DAINS MILL AND KYLE BUILDING THE ROACHES

UPPER HULME

LEEK ST13 8TY

PLANNING AND HERITAGE ASSESSMENT

IN SUPPORT OF CHANGE OF USE AND

EXTERNAL ELEVATION ALTERATIONS AND ANCILLARY BUILDINGS

Date: 14th March 2021 Job No: Dains Mill & Kyle Building Ref:

PowerHaus Consultancy The Stanley Building 7 Pancras Square London, N1C 4AG

www.powerhausconsultancy.co.uk

Disclaimer

***UPDATE*** This report has been produced by Powerhaus Consultancy (PHC) and is intended for the sole and exclusive use of the instructing client. The report shall not be distributed or made available to any third party or published, reproduced or referred to in any way without the prior knowledge and written consent of PHC. The report does not constitute advice to any third party and should not be relied upon as such. PHC accepts no liability or responsibility for any loss or damage to any third party arising from that party having relied upon the contents of the report in whole or in part.

PLANNING AND HERITAGE ASSESSMENT JOB NO: DAINS MILL SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY

CONTENTS

1.0 INTRODUCTION, PLANNING HISTORY AND PROPOSALS ...... 2 2.0 NON DESIGNATED HERITAGE ASSET ASSESSMENT ...... 7 3.0 PLANNING POLICY CONTEXT ...... 12 Local Development Framework ...... 12 4.0 JUSTIFICATION OF PROPOSED DEVELOPMENT FOR CONVERSION OF DAINS MILL WITH EXTERNAL ALTERATIONS ...... 14 i) Principle of Change of Use ...... 14 ii) Conservation and Design ...... 14 iii) Sustainability ...... 15 5.0 JUSTIFICATION OF PROPOSED DEVELOPMENT FOR CONVERSION OF KYLE BUILDING WITH ANCILLARY BUILDINGS AND EXTERNAL ALTERATIONS ...... 16 ii) Ancillary Outbuildings ...... 16 iii) Conservation and Design ...... 17 iv) Sustainability ...... 17 6.0 SUMMARY AND CONCLUSIONS ...... 19 APPENDICES ...... 20

Appendix 1 – Site Location Plans

Appendix 2 – Appeal Decision APP/Q5300/W/20/3245024 Longbourn Forty Hill Enfield EN2 9EU 4 February 2021

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 1

1.0 INTRODUCTION, PLANNING HISTORY AND PROPOSALS

i) Introduction 1.1 This Planning and Heritage Assessment concerns Dains Mill and the associated Kyle building (grain drying store) at The Roaches, Upper Hulme, Leek, ST13 8TY. The location plans are attached at Appendix 1. Two separate planning applications have been submitted at the same time, which propose to bring into active and economic use these important local buildings that have had no use or maintenance for over 15 years. Neither building is formally listed, within a conservation area or within the defined Natural Zone of the Peak District National Park Authority (PDNPA), as set down in the Core Strategy (2011) and Development Management (2019) policies L1 or DMC2 respectively. 1.2 The Mill was carefully restored in 2004 and has never been used for any purpose since its successful restoration, including its fully functioning waterwheel. Dains Mill and its associated drying store (the Kyle) are considered to be non-designated heritage assets of local and regional significance.1 1.3 The infrastructure works to enable the use of the buildings for previously permitted holiday let or residential use have not been commissioned or invested in and still remain after all these years, an economically high hurdle in achieving the active and economic use of both buildings. The property currently has no electricity, water or sewerage facilities and due to its location outside of the main settlement of Upper Hulme, means that there is no cost effective way of connecting the buildings to any normal utilities in order to assist any effective occupation. 1.4 One of its former owners (Roger and Brian Ball), were the instigators of its restoration as a Mill building and have authorised the use of the Archaeological Report undertaken for the restoration. No services were included in this restoration project and the building is therefore a shell. It was restored as an agricultural building but was not brought into use. Permission was granted for holiday lets but was not brought into use. It was also subsequently granted permission for residential use and again was not brought into use. Both buildings are now deteriorating with damp penetration, doors and windows rotting, signs of forced entry and tiles slipping from the roofs. 1.5 The buildings cannot currently function for any use without implementing and investing in the high costs of connection to water, electricity and sewerage to enable the basic functions to exist, setting aside the additional costs of fitting it out and making the building water tight and efficient in energy use. 1.6 It did change hands again recently for residential use but was sold again quickly after purchase, probably after realisation of the significant costs to connect and convert the Mill to residential use. 1.7 It has recently been acquired privately. Two applications are submitted side by side to ensure a comprehensive proposal is presented to the PDNPA in terms of the proposed intentions for both properties. Essential to informing the proposals are the principles of conserving these non- designated heritage assets so that they can be enjoyed for their contribution to the quality of life of existing and future generations (NPPF para 184) that walk and pass by the Mill on a regular basis. The new owners consider themselves to be the next custodian of these important local buildings. 1.8 The proposals seek to sustain and enhance the significance of the heritage assets by putting them into viable uses consistent with their conservation. This will contribute to the social, cultural and environmental benefits of the importance of these buildings to the local community. The buildings signal the rural and agricultural character of the location and whilst no longer of benefit to corn milling or drying, the active use of the buildings, with the opportunity for the local community to visit and see the Mill in action, will give something back to the local community (see paragraph 1.30 below). 1.9 The history of the property reveals that parts of Dains Mill probably dates to the beginning of the 16th Century (footnote 1 above). It was in continuous use until 1946 when the then current owners’ grandfather, who occupied the mill at this time, was in hospital, a violent thunderstorm with very

1 Commercial Archaeology Heritage Statement – September 2017

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 2

heavy rain burst the dam around one of the ponds and as no-one was present to open the sluice gate and the mill was severely damaged (Captains Guide.co.uk). 1.10 Set out below is a brief summary of the planning history since. ii) Planning History 1.11 In February 2004, planning permission was granted to restore the mill (Reference NP/SM/1203/0923). It underwent an intensive programme of restoration funded by a grant and by private money provided by the then owners. The external fabric of the mill was restored in minute detail using original photographs, under the direction of the PDNPA, using the original building materials which had remained on site. 1.12 In Spring 2006, change of use of the mill was granted for holiday let (Reference NP/SM/0106/0032). The mill still had no internal infrastructure (electric, water and sewerage) and despite the then current owners seeking further grant monies, these did not materialise and the use was never implemented. 1.13 In January 2018, removal of the condition which restricted the use of the Mill for a holiday let was granted, allowing residential use (Reference: NP/SM/1017/1042). This use has not been implemented either. 1.14 Set out below is a summary of the two applications now submitted to the NPDA. iii) Proposals 1.15 Two separate but related planning applications have been submitted for: 1. Change of use of Mill to residential and/or holiday let with external alterations – Planning Portal Reference PP 09511428. 2. Change of use of Kyle to residential and/or holiday let, external alterations, ancillary buildings, and new gate – Planning Portal Reference PP 09511476. 1.16 The applicant is seeking a fluid use permission for each building. This is to enable the residential occupation of both buildings, whilst being able to let each building for part of the year for holiday lets, although not at the same time. The intention is that when a holiday let is secured for either building that the other building will be lived in by the owner to enable the holiday lets to be serviced ie regular cleaning and linen changing. A planning condition would be acceptable to the applicant to control this. 1.17 The Mill has historically been granted permission for both holiday let and residential uses and therefore the principle of both uses has been secured and has been demonstrated to be acceptable. 1.18 The Kyle building has only been permitted for ancillary uses for the Mill. However, neither has been occupied for any use and both buildings are already showing signs of deterioration through lack of use, including: - Windows and door frames rotting; - Signs of forced entry; - Significant damp patches rising up internal walls at ground floor in the Mill and in the Kyle building; and - Tile slips with roof leaks emerging at first floor of both buildings. 1.19 The use of the Kyle building for either use would sustain the economic use of the Mill by either holiday let use to contribute to local tourism or residential occupation to enable the Mill to be serviced whilst in use as a holiday let. 1.20 A recent appeal (see Appendix 2) was granted for the fluid use of a Grade II listed building in Enfield, with the Inspector appreciating the need for flexibility and that in that case both uses were acceptable2. Whilst it is accepted that all planning decisions must be based on the merits of each

2 APP/Q5300/W/20/3245024 Longbourn Forty Hill Enfield EN2 9EU 4 February 2021

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 3

individual case, this appeal does demonstrate that it is perfectly reasonable for dual uses to be granted for the same building and this is what is being sought here. 1.21 For these applications, both uses fall within Use Class C3 of the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020 No 757 – now referred to as the “Use Classes Regulations”. It is perfectly acceptable for two uses to be granted permission where both uses can be considered to be acceptable when planning permission is granted (Part 3 Class V UCO 1987). The transitional provisions for permitted development rights remain in place until 31 July 2021. Mill Alterations 1.22 The proposed alterations to the Mill comprise the following alterations to enable the building to be occupied for residential use, taking account of the Building Regulation Requirements Part L1 B): - Replacement doors and windows to limit heat loss and introduce energy efficient measures; - 4 Rooflights instead of seeking additional windows to introduce sufficient natural light to the proposed habitable rooms; - External guttering, drains and flues for implementation of necessary services and wood burners; - Two traditional Victorian style lamps on front elevation; - Balcony on front elevation with integrated bespoke grey water storage within the balcony floor (TekTank), to provide some private amenity space, given the public rights of way through the Mill complex; and - Extended access platform and safety rails over Mill race on rear elevation. 1.23 The documents and drawings submitted for consideration and approval are as set out in Table 1 below. Table 1: Application documents and plans for Dains Mill submitted via Planning Portal

Document Prepared By Cover Letter, Application Form, Notices and Declaration PowerHaus Consultancy Planning, Heritage Assessment and Sustainability PowerHaus Consultancy Statement Peak District National Park Protected Species Form PowerHaus Consultancy Design and Access Statement RPS Design Commercial Archaeology Heritage Assessment with Commercial Archaeology Manchester University Archaeology Assessment

DRAWINGS Site Location Plan 1:1250 Reference L100 RPS Design Existing and Proposed Ground Floor Plan 1:50 RPS Design Reference L104 Existing and Proposed First Floor Plan 1:50 RPS Design Reference L105 Existing and Proposed Roof Plan 1:50 RPS Design Reference L106 Existing Elevation 1 Scale 1:50 RPS Design Reference L107 Existing Elevation 2 Scale 1:50 RPS Design Reference L108 Proposed Elevation 1 Scale 1:50 RPS Design Reference L109 Proposed Elevation 2 Scale 1:50 RPS Design Reference L110 Proposed Doors and Windows Schedule L118 RPS Design

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1.24 It is fully noted that the PDNPA imposed a number of conditions on previous permissions including that - All door frames to be recessed by a minimum of 150mm and window frames no less than 100mm from the external face wall and of timber construction (2004 permission) - All rainwater goods to be cast metal painted black without fascia boards (2004 permission) - The retention of grafitti and dates in the living/dining room, the hole for the mill running gear and stone slabs to the floor (condition 3 of the January 2018 permission) 1.25 The applicant will continue to abide by these requirements in any planning permissions granted and would accept the imposition of such conditions for the planning applications now applied for. Kyle Building Alterations and Grounds 1.26 As well as seeking permission for a fluid use of the building for residential and holiday letting, the following alterations are proposed to the Kyle building: - Replacement doors and windows to limit heat loss; - Two Rooflights; - External guttering, drains and flues for implementation of necessary services; - Cast iron gates for additional security; - Stable building for two horses; - Garage and Lean Too with access stairs; and - Parking off top road using Grasscrete. 1.27 As with the Mill, the same requirements for the details of the installation of windows, doors and rainwater goods would be accepted for the Kyle building alterations. 1.28 The plans and documents submitted for consideration are as set out in Table 2 below:

Table 2: Application documents and plans for Kyle Building Submitted via Planning Portal

Document Prepared By Cover Letter, Application Form, Notices and Declaration PowerHaus Consultancy Planning, Heritage Assessment and Sustainability PowerHaus Consultancy Statement Peak District National Park Protected Species Form PowerHaus Consultancy Design and Access Statement RPS Design Commercial Archaeology Heritage Assessment with Commercial Archaeology Manchester University Archaeology Assessment DRAWINGS Site Location Plan 1:1250 Reference L101 RPS Design Existing Site Plan 1:200 Reference L102 RPS Design Proposed Site Plan 1:200 Reference L103 Existing Floor Plans 1:50 Reference L111 RPS Design Proposed Floor Plans 1:50 Reference L112 RPS Design Existing Front and Rear Elevations Scale 1:50 RPS Design Reference L113 Existing Side Elevations Scale 1:50 RPS Design Reference L114 Proposed Floor Plans Scale 1:50 RPS Design Reference L112

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 5

Proposed Elevations Scale 1:50 RPS Design Reference L115 Proposed Side Elevations Scale 1:50 Reference L116 RPS Design Proposed Stable Building Scale 1:50 Reference L117 RPS Design Proposed Doors and Windows 1:50 Reference L118 RPS Design

1.29 The creation of a new garage adjacent to the Kyle building is required for the secure storage of maintenance and garden equipment for the site and its buildings. It is important that adequate secure storage is available on site given its remote location and extensive grounds which need to be maintained by the owner. Community Access Offer 1.30 The applicant intends to offer open days to the public at least four times a year to view the Mill wheel in operation, which will be promoted with local schools and walking groups who are all probably familiar with the building and its history. Discussion will also take place with Leekfrith Parish Council.

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 6

2.0 NON DESIGNATED HERITAGE ASSET ASSESSMENT

i) Policy Requirements 2.1 Whilst the PDNPA does not have a formally published list of buildings that are considered to be either locally listed or non-designated heritage assets, the extensive planning history of the Mill is supported by documents that fully record and assess the history and importance of the Mill and adjoining Kyle building to the local area and its farming history. The starting point for this assessment therefore is that the application buildings are non-designated heritage assets and that any alterations that directly or indirectly affect these buildings will be assessed in accordance with paragraph 197 of the National Planning Policy Framework (NPPF) 2019 ie that the scale of any harm or loss requires a balanced judgement regarding the effect on the significance of the heritage asset. 2.2 This document does not seek to repeat the properties documented history but in accordance with Historic England’s Good Practice Advice in Planning Note 3 ‘The Setting of Heritage Assets’ and Historic England’s publication Managing Significance in Decision-Taking in the Historic Environment (HE2015a), it will consider whether the proposed alterations harm the setting and/or significance of the buildings. The NPPF also requires the assessment to be proportionate to the significance of the heritage asset and whether the proposed changes enhance or detract from that significance and the ability to appreciate it. 2.3 Importantly these documents provide assistance in the interpretation and implementation of the NPPF and PPG and provide crucial guidance on how to assess the potential effects of a proposal on a heritage asset. There are six main guidance points: • To understand the significance of the affected assets; • To understand the impact of the proposal on that significance; • To avoid, minimise and mitigate impact in a way that meets the objectives of NPPF; • To look for opportunities to better reveal or enhance significance; • To justify any harmful impacts in terms of the sustainable development aim of conserving significance and the need for change, and • To offset negative impacts on aspects of significance by enhancing others through recording, disseminating and archiving the archaeological and historical interest of the heritage assets affected.

2.4 The reconstruction of the Mill in 2004 was preceded by an archaeological investigation undertaken by the University of Manchester Archaeological Unit (UMAU), which was published in 2006 (footnote reference 1 above). This report confirmed the multi-phase development of the mill building with fabric identified as dating back to the beginning of the 17th century. The report concluded: Yate’s map of Staffordshire published in 1775 shows more than a hundred water mills, the majority of which were probably used for corn milling. In the urban areas of Staffordshire and southern Cheshire many corn mills were demolished or changed their use as the towns developed from the late 18th century to the mid-19th century. In many towns during this period steam-powered mills with beam engines driving several sets of stones replaced the old uneconomical and more local mills……In the late 19th century roller milling began to take over from the old method of grinding with a bedstone and runner stone. The new method was used not only in the steam-powered mills in the industrial towns of the Northwest but in the new, much larger scale, mills built to process imported grain.

Dain’s Mill is thus an example of the older, traditional, type of corn mill which used a waterwheel to power mill stones. As a mill whose fabric dates back to the early 17th century it is one of the oldest such standing structures in Staffordshire.

The Heritage Statement of September 2017 by Commercial Archaeology concluded that: The combined weight of the evidence, including desk-based research, cartographic analysis and archaeological investigation, establishes that the Dain’s Mill complex, comprising the restored mill buildings and associated drying house and water management system, represents a heritage asset of both local and regional significance.

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 7

Its special interest arises from a number of factors which include its architectural interest as a multi-phase traditional mill building; its historic interest as a building which illustrates an important aspect of social and economic history supported by detailed documentary evidence associated with named individuals and its archaeological interest as a building and a site which contain potential buried deposits associated with its earliest origins as a watermill.

The mill has been rebuilt using the original collapsed stonework on site and has been restored with extreme accuracy and authenticity under the direction of the Peak District National Park Authority. Not only do the restored mill buildings contribute to our understanding of early watermills in Staffordshire but in its restored form the mill enhances, and is enhanced by, its own immediate historic setting. The integrity of the mill complex comprising the mill buildings, the drying store and the water management system serves to increase the heritage significance of Dains Mill and the contribution made to it by its setting. The mill complex as a heritage asset also serves to enhance the local distinctiveness and historic interest ….

The archaeological report identified Dain’s Mill as one of the oldest standing structures of its kind in Staffordshire and this is clearly corroborated by the extant documentary evidence which pertains to it. Whilst the mill buildings are currently in good repair, the greatest risk to the restored mill would be for it to be left vacant and unmaintained. This would inevitably result in the carefully restored buildings once again falling into disrepair and eventual dereliction. This would represent an impact of substantial harm to the significance of an important heritage asset.

2.5 The focus of the NPPF is on sustainable development within the historic environment. In Paragraph 192 it requires that in determining planning applications, local planning authorities should take account of the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation. 2.6 In the case of Dains Mill its long term conservation is in urgent need of delivery and needs to be assured through a viable use which will maintain it as a heritage asset of significance for this and future generations. This long term conservation would be secured through its use as a permanent dwelling with holiday let and this would accord with the focus on sustainable development in NPPF and with local planning policy, in particular policy HC1 (C) of the Core Strategy, which states that exceptionally new housing can be accepted if it is required in order to achieve conservation and/or enhancement of a valued vernacular or listed building. 2.7 The restored mill is already showing signs of disrepair and water ingress, its survival as a significant heritage asset is dependent upon an assured level of future permanent maintenance such as could be achieved through its conversion to a dwelling and use for residential and/ or holiday letting. 2.8 The ‘Cultural Heritage Strategy for the Peak District National Park – Peak through Time’ document identifies the key objective for the sustainable management of the cultural heritage of the Peak District National Park. In relation to historic buildings and structures it states: The historic buildings and structures of the Peak District are a significant feature of the landscape. They range from grand houses and religious buildings through labourers’ cottages to field barns and stone crosses. Many factors have shaped the architecture of the Peak, with farming probably the strongest – farmhouses and agricultural buildings are a particularly rich resource. Past industrial activity – lead mining, quarrying and textiles – has left an equally strong legacy. Surviving evidence ranges from mills to workhouses, mine engine house to weavers’ cottages.

The cultural heritage is an irreplaceable, finite resource. While the landscape is always changing, in the 21st century the ability to destroy has never been more powerful or more immediate. The skill lies in managing that change, enabling sustainable development of the cultural heritage, so that today’s activities leave a meaningful legacy for the future,

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 8

whilst respecting that of the past… For many, it is not the commonplace, the non- designated, the mundane even, that contributes most to local distinctiveness.

2.9 Part 2, Action Plan of the document includes the objectives for conservation, including the sustainable management of sites, monuments, buildings, settlements and landscapes and their intellectual and aesthetic appreciation, including local customs and traditions and the communities that sustain them.

2.10 Relevant to this report are the following objectives:

- Ensure that cultural heritage is fully integrated into the sustainable management of the PDNPA landscape, through planning and other consultation processes, conservation initiatives and day to day management of the National Park landscape. - Provide encouragement, practical advice and support, including where available financial support, to owners, managers and others, to facilitate the sustainable management of the cultural heritage of the National Park. - Promote, engage in and/or commission practical conservation projects as part of the sustainable management of the cultural heritage of the National Park. - Develop partnership working to achieve sustainable management of the cultural heritage. - Monitor the physical condition of locally important undesignated historic buildings, monuments and structures to inform decision making and targeting conservation action.

ii) Assessment of Setting and Significance

2.11 The Archaeological Assessment undertaken by the University of Manchester as a watching brief and Building Survey in 2006, attached to Commercial Archaeology’s assessment of Dains Mill at that time (footnote 1 reference above), is a composite and robust assessment of the Mill. There is little merit in undertaking a further assessment of setting and significance as the conclusions reached that the Mill and Kyle buildings as non-designated heritage assets of local importance, are fully concurred with and this has not changed since that time. The documents have been submitted again for this reason.

2.12 This assessment therefore now considers the proposed alterations for each building to assess whether the proposed changes would harm or detract from the significance and understanding of each building and would be needed to prevent the buildings from decaying and depreciating once again.

iii) Assessment of Impact of External Alterations to Dains Mill

2.13 Section 1 and Table 1 above sets out the drawings that have been considered to assess the impact of the proposed external alterations to Dains Mill to assess whether the alterations are considered to result in no harm or less than substantial harm to the Mill.

2.14 First, it has been accepted through the Mill’s planning history, that whilst the proposed uses are not the uses that the building was originally constructed for, the uses will preserve this important local building. It has been concluded that alternative uses are required to sustain and enhance the Mill to put it to a viable use that will do no harm to its conservation (NPPF para 192). This acceptance is carried through in this assessment and again is concurred with.

2.15 The proposed Mill drawings demonstrate that there are no new openings/windows proposed to the external elevations Mill or extensions. This is considered a positive response to the Mill’s uses and was a factor not considered in the removal of the restrictive condition preventing residential use in 2018. The Mill needs to perform to a level of sustainability to meet Building Regulation requirements and the PDNPA sustainable development policies CS CC1 and SPD Climate Change and Sustainable Building considered further in Section 4 below.

2.16 The use of rooflights and an element of glazing in replacement doors is considered to be a balanced and proportionate intervention to the external elevations and roof to allow sufficient light into habitable rooms. The proposed materials are high quality, reflect the agricultural aesthetic of the Mill and therefore compliant with local and national heritage policies.

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 9

2.17 The proposed external balcony to the front elevation which has been designed to store grey water in a bespoke TekTank facility within the floor has been proposed to provide a degree of external private balcony space. The location is quite public and is busy in summer months with people enjoying the National Park. An area of private amenity offers a practical solution to this local dynamic. The materials are agricultural/industrial made from steel reflective of the rural location. No important features of the Mill are obscured or diminished from this intervention and are considered on balance to be an appropriate addition.

2.18 A similar fabricated platform extension to the rear elevation that will provide safety measures preventing accidents of potential falling into the former Mill race to the rear. This is required for residential and holiday let occupation and again reflect appropriate materials to the character of the building. Due to the ground levels at the rear, the rear platform will barely be seen from the public footpath down towards the Mill and will cause no harm to this non-designated asset.

2.19 Whilst the Authority’s policies also allow a degree of flexibility to Building Regulation requirements in order to preserve the key characteristics of heritage assets (SPD Climate Change and Sustainable Building), the owner’s also want to keep as many of the internal walls bare (not plastered) which runs counter to sustainability requirements for insultation performance. This means that doors and windows need to perform at a high a rate as possible, whilst reflecting the character of the Mill.

2.20 All windows are therefore proposed to be double glazed made from natural hard wood. This is an appropriate material for the original age of the property and are designed to reflect the historic Mill aesthetic and therefore appropriate.

2.21 The doors are also proposed of hard wood which will be durable and retain the heat within the building. Some glazing is proposed in the doors to allow more light into the Mill which has few existing windows. Whilst this will replace the barn style existing doors, the property will be used as residential and this is more appropriate to this use to provide a reasonable standard of light within the dwelling. The proposed doors are appropriate to the Mill aesthetic. The internal roof space between the rafters will be insulated to obviate more harmful interventions with the internal stone walls. This is a proportionate response to introducing sustainable insultation, the specification of which is referred to in the D&A.

iv) Assessment of Impact of External Alterations and Ancillary Buildings Adjacent to Kyle Building

2.22 The same style of doors and windows are proposed for the Kyle building to make it wind and water tight. Rooflights are again chosen to add additional light into the building rather than creating new windows. They are considered appropriate for the Kyle building which aligns with the age of parts of the Mill and is constructed with the same stone and tile.

2.23 A double garage with room for secure storage is proposed adjacent to the Kyle building. The location will ensure that other than when approaching from the south that the garage building can not be seen in views or public footpaths running through the site. The materials will match the local stone and will not compete with the existing buildings on site. Solar panels and a green roof will also ensure that the building is absorbed into its background of the landscape as well as contributing to sustainable development objectives.

2.24 Ensuring that these buildings are well maintained and looked after is a key consideration for their long term preservation. The location and design of the new garage is considered to cause no harm to the Kyle building and once naturalised will look as though it has been part of the Mill complex.

2.25 There is no harm arising from the location of Stables in the higher field which will be constructed of wood and corrugated iron and therefore a natural building for the location and maintenance of horses on site. The location has no impact on the setting of the Mill and Kyle building and will not be seen from either building.

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 10

v) Summary and Conclusions

2.26 In summary, all of the proposed external alterations are considered to reflect the character of the Mill’s heritage, contribute to its preservation and will enhance its sustainability and chance of continued protection and use. The proposals have been carefully considered with materials selected to make a positive contribution to the Mill’s economic use, that will help to conserve these important local heritage assets. The proposals fully accord with paragraph 192 and 197 of the NPPF and CS policy L3 and DMP policies DMC5 and DMC10. There is considered to be no harm arising to the Mill or Kyle buildings and every prospect that the interventions will enhance these assets and their understanding. There will be no loss of any important attribute of these non- designated heritage assets.

2.27 It is clear from the history and lack of use, that active and economic uses are urgently required to ensure that these important local buildings do not deteriorate further and that the uses and changes sustain and enhance these non-designated heritage assets. The history also demonstrates that no one owner has been able to afford the costs of implementing the basic services required to activate the uses permitted and that this opportunity should be embraced now.

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 11

3.0 PLANNING POLICY CONTEXT

Local Development Framework 3.1 Under section 70 of the Town and Country Planning Act 1990 and Section 38 of the Planning and Compulsory Purchase Act 2004, development should be determined with regard to the development plan, unless material considerations indicate otherwise. Paragraph 11c of the National Planning Policy Framework (NPPF) (2019) states that for decision-taking this means approving development proposals that accord with an up-to-date development plan without delay. The Local Development Framework of this application site is considered to contain the following documents: - Core Strategy (CS) – adopted October 2011 - Development Management Policies (DMP) – adopted November 2019 3.2 In addition, the NPPDA has adopted a range of supplementary guidance that is relevant to consideration of these applications: - Alterations and Extensions Detailed Design Guide - SPD 2014 - Design Guide – 2007 - Climate Change and Sustainable Building – adopted 2013 3.3 A significant material consideration is also the NPPF and supporting guidance, alongside Historic England’s guidance addressed in the section 2. 3.4 The following Core Strategy (CS) policies have been identified as germane to the determination of the two applications: - CS Policy HC1(C) – New Housing - CS Policy DS1 – Development strategy - CS Policy GSP2 – Enhancing the National Park - CS Policy L1 – Landscape character and valued characteristics - CS Policy L3 – Cultural heritage assets of archaeological, architectural, artistic or historic significance - CS Policy RT1 – Recreation, environmental education and interpretation - CS Policy RT2 – Hotels, bed and breakfast and self-catering accommodation - CS Policy CC1 – Climate change mitigation and adaption 3.5 The following Development Management Policies (DMP) have been identified as germane to the determination of the two applications: - DMC1 – Conservation and enhancement of nationally significant landscapes – the South West Peak - DMC3 – Siting design layout and landscaping - DMC5 - Assessing the impact of development on designated and non- designated heritage assets and their settings - DMC10 – Conversion of a heritage asset - DMR4 – Facilities for keeping and riding horses - DMH7 – Extensions and alterations - DMH8 – New outbuildings and alterations and extensions to existing outbuildings in the curtilage of dwelling houses 3.6 The Dains Mill application raises the following issues: i) Principle of Use for Residential and/or Holiday Let ii) Acceptability of Design of External Alterations

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 12

iii) Impact on Setting of Non-Designated Heritage Asset iv) Demonstration of application of sustainable development principles 3.7 The Kyle application raises the following issues: i) Principle of Use for Residential and/or Holiday Let ii) Acceptability of Design of External Alterations iii) Impact on Setting of Non-Designated Heritage Asset iv) Acceptability of ancillary outbuildings v) Demonstration of application of sustainable development principles. 3.8 The applications will now be assessed in Section 4, against these primary policies adding in any references to the relevant supplementary planning guidance documents.

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 13

4.0 JUSTIFICATION OF PROPOSED DEVELOPMENT FOR CONVERSION OF DAINS MILL WITH EXTERNAL ALTERATIONS

i) Principle of Change of Use 4.1 Dains Mill is considered to be a valued building, characteristic of the South West Peak area of the National Park, reflecting its agricultural history and former use. It is not within the Natural Zone or within the Upper Hulme conservation area. The bringing of the Mill into active residential use delivering a low impact economic use by use of an existing building for holiday let and residential, is considered to meet the requirements of CS Policy GSP2 and DMP Policy DMC1 to enhance the National Park and nationally significant landscapes, as no harm will arise from adapting the existing building. 4.2 The proposed uses will retain a historic building and reveal its historic use, conserve a restored building and continue to enhance its rural location that is enjoyed by many local people and tourists to the area in accordance with the principles of CS Policy GSP3 and DMP policy DMC5. 4.3 The building has previously been granted permission for change of use to holiday let and residential but neither use has been fully implemented. This sets the principal acceptability of both uses in accordance with the effective re-use of traditional buildings, which is encouraged in the South West Peak. 4.4 CS Policy DS1 identifies that outside of the Natural Zone in the countryside that recreation and tourism and conversion to housing will be acceptable in principle. Re-use of Dains Mill will not impact on the valued landscape character in which it sits as required by CS Policy L1 and DMP DMC3. 4.5 CS Policy HC1 allows open market housing in accordance with core policies GSP1 and CSP2, where it is required to achieve the conservation and /or enhancement of valued vernacular buildings. Dains Mill is such a building and it has historically been found to be acceptable for residential use. The urgency of bringing into use the Mill building is becoming more and more apparent by the deterioration of the building since its meticulous restoration in 2005/6. The rotting doors and windows will lay open the building to vandalism, further water and wind ingress and threaten the excellent work that has gone into restoring the Mill building. 4.6 The NPPDA has considered both proposed uses before and found both to be acceptable in accordance with CS Policies RT2 and HC1. Neither use would harm the significance or setting of the Mill and would enable the better revelation of the building by the public. 4.7 The applicant is additionally wanting to provide the opportunity for the public to visit the working watermill a minimum of four times a year. Clearly the Mill sits adjacent to a public footpath and it is therefore widely appreciated as it is. However, in casually canvassing the nearest neighbours and local walkers opinions, there is a strong desire to learn more about the Mill and its functioning waterwheel. 4.8 The use would enable a greater appreciation of the Mill following its extensive restoration and archaeological evaluation. The applicant is proposing to offer opportunities for educational visits for local groups and school children. This would accord with the principles of CS Policy RT1. ii) Conservation and Design 4.9 There are limited alterations proposed to the Mill but all are essential for the effective re-use of the building. When it was restored, no consideration was given to the provision of essential services to the building, which is a vital component of its re-use. In order for the building to be maintained as restored, it needs to be heated, it needs secure sustainable windows and doors, private amenity areas and safety measures introduced to the former Mill race and it needs to be regularly maintained to protect against wind and water ingress. 4.10 As is described in the Design & Access Statement, all materials proposed would be from sustainable sources, wood and glass for the windows and doors, black cast guttering and drainage, steel balcony to the front to create an area of private amenity space for the dwelling, steel landing to provide a safety area over the former Mill race all to reflect its agricultural and industrial past. 4.11 All window and door designs reflect the Mill’s agricultural historic use and examples of other such buildings in the NPPDA. The replacement doors and windows will add a degree of quality, security

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 14

and sustainability to the Mill. The existing doors and windows are rotting, need replacing and do not provide a wind and water tight building in accordance with sustainable development principles. 4.12 Section 2 above has undertaken a heritage assessment and considered the proposed external alterations against heritage asset policies and principles. It concludes that the external changes do not harm this non-designated heritage asset, to accord with the NPPF paragraph 197, CS Policy L3, DMP policies DMC5 and DMC10.

iii) Sustainability 4.13 The re-use of Dains Mill will accord with the CS Policy CC1 sustainable development principles. The building is within a low flood risk area Flood Zone 1. The external changes are required to embrace the need to reduce energy consumption by making the building wind and water tight to enable less energy use. 4.14 The Authority’s SPD principally targets high standards for new buildings and it states in paragraph 7.4.1 that there is no need to go beyond Building Regulations in terms of sustainability standards. Nonetheless, the proposals to convert the Mill have sought to reduce the need for energy by upgrading and replacing all doors and windows with double glazed appropriately designed products that will reduce the heat loss from the building and its energy demands. 4.15 All white goods used in the building will be sourced from A+++ rated manufacturers. Bathroom goods will be low flush confining water use to a maximum of 110 litres per person per day. 4.16 The location of the building away from nearby settlements limits and as a non-designated heritage asset limits the flexibility to introduce low carbon technologies. The exploration of hydro power has been assessed but found to be prohibitively expensive and require extensive alterations to the Mill pond and race to extract sufficient water from the stream to power the watermill for energy generation. The Environment Agency has expressed concerns about extraction of water from the stream to power the Mill on a continual basis. The risks to the stability of the Mill would also increase should the property be left vacant for any period of time as became its fate in the 1940s when it was washed away by flooding. 4.17 Given the proximity of an electricity supply adjacent to the existing buildings, the buildings will be powered by low energy efficient electric boilers. A Therma Flow Electric Combi boiler has been selected for its high energy efficiency (100%). It is designed to operate with peak avoidance tariffs to reduce running costs and can be linked with the proposed solar panels on the new garage building. 4.18 The only economic means of dealing with sewerage is through an onsite system. A Klargester BioFicient system has been selected that treats the waste on a daily basis and requires only a once a year emptying and retreatment. It is a high performance low power consumption system with very limited external visual impact. 4.19 The materials proposed to be used are a balance between conserving the unique features of the existing Mill both internally and externally, keeping and retaining its agricultural aesthetic, whilst recognising the practical residential/ holiday use requirements of a functioning home. It is therefore considered that the application for subsequent Building Regulation approval will need to balance the local heritage asset and its qualities and how the building meets current regulation standards as recognised in the Authority’s Sustainable Development SPD. 4.20 Water butts will be used in all appropriate locations to conserve water. Additional grey water recycling has been designed into the platform of the balcony as a purpose designed black TekTank. This has the ability to store water which can be reused for garden and general use purposes. The introduction of bird and bat boxes is proposed to encourage greater biodiversity.

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 15

5.0 JUSTIFICATION OF PROPOSED DEVELOPMENT FOR CONVERSION OF KYLE BUILDING WITH ANCILLARY BUILDINGS AND EXTERNAL ALTERATIONS

i) Principle of Change of use 5.1 The Kyle building alongside Dains Mill is considered to be a valued building, characteristic of the South West Peak area of the National Park, reflecting its agricultural history and former use. It is not within the Natural Zone or within the Upper Hulme conservation area. Whilst it was not the subject of restoration in 2005/6, its continued existence is also threatened by the same lack of active and economic use. It cannot be considered to be an inappropriate existing building as it was very much an important functioning part of the Mill for the drying of corn. The bringing of the Kyle building into active residential use delivering a low impact economic use by use of an existing building for holiday let and residential, is considered to meet the requirements of CS Policy GSP2 and DMP Policy DMC,1 to enhance the National Park and nationally significant landscapes, as no harm will arise from adapting the existing building. 5.2 The proposed uses will retain historic buildings and better reveal its historic use, conserve a restored building and continue to enhance its rural location that is enjoyed by many local people and tourists to the area in accordance with the principles of CS Policy GSP3 and DMP policy DMC5. 5.3 The building has previously been accepted as an ancillary use to the Mill building, albeit that it has not been permitted for independent residential or holiday let use. It has not however, been actively used for a number of decades and faces the same neglect perils as the Mill. The use of the Kyle whilst the Mill is let for holiday use will enable the close monitoring and upkeep of the Mill building. Conversely, when the Mill is occupied by the applicant, the Kyle building could be let for holiday let for a couple and again be closely monitored from the Mill. It is not anticipated that both the Mill and the Kyle would be let for self-catering holiday let at the same time. Both uses have been found to be acceptable for the Mill and both uses would accord with the effective re-use of traditional buildings, which is encouraged in the South West Peak. 5.4 CS Policy DS1 identifies that outside of the Natural Zone in the countryside that recreation and tourism and conversion to housing will be acceptable in principle. Re-use of the Kyle building will not impact on the valued landscape character in which it sits as required by CS Policy L1 and DMP DMC3. 5.5 CS Policy HC1 allows open market housing in accordance with core policies GSP1 and CSP2, where it is required to achieve the conservation and /or enhancement of valued vernacular buildings. The Kyle is such a building. The urgency of bringing into use the Kyle building is becoming more and more apparent by the deterioration of the building from lack of use and occupation. The rotting doors and windows will lay open the building to vandalism, further water and wind ingress. 5.6 The NPPDA has considered both proposed uses before and found both to be acceptable in accordance with CS Policies RT2 and HC1. Neither use would harm the significance or setting of the Kyle or Mill and would enable the better revelation of these buildings by the public. The applicant is wanting to provide the opportunity for the public to visit the working watermill a minimum of four times a year. Clearly the Mill sits adjacent to a public footpath and it is therefore widely appreciated as it is. However, in casually canvassing the nearest neighbours and local walkers’ opinions, there is a strong desire to learn more about the Mill and its functioning waterwheel. 5.7 The use would enable a greater appreciation of the Mill following its extensive restoration and archaeological evaluation. The applicant is proposing to offer opportunities for educational visits for local groups and school children. This would accord with the principles of CS Policy RT1. ii) Ancillary Outbuildings 5.8 It is proposed in order to support the upkeep, maintenance and use of the Kyle building and Mill that two garages are constructed adjacent to the Kyle building. The location has been accepted as a surface parking location previously, however, nowhere in previous proposals has there been any provision for secure maintenance and garage spaces which is a highly important consideration for this rural location. The buildings sit in nearly 2 hectares of land that will need to be maintained with equipment securely stored in locked garages.

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 16

5.9 DMP policy DMH8 supports the principle of new outbuildings within the curtilage of dwelling houses. On the principle that a holiday let and residential use are both acceptable, then supporting outbuildings are required to sustain these uses and buildings with regular upkeep. The location has been assessed as being the most appropriate location as it will not be seen from public footpaths, views around the location and will sit neatly against the backdrop of rocks and natural land formation with no impact on existing landscape features. 5.10 The design has followed the Authority’s design guide principles and seeks to use natural materials and doors to match the Kyle building whilst the sides and roof will be merged with the proposed garden area above, utilising the earth covering for sustainable materials and insulation benefits. Other than the front of the garage building it will not be a visible in the wider landscape and will only be visible from the front. 5.11 A simple car port is proposed on the south west side of the building to enable sheltered parking for use of the Kyle building for holiday let and create a small area of private garden with metal railings for safety along the edge. 5.12 The owner also wishes to keep horses for recreational purposes and proposes two stables with storage for food and bedding part the way down the northern track within the field. Again, the location has been chosen to limit the impact of the stable building on any views and landscape features, particularly from the Mill and Kyle buildings. iii) Conservation and Design 5.13 There are limited alterations proposed to the Kyle but all are essential for the effective re-use of the building. Like the Mill it has no essential services to the building, which is a vital component of its re-use and maintenance. In order for the building to be maintained, it needs to be heated, it needs secure sustainable windows and doors, private amenity areas and it needs to be regularly maintained to protect against wind and water ingress. 5.14 As is described in the Design & Access Statement, all materials proposed would be from sustainable sources, wood and glass for the windows and doors, black cast guttering and drainage, local stone and wooden doors all to reflect its agricultural and industrial past. The raised garden which will form the roof of the garage, will provide a degree of private amenity space for the Kyle building, as the location attracts and the public right of way passes between the Kyle and Mill buildings. 5.15 All window and door designs reflect the Kyle’s agricultural historic use and examples of other such buildings in the NPPDA. The replacement doors and windows will add a degree of quality, security and sustainability to the Kyle. The existing doors and windows are rotting, need replacing and do not provide a wind and water tight building in accordance with sustainable development principles. 5.16 Section 2 above has undertaken a heritage assessment and considered the proposed external alterations against heritage asset policies and principles. It concludes that the external changes do not harm this non-designated heritage asset, to accord with the NPPF paragraph 197, CS Policy L3, DMP policies DMC5 and DMC10. iv) Sustainability 5.17 The re-use of the Kyle will accord with the CS Policy CC1 sustainable development principles. The building is within a low flood risk area Flood Zone 1. The external changes are required to embrace the need for energy by making the building wind and water tight to enable less energy use. 5.18 The proposals to convert the Kyle have sought to reduce the need for energy by upgrading and replacing all doors and windows with double glazed appropriately designed products that will reduce the heat loss from the building and its energy demands. 5.19 All white goods used in the building will be sourced from A+++ rated manufacturers. Bathroom goods will be low flush confining water use to a maximum of 110 litres per person per day. 5.20 The location of the building away from nearby settlements limits and as a non-designated heritage asset limits the flexibility to introduce low carbon technologies. The exploration of hydro power has been assessed but found to be prohibitively expensive and require extensive alterations to the Mill pond and race to extract sufficient water from the stream to power the watermill for energy

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 17

generation. The Environment Agency has expressed concerns about extraction of water from the stream to power the Mill on a continual basis. The risks to the stability of the Mill would also increase should the property be left vacant for any period of time as became its fate in the 1940s when it was washed away by flooding. 5.21 Given the proximity of an electricity supply adjacent to the existing buildings, the buildings will be powered by low energy efficient electric boilers and linked to the Mill building. 5.22 The only economic means of dealing with sewerage is through an onsite Klargester that treats the waste on a daily basis and requires only a once a year emptying and retreatment that will be provided in front of the Mill building. 5.23 The materials proposed to be used are a balance between conserving the simple features of the Kyle both internally and externally, keeping and retaining its agricultural aesthetic, whilst recognising the practical residential/ holiday use requirements of a functioning home. It is therefore considered that the application for subsequent Building Regulation approval will need to balance the local heritage asset and its qualities and how the building meets current regulation standards as recognised in the Authority’s Sustainable Development SPD. 5.24 Water butts will be used in all appropriate locations to conserve water for garden use.

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 18

6.0 SUMMARY AND CONCLUSIONS

6.1 The Mill and Kyle building are both considered to be buildings of important local interest and non- designated heritage assets. The recent history of both buildings demonstrates that whilst restored with great care in 2005/6, that no owner has actively brought into use either building or been able to install the basic essential services to enable the buildings to function. Both buildings are showing concerning signs of deterioration through lack of use and regular maintenance. These applications seek to redress this by investing in sympathetic and limited alterations to the buildings, incorporating a garage and stable building for domestic use and using both buildings for residential and/or holiday let. 6.2 The careful restoration of the Mill has demonstrated that the building is of significant local interest and is an important example of a working Mill. The applicant will enable access to the Mill and working water wheel four times a year in liaison with the local community. 6.3 The alterations to the Mill and Kyle Building with limited ancillary new buildings are considered to cause no harm to the setting of these buildings and are considered proportionate interventions to bring the buildings into economic use. They will provide much needed secure storage and facilities for this rural location. 6.4 For all of the reasons set out in this assessment, the applications are considered to accord with the sustainable and heritage requirements of the NPPF, relevant Core Strategy policies and Development Management Polices and designs reflecting the Design and Sustainable Development SPD guidance and should therefore be recommended for approval.

Sign

On behalf Powerhaus Consultancy

Date: 14th .March 2021……………………………………………………

PLANNING, HERITAGE AND SUSTAINABILITY ASSESSMENT JOB NO: DAINS MILL & KYLE BUILDING SITE ADDRESS: THE ROACHES, UPPER HULME, LEEK, ST13 8TY 19

APPENDICES

Appendix 1 – Site Location Plans

Appendix 2 – Appeal Decision APP/Q5300/W/20/3245024 Longbourn Forty Hill Enfield EN2 9EU 4 February 2021