21/00696/LBCALT and 21/00695/FUL | Partial redevelopment and conversion of the former Fawkham Manor Hospital for residential (C3 Use), including self-contained houses and apartments. Including demolition of modern hospital wings and outbuildings. Associated landscaping, erection of ancillary outbuildings, including bin and bike stores. | Fawkham Manor Hospital Manor Lane Fawkham KENT DA3 8ND

Fawkham Parish Council is not against the principle of the re-development of Fawkham Manor Hospital,  nor the replacement of the hospital wings. However, we have various issues with the resubmitted proposals which cause us to object to this planning application on a number of grounds including the harm to the listed building through the design, layout and number of units, and the inappropriate number of units in this unsustainable rural location, including the impact on local infrastructure.

1. HARM TO THE LISTED BUILDING – these comments also apply to 21/00696/LBCALT 
We are pleased to see that the manor house itself remains largely unaltered. We welcome the removal of elements such as the metal external stairs, and the return of Fawkham Manor to residential use. We also welcome the gap now proposed between Block A and the Manor House, the resulting repair of the gable end, and the moving back of Block A. However, our view remains as an objection to the current planning application overall and we make the following comments:
1.1 Design
1.1.1 Our view is that the design of the new Blocks, though altered, is not in keeping with that of Fawkham Manor, and would cause harm to the Listed building.
1.1.2 The materials and style of the roof, although altered from the previous application, do not reflect the red and black bands of clay tiles of the Manor House. The drawings submitted by the developers are misleading as they show the existing manor house roof as being dark grey. The manor house’s notable Victorian architect, EB Lamb, chose to avoid the use of slate tiles, which were pre-dominant in Victorian houses, in favour of polychromatic clay tiles. We feel clay tiles would be more suitable for the roof.
1.1.3 The horizontal red bands of brick, which are a very striking feature of the Manor House, are not used in the proposed design (although they are incorporated into the design of the hospital wings). The predominant material of Fawkham Manor is grey flint, with red horizontal brick bands and buff brick infill. The proposed new build is entirely of yellow London Stock brick. We would welcome a nod to the manor’s design through the use of red bricks, for example for the bands over the windows.
1.1.4 The windows in the roof are, in our opinion, unattractive. Small dormers with pitched roofs would, in our opinion, be more suitable.
1.2 Layout
1.2.1 We believe that Block C will adversely effect the views of the north-east elevation of  Fawkham Manor from Manor Lane currently available via the old staff car park opening. The removal of the building within the car park, and the removal of hedgerow for sight line purposes, will both serve to open up the view further.
1.2.2 The Listing statement states that this north-east garden front is the most formal elevation and so we believe it is important that the setting of, and views to, that elevation are protected from harm. In our view, this would be best achieved by the removal of Block C from the proposals. This would have added benefits, described later.
1.2.3 On detailed points:
  • Appendix 3 of Heritage statement does not include the historic fireplace uprights below the window as a heritage feature to be retained. We request that this feature, mentioned in the Listing details, is retained.
  • Comment is made (Heritage Statement 3.17) that it is difficult to tell what the original layout of the interior was, and what features are original. The Parish Council is aware that the 1949 estate sales particulars are available, which include interior photos and room dimensions which would assist here, and which should be examined (these are available from the Parish Council).
  • We request that a Conservation Officer visits the interior of the site to record the heritage features prior to work commencing and that a further visit is made after the works are completed.

1.2.4 Given that Fawkham Manor is a heritage asset, a balanced judgement is required on the scale of harm or loss and the significance of the asset [NPPF para 197]. We feel the proposed design and layout of the new Blocks will harm the setting of the manor house, contrary to policy EN4 of the Core Strategy, and further that the design is not aligned with SP7 or EN1 (a) of the Core Strategy, nor paragraph 127 (b) of the NPPF, and we would like to see it altered.

2. NUMBER AND TYPE OF UNITS PROPOSED 

2.1 Although the number of units has reduced from 32 to 26, there is the same number of bedrooms in the revised proposals and so a similar number of residents. The impact on the local infrastructure remains unchanged from the previous proposals. These impacts are discussed later.
2.2 SDC’s Policy SP5 seeks smaller less than 3 bedroom units. The Planning statement says at 4.4.14 that the proposal will help to increase the proportion of smaller units in SDC’s housing stock policy SP5. However, 18 of the 26 units are 4 bed town houses. Of the 8 apartments within the Manor House itself, 1 is 3 bed and 7 are 2 bed, although it would be difficult to describe them as small units as they are, on average, 117m2 in size, around double the size of an average 2 bed apartment. Our view is that the proposal does not help in any significant way to increase the stock of smaller units.
2.3 The Planning statement suggests as 4.4.15 that the units will be suitable for “older households” and those downsizing. It seems unlikely that 4 bed townhouses arranged over three storeys will appeal to such households. The units are around 130m2 and so are above the UK average house size of 85m2 (and 76m2 for a new build).

2.4 The Planning Statement suggests that the units will contribute to the housing need identified in the Local Housing Needs Survey conducted in the neighbouring parish of West Kingsdown  However, an analysis of the needs identified shows only a minority are looking for smaller homes, of which several want bungalows, with others wanting some level of care provision, and West Kingsdown PC are in the process of providing 10 affordable and 3 market houses to help meet that need.

Our view is that the units will not help to meet the identified local need for units for older households looking to downsize.
2.5 In addition, Fawkham is classified in the Settlement Hierarchy as a hamlet, and has around 221 dwellings. Fawkham is in the lowest tier of the Settlement Hierarchy, and as such is unsuitable for much development. It is an unsustainable location: SDC identifies seven facilities and services consider key to sustainability, and states four or more of these as indicating a more sustainable location that may be able to support future development. Fawkham only has two of these key facilities, not four: a village hall and and 0.5 form entry primary school. It does not have the other key facilities: bus transport, rail transport, a doctor, a Post Office or a small store. The 26 units proposed here represent an increase of nearly 12% in the housing stock.
3. HARM TO THE GREEN BELT
 
3.1 We agree with SDC’s assessment of the previous application that the proposals would have a greater impact on openness than the existing development. We feel the revised application will too.
3.2 We disagree with the assertion made at 4.5.9 of the Planning statement which states that the second limb of NPPF para 145 (g) applies. We do not feel that provision of two affordable houses, off site, should be regarded as sufficient to meet this exception. The proposal seeks to reduce the affordable housing contribution as far as possible, whilst also seeking to use that reduced contribution to apply the second limb of 145 (g). Given that SDC policy is for all developments over a certain size to contribute 40% affordable housing, this proposal is merely complying with that – though in fact it then reduces its contribution from 10 to 2 by requesting offset against the existing buildings, which are in a different use.
3.3 Rather, FPC asserts that the first limb should apply, which requires that the redevelopment of PDL should not have a greater impact on the openness of the Green Belt than the existing development. This proposal does have a greater impact, both in footprint and volume, and the harm under the first limb does not have to be substantial, just greater.
4. INFRASTRUCTURE ISSUES

4.1 Overview of the Fawkham Manor Estate

It will be useful to provide at this point an overview of the “Fawkham Manor Estate”. This was part of a larger estate from medieval times which covered most of the parish of Fawkham, purchased in the late 1800s by the Hohler family, which remained largely intact until 1949 when it was sold to the Billings family. In this response, references to the “Fawkham Manor Estate” should be taken to be the area bound by Manor Lane to the east which is accessed by a private road, named “Fawkham Manor Farm”. Some plots within this estate were sold in the 1960s and now form separate residences. Properties on the estate in addition to Fawkham Manor comprise: The Bungalow at Grange Park Farm, Lot 12, Oakwood House, The Coach House, Stables Cottage, 1 Stables Cottage, Parkwood, Park Field, The Spinney, The Cottage and North Lodge.

In the immediate vicinity of the manor house is the accompanying stable block, also designed by Lamb, which has been converted into three residences: The Coach House, Stables Cottages and 1 Stables Cottage. These are not mentioned in the Planning Statement [2.3.1] despite them being the nearest properties to the manor house.

FPC has again sought the views of the residents on the estate, plus those living close by on Manor Lane, and these are reflected in our response.

4.2 Car Parking

4.2.1 The plans include too few parking spaces for the location, and a reduction to 59 from the existing 78, according to the Design and Access statement, although the Planning statement retains the previous 71 at 4.8.2 which may be an editing error – clarity is needed as to which is correct. The comments below assume 59.

4.2.2 Although the proposals adhere to KCC’s minimum vehicle parking standards, we ask that SDC exercises its right, under Policy TN2, to depart from these to take account of special local circumstances and request significantly further parking, both for residents and for visitors/deliveries, for the following reasons:

  • There is no easy access to public transport (a bus stop some 1.3km+ away can only be accessed via PROWs across fields and through woods – obviously unlit and at times very muddy).
  • Residents will be reliant on private cars, as are the vast majority of residents in Fawkham.
  • The latest census data shows a third of houses in Fawkham have 3 or more cars. Given that there will be 18 four bed townhouses, these are likely to have more than 2 cars each.
  • There is no “on street” parking available anywhere close to the site: Manor Lane is a single track road and the estate is served by a single track private access road. Any parking on either of these would block the route, including for emergency vehicle access.
  • Given that the proposed car parking spaces are close to or, in many cases, within the 15m buffer zones for the ancient woodland, it will be important to ensure that parking in kept to with the marked bays, rather than extending further into the buffer zones.
  • The “tandem” parking arrangement proposed for Blocks B and C is contrary to KCC’s parking standards which state that parking spaces for such units should be independently accessible.
  • We feel the current amount of parking spaces per unit is likely to cause blockages and access problems for residents on this site and those elsewhere on the Fawkham Manor estate, and also for emergency vehicle access.

4.2.3 The parking arrangements are contrary to EN1 of the Core Strategy.

4.3 Transport

4.3.1 To reach any services or facilities, future occupants would need to negotiate Manor Lane, a single track lane with steeply sunken sides, many bends and few informal passing places. It represents an unsafe walking environment due to the apparent speed of the traffic, absence of a footway and absence of lighting. Manor Lane is frequently covered with flints washed down from its steep sides, making walking unsafe, especially in the dark. For similar reasons cycling is unlikely to be desirable and would require a level of confidence, fitness and proficiency that future residents may not possess. It is therefore likely that future occupants would be car dependent, as are existing residents of Fawkham, as shown by a recent survey of Fawkham (January 2019): only 15.5% of respondents regularly walk as a form of transport and only one stated they regularly cycle, with only six (4.7%) cycling occasionally.

4.3.2 The Transport Statement suggests that people can use PROWs to reach services at New Ash Green, but the recent survey quoted above would suggest that is unlikely to happen in practice. The footpaths in the area reflect ancient settlement patterns and do not lead directly to New Ash Green Village Centre, which was built in 1967. It is unrealistic to think people will walk across fields along PROWs to reach a bus stop some 1.3km distant, to access a very limited bus service, which does not go to destinations such as Swanley, Dartford and Sevenoaks.

4.3.3 Section 1.3.7 of the Transport Technical Note states “existing passing bays are provided”. Please can the developer be asked to advise the location of these as we are not aware of any passing bays. Manor Lane is at its narrowest along the boundary of the Fawkham Manor estate, which is around 0.5in length. There are 2 or 3 informal places along this 0.5 miles where cars  can pass by each other by driving up the hedgerow/ancient woodland’s bank in a manoeuvre not all drivers are happy to/capable of doing. There is much reversion around blind bends for long distances to reach a wider section of the road. Thes e informal places have been created over time by vehicles going up the steep-sided hedge banks, causing erosion to them and damage to tree roots. None of the places has been designed. One passing place is on front of a field access gates, and all are probably on private land, rather than on the public highway. It is only possible for one car to pass in each direction. The traffic patterns that will be seen under residential use, with school runs and work commutes, are likely to result in traffic congestion issues.

4.3.4 Section 1.3.7 of the Transport Technical Note also says Manor Lane is “lightly trafficked” but no evidence has been provided for that. This should be requested and provided before any planning permission is decided.
4.3.5 KCC Highways has previously asked for a speed survey of Manor Lane to be undertaken. This should be requested and provided before any planning permission is decided.

4.3.6 Section 1.3.10 of the Transport Technical Note talks of residents using the services and facilities in New Ash Green, however a survey of Fawkham residents in 2019 shows residents are far more likely to use the services and facilities in Longfield, and access these via Valley Road. The majority of journeys will be westwards, along the narrowest parts of Manor Lane, to reach Valley Road, and from there to Longfield, Bluewater or Swanley.

4.3.7 Manor Lane leads onto Valley Road at a blind bend where Valley Road is less than 4m wide. The Transport Statement acknowledges that the visibility splays at Manor Lane’s junctions are substandard [2.1.3] and it is our view that this junction could not be improved.

4.3.8 The Transport Technical Note states at 1.3.8 that although it is acknowledged that the visibility at the junction of Manor Lane with Valley Road is sub-standard, the last 3 years crash data does not show any records. However, data for the last 10 years shows 4 records around that junction, plus 2 on Manor Lane itself and a further 3 at the Chapel Wood Road junction, one of which was serious.

4.3.9 In terms of wider road network, Valley Road represents a quicker route from the M20/A20/ M25/A2 than using an alternative route via the Ash Road and so it is our belief that most traffic movements to/from the site would use Valley Road. Valley Road is a narrow C- graded road in poor condition, liable to flood in a number of places, with several blind bends and subject to a 7.5T except for access restriction. KCC Highways has previously stated [DLPS7505] that “additional movements on Valley Rd and Fawkham Road … would not be desirable”. It has also previously been noted that “access to major routes [from Fawkham] is not easy, due to the narrow rural nature of local roads, despite the relative proximity of the motorway network” [SDC’s Conservation Area Appraisal for Baldwins Green, Fawkham].

4.3.10 No travel plan has been submitted for this application, which, given its unsustainable location, we feel should be required.

4.4 Access

4.4.1 The information provided by the applicants only contains information about two of the three access points to the Fawkham Manor Hospital site (as was). These three access points are:

1.The entrance to the old staff car park direct from Manor Lane – this is planned to be the car park for the 12 townhouses in blocks B and C. We would ask that the sight lines when exiting these be checked by KCC Highways.

2. The entrance close to Oakwood House, which was primarily for hospital deliveries, which leads via a single track private road, Fawkham Manor Farm, to the car parking to be used by residents in the apartments in the manor house and Block A.

3. There is also a 3rd Northern access point, also along the private Fawkham Manor Farm, leading from an entrance point off Manor Lane by North Lodge. This was the main entry point for patients/visitors to the hospital. Again, it is single track, and fenced for most of its route with very few passing spaces. During consultation for the Local Plan for a different proposed development using this access, KCC Highways commented [DLPS6177] “Visibility may be an issue due to curve of road and established hedges and trees. Vehicles entering and exiting the access southwards may be problematic due to the sharp alignment of the road to the access”.

It is disgenious to ignore the existence of this access point. The Access Statement says “access will continue as existing from Manor Lane and Fawkham Manor Farm” [7.1] but refers only to the first two access points above. The existing access for the hospital also includes the third access point, over which we understand it has a right of way. Indeed, this was the most frequently used access when in hospital use. We again request some clarity on the use/prevention of use of this access.
4.4.2 The Access Statement states that the nearest properties are located along Manor Lane – which ignores the properties on the estate itself, which are closer to the Manor House, which are listed above.

4.4.3 We would ask that KCC Highways makes a site visit to assess the access and the condition of Manor Lane. Overall, we believe the arrangements are contrary to EN1 and EN2 of the ADMP.

4.5 Vehicle Movement Trip Analysis

4.5.1 We would question the results of the vehicle movement trip analysis undertaken, although based on a better comparison than previously, it is only based on one location – which casts doubt on the data’s robustness.

4.5.2 The traffic movement patterns will differ from those of the hospital use, when movements were spread throughout the day, with more of an impact on the morning and evening peak times. There will also be more traffic movements at the weekends than when in hospital use.

4.5.3 The vehicle movement analysis is also based upon a false assumption, as it ignores the fact that the 3rd most northern access point was the one used by hospital patients and visitors. If this access is (somehow) not used, then the traffic movements via the other two access points will in fact increase when compared to the former hospital use. In addition, there will be traffic travelling further up Manor Lane from Valley Road to reach these two access points, which will cause further erosion to the banks and further damage to tree roots.

4.5.4 We would like to see a more realistic analysis undertaken before we can comment further. We would ask that KCC Highways makes a site visit to assess the access and undertakes a traffic analysis. As it stands, we feel the proposals are contrary to EN2 of the ADMP.

5. OTHER ISSUES

5.1 In terms of footprint, should the current footprint used in calculations exclude buildings which are only entered to service equipment, for example, the plant room?

5.2 As the proposal is not to re-use the hospital wings, but rather to demolish and replace them, does Policy GB9 apply which is cited in the Planning Statement?
5.3 GB9 (c) – not quoted by the developer’s agent –  states “the replacement building would be within the same use as the building to be demolished”. The building being demolished was a hospital and the replacement building is residential. It would seem

5.4 S106

FPC does not object to the lack of affordable housing on site, as the last Local Housing Needs survey in 2017 did not show a need for affordable housing. However, we feel that a s106 payment contribution equating to two (down from three) houses elsewhere too small. We note that the NPPF says that where “vacant buildings are redeveloped, any affordable housing contribution should be reduced” however, it is only the Manor House itself that is being redeveloped, with 8 apartments, and the remaining 18 are being newly built. We are disappointed that the planning framework does not account for a change of use from hospital to residential in this regard.

5.5 CIL

5.5.1 We note that the applicants are seeking a large reduction in their CIL liability to take account the existing floor area which has been in lawful use – does a change in use to residential affect this suggested reduction?

5.5.2 Clearly use as a hospital does not affect local community infrastructure in the same way as residential properties. The GP surgery is under particular pressure and has no capacity. The village school is a 0.5 form entry and heavily over-subscribed.

5.5.3 The proposed 26 units represents an increase in housing stock for Fawkham of 12%, which will have an impact on the local infrastructure which, we contend, should be liable for full CIL payment. As CIL Regulation 40 (as amended) is highly technical we rely on SDC to undertake the appropriate calculation.

5.5.4 We feel a development of this size should need to deliver improvements to infrastructure and, in addition to seeking to greatly reduce the CIL liability, no such improvements are being suggested by the applicants.

5.6 Ecology/Ancient Woodland/Biodiversity

Should planning permission be granted, we would like to see the suggested new woodland, woodland management plans, enhancements, and protected species protection measures made conditions. The Ancient Woodland should be protected in line with statute. We would also want to see Lighting specified under condition, and the biodiversity enhancement offered at 4.9.9 also made a condition.

5.7 Valley Road: planning condition

Should permission be granted, FPC would wish to see a condition that no delivery/ construction traffic is to access the site via Valley Road (which would represent a quicker route from the M20/A20/M25/A2 than using an alternative route).

SUMMARY

We would like to see Block C removed from the proposal. This would help remove the greater impact on the openness of the Green Belt, protect the listed building from harm (when coupled with changes to design), alleviate the impact on local infrastructure, including pressures on parking. We would also want to see changes to the design of the remaining Blocks, as detailed above.
We would like to see more contributions via CIL and to affordable housing.

Fawkham Parish Council