Planning, Design & Access Statement

PLANNING, DESIGN & ACCESS STATEMENT

January 2014

Redevelopment of sawmill to form new Brewery and Winery facility

Land at Charmans Farm, Beggars Lane, Westerham, TN16 1QP

Charmans Farm

PLANNING, DESIGN AND ACCESS STATEMENT 1.INTRODUCTION

Contents Introduction This Planning, Design and Access Statement is prepared in support of a proposal to reuse previously 1. Introduction developed land forming part of the Squerryes Estate, at Charmans Farm, New Beggars Lane, Westerham. The proposal seeks to redevelop the existing sawmill building and its curtilage at Charmans Farm to provide 2. Squerryes Estate facilities to accommodate local businesses, namely Westerham Brewery and Squerryes Estate’s wine enterprise.

3. Site Description Westerham Brewery has been established for 10 years at Grange Farm in Crockham Hill. Relocating to Charmans Farm will reaffirm long-term links with Westerham, a town with a history of brewing, providing a 4. Planning History bespoke facility which would be suitable for modern brewing in a sustainable new building. Westerham Brewery has been working closely with Squerryes Estate to support the move to Charmans Farm, subject to 5. Pre-application work planning permission.

6. Design - Use Squerryes planted their Estate vineyards in 2006 and has been supplying Chapel Down Winery with fruit since 2008. Wine made by Chapel Down from Squerryes fruit has already been recognised with an 7. Design - Layout international award. In 2010 Squerryes processed the first Estate reserve to be sold under the Squerryes label near Eastbourne. This will be released later this year. Squerryes hopes that Westerham will be 8. Design - Amount & Scale established as a ‘grand cru’ area within the South East of England for the production of sparkling wine, and the Estate has planted over 40 acres of vineyards. The new facility at Charmans Farm will support wine 9. Design - Appearance production locally. The Estate plans to take wine production a stage further by establishing storage, labelling, packaging and marketing facilities at Charmans Farm. 10. Access Vines have been ordered by Squerryes to plant a further vineyard in May 2014 on an outcrop of chalk 11. Parking immediately adjacent to Charmans Farm.

12. Environment Westerham Brewery has selected Charmans Farm as the preferred site for a permanent new facility. The complimentary nature of the uses makes sharing a premises highly beneficial in business terms, helping two 13. Planning Policy Appraisal local businesses to stay local, thus contributing to the local economy.

14. Very Special Circumstances The proposal for the site to be mixed use will allow the brewery and winery to be flexible with space requirements, depending on fluctuating need for processing and storage. 15. Summary This statement provides information on the background to the site, planning policy at a national, and local 16. Appendix I level and an assessment and justification for the proposal. The statement has been prepared in full accordance with Government guidance, including DCLG Guidance on information requirements and validation for planning applications.

Charmans Farm 2

PLANNING, DESIGN AND ACCESS STATEMENT 2. SQUERRYES ESTATE

Squerryes Vineyards.

The M25 Motoway.

The red star marks the application site.

The town of Westerham.

The map on the left shows the land owned by the Squerryes Estate. The key above shows the owership status of the land. It is noteworthy that Westerham is centrally located in the heart of the Squerryes Estate.

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PLANNING, DESIGN AND ACCESS STATEMENT 3. SITE DESCRIPTION

Site Description

The application site lies 200m south of the M25 motorway. A shrub and tree screen to the north provides a natural buffer between the site and the M25. The town of Westerham lies approximately 0.5km to the west, and the village of Brasted is approximately 1.5km east. To the south there are fields, a golf course and scattered development.

To the north of the site a line of trees marks the former Westerham Valley line railway. This line ran from Dunton Green to Westerham via Brasted, with service ending in 1961. A small watercourse runs down the east of the site, entering from the north east corner and exiting from the south east. There is a pond to the north of the site which is often overgrown with vegetation.

The site is accessed from New Beggars Lane. The same access also serves the buildings to the east of the site, which consist of offices within a converted barn, an Oast house, and the Grade ll listed Charmans Farmhouse.

Just at the entrance to the site off Beggars Lane is a Public Footpath. The footpath runs from this point north over a bridge over the M25 to Force Green.

Approximately 1.2km from the site there are bus stops along Westerham Road, served by the 315 bus. The 315 bus runs Monday-Friday, connecting the site with Westerham, Sevenoaks and Tunbridge Wells. M25

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PLANNING, DESIGN AND ACCESS STATEMENT 3. SITE DESCRIPTION

M25

Former Railway Line Pond/watercourse

Barn converted Public Footpath Storage/Parking Area to offices Ancillary Buildings

Application Site

Charmans Farmhouse

Beggars Lane Oast House

Sawmill Building

Aerial photograph 2003 Charmans Farm 5

PLANNING, DESIGN AND ACCESS STATEMENT 3. SITE DESCRIPTION

The application site is currently vacant, with a low level of informal use. The topography of the site is largely flat, except for bunding along the north of the site. The main existing structure is a redundant Sawmill building in the 2 3 Hard standing being used south east of the site. The Sawmill has a floor area of 612m (including outbuildings) and a volume of 2,964m . The for storage Sawmill is externally clad in a variety of materials, including corrugated metal sheeting, brick and timber. Bunding

A track from Beggars Lane runs along the north of the site to access the area of extensive but unkempt hard standing, currently put to a variety of informal uses, including storage and coach and car parking. The photographs on this page however show how the area of hardstanding was used for timber storage in connection with the sawmill use, an activity that was carried out on the application site until about five years ago. There are also extant planning permissions for three new structures, which fall within the application site boundary. The combined floor area of the unimplemented planning permissions is 312m2, and the combined volume is 1,250m3. If implemented, the site could contain structures with a total floor area of 924m2 (and more if an existing portakabin is included in the calculations).

Adjoining the site are additional buildings which are part of the Squerryes Estate ownership. The buildings are accessed from Beggars Lane, using the track along the northern boundary of the site. They consist of a converted Oast House, grade ll listed Chamans Farmhouse, and offices within a converted barn. The offices adjoin the planning application site and are currently subject to a Lawful Development Certificate application for use as a Farm Shop (Class A1).

Sawmill curtilage being used for storage Former Sawmill including extensions, showing the variety of Chamans Farm buildings: B1 offices on the right, Charmans materials which have been used as cladding Farmhouse in the background

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PLANNING, DESIGN AND ACCESS STATEMENT 4. PLANNING HISTORY

Planning History A number of planning applications were submitted in 1997, including for retrospective works/ variations of conditions. Collectively they sought authorisation for use of an area to the north of

the original sawyard site for staff car parking; retention of hard standing throughout the open The Planning History relating to this site dates back to 1985. Since then there have storage areas of the site; and use of land to the south of the original access drive for timber been numerous planning applications, Enforcement Notices and a planning appeal. storage. The Local Authority refused all of these applications. The effect is a complex layer of inter-related applications, which have collectively led to the evolution of the buildings on site and established the extent of the lawful use of the A number of Enforcement Notices were subsequently served. A planning appeal followed and site as a sawmill. The position is summarised in the notes below, and (sceptically) on the Inspector granted planning permission for use of the northern area of the site as a car park page 9. and creation of a hard standing area throughout the open storage areas of the site. The Inspector also quashed the Enforcement Notice seeking the cessation of timber storage on land Planning History of the application site to the south of the original access drive.

Application SE/85/1278 granted planning permission for change of use and alteration of Planning History of Charmans Farm buildings a dutch barn for sawmill use. This was approved as an alternative to the extension of the barn adjoining the current site combined with new buildings, approved under Planning permission was initially granted in 1985 (SE/85/23) for the change of use and SE/85/23 (detailed opposite), however no planning condition was imposed preventing extension of the barn which adjoins the current application site, as a sawmill with ancillary implementation of the original permission. storage and offices; construction of two buildings and use of land to the north of the original access drive, and to the west of the barn for ancillary purposes. In 1991, planning permission was granted to extend the site area of the timber yard and to extend the sawmill. A planning condition prevented the use of land near the southern It appears that this consent was partially implemented, via the use of the barn, although neither boundary for timber storage purposes, and limited the height of timber storage the extension to the barn, nor the two new buildings were subsequently constructed. elsewhere on the site to either 2 or 3 metres.

Planning application SE/92/0502 contained a planning condition preventing the subsequent In 1992, planning permission was granted for demolition and replacement of the construction of the new buildings granted under SE/85/23. However as mentioned, this sawmill (as well as a western extension to the barn adjoining the current application permission was not implemented. site - SE/92/0502). However, this consent was not implemented.

Section showing existing converted barn on left, and sawmill on right.

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PLANNING, DESIGN AND ACCESS STATEMENT 4. PLANNING HISTORY

One of the various applications submitted in 1997 was granted planning permission - this was for the use of the entirety of the barn adjoining the current application site as office use (Class B1).

Following the enforcement notices and planning appeal which followed the 1997 planning applications, a planning application was submitted to remove the planning condition relating to parking areas around the B1 barn. This was granted permission in light of the Inspector’s authorisation of use of the area to the north for parking.

Application SE/01/02469/FUL (accompanied by application SE/01/02472/LBCALT), determined in May 2002, allowed the Oast House to be converted into office and workshop use, and including ancillary parking. This is the existing lawful use of the converted Oast House.

Approved application SE/11/02031/LDCEX established the lawfulness of the existing extensions to the west and north of the sawmill building.

Extant planning permissions

Lawful Use Certificate SE/11/00983/LDCPR established that application SE/85/23 for the extension and erection of two new structures remains extant.

Pending applications

A Certificate of lawfulness application has been submitted to Sevenoaks District Council seeking approval to use part of the building currently used as offices adjoining the eastern edge of the site as a Class A1 Farm Shop (reference SE/13/03354/LDCPR).

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PLANNING, DESIGN AND ACCESS STATEMENT 4. PLANNING HISTORY

4/12/98 Planning History Map Appeal

Car Park

SE/11/00983/LSCPR Hardstanding (open timber storage)

SE/11/02031/LDCEX SE/85/23

SE/91/1124

SE/85/1278

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PLANNING, DESIGN AND ACCESS STATEMENT 5. PRE-APPLICATION WORK Pre-application work The applicant has been in informal discussions with community representatives As early as summer 2009, the idea of promoting the Westerham Brewery for the broader throughout the development of the proposal to ensure the submitted application was economic benefit of the town was discussed by the Town Partnership and referenced in their subject to appropriate publicity and debate. Feedback received has helped guide the December 2009 Action Plan. Since then, pre-application work has been undertaken in order to development. As the proposals became more advanced, and following Local Authority develop a proposal that is both operationally effective for the purposes of the businesses and pre-application advice and feedback from consultants, the applicant invited the local community to an informal exhibition with drawings of the proposals and information on supportable in planning terms. The process involved commissioning reports from external the brewing and winemaking processes which are proposed, in order to receive their consultants, seeking formal pre-application advice from Sevenoaks District Council, and arranging thoughts. This took place on the evening of Tuesday 3rd December. Feedback from a public exhibition to engage with the community. the public exhibition was provided on 63 feedback forms, most of which were complet- ed by Westerham residents. The majority “strongly agreed” that: Survey reports were undertaken by external consultants to ascertain whether the development envisaged was an appropriate form of development on the site. This application is accompanied * They found the exhibition helpful and informative by a Flood Risk Assessment; Ecological Appraisal; Transport Statement; and Phase l Geo- * The relocation of the Westerham Brewery and the new Squerryes winery is positive for Westerham Environmental Assessment. The Phase l Geo-Environmental Assessment recommends that a * Charmans Farm is an appropriate location for the Winery and Brewery Phase ll survey should be carried out prior to development to establish the potential effect of * The proposal benefits the retail and tourism offer in central Westerham previous uses. The Soil Contamination Officer at Sevenoaks District Council’s Environment Health Department has advised that a planning condition should be imposed requiring a Phase II A persistent theme to emerge from the local consultees was the strong desire for the survey to be carried out prior to the commencement of the development. The three other reports new facility to be a place that would be accessible for local residents to visit to see the establish that the proposal is a suitable form of development for the application site. process underway and to be able to buy the product. Many felt that the existing brewery was too remote. Formal pre-application advice from Sevenoaks District Council was sought. A copy of the advice Of those who filled in the feedback forms, there was just one who “disagreed” that the is appended to this document. The Planning Department advised that the application should proposal would be of benefit to Westerham. The remainder of those who did not tick explain the contribution of the businesses locally together with the economic, social and “strongly agree” for all the questions instead ticked “agree” to 1 or more question. sustainability benefits of relocating to Charmans Farm. Comments from Westerham residents included: This application submission demonstrates the merits of locating the proposal at Charmans Farm. “A positive development for Westerham and the brewery” Kent Country Council Highways Development Control were consulted by Sevenoaks District Council during pre-application advice and by the applicant’s highways consultant when preparing “Excellent opportunity to grow business within Westerham” the Transport Statement. In response to Sevenoaks District Council, Kent County Council Highways Development Control Officer stated: “This provides an excellent opportunity for more employment in Westerham as well as increasing the popularity of the town for tourists” “In principle, the site and access has the potential to accommodate a proposal of this nature subject to the projected traffic flows not adversely impacting on the local highway network in Comments from those who live outside of Westerham included: respect of safety or capacity” “This will enhance the offer that Westerham gives at the moment” The Transport statement, which was informed by both the written pre-application advice and data (Westerham Business Owner) obtain from Kent County Council, concluded that: “We strongly support the proposed new location as the plans to expand the business “In the context of the guidelines within para. 32 of the NPPF it is considered that there are no are better suited to Charmans Farm in Westerham & feel that the increase in business residual cumulative impacts in terms of highway safety or the operational capacity of the and visitor attraction will enhance the profile of Westerham and bring new business to surrounding transport network and therefore planning permission should not be withheld on existing retail businesses.” transport grounds” Charmans Farm 10

PLANNING, DESIGN AND ACCESS STATEMENT 6. DESIGN - USE

Design - Use The application proposal is for a single new building, to be used jointly by the Westerham Brew- The proposed use by Squerryes Estate is technically speaking part of an agricultural use – ery for the production of beer, and by the Squerryes Estate for production of wine from grapes namely the growing of grapes for wine production. Wine making facilities have been held in grown on the slopes of the Downs nearby. law to constitute agricultural activity (the lead case being Millington v Secretary of State). Thus, an independent building to accommodate the facilities sought for wine making, Both these activities are already established as commercial enterprises within Sevenoaks Dis- could be established on the adjacent agricultural land under Permitted Development. Howev- trict. The Westerham Brewery has been operating in its present form for some 10 years at er, the Estate would prefer to keep the activities within the Charmans Farm site to help pre- Crockham Hill, and Squerryes Estate have been producing grapes for sparkling wine since about serve the openness of the Green Belt. 2006, while the production has been undertaken at Chapel Down, Tenterden and Henners Vine- yard near Eastbourne under the Squerryes label. The application proposes to bring together The proposed building will therefore have characteristics of both general industrial (B2) and these activities in a single building close to Westerham which is the long-term home of the brew- agricultural use. In essence what is sought is consent for a mixed use building, as it is possi- ery (it is where its predecessor brewery was previously established and where the water or liquor ble that the precise area used for each of the activities may change, subject to the require- for brewing is found) and sits at the heart of the Squerryes Estate. ments of the businesses concerned. Thus, in planning terms, the proposal is a sui generis use, being a mixed use for Class B2 and for agriculture. This brings advantages to the Local Brewing is regarded as an industrial process and would normally fall to be considered as a Class Planning Authority in terms of control for future use of the buildings, as planning permission B2 Use. As such, it will be regarded as the same use class as the Sawmill which it is proposed will almost certainly be required for any alternative use of the building other than that pro- to replace. Thus, there would be no change of use if the proposal was to make use of the exist- posed in the application, by virtue of the sui generis nature of the mixed use. This ought to ing sawmill building. However, for production at the scale already established at Crockham Hill, provide comfort to the Local Planning Authority that the applicant will not be in a position to the premises need to be capable of accommodating the necessary plant and machinery (in par- develop and use the buildings for other industrial purposes without the Planning Authority’s ticular, the tanks or coppers as they are known) and a clean working environment with a control- formal approval. lable temperature is required. For these reasons, the existing sawmill building is completely un- suitable. While breweries can be established within more modern industrial buildings with a clear span, the most efficient way of delivering a new brewery is in a bespoke facility purpose built to accommodate the necessary equipment. This is precisely what is planned at Charmans Farm.

Proposed brewery/winery Existing converted barn Blue line showing existing sawmill

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PLANNING, DESIGN AND ACCESS STATEMENT 6. DESIGN - USE

The majority of the building by area will be required by the brewing activity which is more extensive and involves heavier equipment. While it is technically possible for brewing activities to require an Environmental Statement to be prepared, the scale of the Westerham Brewery is not such that a formal Environmental Impact Assessment will be required. The Westerham Brewery is not a major beer producer and indeed the market trend in beer production is towards the re- establishment of a number of smaller, local breweries, reflecting how brewing has come full cir- cle. Local brewing was very much the norm in the early part of the 20th Century until a small number of very large breweries became established in the second half of the century and changed the face of the industry, with many adverse consequences. The return to small-scale production is widely regarded as beneficial both for the product and the consumer.

While brewing can produce odours at certain points in the process, Sevenoaks District Council has not requested a formal odour assessment. This reflects the location of the site, which is removed from residential and commercial properties other than those that form part of the Squer- ryes Estate.

The application site is no longer used for woodcutting and storage and has not been so used for some five years. There is a low level of informal use at present. The highways assessment submitted with this application examines three land use scenarios. Firstly, the vehicle movements Proposed Vineyards/ that might be generated by the current buildings on the site in their existing lawful use. Secondly, Hop Garden the potential additional traffic that could be generated by the implementation of the extant permissions for additional sawmill buildings. Finally, these are compared with the buildings in their proposed use based on survey evidence and a review of the operations in particular at the existing brewery at Crockham Hill. The highways report finds that the proposed use is likely to generate less traffic than the existing buildings in their present lawful use, and significantly less than would be the case if the extant planning permissions were implemented. Key plan of the application site, with section A(2) below. While the proposed application is for production facilities, it is common place for tours of the facilities to be arranged and such is the case at the existing Westerham Brewery. The potential for Proposed brewery/winery traffic movements associated with such events has been indicated within the Transport State- ment. Blue line

showing Both the brewery and winery will include ancillary retail sales to the public. These are an im- existing portant part of the response to the public consultation. Both Westerham and Squerryes wish to establish a facility here that will be accessible and welcoming and one that will be attractive to Sawmill visitors.

Screened soil from bund to be used to fill proposed rear yard area. Charmans Farm 12

PLANNING, DESIGN AND ACCESS STATEMENT 7. DESIGN - LAYOUT

Design - Layout

The location of the proposed building has been determined by the natural features of the site. The winery element of the proposed building, shaded in blue below, is set over two floors and The watercourse prevents the building from being located further east in closer proximity to the consists of a lobby, WCs, and areas for labelling, storing, tasting and selling wine. Rear ac- existing buildings. The building is proposed to be located in the same part of the site as the cess for deliveries is proposed. existing sawmill building. Externally, an element of open storage (principally of empty casks) will be required. This is Deliveries to the brewery will be made to the south and west of the building, and the area to the proposed in a well screened location to the rear of the building. north will be occupied by car parking and landscaping. To the south site of the building will be storage space for waste and recycling.

Internally, the majority of the building will be used for the brewing process. The brewing equipment which is needed to ensure the business can be run efficiently from a single building means there must be adequate floorspace, which this bespoke building provides. This includes equipment such as the storage vessels, some of which reach 5.30 metres, fermentation vessels, and a cask store. There will also be a ground floor brewery office and reception. As indicated below by the red shading, the brewery element of the building also includes first floor mezzanine storage. Mezzanine Storage

Cask store Storage vessels Fermentation vessels Winery

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PLANNING, DESIGN AND ACCESS STATEMENT 8. DESIGN - AMOUNT & SCALE

Design - Amount & Scale

The application is for a single replacement building with associated landscaping and parking. The Brewing production will be 24 hours a day Monday—Friday, and 7am – 7pm on Saturdays. building measures 42m by 18m. The height to the eaves is 6 metres, and the ridge height is 24 hour monitoring will be in place at all times throughout the week. Commercial vehicle 6.945 metres. The building needs to be of this height to accommodate the brewing vessels. movements will take place between 6am and 6pm Monday—Friday. It is anticipated that The total footprint of the building is 756m2. In addition, mezzanine space is proposed across tours of the production facilities would take place Monday-Saturday, with specific timings de- those parts of the building which are not to be occupied by brewery vessels—a total area of pendant on licencing. On Sundays the sales areas will be open between 10am and 5pm, and 1195m2. tours may also be available. Cask store with mezzanine storage over

Roof Plan Section showing typical storage vessels. The larger vessels (5300mm high cold liquor tanks) require additional headroom for maintenance.

Cross section of proposed building Charmans Farm 14

PLANNING, DESIGN AND ACCESS STATEMENT 9. DESIGN - APPEARANCE

Design - Appearance The roof of the proposed building would be formed of Marley ‘Eternit’ fibre cement sheet roofing colour grey or green to be agreed with Sevenoaks District Council. The roof will incorporate flush polycarbonate sheet rooflights.

Proposed Eternit sheet roofing with sheet rooflights.

The walls will have an 900mm high base con- sisting of four courses of Forticrete Ashlar Ma- sonry in colour ‘Buff’ with quoin blocks. The block size will be 440 by 215 by 100 thick laid in stretcher bond.

Proposed Forticrete Ashlar Masonry base.

Above the base, the remainder of the building will be clad in oak weatherboarding. This will consist of 200 by 20/15mm tapered boards laid to a 175mm gauge. Doors measuring [insert] will located on the south elevation to provide vehicle access. These will be clad entirely in oak boarding for a uniform appearance. The Estate is currently investigating the feasibility of using local oak planted at Westerham Wood (using local contractors) for Above: Part proposed elevation this purpose. showing Masonry base and oak clad walls. Oak weatherboarding proposed to clad brewery/winery

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PLANNING, DESIGN AND ACCESS STATEMENT 9. DESIGN - APPEARANCE

Doors for pedestrian access on the east and north elevation which will be framed in oak. The windows on the east, north and south elevations will also be framed in oak.

East elevation pedestrian doors and windows. 3245mm marks the height of the first West elevation showing delivery doors to Brewery. floor winery element.

Brewery delivery Winery delivery door door

South elevation showing delivery doors, and windows to wine store.

Winery Brewery

North elevation showing pedestrian doors, and windows to brewery element. Charmans Farm 16

PLANNING, DESIGN AND ACCESS STATEMENT 10. ACCESS

Access The site will be accessed from Beggars Lane. As shown on page 18, the existing road along the northern edge of the site will provide access to the parking area provided for staff and visitors. The image on this page shows the access path of the deliveries to the new building.

In support of the application, the applicant has commissioned highways consultant Milestone to undertake an assessment of transport implications. Milestone has undertaken previous surveys of vehicle movements of the existing brewery at Crockham Hill. The company has also considered the likely traffic generation from the site in its existing lawful use. In addition to the Transport Assess- ment which concludes that the proposed use will then generate less vehicle movements than the site in its existing lawful use, the assessment has also considered safety at the site access (including junction visibility) as well as the movements of goods vehicles within the site.

The report confirms that the acceptability of the proposal in highways terms.

Delivery access: The image on the right shows a swept path analysis of a maximum size 16.5m articulated vehicle entering the site from Beg- gars Lane and turning (blue line), reversing along the south of the building to delivery doors (purple line), then exiting the site for- wards.

Vineyard planting

Beggars Lane Charmans Farm

Visibility Splay Drawing

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PLANNING, DESIGN AND ACCESS STATEMENT 11. PARKING

Parking The area of existing hardstanding is proposed to be used for car parking, as shown in the plan below. This will be resurfaced with a permeable surface, as advised in the Flood Risk Assessment. Kent County Council Vehicle Parking Standards (July 2006) states that for B2 use development over 200m2, 1 car parking space per 50m2 of development is recommended, and 1 goods vehicle space per 200m2. The guidance notes accompanying these figures states “Adequate facilities should be provided to enable delivery vehicles to park and manoeuvre clear of the public highway”. The site proposes 44 car parking spaces and 4 LGV spaces. This equates to 1 car parking space per 27m2 and 1 good vehicle space per 299m2. The parking spaces are required to support the brewery and winery operations but also to accommodate visitors to the premises on organised tours and those wishing to visit the brewery/winery shop.

Surrounding the parking area across the remainder of the site, the existing landscaping will be enhanced, as detailed on page 19.

Access: Blue dashed line showing access for staff and visitors to parking from Beggars Lane.

Pedestrian footpath into the site.

Four brewery delivery van parking spaces

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PLANNING, DESIGN AND ACCESS STATEMENT 12. ENVIRONMENT

Environment Geo Environmental Assessment

Squerryes Estate is an important landholding in a sensitive area in the countryside. The Warde A Geo Environmental Assessment was carried out by Land Science on behalf of the appli- family are custodians of an extensive area straddling the M25 motorway and take their environ- cant. This reviewed historical mapping and local archive information as well as information on soil mental responsibilities very seriously. chemistry. It was also informed by a site visit.

Ecology Various factors were assessed in relation to potential contamination risk and additional survey work was recommended. Discussions with Sevenoaks District Council indicated that such follow An Ecological Survey has been undertaken by Lizard Landscape Design. Preliminary assess- up work could be dealt with by planning condition. ment identified potential ecological habitats. The potential was regarded as “negligible” overall. Nesting house sparrows were found under the barn outside the application site. Landscaping

The existing unused sawmill building was investigated for potential barn owl and bat habitat, The application site while presently subject to extensive human influence, nevertheless has poten- given that this building is proposed to be demolished. An assessment was undertaken in Au- tial to incorporate enhancements through new additional native planting. The recommendations of gust 2013. The landscape half a kilometre to the south was considered to provide excellent the ecologist have been adopted in the proposal following a mix of plants for the landscaped areas potential but there was no direct cover around the buildings proposed to be demolished. The indicated on the block plan. fabric and construction of the existing buildings is not particularly suitable for bats and there is no evidence of bat droppings. In addition, the potential for barn owls does not represent an A detailed landscaping scheme is expected to be the subject and requirement of suitable planning ecological constraint. conditions.

The survey also considered existing herbaceous site coverage and considered that there was very little suitable reptile habitat. An existing pond to the north west of the site at the boundary Dog Wood – Cornus alba Field Maple – Acer campestre was assessed as “extremely suboptimal for protected species”. The existing ditch was also considered suboptimal for protected species.

The ecological advice in relation to potential scheme enhancements focused on the use of native tree and shrub species within the soft landscape proposals.

It was also recommended that boxes for bats, owls and nesting birds would be advantageous.

Flood Risk

The Flood Risk Assessment has been carried out by Ambiental Limited. The conclusion is that the risk and impact and flooding at the site is currently low and would remain so following redevelopment. The report notes that the proposal is for the redevelopment of an existing site. As there was some potential for increase in impermeable surface coverage a formal drainage design may be required at detail design stage but it was recommended that the developer ex- plores the usage of sustainable drainage measures such as permeable paving for surface water attenuation. Such proposals are incorporated within the proposed scheme. The conclusion overall was that the proposed development is considered to be suitable for the lifetime of the proposed development.

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PLANNING, DESIGN AND ACCESS STATEMENT 12. ENVIRONMENT

Landscape Impact

In the wider landscape, the building will appear as part of a group of existing buildings. These are Guelder-Rose - Viburnum opulus; well screened from the public footpath which runs from Beggars Lane north of the M25, by the line of trees along the former railway line. To the south, a public footpath crosses east/west running parallel to the M25. There are views towards the group of buildings at Charmans Farm from this footpath with Charmans Farm appearing in long distance views, backed by the tree screening along the former railway line at the M25 beyond and then the North Downs rising as the principal landscape characteristic. There are similar fleeting views from Beggars Lane. However, from the road, the most noticeable visual element in the group are the white cowls of the oast house roun- dels on the adjacent site. The ridge of the barn is also visible, but views towards the existing building from the road are mainly obscured by the hedge and tree boundary along the field boundary adjacent to the road.

Given that the application building replaces an existing building on the same footprint, it would not appear alien or unusual in the landscape. The new building will be marginally higher than the existing by 365mm, but will be formed of appropriate materials and will relate well to the existing development including the neighbouring barn which has an established ridge height of 8.75m metres, compared to the development proposal of just under 7 metres.

Grey Willow – Salix inerea Silver Birch – Betula pendula; Pendunculate Oak - Quercus robur

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PLANNING, DESIGN AND ACCESS STATEMENT 13. PLANNING POLICY APPRAISAL Planning Policy Approach Planning Policy

The site lies within the Metropolitan Green Belt and the Kent Downs Area of Outstanding Nat- Section 38(6) of the Planning Compulsory Purchase Act 2004 states that planning applications ural Beauty. It is understood that there are a host of national and local policies which apply, should be determined in accordance with the Development Plan unless material considerations and restrict development in these locations. indicate otherwise. The Development Plan here includes Sevenoaks District Council’s approved Core Strategy Development Plan Document, and saved Local Plan Policies. It is noteworthy however that the planning history of the site establishes firstly that the existing Lawful Use is already one which would be regarded as “inappropriate” in this location under National Guidance - National Planning Policy Framework national and local policy, and that the site constitutes previously developed land. The National Planning Policy Framework (NPPF) was published In March 2012. It introduced a The National Planning Policy Framework paragraph 89 provides that a limited infilling or partial presumption in favour of sustainable development. There are three dimensions to this, social, eco- or complete redevelopment of previously developed sites (brownfield land) whether redundant nomic and environmental. or in continuing use, “which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it in the existing development” is not an inappro- Sustainable development involves positive improvements to the built and natural environment, priate form of development. However, in pre-application advice, Council officers have indicat- through (inter alia) the replacement of poor design with better design. ed that they regard the proposal to be for the erection of a 'materially larger' replacement and would thus represent inappropriate development. As a result, the Council has invited the ap- One of the main core land-use planning principles in the NPPF is the need to encourage the effec- plicant to seek to demonstrate the very special circumstances which would support the pro- tive use of land by reusing land that has been previously developed (brownfield land), provided that posal. it is not of high environmental value.

There is no dispute that the Local Planning Authority regard this site as a previously devel- In this case, the brownfield site is within a Green Belt. Inappropriate development is harmful to the oped (brownfield) site within the Green Belt, with an existing “inappropriate use”. The appli- Green Belt; the limited infilling or the partial or complete redevelopment of previously developed cant maintains the view that the proposal taken as a whole would not have a greater impact sites (brownfield land), whether redundant or in continuing us, need not be (paragraph 89). on the openness of the Green Belt than the existing use, and that paragraph 89 (final bullet point) of the NPPF should apply. This view is reached in relation to the nature of the existing The proposal is also within an AONB. It is not however a major development (in terms of the scale lawful use. The Council’s pre-application advice has focussed solely on the size of the exist- of the proposal or its likely impact), hence paragraph 116 is not engaged. ing building in relation to the proposed building. It did not consider the impact of the existing lawful use for timber storage on the open area of the application site. This use (as clearly evi- The applicant has engaged in local consultation in evolving their plans. This accords with the ad- denced by the photographs on page 6 of this document) show the very significant impact of vice in paragraph 66. lawful timber storage on the openness of the green belt. In addition, the application proposes the removal of the existing permanent bund. This man made feature has a significant effect in Overall, the proposal can be seen to support a prosperous rural economy through the sustainable restricting open views, particularly from the access to the Charmans Farm buildings. The re- growth and expansion of local rural enterprises. The NPPF is clear that this can be achieved both moval of this bund, and the extinguishment of the lawful right to store timber in the open, are through conversion of existing buildings and well designed new buildings (paragraph 28 – identified significant benefits to the openness of the green belt which ought to lead a decision maker to as one of the two key policy considerations in the pre-application advice letter). In seeking to re- the conclusion that the proposal overall is not inappropriate development in policy terms. tain local employment, the proposal performs an important social role. Environmentally too, there are clear benefits from the redevelopment of the existing unsightly sawmill buildings and their rede- Very much without prejudice to the applicants position in this respect, a case for very special velopment with a bespoke facility formed in appropriate new materials. As such, the three dimen- circumstances is made out in section 13 of this document. sions of sustainable development are all present in the application proposals.

While it has been recommended that the applicant seek to demonstrate why the proposed development is proposed to be located on a site with B2 Use in the Green Belt and not on another site such as one on an Industrial Estate, the NPPF advises local authorities that “a sequential approach should not be applied to applications for small scale rural offices or other small scale rural development” (paragraph 25). Nevertheless, the advantages of the application site are identified in this statement and in the submitted business plan.

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PLANNING, DESIGN AND ACCESS STATEMENT 13. PLANNING POLICY APPRAISAL

Local Policy - Sevenoaks District Local Plan In addition: NPPF Paragraphs 214 & 215 establish the relationship between the National Planning Policy framework and Local Plans/Core Strategies. Older local policies will be given due “Development that supports the maintenance and diversification of the rural economy, including weight according to their degree of consistency with national policy. development for agriculture, forestry, small scale business development and rural tourism pro- jects, and the vitality of local communities will be supported provided it is compatible with policies The Local Plan was adopted in March 2000. Under the Planning & Compulsory Purchase for protecting the Green Belt, the Kent Downs and High Weald Areas of Outstanding Natural Act 2004, a number of policies are saved. The Core Strategy replaced 21 saved Local Beauty conserves and enhances the value and character of the District’s woodland and the land- Plan policies, with the reminder to be replaced by the Allocations and Development Man- scape character of other rural parts of the District and that it takes account of infrastructure re- agement DPD. This was submitted to the Secretary of State for Communities and Local quirements.” Government for examination on 27 November 2013.

Policy EN1 (considered to be partially consistent with the NPPF), requires developments Development in the Green Belt Draft SPD to be compatible with the locality in terms of scale, height, density and site coverage, as well as design and the use of materials and landscaping. The scheme should not ad- A draft SPD published in February 2013 concerning development in the Green Belt. However, versely impact on privacy and amenity and should ensure a satisfactory environment for this will not be adopted unless and until the Allocations and Development Management Plan has future occupants. been found sound and is adopted, so it can be afforded very little or no weight at this stage.

Policy VP1 states that parking provision in new development should accord with the parking standards set out by Kent County Council. Local planning authorities should take the accessibility of the development, the type, mix and use of development and the availability of and opportunities for public transport into account.

Local Plan Green Belt policies are largely superseded. Policy EN7 dealing with Special Landscape Areas is replaced by Core Strategy Policy LO8.

Local Policy - Sevenoaks District Core Strategy Development Plan Document

The Sevenoaks District Core Strategy (SDCS) was adopted in February 2011.

Policy LO1 sets out a priority for protecting the rural character of the District including the Green Belt, High Weald and Kent Downs Area of Outstanding Natural Beauty. Pre- application advice identified Policy LO8 as the second key policy consideration. Elevation showing proposed building on the right, and Policy LO8 Provides that: existing converted barn on left

“The countryside will be conserved and the distinctive features that contribute to the special character of its landscape and its biodiversity will be protected and enhanced where possible. The distinctive character of the Kent Downs and High Weald Areas of Outstand- ing Natural Beauty and their settings, will be conserved and enhanced.”

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PLANNING, DESIGN AND ACCESS STATEMENT 14. VERY SPECIAL CIRCUMSTANCES

Very Special Circumstances? In assessing the impact of the proposal in the openness of the Green Belt, we have had regard to the current condition of the site and its appearance, as well as the scale of existing buildings, and The District Council Planning Officers have indicated in response to pre-application consulta- buildings which may be erected under the planning permission that remains extant, as confirmed tion that they do not consider that the proposal constitutes appropriate development within the by the 2012 Certificate of Lawfulness of Proposed Use or Development. This is not a case where Green Belt. a single building is proposed to be replaced by a large number of smaller buildings. In this proposal, there is a single building which is proposed to be replaced by another single building. The applicant contests this, and draws attention to the National Planning Policy Framework, which provides a clear basis for assessing the proposal and for concluding that it is appropri- The sawmill has a footprint of 612 m2 and a volume of 2,964 m3. The proposed brewery/winery ate Green Belt development. The case in this respect is set out in the prelude to the Planning building has a footprint of 756 m2 and a volume of 4,893m3. That represents an additional foot- Policy section above. However, given that the position of the Officers of the Local Planning print of 144 m2 and additional volume of 1,929 m3. As noted above, the winery element could be Authority differs in this respect, the applicant has decided to submit for consideration, on a provided as agricultural permitted development in a building of up to 465 m2 and 5,580 m3. In- without prejudice basis, a case for “Very Special Circumstances”. stead, the applicant has chosen to redevelop a brownfield site in order to reduce the overall impact on green belt openness. The National Planning Policy Framework establishes the range of developments that are regarded as appropriate in Green Belt locations and those types of development which are re- There is a lawful use for timber storage on the extensive hardstanding of the application site which garded as inappropriate. Inappropriate development is harmful by definition to the Green Belt benefits from express planning approval. This use (as clearly evidenced by the photographs on and should not be approved other than in very special circumstances (Paragraph 87). Sub- page 6 of this document) shows the very significant impact of lawful timber storage on the open- stantial weight will be given to any harm to the Green Belt, and for Local Authorities to approve ness of the Green Belt. In addition, the application proposes the removal of the existing perma- inappropriate development, the potential harm to the Green Belt by reason of inappropriate- nent bund. This man made feature has a significant effect in restricting open views. The removal ness, and any other harm, must be clearly outweighed by other considerations (Paragraph of this bund, and the extinguishment of the lawful right to store timber in the open, are significant 88). benefits to the openness of the Green Belt, which ought to be assessed against the additional footprint and volume of the new building. Needless to say the removal of the bund alone would result Green Belt Policy in this respect has been constant through various iterations of policy at na- in an overall reduction in footprint and volume many times greater than the additional footprint and tional level and it is noteworthy how the concept has been applied in the Courts. As Lord Don- volume of the proposed building. aldson M.R. in Pehrsson [1991] pointed out, and as repeated in Vision Engineering [1991], it is not only the existence of the planning harm by reason of inappropriateness that has to be tak- In addition, planning permission exists for additional sawmill buildings of some 312 m2/1,250 en into account, but it is also its extent and weight. If it were so slight as to be insignificant, m3. Furthermore, a portacabin structure of about 30 m2 (volume approximately 75 m3) on the site then it might readily outweighed by the counter balancing benefits. Lord Donaldson put it in would also be removed as part of the proposals. The floorspace and volume of this structure has these terms “this is a balancing exercise, since the extent of the harm to Green Belt interests not been taken into account in the figures presented above. and the extent of the advantage to be derived from the development can both vary from case to case … the decision-taker has to go on to express a view on the weight of the damage Should planning permission be granted and implemented for the proposed development, these which would be done to the Green Belt if permission were granted and the weight or lack of permissions, together with the right to store timber on the hardstanding, would be automatically weight which he attached to the countervailing considerations.”. extinguished.

Thus, in order to apply the VSC test, one is drawn into examining the level of harm to the Therefore, given the provisions of paragraph 89 (final bullet point) which provides for the infilling or Green Belt arising from the inappropriate development. partial or complete redevelopment of previously developed sites in the Green Belt, the extent to which the application proposals cause harm to the openness of the Green Belt must on any analy- In this case, the formal pre-application advice was that the proposed development for “a sis, be very limited indeed. The pre-application advice simply compares the existing building with 'materially larger’ replacement building would not comply with any of the exceptions set out at the proposed building and does not assess the effect of the proposal more widely. paragraph 89 of the NPPF and would thus represent inappropriate development”. No issue taken with the proposed uses and their impact, which is not unexpected given that the existing Thus, applying the approach of Lord Donaldson M.R., given that the level of harm to the Green sawmill building is in poor condition and visually unattractive within the AONB. The inferred Belt can only be regarded as slight, then the balancing exercise needs to reflect that. conclusion is that the materially larger building must harm the openness of the Green Belt and therefore fail to meet the policy test in paragraph 89 of the NPPF. The pre-application advice does not suggest that the proposal is likely to arise from the proposal, other than the harm by virtue of inappropriateness. Again, this is relevant to the balancing exercise that the decision-maker must undertake. Charmans Farm 23

PLANNING, DESIGN AND ACCESS STATEMENT 14. VERY SPECIAL CIRCUMSTANCES

What are the Very Special Circumstances? As the cross-sectional drawing on page 10 demonstrates, the tanks that need to be accommodat- ed are up to 5.3m high, and need clearance above that for maintenance access as well as suffi- The applicant advances the following considerations as forming part of a very special circum- cient room to allow them to be replaced. This drives the need for a 6m eaves height and a ridge stances test in support of the proposals: height of just under 7m. The proposed brewery floorspace is the minimum reasonably necessary to support the planned production at Westerham.  The proposal supports the existing Westerham Brewery. The brewery has close links to Westerham. This has important economic and social benefits.  Viticulture is already well-established on Squerryes Estate.

The Westerham Brewery Company is an award winning craft beer producer, presently based at Winemaking is a complimentary albeit agricultural activity which supports a robust rural econo- The National Trust Property at Grange Farm at Cockham Hill. Established locally in 2004, the my. It is an appropriate form of development in the Green Belt. Again, there are important eco- brewery is very keen to maintain its Westerham links, but it has had difficulties in securing accom- nomic and social benefits which arise from a vibrant local rural economy. The Squerryes Estate is modation for its needs at Grange Farm, where it is a tenant of the National Trust. However, an important local employer and the aspiration is to bring all aspects of wine production within the agreement has been reached in principle with the Squerryes Estate for the brewery to be relocat- Estate's boundaries. ed to Charmans Farm, closer to Westerham itself, in association with the Estate’s own plans for wine production. The Estate regards the two uses as complementary and proposes to accommo- As long ago as 2006, the vines of the three sparkling wine grape varieties (Pinot Noir, Pinot Me- date them together at Charmans Farm. neur and Chardonnay) were planted at Squerryes Estate. These were first harvested in 2008 and the grapes were taken by the Chapel Down winery to produce wine under the Chapel Down la- Real ale brewing is a growing market sector, and by its nature, requires suitable space to accom- bel. Indeed, the wine produced that year by Chapel Down won an International award. modate the large brewing vessels needed for beer preparation, as well as areas for bottling, filling casks and storage of both raw materials and product. Good access is also required for regular In 2010 Squerryes entered into a wine contracting arrangement with Henners Winery near East- deliveries and collections. bourne to produce wine under the Squerryes label exclusively from the Squerryes vineyards. The 2010 vintage with Squerryes grapes on lees ready for release next year. There are presently The proposed brewery and winery building will include a modest facility for visitors to view the some 20,000 bottles of sparkling white wine in store – which is about 7,000 from each year since beer and wine making process, this is likely to be of local benefit and interest. 2010 – 2013 and a further 20,000 bottles worth of juice in tank from 2013. Squerryes vineyard has the capacity to produce between 50,000 and 80,000 bottles per annum. The application is supported by a business case prepared by Westerham Brewery, explaining their difficulties at their existing premises and their need to relocate to new premises. At present, Squerryes grapes are still processed by Henners Winery. However Henners Winery has indicated there is pressure on their current labelling and storage system. With growing pro-  The size of the proposed building is governed by the size of the equipment and facilities duction there, and the Estate’s aspiration for a truly self-sufficient product, the Estate wishes to required to successfully operate the brewery and winery. establish its own winery facilities.

Following careful analysis of the business case for a new brewery, the Westerham Brewery has The plan is to utilise existing buildings wherever possible for the early stages of wine- provided a detailed brief for the dimensions of the space required in a new building, to facilitate making. However, the interest from the Westerham Brewery in Charmans Farm brings with it the the production process. A minimum 6 metre clearance height to eaves is needed across five 6 option to relocate wine-making facilities post-grape pressing, and to encompass later stages of metre bays of 18 metre width to give adequate space for the processes. This drives the principal wine production in a shared building at Charmans Farm. floorspace requirement of 540 sqms. In addition, a small area for a brewery office and a tap shop/reception with storage above is also a reasonable requirement. The Estate sees their wine as a local product to Westerham. In the short term the Estate requires a location for storage and labelling (with pressing and bottling at Chapel Down in the interim) with The proposed use is for a specific purpose, namely a brewery and winery facility. A bespoke the ability to encompass further stages of wine production in due course. building is proposed. The level of investment required means that the new building must be emi- nently fit for purpose. Many existing buildings (including the existing sawmill buildings), do not Wine production differs from brewing as the process is highly seasonal, with the pressing of have an appropriate internal configuration to support the brewing process. grapes during the harvest period between September and October (a 6-week window) within which the fruit will be picked and pressed within a 2-3 week period. Subsequent phases of wine production are also time dependent, but the rest of the time bottled wine is undergoing maturation in storage. As such, the winery use is a good neighbour for a brewery as there is unlikely to be any regular conflict between the uses. Charmans Farm 24

PLANNING, DESIGN AND ACCESS STATEMENT 14. VERY SPECIAL CIRCUMSTANCES

 The site is previously developed land. Redevelopment will have important environmental The grant of planning permission for the application proposal would legally replace the existing permission resulting in the extinguishment of rights to store timber in the open. The replacement benefits. of this use with a landscaped car park and circulation area would be of considerable benefit and is

part of the “very special circumstances” advanced in support of the proposal. The existing sawmill buildings are utilitarian in appearance and are in poor condition. The build-

ings do not make a positive contribution to the Kent Downs AONB.  The site benefits from a Lawful Development Certificate (LDC) confirming the lawfulness of Demolition of the building and replacement with a modern facility will result in an overall benefit to 2 new buildings on site. These rights will be extinguished. the appearance of the AONB. In a similar way to the manner in which the lawful rights to stack timber on the hardstanding would To help soften the visual impact of the proposed building within the Kent Downs AONB, it is pro- be extinguished, a grant of permission to the build proposal would also bring about a new chapter posed to clad the new building in timber. Indeed, the Estate is currently investing the practicality in the planning history and thereby extinguish extant planning consents for the erection of an ad- of using oak grown locally on the Estate, for this purpose. ditional 312 m2 of additional Class B2 buildings on the application site. These buildings are lean- to type extensions of the existing sawmill building, increasing its bulk. The buildings for which The proposed oak cladding will, particularly when weathered, help the building to meld into the permission exists are utilitarian in appearance. The extinguishment of planning permission is a wider landscape. This will be assisted by the proposed landscape treatment as outlined on the benefit to the scheme in relation to the openness of the Green Belt and the appearance of the proposed Block Plan drawing. AONB and is unusual. It can justifiably be considered as part of the “very special circumstances” case. In terms of siting, the proposed building is on the same broad footprint as the existing building. In part this is driven by the position of the nearby watercourse which makes it impossible to move  The proposal would involve the removal of a large bund along the northern site boundary. the building closer to the existing group, which lie on the opposite side of the ditch, without intro- ducing culverting. The removal of the existing manmade bund which skirts the northern site boundary is also considered part of the “very special circumstances” behind this application. This bund previously func- The proposed building will be read as one of a group of structures within the wider land- tioned to screen the open timber storage area from those accessing the remaining Charmans scape. They are not particularly prominent and indeed existing established screening helps sepa- Farm buildings. The proposal in this respect will benefit the openness of the Green Belt. The rate the site from the wider landscape. This includes the established vegetation along the line of bund has no other broader planning or landscaping function. The site can be satisfactorily land- a former railway, to the north of the site. scaped without the bund, which is a superfluous feature, the removal of which will have wider environmental benefits.  The site has a Lawful B2 General Industrial Use.

Not only is the application site previously developed land. It already enjoys a lawful B2 General Industrial Use. The proposed brewery would fall within the same use class if considered in isola- tion.

Class B2 uses are general industrial uses. However, the proposed use of the site is to be a mixed use (sui generis) which means that further planning permission would be required for the introduction of any future alternative use.

 Planning permission exists for open storage of timber over the extensive hardstanding, Redevelopment will bring environmental and openness benefits.

As the photographs on Page 6 clearly demonstrate, the use of the extensive hardstanding for open storage timber has an adverse effect on the openness of the Green Belt and indeed the visual amenity of the Kent Downs AONB. This was established with the benefit of planning permission. The current large area of hardstanding is featureless, and would benefit from proper hard and soft landscaping treatment.

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PLANNING, DESIGN AND ACCESS STATEMENT 15. SUMMARY

Summary

The applicant firmly believes that the new brewery/winery proposals at are appropriate in green belt terms. This view however is not shared by officers of the Local Planning Authority, who consider that the proposals result in a greater degree of impact on the openness of the green belt that existing development. The applicants have therefore presented a case for very special circumstances, in accordance with national guidance, on a without prejudice basis. The applicant regards the level of any harm to be slight, and has demonstrated that by comparing all relevant aspects of the proposals.

The proposal represents an overall improvement in environmental respects It follows that any alleged harm to openness based on the increase in size of the proposed building in relation to the must be very slight.

The courts have held that regard must be had to the level of any such harm to the green belt, together with any other harm, when applying the very special circumstances test. In this case, as the harm to the green belt can only be very slight, and there is no other identified harm, then the countervailing benefits arising from the scheme, which must clearly outweigh the level of harm to the green belt, must be assessed accordingly. A number of circumstances are put forward for consideration in this instance, namely:

• The proposal has important economic and social benefits, supports the existing Wester- ham Brewery which has close links to Westerham.

• The size of the proposed building is governed by the size of the equipment and facilities required to successfully operate the brewery and winery.

• It will support the well-established viticulture enterprise on Squerryes Estate.

• Redevelopment of this brownfield site will have environmental benefits.

• The site already has a Lawful B2 General Industrial Use.

• The existing planning permission for open storage of timber will be extinguished, bringing environmental and openness benefits.

• The existing planning permission for 2 new buildings will also be extinguished, bringing environmental and openness benefits.

• The proposal would involve the removal of a large and unnecessary man-made bund along the northern site boundary.

The appellant considers that, taken together, these considerations amount to very special circumstances that clearly outweigh any identified harm.

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16. APPENDIX I PLANNING, DESIGN AND ACCESS STATEMENT

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16. APPENDIX I PLANNING, DESIGN AND ACCESS STATEMENT

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