Letter from Fulbourn Parish Council
30th August 2013
Secretary of State Casework
Room 3/02 Kite Wing
Temple Quay House
2 The Square
Planning Application South Cambridgeshire District Council S/1066/13/OL
Outline Planning Permission for the Redevelopment of Ida Darwin Hospital
Fulbourn Parish Council is writing to you to ask that you call in the above application because it goes against the aims of the National Planning Policy Framework to protect the Green Belt against inappropriate development of brown field sites within it.
The Cambridgeshire and Peterborough Mental Health Trust wishes to redevelop for housing a hospital site in the Cambridge Green Belt and the local planning authority South Cambridgeshire District Council wishes to include an Extra Care Facility building in the redevelopment on behalf of Cambridgeshire County Council. It has therefore submitted for approval the above outline planning application to redevelop the site.
The site has been designated for housing in the current Local Development Framework and in the emerging Local Plan. Fulbourn Parish Council is not challenging this designation, but we do oppose the application because the location and height of the new buildings proposed in the scheme would have a greater impact on the current openness of the Green Belt at this location.
Moreover, the scheme is significantly different to that which the Trust submitted as proof of evidence to the Examination in Public of the Site Specific Policy designating it for housing, by providing less open space than previously indicated to the western part of the site which was intended to provide a Green Wedge to maintain the openness of the Green Belt and to enhance the separation of Fulbourn from the urban edge of Cambridge. In addition, further significant difference results from the introduction of a large three storey building, when existing buildings are no higher than two storey, with most being single storey.
Fulbourn Parish Council therefore asks that the Secretary of State to call in this application because we consider it conflicts with national planning policy governing the redevelopment of an existing brown field site in the Green Belt as follows:
Paragraph 9.89 of the NPPF (March 2012) “Protecting the Green Belt” states: A Local Planning Authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are (amongst others) – Limiting infill or the partial or complete redevelopment of previous developed sites (brownfield) whether redundant or in continuing use (excluding temporary buildings) which would not have a greater impact on the openness of the Green Belt and the purposes of including land within it than the existing development.
Fulbourn Parish Council therefore feels that in both respects the application fails to meet national planning policy.
We have met with the applicant the Cambridgeshire and Peterborough Mental Health Trust and its agents on a number of occasions and the applicant has held pre-application consultation. However, it has failed to take into consideration in its application any of the views expressed to it about the inappropriateness of the proposed development on the openness of the Green Belt at this location. Moreover, the local planning authority South Cambridgeshire District Council has refused to amend its plans for a three storey Extra Care Facility – the height of which we consider is also inappropriate for the site, given the height and density of the existing buildings.
Description of Site
As the Design and Access Statement accompanying the application describes (chapter 2 “Response to Context”, page 10), the present Ida Darwin Hospital site is comprised of “generally single storey buildings” that are “set within extensive landscaped areas”; and that “the hospital buildings can be seen scattered across the site between the trees” (page 23).
Paragraph 11.60 of the Planning Inspector’s Report following the Examination in Public describes the Ida Darwin Hospital site as consisting of “areas of buildings and parking interspersed with landscaping and other open land. The western part of the Ida Darwin site, where it approaches Capital Park, contains relatively few buildings and a commensurately higher proportion of open land.”
These descriptions rightly point out the whole site is of low density buildings and open, with there being already more openness at the western end of the site.
As to the height of the existing buildings, the original single storey pavilions with swallow pitched roofs are around 5.25m to their ridge and surrounded by much lower flat roofed structures of around 3.5m; the newer single storey buildings with flat roofs are also around 3.5m; newer single storey pavilions are just under 5m to their ridge (again with lower flat roof sections); there is a two storey flat roof building near the entrance to the site which is around 6m high; and there are also three single storey buildings which are around 6.3m high to their ridge. There are no buildings above two storeys on the site.
Height of the Extra Care Facility
With regard to height, South Cambridgeshire District Council’ Green Belt Policy GB/4 conforms to former Planning Policy Guidance (PPG) 2 Annex C4 which states that redevelopment should not exceed the height of the original buildings. The Site Specific Policy SP/9 which conforms to GB/4 makes reference to “two story houses” only (paragraph 2.47) and has to reflect the principles of Policy GB/4.
Emerging Local Plan Policy NH/9 retains this height limitation, stating that the Council will seek to ensure that redevelopment will be limited to that which will not result in a greater footprint unless there are significant environmental improvements, the existing height of the built development is not exceeded and there be no greater impact than the existing development on the openness of the Green Belt.
This planning application should be determined on the principles as stated in Policy GB/4 (with due regard to emerging Policy NH/9) and to Policy SP/9, which means a limit of two storeys should be applied to the redevelopment to conform to the maximum height of the original buildings on site and to meet the aim of the NPPF in respect of the Green Belt.
The Extra Care Facility as a three storey building has the potential to be 12m in height, twice the height of the tallest buildings currently on the site.
If the Extra Care Facility has to be three storeys high then a more sustainable location for it would be Cambridge East where an urban development of 1,300 dwellings is proposed on the boundary of Cambridge City.
Height of residential development
Although limited to two storey buildings in the application, in keeping with the tallest buildings currently on the site, the proposed height of these dwellings is significantly above the height of the current buildings.
With the average height of the current buildings being just under 6m, the height of the new dwellings will be between 8.0 and 8.5m high with a maximum of height 9.5m (Design and Access Statement page 65).
Size of the Green Wedge
The Planning Inspector judged in his Report that the amount of open land within the Major Developed Site fulfils the Green Belt purpose of separating Fulbourn from Cambridge at a sensitive location where the two settlements are close together. As we can see from the descriptions of the site (above) it has extensive “openness” throughout its 13.45 hectares and there is already more “openness” to the west of the site.
DPD Policy GB/4 states that a development should not have a greater impact on the openness of the Green Belt and SSP Policy SP/9 (paragraph 3) confirms that the Green Wedge on the western part of the Ida Darwin site will provide “compensatory enhancement to the openness of the Green Belt at this location.”
Also material evidence is the 1950 study by Professor Sir William Holford and H Myles Wright which identifies the land between Fulbourn village and Fulbourn Hospital as “a main preservation area and green wedge” to prevent Fulbourn merging with Cherry Hinton. This clearly demonstrates the importance of preserving the “openness” of the Ida Darwin site, as confirmed by the judgement of the Planning Inspector and Policy SP/9.
Taking into consideration the above evidence, Policies GB/4 and SP/9 and the NPPF guidance, we conclude that taking half the 13.45ha site for a built environment (6.53ha for residential development (excluding green infrastructure) and the Extra Care facility) is not providing compensatory enhancement for the redevelopment to protect the rural character of the Green Belt at this location and, as a result, the appearance and character of the original Fulbourn Hospital and its grounds particularly from the north east (contrary to Policy CH/5).
The application should take into account the facts that it adjoins the Fulbourn Hospital Conservation Area and there is already more “openness” at the western end of the site, when compensating for the built area (both residential and the Extra Care Facility); the application fails to do this.
Fulbourn Parish Council is asking the Secretary of State to call in this application for outline planning consent to develop Ida Darwin Hospital, because, although it is designated for housing, this particular scheme goes against the aims of the National Planning Policy Framework to protect the Green Belt against inappropriate redevelopment of brown field sites within it.
The parish council considers that the scheme applied for is being driven by a desire by South Cambridgeshire District Council (the local planning authority) to achieve housing targets at whatever cost to the Green Belt, rather than a dispassionate view of valid planning and design issues and legislation.