PPA | Gilbert Scott House

professional planning appraisal PPA


Gilbert Scott House, Old Weston Rd, Flax Bourton, BS48 1UL


May 2020

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1.1 A PPA is a detailed appraisal of the development potential of a site by qualified

Chartered Planners. It is based on a desk-top review of the site; the relevant

planning policy; and planning history.

1.2 A planning appraisal is one of the most important and often under-rated planning

services provided to clients.

1.3 A well-researched and prepared appraisal will set out in an easy-to-read format,

the relevant opportunities and constraints applicable to a potential development


1.4 This planning appraisal covers all the relevant issues, with the core services as


i) Identifying planning policies relevant to a site and/or proposal;


Review of planning history;

iii) Site assessment to identify planning opportunities and constraints;

iv) Advice on development potential and principles taking into account the

constraints, opportunities, site characteristics and policy context;


Potential site layouts.

1.5 The PPA report is paid for by the purchaser of the site upon completion (£700 + VAT

is added to the contract) – they then have a £700 credit to spend on planning with

the planning team if they pursue development.

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2.1 This PPA has been commissioned to identify the potential for residential

development at Gilbert Scott House. It is understood that the extensive property,

built in the mid-twentieth century with later additions, was last in use as a care home

for people with learning difficulties and/or complex behaviour (Use Class C2).

2.2 The property is located off Old Weston Road, with vehicular access via a private

access drive “Cambridge Heights” , which also serves three other properties Peel

House, Graham House, and The Sumachs. These three properties, and Mallory

House (accessed directly from Old Weston Road), were formerly care homes

themselves, in the same style, and presumably same complex, as the property

subject to this PPA. These other properties were each subject to conversion

planning permissions (within the last five years) and have been turned into large

detached houses.

2.3 It should be noted that no site visit has been undertaken to inform this appraisal,

and although the property is not a listed building, a physical inspection and building

survey should be undertaken, by a suitably qualified person to inform any

conversion proposals.

2.4 Notwithstanding the absence of a physical inspection or any specialist advice, it is

considered that there is potential to convert the care home into a single dwelling

house or multiple units. The number and size of each property will dependent on

the ability to provide the necessary internal/external space, outlook, and parking

(see following sections).

2.5 The site is not within an area at risk of flooding and is previously developed

“brownfield” land. The existing building is extensive at circa. 380 sq.mover two floors.

This offers the alternative opportunity of redeveloping the site for new build housing.

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3.1 The property is located outside of a designated settlement boundary and within the

statutory Green Belt. Both National 1 and local 2 planning policy and guidance seeks

to protect the Green Belt from inappropriate development. When considering any

planning application, local planning authorities (LPAs) are required to “ ensure that

substantial weight is given to any harm to the Green Belt ” 3 .

3.2 National guidance states that there are types of development within the Green Belt

that are not considered inappropriate, including, inter alia, partial or complete

redevelopment of previously developed land (which would not have a greater

impact on the openness of the Green Belt than the existing development), and the

re-use of buildings provided that the buildings are of permanent and substantial

construction i.e. conversions.

3.3 Local planning policy echoes this approach, and in terms of the first point above,

clarifies that redevelopment proposals will be supported if they (i) do not extend

beyond the footprint of the existing buildings unless the proposal by virtue of its

height or location on the site would have an equal or lesser impact on the Green

Belt than the existing buildings; and (ii) are sustainable in terms of being well related

to existing settlements, and having safe and convenient pedestrian and cycle

access to services, amenities and a bus or rail service.

3.4 The site is not within a conservation area and the property is not a listed building.

However, it adjoins the Grade II Listed Coroner’s Court and Mortuary (formally Long

Ashton Magistrate's Court ) and given the proximity, forms part of the listed building’s


3.1 Planning legislation 4 requires LPAs to “have special regard to the desirability of

preserving the [listed] building or its setting .” The NPPF requires that great weight is

1 Nation Planning Policy Framework (NPPF, February 2019) 2 North Somerset Council Core Strategy (April 2012) and Sites and policies plan part 1: development management policies (July 2016) 3 NPPF, Paragraph 144 4 Sections 16 and 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990

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placed on the need to conserve heritage assets, including listed buildings (and their

settings), and any harm requires “clear and convincing justification 5 ”. Given this,

any proposals for redevelopment and/or modifications to the existing building will

need to be carefully considered with the setting of the neighbouring listed building

in mind.

3.2 Applications for the creation of a dwelling are required to incorporate sustainable

measures to meet a minimum of 10% of predicted energy use for the residential

development proposals, which is usually met by implementing energy efficiency

measures and the integration of renewal energy sources, such as solar photovoltaic

panels. Similarly, developments will be expected to apply best practice Sustainable

Drainage Systems to reduce any additional impact of surface water run-off.

3.3 The site lies within the designated ‘ North Somerset and Mendip Bats Special Area of

Conservation (SAC) ’, specifically Horseshoe Bat Consultation Zone C, which means

that specialist ecological advice will need to be sought for any necessary bat

surveys that will need to support a development proposal.

3.4 Local to the site, the property includes several mature trees. None appear to be

protected, but their areas of influence will need to be considered when devising

any redevelopment or extension proposals. Some of these trees could also be

considered to form part of the verdant setting of the adjoining listed building,

therefore of visual importance. Specialist arboricultural advice on the condition of

the trees should be sought in any event.

3.5 To the north of site, the surrounding development is bordered by the main southwest

railway line. As such, rail noise will need to be considered for residential

development, and possible noise mitigation incorporated in building upgrades,

new build elements, and possibly private garden areas. Specialist acoustic advice

should be sought and it is likely that the LPA will require this information, as they did

on the other converted care homes adjacent to the site.

5 NPPF, Paragraphs 194

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3.6 The use of the site for care purposes has now ceased, and although not an

‘economic’ use, the LPA may want evidence that efforts were made to reuse the

property for its intended care use (Use Class C2), prior to allowing any conversion to

residential purposes. This can form a marketing appraisal or statement by

past/current property Agents regarding unsuccessful attempts to sale or let the

premises as a care home. Once again, this information was provided for the

neighbouring former care home planning applications.

3.7 Finally, the private access “Cambridge Heights” provides dedicated access to

three existing properties plus the application site. Although not a dogmatic

standard, the Council’s best pr actice for private accesses notes that they should

only serve up to 6no. properties. With that in mind, there is a long planning history

on the gap site to the east of the access drive for infill housing. Two unsuccessful

planning applications for 2no. new houses and, at the time of writing, a live planning

application (under assessment) for a single infill house (LPA ref. 20/P/0721/FUL 6

refers). The outcome of this application, the general arrangements of the private

access, and the stance of the Local Highway Authority, may limit the number of

units achievable on this site.


4.1 Policy DM12: Development within the Green Belt, like national guidance, controls

development in these protected areas. However, it allows specific types of

development that are not considered to be inappropriate, which provide

opportunities for the site. As such, the main development opportunities are: -

• Redevelopment of the site, replacing the existing building with one or more

residential buildings, and

• Conversion of the building into one or more dwellings.

6 https://planning.n-somerset.gov.uk/online- applications/applicationDetails.do?activeTab=summary&keyVal=Q7LJ16LPIOI00

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4.2 The key requirements of redevelopment on previously developed (brownfield) sites

in the Green Belt (outside of settlement boundaries) are noted above, at paragraph

3.3, whereby the paramount consideration is that proposals have no greater impact

on the openness and visual amenities of the Green Belt than the existing building(s)

on the site.

4.3 This translates into an ‘allowance’ of building footprint and volume that can be re -

provided on the site (once existing structures are removed), subject to locational,

massing, and other design considerations. The existing building is extensive and

covers a significant area of the site, and given the proximity of trees to the northwest

area of the site, suggests a natural location for replacement building(s).

4.4 Given the noted constraints and the documented planning history of the 4no.

former care homes on the northeast side of the access drive; conversion of the

existing building would be the path of least resistance for a residential planning

application, and policy DM12 also contains the high-level criterion for these types

of proposals. The change of use of the building would not be considered

inappropriate, including any associated alterations or additions as part of the

conversion works, which need to be proportionate, visually acceptable, and

consider the setting of the adjoining listed building.

4.5 Although the property has not been inspected as part of this appraisal, looking at

the floor plans for the building, it appears that the property can be successfully

subdivided into multiple properties, whilst maintaining suitable dual-aspect outlooks.

4.6 The site is part of the Flax Bourton settlement and relates physically well to the

surrounding built form. Locally there are frequent bus services, accessed via stops

either on Weston Road or the A370, a short walk from the site, as are local facilities.

As such, the site is well connected and suitable for residential development. The

site is also within Flood Zone 1 (Low Risk), which is sequentially preferable in flood risk

terms for housing.

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5.1 The site is considered suitable for either residential redevelopment or conversion to

provide a single house, two houses or multiple apartments (Use Class C3).

5.2 A redevelopment proposal has the potential to produce a single large dwelling on

the site of the existing building, or two separate houses. The latter is limited to two

on the basis that the site needs to remain in character with the houses on the other

side of the access drive, which are all set within good-sized curtilages with breathing

space around the building.

5.3 Alternatively, a single new building has the potential to provide apartments, subject

to space restrictions, parking provision, and any resulting impact on the character

of the area (see Development Principles, below).

5.4 The existing property, like the other four buildings on the other side of the access

drive, could be converted into residential use. Again, as a single large house or two

smaller houses, with a north-south divide resulting in a two-storey (plus roofspace)

dwelling to the south and a smaller single or one-and-a-half storey property to the


5.5 There is also potential to convert the existing building into apartments, again subject

to space standards and parking provision . From the Agent’s plans, it appears as

though the ground floor can subdivide into three units, with an additional flat on the

first floor. Without a building survey, it is not possible to say at this stage whether the

roof spaces can be used to extend this accommodation.

Development Principles

5.6 The adjacent listed Coroner’s Court building, and its setting, will be a strong

consideration for the LPA when assessing any proposals that involve physical

development at the site. The care home building itself does not appear to be of

historical importance, given its twentieth century construction. However, an

application for residential development on this site should be supported by a

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proportionate analysis of the location’s heritage importance, guided by the level of

intervention i.e. full redevelopment would require more in-depth analysis than a

conversion application. Indeed, should complete demolition and redevelopment

be sought, then it is advised to engage a Heritage consultant to provide such

analysis, who can also quantify the degree of harm to the listed building’s setting

and how the proposals mitigate this against the wider benefits of the development 7 .

5.7 Whether a conversion or new building provides flatted accommodation, the LPA

will consider the appropriateness of flats in this location, in terms of ensuring that the

area has a suitable mix of housing types and sizes. Given the existing development

in the area, and looking at the last Census information for the Parish of Flax Bourton;

it is clear that the area is predominantly houses (97%) with very few flats, therefore

there should be no overconcentration of flats that would lead the LPA to object to

the provision of flats on this site, subject to the other development principles.

5.8 The site contains several mature trees, which although unprotected, will be

considered as part of any proposals that include physical development, including

the laying out of parking areas and hard standings etc. They should be retained

wherever possible, as they form part of the areas character and the backdrop to

the listed building’s setting. As such, an Arboricultural consultant will need to be

engaged to survey the trees and advise on the proposals.

5.9 As part of the Policy DM12 (Development in the Green Belt), it is established that

redevelopment proposals should generally stay within the established perimeter of

the existing buildings on the site. This will assist in preventing development within the

retained trees’ areas of influence.

Should redevelopment or additions to the

existing building go beyond the established development area, tree protection

measures will be required in accordance with industry best practice and Policy DM9.

For any necessary tree removals to facilitate development (aside from poor

specimens that require removal under good arboricultural practices), replacement

planting should be considered elsewhere on the site as mitigation.

7 NPPF, Paragraph 196

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5.10 In terms of any external changes or additions as part of a conversion, these will need

to be proportionate and in keeping with the existing building in terms of design,

articulation, and the use of materials.

5.11 The proposal will need to comply with the Council’s sustainable design and

construction policies, notably CS2, and the use of renewable energy measures to

provide 10% of the predicted energy usage.

5.12 The dwellings will need to be designed in accordance with the national space

standards 8 (see the Technical Requirements as well as the Gross Internal Area

(GIA)/storage requirements in Table 1).

5.13 Vehicle parking will need to be considered and off-street provision provided in

accordance with the minimum standards set out in Policies CS11 and DM28, which

are further detailed in the Council’s parking guide 9 . This provision will need to be

balanced against the need to provide usable amenity space for the residential


5.14 Dedicated provision for secure, conveniently located cycle parking will also be

necessary in accordance with the adopted parking standards. This will need to be

fully enclosed (i.e. within a lockable store rather than under a canopy) and to the

standards set out in Policy DM28 and the Parking SPD.

5.15 Refuse and recycling storage provision must be incorporated in accordance with

the guidance set in Policy DM32. This will need to be close to the waste collection

point. The site plan will need to identify the location for storage and show the

size/capacity of the storage containers to demonstrate compliance with Policy

DM32 and Section 4 of t he Council’s Residential Design Guide 10 .

5.16 The Council operates a Community Infrastructure Levy; therefore, redevelopment

will be liable for CIL. Additionally, a residential conversion will be liable for CIL if the

8 Technical housing standards – nationally described space standard, Department for Communities and Local Government (March 2015) 9 North Somerset Parking Standards Supplementary Planning Document, North Somerset Council (November 2013) 10 Residential Design Guide – section 4 Recycling and waste, Development Management Advice Note, North Somerset Council (September 2013)

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building is not ‘in use’ . An ‘in use’ bui lding is defined 11 as a building which “contains

a part that has been in lawful use for a continuous period of at least six months within

the period of three years ending on the day planning permission first permits the

chargeable development.” CIL is charged based on the amount of floorspace

within the building and is payable upon the commencement of development (see

CIL information pages on the Council’s website 12 ).

Application Report/Survey Requirements

5.17 Any formal application will require the standard plans/drawings, application and

CIL Question forms, and ownership certificates. Depending on the level of

development proposed, additional items are likely to include: -

Design and Access Statement;

Heritage Statement;

▪ Sustainability Statement and Energy Strategy;

Noise Assessment;

Arboricultural Assessment; and

Hard and Soft Landscape Plan.


6.1 The following indicative sketch layout, which is overlaid atop the local authority

constraints plan, shows a potential block plan for a redevelopment proposal for two

houses (one two-storey and one single-storey). It is not informed by detailed surveys

but makes some assumptions about trees and largely follows the extent of the

existing building on the site.

11 Regulation 40(11) of the Community Infrastructure Levy Regulations 2010 (as amended). 12 https://www.n-somerset.gov.uk/my-services/planning-building- control/planningpolicy/cil/community-infrastructure-levy/

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