Planning – Application Comments

Consultation Date: Thu 10 Apr 2025

Consultation Date: Thu 10 Apr 2025

Consultation Date: Thu 10 Apr 2025

Consultation Date: Thu 10 Apr 2025

Consultation Date: Thu 10 Apr 2025

Consultation Date: Thu 10 Apr 2025

Comment Date: Fri 30 May 2025

LLFA consultation response 25.00409.FUL 30.05.2025.pdf

Comment Date: Fri 09 May 2025

Thank you for consulting Historic Environment about the above planning application. The proposal is for the change of use of a sports court to car park and drop-off area, with an extension to the existing hardstand.

Significance Assessment
The proposed car park is located within the Millfields Conservation Area (adopted 1977), the CA covers the former Stonehouse Royal Naval Hospital site. The Naval Hospital was built in 1758-1762 by Alexander Rovehead, probably with William Robinson as consultant architect, for the Navy Board. Various additional hospital buildings were constructed as demands on the site changed until it closed in 1995 and was released for mixed use redevelopment. The CA comprises a large formally planned group of major historic buildings within a formidable boundary wall. The monumental and formal character of the site sits in strong contrast to the surrounding area of closely developed townscape. This is most clearly seen in the quality of the buildings that occupy much of the site. There are 21 buildings and structures which appear on the statutory list of Buildings of Special Architectural or Historic Interest, and 11 buildings or groups of buildings that are considered to make a positive contribution to the Conservation Area including 99 Craigie Drive.

Comments
Historic Environment have not in-principle objection to the proposed change of use to parking, or the extension of the hardstanding by an additional 13m2. We do however questioned the use of hit and miss timber fencing to create the boundary, and more broadly the use of timber fencing immediately in front of the School which is shown as existing on the submitted drawings. Timber fencing does not form part of the established material palette for the conservation area which is characterised by granite, Plymouth limestone and metal railing boundaries. We would highlight principle 2 of the Conservation Area Appraisal and Managment Plan;

"Principle 2 - The position, scale, massing and materials of new development will be expected to respect the existing character of the Conservation Area. "

The proposed and existing timber fencing does not respect the existing character of the CA and is to domestic for such a high quality arrangement of major historic buildings. Our preference would be for metal railings that reference the existing boundaries and railings found elsewhere on the site.

Recommendation
When considering developments that affect a designated conservation area, the Local Planning Authority shall give special attention to the desirability of preserving or enhancing the character or appearance of that area, as set out in Section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), requires clear and convincing justification, NPPF16 Para 213. Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal. Less than substantial harm does not mean that the proposed harm is insignificant including, where appropriate, securing its optimum viable use NPPF 16, Para 215.

The works as proposed within this application are considered to result in a low level of 'less than substantial harm' to the significance of the conservation area as a heritage asset. The proposal will result in harm through the introduction of inappropriate boundary treatments unless amended, this will affect the setting and quality of the Conservation Area Streetscape. The public benefit resulting from the proposal is considered to be clear in providing a safe parking and drop off location for the school. We are broadly supportive of the change of use and extension of the hardstanding, the concerns stem from the quality of the proposed materials rather than the acceptability of the scheme in principle.

In weighing up the impact of the development on the significance of the designated heritage asset and the public benefit resulting from the proposal, Historic Environment find the proposed development unacceptable without amendment to include a higher quality contextually appropriate boundary treatment. As such the development is currently considered contrary to guidance within DEV21 of The Plymouth and Southwest Devon Joint Local Plan, NPPF guidance (DEC 2024) and The Planning (Listed Buildings and Conservation Areas) Act 1990.

Comment Date: Fri 02 May 2025

2500409FUL 99 Craigie Drive.pdf

Comment Date: Tue 29 Apr 2025

LLFA consultation response 25.00409.FUL.pdf