Epsom General Hospital Dorking Road Epsom KT18 7EG – Appeal Inquiry Update

Having requested of the Planning Inspectorate and been granted a further 7 days to review the Appellant’s Statement of Case (which was only very shortly available to the Societies before the original deadline), ECS and WERS committee members have updated and expanded their previous response to the Appeal. The revised version, including a new Appendix, strengthens our case for dismissing the Appeal with more detail, and challenges specific inaccuracies of fact and misleading assertions in the Appellant’s Statement of Case.

The revised version can be seen here.

The text of the original post for this appeal is shown below.

Click here to see map for location of Epsom General Hospital.

19/01722/FUL Demolition of the existing hospital buildings, accommodation block and associated structures and redevelopment of the site to provide a new care community for older people arranged in two buildings, comprising 302 to 308 care residences, 8 to 12 care apartments and 26 to 30 care suites proving transitional care, together with ancillary communal and support services Use Class C2, 24 key worker units Use Class C3, childrens nursery Use Class D1 as well as associated back of house and service areas, car and cycle parking, altered vehicular and pedestrian access, landscaping, private amenity space and public open space.

This application for the NHS “Sold Off existing hospital buildings site” by Guild Living involves the demolition of an accommodation block and other associated structures, and redevelopment of the site to provide a new care community for older people arranged in two buildings comprising 302 to 308 care residences, 8 to 12 care apartments and 26 to 30 care suites providing transitional care, together with ancillary communal and support services.

The EEBC Officers recommended approval, despite many public objections to its scale, bulk & massing, including those of the Society and Woodcote Epsom Residents Society, but the members voted to refuse permission in November 2020. Since then the applicant, Guild Living, has both submitted a revised, slightly smaller application (see our post here.) and appealed the decision to refuse their original application.

As a major development application, the Appeal will be heard in August as a full Inquiry, lasting up to five days, with both parties being legally represented by specialist planning law barristers. In view of the Officers’ original recommendation to accept, EEBC have appointed an external planning consultant to lead the defence of the decision to refuse.

Since the case may well set a precedent for “acceptable” height of new buildings in Epsom in order to “optimise” land use in the context of the lack of land supply in the Borough for the scale of new housing required by HMG policy, the Society has taken the unusual step of pooling resources with Woodcote Epsom Residents Society to present to the Planning Inspectorate a detailed statement of all the reasons why we feel the Appeal should be dismissed. See our joint response here.

Epsom General Hospital Dorking Road Epsom KT18 7EG – Appeal Inquiry

Click here to see map for location of Epsom General Hospital.

19/01722/FUL Demolition of the existing hospital buildings, accommodation block and associated structures and redevelopment of the site to provide a new care community for older people arranged in two buildings, comprising 302 to 308 care residences, 8 to 12 care apartments and 26 to 30 care suites proving transitional care, together with ancillary communal and support services Use Class C2, 24 key worker units Use Class C3, childrens nursery Use Class D1 as well as associated back of house and service areas, car and cycle parking, altered vehicular and pedestrian access, landscaping, private amenity space and public open space.

This application for the NHS “Sold Off existing hospital buildings site” by Guild Living involves the demolition of an accommodation block and other associated structures, and redevelopment of the site to provide a new care community for older people arranged in two buildings comprising 302 to 308 care residences, 8 to 12 care apartments and 26 to 30 care suites providing transitional care, together with ancillary communal and support services.

The EEBC Officers recommended approval, despite many public objections to its scale, bulk & massing, including those of the Society and Woodcote Epsom Residents Society, but the members voted to refuse permission in November 2020. Since then the applicant, Guild Living, has both submitted a revised, slightly smaller application (see our post here.) and appealed the decision to refuse their original application.

As a major development application, the Appeal will be heard in August as a full Inquiry, lasting up to five days, with both parties being legally represented by specialist planning law barristers. In view of the Officers’ original recommendation to accept, EEBC have appointed an external planning consultant to lead the defence of the decision to refuse.

Since the case may well set a precedent for “acceptable” height of new buildings in Epsom in order to “optimise” land use in the context of the lack of land supply in the Borough for the scale of new housing required by HMG policy, the Society has taken the unusual step of pooling resources with Woodcote Epsom Residents Society to present to the Planning Inspectorate a detailed statement of all the reasons why we feel the Appeal should be dismissed.

See our joint response here.

It would do no harm for the appointed Inspector to receive representations from local residents requesting the Appeal be dismissed. If you wish to do this, having read our formal response, please contact the case officer at the Planning Inspectorate by mail or email, in each case quoting the Appeal Reference APP/P3610/W/21/3272074. Mail address: Alison Dyson, The Planning Inspectorate, Temple Quay House, 2 The Square, Bristol BS1 6PN. Email to: ALISON.DYSON@planninginspectorate.gov.uk

You can also submit representations via the Planning Inspectorate Portal. Extended deadline for submissions is 8 June.

Madan Cottage Avenue Road KT18 7RD

Click here to see map for location of The Ashley Centre Epsom KT18 5AB .

21/00528/FLH Erection of two storey side extension and enlargement of existing rear dormer window.

This application is for the erection of a two storey side extension to a house in a prominent location abutting the footpath which is a continuation of Madans Walk a well-used route from Woodcote, including the hospital, to the town centre via the attractive Rosebery park.

There is a considerable elongated effect of the previous extension which is built up hard on the boundary against the footpath, and it is proposed to build another story perpendicularly above.

The Society believes this does not comply with the design guide for house extensions requiring the first floor eaves level to be inset 1 metre to prevent a terracing effect, and as proposed would present a tunneling and darkening effect on the footpath which is much narrower at this point and also has extensive vegetation on its opposite side.

Accordingly it has been suggested that a modification to the application is needed to lessen the impact of the proposals being overbearing to users of the footpath.

See our letter here.

The Ashley Centre Epsom KT18 5AB

Click here to see map for location of The Ashley Centre Epsom KT18 5AB .

21/00327/FUL Alterations and improvements to the East Entrance, including new paving, over-cladding to elevations, new aluminium framed sliding doors, new lighting features, signage zones and associated works.

The Society’s objection to this proposal was submitted on the EEBC Planning Website as a “Comment” in the interests of speed of visibility. We have found that sending letters, even as email attachments, results in a variable and potentially long delay before they are processed by the Council and become visible on their Planning Website. The text is repeated in full below.

This Comment is submitted on behalf of Epsom Civic Society.

The proposals broadly fall into five parts; 1, Replacement Paving; 2, Replacement sliding mall entrance doors; 3, Lighting features; 4, Overclading existing elevations and columns in framing and aluminum cladding; 5, Signage zones and their associated lighting works.

1. Replacement paving. Given the recent town centre and market paving scheme, there is no justification that the public highway section is removed and replaced. This would interfere with the flow and feel of the paving continuous along the High Street. Proposals here should be confined to paving within the applicant’s ownership.

2. There is no objection to the installation of the replacement of the mall sliding entrance doors.

3. There is no objection to the proposals for the undercroft lighting upgrade. see item 5 for other lighting comments.

4. The proposed over-cladding of columns, front elevation brickwork, and first-floor windows are the most objectionable parts of the application. They would destroy the rhythm of the traditional High Street conservation area facades with its mixture of Surrey-type brickwork and rendered panels. The Society believes it to be contrary to the direction of the NPPF in that the development would certainly not make a contribution to the local character and distinctiveness. There would also be a conflict with Policy DM8 requiring resistance to the loss (here the facade) of a Heritage Asset.

5. Signage Zones and associated lighting works. Broadly, these have been designed in conjunction with the works at No.4. In our opposing No.4 proposals a reassessment is required, there may be some scope for limited lighting improvements but not to the scale indicated.

In conclusion, the application is not welcomed and refusal is therefore requested.

Epsom General Hospital Multi-Storey Car Park

Click here to see map for location of Epsom General Hospital Dorking Road Epsom KT18 7EG

20/00249/FUL Erection of a multi storey car park comprising ground plus 5 storeys and 527 car parking spaces, reconfiguration of surface parking to provide 104 car parking spaces and improvement to the access road from Dorking Road.

The Society wrote in March 2020 to object to a previous proposal under this application reference number for a new 6-storey Multi-Storey Car Park (MSCP) to be erected on the existing ground-level car park at the side of the current hospital site next to Epsom Sports Club.

At that time the Society, in common with many others, objected strongly to the proposal, on the grounds of its excessive height, massing and scale, the impact it would have on the adjacent sports facilities and surrounding area, which includes the Woodcote Conservation area, and its general unsuitability for the context of its setting.

A revised design has now been submitted, allegedly to address the criticisms of the previous scheme, but is, in the Society’s opinion, if anything even worse than the original. It remains a utilitarian structure with a large bulk and mass and a bland, boxy design devoid of any quality architectural features, which is totally out of keeping with the surrounding residential area. The overall detrimental effect and harm to nearby heritage assets is, in the Society’s view, substantial.

For these reasons, the Society has requested refusal of this proposal too. See our letter here.

See our previous objection (which was submitted as an on-line comment via the EEBC planning website) here.

20 Burghfield Epsom KT17 4ND

Click here to see map for location of 20 Burghfield Epsom .

21/00366/FLH Demolition of Link attached garage, construction of 2 storey side extension and front porch.

This application is for an over-large extension for its setting. In view of the short time remaining for comments, the Society’s response was by comment response on the EEBC planning website rather than by letter as usual. The text of our comments is set out in full below:-

Epsom Civic Society has reviewed this application and considered it relative to Planning Policy Documents of(1) Development Management Policies;(2) NPPF;(3) SPG for Householder extensions; and (4) Environmental Character Study.

The following comments are submitted:-

  1. The house extension is of greater bulk and not subordinate as required in design guide (SPG)
  2. Does not conform to the prevailing development typology including housing types and sizes (DM 10)
  3. The scale, massing, and size excessively detracts from the openness and space of the locality and being too close to adjoining No.19
  4. Building materials and detailing of elevations particular the change to white rendered walls being inappropriate
  5. Failing to achieve well-designed places as required by NPPF section 12
  6. Failing to function well in not adding to the overall quality of the area (NPPF 127)
  7. Not sympathetic to the local character and the built environment (NPPF 127)
  8. Not being visually attractive as a result of the designed architecture and layout (NPPF 127)
  9. The EEBC Environmental Character Study (an important planning tool) in section 39 specifically refers to Burghfield as having an open feel with buildings of a higher quality in terms of build, materials, individuality with a med-high townscape quality. It is considered to application would detract from this standing.

The Society requests that the application is refused.

on behalf of Epsom Civic Society,

Michael Arthur MBE. FCIOB. FCMI

Changes to NPPF and National Model Design Code – HMG Consultation

In their fourth planning consultation since August 2020, the Ministry for Housing Communities and Local Government launched a consultation on changes to the National Planning Policy Framework (NPPF) and a proposal for a new National Model Design Code (NMDC).

The changes to the NPPF are largely the result of responses to the previous three consultations: some are welcome clarifications or recognition of the significance of the Green Belt and Climate Change to planning policy, and some, together with the NMDC, reflect the Government’s Build Back Better & Beautiful post-covid objectives. However, the Government continues to fail to recognise the extent to which continuing extensions to Permitted Development undermine the integrity of the planning system and unacceptably reduces local democracy and the value placed on local input and preferences.

The Society welcomed the changes related to the climate emergency, but believes they have gone nowhere near far enough and requested more commitment to zero carbon homes and places.

The Society also welcomed the NMDC but would prefer its use not to be mandatory but as a reference source from which planning professionals select those ideas and formats most relevant to local circumstances. Local accountability and consultation should be re-emphasised.

The Society also made a number of detailed comments on both aspects of the consultation.

See the full ECS response to this consultation here

Clayhill Lodge West Hill Epsom KT19 8JP

Click here to see map for location of Clayhill Green on West Hill . Clay Hill Lodge is on the northeast corner of the green.

Current application 21/00167/FUL Demolition of existing single storey outbuilding and erection of five terraced houses and integrated cycle store. Associated landscaping works.

Previous application for Clayhill Lodge & Albony 20/00031/FUL Demolition of two dwellings and one outbuilding. Construction of one four storey flatted development comprising a mix of 1, 2 and 3 bed units totalling 14 flats, and one three to three and a half storey terrace comprising 9 no. 3 bedroom houses. Construction of associated landscaping works.

The Epsom Civic Society wrote objecting to the main scheme application  20/00031/FUL in March 2020 for 14 flats and 9 houses including the demolition of both Clayhill Lodge and Albony, which apparently remains under consideration following several recent revisions.

This new application is for the construction of 5 terraced houses in the east section of the original main site. Many of our previous objections are still relevant but the proposed layouts also show the terraced house plot substantially cutting into the rear garden of Clayhill Lodge, necessitating a retaining wall of 3-4 m height above the reduced ground level and also complex temporary supports to the listed wall at the Pound Lane boundary. It is very difficult to believe that these works are viable or cost effective.

This retaining wall will be very close to the rear of the new homes and be unsightly for the occupants, while the density is greater than the guideline upper limit for Epsom of 40 dwellings per hectare.

The garden of Clayhill Lodge on which these houses would be built represents a large environmental asset in the Conservation Area and maybe is more of a heritage asset than the main house.

It is a greater issue that although this application is not feasible in construction terms it could be used as a ‘Trojan Horse’ to set a precedent for the development of the west part of the main site.

For all these reasons, the Society has requested refusal of this application too. See our letter here.

See our previous letter objecting to the original proposal here.

Epsom General Hospital KT18 7EG – Update May 2021

Application 21/00252/FUL discussed below was refused permission by the Planning Committee in May 2021, but the Appeal Inquiry on the original application 19/01722/FUL (previously also refused) will take place in August 2021. See our June 3rd 2021 post regarding that Appeal.

Click here to see map for location of Epsom General Hospital Dorking Road Epsom KT18 7EG .

Current application 21/00252/FUL Demolition of the existing hospital buildings, accommodation block and associated structures and redevelopment of the site to provide a new care community for older people arranged in two buildings, comprising 267 care residences, 10 care apartments and 28 care suites proving transitional care, together with ancillary communal and support services Use Class C2, 24 key worker units Use Class C3, childrens nursery Use Class E, as well as associated back of house and service areas, car and cycle parking, altered vehicular and pedestrian access, landscaping, private amenity space and public open space.

Previous application 19/01722/FUL Demolition of the existing hospital buildings, accommodation block and associated structures and redevelopment of the site to provide a new care community for older people arranged in two buildings, comprising 302 to 308 care residences, 8 to 12 care apartments and 26 to 30 care suites proving transitional care, together with ancillary communal and support services Use Class C2, 24 key worker units Use Class C3, childrens nursery Use Class D1 as well as associated back of house and service areas, car and cycle parking, altered vehicular and pedestrian access, landscaping, private amenity space and public open space.

Following refusal in November 2020 of the original application made in January 2020, the applicant has lodged a new proposal, which slightly reduces the care accommodation proposed, but still presents excessive height, bulk and massing for its setting.

Since the original application, national planning guidelines have become less accommodating for “tall buildings” and the more recent National Model Design Code provides typical parameters for ‘urban neighbourhood’ areas of 12m eaves heights (and densities of 60-120 dwellings/ha) and ‘suburbs’ of 9m eaves heights (and densities of 30-50 d/ha). The applicant has failed to comply with this national design advice as their scheme has a density of 218 d/ha and a height of approx 27m (plus lift motor room/plant) whilst the appearance fails to respect the suburban residential surroundings. The draft revisions to the National Planning Policy Framework published in January 2021 also include policy changes in response to the Building Better Building Beautiful Commission “Living with Beauty” report. This proposes in a new Paragraph 133 that ‘Development that is not well designed should be refused, especially where it fails to reflect local design policies and government guidance on design’.

This application proposes a very large development wedged into a modest site and is at odds with Policies DM 9 – Townscape Character and Local Distinctiveness – by virtue of excessive height, bulk and massing, and DM10 – Design Requirements for new developments – because it fails to respect the privacy of the existing surrounding residences.

The Society also questions the Fire Engineering Stage 2 Report in the light of the ongoing Grenfell Tower enquiry and the Heritage Townscape and Visual Impact Assessment included in the applicant’s supporting application.

Finally, the Society remains concerned that, since existing care residences remain unfilled and other applications for similar accommodation have been withdrawn since January 2020, that, if built, the proposed accommodation would remain unsold and later converted to open market residences, thus depriving the Borough of much needed affordable housing that a development of this size should provide.

For all these reasons, the Society has requested refusal of this application too. See our letter here.

See our previous letter here.

Epsom Lodge 1 Burgh Heath Road Epsom KT17 4LW

Click here to see map for location of Epsom Lodge 1 Burgh Heath Road Epsom KT17 4LW .

21/00031/FUL Change of use of existing Care Home (Use Class C2) to Residential (Use Class C3). Erection of three storey side and rear extension to create 9 flats (4 x 1 bed, 2 x 2 bed and 3 x 3 bed) and creation of basement car park.

Whilst not objecting to the principal of changing the use of the premises, we do feel that the suggested design is inappropriate for this location at the north end of the Burgh Heath Road Conservation Area and at a very prominent position.

The design of the main side extension does not include any similarities with that of the CA, and the window specifications are wrong, not even matching the retained facades. The ‘Edwardian’ style of the existing building is not mirrored in any form with the design of the new facades and is therefore contrary to the Council’s obligation to maintain the character of the CA.

The bulk and massing of the proposal is entirely out of keeping with the Conservation Area, and the Society also has grave reservations about the basement parking arrangement with an exit straight onto the mini roundabout and lack of forecourt space for delivery vehicles making an existing risk of traffic accidents even more severe.

Finally the Society regrets the proposal to fell a mature pine tree, subject to a Tree Preservation Order. For all these reasons, a refusal has been requested.

See our letter here.

38 The Ridings Epsom KT18 5JJ

Click here to see map for location of 38 The Ridings Epsom KT18 5JJ .

21/00064/FLH Formation of new vehicular access involving drop kerb incorporating new hard standing for driveway and soft landscaping, including the felling of Hawthorn T44 within TPO 165 located in the front garden.

This application for a new vehicle access, involving a drop kerb, new hardstanding, soft landscaping and tree felling is in a property located within the Downs Road Conservation Area, which is noted for its exceptional sylvan character and landscaping.

The proposal would have an adverse impact on the setting and involve the creation of a tarmac break in the grass verge, a two-car hard standing in the front garden and the loss of a tree subject to a Tree Preservation Order.

The Society believes the proposal is inconsistent with current planning policy to protect the lanscaping and appearance of Conservation Areas, and for that reason we have requested refusal.

See our letter here.

Epsom General Hospital KT18 7EG

Click here to see map for location of Epsom General Hospital KT18 7EG.

20/00249/FUL Erection of a multi storey car park comprising ground plus 5 storeys and 527 car parking spaces, reconfiguration of surface parking to provide 104 car parking spaces and improvement to the access road from Dorking Road.

This application is a second design for the proposed Multi-Storey Car Park (MSCP) for staff, patients and visitors to the hospital, to be erected on the existing ground-level car park at the side of the current hospital site next to Epsom Sports Club.

The Society previously objected strongly to the original application on the 30th March 2020, on the grounds of its excessive height, massing and scale and the impact it would have on the adjacent sports facilities and surrounding area, which includes the Woodcote Conservation area. It is also near to the Chalk Lane Conservation Area with possible adverse impacts for the southern part of Worple Road Conservation area bordering Avenue Road. The proposed MSCP would adversely affect the setting of three listed buildings on the north side of Dorking Road (East Lodge, the Bell House and Clock House Medical Centre).

Unfortunately, we do not believe that the latest plans and elevations solve any of the major design issues. The only main difference on the latest elevations are coloured panels within an aluminium cladding system. The design remains a utilitarian structure with a large bulk and mass and a bland, boxy design devoid of any quality architectural features, which is totally out of keeping with the surrounding residential area. In addition, the overall detrimental effect and harm to nearby heritage assets is, in the Society’s view, substantial, the quantity of parking proposed may be excessive in the light of climate change urgency, and thus the Society has maintained its objection the application.

See our latest letter here.

See our previous letter here.

6 The Grove Epsom KT17 4DQ

Click here to see map for location of 6 The Grove Epsom KT17 4DQ.

20/01855/FUL Erection of 7 x two bedrooms flats and 2 x three bedrooms flats and associated external works following demolition of the existing building.

This proposal is a modified version of Planning Application 20/00313/FUL which would have been refused by the council had it not been appealed. The Appeal directed that the application should be refused.

A previous application 18/00647/FUL (Conversion of house into 5 Flats) has already been permitted by the council for this site, which is located within the delightful Church Street Conservation Area and close by to the Grade 2 listed Grove House.

This latest proposal is not only inappropriate to its setting in the Church Street Conservation Area, but by converting 90% of the garden to car parking and road access would contravene local policy regarding Backland Development, destroy a green asset contributing to the value of the Conservation Area, and severely impact the adjoning property No 7 The Grove.

For these and many other reasons, the Society has requested refusal of the application.

See our letter here.

Holland House Mospey Crescent KT17 4LZ

Click here to see map for location of Holland House KT17 4LZ.

21/00110/FLH Installation of 1.8 metre steel fence within existing green hedge along front and part side boundary, and extension to existing dropped kerb. 2. Extending the width of dropped kerb, along Mospey Crescent.

While having no objection to extending the width of dropped kerb, the Society believes the proposal for a 1.8 meter steel fence is inappropriate in the location and constitutes an unacceptably adverse impact on the street scene in Mospey Crescent and the adjacent Burgh Heath Road Conservation Area.

For this reason, the Society has requested refusal of the application.

See our letter here.

HMG Consultation – Supporting housing delivery and public service infrastructure

On 3 December 2020, the Ministry of Housing Communities and Local Government launched a consultation, ‘Supporting housing delivery and public service infrastructure’ seeking views on proposals for:-

  • a new national permitted development right for the change of use from the Commercial, Business and Service use class (Class E, introduced in September 2020) to residential (Class C3) to increase delivery of new homes (without the need to go through the full planning application process)
  • measures to provide public service infrastructure (schools, colleges and universities, hospitals and prisons, young offenders’ institutions, and other criminal justice accommodation) more quickly through expanded permitted development rights and a streamlined planning application process
  • the approach to simplifying and consolidating existing permitted development rights following changes to the Use Classes Order.

HMG’s Consultation Document can be seen here https://www.gov.uk/government/consultations/supporting-housing-delivery-and-public-service-infrastructure

Broadly, the Society felt that it was premature for the Government to plough on with the changes set out, given that they have yet to respond to the concerns raised by the Society and many others (44,000 responses in total) about the basis and practicality of the earlier reform proposals set out in the ‘Planning for the Future’ consultation document (August 2020). In summary, our view is that these latest proposals (as with the earlier consultation) are:

  • thinly researched in terms of evidence of the nature and cause of problems
  • failing to consider the wider context in terms of the role of town centres, the lack of resources within local authorities to speed up the planning process, the shortage of funding for public sector building projects
  • excluding local people from planning approval decisions in their own areas
  • an almost ‘Soviet style’ centralisation of control towards national government which does not sit well in terms of either efficiency or effectiveness (nor the liberal democratic tradition of this country).

Here is our full response to this consultation https://epsomcivicsociety.org.uk/wp-content/uploads/sites/5/2021/02/Epsom-Civic-Society-responses-to-Govt-Consultation-re-New-PDR-and-Public-Service-Infrastructure-28-January-2021-CV.pdf