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Case
submitted for the National Society for Epilepsy (NSE)
Documents submitted include:
- Executive Summary - case for development
- Supporting Planning Statement
-
Assessment of Local Infrastructure
- Financial Appraisal
-
National Needs Case
-
Landscape Appraisal and landscape assessment
-
Transportation Statement
Executive
Summary - Case for the Development
The NSE, Chalfont St Peter is the only organisation in the UK which
provides a fully comprehensive range of services for adults with
epilepsy, including residential care for people with 'complex' or
'severe' epilepsy, and state of the art technology.
The
NSE was established in Chalfont St Peter in 1893 with the purchase
of Skippings Farm. Today the centre is home to 220 adults
The
buildings are dated and fall short of the standards introduced in
the Care Standards Act, 2000. If the NSE does not comply with these
standards then the residential care homes will be forced to close
by the Care Standards Commission. The NSE has been issued with a
clear ultimatum in terms of achieving these standards.
The
only viable option open to the NSE to raise monies required to fund
the redevelopment of its facilities is to seek planning permission
for development within its grounds and then sell the land to a developer.
This is referred to as the 'enabling development'. The NSE is proposing
up to 218 houses and 2 private care homes as an enabling development.
In
arriving at the conclusion that an enabling development is the only
option, the NSE has addressed all other possible scenarios. It is
not possible for financial reasons to relocate. The financial work
to justify this statement is addressed it in the NSE's National
Needs Case and further supported by valuation work undertaken by
ATIS REAL Weatheralls.
Supporting
Planning Statement
The applicant draws attention to the following matter: Whilst the
site lies within the Green Belt, the inspector at the last Local
Plan Inquiry recommended that the majority of the site should have
been taken out of the Green Belt. The parcel of land which was not
proposed to be taken out of the Green Belt is well related to the
urban area in any event, contained by existing built form and fulfils
no strategic Green Belt function.
The
NSE's 'very special circumstances' case is exceptional, and
predicated on protecting a national interest. The need for improved
healthcare provision is an important material planning consideration
and also comprises very special circumstances to justify inappropriate
development in the Green Belt.
The
application addresses the matter of a defensible Green Belt boundary
and proposes strategic landscaping to the east, and an approach
wholly in accordance with the aims and aspirations of the Colne
Valley Park.
The
proposal accords with all other relevant development plan policies;
complies with PPG3 and PPG13 and will deliver a high quality built
form.
Location
and description:
The site is located to the northeast of Chalfont St Peter. This
site's principal access faces directly onto Monument Lane and the
site is bounded on its western side by residential development on
Chesham Lane. The site is also contained on its southern side by
residential development fronting Cross Lanes and Rickmansworth Lane.
Skippings Farm marks the northern most extent of the built form.
The NSE has a land holding of 137 hectares, shown on blue line and
the outline application comprises 20.24 hectares. The total foot
print of all the existing buildings on site is 31,851sq.m and total
floor area is 37,740sq.m
The
Development Plan and History of Green Belt designation:
Bucks County Council Structure Plan:
Applicants have submitted representations on behalf of the NSE in
respect of the emerging Structure Plan as follows: an objection
that it contains no policy to support the provision and maintenance
of social infrastructure. The NSE promoted new policy to state:
'the provision of new and redevelopment of land and buildings to
meet the needs of the County's social infrastructure will be supported.
Such infrastructure may include, but not limited to health and other
community care facilities.'
Additions to Policy 8 to read 'operational land at the NSE complex
at Chalfont St Peter to be taken out of the Green Belt to ensure
development can be provided in the national and public interest.'
And
'Any development within the Green Belt, other than appropriate development,
will require to be justified as very special circumstances or as
development in the context of Major developed site status'.
Adopted
Chiltern District Local Plan - 1997 (including Adopted Alterations
May 2001). The policies taken in to consideration are the General
Criteria for Development, Housing Policies; and Green Belt policies,
in particular GB2.
It
is accepted that the proposed development is inappropriate and justification
of the application rests on very special circumstances, in particular
the requirement for enabling development and other material factors
detailed later in their statement. In terms of the Green Belt considerations
they highlight the relevance of the history behind the sites continued
designation as Green Belt.
History
of Site's Green Belt designation:
In the past, the Local Planning Authority, at officer level, has
acknowledged that it would be sensible to take the site out of the
Green Belt. This recommendation was endorsed by the Local Plan Inspector
in September 1996, following a detailed consideration of the evidence.
However, the recommendation was not accepted by elected Members
on the basis that it was not felt that the site was able to provide
a defensible Green Belt boundary.
The
applicant draws attention to the point that this is a highly pertinent
aspect of the sites history which has an important bearing on the
Green Belt judgement that needs to be made at this stage.
The
Planning Issues cover the following matters:
- The Green Belt and the NSE's very special circumstances case
- Transportation
- Compliance with PPG3
- Affordable housing
- The enabling residential development environment
- Local residential amenity
The Green Belt and the NSE's very special circumstances case:
The proposal is inappropriate development in the Green Belt and
therefore the NSE must demonstrate very special circumstances in
order to justify the grant of planning permission as follows:
The
very special circumstances case is based on the following:
i) the need for the development;
ii) the absence of harm to the openness of the Green Belt, the objective
of the Green Belt policy and the purpose of including land in the
Green Belt; and
iii) adherence to the Colne Valley Park's aims and aspirations.
Transportation:
Technical Issues: The Transport Statement by Denis Wilson Partnership
concluded that there will be no prejudicial impact on the local
highway network either in relation to access standards or the capacity
of the local road network to cater for additional traffic. The Applicants
are willing to enter into an agreement under Section 278 in relation
to improvements to the junction with Chesham Lane and Rickmansworth
Road to secure the benefit of a highway safety improvement.
Sustainability: The Transport Statement by Denis Wilson Partnership
has addressed issues of sustainability advised by PPG13.
Compliance
with PPG3:
Sequence to be applied to the Planning of Residential Development:
With regard to paragraph 30 of PPG3 which advises in relation to
the sequence to be applied to housing development, the application
is entirely in accordance with prevailing government guidance. Accords
with the fourth bullet point of paragraph 31 of PPG3.
A substantial
proportion of the enabling development is proposed on previously
developed land and buildings.
There
is sufficient capacity in the existing infrastructure, including
public transport, water and sewerage, other utilities and social
infrastructure to meet the developments demands. We confirm that
reasonable contributions related to the development, in accordance
with Circular 1/97 have been costed in the enabling calculations.
Density:
The enabling residential development exceeds 30 dwellings per hectare
and therefore compliant with paragraph 58 of PPG3.
Housing
Need: The Deposit Draft Bucks Structure Plan 2003 states that an
allocation of 600 dwellings in Chiltern District is required between
2001 - 2006, and the enabling residential development contributes
to the need for additional housing stock.
Affordable
Housing: Application proposes a 20% affordable housing obligation.
Enabling
residential development: Whilst this in an outline application only,
the NSE confirms that the development will be of a high standard
and will have due regard to the character of the area.
Local
Residential Amenity: Whilst this is an outline application only,
the NSE confirms that the development will not be harmful to the
residential amenity of the locality. Landscaping is proposed, suitable
distances from existing dwellings and appropriate access ways are
proposed.
National
Needs Statement
By Graham Faulkner, Chief Executive of the National Society for
Epilepsy
The
NSE is a registered charity (No.206186), founded in 1892, for the
purpose of 'creating a home and industrial colony for such epileptic
persons as are capable of work but unable to obtain regular employment
on account of their liability to fits'.
Today
the aims of the Society are encapsulated in its Mission Statement
which states:- 'The NSE's mission is to enhance the quality of life
of people affected by epilepsy by promoting research, education
and public awareness and by delivering specialist medical care and
support services.'
Deriving
from the mission, the Society's primary objective is:-
'to provide both nationally and internationally for the maintenance,
care, treatment, education, occupational training, occupation and
employment of people with epilepsy'.
Other
Epilepsy Centres: There are only 7 specialist centres in the UK.
Apart from the NSE, none has a comprehensive range of services for
adults with epilepsy. The NSE is a unique integrated health and
social care centre; the only one in the UK providing assessment,
medical treatment, research, care and rehabilitation on one site
for adults with complex epilepsy.
NSE's
Services:
Residential accommodation: The NSE is home to over 220 adults aged
18 - 90 with the most severe and complex forms of epilepsy. Because
of the severity of their epilepsy, residents at the NSE are in the
highest risk groups. They benefit from integrated, holistic medical
and social care with immediate access to the most advanced epilepsy
treatments in the world.
Other
services include: day, leisure and therapy services; medical assessment
and nursing services, research, information and advice. The centre
has 573 staff and much of the accommodation for the staff is of
poor quality.
Relevant
standards - impact on the NSE:
The Care Standards Act 2000 introduced minimum care standards with
which all registered care homes must comply. In 2001 the Society
commissioned a report by Head Projects, a firm with experience in
the design and redevelopment of care homes to provide an assessment
of the layout and accommodation of all the Society's residential
homes against the national minimum care standards.
The
report received in October 2001 concluded that 'all of the existing
homes are in sound condition and a reasonable state of repair having
required some form of refurbishment over the last 10 years. However
it went on to conclude that:
a.
All homes will fail to meet the minimum standards required for disabled
people
b. All first floor accommodation will fail to meet the minimum standards
for accessibility
c. In four homes less than 50% of the bedrooms will meet the minimum
standards size
d. In a further four homes less than 75% of bedrooms will meet the
minimum standard size
e. The minimum standard required for wheel chair users of 12 sq.m
in bedrooms and a combined communal space total of 17.1sq.m cannot
be achieved'.
A letter
from Gill Jeffers, The Buckinghamshire Area Manager of the National
Care Standards Commission dated 7 August 2003 stated:
'Since April 2002, the inspections carried out at the homes on the
NSE site have highlighted a number of areas where they do not come
up to standard. Under normal circumstances a home would be set a
requirement to put matters right within an agreed timescale. Failure
to act may result in prosecution and ultimately a home's closure.
The NCSC have been informed fully about the NSE's proposals for
renovation and as such are in the process of agreeing necessary
remedial work to be carried out while the renovations of the NSE
become a reality, thus safeguarding the site's and service users'
immediate future. I cannot emphasise enough the importance of this
work going ahead. The future of the NSE and the people who live
there depends on it'.
She
went on to outline six specific environmental standards that the
home failed to meet, namely:
| Standard
21.3 |
Existing
larger homes such as those at the NSE are to be organised into
clusters of up to 10 people sharing a staff group, dining room
and other communal facilities by 1 April 2007. |
| Standard
24.11 |
Premises need to meet Part 3 of the Disability Discrimination
Act |
| Standard
25.4 |
Specifying
the size of bedrooms |
| Standard
26 |
The
requirement for bedrooms to provide sufficient room for two
comfortable chairs, low level windows so that wheel chairs can
look out and individually controlled heating |
| Standard
28 |
The
requirement for shared spaces of sufficient size and design
for shared and private use, e.g. domestic kitchens and laundry
facilities and private spaces for visitors |
| Standard
28 |
The
requirement to provide environmental adaptations and disability
equipment, e.g. overhead tracking for hoist, stair rails, bathing
equipment, lowered work surfaces etc. |
Gill
Jeffers concluded that the NSE fails to meet these six standards
and that it is not an option for it to continue in its current form.
In her opinion, if the standards are not met they would eventually
be forced to close.
Assessment
of Funding Options
The NSE have explored several options in order to fund the redevelopment
of the epilepsy centre. The cost of the redevelopment is approximately
£32 million and the Society's funding reserves falls significantly
short of this amount. Examples from previous fundraising endeavours
indicate that they could not raise the required funds in the required
time frame, by 10 April 2007.
Options
explored:
Fundraising: Approaches to Charitable Trusts, government grants.
These options fall significantly short of the required amount;
Bank
Loans: The loan repayments each year would be in excess of the NSE's
net surplus. The debt from the loan could not be paid off. Notwithstanding,
the finance houses are not willing to lend the NSE the cash without
other security;
Relocation:
Any alternative site has to be within 52 minutes drive of the National
Hospital for Neurology and Neurosurgery in Queen Square, London.
Evaluations have been carried out for the cost of relocation within
52 and 75 minutes drive time from the Hospital. The cost of relocating
would be £80.79 million.
Disaggregation
of the NSE facilities: Disaggregation of the NSE's facilities has
also been considered. It should be noted that it is already proposed
to dissagregate to a certain extent by reducing the residential
provision on-site by around 45% or from about 272 places in 2002
to 152 places by 2010. Most of the functions must be integrated
and only the administrative and services office and small works
and gardening team could be relocated. No merit in this option.
The
analysis of the financial options concludes that the only viable
one is to balance the redevelopment costs of around £32 million
by selling the 8.9 hectares of land for an enabling development.
Assessment
of Local Social Infrastructure
The report states that that Chalfont St Peter and the surrounding
area provides an appropriate quantum of social infrastructure to
cater for the enabling development. The infrastructure report should
be read in conjunction with the 'Workplace travel Plan framework'
document. This addresses the sustainability of the site with regard
to local transport infrastructure.
Within
a 5 minute drive of the application site there is a full range of
facilities to include shops, pubs, restaurants, medium scale super
market, library, church, offices and the like. It provides sufficient
facilities to sustain the day to day needs of the proposed new residents.
Broader
Area: Within 10 minutes drive time. There are sufficient schools,
dentists, doctors, chemists, convenience stores and supermarkets.
For example there are 13 primary schools within a range of 0.6 miles
and 2.9 miles.
Capacity:
Of the 13 schools there is surplus capacity in 11 of them; there
was capacity in 4 of the 10 secondary schools surveyed. 8 of the
dentists surveyed had capacity. Of the remaining 5, 3 did not answer
in time.
The
development is compliant with the relevant provision of the development
plan and the more general government guidance on sustainability
in PPG1 and 13.
Landscape
Appraisal
by The Landscape Partnership
Landscape
appraisal includes the following:
- Existing site description
- Wider setting and views towards the site
- Local and streetscape setting and views towards the site
- Landscaping planning context
- Existing role of the site and adjacent land within the Green Belt
- Opportunities and constraints for the NSE and adjacent land
Site
description
The site contains all the existing NSE buildings and amounts to
20.24 hectares (93.35 acres). The site is an irregular shaped oblong
lying adjacent to the east of Chalfont St Peter.
Land
uses
The NSE provides day and residential care for patients with epilepsy
and other disabilities. The facilities allow for integration within
the local community and the shared use of the sports fields and
permissive paths. The NSE also contains buildings and structures
to support facilities such as book-binding and horticultural activities
to encourage patients to work with commercial based activities.
Buildings
The site contains 117 buildings of different types and uses.
Three are Grade II Listed; these include Passmore Edwards House,
Milton House and Pearman House. It is noted that the three listed
buildings have all been extended and the original main part is likely
to be the only part to which the listing relates.
The immediate area around provides the setting for these listed
buildings. The landscape elements include mature trees, open lawns,
the entrance roads and adjacent land and the aspect of the view
towards the properties. Passmore Edwards House is a focal point
for the main entrance and is framed by a group of beech trees. As
the rear elevations of these properties have been affected by changes
it is the front elevations that are key areas for the setting. The
other buildings include existing residential properties, buildings
used for administrative purposes and others provide facilities for
joint uses of the patients.
The
maintenance buildings form a large collection close to Skippings
Farm. These buildings are noted to vary in size and are described
as being generally unattractive in appearance.
Vegetation
The site contains a number of trees some of which are noted to be
mature specimens. A mixture of both deciduous and coniferous species
has been identified and an arboriculture assessment has been undertaken
to categorise the trees depending on their condition and worthiness
of retaining. A number of trees have been identified to be of importance
within the streetscape and overall setting. There is a Tree Preservation
Order 5 (1990) named as a woodland in the south-west corner of the
site between Cross Lanes and following the southern part of Rickmansworth
Lane.
Existing
accesses, footpaths and open spaces
The site has four access points as follows:- on Rickmansworth Lane,
the Tate Road access lies towards the eastern corner of the site;
the second access from a cul-de-sac to Sarcus Dean.
From
Chesham Lane there are two accesses; the northern access is between
Debenham and Victoria Houses and the southern access is the main
entrance to the site. Both of these accesses lead into the central
area of the campus and are linked by Nicholls Avenue.
The
site is crossed by a north-south footpath from Chesham Lane past
Skippings Farm onto Rowans Farm. A second footpath runs east to
west and lies to the north of the site, although within the NSE
and to the south of Skippings Farm. A permissive path has been introduced
by the NSE within the site using Tate Road to lead towards Skippings
Farm, and a second path follows the southern central tree belt and
lies outside the site boundary.
The
site contains a number of open spaces that vary between managed
lawns, open grassland and areas used for sport and recreation and
farming.
Wider
Setting and Views towards the Site
This section outlines the boundaries of the NSE, the estate uses,
topography, settlement patterns and infrastructure, vegetation,
footpaths and bridleways and the distant views towards the NSE.
Local
Setting and Streetscape Views towards the Site
It is noted that a number of the specimen trees and tree groups
within the NSE are important as viewed from the local streetscape
and local rural setting. The boundary vegetation provides important
elements of enclosure and focal points within the streetscape and
rural setting. The views into open spaces within the NSE are important
for both the streetscape and the rural setting. It is the combination
of these elements of vegetation and open spaces, which provide the
existing character to the local setting and the current role of
the NSE within this local setting.
Landscape
Planning Context
Policies that have been identified as being relevant are GB1, GB2,
GB3, GB30, R15, H4, LB1-LB4, GB28, R10, TW1, TW3, TW4, TW5, and
TW6 of the Chiltern District Local Plan and SR1 of the Buckinghamshire
County Structure Plan.
Existing
Role of the Site within the Green Belt
It is stated that the most relevant purpose of the Green Belt to
the area is to retain the separation to prevent coalescence of the
settlements and to provide open space for recreational and agricultural
purposes.
Opportunities
and Constraints
The tree survey that has been undertaken in accordance with BS5837
(1991) categorised the trees from A to D. The A and B trees were
identified to be high quality specimens that were worthy of retention,
the C trees although slightly lower quality are also worthy of retention.
All trees to be retained would need to be protected in accordance
with BS5837 during all stages of demolition and construction works.
The
landscape appraisal also identified the significance of a number
of trees as viewed from the local rural and streetscape setting.
These were identified irrespective of their A to D rating and providing
they are not diseased or dying have been identified as important
to retain as they make a positive contribution to the character
of the area. In contrast, the row of conifers to the south-east
of the playing fields are inappropriate to the character of the
area and should be removed and replanted.
Any
development that would lie close to the areas identified as playing
an important role to the landscape close to the listed buildings
would need to be designed to reflect the character and setting of
the listed building.
The
open land within the NSE and the adjacent land are considered to
be important to the local setting and should be retained open. The
open spaces of importance to the rural setting are additionally
important in their role within the Green Belt.
It
is stated that the existing boundaries to the west and south generally
contain thick and mature tree belts. The eastern boundary of the
NSE with the countryside is less thickly planted and in parts is
open. There are opportunities to enhance the NSE as viewed from
the east and around Skippings Farm and to reinforce the role of
the NSE to provide a buffer between Chalfont St Peter and the adjacent
countryside.
The
young areas of planting along the eastern boundary should be actively
managed to encourage growth.
Opportunities
exist to enhance the facilities used for recreational facilities
on the northern playing fields used by the NSE and local community
for football.
The
existing open areas of the NSE and the sports pitches are used informally
by local people for recreational purposes including dog walking
which has led to a high level of fouling and misuse. Opportunities
exist to use the land within the wider NSE estate to promote access
to the countryside and support the Green Belt and Colne Valley regional
park objectives.
It
is considered that a farm strategy should be established to explore
the future uses of the buildings associated with Skippings Farm,
which is a noticeable feature from the surrounding viewpoints
Within
the NSE there are areas of open land which are contained visually
and physically by the buildings and boundary tree belts. It is stated
that these areas perform no visual role within the Green Belt and
fall into two categories. The first is an area that is used by the
NSE for informal recreational use. The land lies to the south of
the central tree belt and is proposed to be used by the NSE for
archery recreational activities and fund raising events. The second
category are areas which have been identifies as being not actively
used by the NSE and would be suitable for development subject to
the retention of trees identified of importance.
These
areas include the field which is managed between Sarcus Dean and
Tate Road; the linear areas adjacent to the Cross Lane boundary
tree belts; the open spaces adjacent to the areas for the listed
building settings and the areas around Parry Cottages, Redsteps
and Vulcan Houses
In
respect of access points, a study has been undertaken and discussions
with the County Highways Officer and the Chiltern District Council
Tree and Landscape Officer have taken place. The location of a new
access off Chesham Lane would require the removal of two hornbeam
trees on the highway verge and a laurel hedge within the NSE site.
An existing access to Sarcus Dean would be a second access point.
It would be slightly modified to allow the existing road to divide
and lead into the central area of the site. The Tate Road access
would be limited to a cul-de-sac leading only to the four pairs
of semidetached houses.
The
landscape appraisal concludes by stating that a comprehensive approach
to the NSE and adjacent site is being considered. It states that
this would allow the wider estate to continue to be farmed, to used
for horticulture and organic food production, the retention of formal
and informal areas of land for the NSE, areas for open space for
public use, the active use of land for enabling development and
enhanced NSE residential development on land identified as suitable
in the Landscape Appraisal.
The
landscape appraisal concludes by stating that a comprehensive approach
to the NSE and adjacent site is being considered. It states that
this would allow the wider estate to continue to be farmed, to used
for horticulture and organic food production, the retention of formal
and informal areas of land for the NSE, areas for open space for
public use, the active use of | 
