Case 3271595

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ

Sevenoaks District Council — appeal allowed

Outcome
Allowed
Decision date
2 November 2021
Authority
Sevenoaks District Council
Inspector
Pipkin R
Procedure
Hearing
Casework type
Planning Appeal
Type detail
Planning Appeals - Outline
Development type
Other minor developments
Appellant
Pacalis Group, BLCP Eden 1 Ltd and BLCP Eden 2 Ltd
Agent
Tetlow King Planning
LPA reference
19/02834/OUT
ONS LPA code
E07000111
Jurisdiction
Transferred
Link status
Not Linked
Start date
3 August 2021

Summary AI

The appeal for a continuing care retirement community and new golf clubhouse with hotel accommodation was allowed, despite causing harm to the Green Belt. The inspector considered the housing supply, need for specialist housing, and locational factors, among others.

Generated from the decision letter — check against the original before relying on it.

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Page 1 · Chunk 0 Appeal Decision

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Hearing 28 September 2021 Site visit made on 6 July 2021 and 28 September 2021 by Rachael Pipkin BA (Hons) MPhil MRTPI an Inspector appointed by the Secretary of State Decision date: 2 November 2021 Appeal Ref: APP/G2245/W/21/3271595 Kent and Surrey Golf and Country Club, Crouch House Road, Edenbridge TN8 5LQ • The appeal is made under section 78 of the Town and Country Planning Act 1990 against a refusal to grant outline planning permission. • The appeal is made by Pacalis Group Companies, BLCP Eden 1 Ltd and BLCP Eden 2 Ltd against the decision of Sevenoaks District Council. • The application Ref 19/02834/OUT, dated 20 September 2019, was refused by notice dated 25 September 2020. • The development proposed is replacement of existing golf clubhouse and hotel following demolition of existing to create a continuing care retirement community (CCRC) for the elderly alongside a new golf clubhouse with hotel accommodation containing shared social, managerial and operational space to operate and service the continued golf course use and the CCRC with all matters reserved except for access. Decision 1.

Page 1 · Chunk 1 Appeal Decision

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The appeal is allowed and outline planning permission is granted for replacement of existing golf clubhouse and hotel following demolition of existing to create a continuing care retirement community (CCRC) for the elderly alongside a new golf clubhouse with hotel accommodation containing shared social, managerial and operational space to operate and service the continued golf course use and the CCRC with all matters reserved except for access at Kent and Surrey Golf and Country Club, Crouch House Road, Edenbridge TN8 5LQ in accordance with the terms of the application Ref 19/02834/OUT, dated 20 September 2019 and subject to the conditions set out in the attached schedule. Application for Costs 2. An application for costs was made by Pacalis Group Companies, BLCP Eden 1 Ltd and BLCP Eden 2 Ltd against the decision of Sevenoaks District Council. This application is the subject of a separate Decision. Procedural Matters 3. The original application was made in outline with only access to be determined at this stage. All other matters were reserved for future determination.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision I have had regard to the existing and proposed site plans and the indicative layout of the proposed development, but have regarded all elements of these drawings as indicative apart from the details of the access. https://www.gov.uk/planning-inspectorate

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision I have had regard to the existing and proposed site plans and the indicative layout of the proposed development, but have regarded all elements of these drawings as indicative apart from the details of the access. https://www.gov.uk/planning-inspectorate

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 4. The appellants have submitted a copy of a completed signed planning obligation by way of a Unilateral Undertaking (UU) under Section 106 of the Town and Country Planning Act 1990 (as amended) dated 22 June 2021. This deals with control of the use of the development (occupation), highway contributions and infrastructure including the provision of a controlled pedestrian crossing and bus stop works, communal transport for residents and staff, ecology and landscape management, public access to the golf course and facilities, public open space and contributions to public rights of way improvements. I will discuss this in more detail later in this decision. 5. During the course of the appeal, a revised National Planning Policy Framework (the Framework) was published. The parties have had an opportunity to comment on the implications of the revised Framework during the appeal process. I have dealt with the appeal accordingly. Background and Main Issues 6. The parties do not dispute that the proposal would be inappropriate development in the Green Belt as defined in the Framework.

Page 2 · Chunk 5 Appeal Decision

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The main issues are therefore: • the effect of the proposal on the openness of the Green Belt; and • whether the harm by reason of inappropriateness, and any other harm, would be clearly outweighed by other considerations. If so, would this amount to the very special circumstances required to justify the proposal. Reasons 7. The appeal site lies on the western side of Crouch House Road. It comprises the clubhouse building which includes hotel accommodation and a large area of surface parking plus two of the golf course holes at the eastern end of the golf course. The clubhouse is a reasonably large, one and a half storey, L- shaped building. It lies a short distance back from Crouch House Road beyond the car parking. Adjacent to the clubhouse there is a single-storey building and a disused golf driving range which lies outside the appeal site. 8. The site is surrounded by open land, comprising the remainder of the golf course and fields and the adjacent golf driving range, with housing development on the opposite side of Crouch House Road. A railway line runs along part of its north-eastern boundary. A public right of way (PROW) crosses through the site.

Page 2 · Chunk 6 Appeal Decision

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision This limited development on the western side of the road, gives the area an open and spacious character. Its eastern boundary is adjacent to the urban confines of Edenbridge on the opposite side of Crouch House Road. The site lies entirely within the Green Belt. Openness of the Green Belt 9. Paragraph 137 of the Framework states that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. It identifies openness as an essential characteristic of the Green Belt. There is no definition of ‘openness’ in the Framework although it is commonly taken to mean the absence of built or otherwise urbanising development. An assessment of openness requires a consideration of the scale of the development, its locational context and both its spatial and visual implications. https://www.gov.uk/planning-inspectorate 2

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 10. The indicative drawings show substantial built development extending westwards from Crouch House Road onto undeveloped land. The proposed clubhouse, hotel and hub building would be two-storeys and the largest building. It would be positioned at the far western end of the site on the edge of the retained golf course. The residential units would be arranged as short terraces and blocks of flats of between 1.5 and 3 storeys, extending in a linear pattern along two internal access roads between the hub building and Crouch House Road to the east. 11. The extension of the built form into open land would inevitably cause harm to openness. The appellants consider that the harm to the openness is limited, arguing that since the appeal proposal is for outline permission, matters relating to the appearance, landscaping, layout and scale of the development are all reserved and could change through any reserved matters approval. 12. Whilst I acknowledge this point, the proposed replacement clubhouse building would have to be significantly larger than the existing in order to accommodate the range of activities proposed.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision It would also need to be closer to the golf course and therefore positioned away from the built up area. Moreover, a large number of residential buildings as well as access roads and parking spaces would be built on land that is currently open. Consequently, I find that the proposal would significantly reduce the spatial openness of the area. 13. The appeal site is enclosed by boundary vegetation, hedgerows and trees. The site is also bunded. These provide some limitations to views into the site. However, in order to achieve a satisfactory relationship with the existing built up area, it is inevitable that much of the proposed development would need to be positioned towards the eastern side of the site, closer to Crouch House Road from which there would be open views into the site. The presence of internal roads and buildings would have a greater visual impact on the area than the existing building on the site. This would not be sufficiently screened by either the boundary vegetation or bunding within the site. It would also be visible from the railway line and a public footpath. There would therefore be a significant adverse effect on the visual openness of the site. 14.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The Council’s Green Belt Assessment 2017 assessed the District’s Green Belt against the five purposes of the Green Belt, as set out in the 2019 Framework. The appeal site lies within a parcel of Green Belt land of some 300 hectares. This parcel was assessed as being strongly performing Green Belt due to its importance in preventing the outward sprawl of Edenbridge into the surrounding open land and maintaining an essential gap between the built up area and the villages beyond. 15. The appeal site is around 8 hectares and accounts for under 3 per cent of this parcel of Green Belt. It is close to the built up area and some distance from other settlements. Development of this relatively small area would not significantly undermine its purpose in maintaining an essential gap, although it would represent encroachment into the countryside with the subsequent loss of openness. 16. Notwithstanding that the scheme would result in the loss of a relatively small parcel of Green Belt, I conclude that the appeal proposal would result in a significant loss of openness both visually and spatially thereby causing https://www.gov.uk/planning-inspectorate 3

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 significant harm to the Green Belt. Therefore, it would be contrary to the objectives of the Framework. Other considerations 17. The Framework sets out that identified harm to the Green Belt may be weighed with any other material consideration in order to determine if there are very special circumstance which may justify inappropriate development. The appellants have referred to a number of matters, each of which I deal with below. Housing Supply 18. The Council acknowledges that it cannot demonstrate a five year supply of deliverable housing sites and has confirmed that its housing policies are out of date. The statement of common ground indicates that the shortfall in delivery is ‘severe’. At the hearing, it was agreed that the Council had 2.6 years supply. I certainly consider this to be a significant shortfall. 19.

Page 4 · Chunk 11 Appeal Decision

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The Framework sets out at paragraph 11(d)(i) and Footnote 8 that where a five year supply of housing land cannot be demonstrated or delivery of housing has been substantially below the housing requirement over the previous three years, then the most important policies for determining the application should be considered out of date and planning permission should be granted unless the application of policies in the Framework that protect areas or assets of particular importance provide a clear reason for refusing the development proposed. Footnote 7 sets out that this includes land designated as Green Belt. 20. The proposed development is seeking the provision of 100 units of extra care housing. Both parties agree that this type of accommodation would fall within Class C2 of the Town and Country Planning (Use Classes) Order 1987 (UCO). 21. The PPG1 advises that housing provided for older people, including residential institutions in Class C2, should be counted towards housing land supply. It goes on to explain at paragraph 16a2 that housing provided for older people should be counted against their housing requirement.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision For residential institutions, to establish the amount of accommodation released in the housing market, authorities should base calculations on the average number of adults living in households. 22. The Council in its Housing Land Supply update3 (HLS report) sets out that C2 units are expressed in terms of bedspaces. It utilises a methodology for calculating the equivalent number of C3 housing units from C2 units based on an average household occupancy of 1.87 adults. 23. Whilst this approach is noted, I find that the nature of the proposed units would be more akin to a small dwelling with a separate kitchen and living area and mostly two bedrooms. Notwithstanding that the proposal would fall within Class C2, given that each unit would be capable of accommodating a small household rather than just a single occupant occupying a room within a more traditional residential care home setting, I consider that it would be

Page 4 · Chunk 13 Appeal Decision

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision | Paragraph: 035 Reference ID: 68-035-20190722 | | --- | | Paragraph: 016a Reference ID: 63-016a-20190626 | 3 Sevenoaks District Council, Housing Land Supply Update, 27th September 2019 (Update to take account of C2 supply) https://www.gov.uk/planning-inspectorate 4

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision 3 Sevenoaks District Council, Housing Land Supply Update, 27th September 2019 (Update to take account of C2 supply) https://www.gov.uk/planning-inspectorate 4

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 reasonable to count this as a dwelling rather than on the basis of bedspaces. For this reason, it seems to me that the proposed development would contribute 100 residential units, albeit of a specialist nature, to the Council’s housing land supply. 24. Even if I am wrong and the contribution to housing should be adjusted to be counted as bedspaces, the scheme would contribute an equivalent of at least 53 housing units based on the provision of 100 bedspaces. However, it seems to me that since the majority of units provide two bedrooms, in reality this figure could be higher and its overall contribution to housing supply greater. 25. Data within the SHMA shows that nearly 73 per cent of older person households within the District are relatively likely to live in outright owned accommodation. These people will often have significant equity in their homes which may mean that market solutions will also be required to meet their needs. Amongst these households, there is a high proportion of under- occupancy with nearly 59 per cent of such households having at least 2 spare bedrooms. 26.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The emerging Local Plan, whilst carrying very limited weight, recognises that encouraging older people to downsize can play an important role in releasing larger homes for growing families. Whilst not all older person households would either need to or wish to move into a retirement village such as proposed here, there is evidence that such accommodation does meet a need for some. The provision of specialist housing more suited to the needs of this part of the population is likely to encourage them to move, freeing up housing stock and would make a valuable contribution to overall housing supply. 27. The Council acknowledges its shortage of housing land. However, it considers that the provision of housing would not outweigh the overriding need to protect the Green Belt from harmful development in accordance with paragraph 11(d)(i) of the Framework. Whilst I accept that on its own, the provision of general housing would not be sufficient to outweigh the harm to the Green Belt. I do nevertheless find that the contribution to housing supply including the freeing up of housing stock, are factors that together carry substantial weight in the balance. Housing Needs of Older People 28.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The Framework sets out at paragraph 61 that local planning authorities should undertake a local housing needs assessment, conducted using the standard method in national planning guidance. Paragraph 62 goes on to require that it assess the housing needs of different groups including for older people. 29. The Planning Practice Guidance4 (PPG) sets out that the need to provide housing for older people is critical in view of the rising numbers in the overall population. Furthermore, it considers that older people should be offered a better choice of accommodation to suit their changing needs in order that they can live independently for longer and feel connected to their communities. Extra care housing is once form of housing for older people which is recognised by the Government as providing such benefits. 30. The Council produced a Strategic Housing Market Assessment (SHMA) in 2015 which formed part of its evidence base for the Council’s emerging Local Plan. 4 Paragraph: 001 Reference ID: 63-001-20190626 https://www.gov.uk/planning-inspectorate 5

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 The SHMA predicts an increase in those aged over 65 within the District by 48 per cent from 2013 to 2033, with particularly strong growth expected in those aged over 75, driven by improving life expectancy. With an aging population, the Council accepts that there is a need for the type of housing proposed. However, it disputes that the scale and location of the proposed development are able to meet the need appropriately. 31. The SHMA makes an assessment of overall housing need, including the need for different types of home, particularly for a growing older population. As part of its assessment, the SHMA sets out the need for specialist housing and accommodation for older persons. It places specialist housing including sheltered and extra care housing for older persons into Class C3 of the UCO. It makes a separate assessment of the need for care home bedspaces, considered to fall within Class C2. 32. The SHMA estimated a requirement for an additional 1,319 specialist housing units in the District between 2013 and 2033. This equates to an annual need of 66 dwellings.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision This is based on existing provision of 102 affordable extra care units and 1,490 sheltered housing units, both market and affordable. 33. Notwithstanding the inconsistency between the use classes applied to this type of housing, as extra care housing, I consider the scheme would contribute to the need for 1,319 specialist housing units as set out in the SHMA, rather than making a contribution to the need for C2 units, which is based on bedspaces. In providing 100 extra care units it would make a sizeable contribution to the overall need set out within the SHMA. 34. Although the SHMA treats extra care housing as Class C3, from the evidence submitted, the Council has calculated the delivery of extra care housing as falling within Class C2. The Council undertook a review of schemes delivering C2 accommodation as set out within its HLS report. This provided details of schemes with planning permission falling within Class C2. A number of these were providing traditional care homes but there is evidence that several were providing extra care accommodation. 35.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Based on analysis of these approved schemes and the figures and evidence put forward by the appellants, there appears to have been provision of around 189 extra care unit completions between 2015 and 2019 and a further 67 extra care units with planning permission. These figures have not been disputed. 36. No evidence has been put to me to demonstrate that there have been any further schemes permitted within the District since 2019. On this basis, and using the requirement set out in the SHMA, around 256 units of extra care accommodation have or will be provided. Part of this provision included a scheme at White Oak Court, Sycamore Drive5 was completed for a change of use of 51 units from sheltered housing to extra care. These 51 units existed prior to the SHMA have been undertaken and would have counted against the existing supply. Therefore, whilst they count towards the supply of extra care units they would not have contributed to a net gain in the overall number of specialist housing within Sevenoaks. 5 Council Ref: SE/18/00568/FUL https://www.gov.uk/planning-inspectorate 6

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 37. By my calculation, the overall contribution to the 1,319 figure provided by extra care housing would amount to just over 200 units. This equates to around 15 per cent of the overall SHMA requirement for specialist housing to 2033. With the addition of a further 100 units, this would bring the figure to around 23 per cent at around halfway into the SHMA period. 38. Since I have not been provided with any details of how many Class C3 sheltered housing units have been provided, it is not possible to reach a firm conclusion as to what the overall level of delivery has been against the annual need identified within the SHMA and the extent of any shortfall or oversupply. Even in the absence of confirmed numbers of sheltered accommodation delivery, the delivery of less than a quarter of the overall need for specialist housing as extra care housing (including the appeal scheme), does not suggest there has been or would be an oversupply of such housing. 39. The Council submitted a Market Position Statement 2021-266 (MPS) for accommodation with care and support.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision This set out the requirement for extra care housing specifically for older persons, referred to as Housing with Care, for all local authorities covered by Kent County Council. The Council confirmed that the MPS was based on 2017 population forecasts and used a model endorsed by the Housing Learning and Information Network (Housing LIN). It also covered both market and affordable requirements although it did not split the need into these types. 40. The MPS sets out that within Sevenoaks there is a shortfall of 93 extra care units to 2026 and on the basis that this demand would be met, a further 39 extra care units would be required between 2026 and 2031. A total of 132 additional units would be needed. Essentially, by the end of 2031, it suggests that Sevenoaks would require a total of 253 extra care units. Based on the MPS, the appeal scheme would meet the entire need for the District to 2026 in a single location. 41. However, I find it hard to reconcile the MPS figure with the evidence put forward within the SHMA and the HLS report in relation to both demand and supply. By my calculation, the MPS indicates that as of March 2021, Sevenoaks was assessed to have 121 units either currently available or in the ‘pipeline’.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision However, the SHMA in 2015 identified that there were 102 existing extra care units and the HLS report, indicates that some 256 units have either been implemented or have permission. This would bring combined existing and pipeline supply to around 360 units and significantly higher than the 121 identified in the MPS. 42. A need of some 66 units per year as indicated in the SHMA would equate to 660 units over an equivalent ten year period. This would be significantly more than the 132 units predicted to be needed during the MPS ten year period of 2021-2031. Even taking account that some of the 660 units needed would be traditional sheltered accommodation, I nevertheless find that the disparity between these assessments of need would be significant. 43. I recognise that the MPS is a more up-to-date document. However, I have no information as to how the figures have been calculated to inform both the existing and pipeline supply position within the MPS. It is also not clear what 6 Kent County Council, Accommodation with Care & Support Adult Social Care Commissioning Market Position Statement 2021-26 (Last updated 04/2021) https://www.gov.uk/planning-inspectorate 7

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 the methodology has been to determine future demand and the extent to which this has been informed by local assumptions for Sevenoaks District. I have no evidence of the extent to which this has been subject to scrutiny. For these reasons, I can only give this limited weight. 44. The SHMA figures were based on data and a toolkit from the Housing LIN. It used the 2012-based sub-national population projections. The appellants have indicated that this would have been the SHOP@ tool (Strategic Housing for Older People Analysis Tool). This is a tool for forecasting the housing and care needs of older people. The Housing LIN toolkit indicated that there should be around 170 units of specialised accommodation (other than registered care home places) per thousand people aged over 75 years. 45. The appellants have asserted that the figure of 170 specialist housing units per 1,000 of the population is split into 12.5 per cent sheltered housing, 2.5 per cent enhanced sheltered and 2 per cent extra care accommodation. Enhanced sheltered and extra care accommodation are similar and it was accepted by the Council that it would be reasonable to count these together.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision In combination, it was agreed that the need for this type of accommodation would represent 4.5 per cent of the population aged over 75 years. 46. Using this toolkit, the appellants have made an alternative assessment of demand for extra care housing. This is based on the mid-2019 population projections7, taking a percentage of the population of over 75s. This gives an existing need of 555 units of extra care and enhanced sheltered housing increasing to 841 units by 2033. The current supply, both existing and in the pipeline, of around 360 units of this type falls significantly short of the 555 units needed. 47. The appellants have argued that this figure should be adjusted to 8 per cent, thereby taking into account those aged between 65 and 74 years as well as aspirations and social policy. I look at each of these in turn. 48. Whilst the accommodation would be available to anyone over the age of 55 who meets the eligibility criteria which includes amongst other things a need for care, physical frailty and social isolation, based on evidence from research and surveys of other care homes, the need is expected to be from those in their late 70s and 80s, with the average age of residents around 82 years.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Therefore, whilst I accept that there will be people from within the lower age bracket who will both qualify for and choose this housing option, I have no figure to quantify this. I nevertheless agree that the figure of need would be higher to take into account this age group. 49. In terms of social policy and aspirations, it seems to me that with increased provision of extra care housing there could be an uplift in demand due to a shift from more traditional care home accommodation. This is borne out in the MPS, the SHMA and the Council’s 2017 Local Housing Needs Study. On this basis, I agree that the appellants’ figures based on 4.5 per cent may be conservative but I am unable to reach any firm conclusions on this. 50. Due to differences in methodologies and assumptions and recognising that the SHMA is now some years old, it is not possible to reach a definitive position on overall need. The Council advised at the Hearing that is has commissioned 7 ONS Mid-2019: April 2020 local authority district codes – Estimates of the population for the UK, England and Wales, Scotland and Northern Ireland https://www.gov.uk/planning-inspectorate 8

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 work to look at older person’s housing needs within the District. However, this is not yet available. Nevertheless, I find that, on balance, based on existing supply including that in the pipeline, the population and its projected increase within older year groups, there is currently an existing and significant shortfall and a growing need for this type of housing. The proposed development would make a significant contribution towards meeting this requirement. 51. The Council’s draft Local Plan8, following an unsuccessful Judicial Review of the Inspector’s conclusions that the plan should not be adopted, holds no weight in decision making. However, it recognises that a high proportion of the District’s housing requirement will be for specialist accommodation for older people, quoting the housing need figures from the SHMA. Whilst the Council’s intentions for planning for older persons housing as set out within the draft Local Plan are noted, there are currently no policies in place that would specifically secure this type of housing. 52.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision With an aging population within the District and based on the evidence of need, I have no reason to dispute that the proposal would meet the housing needs of older people. However, I turn now to consider whether this accommodation is being provided in the right place. 53. The draft Local Plan proposed that older person housing is concentrated in the three main strategic settlements in Sevenoaks, Edenbridge and Swanley. This is to ensure that older persons’ housing is distributed spatially and sustainably so that not only can it meet the need identified, but also be located where older persons can remain close to their existing connections, family and community. Whilst not adopted policy, this approach to my mind, seems reasonable. 54. None of the submitted evidence provides any analysis of need below District level. However, as one of the larger settlements within the District, it would be reasonable to expect that a proportion of the overall need would arise within Edenbridge. 55. The Council has referred to a number of elderly care accommodation developments within the urban confines of Edenbridge quoting figures in the region of 240 units.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision However, no extra care housing has been provided within Edenbridge and its parish. Furthermore, with the exception of Edenbridge Manor Care Home, which is a traditional care home providing 85 units, the other developments date back to 2012 or earlier. They therefore pre-date the SHMA assessment and the need set out therein is evidently on top of this existing provision. 56. There is no evidence to suggest that there is any extra care housing serving Edenbridge. The schemes for this type of housing to which I have been referred are for developments in other settlements, including Sevenoaks and Swanley. The proposed development would make a contribution to different types of specialist housing designed to meet the diverse needs of older people serving Edenbridge. Whilst it would be a sizeable development, in serving the third largest settlement within the District it would meet a local need. 57. The appeal site was submitted under the call for sites in 2017 for housing development. It was assessed as being unsuitable due to the loss of an 8 Sevenoaks District Local Plan, Proposed Submission Version Regulation 19 Consultation December 2018 https://www.gov.uk/planning-inspectorate 9

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 outdoor sports facility and for the majority of the site being isolated from the main town. In particular that the site was not in walking distance of public transport and existing services and facilities, thereby trips to these facilities would be reliant on the car. 58. The Sevenoaks Allocations and Development Management Plan 2015 (ADMP) identified two possible sites for mixed use development including housing for older people and a further six housing sites identified as suitable for housing specifically designed for older people. These were considered too small by the appellants for what they were proposing. From the evidence submitted, of those developed none have delivered any such housing and a number remain undeveloped. 59. The Council has not specifically stated the proposed development should be delivered on one of the allocated sites although it considers sites within urban confines should be considered. It also maintains the position set out within the ADMP that it can meet its housing targets without the need to release land in the Green Belt and by focusing development within the existing urban and village locations of the District.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision However, at the Hearing I was told that less than 1,000 houses would be delivered on allocated sites within existing urban areas on non-Green Belt land which suggests that land within the Green Belt would need to be considered. 60. In such circumstances, the appellants have argued that they are unable to compete with general housing developers for suitable larger sites as required for their proposal. No viability assessment has been put to me to substantiate that claim. Nevertheless, I accept that there is a minimum number of units and site area that would be likely to be required to support the retirement village concept and the viable provision of shared on-site facilities for residents. I also acknowledge that the availability of sites is considerably constrained by both the Green Belt and Area of Outstanding Natural Beauty designations that cover 93 per cent and 60 per cent respectively of the District. 61. I note that an Inspector in allowing an appeal9 for a development of 79 extra care unit at Land to the rear of 237-259 London Road, West Malling within neighbouring Tonbridge & Malling Borough Council where Green Belt designations likewise limited the choice of sites, reached a very similar conclusion. 62.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The SHMA suggests that the provision of specialist housing is split roughly 60:40 between market and affordable tenures. The appeal scheme would deliver market housing and the Council has confirmed that it would not be liable for affordable housing contributions. 63. Consequently, I conclude that the proposed development would make a significant contribution to meeting the overall need for specialist housing within the District for which the current development plan does not make adequate provision for and for which the emerging local plan, whilst supportive, would be unlikely to deliver for some time yet. 9 APP/H2265/W/18/3202040 https://www.gov.uk/planning-inspectorate 10

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The SHMA suggests that the provision of specialist housing is split roughly 60:40 between market and affordable tenures. The appeal scheme would deliver market housing and the Council has confirmed that it would not be liable for affordable housing contributions. 63. Consequently, I conclude that the proposed development would make a significant contribution to meeting the overall need for specialist housing within the District for which the current development plan does not make adequate provision for and for which the emerging local plan, whilst supportive, would be unlikely to deliver for some time yet. 9 APP/H2265/W/18/3202040 https://www.gov.uk/planning-inspectorate 10

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 Locational factors 64. The SHMA recommends that the Council identifies sites in accessible locations for specialist housing. The proposed extra care accommodation would be on the edge of the urban area, some 1.2 kilometres from the town centre. For less mobile residents, it would not be within easy reach of services and facilities which would be around a 15 to 20 minute walk from the site. Given the age of anticipated future occupants, this would be neither convenient nor provide a realistic option for many of them. Whilst there is a bus stop opposite the site, the service is not considered to be sufficiently frequent to provide a satisfactory means of access to the town centre. 65. In view of the anticipated age of the future occupants, the appellants have explained that the operational model is based upon bringing services and facilities to the residents. This would be supplemented by a communal transport service for residents to enable them to access local services and facilities off-site with a buggy transport system operating within the site between the residential units and the hub building.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Details and the provision of this would be confirmed through a Communal Transport Plan which would be secured through the submitted UU. 66. Whilst there is nothing to prevent future residents from owning and using a car, in view of their advanced age and the arrangements for access to services and facilities, it seems to me that future residents would not be overly reliant on the use of the private car, usage of which is likely to be modest. 67. There is an existing golf course and hotel on the site, which when operational, would be accessed by staff, club members and hotel guests. The appeal scheme would increase the number of staff and the hotel capacity on site with subsequent increases in trips to and from the site. In terms of staff coming to work at the site, the appellants argue this is no different to people working at industrial premises on the edge of town. Furthermore, whilst the walking distance may not be suitable for future residents, this does not mean that younger or more mobile people working or visiting the site would not be able to walk or cycle to it. The site is, after all, on the edge of the settlement, linked to it by footpaths and not entirely disconnected from it. 68.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Overall, I conclude that the appeal site is not in a highly sustainable location and there would inevitably be some increase in traffic to and from the site, including trips by private cars. However, with alternative transport means for future residents as well as taking into account the existing use of the site, this only carries limited weight against the proposal. In coming to this view, I am also mindful that locational factors were not identified by the Council as a reason for refusal. Health and Well-Being Benefits 69. There is a body of evidence to support the provision of housing for older people, such as extra care housing, which allows for and enables social contact and interaction, helping to address issues of loneliness and isolation that can occur. To be successful in this, such developments need to be situated in the community, close to local amenities and facilities, to ensure that people within the scheme can stay independent and involved members of that community for as long as possible. https://www.gov.uk/planning-inspectorate 11

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 70. The entire site would include a mix of uses with associated comings and goings and activities. Future occupants would have the benefit of living as a community with associated opportunities for social interaction with each other and others attending at the hub building. This would help tackle issues of isolation. Whilst some concerns about opportunities for social interactions have been raised in respect of the layout, this could be addressed through the reserved matters. 71. The appellants have provided evidence of the beneficial impact on public health budgets as future residents would have on-site care and support services. Moreover, with future occupants being able to retain their independence with the care they need, the scheme would promote improved well-being. 72. I find I have no reasons to disagree with this position and I agree that there are likely to be overall benefits to health and well-being from this proposal. However, because the scheme is a distance from off-site local services and facilities which may limit opportunities for interactions beyond the immediate community, I reduce the weight accorded to this and therefore give it moderate weight. 73.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The Council has raised a concern about the impact of this scale of facility on existing local infrastructure, such as health care provision. Whilst this is noted, the intention is to draw people mainly from the local area who would already be registered for such services. Furthermore, with improved well- being and the provision of on-site consulting rooms for visiting health care practitioners to administer treatments, it is not expected to give rise to significant additional pressure on existing services. Safeguarding the Long Term Future of the Existing Golf Course and Use 74. The existing golf course on the site is currently closed. It is located within an area where there are a significant number of golf courses. Some of these have closed down which the appellants attribute to an issue of oversupply as well as reduced demand for such facilities from the population. In these circumstances, the appellants have indicated that the golf club will not reopen at the end of the current pandemic. 75. The loss of an outdoor sports facility was one of the reasons for not including the site within the site allocations for the local plan.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The appellants have argued that the proposal would enable the retention of the golf course, for which there is local support, and there would be no loss of an outdoor sports facility. 76. The appellants contend that the appeal golf course is well located to the settlement, providing an opportunity for combined trips and access to employees. The care community would allow for the diversification of the hotel / golf course use with shared facilities and services. This would ensure the ongoing viability and commerciality of the golf course, would enable the maintenance of the land and provide a leisure facility within an accessible location. 77. It has been suggested that the existing golf course is not financially viable. However, I have been provided with no evidence of income and expenditure or falling membership numbers to demonstrate that there is no longer a need https://www.gov.uk/planning-inspectorate 12

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 or viable operating model for the golf course to continue. Whilst I accept that the existing facilities are in need of modernisation and that works to them would improve the appearance of the area along Crouch House Road, it has also not been demonstrated that refurbishment of the existing facilities would be prohibitive. In the absence of this and whilst I understand the appellants’ desire to improve the golf course facilities, I can only give this very limited weight. 78. The appellants have also highlighted that with the existing golf course closed, there are problems with unauthorised access to the land with people using motorised vehicles and causing damage to the grounds. In bringing the site back into active use with associated maintenance and supervision, this type of anti-social behaviour could be more effectively addressed. Whilst security and fencing could help solve the problem, with public footpaths crossing the site, this would be a difficult and expensive solution. 79. I appreciate that it would be easier to tackle such issues were the golf course to be operational.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision However, as it has not been demonstrated that the golf course could not reopen without the proposed development, I attribute very limited weight to this matter. Economic Benefits 80. At the time of the planning application some 14 full-time equivalent staff were employed at the site. The appellants consider the combined use would result in more than 100 individual positions extending to between 130 to 150 people employed with part time working and seasonal working. This would be equivalent to 110 full time staff. In addition, associated economic benefits with serving the residential and leisure use is estimated to be some 30 to 40 jobs through suppliers and delivery of services. 81. Whilst these figures may vary a little, it seems inevitable that the proposed use which includes an expanded operation and new uses would generate a considerable amount of additional employment over and above the existing with a knock-on effect locally. During the construction period, the development would create employment on site as well as those working on the site contributing to the local economy. 82. The existing hotel accommodation provided within the golf clubhouse is not of a high standard, with poor disabled access.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision There is no evidence of any deliberate neglect of the hotel. The scheme would provide an enlarged hotel with better facilities which may give rise to some additional tourism and associated economic benefits over the existing hotel. However, it seems to me that a new hotel could be provided in place of the existing. As such I find it would essentially be replacing an existing hotel, albeit with a larger one, this carries limited weight in terms of justifying the proposal. 83. When taken together, the scheme would provide additional employment and a number of associated economic benefits. Overall, these are positive benefits of the scheme to which, in combination, I give moderate weight. Open Space 84. As part of the proposal new publicly accessible open space of 0.5 hectares would be created and secured through the UU. Whilst this would contribute to health, well-being and provide space for the community, it would also be on https://www.gov.uk/planning-inspectorate 13

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 an area of existing open land that was part of the golf course. Furthermore, it seems to me that this new area of open space would largely meet the needs of the proposed development and its future occupants, employees and visitors. Consequently, I find this delivers very modest public benefits and therefore carries very limited weight. Public Footpath 85. The scheme includes upgrades to the PROW both within the appeal site and wider site. This would make it more accessible by all, with improved surface material to enable wheelchair users to use it. However, this upgrade to the surface of the PROW is largely to accommodate the increased use of the footpath arising from the proposal. As such, whilst there would be some benefit from this, I only give this very limited weight. New pedestrian crossing 86. The scheme includes the provision of a controlled pedestrian crossing, traffic calming measures and improvements to the nearby bus stops on Crouch House Road. The road is subject to a 30 mph speed limit, however, evidence indicates that these are regularly and significantly exceeded.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The local highway authority has supported the highway improvements in terms of traffic calming and the provision of a pedestrian crossing. The proposed crossing would largely benefit future occupants and users of the proposed development in providing safe pedestrian access to it. Nevertheless, in helping to reduce speeds along this road there would be a wider benefit to the community. I therefore give this moderate weight. Facilities for wider community 87. The proposed facilities would be open to the wider community providing bookable space for community meetings and weddings. From what I heard, there are a number of existing community facilities within Edenbridge and there is no identified need for additional community facilities. Whilst I do not have full details of these and whether they would be directly comparable with what the appeal scheme is offering, it nonetheless appears that Edenbridge is already relatively well-served in this regard. It seems to me that the provision of these facilities would largely provide a benefit to the owners of the facilities. Nevertheless, a small public benefit would be derived from having these facilities as an option to what is already available. I give this very limited weight.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Planning Obligation 88. The signed Section 106 Agreement makes provision for appropriate control of the use and its occupation as well as provision for communal transport, landscape and ecology management, open space, highway and PROW improvements. The full details of the highway improvements would be secured by way of a Section 278 Agreement under the Highways Act 1980. I am satisfied that each sought obligation meets the three tests set out in paragraph 57 of the Framework for planning obligations. As a result, I have taken the completed planning obligation into account. https://www.gov.uk/planning-inspectorate 14

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Planning Obligation 88. The signed Section 106 Agreement makes provision for appropriate control of the use and its occupation as well as provision for communal transport, landscape and ecology management, open space, highway and PROW improvements. The full details of the highway improvements would be secured by way of a Section 278 Agreement under the Highways Act 1980. I am satisfied that each sought obligation meets the three tests set out in paragraph 57 of the Framework for planning obligations. As a result, I have taken the completed planning obligation into account. https://www.gov.uk/planning-inspectorate 14

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 Other Issues 89. A question has been raised about the cost of the accommodation and whether it would be affordable. The scheme is not proposing the provision of affordable units and would provide market extra care housing. The appellants have indicated these would be priced according to local market conditions. The sale price of these market units is not a matter before me. 90. Concerns have been raised about the effect of the proposal on the local area both during and after its construction. There may be some disruption during construction works, however, a condition requiring a construction traffic plan to be agreed prior to works commencing would alleviate this. The highway authority has assessed the trip generation from the proposed development as submitted by the appellants. They have not disagreed with this nor indicated that it would give rise to an unacceptable increase in traffic to the detriment of highway safety. 91. Several interested parties have raised concerns about the capacity of the local sewage network to accommodate the proposed increase in dwellings and other uses on the site.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision The imposition of a condition requiring details to ensure this is satisfactory and implemented accordingly would secure this. 92. The appellants submitted ecological appraisals and impact assessments10 which demonstrated that the footprint of the proposed development would be unlikely to significantly impact protected or notable species. However, as the proposal is in outline and the landscape and layout is indicative, further consideration of these matters would be considered under any reserved matters application. 93. The replacement fairways for those lost through the proposed development would be likely to give rise to some harm due to vegetation clearance and the protected and priority species known to be there through the appellants’ survey. The Council has confirmed that any vegetation clearance to change the layout of the existing golf course would not require planning approval. If the correct licences and appropriate mitigation were to be implemented, the owners of the site could clear vegetation on site irrespective of this appeal scheme. 94. The appellants, through the UU, would provide an Ecological and Landscape Management Plan to detail the management of the property and its operations.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision This would provide for the protection, mitigation and enhancement of the biodiversity and ecology of the appeal site and its surrounds. The Green Belt Balance 95. Paragraph 147 of the Framework makes it clear that inappropriate development is, by definition, harmful to the Green Belt, and should not be approved except in very special circumstances. I have concluded that the proposal would be inappropriate development and would therefore, by definition, be harmful to the Green Belt. I have also found that it would cause significant harm to the openness of the Green Belt. These are matters to which I give substantial weight as required by paragraph 148 of the Framework. 10 The Ecology Go-op, Preliminary Ecological Appraisal, 4 March 2019 and The Ecology Co-Op, Ecological Impact Assessment, 9 September 2019 https://www.gov.uk/planning-inspectorate 15

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 96. The proposal would make a contribution to general housing supply within the District of 100 units including through the release of family housing to the market. In view of the Council’s significant shortfall in housing supply, I accord substantial weight to this. 97. The scheme would provide 100 units of extra care housing for older people. This would address an existing shortfall and contribute to meeting a critical need. Due to its location on the edge of the settlement with limited direct access to the existing services and facilities, I reduce the weight attributed to this provision. I nevertheless consider this carries significant weight. 98. Notwithstanding the location of the development, I find future residents would benefit from improved well-being and health. The proposed scheme would also provide a number of economic benefits in terms of job creation and support for local services. In addition, the highway improvements would provide some wider benefits in terms of highway safety along Crouch House Road. I accord each of these factors moderate weight. 99.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Although of benefit to the appearance and security of the area, it has not been satisfactorily demonstrated that the safeguarding and improvements to the golf club and its facilities are reliant on the wider scheme. This therefore carries very limited weight. The provision of facilities to the wider community are also matters to which I accord very limited weight. 100. The provision of open space and improvements to the PROW would be largely of benefit to the proposed development and its occupants and users. I therefore accord these benefits very limited weight. 101. The proposal would not be in a highly sustainable location. However, I have found that this carries limited weight against the scheme. Taking this into account, I nevertheless find that the other considerations cumulatively clearly outweigh the harm to the Green Belt I have identified. Consequently, the very special circumstances necessary to justify the development exist. 102. The demonstration of very special circumstances accords with national policy.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Any conflict with Policies LO1 and LO8 of the Sevenoaks Core Strategy 2011 (CS) which together seek to protect and maintain the extent of Green Belt and other identified conflicts with the development plan are outweighed by other material considerations. Conditions 103. The Council has proposed a number of conditions should the appeal be allowed. I have considered these and imposed them where they meet the tests set out in Paragraph 56 of the Framework, amending where necessary for the sake of simplicity, clarity and precision. 104. In addition to the standard conditions relating to the submission of reserved matters it is necessary to identify the plans to which the decision relates, but only insofar as they relate to reserved matters for consideration at this stage, as this provides certainty. Conditions restricting the number of units, quantum of floorspace and height of each element of the proposed development are necessary to control the extent of the development. A condition requiring the extra care units to be constructed to accessible and adaptable standards is reasonable in view of the proposed future occupants of the development. https://www.gov.uk/planning-inspectorate 16

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision Appeal Decision APP/G2245/W/21/3271595 105. To protect trees on site, local amenity and highway safety, conditions securing a tree protection scheme and construction traffic management plan are necessary. 106. Conditions securing an Order for the realignment of the PROW and certification for its provision and for its surface, are both necessary and reasonable to ensure this work is carried out as approved and to an appropriate standard. A condition preventing any planting within 1 metre of its edge is necessary in the interests of public safety. I have however omitted a condition preventing disturbance of the surface as the Council confirmed this is covered by other legislation. 107. I have imposed conditions requiring the details and implementation of the disposal of foul and surface water sewage and a sustainable surface water drainage scheme and verification of this in the interests of the safe and suitable operation of the site. Conditions requiring investigation of potential contamination and its remediation are necessary to ensure the site is safe for the use proposed. 108.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision In the interests of protecting ecology and enhancing biodiversity, conditions to secure works to be carried out in accordance with the submitted ecology assessments and to provide for biodiversity enhancements are necessary and reasonable. 109. I have imposed conditions requiring details of the provision of electric vehicle charging sockets, car parking for a car share/club and a travel plans in order to deliver sustainable travel. A condition requiring details and implementation in accordance with sustainable design, construction and energy efficiency measures is reasonable in the interests of reducing the environmental impact of the development and tackling climate change. However, I have amended the targets to accord with the requirements of adopted Policy SP2 of the CS. 110. Conditions requiring details of materials, hard and soft landscaping, lighting scheme and means of enclosure are necessary and reasonable in the interests of the character and appearance of the development. Exceptionally, a condition restricting permitted development for means of enclosure is reasonable for the same reason. 111.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Appeal Decision I have not imposed a condition seeking archaeological investigation as the site is not located within an area of archaeological potential. Conclusion 112. I have concluded above that, for this appeal, very special circumstances exist to justify inappropriate development in the Green Belt. My findings on other matters do not lead me to reach a different conclusion. Consequently, I conclude overall that the proposal would comply with the relevant provisions of the Framework and the development plan when considered as a whole. For the reasons given above, and having considered all other matters raised, I conclude that the appeal should be allowed.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin INSPECTOR https://www.gov.uk/planning-inspectorate 17 Appeal Decision APP/G2245/W/21/3271595 Schedule of Conditions 1) Details of the appearance, landscaping, layout, and scale, (hereinafter called "the reserved matters") shall be submitted to and approved in writing by the Local Planning Authority before any development takes place and the development shall be carried out as approved. 2) Application for approval of the reserved matters shall be made to the Local Planning Authority not later than 3 years from the date of this permission. The development hereby permitted shall take place no later than 2 years from the date of approval of the last of the reserved matters to be approved.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin Appeal Decision APP/G2245/W/21/3271595 Schedule of Conditions 1) Details of the appearance, landscaping, layout, and scale, (hereinafter called "the reserved matters") shall be submitted to and approved in writing by the Local Planning Authority before any development takes place and the development shall be carried out as approved. 2) Application for approval of the reserved matters shall be made to the Local Planning Authority not later than 3 years from the date of this permission. The development hereby permitted shall take place no later than 2 years from the date of approval of the last of the reserved matters to be approved.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin 3) The development hereby permitted shall be carried out in accordance with the following approved plans (noting the indicative and illustrative nature of many the plans, ahead of detailed design work and submission in reserved matters): • P01 Block Plan • P02 Proposed Site Layout 1 of 2 • P03 Proposed Site Layout 2 of 2 • P04 Proposed Golf Course Layout • P05 Proposed Site Section A A • P06 Proposed Site Section B B • P07 Proposed Site Section C C • P08 Proposed Site Section D D • P09 Proposed Site Sectional E to F • P15 Location plan • P20 to P45 and P60 - P45 • P50 Proposed Club and Care Hub 1 of 2 • P51 Proposed Club and Care Hub 2 of 2 • Existing impermeable areas 19033-D03A • Proposed impermeable areas 19033-D04A • 19033-GA-01-C Access & Traffic Calming • 254KSGLM02 Landscape Masterplan • 768 - P70 Indicative Building heights • Drainage Strategy layout Sheet 1 of 2 19033-D01-G • Drainage Strategy layout Sheet 2 of 2 19033-D02-F 4) No more than 100 individual accommodation/extra care units shall be built on the site within the Continuing Care Retirement Community in the C2 Use Class with a maximum internal floor area of 13,145 square metres and shall have a maximum of two full storeys with some having accommodation

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin in the roof space areas. 5) The community hub and golf clubhouse, with hotel accommodation, will have a maximum internal floor area of 3,470 square metres and shall have a maximum of two storeys. 6) In terms of ancillary buildings – cycle storage, buggy store, refuse stores, golf course serving buildings – there will be a maximum internal floor area of 480 square metres and no more than 55 square metres maximum internal floor https://www.gov.uk/planning-inspectorate 18

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin 5) The community hub and golf clubhouse, with hotel accommodation, will have a maximum internal floor area of 3,470 square metres and shall have a maximum of two storeys. 6) In terms of ancillary buildings – cycle storage, buggy store, refuse stores, golf course serving buildings – there will be a maximum internal floor area of 480 square metres and no more than 55 square metres maximum internal floor https://www.gov.uk/planning-inspectorate 18

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin Appeal Decision APP/G2245/W/21/3271595 area in terms of small clubhouse/hub gathering and activity building for use by the CCRC. 7) All of the extra care units will comply, as a minimum, with the technical standard M4(2) for accessible and adaptable dwellings as set out in the Building Regulations. 8) No site clearance works, or development shall take place until a tree protection scheme has been submitted to and approved in writing by the Local Planning Authority. The site clearance works, and development shall be carried out in accordance with the approved tree protection scheme. 9) No development shall commence until a Construction Traffic Management Plan has been submitted to and approved in writing by the Local Planning Authority. The Construction Traffic Management Plan shall be implemented in accordance with the approved details. 10) No development shall take place over the alignment of Public Footpath SR600 until an Order for its permanent diversion has been made and confirmed, and the diverted route has been fully provided and certified.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin 11) The public rights of way within the development site shall be surfaced by the developer to a specification to be submitted to and agreed in writing by the Local Planning Authority prior to commencement. This shall be implemented in accordance with the approved details before any of the proposed units are occupied or the clubhouse/hotel/hub building is brought into use. It will thereafter be maintained. 12) No hedging or shrubs should be planted within 1 metre of the edge of any public rights of way on the site. 13) No development shall be commenced until information and details of the phasing of the development ensuring it aligns with any required reinforcing of the sewage network to ensure adequate waste capacity is available. Construction of the development shall not commence until details of the proposed means of foul sewage and surface water sewage disposal have been submitted to and approved in writing by the Local Planning Authority. Such details once approved shall be fully implemented and not altered without the prior written permission of the Local Planning Authority.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin 14) Development shall not begin in any phase until a detailed sustainable surface water drainage scheme for the site has been submitted to (and approved in writing by) the Local Planning Authority. The detailed drainage scheme will be based upon the principles from Drainage Strategy Sheets (Sheet 1: 19033, D01, G and Sheet 2: 19033, D02, F). The discharge rate from the site shall not exceed the agreed discharge rate of 40.1 l/s (Qbar for all storm events) and shall demonstrate that the surface water generated by this development (for all rainfall durations and intensities up to and including the climate change adjusted critical 100 year storm) can be accommodated and disposed of without increase to flood risk on or off-site. The drainage scheme shall also demonstrate (with reference to published guidance): https://www.gov.uk/planning-inspectorate 19

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin Appeal Decision APP/G2245/W/21/3271595 • that silt and pollutants resulting from the site use can be adequately managed to ensure there is no pollution risk to receiving waters. • appropriate operational, maintenance and access requirements for each drainage feature or SuDS component are adequately considered, including any proposed arrangements for future adoption by any public body or statutory undertaker. The drainage scheme shall be implemented in accordance with the approved details. 15) No building on any phase (or within an agreed implementation schedule) of the development hereby permitted shall be occupied until a Verification Report, pertaining to the surface water drainage system and prepared by a suitably competent person, has been submitted to and approved by the Local Planning Authority. The Report shall demonstrate the suitable modelled operation of the drainage system where the system constructed is different to that approved.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin The Report shall contain information and evidence (including photographs) of details and locations of inlets, outlets and control structures; landscape plans; full as built drawings; information pertinent to the installation of those items identified on the critical drainage assets drawing; and, the submission of an operation and maintenance manual for the sustainable drainage scheme as constructed. 16) Before the development commences, an investigation and risk assessment of land contamination shall be completed by competent persons and a report of the findings submitted to and approved in writing by the Local Planning Authority. This shall include an appropriate survey of the nature and extent of any contamination affecting the site, and an assessment of the potential risks to human health, controlled waters, property and ecological systems. Where unacceptable risks are identified, an appropriate scheme of remediation to make the site suitable for the intended use must also be submitted to and approved in writing by the Local Planning Authority.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin 17) Where remediation is necessary in relation to condition 16, and unless otherwise agreed in writing by the Local Planning Authority, none of the development shall be occupied until the approved scheme of remediation has been completed, and a verification report demonstrating the effectiveness of the remediation carried out has been submitted to and approved in writing by the Local Planning Authority. The verification report shall include a description of the works undertaken and a photographic record where appropriate, the results of any additional monitoring or sampling, evidence that any imported soil is from a suitable source, and copies of relevant waste documentation for any contaminated material removed from the site. In the event that, contamination is found at any time when carrying out the approved development, that was not previously identified, it must be reported immediately to the Local Planning Authority. An appropriate investigation and risk assessment must be undertaken, and where remediation is necessary, a remediation scheme must be prepared by competent persons and submitted to the Local Planning Authority for approval.

Page 20 · Chunk 67 Rachael Pipkin

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin Following completion of measures identified in the approved remediation scheme, a verification report that demonstrates the effectiveness of the remediation carried out must be submitted to and approved in writing by the Local Planning Authority. https://www.gov.uk/planning-inspectorate 20

Page 20 · Chunk 68 Rachael Pipkin

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin Following completion of measures identified in the approved remediation scheme, a verification report that demonstrates the effectiveness of the remediation carried out must be submitted to and approved in writing by the Local Planning Authority. https://www.gov.uk/planning-inspectorate 20

Page 21 · Chunk 69 Rachael Pipkin

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin Appeal Decision APP/G2245/W/21/3271595 18) The development shall be implemented in accordance with the recommendations, mitigations and enhancement features detailed in the Ecological Impact Assessment dated 23 December 2019 and Preliminary Ecological Appraisal dated 4 March 2019 by the Ecology Cooperation Ltd. Prior to the commencement of development updated versions (including updated appropriate surveys as required) will be submitted to and approved in writing by the Local Planning Authority. Such amended versions will take into account any layout and landscaping detailed design submitted as part of any reserved matters application. 19) Prior to the commencement of development, details of measures and a programme of works to enhance biodiversity shall be submitted to and approved in writing by the Local Planning Authority and the works shall be carried out in accordance with the approved details and the programme of works. The required details shall include the following: • Native tree and hedgerow planting, • Wildflower meadow seeding, • Bat and bird boxes, and • Lighting scheme that avoids light spill onto the boundary features and retained mature trees.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin 20) Prior to first occupation of the development hereby approved, a scheme to provide electrical charging sockets, for the charging of electric vehicles shall be submitted to and approved in writing by the Local Planning Authority. These details shall include number, type and location. The sockets shall be provided and installed in accordance with the approved details prior to the first occupation of any part of the development. 21) Prior to first occupation of the development hereby approved, details of car parking facilities for car share/car club vehicles and a programme of works, shall be submitted to and approved in writing by the Local Planning Authority. The car parking facilities shall be provided in accordance with the approved details and the programme of works, shall be for the exclusive use of electric vehicles, and shall be retained for such use, at all times. 22) Prior to first occupation of the development hereby approved, a travel plan shall be submitted to and approved in writing by the Local Planning Authority. The measures within the approved travel plan shall be implemented in accordance with the approved details and programme.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin In addition to the details set out in the Framework Travel Plan details within Transport Assessment 19-TP0015 v1r1 by Neil Brant Consulting September 2019. The plan shall contain the following information: • Measures to promote sustainable travel, including sustainable transport incentives to residents: and • Travel plan implementation and monitoring schedule. 23) The development hereby approved shall not be commenced until details of the implementation and design of the matters contained in the Sustainable Design & Construction Statement & Renewable Energy Assessment P2082-B20-REP- MEP-002 by Box Twenty dated September 2019 have been submitted to and https://www.gov.uk/planning-inspectorate 21

Page 21 · Chunk 72 Rachael Pipkin

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin In addition to the details set out in the Framework Travel Plan details within Transport Assessment 19-TP0015 v1r1 by Neil Brant Consulting September 2019. The plan shall contain the following information: • Measures to promote sustainable travel, including sustainable transport incentives to residents: and • Travel plan implementation and monitoring schedule. 23) The development hereby approved shall not be commenced until details of the implementation and design of the matters contained in the Sustainable Design & Construction Statement & Renewable Energy Assessment P2082-B20-REP- MEP-002 by Box Twenty dated September 2019 have been submitted to and https://www.gov.uk/planning-inspectorate 21

Page 22 · Chunk 73 Rachael Pipkin

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin Appeal Decision APP/G2245/W/21/3271595 approved in writing by the Local Planning Authority. Such measures shall include: • That the Club and Care Hub Building achieves BREEAM Excellent rating. • At least a 10% reduction in total carbon emissions through on-site installation and implementation of decentralised, renewable or low- carbon energy sources The development shall be carried out in accordance with the approved details. 24) No development above ground floor slab level of any part of the development hereby permitted shall take place until samples/details of the materials to be used in the external surfaces of the development have been submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved materials. 25) No development above ground floor slab level of any part of the development hereby permitted shall take place until details of the hard and soft landscaping, finished levels or contours, car parking layouts, vehicle and pedestrian access and circulation areas, hard surfacing materials and all means of enclosure have been submitted to and approved in writing by the Local Planning Authority.

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin The development shall be carried out in accordance with the approved details prior to the first occupation of the development and shall thereafter be retained for the lifetime of the development. 26) Details of the landscaping planting plans and schedules of trees and plants, including species, sizes and numbers, along with details of all new trees and bushes, and trees that are to be retained, and a written specification of the landscape works (including a programme for implementation, cultivation and other operations associated with plan and grass establishment) shall be submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved landscaping planting plans and schedules prior to first occupation of the development. Any tree or shrub which forms part of the approved landscaping which, within a period of five years from planting, fails to become established, becomes seriously damaged or diseased, dies or for any reason is removed, shall be replaced in the next planting season by a tree or shrub of a similar species, size and maturity.

Page 22 · Chunk 75 Rachael Pipkin

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin 27) Details of a lighting scheme shall be submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved lighting scheme prior to first occupation of the development and shall thereafter be retained for the lifetime of the development. 28) No development shall take place before details of all walls (including retaining walls), fences, gates or other means of enclosure to be erected in or around the development have been submitted to and approved in writing by the Local Planning Authority prior to the first occupation of the development. The means of enclosure shall be carried out in accordance with the approved details and shall thereafter be permanently retained and maintained. https://www.gov.uk/planning-inspectorate 22

Page 23 · Chunk 76 Rachael Pipkin

Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin Appeal Decision APP/G2245/W/21/3271595 29) Notwithstanding the provisions of the Town and Country Planning (General Permitted Development) Order 1995 (or any Order revising revoking and re- enacting that Order with or without modification), no new fences, gates, walls or other means of enclosure shall be erected without the prior written approval of the Local Planning Authority. End of schedule https://www.gov.uk/planning-inspectorate 23

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Kent & Surrey Golf Club, Crouch House Road, EDENBRIDGE, TN8 5LQ — Sevenoaks District Council — Rachael Pipkin Appeal Decision APP/G2245/W/21/3271595 29) Notwithstanding the provisions of the Town and Country Planning (General Permitted Development) Order 1995 (or any Order revising revoking and re- enacting that Order with or without modification), no new fences, gates, walls or other means of enclosure shall be erected without the prior written approval of the Local Planning Authority. End of schedule https://www.gov.uk/planning-inspectorate 23 Appeal Decision APP/G2245/W/21/3271595 APPEARANCES FOR THE APPELLANTS: John Sneddon Managing Director, Tetlow King Planning David Boden Pacalis Group Companies Matthew Hunt BLCP Eden 1 Ltd and BLCP Eden 2 Ltd FOR THE LOCAL PLANNING AUTHORITY: Mark Mirams Principal Planning Officer Emma Henshall Senior Planning Officer, Policy Naiomi Sargant Planning Officer, Policy Nicky Biddall Kent County Council Public Rights of Way Officer INTERESTED PARTIES: James Corrish Local resident https://www.gov.uk/planning-inspectorate 24

Extracted from the decision letter PDF and shown in full, chunk by chunk.

Main issues and findings

Green belt
Against appellant
¶9-16

The development would result in a significant loss of openness, causing harm to the Green Belt. The appellants argued that the harm to openness was limited, but the inspector disagreed, considering the proposed development's impact on the area's spatial and visual openness.

Other
For appellant
¶18-24

The inspector considered the housing supply in the area and concluded that the proposed development would contribute to the Council's housing land supply. The appellants argued that the proposed development would provide 100 units of extra care housing, which would make a significant contribution to the overall need for specialist housing.

Other
For appellant
¶28-36

The inspector considered the need for specialist housing and concluded that the proposed development would meet a significant need for extra care housing. The SHMA predicted an increase in those aged over 65 within the District by 48% from 2013 to 2033, and the proposed development would make a sizeable contribution to the overall need for specialist housing.

Other
For appellant
¶64-68

The inspector considered the locational factors and concluded that while the site was not in a highly sustainable location, the proposed development would not be overly reliant on private cars. The appellants argued that the operational model was based on bringing services and facilities to the residents, and a communal transport service would be available for residents to access local services and facilities off-site.

Policies relied on

Reference Weight
NPPF 208
Substantial
Local Plan D1
Limited

Site constraints from the Casework Database

Conservation area
Green belt
Listed building setting
AONB
SSSI
Flooding an issue

Source

Decision letter, 24 pages, issued by the Planning Inspectorate on 2 November 2021 under the Open Government Licence.