PAPER B1
ISLE OF WIGHT COUNCIL DEVELOPMENT CONTROL COMMITTEE -
TUESDAY 2 APRIL 2002
REPORT OF THE STRATEGIC DIRECTOR OF CORPORATE AND ENVIRONMENT SERVICES
|
TCP/24342 P/01544/01 Parish/Name: Newport Registration
Date: 31/08/2001 -
Outline Planning Permission Officer: Mr. C. Boulter Tel: (01983) 823568 Change
of use of buildings & outline for retirement dwellings with ancillary
hydrotherapy, medical, leisure & social facilities, convalescent/nursing
facilities for over 50's; additional highways, ecological, landscape &
drainage information received (readvertised application) Whitecroft, Sandy
Lane, Newport, PO303EB |
This application was submitted in August 2001 and is a major application involving a departure from the Development Plan. Significant consultations with regard to highways and access, ecology, habitat and landscape, drainage and policy have been undertaken but there are still a number of outstanding issues. The relevant Health Trusts have not responded to requests for comments.
In view of the length of time that these
consultations and negotiations have taken, the applicants have exercised their
right to appeal to the Secretary of State because the Local Planning Authority
has not issued a decision on the application within the statutory
timescale. A second application has
been submitted in order that negotiations with the consultees can continue and,
hopefully, a decision made locally on that application.
Because this application has been appealed, the
Local Planning Authority can take no further action upon it. However, as part of its case at the Local
Inquiry due to be held in July, the Planning Authority will have to put forward
the view that it would have taken on the application, had it been in a position
to determine it. This report therefore
is before Members to give an opportunity for the Development Control Committee
to indicate what its decision on the application would have been, had it been
in a position to determine it.
Site and Location
Members will be familiar with the former
Whitecroft Hospital site which is in a rural location some 2 kilometres south
of Newport. Main access is off Sandy
Lane, which in turn has access off Whitcombe Road at Cox's Corner. Site comprises a central core of Victorian
red brick institutional style buildings with a Listed clock tower and a main
hall building. The remaining buildings
on the site although of some interest in terms of their local history, are not
Listed. There is a number of
residential properties (formerly occupied in connection with the hospital but
now private dwellings) around the periphery of the site, which also has
extensive wooded grounds. Most of the
buildings on the site are presently empty but the Isle of Wight Health Care
Trust does occupy one building in the west of the site and the Isle of Wight
Council (Education Department) occupies Thompson House whose grounds
immediately adjoin the northern part of the site.
Details of Application
Proposal is to create a "club type
lifestyle village" by the conversion of some buildings (Rhodes/Tennyson,
administration building and tower, main hall) to apartments, administration and
leisure buildings, with the construction of a further 210 individual units, 61
single storey, 116 two storey and 15 three storey in the grounds. Other buildings would be demolished. Generally, the three storey units would be
focused around the main buildings to be retained and the site of the existing
substantial Victorian ward buildings, with the single storey units towards the
periphery of the site.
A new internal access road would be constructed
around the central part of the site (where the main administration and communal
buildings would be) with a series of further access roads linking into the
groups of proposed new build accommodation.
The communal facilities will include health (doctors surgery,
dispensary, clinic, rehabilitation centre), sport and leisure (tennis court and
golf facilities), administration, education and daily needs provision. Further facilities for open air leisure
could be incorporated, subject to additional land acquisition to provide
fishing lake, par-3 golf course, allotments, croquet lawn and extension of
natural habitat of wildlife. The village
is intended to offer "a club type lifestyle for those over 50 in an
unrivalled quality of life setting."
As residents became less active and needed more care, this would in due
course be provided within the site which, the applicants indicate, would remain
a self contained community, with all the facilities needed for its residents
provided on site.
Any necessary improvements to access would be
provided, with discussions proceeding with a local bus company to ensure public
transport facilities of an acceptable standard are provided. The "village" will also have its
own mini-bus available for residents use.
The application, insofar as the construction of new buildings is
concerned, is in outline, with siting, landscaping and access not
reserved for future approval. A
subsequent reserved matters application would be required for the design and
external appearance for the individual units, before they could be
constructed. Full consent is sought for
the conversion of the buildings to be retained. Overall, the tower block (Listed) and admin block would include
restaurant, library, bar, reception, administration and snooker room at ground
floor, with three two-bedroom flats and one manager's flat at first floor. The retained Rhodes Tennyson building
would be converted to three one-bedroom, five two-bedroom and one three-bedroom
flats on ground floor with five two-bedroom and one three-bedroom flats at
first floor. The main hall (to the
south east of the clock tower) would be retained for recreation and leisure
whilst the laundry building and the Health Authority District Office would need
to be retained for the time being as the Authority holds options from the site
owner.
Where demolition is required, materials (bricks,
slates and tiles) will be stock piled for re-use in the new development.
Further documentation, including Traffic, Transportation and Sustainability Report, Landscape/Ecology/Rights of Way Report, Interim Drainage Report and Bat and Badger Surveys has been submitted in support of the application. It is indicated that the development would take place over four phases, each a year long. Each phase would see the construction of 50 units, thus an average of 1 unit per week. Refurbishment of the retained buildings would also be carried out phase by phase.
Development Plan and/or Zoning
Relevant national planning policy guidance is as
follows:
PPG1
– General Policy and Principles.
PPG3
- Housing.
PPG7
– The Countryside – Environmental Quality and Economic and Social Development.
PPG9
– Nature Conservation.
PPG13
- Transport.
PPG15
– Planning and the Historic Environment.
Relevant policies of the Isle of Wight Council
Unitary Development Plan (adopted May 2001) are as follows:
S1
- New Development will be concentrated within existing urban areas;
S2
- Development will be encouraged on land which has previously been developed
(brown field sites), rather than undeveloped (green field) sites. Green field sites will only be allocated for
development where they are extensions to urban areas and where no suitable
alternative brown field site exists;
S3
- New developments of large scale, will be expected to located in or adjacent
to the defined development envelopes of the main Island towns of Cowes/East
Cowes, Newport, Ryde and Sandown/Shanklin;
S4
- The countryside will be protected from inappropriate development;
S6
- All development will be expected to be of a high standard of design;
S7
- There is a need to provide for the development of at least 8,000 housing
units over the planned period. While a
large proportion of this development will occur on sites with existing
allocations or planning approvals, or on currently unidentified sites, enough
new land will be allocated to enable this target to be met and to provide a
range of choice and affordability;
S10
- In areas of designated or defined scientific, nature conservation,
archeological, historic or landscape value, development will be permitted only
if it will conserve or enhance the features of special character of these
areas;
S11
- Land use policies and proposals to reduce the impact of and reliance on the
private car will be adopted and the Council will aim to encourage the
development of an effective, efficient and integrated transport network;
G1
- Development Envelopes for Towns and Villages;
G2
– Consolidation and Infilling of Scattered Settlements Outside Development
Envelopes.
G4
- Criteria for New Development;
G5
- Criteria for Development Outside Defined Settlements;
G10 - Potential conflict between proposed
development and existing surrounding
uses;
D1
- Standards of Design;
D2
- Standards for Development Within the Site;
D3
- Landscaping;
D4
- External Building Works;
D9
- Works of Art, Artifacts or Architectural Features;
D11
- Crime and Design;
D12
- Access for people with disabilities to buildings that open to the public;
D13
- Energy Conservation;
D14
- Light Spillage;
B1
- Alterations and Extensions to Listed Buildings;
B2
- Settings of Listed Buildings:
B3
- Change of Use of Listed Buildings;
H1
- Major new housing development to be located within the main Island towns;
H2
- To ensure that large residential developments contain a variety of house
sizes and types;
H4
- Unallocated residential development to be restricted to defined settlements;
H6
– High Density Residential Development.
H9
- Residential Development Outside Development Boundaries;
H14
- Locally Affordable Housing as an Element of Housing Schemes;
C1
– Protection of Landscape Character;
C8
– Nature Conservation as a Material Consideration;
C17
– Conversion of Barns and Other Rural Buildings;
E8
- Employment in the Countryside;
P4
- Restoration of Derelict Land and Removal of Eyesores;
TR3
- Locating Development to Minimise the Need to Travel;
TR4
- Transport Statement Requirements for Major Development;
TR6
- Cycling and Walking;
TR7
- Highway Considerations for New Development;
TR16
- Parking Policies and Guidelines;
TR17
- Public Rights of Way;
U1
– Location of Heath, Social, Community, Religious and Education Facilities;
U2
- Ensuring adequate educational, social and community facilities for the future
population;
U3
- Appropriate location of education, community, social, health and welfare
facilities and the promotion of sharing and dual use;
U9
- Residential Care and Nursing Home Accommodation;
U11
- Infrastructure and Services Provision;
U12
- Water Supply for Firefighting Purposes;
L10
- Open Space in Housing Developments.
Whilst the site is to the south east of Sandy
Lane, the countryside to the north west of that road is designated as of
Outstanding Natural Beauty. To the
south east of the site is the Gatcombe withy bed SINC which is designated for
its woodland, wetland and species value.
A detailed planning brief for the site was
prepared by the two former Borough Councils in 1988 and this has been carried
through into the UDP as supplementary planning guidance, with the following
comment:
"Site
of former hospital in extensive parkland setting in the countryside. Principles of change of use or redevelopment
to employment, tourism or institutional uses appropriate but not residential
development. Buildings to be retained,
appropriate building footprint area and important existing landscape features
identified. Planning guidelines for the
site were prepared in July 1988".
A copy of the 1988 guidelines is attached for
Members information at Annex A.
Representations
Gatcombe Parish Council welcomes the application
and the uses and development proposed subject to appropriate phasing. Also requests that stringent conditions be
imposed concerning highway matters, environmental impact and the layout of the
buildings. Subsequent request to be advised of all relevant conditions which
may be applied to any consent granted.
Also request full consultation on any application for detailed planning
permission.
Highways Engineer considers proposal contrary to
policy TR3. Existing highway network
poor at this location; alignment of Whitcombe Road poor and junction of Sandy
Lane is at a bend. Speed limit is 60
mph and visibility at the junction is substandard. Traffic/transportation argument for allowing proposed development
based upon comparisons of traffic generation based on potential redevelopment
of the site against a minimum traffic generation use based on existing
residential homes traffic generation on the mainland. He continues that the theoretical capacities of a 7.3 metre
carriageway can accept the traffic flows generated by the proposed
development. No mention made of
environmental capacity. No doubt there
will be an increase in traffic movement on Sandy Lane and local residents
concerns regarding impact on the rural character of the lane is a matter which
falls outside the Highway Authority remit.
Junction improvements proposed would be of benefit and may require
additional details to address environmental appearance (e.g. redundant
carriageway areas at junction).
Improved signing should also include advisory signs regarding horse
riders and pedestrians in road. The
following transport improvements are offered:
Diversion
of bus route 6;
Bus
stop/shelter in centre of village;
Bus
lay by (not required by bus company);
Provision
of mini-bus;
Seven
day bus service.
Highways Engineer feels there should be greater
consideration to upgrading of all bus route facilities in terms of bus
stop/picking up and setting down facilities, passenger information etc. for the
entire route and its termini. A travel
plan agreement to secure the above items should be drafted. In particular details of length of time that
facilities such as bus diversion and mini-bus provision will be secured should
be approved. The proposed improvements
plus additions referred to above and highway and transport facilities mitigate
the Highway Authority's concerns regarding the impact to the proposed
development and subject to agreement for the off site highway work, he
recommends conditions requiring closure of the existing access to Sandy Lane, a
restriction on the number of visitors that can use the on site facilities (e.g.
proposed theatre), provision of new section of bridleway to the west of site in
consultation with the Rights of Way Section and improvement of the bus
turnaround details.
Environment Agency requested further information
regarding disposal route for surface water runoff, intended treatment of
watercourses in that information is insufficient in regard to intention for on
site stream corridor in that various changes to this stream, including
provision of bridges, are proposed. As
Agency has presumption against culverting and is unlikely to consent structures
that would negatively affect the existing water environment, the design and
siting of such structures should be addressed at planning stage.
Current sewage treatment works has discharge
consent issued by the Agency but proposed development may alter volume of
effluent to be treated and consent will require modification. Unclear from the submitted drainage report
whether the flow rates assumed in the design for the foul system take into
account flows at peak periods (mornings and evenings).
Further letter confirms Agency's request that
applicant/agent clarifies intentions for the on site stream corridor. Until details of any proposals which would
impact on the water courses and their corridors are received, along with
details of foul and surface water disposal previously requested.
Following discussions directly with applicant’s
agents, Agency has now written to indicate that, on the basis of the additional
information received, it has “no objection in principle to the proposal”. Conditions regarding provision and
implementation of a surface water regulation system, temporary protective
fencing along the top of the bank of all streams/ditches on the site, the
preparation of a water corridor management plan, to be agreed by the Local
Planning Authority, oil/petrol interceptors for all hardstanding/parking areas,
surface water systems and bunding for fuel storage tanks, should be imposed on
any consent which might be issued.
Southern Water expresses concern at the total
volume of effluent discharged from the site.
Any surface water currently connected to foul system must be
disconnected. Submitted information
does not give estimate of total daily volume from the site and an assessment is
required of the change in discharge when fully operational as a hospital (some
years ago) and what predicted discharge would be with the future development. Recommends developer requests a sewer
capacity check on the downstream public sewerage system to be undertaken by
Southern Water. This would only take a
few weeks and Southern Water suggest delaying the granting of planning
permission until a satisfactory result has been given to the capacity check.
English Nature are concerned that there are a
number of protected species (including red squirrel, dormouse and badger as
well as several bat and bird species) present at the development site. Proposed development might have detrimental
effects on these species and ecological survey should be undertaken determining
species concerned, population level, impact of proposal, mitigation, what can
be done in mitigation against impact, is the impact necessary or acceptable and
is a licence required from English Nature?
The Council's Ecology Officer considers proposal
unlikely to have impacts on either ecological features and protected
species. Further information will be
required to evaluate scale of these impacts.
He suggests basic information necessary in order to give proper
consideration of the likely environmental effects, based on which it may be
possible to demonstrate how to retain and incorporate with the development
existing habitats, species, buffer areas and landscape features of major
importance for wildlife; to compensate for features lost to development through
restoration, enhancement and the creation of new or additional buffers to
reduce impact; managing existing, restored and newly created habitats and
features of major importance for wildlife and monitor existing, restored,
enhanced and newly created habitats to ensure they are unaffected by the new
development and continue to function.
Principal Planning Officer (Development Plan)
has commented on the proposal in relation to national policies, the UDP and the
supplementary Planning Guidance. He
confirms that the clear intention of the guidelines is that the site should not
be used for permanent residential dwellings.
The location of new development outside the area defined in the
guidelines for building development means that the current proposals do not
accord with the first point of the guidelines.
The applicants original contention was that the proposed use will be a
residential institution, Class C2 "Use for the provision of residential
accommodation and care to people in need of care .....". However, his view is that as each of the
dwellings proposed will be occupied as a single household, each will fall
within Class C3, rather than Class C2 and this will therefore be outside the
guideline definition of institutional use.
Although the concept is that residents will continue an independent
lifestyle secure in the knowledge that personal and health care will be
available if needed, the agent now acknowledges that the proposal is a system
of housing. It is described as a
complete village comprising small housing units and communal and leisure
buildings. Although the site could be
said to be a mix of uses (D1, A1, C2 Nursing Home and C3 Residential Dwellings)
the applicants continue to refer to the hydrotherapy, medical, leisure and
social facilities being ancillary to the residential retirement dwellings and
this reinforces the view that the overall proposed use of the site should be
considered C3, with ancillary uses, rather than a specific institutional or
Class C2, use.
He concludes that the current proposals do not
accord with the guidelines for development of the site and exceed the area for
building development. The application
should be considered on its merits.
Housing development in the countryside is a departure from the UDP and
contrary to PPG3.
Recent advice from GOSE confirms that the
definition of housing covers all new housing development and includes special
needs housing such as that for the elderly.
It further confirms that the principles of location, design, mixed
communities described in PPG3 apply to all housing forms including special
needs.
PPG3 recognises that some residential
development may need to take place outside urban areas but sequentially,
expansion of existing settlements is seen as the next most sustainable option
after development of appropriate sites within urban areas. New settlements are seen as having the
potential to make a contribution to housing needs only where they are in the
right location, there is a shortfall in housing provision, they are large
enough to support a range of local services including schools, shops and
employment, they make use of previously developed land and the use of public
transport is encouraged. Overriding
this is that there is no more sustainable alternative. His view is that, of the above criteria, it
is only that part of the site which re-uses existing buildings meets the
current guidelines. The UDP makes
adequate provision for housing with allocations related to the Island's main
settlements. Residential development in
the countryside is contrary to the policies of the UDP unless in specific
circumstances which are not met by the current proposals. He concludes with a view that there is no
support for the current proposals either from the UDP or from national housing
policy.
The Isle of Wight Primary Care Trust, the Isle
of Wight Health Care NHS Trust and the Isle of Wight Portsmouth and South East
Hampshire Health Authority have also been consulted, but to date no responses
have been received.
Thirty six letters of representation have been
received from residents of Sandy Lane, Marvel Lane, Whitcombe Road, Gatcombe,
Shalfleet, Ryde, Billingham, Ventnor, Wootton Bridge, Shorwell, Newport. Also included in this total are letters from
Wight Wildlife, Wight Squirrel Project, the Isle of Wight Heritage and Field
Study Centre and the Whitecroft Residents Association. Some residents have written more than one
letter. A summary of the grounds of
objection made by or on behalf of third parties is attached to this report at
Annex B.
Evaluation
In determining this application, consideration
must be given to the following:
Policy;
Highways,
transportation and access;
Visual
impact and effect on character of the site itself and the surrounding area,
including amenities of nearby residents;
Sustainability
and transportation issues;
Effect
on Listed buildings within the site and their settings;
Effect
on ecology and habitat;
Drainage
issues, both surface water and foul sewage disposal;
Social
Issues.
All these are issues which have been highlighted
to some degree or another in the comments of consultees and third parties.
Policy
Section 54A of the Town and Country Planning Act
1990 requires that planning applications should be determined in accordance
with adopted policy, unless there are material considerations which would
indicate otherwise.
The view of the Principal Planning Officer
(Policy) is that this development should be seen as a housing development, with
associated ancillary facilities. The
fact that the occupation of the residential units may be limited to people over
50 years of age and that the ancillary facilities maybe aimed towards providing
an improved quality of life for these residents, does not justify the view that
the proposal is an institutional use in accordance with the principles of
alternative use set out in the planning brief for the site. I agree with these views.
I agree therefore that proposed development must
be tested against national and local policies for housing provision and in this
context, PPG3 and UDP policies G5, H1, H4 and H14 are particularly relevant.
PPG3 requires that Local Authorities adopt a
sequential approach when dealing with new residential development schemes. In the first instance, such schemes should
ideally be located on previously developed land within built up areas. It is only if such sites are not available
that consideration should be given to development of "green field"
sites, initially within, and subsequently outside but close to defined
settlements. Only if no sites are
available within these categories, should Local Planning Authorities consider
the development of sites outside development envelopes and then only if it can
be shown that there is an overriding need.
This principle supports the concept of creating and maintaining
sustainable communities, which minimise the need for the private car to be used
in order to access necessary facilities.
In this particular case, no sequential analysis
of available sites has been provided, although the proposed development is well
outside any defined development envelope or settlement and is clearly wholly
within the countryside. I agree that it
has to be recognised the site has a history of institutional use and that as it
has reached the end of its usefulness for that purpose, an alternative must be
found. The Council has recognised this
in its Supplementary Planning Guidance but is quite clear that a residential
use is not acceptable here, for reasons of sustainability. Policy H1 is quite specific that the
majority of new residential development will be expected to be located within
the defined development envelopes of the main settlements and that applications
for major residential schemes outside these settlements will not be
permitted. Similarly, policy H4 accepts
the principle of new residential development on the sites not allocated within
the Plan, providing they are within development envelopes of defined
settlements. Bearing in mind that the
proposal does not fall within one of the types of development that may
exceptionally be permitted outside the defined settlements in policy G5, it
could be argued that the proposal falls at the first hurdle as far as policy is
concerned.
The applicants however, have indicated that the
proposal should be considered as comprising a mix of uses, rather than an
exclusive C2 use. These uses include
shop (A1), restaurant (A3), close care apartments (ultimately the nursing/residential
home) (C2), residential units (C3), non-residential institutional (medical and
health services and use of the hall and health and leisure centre) (D1) and
assembly and leisure (D2).
Whilst they accept that the adopted guidelines
refer to the acceptance of development of those parts of the site which have
been previously developed, they point out that the definition contained in the
appendix to PPG3 includes land within the curtilage of the development. The application site involves only the
curtilage of Whitecroft Hospital, and therefore the whole area should be
considered as previously developed land.
Applicants agree that this does not mean that the whole area of
curtilage should be redeveloped but that, as stated in PPG3, "the Local
Planning Authority should make a judgement about site layout in this context,
bearing in mind other planning considerations....." The scheme does not envisage development of
the whole site and the applicants indicate dwellings and buildings have been
sited in order to preserve and protect the integrity of the site as a habitat
for bats, badgers and other wildlife, and also the Tree Preservation
Order. Applicants accept that the
application may be technically outside the UDP but contend that the UDP should
be construed in the light of PPG3 which states (inter alia) that "the
Government is committed to promoting more sustainable patterns of development
by making more efficient use of land by maximising the re-use of previously
developed land and the conversion and re-use of existing buildings."
Applicants contend that because this is not a
green field site, proposed development will maximise the use of the previously
developed land and minimise future requirements for development on greenfield
sites. The various reports submitted in
connection with the application are considered by the applicant to constitute a
justification for the proposed development in terms of sustainability.
Notwithstanding these views expressed by the
applicant I believe that the proposal is fundamentally an application for
residential development in the countryside.
The UDP addresses the issue of brownfield sites and the sequential
approach and states:
”Brownfield Sites and the Sequential Approach
In order to maximize land recycling to support sustainability and urban regeneration, brownfield sites for the purposes of this plan are defined as previously developed land within settlement boundaries. Previously developed land may be identified outside settlements but will be less sustainable in terms of access to jobs, schools and other facilities and will only be appropriate for countryside related development as set out in policy G5 of the UDP.”
Even if the premise that the site is a "brown field" site is accepted I believe that no approval should be granted for its development until it can be shown conclusively that there are no other sequentially superior sites available for development. Even if such sites were to be unavailable, I believe this application should be examined closely and no approval granted until it has been accepted that the scale and nature of development proposed is acceptable within the context of the agreed planning brief, the landscape, the surrounding road network and effect on the habitat and character of the area.
The development brief, adopted as supplementary
planning guidance in the UDP, makes it clear that residential development per
se is not an acceptable re-use of this site.
The guidelines also define an area where new development will be
acceptable, restricted to the general area of the existing buildings. As pointed out by the Principal Planning
Officer (Development Plan) this proposal should be considered as a residential
development, and new development extends outside the area of the existing buildings. Therefore, I agree that the proposal cannot
be considered as complying with the adopted development brief.
The development proposed involves the
construction of 192 new dwellings and the creation of 18 units by refurbishment
within existing buildings. Policy C17
of the UDP accepts the re-use and adaptation of rural buildings for employment,
recreational or tourism purposes but only accepts residential use if every
reasonable attempt has been made to secure a suitable employment, recreation or
tourism use for the building, or the residential conversion is a subordinate
part of a scheme for employment, residential or tourism use and the building is
of historic and architectural merit and conditions or agreements are applied
prohibiting further extensions, alterations or outbuildings.
The only Listed building on the Whitecroft site
is the combined water/clock tower itself which is Listed Grade II and is
attached to the administration block which is to be retained and
converted. Following its closure, the hospital has been marketed by the Health
Authority in the light of the planning brief but no offers of use for
employment, recreation or tourism use appear to have come forward. In those circumstances, and bearing in mind
the relationship between the administration building to be retained and the
Listed clock tower, Members may consider that proposal for residential re-use
of these buildings to be retained would, in isolation, comply with policy C17
of the UDP.
GOSE has confirmed that all housing schemes,
even those for “special needs”, fall within the definition of housing in
PPG3. In these circumstances, under UDP
policy H14, 20% of the housing proposed should be made available, at 50% of the
market value, to a registered social landlord.
No such offer is included in the application, as the applicants contend
that the scheme is providing specialist housing and as such should not be
“caught” by the policy. However,
bearing in mind GOSE’s advice, I consider that for the scheme to be acceptable,
it should meet the provisions of H14.
As it does not, this is a sustainable reason for refusal.
Overall, the proposal should be considered as an
application for major residential development in the countryside, and therefore
contrary to the aims of PPG3 and UDP policies S1, S3, S4, G1, G2, G5, H1, H4
and H14.
There are specific UDP policies relating to
matters such as transportation, development harmonising with its surroundings,
effects on ecology and wildlife, requirement for appropriate and adequate service
and utility provision and these will be considered individually in the
subsequent sections of this evaluation.
Highways, Transportation and Access
A significant amount of the third party
representations has expressed concern that the highway system serving
Whitecroft, particularly Sandy Lane, is inadequate to cope with the level of
traffic generation likely to be created by the development now proposed.
The applicants have submitted a traffic,
transportation and sustainability report which has been examined closely by the
Council's own Highway Engineers. The
conclusion of the applicants report is that:
The
total predicted development traffic movements would be significantly less than
were attracted to the existing established hospital use, when this was in full
operation;
The
alternative uses identified by the Council as being suitable, would result in a
higher level of traffic movements than the proposed retirement village;
It
is proposed to improve the existing highway in the vicinity of the site,
including the widening of part of Sandy Lane to the main site access, to allow
two-way working by all vehicles;
Carriageway
would be diverted into the site to discourage use of narrow section of Sandy
Lane to east of main site access and the secondary site access closed to
vehicular traffic;
Reconstruction
of junction of Sandy Lane with Whitcombe Road (Cox's Corner) to emphasise
priority of through traffic and control speed of vehicles entering and leaving
Sandy Lane;
New
signs and carriageway markings at the junction;
These
combined measures should substantially enhance access to the site and the
safety of the surrounding road network, for both the existing and future road
users.
A number of other issues are covered in the
report, including the provision of new sections of footpath and bridleway on
land to the west of the site to enhance pedestrian access from the site to
local leisure routes, a new bus stop and shelter to be provided at the centre
of the village to encourage use of the existing bus service by both residents
and visitors. Discussions with Southern
Vectis have resulted in an agreement that applicants will fund the additional
operating costs of diverting a bus route into the site for a period of 3-years
from first occupation. Southern Vectis
have confirmed they are happy in principle with the proposed access and bus
stop arrangements. A private mini-bus
will also be provided for exclusive use of residents and staff which will be
permanently funded from the service charge and will collect and return
employees as well as providing regular service for residents to local towns and
outside leisure facilities. All
residents and workers from the new retirement village will have access to a
range of means of travel by non-car modes and the conclusion of the study is
that there can be no reasonable basis to object to the proposed retirement
village development on highway, traffic and sustainability grounds.
The Council's Highways Engineer considers that
the proposed junction improvements would be a benefit, although environmental
appearance will need to be carefully considered. Improved signing should also include advisory signs regarding
horse riders and pedestrians in road.
The applicant’s study makes no mention of environmental capacity and
there will doubtless be an increase in traffic movement on Sandy Lane. However, impact on the rural character of
the lane, which is a matter about which local residents have expressed concern,
falls outside the Highway Authority remit.
It is clear from the Highway Engineer's comments
that he considers that the proposed improvements, including the diversion of
bus routes, the provision of bus stops and a lay by, the provision of a
mini-bus for residents and employees, a 7-day bus service and improvements to
the junction of Sandy Lane and Whitcombe Road are all significant benefits
which will mitigate against perceived disbenefits of the scheme. In particular, a travel plan agreement to
secure the improvements and to detail the length of time (suggested as 3-years
by the applicants) that the bus diversion would be available, would be an
essential element of any approval.
However, it must be said that the phasing arrangements proposed would
mean that the development would not be completed until after that 3 year period
expires. The need for public transport
will remain as long as the site is in use, and if additional finance is needed,
it should come from the development itself.
Highways Engineer considers that subject to an agreement for off-site
highway works, a travel plan and the public transport elements outlined above,
an approval could be issued, subject to conditions requiring the closure of the
existing access onto Sandy Lane, a restriction on the number of visitors that
can use the on-site facilities which may be open to the public, the provision
of a new section of bridleway to the west of the site and an improvement to the
bus turn round details, the application could be approved.
The increase in traffic above present levels
will have an environmental impact on the lane and the occupiers whose
residential properties front that lane, but this has to be seen in the context
of the traffic generation which a) would have been generated by the hospital
when operating at capacity and b) the level of traffic generation which might
arise should an acceptable development be proposed in the context of the agreed
planning guidance for the site. Having
said that, however, it is for the Local Planning Authority to decide whether
the intensity of development now proposed is acceptable and one of the criteria
to be used in judging this factor is generation of traffic. I do not think it is possible to say that
other uses, acceptable in the planning brief, will inevitably create a greater
traffic generation than the development now proposed. The Local Planning Authority will still have the opportunity to
make the judgement as to whether the intensity of development, within the
guidelines, is acceptable or not.
In this context, I have to agree with my Highway
colleagues regarding the technical acceptability of the development proposed in
highway terms, provided those recommended mitigating factors are covered by
agreement and condition. However, I do
have some reservations regarding the environmental impact of the additional
traffic in this countryside area, which the Highways Engineer has indicated is
outside his remit. Although I could not
recommend that Members refuse the application on technical highways grounds, I
do consider there would be grounds for refusal relating to the environmental
impact of the additional traffic generated, particularly bearing in mind the
nature of the access road and the site's rural location. The intensity of development proposed would
in my opinion result in a significant amount of traffic going to and from the
site, leading to unacceptable environmental impacts, contrary to policies S4
and G5 of the UDP.
Visual Impact and Effect on Character of Site
and Surrounding Area, Including Amenities of Nearby Residents
The present character of the Whitecroft site is
defined in longer views by the Clock Tower appearing above significant mature
wooded grounds and in the nearer views by the substantial Victorian
institutional red brick buildings set out in the shape of an anchor within a mature
parkland setting. The proposed
development is unlikely to have an adverse effect on these longer views.
The proposal is to demolish a significant number
of the former ward buildings, because they are considered by the applicants to
be unsuitable for conversion to modern residential units. Out of a total of 210 new dwellings, only 18
would be provided through conversion of existing buildings. This means that a 192 new dwelling units
would be created in the grounds, with the associated roadways, parking areas
etc. Although in outline, siting access
and landscaping are not reserved matters and so the Local Planning Authority is
now considering the precise positions of new buildings and access roads which
are proposed to be provided. A mix of
scale of buildings is proposed, with the three storey units (15 of them)
located in the central part of the site, single storey units (61) around the
periphery, and the remaining 116 two storey units, grouped in between. This has the effect of lowering the scale of
building the greater the distance from the centre of the site, and is thought
an acceptable basis for development, should a) the principle and b) the overall
amount of development be considered acceptable.
The site is the subject of a Tree Preservation
Order and the applicants have carried out a tree survey of all the protected
trees and have indicated that the layout of new buildings is designed as far as
possible to accommodate the retention of protected trees, groups of trees and
areas of important landscape and ecological features. A detailed levels survey has also been undertaken to minimise the
amount of grade changing required to accommodate the layout of buildings
proposed.
Applicants Landscape Consultants have indicated
that major blocks of planting and important individual trees would remain to
retain the "parkland" feel of the site and areas around new and
retained buildings would be "open plan" with few fences to divide up
the grass and planting. Large areas of
concrete and tarmac hard standings would be removed and in their place new
buildings surrounded by "soft" landscaped areas. The applicants consultants consider that
these will open up and benefit the site generally and that the whole site could
accommodate development when done sympathetically with due regard to areas and
aspects identified as important for nature conservation. Great care has been taken to ensure that
very few trees will be adversely affected.
Under the applicants tree survey, 14 of the 150 protected trees are identified
as at risk with care needed when dealing with levels in the vicinity of a
further 5 trees. A considerable number
of trees however, will require protective fencing, should the development be
carried out.
It is apparent that care has been taken to integrate
the proposed built development into the existing landscape. However, a large proportion of the current
parkland grounds will need to accommodate some form of building development, if
the scheme is to proceed. Although
designed and laid out in such a way as to minimise impact, there will clearly
be a significant change in character of the grounds and the setting of the
remaining former hospital buildings. In
my opinion, the character of the development would not result in the impression
of small groups of buildings, integrated into a mature landscape, rather it
will be of a significant amount of linked “semi-suburban” buildings, thus
significantly changing the character of the grounds.
Although I accept that, in landscape terms, the
grounds can accommodate some additional built development without adversely
affecting its character, I believe that the amount of development now proposed
and the fact that it extends across virtually all the parkland setting of the
hospital, is unacceptable and that adverse impact on the character of the area
would ensue, contrary to policies C1, G4, G5 and S4 of the Isle of Wight
Unitary Development Plan.
As far as impact on occupiers of nearby dwelling
houses is concerned, there is clearly, as referred to in the representations
received, a perception that there will be an increase in the amount of traffic
using Sandy Lane as a result of the development now proposed.
As indicated in the Traffic and Transportation
section of this report, it must be accepted that there will be an increase
above the levels presently generated by the uses within the site, but against
this must be set the view of the Highways Engineer, that, with improvements and
appropriate conditions, the road network is technically adequate to cater for
the additional traffic anticipated.
However, residents are concerned that the inevitable increase in
vehicles will lead to an increase in accident risk and therefore adversely
affect their amenity. Although fear of
adverse effects from development can in certain circumstances be a material
consideration in determining a planning application, in this particular
instance, bearing in mind the technical advice available, I do not think that a
reason for refusal on this basis could be easily substantiated.
The nearest dwelling houses to the perimeter of
the site are "The Pines" and "The Lodge." The southern boundary of "The
Pines" is reasonably well treed and the adjoining proposed development
would comprise two storey dwellings, some 10 metres from the common
boundary. A parking area would also be
created adjoining the south east corner of that property's curtilage. I consider that the relationship between
existing and proposed dwellings in this part of the site would be acceptable
and would not of itself lead to any sustainable reason for refusal. Between "The Pines" and "The
Lodge" is a "finger" of land some 45 metres long with a frontage
to Sandy Lane of about 38 metres and a minimum width at its southern end of
about 17 metres. It is proposed to locate
two pairs of two storey dwellings in this area, with the northern two obtaining
vehicular access directly from Sandy Lane.
Whilst the upper floor of the northern pair would have some oblique
overlooking of the rear part of the garden of “The Lodge”, and the upper floors
of the southern most pair, about 42 metres from the rear elevation of “The
Lodge”, would also obliquely overlook its rear garden, I do not think there is
sufficient direct loss of amenity from these relationships to warrant a refusal
of the layout as now suggested.
Some 8 metres from the rear garden boundary of
"The Lodge" is proposed the north western end of a terrace of four
single storey dwellings, whose rear windows would look obliquely towards the
bottom end of the garden to "The Lodge." In view of the fact that the proposed dwelling is single storey
and the distances between dwellings, I do not consider that there is sufficient
weight in any objection to the layout of this part of the site to warrant a
refusal on grounds of adverse effect on amenity of nearby residents.
Sustainability
One of the principles of PPG13 is that new
development should be located so as to minimise the need to travel and to
reduce reliance on the private car. UDP
policies follow this presumption, particularly policies S1 and S3 which
indicate that new development will be concentrated within existing urban areas
and that new developments of large scale will be expected to locate in or
adjacent the defined development envelopes of main towns. Similarly, policy TR3 requires the location
of development in such a way as to minimise the need for travel and this point
is referred to by the Highways Engineer in his advice that the proposal is
contrary to this particular policy.
This is a relatively remote rural location
which, whatever alternative use is finally agreed for the former hospital
buildings, will rely to a certain extent on the private car for access
purposes. The package of measures put
forward by the applicants, including the re-routing of scheduled bus services
through the site and the provision of a mini-bus for the exclusive use of
residents of the site are in recognition of the need to follow national and
local policy by providing alternatives to the private car. It must however be accepted that not every
resident or visitor will be able or willing to take advantage of the public
transport and mini-bus alternatives on offer and, the larger the scale of
development, the greater the number of private car journeys that are likely to
be generated. As the proposal is a new
development which would clearly create significant travel demand, under policy
TR3 of the UDP, it should be located within an existing defined settlement and
be easily accessible by public transport, bicycle and on foot. The site is not within or even adjoining an
existing defined settlement and although ease of access by public transport
will be increased as a result of the proposal, access by bicycle or on foot
will, for the majority of population, not be a realistic likelihood.
Therefore, I conclude that despite the
additional public transport provision which the applicants have been able to
negotiate, the proposal does not comply with policy TR3 because it is likely
that a significant number of additional car journeys is likely to be generated.
Effect on Listed Building
The only Listed building within the site is the
Clock/Water Tower, which was Listed Grade II in 1987. Following the submission of this application, English Heritage
has been asked by one or more third parties to consider Listing the remaining
buildings on the site, including those which are proposed for conversion and
those proposed to be demolished. To
date, there has been no indication from English Heritage as to whether further
Listings are likely, but it must be borne in mind that following a specific
inspection in 1987, only one of the buildings was thought worthy of Listing.
The proposal is to keep the Clock Tower, with
appropriate repairs and although an adjoining ancillary building would be
removed, the main administration building attached to the Clock Tower would be
retained. To the south east of the
tower, the existing single storey pitched roof building attached to the base of
the tower will be removed and a new apartment building constructed. No details of this apartment building are
submitted and no indication given of the number of apartments proposed other
than, in the three new apartment blocks proposed, eighteen flats altogether are
to be provided.
Policy B1 (Alterations and Extensions to Listed
Buildings) of the UDP sets certain standards and criteria which new development
on Listed Buildings should achieve. In
the absence of design details, it is not possible to ascertain exactly what the
impact of the new development on the setting of the Listed Clock Tower would be
and therefore the proposal in this respect is considered contrary to policy B3
of the UDP.
Effect on Ecology and Habitat
The applicants have submitted three reports in
relation to ecology and habitat and this has been a particular issue raised in
third party comments.
It is confirmed that red squirrels use the site
certainly for periodic feeding and it may form part of a larger territory. Applicants intend to retain as many pine
trees and trees/shrub corridors as possible and develop new planting areas of
pine and hazel in order to integrate with existing vegetation inside and
outside the site. No evidence of
dormice has been found although there are areas which would provide good habitat. Applicants indicate proposals would ensure
hedgerows and grass banks alongside the stream would remain virtually intact and new
native planting areas would contain a good percentage of hazel.
The Wight Squirrel Project confirms the status
of red squirrel and dormouse populations in the grounds of Whitecroft
and the surrounding area. They confirm
two records of sitings in the hedgerow on the southern boundary in the summer
of 1999 and the following winter. The
hedge was still being used by dormice in December 2001. Although the project would trust that any
development plans would take these species and others into account, a problem
is foreseen of an influx of cats and dogs which can have a devastating effect
on any wildlife living in or near residential development.
No evidence of water voles has been found
although again the stream and its adjacent banks would be a good habitat. A rich variety of insects and birds is
likely within the site and applicants indicate they would make every attempt to
recreate any habitat lost as a result of the development. No reptile information has been obtained.
Specific reports have been submitted by the
applicants in respect of badgers and bats.
This information confirms the existence of badger setts in and near the
application site and although these locations have not been identified in
public documents, it is clear there is a main sett within an area affected by
possible development in the future. The
Council's Ecology Officer has confirmed that this issue has yet to be resolved
although the applicants consultant does make recommendations for mitigation
including retention of sets in specific locations, or the construction of an
artificial sett where development unavoidably impacts on an existing site.
Reports confirm that several of the existing
buildings contain bat roosts. No
meeting has yet been undertaken with English Nature to discuss the constraints
(including timing of demolition works) and mitigation. English Nature advise that these matters
cannot be dealt with solely by condition but require to be addressed as part of
the planning process. Bats are now a
European protected species under the Habitat Regulations and any works
affecting them will require a Development Licence from DEFRA.
The Council's Ecology Officer identifies a
further unresolved issue which is the requirement or otherwise for a flood
attenuation pond in connection with the built development. At present if a flood attenuation pond is
required, its location is shown outside the site boundary for the current
application, on land which may possibly be acquired by the developers in the
future. If such a pond is required and
has to be located within the current application site, there are significant
environmental constraints on location and there have been no discussions to
address this issue.
Whilst it is clear that the applicants have paid
considerable attention to the need to protect wildlife habitat, particularly of
protected species, within the development proposals, the absence of final
resolution of issues raised by the County Ecology Officer, i.e. exact location
of any flood attenuation, mitigation of effect on bats and the acceptability or
otherwise of mitigation/replacement of identified and affected badger sets, it
is my view that proposal in its present form does not comply with policy C8 of
the UDP in that it has not been possible to confirm that the proposals do not
adversely affect protected or endangered species and their habitats.
Drainage Issues
Applicants submitted drainage report is an
"interim" report evaluating the drainage discharge requirements of
the development. This report confirms
that liquid effluent from the site is pumped by two submersible pumps via a 150
mm diameter pipeline to discharge into the public sewerage system for treatment
by Southern Water. The design flow is
15 litres per second. The pumping
station was renewed circa 1994 to serve the former hospital site including the
laundry and associated houses, cottages and offices. Although designed to adoption standards, it is understood the
pumping station has always been owned by the owner of the site together with
the pipeline and easements over the land along its route to the public sewerage
system.
The system has, it is understood, been
maintained since installation but this will need to be checked. Records of maintenance or troubles that may
have occurred in the past will be used to ascertain the future maintenance and
replacement regime.
Commercial/industrial life of a submersible pump is generally accepted
to be in the region of 12 - 15 years, so the pumps are three quarters or two
thirds into that timescale.
Flow calculations for the future requirements
for effluent disposal have been carried out and calculations indicate that a
flow rate of about 8 litres/second is anticipated. In addition, backwash from the proposed swimming pool which might
occur two or three times a week could produce a further 6 litres/second.
The conclusions of the study are that on the
basis of that information and the length of travel for the pumped rising main,
the existing pumps will be suitable for the proposed future inputs. Certain operations will have to be
controlled, such as avoiding backwashing of the swimming pool filters on days
when conferences are held at Thompson House.
As far as surface water is concerned, it is
understood this runs off to local watercourses although a small quantity may be
discharged to the pumping station. This
is currently being investigated.
However, the proposed development will involve the demolition of large
buildings and car park/hardstanding areas with the result that the surface
water runoff to be dealt with is unlikely to increase from its present
value. If further land is acquired for
construction of a golf course and fishing lake, the latter facility will be of
considerable benefit in balancing any surface water runoff in times of heavy
rainfall.
The consultants recommendation is that if
planning approval is granted, a further detailed investigative study is
undertaken to establish the extent of use of the private sewer by any of the
surrounding properties whether they are commercial or residential in
nature. This would provide information
necessary to secure the basis for an operational business plan for the
lifestyle village and for the ongoing design work.
Copies of the interim drainage report have been
sent to both the Environment Agency and Southern Water. At the time of writing,
Southern Water has expressed concern at the total volume of effluent discharge
from the site. Any surface water
currently connected to the foul system must be disconnected. Southern Water suggest that what is required
is an assessment of the change in discharge from when the site was fully
operational as a hospital and what the predicted discharge would be with the
future development. The developer
should request Southern Water to carry out a sewer capacity check on the
downstream public sewerage system.
Southern Water suggest delaying the grant of
planning permission until a satisfactory result has been given to this capacity
check.
The Environment Agency’s concern at the
possibility of structures being erected in the watercourse corridor on the
south west boundary of the site has been addressed and the applicants agent has confirmed that there
are no proposals for any structures crossing the stream within the application
site. The Agency’s objection to the
proposal has therefore been removed, providing conditions are imposed on any
approval.
The applicants agent is aware of these
requirements and has been in ongoing discussions with Southern Water. However, at the time of writing, all these
issues have not been resolved and therefore the Planning Authority cannot be
assured that adequate foul and surface
water drainage provision can be made.
Therefore, until this issue is resolved, the proposal cannot be
considered compliant with policy U11 of the UDP.
Social Issues
The proposal is for a specific "lifestyle
village", with a restriction to occupation of the proposed dwelling units
by people over 50 only. It is
anticipated, that as residents become older and need more care, this care will
be provided on-site through the facilities (e.g. pharmacy, doctors surgery,
clinic, nursing provision etc), with eventually, dedicated nursing home
provision within the site.
There would also be "club type"
facilities including par three golf course, library, bar/cafe, theatre,
post-office style shop, hobbies room, hairdressing/beauty salon, billiard room,
launderette, computer room, croquet lawn and bridge club. Provision of some of these facilities may
depend on the acquisition of additional land, should planning permission be
granted. However, of principal concern
is the fact that in this rural location, a community of people aged 50 plus,
will require increasing levels of care, and if this type of facility is to be
approved, the Local Planning Authority will need to be assured that adequate
social and community facilities are available in an appropriate location for
the future population (policies U2 and U3).
It will also be necessary to be assured that present service providers
in the nearest communities will be able to provide an appropriate level of
service, should it be necessary, if the development is approved.
The applicants have indicated satisfactory
discussions with health and social service providers, and contend that all such
requirements can be met within the site by the provision of appropriate health
and nursing care facilities, funded from the service charge payable by
residents. In order to seek further
information in this particular area, comments were invited from the Isle of
Wight Primary Care Trust, the Isle of Wight Health Care NHS Trust and the Isle
of Wight Portsmouth and South East Hampshire Health Authority, but to date no
comments have been received from any of these bodies. In view of these consultations, no specific request has been made
for views from a Social Services perspective.
This is also an issue which has been raised in
representations, particularly the idea that residents would be attracted from
the mainland to live in a "life-style village." Of course, planning policy cannot dictate
the origin of residents of any housing scheme unless there are nomination
rights given to the Housing Authority by a Housing Association or similar
registered social landlord. In this
case, those rights are not proposed, although the applicants have indicated in
their supportive information that research has discovered that in similar
"life-style villages" elsewhere, 75% of the residents originate
within a 15 mile radius of the site.
In the absence of formal comments by the health
care consultees, it is not possible to confirm that adequate social facilities
are provided, in a suitable location, and therefore the Local Planning
Authority cannot be assured that the proposal complies with policies U1 and U2
of the UDP.
Conclusions
This proposal is for
a significant, albeit specialist, residential development in the grounds of an
unused former hospital building in the countryside. Proposal does not comply with the planning brief for the area in
that the development is proposed outside the area suitable for building,
defined in the brief and is for residential, rather than institutional,
business, holiday, sports and leisure, conference, exhibition or country park
uses. It does not comply with the
principles of sustainable development set out in PPGs 3 and 13 and is contrary
to policies of the UDP relating to residential development in the countryside
and seeking to minimise the need to travel by private car. The development would adversely impact on
the character of the site and its landscape and significant questions regarding
drainage, ecology, habitat and health support facilities remain unanswered at
present.
Had the Local Planning Authority
been in a position to determine the application, I would have recommended
refusal for the reasons set out below.
That the applicants
be advised that, had the Local Planning Authority been in a position to
determine the application, it would have been refused for the following
reasons:
1. The
site is in the countryside, outside any defined development envelope and no
sequential analysis has been undertaken to show why this site should be
developed for residential purposes before other suitable or available sites and
the proposal is therefore contrary to the provisions of Planning Policy
Guidance Note 3 (Housing).
2. The
site is in the countryside and outside the development envelope as defined in
the Isle of Wight Unitary Development Plan, and the proposal for residential
development of the scale proposed is considered by the Local Planning Authority
to be inappropriate in the countryside and therefore contrary to policies S1,
S3, S4, G1, G5, H1, H4 and H9 of the UDP.
3. The
development proposed is for residential development with ancillary facilities,
and involves the construction of dwellings outside the area defined as suitable
for development in the planning brief, adopted in the Unitary Development Plan
as Supplementary Planning Guidance.
4. The
proposal makes no provision for affordable housing as required by policy H14 of
the Isle of Wight Unitary Development Plan, and approval would therefore be
contrary to that policy.
5. The
development proposed would, in the opinion of the Local Planning Authority, be
likely to lead to a significant amount of traffic being attracted to the site,
the environmental impact of which would be unacceptable, bearing in mind the
rural nature of the access roads and the proposal would therefore be contrary
to policies S4 and G5 of the Unitary Development Plan.
6. The
proposal would result in adverse impact on the visual amenity and character of
the area, contrary to policies S4, C1, G4 and G5 of the Isle of Wight Unitary
Development Plan.
7. The
proposal would create a significant area of residential development in an
isolated rural area, leading inevitably to an increase in journeys to and from
the site by private car, contrary to the provisions of PPG13 and policies S11
and TR3 of the Isle of Wight Unitary Development Plan.
8. In
the absence of detailed drawings, the Local Planning Authority is not satisfied
that sufficient information has been submitted to assess the impact of the
proposed new apartment block adjacent the Grade II Listed clock tower and
therefore is not satisfied that the proposal complies with policy B1 of the
Isle of Wight Unitary Development Plan.
9. The
Local Planning Authority is not satisfied that sufficient information has been
submitted to be assured that the proposals do not adversely effect protected or
endangered species or their habitats, and therefore the proposal does not
conform with policy C8 of the Isle of Wight Unitary Development Plan.
10. In
the absence of a full sewer capacity check, the Local Planning Authority is not
satisfied that adequate foul and surface water drainage provision can be made,
and therefore the proposal is contrary to policy U11 of the Isle of Wight
Unitary Development Plan.
11. The
Local Planning Authority is not satisfied that the proposal provides adequate
health care provision for the specialist age group residents for which the
scheme is proposed and therefore cannot be assured that the proposal complies
with policies U1 and U2 of the Unitary Development Plan.
Strategic Director