treatment - means there is no significant privacy impact on neighbours.
5.5 The site is relatively constrained by its size, shape and relationship with the properties at Bell Lane (to the east); this means that the extended dwelling is quite close to the boundary – particularly the eastern boundary which separates the site from 61 Bell Lane. However at the closest point the extension is at least 0.5 metres from any site boundary. The extension also has a relatively low eaves height of 2.5 metres with the bulk of the ridge pulled away from the neighbour at 61 Bell Lane because of the hipped roof form. In combination: the scale; position relative to the boundary; and the roof form, mean that there is an acceptable relationship between the extension and neighbour at 61 Bell Lane.
5.6 In regards to the adjoined property at number 14, the extension is due north of this neighbour and therefore unlikely to directly impact their access to sunlight. The main element of the extension is approximately 3 metres from the dwelling at no. 14 and this degree of separation, in-combination with the relatively modest scale of the extension, means there is not an overbearing physical relationship. The extension is clearly visible from the neighbouring property, but it is not considered to harm the enjoyment of their property.
5.7 For these reasons, officers consider that the amenity impact of the extension is acceptable and in accordance with policy DM23 of the Development Plan.
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Planning Balance and Conclusion 5.8 The proposal is considered to be acceptable with regard to the relevant planning policies and there are no other material considerations that would indicate refusal. Approval is therefore recommended.
RECOMMENDATION: APPROVE subject to controlling conditions including the following: 10. Plans/drawings considered/approved
DETERMINATION:
BACKGROUND PAPERS: Planning Application File Ref No DC/17/5248/FUL
Committee Date: 19 July 2018
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7. MARTLESHAM – DC/18/2068/FUL – Proposed detached two-storey dwelling (revised scheme) at 8 Birch Grove, Martlesham Heath, Ipswich, IP5 3TD for Mr and Mrs Double.
Case Officer: Naomi Goold
Expiry Date: 10th July 2018 (Extension of time until 27th July 2018)
DC/18/2068/FUL – 8 Birch Grove Martlesham Heath Ipswich Suffolk IP5 3TD
DO NOT SCALE SLA100019684
Reproduced from the Ordnance Survey mapping with the permission of the Controller of Her Majesty’s
Stationery Office © Crown Copyright. Unauthorised reproduction infringes Crown copyright and may lead to
prosecution or civil proceedings.
EXECUTIVE SUMMARY
Planning Permission is sought for the erection of a detached two-storey dwelling in the side garden of No.8 Birch Grove. The application has been referred to the Planning Committee for determination at the instigation of Offi er’s e ause of the wider pu li interest in the appli ation and e ause a similar application nearby at No.11 Birch Grove was determined by the Planning Committee. The application is recommended for refusal because it is considered that it would be out of character with the existing pattern of development and appearance of the street scene. The application is considered contrary to Policies SP15 and DM7 of the Core Strategy and Policies MAR3 and MAR4 of the Martlesham Neighbourhood Plan.
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1. SITE DESCRIPTION 1.1. Ma tlesha Heath desig ed a d de eloped as a e illage ; uilt as a se ies of hamlets which are linked by a number of green spaces. The hamlets were designed by different architects and built by different builders which act to give the development a distinctive character. The hamlets have been built surrounding a central green and The Square which is home to a number of services and facilities.
1.2. Birch Grove, formerly known as Hamlet K, is a cul-de-sac development of 12 detached houses located on the northern side of Eagle Way. This hamlet has a cluster of the most spaciously set dwellings on Martlesham Heath; they are a series of large properties set in large plots. The application site comprises part of the side garden of No.8 Birch Grove, one of the properties built on the eastern side of the road.
1.3. To the north of the site is 10 Birch Grove, a large detached, two-storey property. The dwellinghouse of No.10 and area immediately surrounding the property to the south and garden to the north, sits at a lower level in relation to the application site. To the south of the site is the host dwelling of 11 Birch Grove, with No.6 Birch Grove further south. The eastern side of the site is bounded by Eagle Way with the highway of Birch Grove to the west.
1.4. No.8 Birch Grove unlike many of the properties in the Grove is positioned off centre and slightly closer to the southern boundary. To the north of the dwelling is a large summerhouse with ornamental ponds and rockery in the north-east corner of the site. The remainder of the site is laid to grass with mature planting. The property is elevated in relation to the road with a gravel drive rising up providing access to a large parking area and a detached double garage. The front of the site is open, laid to grass with a few small shrubs. The site occupies a prominent position in the street scene.
2. PROPOSALS AND PLANNING HISTORY 2.1. The application seeks full planning permission for the sub division of the existing plot of No.8 Birch Grove and erection of a two-storey, four bedroom dwelling to the north of the host property. It is proposed that the existing summerhouse and one of the ornamental ponds will be removed to facilitate the development.
2.2. The existing vehicular access would be retained to serve the host dwelling and a new vehicular access proposed off Birch Grove close to the northern boundary of the site to serve the new dwelling. The new access would lead to a parking/turning area and a proposed integral garage. The plans clearly show that any vehicle would have space to manoeuvre within the site and therefore can enter and exit in a forward gear.
2.3. A planning application (DC/ / /FUL as su itted i fo P oposed Detached Two-Storey Dwelling and Garage at No.8 Birch Grove. This application was however withdrawn. At the time Officers raised concerns in relation to the overall size and scale of the property and impact this would have on the character and appearance of the street scene.
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2.4. The design of the new dwelling and its positioning on site has been revised in the current submission.
2.5. Planning permission has also been sought for a new dwelling in the side garden of No.11 Birch Grove under DC/17/3143/FUL. The application was determined at Planning Committee with Members refusing the application following reason:
Bi h G o e is ha a te ised la ge deta hed d elli gs set ithi su sta tial plots, and this character derives from the vision and masterplanning of Martlesham Heath. Whilst it is acknowledged that there maybe physically space to accommodate a dwelling on the site, the resulting impact from these proposals creates a development which appears cramped and out of character with the spacious character and appearance of Birch Grove. Both the host and proposed dwelling are located close to the site's boundaries, this is an uncommon feature in the street. The positioning of those dwellings then pressures the developable area within the application site. The over developed nature is further exacerbated by the lack of space to accommodate suitable garaging for the property. The proposal also creates an unacceptable reduction in the residential amenity afforded to both numbers 9, 11 and 12 Birch Grove, those residents currently benefit from a private environment with no overlooking. The proposals would have an unacceptably detrimental impact on the existing patio doors serving a main room of No.11 Birch Grove which is located in close proximity and faces directly towards the proposed dwelling. The proposal is therefore o t a to poli ies “P , DM a d DM of the Lo al Pla Jul .
2.6. A revised application was submitted earlier this year (DC/18/1143/FUL) for Co st u tio of a deta hed t o-storey dwelling and detached garage - revised s he e . The appli atio as si ila l efused due to the a ped atu e of the plot, inadequate size of curtilage retained with existing dwelling, loss of an important gap and associated impact on the street scene and character of the area. The development was considered to have an unacceptable impact on the amenity of the neighbouring properties 9 and 12 and host dwelling of 11. The application was refused as the proposal was contrary to Policies SP15, DM7, DM23 of the Core Strategy.
3. CONSULTATIONS
3.1. Martlesham Parish Council:
The Parish Council objects to this planning application. It notes that some of the easo s fo the pla i g autho it s efusal of pla i g application DC/18/11134/FUL for 11 Birch Grove apply equally to this site. The refusal notice acknowledged that Bi h G o e is ha a te ised la ge deta hed d elli gs set ithi su sta tial plots, and this character derives from the vision and masterpla i g of Ma tlesha Heath . The Cou il s o je tio s a e ade o the follo i g g ou ds:
1. The planning application is against SCDC Local Plan policies DM7 & DM23 and does not meet all the criteria that are required for the sub-division of plots.
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a) DM7 – Infilling and Backland Development within Physical Limits Boundaries – it would be out of character with the area and street scene. It would significantly reduce residential amenity with loss of privacy for the neighbouring property at no.10. It would erode the particular character of the surroundings. Provision for a reasonable size curtilage has not been made with regard to the size of the buildings and their setting. In Birch Grove this new dwelling would be uncharacteristically close to the existing dwelling and to the boundary with no. 10. It also extends rearwards towards the boundary with Eagle Way which is uncharacteristic of the hamlet's overall design and would adversely affect the street scene from Eagle Way.
b) DM23 – Residential Amenity – the Council considers that there would be unacceptable loss of amenity to the neighbouring property due to overlooking and loss of sunlight. Particular attention needs to be paid to the difference in height levels between no. 8 & no. 10 Birch Grove. The proposed property is only about 5.5 feet from the boundary, and would sit about 8 feet higher than o. , the efo e the ga le e d o e looki g o. s patio ill e at a elati e height of approx. 35 feet above the patio. Overall the structure will be approx. 65 feet long close to the southern boundary of no.10.
Please see the three images at the foot of this document - 2 aerial shots showing the proposal in the context of the existing layout, and the street scene showing elevation difference between no. 8 (applicant) and no. 10 (neighbour).
2. It is against the National Planning Policy Framework. Paragraph 53 states: Lo al pla i g autho ities should o side the ase fo setti g out poli ies to resist inappropriate development of residential gardens, for example where de elop e t ould ause ha to the lo al a ea .
Condition 5 of the original 1981 planning permission for Hamlet K (now Birch G o e C / lea l states ot o e tha d elli gs to e e e ted o the site . This o ditio as i posed in the interests of amenity and the Parish Council is unaware of any time limit on this condition.
Martlesham Heath was an award winning village due to its design and therefore conditions were imposed so that it could retain its character & this has been maintained successfully over many years. If backland development is allowed, it will undermine the original design of the Birch Grove hamlet which was one of large properties on large plots. It could set a precedent of infilling which would eventually erode the character of the village which the District Cou il has sought to etai as a a e e a ple of a su essful e illage. The Lo al Pla said of Ma tlesha Heath: Basi all , the o e all ph si al and design principle which emanates from the original social concept is one of a series of hamlets separated from each other by wide areas of open space. The District Council has sought, and will continue to uphold the principles of
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this concept, and, accordingly, once these hamlets have been fully developed there will be no potential for further development other than ancillary to recreation of an outdoor nature. To do otherwise would be regarded as ad e sel affe ti g the illage a d its ope setti g.
3. It does not accord with the following Martlesham Neighbourhood Plan policies, hi h ha e uilt o the Dist i t Cou il s poli ies to ai tai a e e pla village:
Policy MAR3: Development within Martlesham Heath
A. Within the physical limits boundary of Martlesham Heath, but outside the areas to be protected from development (Policy MAR2), proposed development should be in keeping with the character of the individual hamlet in which the site is located or is adjacent to.
B. In particular, development should be at broadly the same density as the existing density of the hamlet. It must also take into account the requirement for an appropriate level of parking (Policy MAR15).
Policy MAR4: Residential Design and Amenity
Proposals for residential development will be expected to demonstrate good quality design. In particular, development proposals will be expected to (NB. Only relevant clauses are shown below):
1. respond to and integrate with local surroundings and the local landscape context as well as the existing built environment; 3. retain the established building line and be in keeping with the existing arrangements of front gardens, walls, railings and hedges; 4. relate to the established plot widths within streets, particularly where this has established a rhythm to the architecture in a street; 6. ensure that new buildings, including balconies, do not adversely affect the residential amenity of neighbouring properties by virtue of overshadowing or impinging on privacy;
The Parish Council adds the following comments: The existing dwelling at no.8 is not built centrally on the plot as the plot was used as a landfill site; this is not acknowledged within the planning application. There would need to be more extensive research into land contamination. The applicant considers this to be a much needed family home. The Martlesham Neighbourhood Plan has not identified a need for such large houses ithi the pa ish o is it eeded to eet “CDC s -year housing land supply.
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If SCDC is minded to approve this application, the Parish Council strongly urges the Planning Committee to make a site visit before reaching a decision because of the complexity of the land gradients.
3.2. Suffolk County Council - Highway Authority: have recommended that permission should include conditions requiring details of the access including any gates, storage and presentation areas for recycling and refuse bins and parking and turning areas.
3.3. Suffolk County Council – Archaeological Service: No objections but recommend standard conditions requiring the submission and implementation of a written scheme of investigation.
3.4. SCDC Head of Environmental Services and Port Health: Recommend a suitable consultant be engaged to undertake a phase 1 contaminated land investigation as a minimum to adequately assess the risk of these former land uses on the proposed development, this may necessitate future intrusive investigation prior to determination or the full suite of land contamination conditions be applied.
3.5. Third Party Representations:
167 letters of objection raising the following matters:
Principle Contrary to covenant preventing further residential development and number of properties in hamlet to 12 Contrary to condition 25 of E7763/28 and 17 of C7763/182 restricting number of dwellings in hamlet to 12 Against ethos and original design of award winning estate Martlesham Heath development must be preserved for future generations/families to enjoy Estate is fully developed and no further development should be allowed to retain its character To approved development would be contrary to previous decisions taken in relation to 11 Birch Grove and elsewhere on Martlesham Heath Contrary to text in former Local Plan which stated that once hamlets fully developed there will be no further potential for development Will set precedent Open flood gates to expansion on all vacant land Turn village into a small town
Need No need for further residential development Adastral Park will provided 2000 new homes in addition to new housing at Mill Heath New housing being built and to be built will accommodate a variety of needs Proposal has no benefit for the village only commercial gain
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Infrastructure Cause strain on existing infrastructure Place pressure on services and amenities including doctors, schools and utilities, exacerbated if further development occurred
Wildlife Adverse impact on wildlife on the Heath Increased pressure on SSSI
Highways Increased pressure on roads, existing roads cannot cope with existing traffic Shared driveway will eventually cause disharmony between residents Safety concern due to conflict with new access and associated traffic with existing foot traffic including dog walkers and children using footpaths around Birch Grove Insufficient parking
Residential Amenity Adverse impact on the amenity of the occupiers of the properties in Birch Grove especially 8, 9 and 10 and also 29 Lancaster Drive New building too close to boundary with 10 Birch Grove, combined with elevated nature of site, development will be visually intrusive and cause a loss of light and overshadow patio area Adverse impact on outlook of existing residents Parking for existing dwelling is too close to boundary with 6 Birch Grove Noise and disturbance caused by construction vehicles If pile driving or excavation is necessary this will cause disturbance and expose residents to potential contaminants Contrary to Policy DM23 of Core Strategy and MAR4 of Martlesham Neighbourhood Plan
Visual Amenity Existing pattern of development is large houses in substantial plots – character derived from vison and master plan Poor design and choice of materials not in keeping with the existing properties New plot would not be of size similar to the surrounding properties Development would be too close to site boundaries Destroy airy, low density feel of locality Elevated position of plot would result in development appearing overbearing in relation to adjacent properties Development cramped and out of character with street scene Detrimental impact on appearance of Birch Grove and Eagle Way Development would tower above 6 and 10 Birch Grove Gap between host dwelling uncharacteristically close (5.5m), normal separation 20m
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Resultant height of building will have detrimental impact on landscape character of area New dwelling does not front Birch Grove which will sit in contrast to other properties Proposal appears shoe horned into site Contrary to Policy SP15 and DM7 of Core Strategy Contrary to Neighbourhood Plan MAR3 which states that housing density should remain the same, development would increase density
Other Matters Site previously used to dispose of waste which maybe hazardous Devalue existing properties Revised scheme does not respond to concerns regarding original scheme Majority of supporters live outside the village Unclear where the summerhouse from site is to be relocated Proposal will not provide affordable property to benefit any local purchaser Trees on site previously cleared, these should be reinstated Summerhouse constructed on the site was not built in accordance with the approved drawings
Four letters of support raising the following matters:
New building should be supported to help to reduce the massive housing shortage faced by UK Proposal does not distract from character of Martlesham in any way, shape or form Should not seek to protect plot of grass hidden away making little contribution Existing homes on Martlesham Heath out of reach for majority of villagers, good to see landowners making space available to allow new family home Building on part of a side garden will help to reduce pressure to build on shared areas
4. RELEVANT POLICIES
4.1 NPPF and NPPG
4.2 Suffolk Coastal District Local Plan – Core Strategy and Development Management Development Plan Document (adopted July 2013) policies:
SP1a – Sustainable Development SP1 – Presumption in Favour of Sustainable Development SP2 – Housing Numbers and Distribution SP3 – New Homes SP14 – Biodiversity and Geodiversity SP15 – Townscape and Landscape
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SP19 – Settlement Hierarchy SP20 – Eastern Ipswich Plan Area DM7 – Infilling and backland development within the physical limits boundaries DM19 – Parking Standards DM21 – Design – Aesthetics DM22 – Design: Function DM23 – Residential Amenity DM24 – Sustainable Construction DM27 – Biodiversity and Geodiversity
4.3 “uffolk Coastal Lo al Pla sa ed Poli AP A eas to e P ote ted f o De elop e t
4.4 Martlesham Neighbourhood Plan has been found sound by an Inspector and received a es ote at a ecently held Referendum. The Council has not yet however formerly ade the Neigh ou hood Pla ut the do u e t a e a a ded full eight ith the following policies being of particular relevance:
MAR1 – Martlesham Physical Limits Boundaries MAR3 – Development within Martlesham Heath MAR4 - Residential Design and Amenity MAR16 – Parking Standards
5 PLANNING CONSIDERATIONS
Principle of development
5.1 The NPPF seeks to promote sustainable development and sets out a number of core principles which help to achieve this. One fundamental principle is to locate residential development so that it reduces the need to travel and is positioned close to services and facilities.
5.2 The application site is located inside the physical limits boundary of Martlesham Heath which is identified as a Major Centre within the settlement hierarchy set out in Policy SP19. This is a tool utilised to determine the scale of development appropriate to a particular location, the Major Centres are located at the top of the hierarchy and defi ed as su egio al e t es fo o e ial a d so ial fa ilities . Ma tlesha Heath has a large number of services and facilities sufficient to cater for the everyday needs of residents and more. There is sufficient service infrastructure to cater for one addition dwelling. Policy SP19 states that residential development within the physical limits will be permitted in the form of estates where consistent with local character, groups and infill. The location of residential development in areas where there are the
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facilities and services available helps to reduce the overall need to travel and aids the achievement of sustainable development in accordance with SP1.
5.3 The original consent for the properties on Birch Grove (Hamlet K reference C7763/182) included a condition which restricted the number of properties built to ot o e tha d elli gs to e e e ted o site . This o ditio ould ot ho e er prevent the submission of any subsequent full application for additional dwellings on Birch Grove. If allowed, any later permission would supersede the earlier condition.
5.4 Policy MAR1 of the Martlesham Neighbourhood Plan states that development proposals will be supported within the physical limits boundary subject to compliance with other policies in the development plan.
5.5 The principle of residential development within the physical limits of Martlesham Heath is therefore in accordance with policy.
5.6 Representations have been received questioning the need for an additional dwelling in the Martlesham locality by virtue of the recently consented scheme for housing at Adastral Park (Brightwell Lakes), Mill Heath and Black Tiles Lane. The housing requirement in the District Local Plan is a minimum; there is no ceiling to housing supply.
5.7 Policy DM7 of the District Local Plan relates to infilling and backland development within physical limits boundaries. This policy identifies a number of criteria which proposals must comply with; these will be considered further within this report in association with other relevant policies.
Design and Character of the Area
5.8 No.8 Birch Grove is located slightly off centre within its plot, positioned closer to the southern boundary of the site. The application seeks to sub divide the existing plot of No. 8 to provide a new dwelling to the north of the property.
5.9 A number of the properties on the eastern side of Birch Grove occupy an elevated position in relation to the road. The host dwelling sits approximately 1.6 metres above the road, with parts of the rear garden sitting over 2.5 metres higher than the highway. The levels between No.6 and No.8 Birch Grove are similar however the land immediately surrounding No.10 Birch Grove was excavated at the time of the construction of the house, resulting in the property and associated patio areas sitting lower than the application site.
5.10 A two-storey dwelling is proposed, the highest section of which will run parallel to the road with a one-a-half storey front wing providing an integral double garage with bedroom accommodation above. A single-storey rear wing is also proposed accommodating a breakfast area. The addition of the front and rear wings results in the building having a depth of 19.7 metres. The principle elevation of the building will face west towards Birch Grove. A 45 degree pitched roof is proposed on the main and
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front wing of the property with the rear element comprising a shallower pitch. The overall ridge height is approximately 8.6 metres.
5.11 The main section of the property is to be constructed in multi red brick with brown concrete pantiles, the front and rear wings are to be clad in a light cream coloured artificial weatherboard above a multi red brick plinth. The colour of the cladding will i ease the uildi g s isual p o i e e i the st eet s e e.
5.12 A Sustainability Statement has been submitted with the application detailing measures to be incorporated into the design to help minimise energy wastage. Such measures are encouraged and fully supported by policies within the District Local Plan
5.13 Birch Grove comprises an informally laid out cul-de-sac of 12 large detached properties primarily set within large plots. At the entrance to the road sits No.1 Birch Grove which occupies a smaller plot, this property alongside No.2, by virtue of their positio i g ha e so e ese la e to lodges at the e t a e to the ul-de-sac. The dwellings within the road each sit away from their boundaries giving the street scene a very spacious character. The development within the road is dominated by the planting and large gardens surrounding the dwellings and not the built form of the buildings.
5.14 The host dwelling occupies a prominent positioned within the street scene by reason of its elevated position and open nature of its frontage. When travelling north along Birch Grove, once past Nos 1 and 2 at the entrance to the road, the application site comes into view. The site makes a positive contribution to the street scene in its relatively undeveloped form, adding to the character of the road. The site is also prominent when viewed from Eagle Way where the spacious nature and character of the plots within Birch Grove can be seen in contrast to development on the other side of Eagle Way.
5.15 The sub division of No.8 would result in the host and new dwelling having narrower plots than the majority of existing properties in the road. The narrowness of the plots results in the existing and proposed buildings sitting in close proximity to the site boundaries in contrast to the existing pattern of development.
5.16 The existing dwelling would be retained and new development provided with, a curtilage which although sufficient in terms of providing amenity space, the size of the area would be out of character with those typically found on the road.
5.17 Policy DM7 seeks to resist development which would result in a cramped form of development out of character with the area and street scene, does not relate well to the adjacent properties and appears designed in isolation and has not been provided/retained with a reasonable size curtilage. Policy SP15 seeks to protect the townscape of urban areas. The current application is considered contrary to the requirements of these policies. The addition of a property and the resultant plot size of the existing and proposed dwellings would appear overly cramped and would result in material harm caused to the character and appearance of the area and street scene.
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The prominence of the site is exacerbated by the choice of cladding colour and the insufficient width of the plot confirmed by the excessive depth of the property.
5.18 Ma tlesha Heath Wood is desig ated as a A ea to e P ote ted f o De elop e t APD u de sa ed poli AP of the fo e Lo al Pla , “P of the District Local Plan and Martlesham Neighbourhood Plan. There is no encroachment into this designated area as a result of this development.
5.19 The issue of precedent has arisen, as there is concern that if one infill plot is allowed o Bi h G o e the othe s ill follo to the fu the det i e t of the a ea s ha a te . Each application is judged on its own merits; however this matter has been given consideration. If the development was approved there could be pressure to allow other plots in the road, it is not however felt that the approval of one dwelling within this road will put undue pressure on the Local Planning Authority to approve infill development elsewhere on Martlesham Heath.
5.20 Policy MAR3 Martlesham Neighbourhood Plan states that development within the physical limits boundary is expected to be in keeping with the character of individual hamlets, be broadly the same density as the existing density of the hamlet, demonstrate a high quality built design and layout and retain or provide appropriate landscaping. The current application does not adhere to the criteria within this policy.
5.21 Policy MAR4 of the Neighbourhood Plan requires residential development to demonstrate good design. The policy sets out a number of criteria including requiring development to respond to and integrate with local surroundings and relate to the established plot widths within streets, particularly where this has established a rhythm to the architecture in the street. The proposal is contrary to the above criteria set out in this policy.
Residential Amenity
5.22 A number of letters of objection and the Parish Council have raised concerns in relation to the impact of the development on residential amenity. These are detailed in Section 3.5 of this report.
5.23 No.10 Birch Grove lies to the north of the application site with the host dwelling adjoining to the south. A high close boarded fence runs along the northern boundary adjacent to the rear garden area associated with the site. The owners of 10 Birch Grove have planted some trees within their garden along this boundary. The northern boundary adjacent to the front garden which accommodates the existing parking and turning area is planted with evergreen trees. The existing dwelling (No.10) and new dwelling will be approximately 15.5 metres apart at their closest point. The new property is proposed to be set approximately 1.8 metres off the northern boundary.
5.24 There is a levels difference between the application site and the property and patio a ea i ediatel su ou di g No. . The eigh ou s ai sitti g out a ea lies immediately to the south of the dwelling and there is an existing summerhouse
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adjacent to this area. The proximity of the new dwelling to the northern boundary and the levels change between the site and the house and patio area of No.10 Birch Grove will result in the development having a degree of impact o the eigh ou s a e it when compared to the current situation. Having considered the separation distances carefully and used the assessments set out in Supplementary Planning Guidance 16, it is however not felt that the impact will be so significant as to warrant refusal of the application on this basis. The windows of no.10 are a sufficient distance away from the new dwelling to prevent a significant loss of light to or outlook from them.
5.25 There are no first floor windows on the side elevation of the new dwelling facing north which would cause an unacceptable loss of privacy to the owners of No.10 Birch Grove.
5.26 The impact of the development on the amenities of No.9 Birch Grove and No.29 Lancaster Drive has been highlighted as a concern. There are sufficient separation distances between the sites and proposal in addition to the presence of two highways helping to lessen the impact. This relationship is considered acceptable.
5.27 The boundary between the host dwelling and application site will be defined by a new 1.8 metre close boarded fence. There are two first floor windows in the new development which will look south towards the end gable of the host dwelling and a proposed open front garden area, they serve a bedroom and en-suite. There are no windows on the gable end of the existing dwelling and by reason of the openness of the frontage area; the window will not cause a significant loss of privacy.
5.28 The relationship between the proposed development and host dwelling is considered on balance acceptable. There will inevitably be a level of mutual impact but this is not considered to unacceptable in terms of residential amenity.
5.29 As the application involves the erection of a new dwelling, the development may give rise to some additional noise and disturbance from traffic movements to and from the site. The disturbance caused by this is not considered significant by virtue of its confinement to the front of the site and distance from neighbouring properties.
5.30 There may be some disturbance caused during the construction phase of the development which may include piling works, this will however be short term. A construction management plan can be utilised to ensure appropriate provisions are made.
Highway Safety
5.31 Access to the site will be via a new driveway off Birch Grove close to the northern boundary of the site. The existing driveway will be retained by the host dwelling which currently benefits from a very large parking and turning area, this will be sub divided with an area provided for this purpose in front of each dwelling. Further parking will also be available within the integral garage associated with the new dwelling and
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detached double garage to be retained with the host dwelling. There is considered to be sufficient space on site for the parking and turning of vehicles.
5.32 The Highway Authority has no objections to the application but has recommended some standard conditions requiring details of the access, parking and turning areas and bin storage and presentation areas. These details have however been provided on the submitted drawings. A designated space within the rear garden of the plot has been shown for the storage of waste and recycling bins and a presentation area shown close to Birch Grove.
5.33 Some letters of representation have raised concerns in relation to highway safety. Firstly that the proposal will lead to increased pressure on the existing roads exacerbating existing traffic problems in the locality. The proposal will involve the provision of one additional dwelling and the Highway Authority has not raised any concerns in relation to the capacity of the highway network to cater for this. Comments have been raised regarding the presence of a shared driveway; the drawings illustrate separate access points and driveways for the new and host dwellings leading to parking areas with no formal division. Concerns have also been submitted in relation to the potential conflict between the new access and existing pedestrian use of the footway and footpaths in Birch Grove. The Highway Authority has not raised this as a concern. The footpath providing access to Eagle Way is located in between numbers 10 and 12 and the path providing access to the woodland is between 9 and 11, both sit to the north of the site. The new access crosses the pavement adjacent to the road as do the other properties on the eastern side of Birch Grove.
Ecology
5.34 No ecological survey has been provided with the application. The land is currently utilised as a garden with a large summerhouse occupying part of the site, an ornamental pond and rockery on the eastern side and the remainder laid to lawn. The use and maintenance of the area as private garden with the lawn regularly cut would not make the site attractive for reptiles.
5.35 There is an existing conifer hedge planted next to the existing parking area to the north of the host dwelling which is to be removed. The loss of this planting will be off set in part by the proposal to plant some new trees.
5.36 There are no records of protected species recorded on the site.
Other Matters
5.37 The applicant provided an environmental search and land contamination questionnaire in support of the application. There is evidence of several areas of infilled land and landfill along with potentially contaminative uses in the area. For this reason Environmental Protection have requested that further investigation is undertaken in the form of a Phase 1 contaminated land investigation as a minimum to
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adequately assess the risk of the former land uses on the proposed development. Dependent on the Phase 1 findings, further intrusive investigation may be necessary. Although it would be desirable for the investigatory works to be undertaken pre- determination of the application, the applicant understands the risks and wishes to deal with this matter post determination. Additional land contamination investigation works will be conditioned.
5.38 The application site lies in an area of archaeological interest, to the south-east of a Scheduled Bronze Age Barrow, which forms part of a wider barrow group spread across Martlesham Heath. The Archaeological Service has highlighted that there is potential for satellite burials of prehistoric or later date to be situated around this monument, including within the application site. As a result of the high potential for the discovery of assets of archaeological importance, the Archaeological Service recommends conditions requiring a Written Scheme of Investigation to be submitted.
5.39 A number of representations have been received stating that no other infill development has been approved previously on Martlesham Heath. This does not however prevent an application being made and each application must be considered on its planning merits. The presence of a restrictive covenant on the land preventing further residential development has been raised. The applicants are fully aware of the existence of this covenant.
5.40 The potential impact of the development on land and property values is also not a material planning consideration.
5.41 The development will be CIL liable.
Planning Balance and Conclusion
5.42 The application seeks planning permission for the sub division of No.8 Birch Grove and the erection of a new dwelling. The site lies within the physical limits and therefore the principle of residential development, subject to compliance with other policies in the District Local Plan, is acceptable. The site however lies within a prominent position within the street scene, the sub division of the No.8 Birch Grove will result in the new and host plots having narrower proportions than the existing properties in the road, in combination with the proximity of the site boundaries, this results in the development appearing overly cramped. The proposal does not relate well to the existing pattern of development and will appear out of character with the area and street scene.
5.43 The benefit arising from the contribution of one new dwelling in a sustainable location is outweighed by the adverse impacts of the development outlined above.
5.44 The application is recommended for refusal.
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RECOMMENDATION: REFUSE for the following reasons:
Birch Grove is characterised by large detached dwellings set within substantial plots, and this character derives from the vision and master planning of Martlesham Heath. The application site occupies and prominent position within the street scene by virtue of its elevated nature and open frontage. Whilst it is acknowledged that there may be physical space to accommodate a dwelling on the site, the sub-division of this plot would result in the subsequent plots not being of a size similar to those surrounding it, making it appear cramped within the area and street scene and out of character with the spacious character and appearance of Birch Grove. Both the host and proposed dwelling are located close to the site's boundaries; this is an uncommon feature in the street. The proposal is therefore contrary to Policies SP15 and DM7 of the District Local Plan (2013), MAR3 and MAR4 of the Martlesham Neighbourhood Plan (2018) and provisions of the NPPF.
DETERMINATION:
BACKGROUND PAPERS: DC/17/3144/FUL (No.8 Birch Grove), DC/17/3143/FUL & DC/18/1134/FUL (No.11 Birch Grove)
Committee Date: 19 July 2018
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