Lewis & Co Planning
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Site at Holy Trinity Church, Blatchington Road, Hove
Planning Statement
Lewis and Co Planning, 2 Port Hall Road, Brighton, BN1 5PD. T: 01273 413700 E: [email protected]
Lewis & Co Planning
town planning consultants
CONTENTS
Page
1.0
Introduction
3
2.0
The Site and Surrounding Area
5
3.0
Background to the Proposals
6
4.0
Planning Policy Considerations
8
-
Principle of Development
8
-
Heritage Impact
12
-
Economic Impact
16
-
Highways Impact
16
-
Ecological Issues
17
-
Sustainability
19
5.0
Conclusions
20
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1.0
INTRODUCTION
1.1
This statement is submitted in respect of the application for planning permission and listed
building consent for the conversion of the Holy Trinity Church into a medical centre for use
by two existing surgeries (The Central Hove Surgery and Sackville Medical Centre). The
two surgeries have both outgrown their existing premises. In the case of the Central Hove
Surgery, its lease on current premises expires in 2015, whilst for the Sackville Medical
Centre, they are holding over on a temporary 3 year arrangement (as their lease has
expired). The two surgeries have been looking at alternative sites for about 8 years, and
the Holy Trinity Church can be seen as a “perfect match” – providing replacement facilities
within the same catchment area as the existing surgeries, and providing a community style
use that is respectful of religious history of the host building.
1.2
1.3
In summary, the following primary matters are included in the application:
-
Conversion of church into medical centre
-
Creation of two additional floor levels within the church
-
Alterations to existing window openings, and creation of new openings.
-
Erection of new pharmacy, in the north west corner of the site
-
Creation of new vehicular access between the Vicarage and Blatchington Road
Officers will note that the change of use from church to medical centres involves two uses
within Class D1 of the Town and Country Planning (Use Classes) Order. Consequently the
change of use from church to medical centre does not constitute development, as
confirmed in the Town and Country Planning Act 1990 (Section 55(2) (f) – where is stated
that development shall not have occurred:
“f)
in the case of buildings or other land which are used for a purpose of any class
specified in an order made by the Secretary of State under this section, the use of
the buildings or other land or, subject to the provisions of the order, of any part of
the buildings or the other land, for any other purpose of the same class.”
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1.4
Similarly, the creation of additional floor levels within the building does not in its own right
require planning permission (only interior floors which create 200m 2 of more of retail
floorspace require planning permission – as confirmed in National Planning Policy
Guidance: Paragraph: 001 Reference ID: 13-001-20140306), though the new floors do
require listed building consent.
1.5
This statement should be read in conjunction with the architect’s drawings and other
supporting documents that make up the application for planning permission and listed
building consent. The submitted documentation shows that:
-
The scheme has been designed to a very high standard, and will provide an excellent
level of service to the local community
-
The scheme takes full account of the listed status of the host building – and results in a
use that preserves the building and the character and appearance of the surrounding
area
-
That the scheme will also result in economic development – with both of the existing
medical practices being able to expand the range of services that they can offer the
community
-
That the travel demand for the new use is not materially different from the “existing”
use as a place of worship.
1.6
Images used in this statement are provided by Deacon and Richardson Architects, unless
otherwise stated.
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2.0
THE SITE AND SURROUNDING AREA
2.1
The site accommodates the vacant Holy Trinity Church, and adjacent Vicarage. The
Church and the Church Walls are both grade II listed structures. The site is located within
the Cliftonville Conservation Area.
2.2
An assessment of the existing structure and its contents is provided in the Scott Ralph
Heritage Statement that accompanies the application (see Sections 1 and 4). A structural
overview has also been provided by Ings Engineering Limited (see letter dated 05
November).
2.3
The site is centrally located, with numerous bus routes passing by the site. The regional
shopping centre (Church Road, Blatchignton Road and George Street) is located to the
south and west, and Hove Station is within easy walking distance. A fuller assessment of
the scheme’s accessibility is provided in the Reeves Transport Planning Statement.
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3.0
BACKGROUND TO THE PROPOSALS
3.1
With regard to the background to the scheme, there are two main matters – the efforts of
the Diocese to find alternative uses for the church, and the efforts of the two medical
practices to find alternative and more suitable premises.
The Church
3.2
The Diocese’s efforts to find alternative uses for the site are set out in Section 2 of the
Scott Ralph Heritage Statement.
3.3
Hyde Housing undertook a public consultation exercise in 2007 for a scheme for the
redevelopment of the site (including demolition of the church) for an affordable housing
scheme. The scheme was not progressed after significant public opposition.
3.4
Brighton and Hove City Council expressed an interest in the site in 2008, but no further
contact was made between the Council and the Diocese after the Council’s initial interest
was registered.
3.5
Following on from the above, discussions and presentations were made with (and to)
Council officers and Members with regard to the conversion of the church in to a medical
(much along the same lines as currently proposed), together with the erection of a new
pharmacy on the south west corner of the site. Whilst the proposals were generally well
received, some concerns were expressed regarding the location of the pharmacy on a
prominent corner (note that for the current application, the pharmacy is no longer proposed
on the south west corner).
3.6
The proposed medical centre use is the only use that has come forwards over a six year
period and which has involved the retention of the church. The proposed scheme will
ensure that the church is preserved, that it still serves the community, and that that it will be
open to the public.
As confirmed in Section 3 of the Heritage Statement, if a suitable
alternative use for the church cannot be found, then the only logical step would be for the
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Diocese to refer the case to the Church Commissioners, which would likely end with the
building’s demolition. The public consultation exercise that related to the earlier proposals
for housing on the site showed the depth of feeling for retaining the church, and the current
proposals are the only reasonable proposals for achieving this aim.
The Medical Practices
3.7
The application, if approved, will facilitate the relocation of two existing medical practices –
The Sackville Medical Centre (in Sackville Road) and the Central Hove Surgery (in Ventor
Villas). Both of these practices are currently housed in out-of-date facilities, and need new
premises to provide for modern standards of care.
3.8
Letters from both Practices are included at Appendices 1 and 2 of this Statement. However
in summary it can be seen that:
-
Both Practices are now effectively in temporary accommodation (with the Sackville
Medical Centre on a rolling 3 years temporary arrancgement, and the Central Hove
Surgery on a lease that expires in 2015).
-
The Practices are significant local employers, retaining GPs, Nurses, Health Care
Assistants, and Administrative staff. Both practices employ 21 people (so 42 in total),
as well as hosting other services such a Community Midwife and Counsellor.
-
The Sackville Medical Centre currently has 11,300 patients, mostly living in the Hove
area, whilst Central Hove Surgery has 5,450 patients.
-
Both practices have an expanding register of patients. However, the Sackville Medical
Centre has recently had to ask the NHS for permission to close its list to new patients,
and the Central Hove Surgery is likely to have to do the same “in the near future”.
-
As well as being restricted with capacity for additional patients, both practices are
hampered in the type and amount of care that they can offer owing to the constraints of
their existing premises.
-
The new premises will enable the Practices to expand their range of services in line
with growing community needs as well as continuing/improving the training services
they offer.
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3.9
Clearly both Practices are very important within the surrounding community. However,
larger sites that are suitable and affordable for community use are few and far between,
and even when available, are not always appropriate owing to the unique relationship
between each Practice and its patients, meaning that a site’s location is of paramount
importance. The Sackville Medical Centre confirms that it has been involved in site
searches for 8 years – looking at projects on Portland Road, Newtown Road, Connaught
Road, the King Alfred Centre and Sackville Trading Estate. The Holy Trinity site represents
the best opportunity for relocation and the provision of modern medical services.
4.0
PLANNING POLICY CONSIDERATIONS
4.1
The main issues to consider in the determination of the applications are:
-
The Principle of Development
-
Heritage Impact
-
Economic Impact
-
Highways Impact
-
Ecological Issues
-
Sustainability Issues
These are considered in greater detail below and overleaf, together with relevant
Development Plan and National Planning Policy Framework references.
The Principle of Development
4.2
As noted in the Introduction, the “change of use” element of the proposals does not need
planning permission – as both “church use” and “medical centres use” fall within the same
“D1” use class. Likewise, planning permission is not needed for the intensification of Class
D1 floor space – as the additional space is created by way of providing additional floors
within the existing building (notwithstanding external changes such as new windows).
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4.3
The new pharmacy does require planning permission, and is in accordance with Local Plan
policy SR1 which relates to the provision of new retail facilities within or on the edge of
existing shopping centres. The scheme’s compliance with this policy (together with relevant
National Planning Policy Considerations) is set out below:
Applications for new retail development within the built-up area and within or on the
edge of an existing defined shopping centre* will be permitted where the proposal:
a. itself, or cumulatively with other or proposed retail developments, will not cause
detriment to the vitality or viability of existing established shopping centres and
parades in Brighton & Hove;
The need for retail impact analysis has altered since the publication of the National
Planning policy Framework – with such analysis only required if the proposed
development is for in excess of 2500m2 of retail floorspace. The proposed pharmacy
provides for c.100m2 of floorspace, and so is clearly below this threshold.
Notwithstanding this, the new surgery, and its register of over 16,000 patients, has the
ability to generate “Linked Trips” to the benefit of nearby shops.
b. is well located with convenient, attractive and safe pedestrian linkages to
existing shopping frontages;
The site is well located, being immediately adjacent to the regional shopping centre.
There are numerous crossing points along Blatchington Road, and there is also a
crossing point (protected by a pedestrian island) on the junction of Goldstone Villas
and Blatchington Road.
Officers will also note that the public entrance to the pharmacy and surgery will be from
Goldstone Villas – which is the nearest access point relative to the boundary of the
Regional Shopping Centres (which is the west side of the Goldstone Villas/Blatchington
Road junction).
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c. is genuinely accessible by a choice of means of transport that enables
convenient access for a maximum number of customers and staff by means
other than the car;
As noted earlier, the site benefits from a highly sustainable location, and is well served
by public transport. Cycle Parking is to be provided on site, and there is a taxi rank
outside.
d. will not result in highway danger, unacceptable traffic congestion or
environmental disturbance;
The Reeves Transport Planning report shows that the scheme is acceptable with
regard to highways. Paragraph 32 of the National Planning Policy Framework states
that planning permission should only be refused on highways grounds when the
cumulative impacts of development are “severe”. This is clearly not the case for the
Holy Trinity site.
e. provides adequate attendant space and facilities for servicing and deliveries;
The site layout plan (drawing 3510.PL.101) shows that servicing can take place from
within the site.
f.
provides facilities for parent and child, the elderly and people with disabilities;
and
The new unit will conform with all Building Regulations requirements with regard to
access. There is ramped access from the two disabled persons parking bays to the
front door of the pharmacy.
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g. provides facilities for the recycling of waste packaging generated by the
proposal and complies with relevant policies in the Waste Local Plan.
Refuse storage is shown on drawing 3510.PL.101.
In addition, applications for new retail development on the edge of existing
established shopping centres will be required to demonstrate, firstly, that there is a
need for the development and, secondly, that no suitable site can be identified within
the existing centre. The development should also be appropriate in scale with the
centre, whether regional, town, district or local, to which it is intended to serve.
Note that since the publication of the National Planning Policy Framework, there is no need
for the applicant to demonstrate need for the development.
With regard to suitable alternative sites, it should be noted that the basic principle of a
pharmacy allied to a medical practice has previously been accepted by the Council – and is
an established feature in many new medical practices. Examples of this can be found at:
Charter Medical Centre, Somerhill Road’ Hove:
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Beaconsfield and Stanford Medical Practices, 175 Preston Road, Brighton:
The pharmacy element of the scheme is essential to the scheme. As the pharmacy use is
functionally related and essential to the main medical centre use, it cannot be separated
from the scheme. As the scheme relates to the re-use of an existing site, there cannot be
any alternative sites within the Regional Centre that would be more appropriate.
4.4
Consequently it can be seen that the principle of development is acceptable with regard to
local and national planning policy.
Heritage Impact
4.5
The scheme’s acceptable Heritage Impact is assessed in Sections 4 and 5 of the Heritage
Statement.
4.6
Brighton and Hove Local Plan policy HE1 allows alterations and extensions to listed
buildings where the proposals would not have any adverse impact on architectural and
historic character of the building. The National Planning Policy Framework advises that
“great weight” should be attached to the conservation of designated heritage assets (the
listed building and the surrounding conservation area). Paragraph 131 of the Framework
states that local planning authorities should take account of the desirability of enhancing
the significance of heritage assets, and putting them to viable uses consistent with their
conservation. Paragraph 134 states that where development leads to “Less than
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substantial harm” to the significance of a designated heritage asset, this harm should be
weighed against the public benefits of the proposals, including securing its optimum use.
4.7
An assessment of the Church’s significance was provided by the Conservation Team in
2007 (when originally asked about demolition):
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4.8
The proposed development, whilst undoubtedly involving a considerable amount of work,
will preserve the architectural and historic character and appearance of the church:
-
The proposed use represents the best way of saving the church (see Section 3 of the
Heritage Statement), in line with paragraphs 131 and 134 of the National Planning
Policy Framework.
-
The proposed works have been sensitively designed, with as minimal intervention as is
possible for securing the community use on the site, in line with paragraph 134 of the
National Planning Policy Framework.
-
Given the above, any perceived harm is “less than substantial” and so needs be
considered against the public benefits of the proposals (paragraph 134 of the NPPF).
The public benefits of the proposals are immense – with the long term futures of two
medical practices secured, and with that the services provided to almost 17,000
patients and the protection of over 40 jobs.
4.9
In the light of the above, it can be seen that the listed building impact of the scheme is
acceptable and therefore in compliance with Local Plan policy HE1.
4.10
With regard to the conservation area (Local Plan policy HE6), the scheme has been
significantly improved since proposals were first shown to the Council in 2012. At that time,
a new pharmacy (with flats above) was proposed on the south west corner of the site,
which may have impacted on views from the west and/or Ventnor Villas – a view point that
was highlighted as being particularly important by the Conservation Team (see second
paragraph of email on previous page of this statement) back in 2007.
4.11
The current proposals show the pharmacy moved back to the north west corner of the site
– adjacent to the single storey building that houses the entrance to public conveniences on
Goldstone Villas. The proposed pharmacy is also single storey in height, and will have a
flint wall that compliments the appearance of the existing listed wall that surrounds the site.
As can be seen in the images provided by the architects (see extracts overleaf), the
proposed development will result in a scheme that compliments that character and
appearance of the conservation area, and preserves the views that have been highlighted
as being particularly important. The scheme therefore complies with policy HE6.
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Economic Impact
4.12
As noted in the letters submitted by the two medical practices (see Appendices 1 and 2 of
this statement), the proposed development will support the current level of staffing (42
jobs), with the added benefit that some part-time positions can become full time positions.
As the Practices continue to expand (and will have the space to expand on the Holy Trinity
campus), then staff levels can increase further.
4.13
Both of the Practices are committed to further training opportunities. For example, the
Sackville Medical Centre is an accredited Training Practice with the KSS Deanery and
hosts medical students, Foundation Year doctors, and Specialist Training Doctors for
Primary Care Training and experience.
4.14
Informal consultations between the architects and the Council’s Economic Development
Team have been made, with the Economic Development Team indicating support for the
scheme, and saying that a financial contribution is extremely unlikely.
4.15
With regard to financial contributions, officers should be aware that the “new building”
element of the scheme amounts to just over 100m2 (i.e the pharmacy and link), which is
considerably below the 500m2 threshold set out in the Council’s Technical Guidance on
Developer Contributions (see table on next page). There is no change of use that requires
planning permission (as both the existing and proposed uses are within Class D1), and the
additional floorspace to be created inside the church building does not require planning
permission (see paragraph 1.4 of this Statement). Consequently we trust that planning
permission can be granted without requiring additional financial burdens on the developer
with regard to developer contributions.
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Extract from Brighton and Hove City Council’s “Guide to Developer Contributions” publication:
Highways Impact
4.16
The scheme’s highways impacts are considered in the Reeves Transport Planning report
that accompanies the application. The report demonstrates that the scheme is acceptable
with regard to Local plan policies TR1 (travel demand) TR7 (safe development), TR14 and
TR18 (car parking and cycle parking).
Ecological Issues
4.17
The application is accompanied by reports from the PJC Consultants with regard to trees,
ecology and bats.
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4.18
With regard to trees, the Arboricultural Impact Assessment shows that four trees will need
to be removed (T11, T12, T13 and T14 – as shown on the Tree Protection Plan at
Appendix 1 of the Assessment), and that in order to mitigate against the loss of these
trees, new planting should be undertaken during the soft landscaping phase of the scheme.
This is a matter than can be controlled by Planning Conditions.
4.19
The Assessment continues by recommending “crown raising” for four other trees (T3, T4,
T6 and T8), and tree protection works for all retained trees.
4.20
As the proposed development retains trees where possible, and provides for replacement
planting for those trees that have to be removed, the scheme accords with Local Plan
policy QD16.
4.21
The PJC Phase 1 habitat survey and bat survey makes the following observations:
-
No evidence of protected species was found.
The presence of protected species
would be “highly unlikely” owing to site conditions and the lack of habitat connectivity.
-
The site has limited ecological value
-
No evidence of bats was found in the church building or bell tower.
-
No evidence of cracks in trees that could indicate the presence of bats
-
The mature trees that surround the site are an important ecological feature.
-
Bird boxes could be erected within the development to increase the number of
breeding opportunities for species such as house sparrows, starlings and swallows.
This can be controlled by condition.
4.22
Consequently it can be seen that there are no ecological concerns that could influence the
development. The ecological value of the site will not be harmed by the development, and
with the use of appropriately worded conditions for bird boxes, the ecological value of the
site can be enhanced.
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Sustainability Issues
4.23
With regard to the Council’s Supplementary Planning Document on sustainable building
design – SPD08, the proposed scheme can be looked at in two distinct parts – the new
pharmacy and the new surgery.
4.24
The new pharmacy represents a new retail facility that is less than 150m 2 in size. For
development of such scale, the SPD08 document does not recommend any specific
BREEAM level, but does ask that the development shows a reduction in water and energy
use. With regard to water and energy use, note that all toilet facilities will be dual flush
units, and aerators will be fitted to tap heads to reduce water flow. Roof insulation will be
specified in accordance with building regulations standards.
4.25
With regard to the medical centre, this is to be created through the conversion of an
existing building. The Councils’ SPD08 states that for commercial uses arising out of
conversion of existing buildings, the “standard” is again that there should be a reduction in
water consumption and also a minimisation in surface water run off.
The developer’s
contract with the NHS requires the development to be carried out to the equivalent of
BREEAM Conversion Very Good for , and so will be implemented to a higher standard than
is set out in the Supplementary Planning Document.
4.26
The scheme will be carried out to sustainability standards that are in excess of those
recommended in the Council’s supplementary planning document SPD08. This is because
of the NHS funding parameters within which the developer has to work. As the application
seeks planning permission and listed building consent, there is very tight control over what
the development can be. Whilst it is a central tenet of planning law that permissions run
with the land, and not the applicant, in the case of the Holy Trinity Church, it can be seen
that the very specific floor plans (that require listed building consent) mean that the
development can only be used as a medical centre, and so the implementation of the
scheme will always be subject to the NHS’s sustainability criteria.
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4.27
Given the above, if the Council is minded to grant planning permission and listed building
consent, the authority is respectfully requested to not impose its standard “sustainability”
conditions on the development. The reasons are two-fold:
-
As noted above, the scheme has to be implemented to a higher standard anyway.
-
The Council’s standard wording for conditions generally includes words to the effect
that the permitted development cannot be first brought into use until a final post
construction certificate has been issued, and submitted to the Local Planning Authority
for approval. Such a condition means that it would not be possible for either of the two
medical practices to legally occupy the building once it was first completed – as it
would take many months for the Certificate to be issued, and for the Council to approve
the application to clear the planning condition. This could cause a problem with
funding for the scheme. A condition requiring the submission and approval of a
certificate within the first year of occupation would overcome such concerns.
5.00
CONCLUSIONS
5.1
The proposed development is an imaginative solution to the problem of finding new uses
for large listed buildings.
5.2
The development brings substantial community benefit, and will preserve the long term
future of two medical practices that are significant local employers.
5.3
In the light of the above, we trust that the council will be able to grant planning permission
and listed building consent.
Lewis and Co Planning
November 2014.
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