Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Hearing held on 24 October 2023 Site visit made on 25 October 2023 by M Cryan BA(Hons) DipTP MSc MRTPI an Inspector appointed by the Secretary of State Decision date: 2 January 2024 Appeal Ref: APP/L3245/W/23/3324562 Sych Farm, Adderley Road, Market Drayton TF9 3SW • 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 LNT Care Developments against the decision of Shropshire Council. • The application Ref 22/04423/FUL, dated 28 September 2022, was refused by notice dated 23 December 2022. • The development proposed is a two storey 66-bed Care Home for Older People (Use Class C2) and associated outbuildings with associated access and parking, including the demolition of existing buildings. Decision 1. The appeal is dismissed. Procedural Matter 2. The Government published an amended version of the National Planning Policy Framework (“the Framework”) on 5 September 2023, replacing the July 2021 version extant at the time the planning application was determined. Following the Hearing, a further revision of the Framework was published on 19 December 2023.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The amendments made did not have any bearing on the issues in this appeal, and it was therefore not necessary to seek comments from the main parties on the updated Framework. Where I have referred to specific paragraphs of the Framework, the numbering is that of the December 2023 version. Main Issues 3. The main issues are: • Whether the appeal site is an appropriate location for the proposed scheme, having particular regard to effects on the supply of employment land, and local need for the development; • Whether the proposed development would provide satisfactory living conditions for future residents with particular regard to noise disturbance and any mitigation proposed; and • Whether or not Sych Farm should be considered a non-designated heritage asset, the effect of the proposed development on the architectural and historic significance of any heritage assets, and whether any harm to or loss of heritage assets would be outweighed by the benefits of the proposed development. https://www.gov.uk/planning-inspectorate

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 Reasons 4. The appeal site comprises the farmhouse and related agricultural buildings, and an area of associated land, of Sych Farm. The site is on the northern edge (and within the development boundary) of the town of Market Drayton. Access is from Western Way on the site’s northern edge; this becomes Burnside Road alongside the Gingerbread Man public house to the west of the site. Beyond this a roundabout connects to the wider highway network, including the busy A53 Market Drayton bypass which runs along the southern edge of the appeal site. To the east of the site is open agricultural land, while across Western Way to the north is a large commercial area which includes the town’s livestock market. 5. The farmhouse is a two-storey building, with a block of one- and two-storey outbuildings around a regular courtyard to the west. The buildings are of red brick, though while the farmhouse has a slate roof the outbuilding has clay tiles. They were built in the mid-19th century as a model farm. The proposed development is the demolition of the existing buildings on the site, and the erection of a purpose-built 66-bed residential care facility for older people.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Its facilities would include lounges and dining rooms, a café/bar, family rooms, a TV/cinema room, and services such as a shop, a clinic and a hair studio. The scheme would also include associated infrastructure, access, car parking and landscaping. The proposed development would create employment for around 50 to 60 people, which it was suggested at the Hearing would amount to around 48 full-time equivalent jobs. Whether an appropriate location for the proposed development Relevant development plan policies 6. The development plan comprises the 2011 Shropshire Core Strategy (“the SCS”), and the 2015 Site Allocations and Management of Development Plan (“the SAMDev”). The Council is currently preparing a new local plan (the Draft Shropshire Local Plan – “the DSLP”) which was submitted to the Secretary of State for examination in September 2021; Examination Hearings have taken place during 2022 and 2023. Reference was also made at the Hearing to a neighbourhood plan being prepared for the “Three Parishes” of Adderley, Norton in Hales, and Moreton Say.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision It is my understanding however that, although the appeal site lies within the parish of Adderley (and the parish council was supportive of the scheme), it is outside the area covered by the Three Parishes plan, the emerging policies of which therefore would not be relevant in this appeal. 7. Policy CS6 of the SCS and Policy MD2 of the SAMDev set out sustainable design and development requirements. They seek development of a high quality; among other things it requires all development to respect and enhance local distinctiveness, and state that proposals likely to generate significant levels of traffic should be located in accessible locations where opportunities for walking, cycling and use of public transport can be maximised and the need for car- based travel reduced. 8. Policy CS11 of the SCS seeks to meet the diverse housing needs of Shropshire residents by, among other things, supporting the provision of housing for vulnerable people and specialist housing provision, including nursing homes, https://www.gov.uk/planning-inspectorate 2

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 residential and extra care facilities, “in appropriate locations and where there is an identified need”. 9. Policy CS13 of the SCS seeks to develop and diversify the Shropshire economy, including by planning and managing a responsive and flexible supply of employment land and premises comprising a range and choice of sites in appropriate locations to meet the needs of business. Policy CS14 aims to manage the supply of employment land, with the aim of delivering around 290 hectares during the 2006-2026 plan period; among other things, it seeks to do this by protecting existing strategic employment land and premises to secure these sites for employment uses. 10. Policy MD4 of the SAMDev seeks to manage and maintain the supply and provision of employment land and premises. It is broadly supportive of proposals for Class B or sui generis uses which include industrial or commercial employment opportunities on committed or allocated sites.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision It states that proposals for alternative uses on these “portfolio sites” will only be acceptable in certain circumstances; these are where there are no other suitable development sites for the proposal, where the development will provide significant employment opportunities or other significant benefits for the sustainability of the community, and where the development will not adversely affect the range and choice of employment sites in terms of location, quality, type and size. The supporting text to the policy includes Class C2 among alternative uses, while reiterating that the plan’s “presumption in favour of protecting portfolio sites from alternative uses” means that “clear and compelling evidence” will be required in respect of the policy tests before such uses will be permitted. 11. Policy MD9 of the SAMDev seeks to protect existing employment areas for “Class B and appropriate sui generis employment uses”.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision It indicates that this protection will be “proportionate to the significance of the employment area” (with reference to the hierarchy set out in the plan), and having regard to factors including the availability of other suitable sites, the impact on the range and choice of employment land, the business case for the proposed use, and the potential for conflict with neighbouring uses. The policy goes on to state that where proposals for alternative uses would lead to the loss of the protected employment area, evidence of appropriate marketing over a sustained period will be required to demonstrate that the land or premises are no longer commercially viable for the preferred uses. 12. Turning to the DSLP, emerging Policy SP13 seeks to deliver around 300 hectares of employment during the 2016—2038 plan period. It distinguishes between “primary” and “secondary” employment uses including, in the secondary category, uses within Class C2. It states that there is a presumption to protect allocated employment land and established employment areas primarily for Class B employment uses.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Proposals for other uses will only be supported where it is demonstrated that the supply of employment land would not be compromised, where the proposed use would make a significant contribution to the local economy, and where a comprehensive marketing exercise demonstrates that the site is not suitable or viable either for the established use, or for any other employment use. 13. Emerging Policy DP1 seeks to ensure that residential development provides a mix of dwelling sizes, types and tenures in order to meet the identified needs https://www.gov.uk/planning-inspectorate 3

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Proposals for other uses will only be supported where it is demonstrated that the supply of employment land would not be compromised, where the proposed use would make a significant contribution to the local economy, and where a comprehensive marketing exercise demonstrates that the site is not suitable or viable either for the established use, or for any other employment use. 13. Emerging Policy DP1 seeks to ensure that residential development provides a mix of dwelling sizes, types and tenures in order to meet the identified needs https://www.gov.uk/planning-inspectorate 3

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 of local communities. Among other things, it states that the development of sites of 50 or more dwellings should provide an appropriate range of specialist housing designed to meet the diverse needs of older people, which could include residential care homes and nursing homes. 14. I was also directed to another emerging policy, Proposed Draft Policy DP2. Somewhat confusingly, this is not the Draft Policy DP2 in the submission version of the DSLP (which addressed self-build and custom-build housing); it was explained at the Hearing that it is a new policy which had been prepared in response to direction from the examining Inspectors that the development plan needed to specifically address housing provision for older people and those with disabilities and special needs. Among other things, the policy seeks to ensure that specialist housing for older people is integrated into, rather than set apart from (including gated-off from) existing and new communities, and in locations where future occupiers can benefit from access to existing services and facilities.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision It also provides further detail in respect of the level of provision of specialist housing for older people on larger sites allocated for housing development referred to in Policy DP1. 15. The DSLP is not yet adopted, and its emerging policies were not referred to on the decision notice issued by the Council, but it is nevertheless a relevant material consideration. Given the stage of the plan’s preparation, I afford draft policies SP13 and DP1 moderate weight for the purposes of determining this appeal. The position in respect of “Proposed Draft Policy DP2” is slightly different; it is a very recent addition to the DSLP and, notwithstanding that it appears to have been prepared at the prompting of the local plan Inspectors, it has not yet been tested at examination, and I therefore afford it only limited weight. All this said, the adopted policies of the SCS and the SAMDev continue to be afforded full weight for the purposes of determining this appeal. 16. Both parties referred to other development plan policies in their written evidence and at the Hearing. However, I consider that those summarised in this section are the ones which are of greatest relevance to this main issue. Employment land 17.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The appeal site falls within the Sych Farm Phase 1 employment area, which also encompasses the adjacent Gingerbread Man pub, the business units and large livestock market to the north of the site, and the various commercial and industrial units extending north along Western Way. It is therefore part of a protected employment area designated in the SAMDev. The open fields to the north-east and east of the site are part of an area allocated as an employment site (Sych Farm Phase 2) by the SAMDev. It is not proposed that these designations would change under the emerging DSLP. 18. The Sych Farm employment area is defined as a “key local site” by the employment land and sites study within the SAMDev evidence base (“the SEAS”)1. This is the third tier within the SAMDev hierarchy, and Table MD9.1 in the SAMDev describes such sites as being “expected to deliver good quality development providing strategic and local employment opportunities with clear economic benefits for the Shropshire economy”. 1 Shropshire Strategic Sites and Employment Areas Study: Phase 2 – Market Towns and Key Centres: BE Group for Shropshire Council (2013) https://www.gov.uk/planning-inspectorate 4

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 19. I was told at the Hearing that the owners of Sych Farm are no longer living in the farmhouse, having relocated to another property they own elsewhere in the area. At the time of my site visit parts of the agricultural buildings were still being used to house cattle, although it was explained that these belong to a neighbouring farmer who is renting the space from the site owners. One of the reasons put forward for the owners’ relocation was that the landholdings at Sych Farm have been progressively reduced over the years by the sale of land for commercial development, leading to the other property becoming a more efficient base for farming operations. This change was, however, anticipated by (and is in line with) the identification and allocation of Sych Farm and surrounding land for employment purposes in the development plan; the apparent gradual winding down of the site as a working farm is not, in itself, a significant or decisive matter in this appeal. 20.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Planning permission was granted in 2009 for the redevelopment of much of the site (not including the farmhouse itself) for a “live-work” scheme comprising six new dwellings and the conversion of the farm outbuildings to six “office-style” units (“the 2009 permission” – LPA Ref: 09/01335/FUL). That permission included conditions restricting the commercial units to (then) Class B1 uses, and limiting occupancy of the six dwellings to the occupiers of the business floorspace and their dependants. The 2009 permission was granted under different development plan policies, and I was not provided with a full officer report for it. However, the decision notice states that the scheme had been approved because, among other things, it would “utilise and2 allocated employment site for a sustainable development that would encourage new enterprise”. 21. The 2009 permission was not implemented and has now lapsed; none of the evidence put before me clearly explained why it had not been developed, although of course I recognise that these things happen, and often.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The appellants argued that the appeal site has been protected for employment purposes for an “excessively long” period, and that there is no prospect of the type of scheme preferred by the development plan coming forward. In 2015 the SEAS referred to the 2009 permission (although even by then it had presumably expired) and described the landowners as “waiting for an improving market before offering the site to developers (the land has previously been marketed for these uses, unsuccessfully)”. 22. Given the varying degrees of uncertainty which the economy has faced over the last decade and a half it is questionable whether the market has improved to the extent which the site owners have apparently been hoping for since 2009. I was told at the Hearing that a marketing board was visible on Google Maps imagery of the site from 2021, and during my site visit I saw an old “for sale” board among the various bits and pieces discarded around the site. However, there was nothing to explain how much or how long the site had been marketed for, to whom, and what (if any) expressions of interest or feedback the marketing agents may have received.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The evidence which was available to me does not demonstrate that the development plan requirements in respect of appropriate marketing of the site over an extensive period have been met. 2 Sic – my assumption is that this should read “an”. https://www.gov.uk/planning-inspectorate 5

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The evidence which was available to me does not demonstrate that the development plan requirements in respect of appropriate marketing of the site over an extensive period have been met. 2 Sic – my assumption is that this should read “an”. https://www.gov.uk/planning-inspectorate 5

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 23. The Council referred at the Hearing to the recent announcement of government funding for the Shrewsbury North West Relief Road, but there was little solid information to show that this on its own would be likely to make the appeal site more attractive to industrial investors. At the same time, none of the evidence I saw or heard demonstrated that the site is not suitable for the “primary” employment uses sought by the development plan. 24. In terms of possible alternative sites for a proposed C2 use, the appellants stated that all the residential sites in Market Drayton allocated by the SAMDev have been built out, and that therefore “only employment allocations remain developable”. However, there was little to demonstrate the extent to which potential “windfall” sites within the town had been considered and discounted. The appellants drew my attention to another site, at the rear of the Aldi store across the A53 and only 150m or so from the appeal site, where outline planning permission had been granted for a residential care home (LPA Ref: 19/01639/FUL). I understand that that no operator had been identified for that other scheme, and the permission has now lapsed. 25.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Contrary to what was said in the appellants’ statement, the SAMDev policy map shows that the other site is not within a Protected Employment Area. Regardless of its proximity to the appeal site, the planning considerations in respect of that other site are very different. The fact that the Council approved that application “without any request for demonstration of need” does not therefore weigh in favour of the appeal proposal. However, it does illustrate the potential availability of a “windfall” site which may be appropriate for the proposed use. Need for the development 26. The appellants’ case was supported by a “needs assessment”, with an updated version of that submitted with the planning application provided at the appeal stage3. This looked at a catchment area of an eight-mile drive4 from the appeal site, analysed the demographics of the elderly population, the current and future supply of care home beds (using the measure of “market standard” beds with wet rooms5), and projected future demand for such spaces. It estimated that, within the selected catchment area, there would be a shortfall of around 283 beds by 2027, and that this would increase to around 317 beds by 2032. 27.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The appellants’ study found that around two thirds of the existing supply of bedrooms in care homes within the Market Drayton area are within converted properties, with the remainder being in older purpose-built facilities. It also found that only around nine percent of bedrooms meet the market standard including wet room facilities, and that therefore the existing stock was not “future proofed”. The appellants’ evidence at the Hearing emphasised the quality of the accommodation which the proposed development would offer. The smaller, more local catchment area was suggested to be reflective of people’s “real lives” and wishes to remain close to established family and social networks. 28. The Council’s analysis of the North East Shropshire catchment area, including Market Drayton, indicated that there was presently adequate capacity to meet 3 Sych Farm Planning Needs Assessment, June 2023, Knight Frank. The original version was dated March 2022. 4 Rather than a simple radius. 5 i.e. Bedrooms with WC, wash basin and ensuite wet room or shower/bath facility. https://www.gov.uk/planning-inspectorate 6

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 the need for all types of care home provision, and that combined with pipeline supply it would provide sufficient capacity to meet the demand in that part of the county. The Council also referred to the approach of the Shropshire Adult Social Care Strategy, which aims to assist people to stay in their own homes, including by providing support with domestic or self-care needs, thereby deferring moves into care facilities until much later in life than might have been the case recently. It disagreed that there would be a shortfall in care home capacity, and considered that the scheme would not therefore meet an identified local need. It explained at the Hearing that considering a wider catchment area in planning for social care needs enabled it to ensure that efficient use was made of capacity. 29. The main parties’ assessments of need are based on different catchment areas, timeframes, and criteria, and are therefore not directly comparable. The discussions at the Hearing did not appear to narrow the differences of interpretation and analysis between the Council and the appellants.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision However, based on all the written submissions, and what I was told at the Hearing, I have no substantive reason to discount the evidence of either party, including the appellants’ case that there is a local need for additional care home accommodation within the Market Drayton area. 30. The appellants suggest the appeal site is a highly sustainable and accessible location, close to day-to-day services and amenities. The site is certainly well- integrated with the major road infrastructure into and around Market Drayton – as I have already described above, it is next to the town’s bypass. There are level pedestrian and cycle routes around the site, but using them to get to and from the nearest bus stops at Prospect Road (a 900m walk to the south) and the shops and amenities in the town centre beyond that requires crossing the A53 next to the Gingerbread Man roundabout. I walked part of that route myself after my site visit, and saw that the A53 was very busy with large numbers of heavy goods vehicles passing by. It is not an easy road to cross on foot. 31.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision My visit was carried out on what was clearly a busy auction day at the nearby livestock market, and numerous vehicles were parked or manoeuvring on Western Way and Burnside Road between the appeal site entrance and the Gingerbread Man public house. In places, the parking was obstructing the footway. There were also other lorries and commercial vehicles passing along Western Way, and that road would be likely to become even busier still at such time as the remaining parts of the designated employment land it serves are developed. In my view, the highway environment around the appeal site is essentially a hostile one for pedestrians and cyclists. 32. It seems extremely unlikely to me that most people visiting the proposed development would choose to do so other than by private car. This would also limit the potential usefulness of nearby amenities for staff and residents of the home. I note also the appellants’ suggestion that the site’s location next to the livestock market, which serves a large catchment area, would allow care home residents’ families to combine visiting them with trips to the auctions.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision That may be so, although there was no substantive evidence to explain the proportion of local residents who are regular market users. In any event, beyond that possible moderate locational advantage, the site’s position between two roads carrying commercial and industrial traffic, and alongside a busy existing industrial area which is allocated for further development (and noting that I https://www.gov.uk/planning-inspectorate 7

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision That may be so, although there was no substantive evidence to explain the proportion of local residents who are regular market users. In any event, beyond that possible moderate locational advantage, the site’s position between two roads carrying commercial and industrial traffic, and alongside a busy existing industrial area which is allocated for further development (and noting that I https://www.gov.uk/planning-inspectorate 7

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 turn to specifically address the question of noise in a moment), means that its surroundings would not provide the pleasant sort of environment which residents of the proposed development, or their families, would be likely to be looking for in a care home. Findings on this main issue 33. Tying all the foregoing points together, I consider that the creation of the equivalent of around 48 full-time jobs would be a positive benefit of the scheme. However, the proposed development would not fall within the former B1 (offices, research and development and light industrial processes suitable within residential areas), B2 (industrial processes not covered by B1), or B8 (storage or distribution) use classes which the relevant policies of the SCS and the SAMDev prioritise for employment land and sites, and an inevitable consequence of it going ahead would be to reduce the availability of sites suitable for those priority uses. 34.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The policies of the SAMDev do open up the use of sites within protected employment areas for other employment-generating purposes, but this is subject to compliance with a range of criteria (described in paragraphs 10 and 11 above) which clearly aim to make this the exception rather than the rule. The same is true of the emerging policies in the DSLP, with their distinction between “primary” and “secondary” employment uses. The appellants have not demonstrated that the site is not suitable or commercially viable for the preferred uses and that it has been appropriately marketed over a sustained period, or that there are no other suitable sites for the proposed use. The evidence put forward to support the loss of the employment site is not therefore clear and compelling. 35. I acknowledge that there is likely to be a local need for additional care home accommodation over the coming decade or so, and that the proposed development would make a contribution to meeting this need. However, notwithstanding the fact that Sych Farm is only 1km or so from Market Drayton town centre (and closer still to the nearby Aldi and Morrisons supermarkets), the busy A53 is a significant barrier between the appeal site and the town.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The site’s surroundings, including the various industrial and commercial uses to the north, also mean that it is not, in my view, a suitable location for the proposed development. 36. I therefore conclude that the proposed development would conflict with Policies CS6, CS13 and CS14 of the SCS, and Policies MD2, MD4 and MD9 of the SAMDev, the principal relevant provisions of which I have set out in paragraphs Error! Reference source not found. to 11 above. For the same reasons, I also conclude that it would conflict with emerging policies DP1, DP2 (“Housing Provision for Older People…”) and SP13 of the DSLP, the principal relevant provisions of which are set out in paragraphs 12 to 14 above (though, as I have explained in paragraph 15, the emerging status of the DSLP means that I do not give full weight to conflict with these policies). I also find that the proposal would conflict with the provisions of the Framework, notably the requirements set out in paragraph 125 that developments function well, support local facilities and transport networks, and create places which are safe, inclusive and accessible. https://www.gov.uk/planning-inspectorate 8

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 Noise disturbance 37. The planning application was accompanied by a noise impact assessment report and addendum (which for simplicity I refer to together as “the NIA”). This examined the likely impacts on the proposed care home from a range of surrounding noise sources: traffic noise from the A53 and Western Way/ Burnside Road, the lorry park on the north side of Western Way, the livestock market, and the Gingerbread Man public house. 38. The NIA predicted that road noise levels at the northern and southern façades of the care home would, with open windows, exceed the BS8233:2014 criteria6 during both daytime and night-time. In respect of the Gingerbread Man, the NIA predicted that noise from a freestanding cooler condenser unit at the rear of that building would lead to night-time noise levels at the south-west corner of the care home being +11.6dB above the background sound level which, unchecked, would be likely to have a significant adverse effect on health and quality of life. By the Council’s calculation, which was not disputed by the appellants, 53% of rooms in the building would only be able to achieve acceptable internal noise levels with closed windows. 39.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The appellants said at the Hearing that the approach to site layout had been led by two main considerations; the presence of a watercourse at the north of the site, and then the surrounding noise sources. This appears at odds with the statement in the NIA that the noise consultants were commissioned at a point when “the proposed layout plan [had] already been created”. I have no reason to doubt the technical evidence that was put to me on this matter. However the “ProPG” guidance7, while not having any statutory status, advises that “using fixed unopenable glazing for sound insulation purposes is generally unsatisfactory and should be avoided”, and that “relying on sound insulation of the building envelope to achieve acceptable acoustic conditions in new residential development, when other methods could reduce the need for this approach, is not regarded as good acoustic design”. 40. While I acknowledge that occupiers of the care home would be able to spend time using the various communal spaces for leisure and recreation, it is also inevitable in such accommodation that there would be some residents who could not or would not do so, and they would therefore be likely to spend long periods within their bedrooms.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision For those people in particular, though more generally for all affected residents, fixed glazing may well represent an unwelcome lack of control over their living environment which would be detrimental to their quality of life. It is also of note that daytime noise levels at the southern façade would be 58dB L ; BS8233 recommends an upper limit of Aeq 55dB L for gardens, suggesting that a substantial portion of the space Aeq between the care home and the A53 would not in fact be particularly suitable for its proposed use as a garden. 41. Discussion of the condenser at the rear of the Gingerbread Man during the Hearing did see agreement between the parties that it would be technically feasible to erect an acoustic barrier to limit the noise reaching the nearest windows of the care home. However, in order to be effective (by blocking “line of sight” sound) any such barrier within the appeal site would have to be 6 For the LAeq measure 7 Guidance in Professional Practice Guidance on Planning and Noise, May 2017, Association of Noise Consultants, Institute of Acoustics, and Chartered Institute of Environmental Health https://www.gov.uk/planning-inspectorate 9

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 almost as tall as the buildings eaves, so would be unlikely to be acceptable aesthetically. The appellants suggested that it would be reasonably straightforward to erect a smaller and less intrusive barrier close to the condenser within the pub site. That would be dependent on a suitably robust and enduring agreement being agreed with the pub operator and secured by a planning obligation, and no such mechanism was provided. 42. The Council drew my attention to a recent residential development (“Montgomery Place”) a little way further west along the A53, where new houses had been permitted at what were said to be similar, or shorter, distances from the highway. The Council suggested during the Hearing that differences of layout may have had a bearing on the sound environment at that scheme, although I have no reason to dispute the opinion the appellants’ noise consultant that that would have been unlikely to have made a significant difference in itself.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision I was able to view that site after carrying out my site visit, but there was no further evidence put before me setting out either the reasoning in that case or any measures that development may include to avoid or mitigate noise impacts. I cannot therefore be sure that it is directly comparable to the case before me. 43. I conclude that the proposed development would not provide satisfactory living conditions for future residents, with particular regard to noise disturbance and the mitigation proposed. It would therefore conflict with Policy CS6 of the SCS and Policy MD2 of the SAMDev, which together seek to ensure that development is sustainably designed and contributes to the health and wellbeing of communities. Heritage assets Local and national planning policy 44. The farmhouse and traditional farmstead buildings at Sych Farm are not statutory listed buildings, nor are they within a conservation area. The Council does not maintain a local list of heritage assets, although the buildings appear on the Shropshire Historic Environment Record. Being locally listed is not an essential criterion for a non-designated heritage asset (“NDHA”), as set out in the definition in the Framework’s glossary. 45.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Historic England considered the buildings for statutory listing during 2023, but concluded that they do not fulfil the criteria for listing (though this does not undermine any local significance they possess)8. Nevertheless, despite having initially referred in their appeal statement to “so-called ‘non-designated heritage assets’”, the submitted statement of common ground indicated that the main parties agreed that the buildings are to be regarded as NDHAs, and that the appeal scheme would result in their demolition “and therefore the loss of whatever heritage value they may or may not have”. 46. Paragraph 195 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 209 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 8 Historic England Advice Report, 12 July 2023 https://www.gov.uk/planning-inspectorate 10

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 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.” 47. Policy CS17 of the SCS and Policy MD13 of the SAMDev seek to protect the historic environment of the county, including NDHAs. Policy MD13 states that “proposals which are likely to have an adverse effect on the significance of a non-designated heritage asset, including its setting, will only be permitted if it can be clearly demonstrated that the public benefits of the proposal outweigh the adverse effect”. Significance of Sych Farm 48. Based on the evidence before me, including what I was told at the Hearing and saw on site, I consider that there are three main elements which contribute to the significance of the farm: its development as a model farm, the quality of its architecture, and its association with the prominent local Corbet family. 49.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The development of Sych Farm as a model farm took place during the “high farming” period between 1840 and 1870, when farming and farmstead planning advanced to reflect the increased availability of commercial feeds and fertilisers. The farm buildings show some architectural elaboration, including reticulated stone details and dentil courses of brickwork, which perhaps elevate them above the commonplace in the area at the time they were constructed, although they have been much altered over time. While the Corbet family was a significant landowner in the area, it is of limited interest or significance outside the locality. 50. In assessing the buildings for listing, Historic England noted among other things that neither the architectural distinction nor the connection with the Corbet family was sufficient to demonstrate that the farmhouse is of special interest.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision In respect of the outbuildings, it commented that the arrangement is not sufficiently innovative or experimental to be of special interest in terms of the development of farming practices, and that while they are “of interesting design with some good detailing”, the degree of interest (and the cumulative extent of alterations) means that they fall short of the level required for national listing. 51. Neither of the main parties disagreed with Historic England’s reasoning or conclusions; clearly though while the appellants considered that the overall significance of the buildings as an NDHA is low, the Council continued to rate it somewhat more highly. Benefits arising from the development 52. The appellants consider that opportunities for a viable and beneficial alternative use for the buildings are extremely limited. As I have described above, the proposed development would provide residential care accommodation for up to 66 people, and jobs for 50 to 60. They also consider that the redevelopment of the site would contribute positively to the character and appearance of the area and, through the creation of habitat zones alongside the watercourse at the northern edge of the site, provide ecological benefits. 53.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision For its part, although the Council acknowledged that the proposal would create some jobs, it stressed throughout the Hearing that it was keen to see “primary” employment, and that it did not consider there to be a demonstrated local need https://www.gov.uk/planning-inspectorate 11

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision For its part, although the Council acknowledged that the proposal would create some jobs, it stressed throughout the Hearing that it was keen to see “primary” employment, and that it did not consider there to be a demonstrated local need https://www.gov.uk/planning-inspectorate 11

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Appeal Decision APP/L3245/W/23/3324562 for the care home accommodation (as covered at length under the first main issue above). It therefore remained of the view that any positive factors which might be identified would not outweigh the heritage harm caused by the loss of the farm buildings. Findings on this main issue 54. I saw on my site visit that the farmhouse and farmstead outbuildings are relatively neat and attractive buildings of their type, albeit that they are not apparently remarkable, and in need of some TLC. The farmhouse is typical of its time and place, and therefore not especially striking in and of itself. The “model” farmstead outbuildings are perhaps more noteworthy; they have a pleasing combination of robust brick sturdiness and a formal plan layout, with interesting and pleasing details picked out in brick and stone. 55. Beyond these positive factors, it is evident that the buildings have been altered many times over the years.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision Their current condition means that they would be likely to require considerable investment in order to bring them into viable use as anything other than farm buildings (though I note that neither main party appeared to have prepared any outline costings to demonstrate the extent to which this may or may not be realistic). While Historic England’s observations, and its decision not to statutorily list the buildings, are not determinative, in my view they summarise the buildings’ features and significance very well. 56. In summary then, I consider the heritage significance of Sych Farm to be moderate and local, and derived primarily from its architectural value. As the proposal would involve the complete demolition of the farm buildings, 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 Sych Farm this does not weigh solely in favour of its retention. 57. Weighed against the loss of the NDHA would be the benefits from creating a number of jobs on the site and providing care home accommodation for elderly people.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision The value and weight of these benefits is reduced somewhat because of the harm which I have identified in assessing the first two main issues; the proposal would result in the loss of designated employment land which has not been adequately justified, and which could therefore significantly undermine the strategy for future economic growth in Shropshire. The care accommodation would be in a place with, to all practical intents, limited access by means other than the private car, and where noise impacts would mean that future occupiers would not have acceptable living conditions. I therefore give the public benefits of the proposal only moderate weight, and find that this would not outweigh the heritage harm caused by the total loss of the heritage asset. 58. The proposed development would therefore conflict with Policy CS17 of the SCS and Policy MD13 of the SAMDev, the principal relevant provisions of which I have set out in paragraph 47 above. It would also conflict with the provisions of the Framework which seek to conserve and enhance the historic environment, as summarised in paragraph 46 above. Other Matters 59.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision I was told at the Hearing that the site behind Aldi south of the appeal site, where outline planning permission had been granted for a care home in 2019, https://www.gov.uk/planning-inspectorate 12

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — Appeal Decision I was told at the Hearing that the site behind Aldi south of the appeal site, where outline planning permission had been granted for a care home in 2019, https://www.gov.uk/planning-inspectorate 12 Appeal Decision APP/L3245/W/23/3324562 had recently been the subject of another planning application for a care home, though I was not provided with any further information about that proposal. Regardless of its outcome though, the differences between the two sites including their allocations within the development plan, which I have considered above, mean that it is not directly comparable to this appeal scheme. Conclusion 60. I have found that the proposed development would conflict with the development plan taken as a whole. There are no material considerations, including the Framework, which indicate that a decision should be made other than in accordance with the development plan. 61. For the reasons given above, the appeal is therefore dismissed.

Sych Farm Adderley Road, MARKET DRAYTON, TF9 3SW — Shropshire County Council — M Cryan Inspector https://www.gov.uk/planning-inspectorate 13 Appeal Decision APP/L3245/W/23/3324562 Appearances FOR THE LOCAL PLANNING AUTHORITY Liam Cowden Shropshire Council Ruth Hitchen Shropshire Council Nick Hughes Shropshire Council Philip Mullineux Shropshire Council Andy Wigley Shropshire Council FOR THE APPELLANT Alistair Wood LNT Jo Kemp LNT Thomas Davidson LNT Anthony Robertshaw Dynamic Response https://www.gov.uk/planning-inspectorate 14