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From: Henny Handley <[email protected]> Sent: 21 October 2019 15:33 To: West1 Subject: Objection letter to appeals: APP/X0360/W/19/3224323 and APP/X0360/W/19/3224329 Attachments: 191021 Malmesbury Estate APPEAL objection letter .3 FINAL.pdf FAO Adam Hill, Please find attached an objection letter for the above referenced appeals. I would be grateful if you could keep me informed on any further correspondence on this appeal, as I understand it will now be determined through a hearing. We would welcome the opportunity to comment further on the Appellants proof of evidence. Please confirm receipt of this email. Kind regards, Henny Handley Associate Planner (Working days: Monday to Wednesday. For enquiries on a Thursday and Friday please contact the office on 01344 207777) Pegasus Group PLANNING | DESIGN | ENVIRONMENT | ECONOMICS | HERITAGE The Columbia Centre | Station Road | Bracknell | RG12 1LP T 01344 207777 | E [email protected] M 07823520732 | DD 01344 203269 | EXT 7004 Birmingham | Bracknell | Bristol | Cambridge | Cirencester | Dublin | East Midlands | Leeds | Liverpool | London | Manchester| Newcastle |Peterborough To help protect www.pegasusgroup.co.uk your privacy, … Pegasus Group is the trading name of Pegasus Planning Group Ltd (07277000) registered in To help protect To help protect To help protect your privacy, your privacy, your privacy, England and Wales. Microsoft Office Microsoft Office Microsoft Office prevented prevented prevented This email and any associated files, is intended for the exclusive use of the addressee only. automatic automatic automatic download of this download of this download of this If you are not the intended recipient you should not use the contents nor disclose them to any picture from the picture from the picture from the Internet. Internet. Internet. https://i.imgur.co https://i.imgur.co https://i.imgur.co other person. m/ZuAcceY.jpg m/iHET88g.jpg m/SuR3NpN.jpg If you have received this message in error please notify us immediately. We have updated our Privacy Statement in line with the GDPR; please click here to view it. Please consider the environment before printing this email message. To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. https://i.imgur.com/OZh85Hx.jpg 1 Ref P18-2371.3/HH 21st October 2019 Adam Hill The Planning Inspectorate Room 3C ~ sent by email only ~ Temple Quay House 2 The Square Bristol BS1 6PN Dear Mr Hill, Objection to appeals at the Malmesbury Estate – Council Application ref. 182327 and 182524 - Appeal references APP/X0360/W/19/3224323 and APP/X0360/W/19/3224329 I submit this letter on behalf of Remenham Parish Council, objecting to the two proposed planning appeals, ref. APP/X0360/W/19/3224323 and APP/X0360/W/19/3224329 at the Malmesbury Estate, Remenham Hill, Henley. The two proposals subject to these appeals are for the following developments: • APP/X0360/W/19/3224323 - Full planning application for the proposed erection of grooms accommodation with a players gym following the demolition of existing outbuilding. • APP/X0360/W/19/3224329 - Full planning permission for the erection of a stable (consisting of 24 boxes, tack room, feed room and storage) with outdoor arena. It should be noted that the Council’s description of development for application 182524 is incorrect. The proposal is for an arena not an area. Pegasus Group The Columbia Centre | Station Road | Bracknell | RG12 1LP T 01344 207777 | W www.pegasuspg.co.uk Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester | Peterborough PLANNING | DESIGN | ENVIRONMENT | ECONOMICS | HERITAGE Both Statements of Case (SoC) have been received and in the absence of full proofs of evidence, limited justification for the appeals has been put forward by the appellants. However, the information contained within the SoC have been considered and we wish to provide a commentary on them as follows. Please note that this letter should be read in conjunction with our original objection letter to the planning applications, appended to this letter for convenience. Inappropriate development and very special circumstances The Council has found that both proposals are contrary to Green Belt policy and as such refused both applications on this ground. Green Belt policy is set out in the NPPF and applies to all designated Green Belts in the Country. Inappropriate development within the Green Belt is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. Paragraph 145 of the NPPF sets out a number of exceptions where new buildings may be permissible. These include a) buildings for agriculture and forestry, b) for the provision of appropriate facilities for outdoor sport, recreation, cemeteries, and allotments, c) the extension or alteration of a building, d) the replacement of a building, e) limited infilling in villages, f) limited affordable housing for local community needs or g) limited infilling or the partial or complete redevelopment of previously developed land. Each of these exceptions have further limitations attached to them. This appeal warrants consideration against three of the exceptions, these being b, d and g. In the SoC great emphasis is placed upon both developments coming under criterion ‘b’ as appropriate facilities for outdoor sport and recreation. However, justification for why they consider this is due to come forward in the Proof of Evidence, and therefore it is not possible to comment in detail on this. Instead the SoC contains a number of very subjective claims that the development is merely acceptable development in this location without any policy justification for that consideration. There must be some degree of consideration to the scale and location of the proposed developments and the sudden requirement for such an intensification of the use. Firstly, exception ‘b’ states that the provision of “appropriate” facilities in connection with the existing use of land for outdoor sport is deemed to be acceptable. It is considered helpful at this point to clarify what type of outdoor sport currently exists at the site. The polo facility was consented in 2016, with a condition requiring that it remains as a private Page | 2 facility to be used by the occupiers and guests of Park Place only and should not be used as a private club. The question over whether there is a requirement for 10 grooms to live onsite in order to serve a facility for the occupiers and guests of Park Place will clearly need to be carefully considered by the Inspector. It cannot be appropriate that all staff who assist in the running of the facility must reside on site, and this is acknowledged by the Appellants themselves when referring to other grooms remaining off site. It is clearly not necessary for the existing authorised use of the site, given that the facility has operated without grooms accommodation to date. Such a desired provision might however be expected of a growing private club, and it is strongly considered that is how the current site has, and is intended to, operate by the Appellant. It is noted within the SoC for appeal A that the polo team that currently train at the facility have progressed through the ranks quickly and now wish to compete at a higher level (paragraph 2.7) implying a change in circumstances from the original polo pitch application. However, paragraph 5.3 states that “the appeal proposal has absolutely nothing to do with changing the lawful status of the permitted use or intensifying the use in anyway.” Furthermore, paragraph 2.8 of the SoC for appeal b states that “a consequence of the success of the polo team resulting in the number of horses needing to be stabled in association with the adjacent polo facility increasing beyond the originally envisaged capacity.” [my emphasis]. It is considered that there is some disparity between these statements and certainly implies that the additionally proposed facilities subject to this appeal, will indeed, increase the intensity of the use beyond that of the authorised consent. Whilst recognising that there would be a connection between any groom and the location i.e. it’s their place of work, this should not imply that it is appropriate, or there is any requirement, to live on site in this instance. If similar logic were applied to other sporting facilities, it would imply mass accommodation could be provided in Green Belt locations across the country due to staff being connected with such facilities. This is clearly not the intention of national or local policy guidance relating to the Green Belt. The SoC for appeal A sets out that the site employs 15 grooms on a seasonal basis and the appeal proposal seeks to provide for 10 on site bed spaces for grooms. It does not, however, confirm why 5 grooms are able to reside off site whilst the other 10 need to reside on site. If the requirement is for the welfare and security of the horses, then accommodation for one groom to stay overnight may be considered to be appropriate. However, if that really is the requirement then the accommodation should be located Page | 3 adjacent to where the horses are, and not over 600 metres away as currently proposed. Further details are due to come forward from the appellant on this matter in their statement of case, however this has not been justified to date. Appropriate facilities for outdoor sport within the Green Belt should relate to facilities that are necessary to ensure the functionality of the facility in order to allow the sport to take place. Similarly, the suggestion that a gym is an appropriate facility on site, simply because it is something that might be used by some of the Polo players, is not accepted.
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