town and country planning act 1990 (as … · dorothy house hospice care, winsley, bradford on...

Dorothy House Hospice Care, Winsley, Bradford on Avon, BA15 2LE 1 Rackham Planning, First Floor, 24 High Street, Thornbury, Bristol, BS35 2AH

TOWN AND COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004

APPLICATION FOR PLANNING PERMISSION FOR THE RECONFIGURATION OF EXISTING CAR PARK AND PROVISION OF EXTENSION TO PROVIDE ADDITIONAL PARKING AND

ASSOCIATED WORKS

DOROTHY HOUSE HOSPICE CARE, WINSLEY, BRADFORD ON AVON, BA15 2LE


Contents

1. Introduction 3

2. Site Description 5

3. Proposal 12

4. Planning History 17

5. Pre-Application consultation 20

6. Planning Assessment 22

7. Summary and Conclusions 33


1. Introduction

This Planning Statement has been prepared by Rackham Planning on behalf of Dorothy House

Hospice Care (DHHC) (‘the applicant’) and is submitted in support of an application for

planning permission to provide additional car parking through the reconfiguration of the

existing car park to make more efficient use of this space and an extension to provide further

parking for staff, carers and visitors at Dorothy House, Winsley, Bradford-on Avon, BA15 2LE

(‘the application site’). The full description of development is as follows:

‘Application for planning permission for the reconfiguration of the existing car park and

extension to provide additional parking and associated works’.

This planning application has been submitted following a formal pre-application enquiry to

Wiltshire Council which related to the extension of the car park into a neighbouring playing

field to the west of Dorothy House. This pre-application enquiry was not supported and the

proposal that is now the subject of this application suggests an alternative location to the

south of the existing car park. The extension is the minimum size necessary to enable Dorothy

House to continue to operate in its current location and provide a vital hospice care service.

Part of the proposal also includes the reconfiguration and more efficient use of the existing

car parking areas; provision of better access and manoeuvrability into and around the site;

better footpaths to improve on site safety; more formal arrangements for drops, servicing and

deliveries.

These additional works have also been proposed to increase the efficiency of the existing car

park and reduce the amount of new parking spaces to the bare minimum in order to reduce

the impact on the openness of the Green Belt (GB); the Area of Outstanding Natural Beauty

(AONB); the natural conservation issues; and the impact on the Conservation Area (CA) within

which the site is located.

Given the site’s sensitive location, a number of supporting studies have been prepared in

support of the application, including:

The supporting justification for the proposal in terms of its impact on the openness of

the GB, AONB, CA and also against other land use planning designations when

considered against the policies in the Development Plan and other material

considerations, within this Statement;

Transport Statement prepared by White Young Green (WYG);

Aboricultural Assessment prepared by Silverback;

Archaeological Survey prepared by Bristol & West Archaeology;


Landscape and Visual Impact Assessment prepared by Landscape Collective;

Ecological Appraisal prepared by ADAS; and

A set of drawings prepared by NVB Architects;

The Transport Statement provides a detailed assessment of the movements associated with

Dorothy House and demonstrate that the additional car parking space will not cause any

adverse highway safety impact.

The Ecological Survey confirms that the use of the proposed area for a car park will not have

any harmful impact on protected species in the vicinity of the development, notably bats and

slow-worms and that mitigation can overcome any identified harm.

The Aboricultural Assessment confirm that the only trees that are proposed to be removed to

enable the car park to be reconfigured and extended are the lowest grade trees.

The Archaeological Desk Based Assessment confirms that the proposed works will have no

harmful impact on any features of historical significance, should they be present on site.

The Landscape and Visual Impact Assessment confirms that there is no harm to the wider

landscape setting of the AONB.


2. Site Description

The application site is formed by the car park and land at Dorothy House Hospice, located on

the south western edge of the village of Winsley, itself 2.7km to the west of Bradford-on-Avon

and 5.9km to the south east of Bath (photograph 1). The A36 (Warminster Road) lies 1.6km

to the west providing access to Bath.

Access into the site is off a lane to the south of Bradford Road/ Limpley Stoke Road

(photograph 2). This lane becomes known as Murhill and provides access to a small number

of residential properties.

Photograph 1 – Location of the application site (source: Google maps)

Photograph 2 – Dorothy House and entrances off Bradford Road and Woodlands Drive (source:

Bing maps)

Application Site

Application Site


Photograph 2 is a larger scale aerial photograph showing the site on the southern edge of

Winsley. The surrounding area is predominantly rural in nature and, as photograph 1

confirms, is generally either wooded or in an agricultural use. The villages of Freshford,

Turleigh and Avoncliff are located within a 1.4km radius of Dorothy House. There are train

stations at both Freshford and Avoncliff, which provide direct access to Bristol. The

Wheatsheaf Junction bus stop (north-west bound and south-east bound) is located 75m to

the north west, serving the 265 which runs from Bath to Salisbury. Details of the sustainable

transport links that serve Dorothy House are provided in more detail in the Transport

Statement prepared by WYG.

Photograph 3 shows the access road to the south of Bradford Road, off which the application

site is located. Also visible in this photograph, and shown more clearly in photograph 4, is the

existing playing field which was the location of the proposed car park extension that was the

subject of the pre-application enquiry in January 2016. However, given the negative

comments in this pre-application response, an alternative location is proposed to the south

of the existing car park (photograph 5).

Photograph 3 - the access road and existing entrance to Dorothy House (source: Google Maps)


Photograph 4 - the playing field that as the subject of the pre-application enquiry (source:

Google Maps)

Photograph 5 - the access road and existing entrance to Dorothy House (source: Google Maps)

Photograph 6 below shows the surrounding land uses, including Avonpark Village – a

retirement village for the over 55s, 0.5km to the west of Dorothy House. Murhill Woods are

located 0.6km to the south west and both the River Avon and Kennet & Avon Canal are 0.4km

also to the south west.

Playing field subject of pre-

application enquiry

Existing car park

Site access

Proposed location of car park extension


Photograph 6 – Site and surrounding uses (source: Google maps)

Photograph 7 shows a view of the existing car park and demonstrates the high level of

demand, resulting in double parking and very unsafe and inconvenient parking arrangements.

The difficulties in parking are hugely inconvenient for staff, visitors, as well as patients and

families of patients who are very likely to be in distress, given the reason for their visits.

In times of extremely high usage, the playing field (photograph 4) and the neighbouring field

to the south are used for temporary overflow car parking under Schedule 2 Part 4 Class B of

the Town and Country Planning (General Permitted Development) England (Order) 2015

Freshford Freshford

Train Station Avoncliff Train

Station Avoncliff Village

Kennet & Avon Canal

Dorothy House

Winsley Avonpark

Village Murhill Woods

River Avon


which permits the use of any land for a maximum of 28 days per year for any use. In this

respect, each separate parcel of land is used on this temporary basis.

Photograph 7 – View of the existing car park (note double parking)

The site is located within the GB, as defined in the West Wiltshire District Plan (1st Alteration)

and also within the Cotswolds AONB Dorothy House and the existing car park are located

within the Winsley CA which covers a large part of the south of the village. The nearest Listed

Building is the Grade II Listed ‘Garden wall with stone talbots at Dorothy House Hospice

(formerly Winsley House)’, located to the north of Dorothy House (as shown in photograph 8

below). The site is also partially within an Area of Archaeological Interest.


Photograph 8 – The listed wall on the northern boundary of Dorothy House

The full Listed entry is set out below:

‘A stone wall dated 1637/1657 built for Winsley House with three limestone talbot statues,

altered and repaired in the C20.

Description: the section of wall is approximately 120m long and c2m high. It is built in random

stone rubble with dressed stone to the later curved sections at the main entrance along

Bradford Road, and with flat stone copings throughout. The entrance is marked by two stone

talbot statues set on a flat stone base on top of the coping. Another talbot statue is set above

a flat-arched, stone ashlar doorway further north along Bradford Road, which has a planked

timber doorway with decorative cast-iron strap hinges. Above the doorway is a small date

stone, inscribed with '1637' or '1657' (the third number only partly legible). The statues, despite

the stone being slightly weathered, are clearly defined and depict the talbots with curly fur

and tails resting on their backs. They sit in an upright position and have a studded collar around

the neck with a chain attached. During the recent restoration of the statues, historic red paint

traces were found in the mouth of one of the Talbots.’

(Source: Historic England - https://historicengland.org.uk/listing/the-list/list-entry/1424264)

The application site is located within Flood Zone 1 which is land classified as being at the

lowest risk of flooding. Due to this, a Flood Risk Assessment does not need to be submitted as

part of this application.


Dorothy House activities

Dorothy House Hospice Care (DHHC) is a charity providing free, palliative care and support for

people with life-limiting illnesses. They operate from three premises including outreach

centres at Trowbridge and Peasedown St John as well as the main hospice located in Winsley.

Dorothy House run a number of shops in towns across this part of the South West, primarily

in Wiltshire and in and around Bath.

The Operational Statement prepared by the applicant sets out in more detail the specific type

of care work undertaken, including a 10 bed inpatient unit and large day-care patient centre.

In addition, DHHC also undertake education and training for health and social care

professionals, organisations, community groups and businesses as well as the wider

community, to provide better care for those dealing with or affected by death and dying.

The large number of full and part time staff, around 150, work at Winsley, with many other

employees using this Head Office location for training and fundraising as well as management

activities.


3. Proposal

The proposal for additional car parking spaces is submitted on the basis of the existing high

demand and use of the spaces within the car park and also the future needs arising from

DHHC. The existing parking demand has been confirmed by a baseline parking survey

commissioned and carried out by WYG, as explained in the Transport Statement (TS). A

summary of the results are contained in Section 3 of the TS, with the full results in Appendix

B.

Table 3.1 of the TS confirms the occupation rates of the car park (i.e. the number of cars using

it compared to the number of existing spaces) and on each weekday, occupation was generally

well over 100%. The highest occupancy rate experienced was on Monday, with demand being

almost 40% more than the current capacity. This survey clearly demonstrates that there is a

consistent over demand for the car park compared to the number of spaces available. This

results in staff and visitors either double parking in the car park or parking on street (as shown

in photograph 7 above).

Given the site’s location in the GB, the need for the additional spaces and the consideration

of alternative locations and solutions was key, as this would help to demonstrate the very

special circumstances required for the proposal in the GB. As such, part of the preparation

and justification for the new car park included a Travel Habits Survey, which was intended to

understand the mode of transport that staff took to work; start and finish times; details of

where they travelled from; and why they do not currently use public transport or take more

advantage of car sharing. The results confirm the reasons why the majority of staff drive to

work, namely given that it is essential for the job and the lack of sustainable alternatives.

The survey also considers the potential for increasing public transport usage and also car

sharing. The results confirm that whilst alternative modes of transport may offer the potential

to reduce the number of car trips, the location of the site on the edge of the rural settlement

of Winsley, coupled with the distance that people travel means that this is always likely to

have limited impact and not take the majority of existing car drivers off the road. Therefore

DHHC have a clear existing need to increase the provision of parking spaces on site.

Further, and as explained in the Operational and Need Assessment prepared by the Applicant,

there are future plans to expand the care and other related services at the application site.

These include, converting other parts of the building to provide additional Inpatient beds

(from 10 beds to 16 beds); additional conferencing and training opportunities taking

advantage of the specialisms and expertise that Dorothy House have in caring for patients

with life limiting illnesses; and establishment of a centre of excellence for palliative care.


Therefore, there is clearly a need to provide additional car parking spaces to meet both the

existing and future demands arising from the Hospice.

As part of the solution to providing additional parking on site, the existing car park is proposed

to be reconfigured to make more efficient use of this space. The proposed plans prepared by

WYG show that through this reconfiguration; use of an existing landscaped verge; and removal

of the existing smoking shelter, an additional 31no. parking spaces (including 4 disabled width

bays) can be provided. Around the main entrance, reconfiguration of the existing car park area

will provide a further 8 spaces, including 4 disabled bays.

On the basis of the parking accumulation surveys, this existing re-arrangement and

reconfiguration will still not provide the additional spaces required to meet the current

demand and the car park will remain at or near, full capacity and offer no space for future

growth, particularly to meet the areas identified by DHHC in their Operational Statement.

As a result, there is a need to provide additional car parking capacity on the site. The land

within the applicant’s ownership is edged in blue on the site location plan prepared by NVB

Architects. The playing field to the west of the site and access road was the subject of the pre-

application enquiry in January 2016 (see section 5 below) and was not supported by the

Council. There is no other land available, either that the applicant owns or that they can lease

in a less sensitive location and therefore the fields to the south of the existing car park were

proposed as the most sensitively sited alternative.

The Proposed Car Park Extension Sheet 2 of 2 (drg ref: A096365 GA02 Rev C) prepared by WYG

shows the access road and location of the new car park providing an additional 79 overflow

spaces. The existing fields that are the location of the proposed car park extension are shown

in photographs 9 - 10 below and are formed by two fields to the south of the existing car park.

The fields are separated by wooden stock fencing and surrounded on their western and

southern sides by mature woodlands.

The field that is orientated in a general north-south direction will broadly be used to form the

access driveway (visible in photograph 9). The route of the access driveway will be around the

existing telegraph pole and stem and also avoid the trees and the Root Protection Areas of

the existing mature tree belt on the western boundary of the site. The field orientated in an

east-west direction will be the location of the proposed car park.


Photograph 9 – View from the proposed overflow car park towards the driveway. Existing cars

and solar panels visible.

Photograph 10 – View from the proposed overflow car park towards Dorothy House. Note

existing solar panels visible in foreground and ridge of Dorothy House visible in background.


Photograph 11 – view of the Chapel from landscaped garden

Photograph 12 – View from the Dorothy House (Chapel) towards site. Note Solar panels not

readily apparent and only top of telegraph poles visible.

The proposed new car park will be arranged to minimise the space required and will be cut

into the existing hillside as much as possible to reduce its visual impact. The Proposed

Landscape Plan prepared by NVB Architects (drg ref: 2100 Rev C) shows a 3m landscape buffer

around the car park to reduce its visual impact and provide ecological enhancements.

A detailed Landscape Visual Impact Assessment (LVIA) assessing the impact of the proposed

car park on the wider area, including the AONB, has been prepared by the Landscape

Collective.


Photograph 13 – View of landscaped area around existing car park to be developed as footway

The Proposed Car Park Extension Sheets 1 and 2 (WYG drawing A096365 GA01 Rev C and GA02

Rev C) show a number of further changes to the existing layout. These include:

A reconfiguration of the entrance so that the main path for vehicles and priority is

towards the car park and not the main entrance (used by deliveries and ambulances).

To enable this, the end section of the existing stone wall (visible in photograph 3) will

be rebuilt at a 90 degree angle inside the existing tree line to enable the access road

to sweep into the site and significantly enhance visibility into and out of the site. The

wall will be rebuilt using the existing stone. The re-siting of this wall is likely to involve

the loss of this tree, however given its age and condition there is no objection to this.

The grass verge adjacent to the entrance and Nicholson House will be used to

accommodate service and delivery vehicles;

No designated footpaths exist in the existing car park and pedestrians have to

navigate through the busy car park without protection. Two designated footways are

proposed to provide a route to the existing covered entrance walkway from the car

park. This new path will link to the existing paths within the site to the new car park;

Within the existing car park are a number of floodlights illuminate the existing spaces.

These will be replaced with low level sensitive lighting to ensure that all the car park

is sensitively lit to ensure that there is no harm caused to the existing bats identified

in the area. A Lighting Strategy prepared by Designs for Lighting in conjunction with

the ecologists ADAS is submitted in support of this application which confirms that

the location, lux levels and dark corridors will all retain the site’s importance for bats.

General location of footpath


4. Planning History

A total of eight planning applications have been submitted at Dorothy House which are

summarised below. The extension in 2004 (W/04/01318/FUL) relates to the erection of the

chapel building and the two highlighted relate most directly to this proposal.

Ref: Proposal: Decision Date: Decision:

W/88/01099/FUL Filling existing

quarry and

formation of public

car park

08/11/1988 Approved

W/97/01363/FUL Vehicular access

erection of timber

gates and

implement shed

26/11/1997 Approved

W/98/00953/FUL Overspill car park

and landscaping

12/08/1998

W/04/01318/FUL Proposed Extensions 08/11/2004 Approved

W/10/02009/FUL Extension to car park

to provide an

additional 40 car

parking spaces

16/10/2010 Approved

W/11/03126/FUL Erection of Solar

Panels

19/01/2012 Approved

W/12/00436/FUL Provision of

overflow car park

and associated

works

Withdrawn

10/04/12

W/13/00009/FUL 2 single storey, two

bedroom

community lodges

25/02/2013 Approved

Application ref: W/10/02009/FUL involved the creation of an additional 40 spaces in an area

immediately south of the existing car park. Planning permission was granted and as image 1

below confirms, a number of these spaces have been built out. However the spaces located

towards the existing chapel have not been built out given that they would have a harmful

visual impact on the views and outlook from this sensitive part of the building which was sited

and designed to be as calm, reflective and peaceful as possible (as shown in photograph 11

above). A car park involving the movement of cars cannot be sited where it is readily visible

from this part of the building.


Image 1 – Extract from approved Proposed Block Plan (approved W/10/02009/FUL)

highlighting area not built out given proximity to chapel and day care patients/ visitors

Application ref: W/12/00436 was an application for a 68 space car park on the land to the

west of Woodlands Drive, on the playing fields that were the subject of the 2016 pre-

application enquiry. This application was subsequently withdrawn as it was considered

unacceptable. However it is of note that the County highway officer and ecologist did not

object to the proposal.

Image 2 – Extract from Proposed Site Layout Plan showing location of proposed car park on

playing field (app ref: W/12/00436/FUL)

This planning history confirms that there has been an ongoing need for additional car parking

to serve Dorothy House since 1988 and that this has only partially been met by previous

extensions, the most recent of which was approved and built out in 2010. This planning

permission granted an extension near to the curtilage of the existing building, however it

Chapel


cannot be constructed for the reasons set out above. Therefore this need remains and as the

Operational Statement confirms, will only become more pressing as the services that DHHC

offer grow.


5. Pre-application Consultation

i. Local Planning Authority

A pre-application enquiry was submitted to Wiltshire CC in December 2015 by the architects

NVB, with a formal response issued on 19th January 2016. As summarised above, this enquiry

was submitted on the basis of the proposed location of the car park within the playing field to

the west of the access road that was also the subject of the withdrawn application in 2012.

The comments made in the formal response are summarised below, with an explanation of

how the revised proposal addresses them in bold:

- The site lies outside the defined limits of development where future development can

only be approved in exceptional circumstances.

o The proposed car park has been relocated so that it relates more to the

existing curtilage of Dorothy House. Further, the evidence in this Planning

Statement sets out the exceptional circumstances that exist to justify the

proposed development in this location; including the need (both current

and future); the lack of alternatives and also the mitigation measures that

are proposed to reduce the impact on the openness of the GB and landscape

setting of the AONB as well as the ecological and other impacts. These are

set out in more detail in the Assessment section of this Statement and in the

supporting documents.

- The site is located in the GB and ‘very special circumstances’ will not exist unless the

potential harm to the GB by reason of inappropriateness, and any other harm, is

clearly outweighed by other considerations.’

o The case for very special circumstances for the proposal in the GB is set out

in the Assessment section of this Statement. These are considered to arise

as a result of the need, lack of alternatives and mitigation proposed.

- Recreation land – the site is known to be a playing field, any application would need

to take policy LP2 into account.

o This comment related to the location of the site on the playing field. Given

that the proposed car park is located on land to the south of Dorothy House,

this issue is no longer relevant.

- The site is located within the AONB where great weight is placed on the conservation

of the landscape and scenic beauty.


o The siting of the car park extension has considered this issue in detail and

an LVIA has been prepared to consider the impact of the proposal on this

sensitive landscape setting.

- The site is located on the boundary of a CA and near to a Grade II Listed building.

o The proposed siting of the car park has no direct or relevant relationship

with the Listed Building which is located on the northern boundary of the

site. The Listed wall is not visible from the proposed car park area and there

will be no adverse impact as a result of the proposal.

- The car park is an overflow car park, therefore the access from Limpley Stoke Road

should be removed and the main access taken form Woodlands Drive.

o Given that the location of the proposed car park has changed, this comment

is no longer relevant. However the proposal that is the subject of this

application proposes to alter that priority within the site to enable better

movement into and out of the site.

- Details of how the generated storm water should be provided in the form of a

Drainage Strategy.

o A Drainage Report undertaken by WYG is submitted with this Statement.

- The site is in close proximity to a number of bat species and other protected species.

o A Preliminary Ecological Appraisal prepared by ADAS is submitted with this

Statement, which contains comprehensive details of the proposed bat

mitigation strategy.

- The site is located partially within an area of archaeological interest.

o A Desk-based Heritage Assessment prepared by Bristol & West Archaeology

is submitted with this Statement. The Statement confirms that the

archaeological potential of the site is low.

ii. The local community

The applicants have also engaged with the local community and parish Council to inform them

about the proposed extension to the car park. A meeting was held on 13th September 2016

where local residents were invited to the application site to hear about the proposals and

discuss them with the applicant. The meeting was attended and the issue of parking capacity

is one that affects the village so residents were very supportive of the proposal, including the

enhancement to the existing car park. They also supported the measures to minimise the

visual impact of the location and the additional planting and screening and wildlife

enhancements proposed.


6. Planning Policy Assessment

In 2012 the National Planning Policy Framework (NPPF) was published and replaced all Central

Government Planning Policy Guidance notes and Statements. The overarching aims of the

NPPF are to encourage sustainable economic growth, to support the economy.

The NPPF reaffirms the requirements of Section 38(6) of the Planning and Compulsory

Purchase Act 2004 where applications for planning permission must be determined in

accordance with the Development Plan, unless material considerations indicate otherwise.

Paragraph 17 of the NPPF lists a set of twelve core land-use planning principles which should

underpin both plan-making and decision-taking. The relevant principles are summarised

below with a brief analysis of how the proposal accords with them is set out in BOLD:

- ‘Not simply be about scrutiny, but instead be a creative exercise in finding ways to

enhance and improve the places in which people live their lives’ – This principle is

relevant to the application as the need for additional parking has been identified in

the Operational Statement and is inextricably linked to the need and ability of DHHC

to maintain its existing levels of care and also provide future care.

- ‘Take account of and support local strategies to improve health, social and cultural

wellbeing for all, and deliver sufficient community and cultural facilities and services

to meet local needs.’ The need for the additional car parking spaces has been set out

above and in the Operational Statement and they are required to meet the existing

demand and need at Dorothy House as well as provide capacity to meet future

identified needs.

Paragraph 30 seeks to reduce greenhouse emissions by supporting more sustainable patterns

of growth, where reasonable to do so, which facilitate sustainable modes of transport. The

Transport Statement prepared by WYG provides details of the Travel Habits Survey requested

of all staff at Dorothy House and provides details of the reasons why the majority drive to

work as well as the barriers that stop greater use being made of public transport. In this rural

village where public transport links are limited, staff work different hours and commute from

surrounding rural areas, there are limited opportunities to reduce the use of the private car.

However paragraph 34 acknowledges that this can be more difficult in rural areas

The NPPF includes sections relating to development in the GB as well as protecting the

landscape and natural environment. These are covered in detail below.

The in principle acceptability of the extended car park in this location is determined by the

key landscape, natural and policy designations attributed to the site. As the Development Plan

and proposals map below (image 3) confirms, these relate to the site’s location in the GB,


AONB and close to a number of natural ecological settings (Site of Special Scientific Interest –

SSSI) as well as its proximity to Winsley CA. An assessment of the proposal against these issues

is set out below:

Image 3 – Extract from Proposals Map showing application site within GB and AONB (green

shading); and location outside Conservation Area (cross hatch)

Impact on the openness of the Green Belt

Paragraph 87 and 88 of the NPPF confirm that inappropriate development in the GB is, by

definition, harmful and should not be approved except in very special circumstances. Such

circumstances ‘will not exist unless the potential harm to the Green Belt by reason of

inappropriateness, and any other harm, is clearly outweighed by other considerations.’

Paragraph 89 identifies six exceptions to the general policy that new buildings are

inappropriate and is related to the fundamental, overarching aim of the GB which is to protect

their openness.

Paragraph 90 confirms that “certain other forms of development are also not inappropriate in

the Green Belt provided they preserve the openness of the Green Belt and do not conflict with

the purposes of including land in [it]’.

The purposes of including land in the GB are set out in paragraph 80 of the NPPF:

1. to check the unrestricted sprawl of large built-up areas;

2. to prevent neighbouring towns merging into one another;

3. to assist in safeguarding the countryside from encroachment;

4. to preserve the setting and special character of historic towns; and


5. To assist in urban regeneration, by encouraging the recycling of derelict and other

urban land.

The proposed extension of the car park will not conflict with any of these objectives given

that:

1. It has no impact on the sprawl of a large built up area, the nearest one to the

application site being either Bradford on Avon (though this is defined in the Core

Strategy as being a small market town), or Bath;

2. The siting of the car park and Dorothy House on the edge of Winsley and the location

of Winsley itself, all ensure that the proposal will not contribute to the merging of any

towns;

3. There may be some limited encroachment into the countryside as a result of the

proposal. However the location of the extension has been sited so as to minimise its

visual impact, as confirmed in the LVIA prepared by the Landscape Collective. Further,

a 3m landscape buffer is proposed around the site which also acts as a wildlife corridor

but which seeks to minimise the site’s impact on the countryside and AONB. Further,

there are no new buildings proposed and therefore no new or additional buildings or

height introduced.

4. There is no impact on the setting of Winsley as a historic town or notably the CA given

the distance of the site from the CA and also the fact that the existing building and car

park screen the site from the CA.

5. There is no derelict land available to be recycled nearby.

There is no policy in the Core Strategy specifically relating to the GB, although paragraph 6.87

reiterates the objectives and purposes of including land in the GB and refers to the NPPF. As

a result there is considered to be no conflict with the purposes of including land in the GB and

consequently the proposal complies with paragraph 90 of the NPPF which confirms that

“certain other forms of development are also not inappropriate in Green Belt provided they

preserve the openness of the Green Belt and do not conflict with the purposes of including land

in Green Belt”.

Equally, proposals for new development at Dorothy House have been approved as recently as

2004 when planning permission was granted for the new chapel and two lodges in 2013 which

suggests that the principle of development associated with DHHC can be considered a very

special circumstance.

However the pre-application response considered that the use of the playing field had an

impact on the openness of the GB. Whilst the current location is different to this site, it is

considered to not have a harmful impact for the reasons set out above and also given the

following:


It has been sensitively sited in one of the most well screened locations within the

wider area that is owned by DHHC given that it is well screened by an existing mature,

tree screen on the western and southern boundaries. These trees are being retained

as confirmed on the Site Layout Plan and also in the Arboricultural Assessment

prepared by Silverback.

Additional screening and planting in a 3m wide landscape strip is proposed on the

eastern boundary where this siting could have an impact.

However this impact has been assessed in the Landscape and Visual Impact

Assessment (LVIA) which confirms that given that the proposal is essentially a two

dimensional development with no vertical features, it will not harm the landscape

character, setting or features. Equally the LVIA confirms that there will be no harm to

the visual amenity from public vantage points or properties and views from public

highways will be very limited.

There is no vertical development as part of this proposal and it is essentially a two

dimensional development;

The finish of the driveway and parking spaces can be controlled to reduce the amount

of black tarmac of concrete, for example, by using a grasscrete finish on the parking

spaces which allows grass to grow.

Further, and notwithstanding the fact that the proposal is considered to not be inappropriate,

if the Council remain of the view that the development is inappropriate the case for very

special circumstances is set out below:

a) There are no alternative locations to locate the car park. A number of other options

have been considered including:

i. The use of the playing field to the west of the access road that was the subject

of the pre-application enquiry response in January 2016 and the planning

application that was withdrawn in 2012. This alternative location would

involve the loss of a playing field and is also located nearest to the Winsley CA

and would also present the same Green Belt, AONB, landscape and other

ecological and environmental constraints as the application site.

ii. The further extension of the existing car park to the east to implement the

extant part of the planning permission approved in 2012 (see image 1 above)

does not offer a reasonable alternative given the operational impact on the

chapel, the purpose of which is to enable patients and families (who may also

be bereaved) quiet reflective time. This purpose would be compromised with

the movements and disturbance associated with a car park. The existing view

from the Chapel is shown in photograph 11 which must be maintained. This

location would also present the same Green Belt, AONB, CA, landscape and


other ecological and environmental constraints as the application site. Also,

as discussed above, the approval of the chapel and this car park extension in

2012 have established the principle of new development in this sensitive

location.

iii. As the Site Location Plan confirms the land owned by the applicant surrounds

the existing building and car park and offers the same constraints as the

proposed.

iv. As a charity, the applicant is not able to identify and purchase land within an

urban area or outside the Green Belt to be used as a car park. Further, this

would not work from an operational or practical perspective given that staff

and visitors would then need to be transported from this alternative site to

Dorothy House having travelled from a wide catchment area and long

distance.

v. In addition to the reconfiguration of the existing car park to provide additional

spaces, consideration was given to providing a two storey car park on the

existing site. However this was quickly ruled out given the clear harmful

impacts on the openness of the GB.

Therefore there are not considered to be any reasonably available alternative locations

either within or outside the GB, nor any alternative locations within the GB that have less

of an impact on its openness or the purposes of including land within it.

b) The existing and future need for the parking spaces as described in the Operational

and Need Assessment. The reasons for the growth in this type of care are well

documented, notably given the rapidly ageing population and the reducing and more

stretched NHS budget to cover this form of care. As a result, the importance of

charities such as DHHC increases. There is insufficient parking to accommodate the

current business needs (as demonstrated by the parking accumulation survey set out

in the Transport Statement) and with the identified growth (such as the increase in

the number of in-patient beds; the increased levels of training required and new

palliative Centre of Excellence being established, confirms that this demand will only

increase. It should be noted that the Operational Statement also refers to the

potential future establishment of a children’s nursery, possibly within Nicholson

House. To confirm, the parking need set out in this application do not include the need

arising from this use, given that a children’s day nursery would require a separate

planning application to change the use of Nicholson House and also it is likely that any

parking requirements could be met within this site’s curtilage. However reference to

this has been retained to identify the areas that the applicant wants to expand into.

c) The proposed car park proposes no new building and the only built development will

amount to an internal access road, parking spaces and a footpath. Therefore there is


very limited physical impact on the openness of the GB compared to a new building.

Further, as suggested above, the top dressing, surface or finish of the parking bays

and access road could be controlled by a suitably worded condition. This would

further reduce the visual impact.

d) The fact that the site is so well screened from public vantage points and will not have

any harmful impact on the landscape setting of the AONB. Further, and as photograph

11 above confirms, given the site’s sloping topography, the new car park will not be

visible from Dorothy House itself.

e) The fact that there is no harm to the AONB setting of the site, the nearby Winsley CA;

an SSSI and Special Area of Conservation (SAC) as well as an Area of Archaeological

Interest. These issues are all summarised below and considered in detail in reports

accompanying the application.

f) The fact that there has been local support for the proposal from local residents who

will really benefit from more parking spaces at Dorothy House given that this will

significantly reduce the pressure on the existing on street parking in the village.

These reasons are considered to amount to very special circumstances that support the

proposal and justify the development in terms of its GB location.

Landscape considerations and the impact on the Cotswolds Area of Outstanding Natural

Beauty (AONB)

The site is located within the Cotswolds AONB and the pre-application response confirmed

that Core Strategy policy 51 was relevant where it stated that “Development should protect,

conserve and where possible enhance landscape character and must not have a harmful

impact upon landscape character, while any negative impacts must be mitigated as far as

possible through sensitive design and landscape measures”.

This policy also confirms that proposals need to demonstrate that they’ve considered the

objectives and policies in the Management Plan. In this respect, the Cotswold AONB

Management Plan (2013 – 2018) identifies the special qualities of the AONB, including the

limestone geology; the Cotswold escarpment; the high wolds (the large open elevated

commons); the river valleys; dry stone walls; flower rich limestone grasslands; broadleaved

woodlands; tranquillity of the area; and accessible landscapes.

The site is within the finger of the AONB within Wiltshire and identified as being within the

Low Limestone Plateau Character Type. Much of the site’s importance relates to its

biodiversity importance where the lowland and mixed deciduous habitat woodland prevail.


Image 4 - Extract from AONB Management Plan Landscape Character Types (site highlighted)

Management Plan DTP1 sets out the criteria that development in the AONB should meet:

Be compatible with the distinctive character of the location as described by the

relevant landscape character assessment, strategy and guidelines;

Incorporate designs and landscaping consistent with the above, respecting the local

settlement pattern and building style;

Be designed to respect local building styles and materials; there is no building as the

development proposes providing a car park to serve Dorothy House and therefore

no local building styles to replicate

Incorporate appropriate sustainability elements and designs; this is not considered

relevant given the nature of the proposal.

Have regard to the impact on tranquillity, including dark skies; low level, sensitive

lighting is proposed to light the new car park to enable staff and visitors to navigate

their way to the building. Given that the Hospice is open during reasonable working

hours, there will not be a need to light the car park late into the evening. Therefore

timers and sensors will ensure that the car park is illuminated only when required.

The Lighting Strategy prepared by Designs for Lighting also confirms that the

floodlights in the existing car park will be replaced with a low level, sensitive lighting

solution that retains dark corridors for bats.

Not have an adverse impact on local community amenities and services as well as

access to these; the proposed extension to the car park is generally supported by

the local community given the existing overspill parking problems that the current

arrangements create on the local highway.


protect, and where possible enhance, landscape and biodiversity; the proposal

includes a 3m wide landscape buffer which will be planted with local species rich

vegetation to provide a visual screen to the car park and also a haven for wildlife.

The type of planting is shown on the Proposed Landscape Plan (NVB drg ref: 2100

Rev C) and has been prepared in consultation with the ecologists ADAS who have

prepared the Ecological Appraisal.

Be in accordance with a more sustainable pattern of development, reducing

dependence on car travel. Given the nature of the proposal and the location of the

site, limited compliance with this objective can be demonstrated.

The issue of the impact of the proposal on the landscape setting and character of the site and

area is considered in more detail in the LVIA prepared by the Landscape Collective. However

overall, given the unique nature of the application and the applicant, the proposal complies

with this policy as a far as it possibly can. Where the proposal has not been demonstrated to

comply wholly with these criteria, the nature and reason for the proposal (namely to provide

additional parking to meet the current and future demand arising from Dorothy House) is

considered to outweigh any limited non-compliance. Further, the car park extension does not

introduce any significant new built form into the AONB and therefore will have a very limited

impact on its natural beauty.

Part 11 of the NPPF seeks to conserve the natural environment by protecting and enhancing

valued landscapes. Paragraph 115 places great weight on the conservation of the landscape

and paragraph 116 confirms that planning permission for major development (my emphasis)

should be refused except in exceptional circumstances and consideration should be given to

the need; the costs and scope for developing elsewhere; and the harm to the environment.

In respect of these three issues; issues relating to the need for the extended car park have

been considered in the case in support of the GB above and the reason why this is the only

alternative location has also been considered in the GB case. Issues relating to the harm to

the environment are considered in detail in the LVIA prepared by the Landscape Collective

and the Ecological Appraisal prepared by ADAS.

For these reasons, the proposal is considered to comply with the NPPF, policy CS51 of the

Core Strategy and the AONB Management Plan.

Transport, access, movement and parking issues

Issues relating to parking, access and movements associated with the proposed car park

extension are set out and justified in detail in the Transport Statement prepared by WYG. In

addition to the reconfiguration of the existing car park to maximise the number of parking

spaces that can be accommodated within it, the access into the site has been reconfigured to


enable easier access into the site. WYG drawing ‘Proposed Car Park Extension’ (ref A096365

– GA01) also suggests that double yellow lines can be added to the highway outside the

existing entrance to ensure that the safety, visibility and manoeuvring around the site

entrance is ensured.

Impact on the Winsley Conservation Area

Core Strategy policy 58 seeks to conserve and protect the special character of CAs, which are

identified as Heritage Assets (HA). The NPPF considers that the significance of the harm to the

HA should be assessed against the Asset’s significance. Notably, paragraph 134 states that

“where a development proposal will lead to less than substantial harm to the significance of a

designated heritage asset, this harm should be weighed

against the public benefits of the proposal, including securing its optimum

viable use”.

There is no CA Appraisal or Management Plan for Winsley which identifies any specific

features or characters. Therefore it is considered that general policies to protect the HA

should be considered. As the Local Plan Proposals Map extract above (image 3 – reproduced

below) confirms, the site is located outside the CA (noted by the blue hatching).

Image 3 (reproduced) – General location of the new car park the CA boundary

Image 3 confirms that the existing car park and Dorothy House itself are within the CA but the

new access road and car park are outside of it. Photograph 11 above is taken from within the

Chapel building (i.e. from within the CA) and confirms that the proposed car park will not be

visible. This is further confirmed by the Proposed Section Drawing A-A (ref: 2200 Rev A) which

shows the difference in levels.


Further, given the fact that there is no height to the proposed development (in other words it

involves a new hard surface car park) there, coupled with the fact that it will be well screened,

it is considered that there is less than substantial harm to the CA as a Heritage Asset and the

proposal is in accordance with CS policy 58 and the NPPF.

Ecological considerations

The site is very close to an internationally protected SSSI and a SAC important as a hibernation

site for rare Horseshoe bats. A Phase 1 Habitat Survey and Ecological Appraisal has been

undertaken by ADAS in respect of assessing the impact of the proposed development on

protected species.

Surveys carried out to date also seek to confirm the presence or otherwise of other species

including reptiles and badgers. The studies to date confirm the following:

Bats - Surveys to date have shown that different species of bat use the site including both

Greater and Lesser Horseshoe bat. They mainly use the woodland edges and hedgerows as

dispersal/foraging routes. These species are particularly adverse to light and the proposal

includes a sensitive lighting strategy designed with ADAS to ensure that it does not impact

bats or any other sensitive species.

Reptiles – Reptile surveys have been carried out by placing refuge mats around the site to

assess the presence or otherwise of adders, grass snakes, common lizards and slow worms.

Results to date have concluded that mitigation measures can be put in place to ensure that

the site is cleared in a way so that any species present vacate the site. The area of grassland

which will be developed into a car park is quite species-rich and our surveys have shown that

it is also important foraging habitat for Slow-worm (a relatively common species of reptile).

The development of the site can be controlled to ensure that there is no harmful impact on

these species. Also additional reptile habitat will be created to compensate for loss of the

grassland (in the form of a hedgerow, ditches and banks which will create refuge, foraging,

basking and hibernation habitat as well as a new foraging/dispersal corridor for bats).

Impact on trees

As the above photographs of the site confirm, the site is well screened by a substantial, mature

tree screen and the sylvan setting of the site’s surroundings forms part of its character.

Therefore an important part of the proposal is to ensure that there is no harmful impact on

these trees. For this reason an Arboricultural Impact Assessment has been prepared by

Silverback to ensure that the layout of the new parking areas and access road ensures does

not harm any important trees within the site.


A number of older, smaller and less important trees (notably trees T08, 09, 10, 11, 12, G13 as

identified on the Tree Constraints Plan) are being removed to enable the existing parking area

(notably the area around the smoking shelter) to be increased in size to provide more spaces.

The layout of the access road is located outside the Root Protection Area (RPA) of trees T03-

T07, T15 and T17 (given that these trees provide a screen for the site). The Report confirms

that the proposal will have no impact on the existing remaining trees and is therefore

acceptable in this respect.

Archaeological considerations

An Archaeological Desk Based Assessment has been prepared by Bristol & West Archaeology

in support of the application to consider and assess the impact of the proposal on

archaeological potential of the site. The report concludes that there is moderate potential for

the presence and survival of archaeological material within the site.

However given that the proposal is for a car park and doesn’t require deep foundations the

disturbance of this is considered unlikely. However as a precaution, during the construction

(especially the groundwork phase) monitoring might be recommended in order to record any

archaeological remains if they are present. Any remains are likely to be associated with early

prehistoric occupation, agrarian management and rural settlement of later prehistoric,

Romano-British, medieval and post-medieval date.

For these reasons the proposal is considered to comply with the objectives of the NPPF and

Core Strategy.


7. Summary and Conclusions

The proposal that is the subject of this application has been changed since the initial pre-

application enquiry was submitted in late 2015. This enquiry related to the development of

the adjacent playing field as a permanent extension to the car park. However the proposal

that is the subject of this application has proposed an alternative location, to the south of the

existing car park.

The existing car park will be reconfigured to ensure that the most efficient use is made of this

space to ensure that the amount of new parking spaces required is the minimum necessary

to enable the applicant to meet its existing and reasonable future demands. The location of

the site in the GB, Cotswold AONB and on the edge of the Winsley CA all offer landscape,

historic and planning policy constraints to the site’s development.

A number of alternative locations have been considered and the proposed location is the only

alternative. This Planning Statement has set out the very special circumstances justifying the

development in the GB. It has also, alongside the LVIA, confirmed that the proposal is not

harmful to the natural beauty of the AONB.

A comprehensive assessment of the efficiency of the existing car park and access and

movements in and around the site have been carried out by WYG who have proposed to make

more efficient use of the existing car park, re-prioritise the existing access and also proposed

to improve the visibility of the site entrance. Through the reorganisation and more efficient

use of the existing car park, an additional 39 parking spaces are created, including 9 disabled

parking bays. This minimises the land required for additional parking.

The need and demand for the additional parking has been quantified through parking surveys

and questionnaires of staff as well as from a detailed understanding of the applicant’s

Operational Needs, both now and in the future. The provision of a car park that is fit for

purpose for Dorothy House is an essential part of their infrastructure if Dorothy House Hospice

are to continue to provide specialist care to patients and families of those with life limiting

illnesses.

A number of other reports and studies have been commissioned in support of this application

which have confirmed that there is no unacceptable or harmful impact on the ecological

potential of the site and its surroundings; trees surrounding the site and the area’s

archaeological potential.

The proposal also has the general support of the local community. For these reasons, the

proposal is considered to comply with the overall aims and objectives of the Development

Plan and NPPF and should be granted planning permission.

town and country planning act 1990 (as … · dorothy house hospice care, winsley, bradford on...

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