Minutes:
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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.
……….
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.
……..
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.
…….
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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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.
…….
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.
……..
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.
……
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.
………