Agenda item

Written Submissions

Minutes:

 

Written Representations for applications to be considered by the Eastern Area Planning Committee – 9 February 2022

 

SEC/2020/0001 - TO MODIFY A PLANNING OBLIGATION FOR PLANNING PERMISSION 6/2018/0493 (DEMOLISH TEMPORARY CLASSROOMS AND OUTBUILDINGS AND CONVERT EXISTING REMAINING BUILDINGS TO FORM 10 DWELLINGS AND ERECT 20 NEW DWELLINGS WITH PARKING AND LANDSCAPING, REMOVAL OF EXISTING RAISED WATER TANK AND TO REMOVE THE REQUIREMENT FOR AFFORDABLE HOUSING AT THE FORMER ST MARYS SCHOOL, MANOR ROAD, SWANAGE,

 

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Warren Sellers

 

I sincerely request a gift of your time to read this letter before the next meeting of the Eastern Area Planning Committee of Dorset Council regarding the Agenda item viz:   SEC/2020/0001  To modify Planning Obligation for planning permission 6/2018/0483..to remove the requirement for Affordable Housing (AH) at the former St Mary’s School, Manor Road, Swanage.

Please reconsider the urgent need for an increase in Affordable Housing in Swanage and restore the requirement for AH in application  6/2018/0483.  I am seriously alarmed to read in your minutes of 5th January 2022 that Officers of the Council have thus far rejected the pleas of Swanage Councillors and others to include the Obligation as a condition of planning.

It is not too late to politely set aside the previous decision to accept the District Valuers’ recommendation to remove this Obligation and so finding in favour of owner, Trustees and the developer,  of the land instead of the future owners of the dwellings proposed, especially those who hope to purchase AH.

If the trustees and the developer will not produce an alternative financial statement of their individual needs in favour of the original proposal to include  a proportion of AH, your action as a member of the Area Committee to restore this Obligation at your next meeting will give opportunity for other developers to have more time to present their proposals to the trustees, however long that procedure may take.


Please do not lose this chance to restore the hope of more Affordable Housing.
Our Grammar School in Swanage closed its doors for pupils in 1974.  In 2021 proposals were announced for the building of 90 dwellings, 60 for the open market and 30 AH on that school site to the delight of many, some also breathing a happy sigh of relief after more than 45 years of effort from planners, councillors, constructors and members of the community.  This site in Manor Road may be more complicated and smaller in size. It is obviously worth taking more time to reflect on the personal needs of owners, trustees, developers and future Swanage occupiers.

I am also aware that allowing the removal of this Obligation will severely affect every community in the area of Dorset Council where there are hopes for more AH.
I hope each Councillor will read again the pleas of Swanage Councillors who have already spoken so firmly about our local need for AH.

 

 

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Colin Brixton

 

The development within the town is also within the AONB, where development is allowed as an exception, subject to a S106 agreement.

I object to the removal of the S106 obligation in this case on the grounds that the prime objective of site development in Swanage is to

gain more affordable housing. If this is lost the resulting outcome will no doubt be a greater influx of either non resident owners; and/or

the semi or fully retired from outside the area, so further increasing  the unbalance of the population by age group.

 

The applicant has had ample time to revise the application or withdraw. Failure to adequately anticipate problems with the site and the

effect on profit margin is in my opinion irrelevant.

 

Furthermore acceptance of this application will no doubt encourage future applicants to take similar action.

 

The consideration in my opinion should go against the officers recommendation, and be refused.

 

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Bracken Developments – applicant

 

Following the last committee meeting where members voted to defer the planning

application for further discussion with us, as the applicants, we have held a virtual meeting with your case officer.

 

This submission was made in May 2020 and has been the subject of considerable open book scrutiny by the councils own appointed RICS accredited surveyor, the district valuer, who has confirmed that the site is not developable on reasonable commercial terms if it includes any affordable housing. Your officers agree with these findings and have, again, recommended this application for approval.

 

This is not a speculative application put forward to maximise our financial return, as has been suggested. Rather we are in a position where we want to deliver these 30 units in

Swanage, with all of the benefits to the town that will bring, including a very considerable CIL contribution, but we are unable to do so as the site is financially unviable.

 

The viability of the planning permission is not a matter of judgement, it is a matter of fact, and you will recall from the previous committee meeting that officers repeatedly said that they would recommend the original planning application for approval with no affordable housing, based on the viability exercise that has been carried out and that is now before you.

 

Just for the record, Bracken has no issue whatsoever with providing affordable housing on the land it develops, where it is viable to do so. For example, we have just handed over 13 houses to Sovereign Housing Association in Weymouth, and have a further 33 affordable units currently in the planning system in Dorset.

 

As you will have noted from the officer’s report, Bracken owns this site, having acquired it in July 2019, and therefore there is no possibility of renegotiating the land transaction.

 

Our land at Swanage is a technically challenging and difficult brownfield site to develop, and the application before you has been the subject of proper detailed scrutiny by your officers and the Councils appointed experts. We therefore ask you to accept your officer’s recommendation and approve this application, thereby allowing this site to be developed.

 

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Jo Tasker, Ken Parke Consultants

 

 I am speaking on behalf of the applicants to support the application.

 

I will not take up much of your time as you have also heard a statement read out from Bracken Developments, the applicants.

 

As you are aware we have gone through a very thorough assessment process for this application and have followed the exact process allowed for by adopted Development Plan policy as well as Government Policy.

 

The applicant’s professionally prepared economic appraisal, which has been confirmed as a legitimate and accurate analysis by the Council’s own independent professional, is the evidence before the Council.

(continued below)

The economic appraisal is evidence based and accurate. Members are asked to accept the professional recommendation from their own expert and independent consultant that the conclusion of the appraisal is sound. The development cannot be delivered unless the requirement for affordable housing is removed.

Members are also asked to accept the recommendation from legal and planning officers who sanction the validity of the application and that the approach is correct and sound in law.

 

 

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6/2018/0566 - REDEVELOPMENT OF EXISTING HOTEL TO PROVIDE NEW TOURIST ACCOMMODATION INCLUDING 30 BEDROOM HOTEL, APARTMENTS & VILLA ACCOMMODATION, ASSOCIATED LEISURE & DINING FACILITIES (ENVIRONMENTAL IMPACT ASSESSMENT DEVELOPMENT) AT KNOLL HOUSE HOTEL LTD, KNOLL HOUSE HOTEL, FERRY ROAD, STUDLAND, SWANAGE,

 

 

 

 

Mark Funnell, National Trust

 

 The National Trust is a conservation charity that looks after nature, beauty and history for the nation – for everyone, for ever. The Trust owns the land around Knoll House Hotel, which it holds for its charitable purposes. This land includes areas of Dorset Heathland, woodlands and beach facilities. Part of the Trust’s land is leased to the hotel.

 

Knoll House Hotel has a long history, with associations with the Bankes family of Kingston Lacy, who bequeathed the lands surrounding the hotel to the Trust. The Trust would like to see the sensitive, sustainable re-development of the hotel.

 

The Trust maintains its objection on three grounds: landscape, ecology and parking.

Landscape: The proposed development would more than double the floorspace on-site, with building heights increased considerably. We consider that the proposals would over-develop the site and have a detrimental impact on key views and the landscape and scenic beauty of the AONB and Heritage Coast. The proposals do not appear to meet the tests for ‘major development’ in the AONB. The AONB Partnership and Dorset CPRE have raised similar concerns.

 

Ecology: The proposals would introduce 63 residential units and other leisure uses to the site. The Trust understands that under the applicant’s proposed operating model the intention is to manage these 63 units in conjunction with the 30-bed hotel. In the long term these 63 units could become individually sold and occupied. Even if they remain tied to the hotel, there would still be 63 new residential units adjacent to the internationally important Dorset Heathlands. As well as the increase in guest bedspaces on-site, there would be a significant uplift in staff numbers, as well as day-users of the leisure facilities. Further, the surface water drainage from the entire site has not been resolved and the current proposition is likely to have ecological implications. We agree with Natural England and the RSPB that the proposals would have adverse effects on the integrity of the Heathlands. The applicant has proposed ecological mitigation measures on Trust land but appears to have no secured means of delivering them. The 1999 lease of amenity land from the Trust to the hotel has expired and a renewal has not been agreed. To be clear, the Trust would not agree to a renewal lease, section 106 or other agreement with the applicant to support development in this form.

 

Parking: The major increase in floorspace (c.138%) would be matched by a very small increase in car parking (c.10%). Experience suggests this will lead to parking problems in the local area, especially during peak season.

The National Trust maintains its objection on landscape, ecology and parking grounds. We trust that this is a useful summary of our position.

 

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Ian Girling, Chief Executive, Dorset Chamber

 

My name is Ian Girling and I am the Chief Executive of Dorset Chamber, the county's leading business organisation and a member of the British Chambers of Commerce.

 

We fully recognise the heritage and beauty of the Knoll House Hotel. However it is clear the hotel is in major need of renovation and as it stands, is no longer fit for purpose. This is why major investment is required to maintain tourism and keep the Purbecks on the map as a world class destination and without this, the area and many businesses will suffer. The wider benefits of the hotel to other businesses in the area should not be underestimated.

 

The new plans seek to mitigate impact on the natural environment and our understanding is the new proposals are very understanding of this very important point. The proposals would significantly revitalise tourism in the local area as well as creating a first-class resort that would add significant economic benefit to the wider area. The new hotel would create significant employment in a relatively rural area, particularly offering young people seeking a career in hospitality a huge opportunity.

 

Our concern is if this proposal is not approved, the local economy will suffer and a major opportunity for a hugely exciting and beneficial resort that will really lift the area will be lost. This is a beautiful part of Dorset but without sympathetic investment, we will see decline and major revenue and employment opportunities lost. Such a beautiful part of the world deserves a world class destination, and this is why we support this planning application.

 

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Ben Read, Black Box Planning Ltd – on behalf of the applicant

 

This planning application is presented to members after a long period of consideration, since its first submission in 2018. The applicant, Kingfisher Resorts, recognises the sensitivity of the surrounding landscape and this has been central to the proposals from the outset.

 

The proposal does not seek to deliver a significant intensification in use. Overall, there will be a reduction of people accommodated on site. However, those guests will be afforded more space and access to a greater range of facilities, which is what is required of a five star destination. It is the number of people on site which has formed a considerable debate with Natural England over the last three years and the Officer Report helpfully recognises that the proposal will result in a reduction.

Knoll House was once an iconic destination on the Dorset Coast, an asset to the area.

 

However, now the condition of the hotel, which is spread across 30 buildings, is in sharp

decline. The proposal seeks to restore the quality that Knoll was once known for.

The objective is to deliver a range of enhancements to the surrounding area, which will be beneficial for the local environment, including:

- A Woodland Management Plan;

- Heathland restoration;

- Mire restoration, restoring local wetland habitat;

- A circular walk which can be taken as an alternative to the Heathland;

- Informative signage which highlights the sensitivity of the area;

- Visitor Information Packs for each guest;

- A Construction Environmental Management Plan;

- A Staff and Skills Strategy which will include education on the local environment as

part of their training; and

- Not to permit the keeping of dogs on site.

 

The measures will be secured by a binding Legal Agreement. There is no risk to the Council that planning permission will be issued if the measures are not secured. It would be unusual to have completed a s106 before a Committee Resolution. These measures are recognised by Natural England.

 

With regard to the AONB and impact, the assessment in the Officer Report is extremely narrow. It also appears to have been based on errors in the OR in respect of building sizes, a number of which have been reported as more than twice the size of those proposed. This is a major concern.

 

Notwithstanding the errors, it does make clear that ‘major development is a matter for the decision maker. This is right. It is perfectly appropriate for members to reach a different conclusion to the OR. The applicant, in undertaking an Environmental

 

Impact Assessment,

including Landscape Visual Impact Assessment, has reached a different conclusion to officers. It is not considered that it does constitute major development. The key area of difference on this issue is that the comments of the AONB Board and in the OR do not recognise that the site is already previously developed and has visual presence in the AONB. It is not a greenfield site. This has resulted in impacts being overstated. The proposal will actually reduce the area of the site which is to be developed, rationalising the existing sprawl.

 

Members will be aware of the High Court Judgement handed down by Justice Swift in respect of 750 homes to be built in the AONB at Bridport. It was recognised in the judgement that the AONB is not a bar on development, a much larger development on a greenfield site. In thatcase, the development was concluded to be in the public interest to meet housing needs. In this case, the same can be concluded in delivering economic and social objectives. Officers

recognise that there is a need for this development and that it cannot be delivered outside the AONB.

If members are in any doubt about landscape impacts, I would encourage them to visit the site.

As a matter of planning policy, and law, it is important that members consider the issue of major development but in doing so, they are entitled to conclude that it is not major

development.

 

The Benefits of the Scheme

The Officer Report takes a very light touch approach to the benefits of the proposal. It does recognise the substantial economic benefits arising from the investment, which is welcomed, it fails to mention them in totality:

- Economic benefits:

o Total construction investment – circa £40m (at 2019 prices);

o Jobs:

233 jobs in total. This amounts to a 14% increase in employment in

Hotels and Restaurants in the former Purbeck District area

- Economic Projections:

o £40m construction investment

o £5m GVA every year in operation for the local economic from onsite

activity

o £1m GVA a year in the supply chain

o £2.5m a year in additional spend in the local area.

- Qualitative benefits:

o Year round jobs

o Improved quality of jobs offering above average salaries; career

progression opportunities and apprenticeship schemes

o Increased confidence in the local tourism market, encouraging further

investment

o Higher quality tourism offer in the area, encouraging other businesses to

improve theirs, encouraging a cluster of high quality provision.

- Environmental benefits:

o Energy efficient buildings, including provision of renewable energy

(combined heat and power)

o Sustainable buildings in excess of that required by Building Regulations

o Agreement to condition securing Electric Vehicle Charging Points on site

(Kingfisher deliver these in any event)

o Promoting more sustainable patterns of transport and an electric staff bus

to be secured in the s106 Agreement

o Opportunity to regulate existing drainage, reducing runoff rates and

cleaning runoff through infiltration systems.

- Local resident benefits:

o Improved local offer accessible to existing residents

o Job and career progression opportunities for local people

o Memberships for local residents within a defined catchment (which will

also divert people from using the heathland)

o Retaining Knoll House as a local asset to be proud of in the long term.

 

The benefits of the proposal are significant and will also provide a long term and sustainable solution for Knoll House. For the reasons set out in the extensive assessment undertaken to support the proposal, there is no reason why members cannot reach a different conclusion to Officers and resolve to grant planning permission subject to the completion of a S106 Agreement and a Habitat Regulation Assessment. Kingfisher respectfully invite members to

support the proposals on that basis. Thank you.

 

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Tim Watton, Clerk to Studland Parish Council

 

Studland Parish Council have unanimously decided to object to this planning application on the grounds of: size, mass, and impact of the development; harm to designations, and inadequate parking. More detail on our objections are shown below.

Main objections and concerns:

-         Impact on nature conservation: the development will be within the 400m boundary that prohibits developments close to the heathland. Studland is in an AONB, and these plans are totally out of character with the area, and the conservation of the area

-         Size / bulk /impact on outlook: the scale of the development is disproportionate to the site. The proposed total floorspace would be 250% greater than the current hotel. One section will be five storeys high (compared to three now). Given its height and scale, not only will it be highly visible from the heath (e.g. Agglestone Rock), from parts of the village, but also very clearly from the sea

-         Loss of trees: 40 trees are to be cut down. Whilst there is a replacement plan, there is no clarity of the type and size of trees to replace the mature trees being cut down; inevitably the mature trees would only be replaced by smaller saplings, changing the character of the site

-         Highway issues: we believe the highway and transport plans outlined are totally inadequate and are inaccurate. The hotel / resort will have a higher number of guests than the current hotel, and will have a much greater number of staff. The guests arriving, especially in the larger flats, will come in multiple cars. The 5 star, 24 hour nature of the hotel will require staff arriving and leaving throughout the day and possibly night. Not all staff will want to come by shuttles and will need car parking space, as well as increasing traffic volumes. As the hotel is proposed to operate 12 months a year, as opposed to 9 as currently, these will be year around issues.

Other objections and concerns:

-         Lack of staff accommodation: we do not believe that the hotel will be able to function without some staff accommodation. Given the aspirations of the hotel to provide a 5 star service, this will mean having some staff available on site

-         Lack of car parking: despite the large increase in number of residents and staff, only four additional car parking spaces (83 as opposed to 79 currently) will be provided; this issue is compounded by the fact that most staff are currently residential, whereas under the proposed plans, no staff will be residential and therefore will require to travel to the site. We find this astounding, and believe the hotel will require much greater volumes of car parking space; if this is not provided, then there is the potential that staff and guest will find other car parking spaces in Studland e.g. in NT car parks, or on the roads.

-         Impact on infra-structure of Studland: the roads and utilities for Studland are designed for a small village, with some seasonal fluctuations. However, the size of the hotel will lead to increased usage of roads and other utilities throughout the year

-         Construction noise / traffic: the scale of the development will lead to a huge increase in construction traffic – which will predominately use the Ferry Road / Swanage Road, and the Studland to Corfe Castle Road: these are relatively narrow roads not suitable for large volumes of large and wide lorries. The number of ongoing service vehicles will also increase – compared to now – due to the size and scale of the hotel: this will increase traffic flows.

-         Safety of foot pedestrians: there is no pavement between Studland and the hotel, which means that hotel residents who wish to use facilities in Studland – such as the shop, Social Club, pub, or Church – will either have to walk along the road, or drive (increasing traffic flows and parking issues in the village)

-         Light pollution at night: being an AONB, Studland is very dark at night, with very few street lights. Having a hotel of the size of that proposed would lead to a dramatic increase in light pollution, making the hotel very visible from several parts of Studland, the sea, and potentially from Bournemouth

Support

-         Retail facility: we are pleased that the hotel will have no retail facility. The current hotel is the largest single user of the shop in Studland – the Studland Stores – and loss of business from the hotel would challenge the viability of the shop.

 

Additional comment made at Studland Parish Council meeting on 7 February 2022:-

 

At a recent public meeting in Studland the majority of residents supported the idea of an upmarket development in Studland. Studland Parish Council hope the planners at Dorset Council and at Kingfisher / Knoll House Hotel can come to a solution that would allow a more suitable and sensitive development to go ahead. 

 

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