Planning – Application Comments

Consultation Date: Mon 19 May 2025

Consultation Date: Mon 19 May 2025

Consultation Date: Mon 19 May 2025

Comment Date: Wed 30 Jul 2025

PLYMOUTH CITY COUNCIL CONSULTEE COMMENTS FOR A PLANNING APPLICATION.

APPLICATION SUMMARY
PLANNING APPLICATION: 25/00684/FUL
ADDRESS: 50 Dunstone Road, Plymstock, Plymouth PL9 8SF
DESCRIPTION: Conversion of care facility to 4no. dwellings including the removal of the conservatory (part retrospective).

CASE OFFICER: Sam Lewis (Planning Officer)
Development Management, PCC Strategic Planning & Infrastructure, Floor 2 Ballard House PL1 3BJ

CONSULTEE: Gary Lester (Transport Officer)
PCC Strategic Planning & Infrastructure, Transport Planning Team, Floor 2 Ballard House PL1 3BJ

Date: 18th July 2025

AMMENDED COMMENTS:
Following the submission of amended details, and further to the previous comments dated 19th June 2025, the Local Highway Authority (LHA) would no longer wish to raise any objections in principle the proposed Change of Use and sub-division of the property from its previous use as a residential Care-Home, into four in number dwellings with private car parking.

Referring to the amended details in the Transport Technical Note and the amended drawing titled and numbered, 'Site Plan Option B - 2025-08-1005 REV A', shows car parking for each of the proposed four dwellings. Comprising of two separate banks of two car parking spaces (total 4) directly off Dunstone Road, one bank using the existing vehicle access, and the second bank provided with a new and additional vehicle access and footway crossing further along the street that also includes a bin storage area, and incorporates the necessary intervisibility splays either side of the two parking spaces. Although not shown, the new private parking area should be permeably paved, or positively drained and include a drainage channel. With the further three private car parking spaces located within the rear courtyard, using the existing access from Dunstone Road.

The proposed private car parking in the rear courtyard for both the 2-bed, and 1-bed, dwelling meet the indicative parking standard, having two parking spaces, and one space, respectively. However, the car parking off Dunstone Road for the two 4-bed dwellings falls short of the indicative standard by one space each, with the application details suggesting the proposed level of private parking would maintain the status quo of the previous Care Home use. On balance with all things considered including, the previous use, accessibility, proximity to local amenities and services, and car ownership, the indicative parking shortfall of two spaces is acceptable.

The amended details indicate the proposed development will not result in a loss of car parking and its availability for use at the neighbouring dwelling number 54, using the existing arrangement.

The application details confirm that the necessary electric vehicle charging points and infrastructure can be provided; along with the required cycle storage within the private gardens; all in accordance with the standards set out in the Councils SPD. With a recommendation that those provisions are secured by way of a planning condition.

SUMMARY:
As considered above and on balance the LHA would not wish to raise any objections to the proposed Change of Use and sub-division of the property from its previous use as a residential Care-Home, into four in number dwellings, providing, private car parking, electric vehicle charging points, and cycle storage; in accordance with the amended technical note and drawing titled and numbered, 'Site Plan Option B - 2025-08-1005 REV A'. Recommending the following planning conditions are applied: -

CYCLE PROVISION (amended)
() No dwelling shall be occupied until space has been laid out within the site in accordance with the guidance set-out in paragraph 8.30 of the Councils SPD
To provide high quality conveniently located, secure, and preferably covered cycle parking/storage at a ratio of once cycle parking space per bedroom at each of the four dwellings. The secure area for storing bicycles within the private gardens shall remain available for its intended purpose and shall not be used for any other purpose without the prior consent of the Local Planning Authority.

Reason:
In order to promote cycling as an alternative to the use of private cars in accordance with Policy DEV29 of the adopted Plymouth & Southwest Devon Joint Local Plan 2014 - 2034.


PARKING PROVISION (amended)
() In accordance with the approved amended plan drawing titled and numbered, 'Site Plan Option B - 2025-08-1005 REV A' each parking space shown on the plan including the respective intervisibility splays shall be constructed, drained, surfaced, and made available for use before the unit of accommodation that it serves is first occupied and thereafter that space shall not be used for any purpose other than the parking of cars belonging to the occupiers.

Reason:
To enable vehicles used by occupiers or visitors to be parked off the public highway so as to avoid damage to amenity and interference with the free flow of traffic on the highway in accordance with Policy DEV29 of the adopted Plymouth & Southwest Devon Joint Local Plan 2014 - 2034.


PROVISION OF ELECTRIC VEHICLE CHARGING POINTS (amended)
() Prior to occupation of the four dwellings one in number electric car charging point shall be provided at each of the four dwellings parking space in accordance with the details set out as a minimum requirement in par 8.39 & Table 33 of the Councils Supplementary Planning Document (SPD).

Reason
To assist in the lowering the carbon footprint of the development in accordance with Policy DEV29 of the adopted Plymouth & Southwest Devon Joint Local Plan 2014 - 2034.


INFORMATIVE: KERB LOWERING
() Before the access hereby approved are first brought into use it will be necessary to secure dropped kerbs and a vehicle footway crossing with the consent of the Local Highway Authority. The applicant should contact Plymouth Highways for the necessary approval. Precise details of all works within the public highway must be agreed with the Highway Authority.

INFORMATIVE: PUBLIC HIGHWAY APPROVAL
() This planning permission does not authorise the applicant to carry out works within the publicly maintained highway. The applicant should contact Plymouth Highways for the necessary further approval. Precise details of all works within the public highway must be agreed with the Highway Authority and an appropriate Permit must be obtained before works commence.


Gary Lester
Transport Planning Officer
Officer authorised to sign on behalf of the Service
Director for Strategic Planning & Infrastructure

Comment Date: Thu 17 Jul 2025

250717_2500684FUL 50 Dunstone Road.pdf

Comment Date: Mon 30 Jun 2025

PLYMOUTH CITY COUNCIL CONSULTEE COMMENTS FOR A PLANNING APPLICATION.

APPLICATION SUMMARY
PLANNING APPLICATION: 25/00684/FUL
ADDRESS: 50 Dunstone Road, Plymstock, Plymouth PL9 8SF
DESCRIPTION: Conversion of care facility (Class C2), to 4 in number dwellings (Class C3), including the removal of the conservatory.

CASE OFFICER: Sam Lewis (Planning Officer)
Development Management, PCC Strategic Planning & Infrastructure, Floor 2 Ballard House PL1 3BJ

CONSULTEE: Gary Lester (Transport Officer)
PCC Strategic Planning & Infrastructure, Transport Planning Team, Floor 2 Ballard House PL1 3BJ

Date: 19th June 2025

COMMENTS:
The Local Highway Authority (LHA) is unable to support the proposed development in its current form and would object to planning permission being granted, for the proposed Change of Use and sub-division of the property from its previous use as a residential Care-Home, into four in number dwellings. Comprising of :- 1x 1- Bedroom dwelling + 1x 2-Bedroom dwelling + 1x 3-Bedroom dwelling + 1x 4-Bedroom dwelling. Although the drawings and Technical Note (TS - par 4.3.1) instead indicate there are 2 x 2-bedroom dwellings plus 2 x 4-Bedroom dwellings.

The application property is situated in the suburban Plymstock (Dunstone) area of the city, where car ownership levels tend to be amongst the highest in the city with an average car ownership of more than one car or van per household. The property has an existing driveway with off-street parking to accommodate two cars at the front in Dunstone Road, which as part of the proposal would be removed and closed off but re-provided close by adjacent to the west boundary. There is also an existing driveway entrance and private access road along the side of the Barn on the east boundary of the site, which leads to a type of rear courtyard area, all surfaced with gravel and concrete. Part of the courtyard at the rear of the building has previously been used for informal staff car parking associated with the Care Home, although not identified in the application details, parking which would be lost and unavailable following the proposed redevelopment. But alternatively, the proposal would put in three in number new car parking spaces in the northeast corner of the courtyard, to providing one parking space for each of the three remining three dwellings.

The existing driveway and courtyard of the application property also provides pedestrian and vehicle access to the adjacent dwelling number 54, which is situated to the rear of the application property and benefits from an established pedestrian and vehicular right of way over it. Although number 54 is outside of the ownership and (red line) of this planning application, it relies on the use of the right of way over the neighbouring driveway and courtyard of the application property for access, including to its parking space. Although the Right of Way is not a material planning consideration, any resultant loss of car parking at number 54 would be, therefore the application needs to show that this proposal would not result in a loss of parking at number 54.

The proposed four dwellings would be served by five in number off-street parking spaces. With one of the four-bedroom dwellings having two car parking spaces, and the remaining three dwelling have one space each. Which would be a shortfall of three (or 5 spaces if there are, 2x2-bed + 2x4-bed dwellings) when compared to the Councils indicative parking standards, set out in Section 8 of the Supplementary Planning Document (SPD). That, contrary to best practice and Council policy, in this location would likely cause overspill car parking outside in the street as acknowledged in the application details.

Moreover, the shortfall in off-street parking would be further compounded in that the proposed re-provision of two of the parking spaces with a new vehicle access and driveway to serve one of the dwellings in Dunstone Road, is considered impractical and unsafe. Because, although Dunstone Road is unclassified and therefore a car would not ordinarily need to turn within the property but could reverse in or out (As already occurs at the adjacent existing driveway and parking serving the site that would become redundant and be close off). The proposed two new car parking spaces are set differently, not as the existing at ninety degrees and directly off the street where a car could easily and safely reverse in or out. But instead, they are situated behind a wall and set further into the site and parallel to the street, accessed via a short driveway entrance of approximately 2.8 metres wide and 5.0 metres in length. After entering the new driveway, or leaving the two new parking spaces, a car would need to make a tight sharp ninety-degree turn. Where there would be insufficient space to do so, in either forward or reverse gear, within the constrained parking and driveway layout, making their use less likely. Incidentally, an example of a parking layout and the space needed to make a tight ninety-degree turn within a private driveway as informed by car wheel tracking, can be found in Figure 7.4.2 Private Drives, in the Councils Devon Design Guide, Highways in Residential and Commercial Estates.

Furthermore, the proposed new driveway entrance/exit in Dunstone Road lacks the necessary inter-visibility splays either side where it meets the footway. Therefore, a car leaving the site would emerge blindly (either in forward or reverse gear) onto the footway between two high piers and the boundary wall, without any advanced warning of, or for, a pedestrian walking along the footway, which would be unsafe. Unlike the existing access and parking serving the site in Dunstone Road that is much wider at about five metres wide, and more at the entrance itself where there are lower curved entrance walls, that altogether provide inter-visibility between a pedestrian and an emerging car. Therefore, due to the lack of inter-visibility at the new entrance/exit, and for highway safety reasons, the proposed two new parking spaces along with the new access and associated vehicle footway crossing in Dunstone Road, would be substandard and unsafe in its use and therefore not supported or approved by the LHA.

The Councils Supplementary Planning Document (SPD) in Section 8, Transport and Infrastructure (DEV29-DEV31) (along with Section 13) relates to transport provisions. That referring to paragraph 8.2 (reflects current national guidance) and should be considered alongside: The NPPF, NPPG, and the site specific policies set out in the Joint Local Plan - The Chartered Institution of Highways and Transportation (CIHT), and the institute of Highway Engineers (IHE)'s Guidance Note: Residential Parking - The government's Manual for Streets: Designing and modifying residential streets - And Manual for Streets 2: Designing and modifying non-trunk roads and busy streets ' Also the Design Manual for Roads and Bridges (DMRB).

Council policy guidance and parking standards contained within Section 8 of the SPD, accords with the advice within the NPPF (2024) in respect of the transport considerations and provisions and the weight afforded as part of the planning balance. Including the advice in the NPPF paragraphs 112 & 115: - (112) advising, If setting local parking standards for residential and non-residential development, policies should take into account: a) the accessibility of the development; b) the type, mix and use of development; c) the availability of and opportunities for public transport; d) local car ownership levels; and e) the need to ensure an adequate provision of spaces for charging plug-in and other ultra-low emission vehicles. Along with advice in paragraph 115 that, in assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that: - a) sustainable transport modes are prioritised taking account of the vision for the site, the type of development and its location - b) safe and suitable access to the site can be achieved for all users - c) the design of streets, parking areas, other transport elements and the content of associated standards reflects current national guidance, including the National Design Guide and the National Model Design Code.

Whilst the National Model Design Code, Part 1, under the heading 'Movement' paragraph 50 states (inter-alia): - (iii) Car parking: Standards for all uses will be set in the local plan, but the ways in which they are accommodated will vary... And (iv) Cycle Parking Standards will be set in the local plan'

The Councils SPD in paragraph 8.6, advises, Car parking standards for new residential development are important to avoid adverse impacts of inadequate parking such as excessive on-street parking or illegal parking and to protect the amenity of surrounding residential areas and ensure safety of the highway network. Paragraph 8.7 includes Table 30 that gives indicative car parking provision for new residential development, including residential conversions. The indicative residential car parking standards are: - one parking space for each one-bed dwelling ' two parking spaces for each two or three-bed dwelling ' And three parking spaces for each four-bed dwelling. Whilst also stating that any application that proposes a lower or higher level of parking is required to provide evidence to justify the proposal.

In terms of the accessibility of the location, paragraph 8.19 of the Councils SPD provides a map that shows accessibility across the city by public transport, Bus, although used when considering parking for commercial applications, it is none the less the councils accessibility indicator for sustainable bus travel. Referring to this shows the location of the application site has poor accessibility by bus, being just 25% accessible by bus (despite having bus stops within walking distance). That when coupled with the local area having one of the highest car ownership levels within the city averaging more than one car (or van) per household. Indicates the development is likely to have a car parking demand in accordance with the Councils indicative parking standards

So, whilst acknowledging there are a range of local facilities and amenities nearby including the Broadway Shopping Centre, Goosewell Primary School, and bus stops, that does not necessarily negate the need for car ownership or use for some essential travel and longer journeys. Although the Council supports the need to encourage sustainable travel, parking standards, car-free development, the provision of Electric Vehicle Charging Points, and cycle parking, etc. The application has failed to justify the loss of the informal car parking space at the rear of the building in the rear courtyard and the proposed parking shortfall. Proposing five car parking spaces, including two in Dunstone Road that would be impractical and unsafe in their use. which being less than the indicative eight parking spaces 8 (or 10 if there are 2x2-bed + 2x 4-bed dwellings) in the Councils parking standard, in this location would be likely to result in unacceptable overspill car parking, as acknowledged in the application details, and cause damage to the public street amenity. Which the proposed redevelopment would have the opportunity to avoid.

Traffic generation is considered in the associated TN (section 4.4) using the TRICs data base, as accepted practice. Which suggests the former Care Home use would have generated an average 41 associated (two-way trips) vehicle movements per day. Whereas by comparison the proposed four dwellings are forecast to generate an average 16 - 24 associated vehicle movements per day. Which would give a potential 50% reduction in the number of associated vehicle movements per day, which the TN notes would also reduce on-street parking demand. Although it is acknowledged that the average number of up to 41 vehicle trips per day generated by the Care Home is negligible when considering traffic impacts.

In terms of on-street parking the former Care Home would have generated a greater demand for short term parking from deliveries and visitors throughout the day. But with the popularity of on-line shopping there would continue to be a level of demand for additional short term on-street parking by associated deliveries to the dwellings. Along with the associated overspill on-street residential parking from the new dwellings caused by the proposed shortfall in the number of private parking spaces, which would occur daily and overnight for much longer periods of time than the Care Home demand, including when occupiers were not using their car, and travelling by other means, for example when waking or cycling to local destinations. With the application details acknowledging there would be a parking shortfall that would cause overspill car parking in Dunstone Road, where parking is unrestricted.

Cycle parking and storage, the application details confirm (PS par 5.3 & TN par 4.3.3) there is space available within the curtilage of each of the dwellings to have a cycle store. But is not identified in the application details so would need to be secured by way of a planning condition, in accordance with the advice contained within the Councils SPD, as part of any consent.

Electric Vehicle Charging Points, the application details confirm (TN par 4.3.2) that electric vehicle charging points could be provided for each household at each of their parking spaces. Therefore, one in number electric vehicle charging point per household would need to be secured by way of a planning condition, in accordance with the advice contained within the Councils SPD, as part of any consent.

Regarding drainage and referring to the PS paragraph 5.6, the proposed alterations to create four dwellings would utilise the existing drainage within the site and accommodate drainage of parking spaces. Of course, the proposed new driveway, if hard surfaced and falling toward the street, would need to provide a drainage channel connected to the private on-site drainage system to prevent surface water from running onto the fronting public footway.

SUMMARY:
The LHA is mindful that this application is for a Change of Use and sub-division of a residential Care Home that was in multiple occupation, now proposed to be converted into four dwellings. With many of the supporting details relating to a more strategic high-level assessment approach, and view. Including referring to such things as, spatial planning, brownfield land, whilst suggesting that car parking provision can prevent the effective use of land and stifle sustainable development, and accessibility. However, in this case for a Change of Use and sub-division of a Care Home, into four dwellings, it is the material impacts of the proposed changes within the application setting that give cause for concern. Changes relating to, Highway safety, access/egress and the lack of inter-visibility at the proposed new driveway, rear courtyard space and loss of parking, parking shortfall and provision, overspill parking, and public street amenity. Whilst the car parking provision must be assessed as part of the transport and planning balance, it is considered that the application details have failed to sufficiently justify the reduced level of off-street parking to serve the redevelopment.

The LHA recommends the application is refused for reasons of: -
Insufficient Details; Likely to Give Rise to Issues of Highway Safety; and Overspill Car Parking in the Local Street.
There are insufficient details regarding, the use of the space in the rear courtyard and potential loss of car parking opportunities there, and missing details relating to preservation of access to the parking space serving the neighbouring number 54. Also, because the layout, access and egress for the proposed two new parking spaces off Dunstone Road is impractical and would be unsafe in its use and likely to give rise to issues of highway safety. Along with the unjustified off-street parking shortfall that is likely to cause overspill parking with potential highway safety issues, and damage to the public street amenity. Contrary to Policy DEV29 of the Plymouth & Southwest Devon Joint Local Plan 2014-2034. And contrary to The National Planning Policy Framework 2024 paragraphs 112 , 115



Gary Lester
Transport Planning Officer
Officer authorised to sign on behalf of the Service
Director for Strategic Planning & Infrastructure

Comment Date: Thu 19 Jun 2025

2500684FUL 50 Dunstone Road.pdf

Comment Date: Fri 30 May 2025

956382 Consultation Response 2.pdf