Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Hearing Held on 15 June 2022 Site visit made on 15 June 2022 by M Cryan BA(Hons) DipTP MSc MRTPI an Inspector appointed by the Secretary of State Decision date: 26th July 2022 Appeal Ref: APP/U1430/W/21/3284583 Beulah Baptist Church, Clifford Road, Bexhill-on-Sea TN40 1QA • The appeal is made under section 78 of the Town and Country Planning Act 1990 against a refusal to grant planning permission. • The appeal is made by The Trustees of Beulah Baptist Church against the decision of Rother District Council. • The application Ref RR/2020/2418/P, dated 30 November 2020, was refused by notice dated 26 April 2021. • The development proposed is described as “Demolition of existing sanctuary and Buckhurst Room hall and construction of a new church and community centre with associated external works. Retention of the Clifford Hall and new cladding and window configuration to the Beulah Centre elevation on Clifford Road”. Decision 1. The appeal is dismissed. Procedural Matter 2. The Government published a revised National Planning Policy Framework (“the Framework”) on 20 July 2021, replacing the version published in February 2019.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision While this was after the Council had determined the planning application, it was before the appeal was lodged, and all appeal submissions and the discussions at the hearing itself were made in the light of the revised Framework. Where I have referred in my decision to specific paragraphs of the Framework, the numbering is that of the July 2021 version. Main Issues 3. The main issues are: • The effect of the development on the architectural and historical significance of non-designated heritage assets, including whether harm to or loss of heritage assets would be outweighed by the benefits of the scheme; and • The effect of the proposed development on the character and appearance of the area. Reasons 4. The appeal site is Beulah Baptist Church, a complex of interconnected buildings which are used for a range of community activities as well as for worship. It sits at the corner of Clifford Road and Buckhurst Road, and lies between the original settlement of Bexhill Old Town to the north-east, and the later town centre to the south and south-west which was developed during Bexhill’s https://www.gov.uk/planning-inspectorate

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Appeal Decision APP/U1430/W/21/3284583 growth as a resort during the Victorian and Edwardian periods. The surrounding area is predominantly residential in character, comprising a mix of Victorian houses and more recent blocks of flats, although the site is only a short distance from the commercial, civic and other varied uses of the town centre. 5. There are four distinct parts to the church complex. The oldest building is the Clifford Hall at the south-east corner of the site, which opened in 1896 as a combined school and place of worship but which is now used as a multipurpose hall. At the north-east corner, where Clifford Road joins Buckhurst Road, is The Sanctuary1. This opened in 1898 as the main Baptist church, and is the largest and most prominent building within the site; it is a high space with a raked floor and fixed seating, with a gallery at first floor level accessed by the corner tower. At the north-west corner of the site, accessed from Buckhurst Road, is the Buckhurst Room from 1980 which provides a multipurpose function room adjacent to The Sanctuary.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision The Beulah Centre opened in 1986 and is the most recent addition to the complex; I saw on my visit that it had also been reconfigured and refurbished relatively recently. It links the Clifford Hall and Sanctuary buildings, providing various reception, office, kitchen, toilet and meeting spaces on two floors. 6. The proposal is a redevelopment of the site to meet the current and future needs of the church, including accommodating its various community activities. The Sanctuary and Buckhurst Room buildings would be demolished; they would be replaced by a new double-height main hall, with a two-storey section providing offices, meeting rooms and other facilities (including a roof garden) along the Clifford Road frontage and part of the south side of the main hall. The main hall would have a shallow pyramidal roof, and there would be a tower at the north-eastern corner; the two-storey part on the eastern side would have a flat roof. The building would be clad in stone and brick with standing- seam copper cladding to canopies, roof-top turrets and pitched roofs. The Clifford Hall and Beulah Centre buildings would be retained, although the front of the Beulah Centre to Clifford Road would be reclad.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Non-Designated Heritage Assets Local and national planning policy 7. Beulah Baptist Church is not a statutory Listed building, nor is it within a Conservation Area. The Council does not maintain a Local List of heritage assets, but nevertheless considers the two oldest parts of the church complex, the Clifford Hall and The Sanctuary, to be non-designated heritage assets (NDHAs). The Clifford Hall building would be retained. However in the Council’s view the demolition of The Sanctuary, which it considers has a high level of local significance, would be “a considerable conservation loss”. 8. Although the appellants’ initial submissions drew attention to the fact that the site is not locally listed, this is not an essential criterion for an NDHA (as set out in the definition in the Framework’s glossary).

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision It was made clear at the Hearing that the appellants do not in fact disagree that The Sanctuary should be considered an NDHA, and their key arguments are that its heritage 1 Although some of the written evidence and discussion at the Hearing also used the terms “the main church” or “the Victorian church” to refer to this building, I shall use the name “The Sanctuary” throughout so as to differentiate it from “the church”, which I have used to mean either the complex as a whole or the organisation of Beulah Baptist Church (as the context demands). https://www.gov.uk/planning-inspectorate 2

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision It was made clear at the Hearing that the appellants do not in fact disagree that The Sanctuary should be considered an NDHA, and their key arguments are that its heritage 1 Although some of the written evidence and discussion at the Hearing also used the terms “the main church” or “the Victorian church” to refer to this building, I shall use the name “The Sanctuary” throughout so as to differentiate it from “the church”, which I have used to mean either the complex as a whole or the organisation of Beulah Baptist Church (as the context demands). https://www.gov.uk/planning-inspectorate 2

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Appeal Decision APP/U1430/W/21/3284583 significance is limited, and that its loss would be justified by the need for and benefits of the development as a whole. 9. Paragraph 189 of the Framework states that heritage assets are “an irreplaceable resource, and should be conserved in a manner appropriate to their significance”. In respect of NDHAs specifically, Paragraph 203 of the Framework states: “The effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that directly or indirectly affect non-designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.” 10. Policy EN2 of the 2014 Rother Local Plan Core Strategy (“the RLPCS”) seeks to protect the historic built environment within the district, including that which is not statutorily protected by, among other things, reinforcing the special character of the district’s historic settlements, including villages, towns and suburbs.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Policy BX1, meanwhile, sets the overall strategy for the town of Bexhill; among other things, it seeks to conserve and enhance the town’s distinct and independent character. The significance of Beulah Baptist Church and The Sanctuary 11. There are three main elements to the significance, or potential significance, of The Sanctuary; these relate to architecture, culture, and the townscape. 12. Architecturally, The Sanctuary was designed in the gothic revival style by Resta W. Moore of Brighton, and built by Charles Thomas of Bexhill-on-Sea of red brick in Old English bond, with limestone dressings and buttressing. The Sanctuary is oriented roughly north-south, with the portico to the north and the chancel to the south. The transept and sanctuary windows are Victorian gothic bar tracery, each one with twin lancets plus oculus with geometric stained- glass pattern. The rear of the sanctuary is lit by three trefoil windows with borrowed light from the Portico. These are all positive features; other windows were reglazed in plain glass following damage in the second world war. 13.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Externally, the tower at the north-east corner originally had a short spire; this can be seen in historic photographs, although it was removed at some indeterminate point during the 20th century, and certainly was no longer in place by the time the Beulah Centre building was added in the 1980s. Internally, although some original pews and stalls remain, others have long- since been removed, as has the organ previously at the southern end of the chapel. There have also been various reconfigurations of doorways, access ramps and suchlike, as the Beulah Baptist Church as a whole has been expanded and altered over the years. 14. Culturally, the church has some significance as the first permanent place of worship for Baptists within Bexhill-on-Sea. It is also associated with the famous Baptist preacher Charles Haddon Spurgeon (1834—1892) and his family; the site for the church was chosen by his widow Susannah on a visit to the town, and their sons Charles and Thomas laid two foundation stones within the Clifford Hall frontage. A memorial stone to Charles Haddon Spurgeon was unveiled by Susannah within The Sanctuary in 1898, although of course having died six years previously he had not ever visited or preached at the church.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision https://www.gov.uk/planning-inspectorate 3

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision https://www.gov.uk/planning-inspectorate 3

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Appeal Decision APP/U1430/W/21/3284583 15. The townscape significance of The Sanctuary (and, indeed, Beulah Baptist Church as a whole) comes from two main factors. The first of these is the simple fact of it being a Victorian religious building, a culturally important (if relatively commonplace) typology in our towns and cities, and it having some distinctive character which reflects the planned growth and development of Bexhill-on-Sea in the late 19th and early 20th centuries. 16. The second, related, factor, is the contribution it makes to the town’s sense of place; progressing down the hill from Old Bexhill along Buckhurst Road one first passes Beulah Baptist Church and the – albeit truncated – landmark of its corner tower. Next, the tower and dome of the Bank Chambers building at the corner of Buckhurst Road and Amherst Road becomes visible. Finally, the road opens up into the space of Buckhurst Place, and its neat triangular garden overlooked by Bexhill Town Hall. While it would be overegging the pudding to describe the succession of buildings as representing a formal or processional approach to “new” Bexhill-on-Sea from the Old Town, they do combine to give a modest sense of arrival. 17.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Historic England (“HE”) assessed Beulah Baptist Church for statutory Listing but declined to List it. HE noted that although there is some architectural interest in the tower and polygonal stair extension, the church is “otherwise a largely typical example and one of many built and surviving from the late 19th century”, and that the alterations and late 20th century extensions “of little architectural interest have further compromised the elevations and plan, resulting in a large building that lacks cohesiveness”. In terms of the building’s historic interest, HE concluded that the connections with the Spurgeon family were not sufficient to overcome the building’s lack of architectural special interest so as to justify a statutory listing. A Certificate of Immunity from Listing was issued by HE on 5 June 2020. 18. The appellants’ assessment of the significance of The Sanctuary, set out in the submitted Heritage Impact Assessment and elaborated upon in appeal submissions and at the Hearing largely followed the conclusions in HE’s appraisal.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Essentially, while they acknowledge that The Sanctuary has some heritage significance and accept that it is an NDHA, the appellants’ view is that the Council has overstated the degree of significance. Rather than its architecture, the appellants consider that any significance is primarily cultural and associated with the building’s historic and continuing role as a church serving the community. 19. Although assessing such matters cannot of course be an exact science, I asked the main parties at the Hearing to summarise their view of the different aspects of The Sanctuary’s heritage significance. The Council considered that the building has very high townscape and cultural significance, and high architectural significance. The appellant suggested that it has moderate social and cultural significance, and only low architectural significance. The benefits of (and need for) the development 20. The appellants consider that the proposed redevelopment of the church site, including the demolition and replacement of The Sanctuary, is necessary to enable them to viably continue to deliver (and expand and improve the delivery of) their community services.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision The Hearing was told of the various community activities which take place at the church, including toddler groups, youth groups, a food bank, and a support group for refugees who have fled the war in https://www.gov.uk/planning-inspectorate 4

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision The Hearing was told of the various community activities which take place at the church, including toddler groups, youth groups, a food bank, and a support group for refugees who have fled the war in https://www.gov.uk/planning-inspectorate 4

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Appeal Decision APP/U1430/W/21/3284583 Ukraine, among numerous other examples which were cited. It was also explained that the ability to run and expand such activities was constrained by several factors, including a lack of community space compared to demand (for example, to increase the capacity of the toddler group), and the lack of flexibility and adaptability of the existing spaces. Conflict between different groups of users (for example, in respect of shared access arrangements, or a lack of sufficient suitable toilet, changing or quiet/private spaces) also limits the church’s ability to meet the demand and need for community activities and space. 21. The appellants consider that the proposed redevelopment would enable the church to provide more, more versatile, and better-quality spaces for a variety of community uses than it is able to do at the moment. This is in the context of some parts of the fabric of the building requiring a significant investment in repair and refurbishment simply to maintain – rather than improve – the available facilities. My attention was drawn to various elements of the complex where considerable remedial work is needed, for example to address leaks or damp.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision I also saw on my site visit that some of the facilities such as toilets are not of the standard which a multi-purpose community facility would generally wish to provide these days. 22. It was put to me that the redevelopment would represent an opportunity to create a more sustainable building which would make much more efficient use of energy and water resources than at present, reducing the church’s carbon footprint and saving on running costs. An interested party speaking in favour of the appeal proposal told the Hearing about numerous other churches within Bexhill which had significantly cut back their religious and community services, or closed altogether, as a result of unsustainable operating and maintenance costs. I also heard that the proposed redevelopment would also provide improved accessibility by providing level and more direct access through most of the site (including lifts to all upper floor parts), making the centre as a whole much more user-friendly than the current rather labyrinthine layout which has numerous changes in level. 23.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision For its part, the Council is supportive of the appellants’ desire to improve the facilities at Beulah Baptist Church, and to continue to deliver and expand its range of community services and activities. However, the Council does not consider that other options for remodelling (and part rebuilding) the site without demolishing The Sanctuary which the appellants had prepared were appraised properly. It also considers that the positive factors it acknowledges would not outweigh the heritage harm caused by the loss of The Sanctuary. Findings on NDHA main issue 24. Beulah Baptist Church as a whole has changed considerably over the century and a quarter or so since it was built. While the Clifford Hall is the oldest part of the complex, The Sanctuary is its most prominent feature. It was described by Bexhill Heritage, a representative of which appeared at the Hearing, as “a distinctive well-mannered and graceful piece of architecture with much attractive detailing and finely proportioned stained glass windows”.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Based on what I saw on my site visit, I largely agree with that assessment, although such distinctiveness as the building possesses is really only relative to its local surroundings rather than being of any greater interest. All the same, while The Sanctuary is in many ways a visually and architecturally unremarkable late- https://www.gov.uk/planning-inspectorate 5

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Based on what I saw on my site visit, I largely agree with that assessment, although such distinctiveness as the building possesses is really only relative to its local surroundings rather than being of any greater interest. All the same, while The Sanctuary is in many ways a visually and architecturally unremarkable late- https://www.gov.uk/planning-inspectorate 5

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Appeal Decision APP/U1430/W/21/3284583 Victorian church building, it has a pleasing form and detailing, and its setting at the corner of Buckhurst Road and Clifford Road behind its narrow but neat lawns and shrubs makes a positive contribution to its immediate surroundings. The corner tower in particular contributes to a sense of place on approaching Bexhill-on-Sea’s small civic quarter, although its truncated form means that its influence is very localised rather than broad. 25. Beyond these positive factors though, it is apparent that The Sanctuary, and the wider church site, has been altered many times over the years; as a result, there are very few noteworthy original features remaining. The extensions which have been built around and connected to The Sanctuary have also resulted in the complex as a whole having a confusing and incoherent internal layout; such modest architectural merit as the exterior of the building retains is generally much less apparent once inside the building.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision While EH’s observations on this matter, and its decision not to statutorily list any part of Beulah Baptist Church, are not determinative, they summarise the situation in respect of the building’s architectural significance very well; I find that the historic architectural significance of The Sanctuary is limited. 26. The cultural heritage significance of Beulah Baptist Church, and The Sanctuary in particular, is rather greater. The discussion at the Hearing on Charles Haddon Spurgeon was educational for me, as I was not familiar with his name before this appeal. However, while he is clearly an important figure for the growth of the Baptist church in England, he did not visit or preach at Beulah, and the association is therefore somewhat limited. There is no reason why the plaques to his memory, and that of his wife, could not be reinstated elsewhere on the site if the buildings were to be redeveloped, as indeed the appeal scheme proposed. The principal historic element of the site’s cultural heritage significance could therefore be acknowledged.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Meanwhile, it seems to me that the remaining cultural significance is derived primarily from the continuing, and apparently relatively thriving, use of the church complex both for worship by the Baptist community of Bexhill and their visitors, and the wide range of community uses which its various rooms and halls are put. 27. The townscape heritage significance of The Sanctuary is largely a function of its setting on an approach to the town centre, and the modest if pleasing contribution which it makes to arriving in Bexhill-on-Sea. Given the relatively limited architectural significance of The Sanctuary itself, while this is a positive factor it is one which could also be achieved by another well-designed civic or community building on the site, rather than something which could only be associated with The Sanctuary. I therefore consider its townscape heritage significance to be moderate. 28. Taking all of these points together, I consider the heritage significance of The Sanctuary to be moderate and local, and derived primarily from its historic cultural associations rather than its limited architectural value.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision As the proposal would involve the complete demolition of The Sanctuary, it would mean the total loss of an NDHA; the scale of harm to that asset would therefore be substantial. However, given the limited architectural and historic significance of The Sanctuary this does not weigh solely in favour of its retention. 29. Weighed against the loss of the NDHA are the benefits which would be derived from provided expanded and enhanced community services, in a building which would make more efficient use of energy and other resources, and which would https://www.gov.uk/planning-inspectorate 6

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision As the proposal would involve the complete demolition of The Sanctuary, it would mean the total loss of an NDHA; the scale of harm to that asset would therefore be substantial. However, given the limited architectural and historic significance of The Sanctuary this does not weigh solely in favour of its retention. 29. Weighed against the loss of the NDHA are the benefits which would be derived from provided expanded and enhanced community services, in a building which would make more efficient use of energy and other resources, and which would https://www.gov.uk/planning-inspectorate 6

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Appeal Decision APP/U1430/W/21/3284583 be far more versatile, accessible, and adaptable to the needs of the community it would serve. In my view, these benefits carry considerable weight in favour of the proposal. 30. The appellants presented alternative options for redeveloping the site as part of their planning application and appeal submissions. I note the Council’s comments, made both in written evidence and at the Hearing, that it is not satisfied that demolition has been justified as the best or only viable option [my emphasis] to achieve improved facilities and continued use of the church; however, that is not the relevant test set out in either the Framework or the development plan. 31. Accordingly, I find that the benefits of the proposal would outweigh the harm arising from the loss of the NDHA. I therefore conclude that the proposed development would not unacceptably harm the architectural and historical significance of non-designated heritage assets. The proposal would therefore comply in these respects with Policies EN2 and BX1 of the RLPCS, and with the requirements of paragraphs 189, 197 and 203 of the Framework, the objectives of which I have described above. Character and appearance 32.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision The appeal site is at a prominent street corner location. Although it is close to the centre of Bexhill-on-Sea, the surrounding area is predominantly residential. There is a considerable breadth of housing types nearby, including substantial two- and three-storey semi-detached Victorian villas (many of which now appear to have been converted into flats), inter-war semi-detached and detached houses, and various purpose-built blocks of flats from the 1950s or ‘60s through to the present day. There is a similar breadth of materials (walls may be of red or orange brick or of painted render), roof types (pitched and flat are both commonplace) and detailing (bay windows and a variety of porch canopies are frequently seen, window size and style generally vary according to the age of the building). 33. Across all building types there is generally a uniformity of scale, or at least of height; most are two or three storeys high, although some purpose-built blocks of flats have four (or, rarely, five) storeys. The most important civic and community buildings, including The Sanctuary of Beulah Baptist Church, use height and corner features such as towers to emphasise their significance.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision The Bank Chambers and Bexhill Town Hall further down Buckhurst Road have a strong identity and make a very positive contribution to the area. My attention was also drawn to the grey-painted concrete telephone exchange building (also on Buckhurst Road); it too has a strong identity, although its starkness does not make a positive contribution to the character or appearance of the area when considered alongside many of its more sympathetic neighbours. 34. The centrepiece of the proposed new development would be a double-height church and multi-purpose hall. The two most prominent features would be a new tower at the north-east corner, and the low pyramidal roof above the main double-height hall. There would be a new glazed entrance foyer on the Clifford Road frontage, with coffee bar, and a linked overflow space or meeting room. There would be further meeting rooms, offices and other facilities in a two- storey building on the Clifford Road side of the site. The materials palette would comprise brick cladding, panels of recessed textured brick, stone https://www.gov.uk/planning-inspectorate 7

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Appeal Decision APP/U1430/W/21/3284583 cladding, curtain wall glazing, with copper fascias, copper standing-seam roofing, and copper turrets to the pyramidal roof. 35. The Council expressed concern in its appeal statement about several elements of the proposed replacement building; these were elaborated on in discussion at the Hearing. I summarise these major concerns as dividing into the specific (the design of the lobby frontage to Clifford Road, the effect on the Clifford Hall of the proposed recladding of the existing Beulah Centre building, the appearance of the proposed large glass window on the northern elevation) and the more general (that the building would be bulky, blockish and anonymous, and would read more as a commercial building than a church). 36. The reception/foyer area would be a large glazed space extending along much of the Clifford Road frontage. It would have a copper roof canopy between the projecting ground floor level and the windows of the first-floor meeting rooms and offices above.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision In describing the proposed use of a projecting copper canopy here (and on the reconfigured doorway to the Beulah Centre further along Clifford Road), the appellants explained at the Hearing that this had in part drawn inspiration from the canopy porches on many nearby houses. 37. However, while domestic porches are a reasonably common feature of the area, it does not follow that they are an appropriate or significant design cue for a substantial religious and community building. The foyer proposed here would in any case be of entirely different proportions, materials and appearance to the residential porches nearby. It was described by the Council as being “clunky and chunky” and commercial in nature. Notwithstanding that copper roofing is a high-quality material which would weather attractively, I agree with that assessment. Because of its bulk and prominence, in my view the reception area as currently proposed would present an unsympathetic and intrusive frontage to Clifford Road. 38. The existing Beulah Centre is visually distinct from the Clifford Hall and The Sanctuary on either side, and this breaks up the Clifford Road frontage.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision The distinctiveness also emphasises the functional role of the Beulah Centre at present, as the principal entrance and focus for community (rather than worship) activities which are held in the Beulah Centre and Clifford Hall parts of the church. Under the appeal scheme, the new main hall building and its ancillary rooms and spaces would be internally connected to the Beulah Centre. The front elevation of the Beulah Centre would be reclad, with the separate entrance being retained. The recladding would use panels of stone and textured brick with a vertical emphasis for the Beulah Centre, as well as a projecting copper canopy of similar overall form to that on the proposed Clifford Road foyer. 39. The overall effect of the development, including the recladding, would be to subsume the Beulah Centre into the new building. In many ways this would not be problematic, as the existing Beulah Centre building is clearly of its time and visually unremarkable.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision However, the loss of much of the visual differentiation between the different parts of the church while at the same time retaining a functional or operational distinction would result in that part of the complex sitting in an unsatisfactory no-man’s-land between integration and separation. It would present a visually incoherent face to Clifford Road, and in practical terms would be likely to be somewhat confusing for visitors. In these respects https://www.gov.uk/planning-inspectorate 8

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision However, the loss of much of the visual differentiation between the different parts of the church while at the same time retaining a functional or operational distinction would result in that part of the complex sitting in an unsatisfactory no-man’s-land between integration and separation. It would present a visually incoherent face to Clifford Road, and in practical terms would be likely to be somewhat confusing for visitors. In these respects https://www.gov.uk/planning-inspectorate 8

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Appeal Decision APP/U1430/W/21/3284583 it would fall short of the Framework’s requirement that development should function well, as well as the guidance of the 2021 National Design Guide. 40. The proposed northern elevation of the new hall would be relatively simple, with a stone-clad tower at the north-east corner, and a double height structural glass window set in a stone surround, in an otherwise plain brick and stone wall. In this context, I do not agree with the Council’s assertion that the glass screen would be a “highly discordant elevational treatment in the streetscene”. The screen’s visual prominence and status might have the effect of drawing some visitors to that frontage in the hope or expectation of finding the main entrance to the church, which in fact would be around the corner on Clifford Road, this would not in itself be a significantly harmful failing of the scheme. 41. While the Council described the tower as “probably the most successful element of the proposed new building”, the Bexhill Society took a different view, describing it as “an artifice” and “at odds with its surroundings”.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision It was confirmed at the Hearing that the proposed tower would be neither as tall nor as close to the corner of Buckhurst Road and Clifford Road than the existing one. As a result, I consider that Beulah Baptist Church would become a rather less prominent landmark in the streetscene than it is at present. Nevertheless, the proposed tower would have both functional and aesthetic roles, would be of decent quality materials, and indeed would be the only significant element of the scheme which would instantly and unambiguously identify it as being a church. 42. Taken altogether, I consider that the Buckhurst Road frontage would meet the church’s aim of creating a modern and welcoming building in a way which would not be achieved by the bulky, commercial-looking and relatively anonymous frontage proposed for Clifford Road. 43. Other aspects of the scheme would also be acceptable, including the pyramidal copper roof above the main hall which, although it would be relatively shallow and therefore unseen from close up, would contribute some visual distinctiveness in longer views, and would echo the use of copper for the dome of the Bank Chambers building nearby.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Some less satisfactory matters (such as the proposed rooftop guardrails which would be visually intrusive) could have been addressed by the use of conditions requiring the submission and approval of further details, had the scheme been otherwise satisfactory. 44. I recognise that the appellants submitted several earlier iterations of this scheme to the Council for pre-application consultations, and as I have already acknowledged there is much within the proposal which is commendable. However, I consider that the proposed development would present an unsympathetic and incoherent frontage to Clifford Road; in this light, I concur with the Council’s concerns about the blockish form and the anonymous, commercial design and character of the development. 45. I conclude that the proposed development would, because of its unsympathetic bulk, massing and detailed design, cause unacceptable harm to the character and appearance of the area.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision It would therefore conflict with Policies EN3 and BX1 of the RCS, which seek to conserve and enhance the distinct character of Bexhill by, among other things, ensuring that new development contributes positively to the character of its site and surroundings, and responds appropriately to local context in terms of identity, placemaking, ease of movement, and appearance. The proposal also fails to comply with the https://www.gov.uk/planning-inspectorate 9

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision It would therefore conflict with Policies EN3 and BX1 of the RCS, which seek to conserve and enhance the distinct character of Bexhill by, among other things, ensuring that new development contributes positively to the character of its site and surroundings, and responds appropriately to local context in terms of identity, placemaking, ease of movement, and appearance. The proposal also fails to comply with the https://www.gov.uk/planning-inspectorate 9

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Appeal Decision APP/U1430/W/21/3284583 requirements of Paragraphs 130 and 134 of the Framework which seek to ensure that development is well-designed, functions well, and adds to the overall quality of the area. Other Matters 46. In 2020 the Council determined that prior approval for the demolition of the entire Beulah Baptist Church was not required, and a notice to that effect was issued on 25 August 20202. As the Council pointed out, the matters which can be considered in determining a prior approval notification are very limited. I have not inferred from the Council’s decision in that case that it is supportive (rather than grudgingly accepting, within the confines of a prior approval notification) of the principle of the loss of the church buildings; indeed, from all the evidence before me that is quite clearly not the case. 47. My role in determining this appeal is to consider the entire scope of the proposal before me. In planning terms, the buildings could be lawfully demolished at any point up until that notice expires on 24 August 2025.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision However, the appellants explained to me at the Hearing that to do so without any alternative planning permission in place would be “disastrous in the short and medium term” for the church and the various community groups using the buildings. On this basis, I do not consider that there is a realistic prospect of the demolition being carried out without an alternative scheme in place if this appeal is dismissed. It therefore carries little weight as a fallback position and, notwithstanding my conclusion on the loss of The Sanctuary, has not had a significant bearing on my decision. 48. A large number of comments were submitted by interested parties. The majority of these were from supporters of the scheme, keen to emphasise the way in which it would enhance the delivery of worship and community activities at Beulah Baptist Church, although a significant number were from people or organisations objecting either particularly to the loss of a heritage asset, or about particular or general aspects of the proposed replacement scheme. To the extent that these matters are material, they have been addressed in my consideration of the main issues above. None of the other matters raised have altered my overall decision.

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — Appeal Decision Planning Balance and Conclusion 49. Although I have found that the loss of The Sanctuary would be acceptable in the light of the benefits of the scheme, the proposal would not be acceptable in terms of its effect on the character and appearance of the area, principally because of its unsympathetic frontage to Clifford Road. As a consequence, the development conflicts with the development plan taken as a whole. 50. There are no material considerations, including the Framework, which indicate that a decision should be made other than in accordance with the development plan. For the reasons given above, the appeal is therefore dismissed

Beulah Baptist Church , Clifford Road, Bexhill on sea, TN40 1QA — Rother District Council — M Cryan Inspector 2 LPA Ref: RR/2020/1428/DN https://www.gov.uk/planning-inspectorate 10 Appearances FOR THE LOCAL PLANNING AUTHORITY Clare Gibbons Rother District Council James Laibach Rother District Council Diane Russell* Rother District Council FOR THE APPELLANT Julia Mitchel Lewis & Co Paul Burgess Lewis & Co Phil Winch CPL Architects David Lockwood Beulah Baptist Church Pat Reigh Beulah Baptist Church INTERESTED PARTIES Christine Bayliss Councillor, Rother District Council David Beales Bexhill Heritage * Participant appeared by video link https://www.gov.uk/planning-inspectorate