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 24 July 2024 Site visit made on 24 July 2024 by A Hunter LLB (Hons) PG Dip MA MRTPI an Inspector appointed by the Secretary of State Decision date: 12 August 2024 Appeal Ref: APP/U1430/W/24/3342573 Beulah Baptist Church, Clifford Road, Bexhill, East Sussex TN40 1QA • The appeal is made under section 78 of the Town and Country Planning Act 1990 (as amended) 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 (RDC). • The application Ref is RR/2023/1498/P. • The proposed development is described as “the demolition of existing Sanctuary and Buckhurst Room Hall and construction of a new church and community centre with associated external works. Retention of Clifford Hall and alterations of the Beulah Centre elevation on Clifford Road.” Decision 1. The appeal is dismissed. Preliminary Matters 2. Following the Council’s notice of decision, the National Planning Policy Framework (the Framework) was revised on 19 December 2023. Having regard to the matters that are most relevant to this appeal, there have been few substantive changes.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision Hence, I am satisfied that no one will be prejudiced by the changes to the national policy context, and both parties have had the opportunity to make comments on the revised Framework within their statements and final comments. 3. I am also aware of both the Deputy Prime Minister and Secretary of State for Housing, Communities, and Local Government’s Written Ministerial Statement “Building the homes we need” dated 30 July 2024 regarding changes to the planning system, and the consultation “Proposed reforms to the National Planning Policy Framework and other changes to the planning system” dated 30 July 2024. However, I am content that the issues they both raise are not material to the determination of the appeal proposal, consequently, there has been no need to seek the views of the parties in regard to these proposed changes. 4. The Council acknowledged that its reference within its notice of decision to Policy BEX1 of the Rother Local Plan, Core Strategy, adopted September 2014 (RLP) was an error. It should have stated RLP Policy BX1, a copy of the correct policy was subsequently provided, and shared with the appellants. The appeal has been determined on this basis. 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/24/3342573 5. During the event the Council mentioned Annex 4, which is referred to by RLP Policy EN3 and provides some brief expansion on design principles. However, the Council had not provided a copy of Annex 4 in advance of the event. A copy was subsequently provided and shared with the appellants. The appeal was determined on this basis, and I am satisfied that no one has been prejudiced by the acceptance of this additional information. 6. Both parties have made me aware of an earlier appeal decision1 at the appeal site relating to the demolition of The Sanctuary and the Buckhurst Room, together with its redevelopment (‘the earlier appeal decision’). I have had regard to the earlier appeal decision insofar as it is relevant to the appeal scheme before me. 7. The appellants submitted Preliminary Ecological Appraisal and Preliminary Roost Assessment, dated June 2023, prepared by Arborweald Environmental Planning Consultancy (PEA) states that two further bat surveys are required to establish the presence of bats that may or may not be using the buildings at the appeal site.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision In light of this, and in the absence of any further surveys, the main parties’ comments were sought as to whether there was sufficient information regarding protected species. Following this, the appellants submitted a brief statement from Arborweald Environmental Planning Consultancy, dated 16 July 2024, which referred to one of these recommended surveys being undertaken. I will return to this later in my decision. Main Issues 8. In view of the above, and taking into account the reason outlined on the Council’s notice of decision, the main issues are: - the effect of the proposed development on the non-designated heritage asset (NDHA), known as The Sanctuary; - the effect of the proposed development on the character and appearance of the building and the area, with particular regard to its scale and design; and, - the effect of the proposed development on protected species. Reasons NDHA 9. Beulah Baptist Church is not listed, nor is it located within a Conservation Area.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision The buildings at the appeal site comprise four distinct elements; The Sanctuary, which is a large gabled building said to have been built in the 1890’s, and used as a place of worship with openings on its sides, it also has a tall tower constructed of brick; the Buckhurst Room, which is a modern single storey building, said to have been built in the 1980’s and attached to one side of The Sanctuary providing a community space; the Beulah Centre, a modern two storey building also said to have been constructed in the 1980’s, built of brick, and attached to the rear side of The Sanctuary; and Clifford Hall, a brick built building with a front facing gable said to have been constructed in the 1890s located on the other side of the Beulah Centre. 10. The Council considers the two oldest parts of the complex of buildings, Clifford Hall and The Sanctuary, to be non-designated heritage assets (NDHAs). 1 Appeal Ref: APP/U1430/W/21/3284583 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/24/3342573 Clifford Hall is to be fully retained and not altered as part of the proposal, as a result no unacceptable effects on Clifford Hall as a NDHA have been identified by the main parties, and I see no reason to disagree. It was clear at the event that both main parties agree that The Sanctuary is a NDHA, however there is some variance in opinion as to its degree of significance, particularly in respect of its architectural quality, its contribution towards townscape merit, and its cultural significance. 11. Paragraph 203 of the Framework advises that account should be taken of heritage assets, including the positive contribution that conservation of heritage assets can make to sustainable communities, and the desirability of new development making a positive contribution to local character and distinctiveness. 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.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision 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.” 12. The most relevant policies of the development plan in this regard and as set out in the agreed Statement of Common Ground dated 13 June 2024 (SoCG) are: RLP Policy EN3, insofar as it seeks to ensure new development contributes positively to the character of the site and surroundings; and RLP Policy BX1, which seeks to conserve and enhance the town’s distinct and independent character. 13. The Sanctuary has a community value as a place of worship, although noting from my site inspection and from what I heard at the event, most of the other community uses take place in other parts of the complex of buildings. It was said at the event that the congregation currently is between 250-300 worshipers, which indicates to me it has a considerable community value and cultural significance as a long-established place of worship.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision Although I do recognise, despite its association with the Spurgeon family, it was not visited by the prominent preacher Charles Haddon Spurgeon, who died before it was built, and although his wife and sons did have a connection to the building following his death, it is of a lesser significance. Moreover, it was established at the event that the plaques relating to the Spurgeon family could be incorporated into the retained or proposed development through a suitable planning condition, in the event the appeal is allowed. 14. The appeal site is located on a corner with frontages onto both Buckhurst Road, and Clifford Road. What would have been the front of The Sanctuary together with its tower, and the Buckhurst Rooms, face onto Buckhurst Road. The side of The Sanctuary that faces onto Clifford Road, is also attached to the Beulah Centre, which also has Clifford Hall on its opposite side. Buckhurst Road is a busy thoroughfare that connects, via Upper Sea Road, Bexhill Old Town with Buckhurst Place, which contains a large triangular shaped mainly grassed area, near to what from is now Bexhill’s town centre. 15. The land levels fall when travelling along Buckhurst Road towards the appeal site and Buckhurst Place.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision The Sanctuary, is clearly visible on this route, assisted by its partly diagonal alignment with Buckhurst Road. Its use of brick and sandstone detailing is also very similar to that on some of the other older buildings around Buckhurst Place; the Bank building; the Council Offices (said https://www.gov.uk/planning-inspectorate 3

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision The Sanctuary, is clearly visible on this route, assisted by its partly diagonal alignment with Buckhurst Road. Its use of brick and sandstone detailing is also very similar to that on some of the other older buildings around Buckhurst Place; the Bank building; the Council Offices (said 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/24/3342573 to be grade ii listed); and the ‘Warburtons’ building. These buildings, along with The Sanctuary, collectively provide some distinctive design elements, that help to create a local identity for this area and the approach into and around Buckhurst Place. The Sanctuary’s tower, which is notably lower than originally built without its spire (said to have been removed some 30-40 years ago) does positively add to the townscape quality, and its scale particularly against many other buildings nearby, assists with it being seen as a focal building, as a result its contribution to the townscape quality has a medium significance. 16. The broad form and appearance of The Sanctuary is reflective of its period of construction. Nevertheless, as the appellants rightly pointed out, it has been significantly altered since originally built, not least the additions of the Beulah Centre, and Buckhurst Room, the removal of the spire, internal changes including the removal of the organ, and the closing up of its front entrance onto Buckhurst Road. 17.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision The appellants have advised me that Historic England has issued an immunity from Listing for The Sanctuary, which is noted, although as the Council has indicated, the requirements for listing are quite different to the contribution a building can make as a NDHA. It is said that in assessing The Sanctuary, Historic England described it as being largely typical of many such buildings of the nineteenth century, and due to the alterations made it was of limited architectural interest and lacked cohesiveness. Based on my own observations, and the submissions from all parties, I am content that its architectural value is low due to the alterations that have been made to it, and with it being typical of many other such buildings of its time. 18. The appellants were clear at the event that the retention of The Sanctuary was investigated but found not to be feasible, and that it would require major alterations, nor did it meet their expectations of providing a much more environmentally friendly, open, and welcoming building. Whilst the Council disagreed and preferred its retention, there was no substantive evidence provided by the Council or any interested parties to fully justify why its retention is feasible.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision Moreover, neither Policies BX1 nor EN3 of the RLP require the appellants to justify why the buildings proposed for demolition could not be re-used in the first instance. 19. The Council stated that it assessed the significance of The Sanctuary against guidance said to have been prepared by English Heritage in 2008; stating it has a medium aesthetic value, high community value, a low evidential value, and a medium to high historic value. Although a copy of this guidance has not been provided, and its relevance in assessing the significance of NDHA’s is unclear. Consequently, little weight can be attached to it, and it has not led me to conclude differently to my findings above. 20. Bexhill Heritage (BH) did not persuade me that the Beulah Baptist Church has a high architectural significance. Whilst it may have been built in a neo gothic style as part of the De La Warr’s Estate, and it may have been the first tall building on this side of the railway line, much development has taken place since, including alterations to the building. Nor did I find that it makes any meaningful townscape contribution beyond that set out above regarding the approach to Buckhurst Place. 21.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision I conclude The Sanctuary has significance as a NDHA in terms of; its cultural value as a place of worship, which I regard to be of a medium to high https://www.gov.uk/planning-inspectorate 4

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision I conclude The Sanctuary has significance as a NDHA in terms of; its cultural value as a place of worship, which I regard to be of a medium to high 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/24/3342573 significance; its contribution as part of the townscape merit as a tall building in a distinctive style close to other similar such buildings on the approach to and around Buckhurst Place, which I regard to be of moderate significance; and its architectural significance as a relatively typical place of worship of its time, which due to the considerable alterations to it, I regard to be of low significance. As such, the loss of The Sanctuary would partly conflict with RLP Policy BX1, insofar as it seeks to conserve Bexhill’s distinctive character. 22. Therefore, for the reasons set out above, and taking into account the collective significance of the NDHA, providing a replacement place of worship of an appropriate design and scale, which positively contributes to the character of the area, as required by RLP Policies BX1 and EN3 is secured, alongside any other relevant considerations, consistent with paragraph 209 of the Framework, the loss of the NDHA could be justified in this case. Nonetheless, this position will be dependent upon the outcome of the next main issue. Character and appearance 23.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision The immediate area contains predominantly residential properties, in a variety of property styles, including gabled townhouses, semi-detached houses, and flats, some of which have flat roofs. The heights of the properties vary, including some two-storey properties, others are generally taller, many are buildings that contain flats that are three, four and five storeys high, which provides a degree of height to buildings in this immediate area. Despite their variety, the properties are generally setback from the pavement edge with landscaping or open areas between them and the pavement. The nearby properties are mostly clad in brick, with some also rendered, and there are some properties that feature sandstone detailing, whether in a paint finish or not. 24. It is acknowledged that the design of the new Church should not be a pastiche to a Victorian Church. The proposal is a modern and contemporary building, which the appellants said has replicated some of the distinctive elements of the Bank, and the Council Offices. It is clear that the appellants have carefully considered their approach to the Clifford Road elevation in light of the earlier appeal decision. 25.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision I was not persuaded by the argument from the appellants that the scale of The Sanctuary was only significant up to its existing eaves level. Its significant pitched roof above, which is clad in red tiles is a prominent feature that is seen above The Sanctuary’s side walls from both Clifford Road and Buckhurst Road, it helps to convey its status and prominence as a place of worship. Whilst the proposed new Church with its dome roof, set in from its outer sides and its attached flat roofed glazed link, would have a similar eaves height to The Sanctuary, its two-storey scale would be more reflective of the modest height of the attached Beulah Centre, contrasting harmfully against the much higher mainly pitched roof residential properties nearest to the appeal site. Although the appellants said that its flat roof design allows the incorporation of environmentally sensitive features and that the buildings have been kept low in response to comments from adjoining residents, these aspects do not fully justify its diminutive scale, that would change how the hierarchy of buildings at the appeal site would be seen. 26.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision It is accepted that its dome roof, proposed to be clad in a standing seam copper material, would replicate a similar roof style on the Bank, providing a https://www.gov.uk/planning-inspectorate 5

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision It is accepted that its dome roof, proposed to be clad in a standing seam copper material, would replicate a similar roof style on the Bank, providing a 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/24/3342573 distinctive feature that would be visible from both Clifford Road and Buckhurst Road, which may help to differentiate the building from others nearby. However, the proposed development’s lack of scale and prominence, exacerbated by its relatively linear form along Clifford Road, would hinder it being distinguished as a Church. 27. The incremental use of sandstone on the proposal, progressing from the Beulah Centre towards Buckhurst Road, could be said to be representative of the relative cultural importance of these parts of the buildings. Notwithstanding that the external alterations and use of sandstone to the Beulah Centre could be seen as a minor improvement, its appearance would not relate well to the front facing gable on Clifford Hall, or to the proposed contemporary aspects on its other side. Whether it has opaque glazing or not, the glazed link would appear stark set against the mainly brick clad properties nearby, particularly the modern Beulah Centre, introducing an alien element that would not satisfactorily assimilate with the different parts of the existing building or the contemporary appearance of the proposed Church. 28.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision The proposed Church includes large heavy and bulky sandstone lintels on its Clifford Road elevation. Although it would have some vertical emphasis in its design, including its proposed pillars and by its use of materials, its bold use of the sandstone detailing harmfully contrasts with the existing building and the area, where sandstone detailing is more ornate. It is noted the appellants argue that the different uses of the building are reflected in the different designs of the complex of buildings. However, they fail to successfully unify the existing building and the proposed newer parts, creating an illegible form of development, that due to its relatively low and continuous length along Clifford Road would still have a strong horizontal emphasis, that would outcompete the overly contrived new vertical elements. 29. The proposed porch has been reduced from what was previously proposed, and its proposed copper roof would also relate well to its main roof material.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision Notwithstanding the existing buttresses and whether its location would open-up this area, the proposal would bring the building much closer to Clifford Road, and collectively the development and the protrusions beyond the existing building line, would disturb the generally established setback of buildings and arrangement of spaces between buildings and the pavement edge in this area. 30. The previous appeal decision found the tower to be the most successful part of the previous proposal and did not object to the expansive glazing on the Buckhurst Road elevation, as it provides important views into the building to help create an open and inviting place. I see no reason to disagree with those findings. Although, the Council’s comments that the appearance of the tower could have been enhanced are agreed, perhaps being as tall, if not taller than the existing tower, and not as wide as proposed to increase its prominence. In addition, there could have been a greater use of red brick to emphasis the status of the building and make it more legible when travelling towards Buckhurst Place. 31. Overall, the scale of the building is somewhat underwhelming, particularly against the taller residential properties around it.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision Furthermore, its design approach, including the detail of its design and materials awkwardly relate to the Beulah Centre and Clifford Hall, creating a disjointed arrangement of https://www.gov.uk/planning-inspectorate 6

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision Furthermore, its design approach, including the detail of its design and materials awkwardly relate to the Beulah Centre and Clifford Hall, creating a disjointed arrangement of https://www.gov.uk/planning-inspectorate 6 Appeal Decision APP/U1430/W/24/3342573 attached buildings, which is not assisted by some parts of the proposals that are closer to Clifford Road than the existing building. 32. I therefore conclude that the proposed development due to its scale and design would be harmful to the character and appearance of the existing building and the area, contrary to RLP Policies EN3 and BX1, that amongst other things, require new development to be of a high quality of design that conserves and enhances the distinctive character of the area. In addition, the proposal would also conflict with paragraphs 135 and 139 of the Framework, insofar as they require new development to add to the overall quality of an area, be visually attractive, sympathetic to local character and history, including the surrounding built environment, and for development that is not well designed to be refused. 33.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision I also find the proposal due to its inappropriate scale and design to be inconsistent with the key objectives of Policies I1, I2, I3, and C1 of the National Design Guide, dated January 2021, that collectively seek to ensure well-designed development that responds to local character and built context, including through its form and legibility, and by creating a new and positive character to enhance its identity. Protected species 34. I saw on my site inspection that the buildings proposed for demolition have several openings, such as louvered vents, a tower structure, and a variety of roof forms and eaves detailing. Indeed, the PEA has identified numerous low- quality features, including exposed wooden rafters that can be suitable for bats. 35. The PEA states that the buildings proposed for demolition, together with the Beulah Centre, which is proposed to be altered, are identified as having a moderate suitability for bats and recommends further surveys (a minimum of two dusk bat emergence surveys) to establish if bats are present, which it is suggested could be a condition.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision However, given that the PEA did not initially assess the presence of bats at the appeal site, and given its conclusions about the buildings having a moderate suitability for bats, this ‘recommendation’ would not be a final check, but it would indeed be a survey of the buildings proposed to be demolished. 36. Paragraph 99 of Circular 06/2005 is clear that a precautionary approach should be taken in respect of protected species, and surveys should be undertaken prior to the grant of planning permission, to take full account of the presence of protected species, which are an important material planning consideration. 37. The appellants very recent statement in respect of bats2, advised that a dusk bat emergence survey of the appeal site was undertaken on 10 July 2024 and a further survey is planned for 20 August 2024. It further states that no evidence of bats was found during the first survey, and in the opinion of the ecologist it is unlikely that bats are to be found on the second survey. It is, however, said that if bats are identified or suspected on the second dusk emergence survey, a third such survey would be required.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision It is suggested that the additional emergence survey(s) could be required as a condition should the appeal be allowed, together with other precautionary actions to protect bats that may be 2 From Arborweald Environmental Planning Consultancy, dated 16 July 2024 https://www.gov.uk/planning-inspectorate 7

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision It is suggested that the additional emergence survey(s) could be required as a condition should the appeal be allowed, together with other precautionary actions to protect bats that may be 2 From Arborweald Environmental Planning Consultancy, dated 16 July 2024 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/24/3342573 using the appeal site. Although, no copy of the first bat survey has been provided. 38. I acknowledge there is no dispute between the main parties on this issue, and an agreed pre-commencement condition has been suggested to address the second survey, along with any further surveys and mitigation that may be necessary. However, mindful of the recommendation of the PEA for two dusk emergence bat surveys to establish the presence of bats, and the clear stated guidance within paragraph 99 of circular 06/2005, it is apparent that it has not been fully evidenced through surveys that bats are not using the appeal site. As such, and with this being an important material consideration, I am unable to make an informed decision about the effect of the proposal on protected species, including assessing whether any mitigation measures would adequately safeguard or compensate bats, and how they could affect the character and appearance of the building and the appeal site. 39.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision In addition, the agreed condition, requiring at least a further dusk emergence survey together with any mitigation, would not meet the tests for conditions as set out in paragraph 56 of the Framework in this case, as it would not be reasonable or precise. This is because the exact number of bat surveys required would not be known without the second survey being undertaken first, and any potential effects of bat mitigation, would also be unknown, which could potentially affect the external appearance of the proposals. 40. The PEA did not identify any other unacceptable effects upon protected species. Had I been minded to allow the appeal, the PEA’s recommended mitigations for breeding birds, along with measures to prevent bonfires at the appeal site, and address construction waste, could have been addressed by a suitably worded planning condition. 41. I therefore conclude that there is insufficient information to fully assess the effects of the proposed development upon protected species, notably bats, contrary to RLP Policy EN5 and Policy DEN4 of the Development and Site Allocations Local Plan, adopted December 2019 (DSA) which amongst other things, collectively seek to protect, conserve and enhance biodiversity.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision In addition, and for the same reasons the proposal would also be contrary to paragraphs 180 and 186 a) of the Framework, which states that development should contribute to and enhance the natural and local environment, and planning permission should be refused where significant harm to biodiversity cannot be avoided. Other Matters 42. The appellants Community Involvement Statement sets out the range of the community work and uses at the appeal site. In addition, at the event the appellants also outlined the extensive community benefits of the existing operations at the appeal site, and how the proposed development would increase their capability to significantly expand them and provide a modern purposefully built Church. It was also clear that the appeal site is more than a place of worship, and that it reaches into the community as an enabler for local services, and along with its partner organisations provides important local services. I was also made aware of some of their community work, including with Ukrainian migrants, mental health, and the important services they provide to vulnerable members of the community. 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/24/3342573 43. In addition, I have had regard to a large number of representations received from interested parties, expressing their support for the proposed development in addition to the above points, which are by no means exhaustive, and include the following: that the proposal would provide a sustainable building for future generations with improved accessibility; the poor condition of The Sanctuary; and the economic, social and environmental benefits associated with its re-development. An interested party has also made me aware that the proposed re-development of The Sanctuary will provide enhanced access and usability for persons with a range of disabilities. 44. The benefits of the proposal are not disputed by the Council, which it is said were considered when it determined the planning application. Although, I am not aware that The Sanctuary or the Buckhurst Room is under threat from closure because of their current condition, or that any planned community uses are proposed to cease because of it. Furthermore, many of the community uses are said to take place within the Clifford Room and Beulah Centre, which are to be wholly retained.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision Therefore, the weight I can give to the stated benefits collectively, over and above those that take place already and do not appear under threat, is somewhat tapered and largely limited to the enhanced provision of community uses. I regard these to constitute moderate weight in favour of the proposal. 45. The appellants have provided details of the proposed environmentally sustainable design aspects of the proposal, which is also set out within their supporting statement. Although, it was clear at the event that the appellants are not proposing to construct the proposed development to specific recognised environmental standard. As such, their actual effectiveness and the overall sustainability of the proposed development would not be certain or measured to a recognised benchmark. Nevertheless, these environmentally sustainable features would to a limited extent weigh in favour of the proposal. 46. It is noted that a Prior Approval has been allowed3 for the demolition of the entire complex of buildings at the appeal site, including the Beulah Centre and Clifford Hall.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision However, there is no evidence that this is likely to occur, particularly because; it has been said that there has been a recent £400,000 refurbishment of the Beulah Centre; the important community uses collectively taking place within the buildings at the appeal site; and given the numbers of worshippers said to be attending Church services. Whilst this prospect of complete demolition cannot be discounted, it appears unlikely to occur based on the information presented within written submissions and at the event. Moreover, this application specifically seeks to retain the Beulah Centre and Clifford Hall. I therefore attach limited weight to this as a realistic fall-back position. 47. I have also had regard to objections received from residents and others, expressing concerns in addition to the main issues above, relating to parking and highway safety, including during construction works. However, I note that these matters were considered where relevant by the Council when it determined the planning application. Whilst I can understand the concerns of the interested parties, there is no compelling evidence before me that would lead me to come to a different conclusion to the Council on these matters. 3 Ref.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision RR/2020/1428/DN https://www.gov.uk/planning-inspectorate 9

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision RR/2020/1428/DN https://www.gov.uk/planning-inspectorate 9 Appeal Decision APP/U1430/W/24/3342573 48. The appellants referred to the planning history associated with the appeal site, including the 4 no. requests for pre-application advice (with no response said to have been received to the last request). Whilst I can appreciate the appellants comments regarding how they have sought to engage with the Council, I do note that no pre-application advice was sought following the dismissal of the previous appeal4 and before their submission of this proposal. I have had due regard to the planning history of the appeal site insofar as it is relevant to the appeal proposal, however it has not altered my findings as set out above. 49. The prospect of re-purposing The Sanctuary has been raised by some parties. The appellants advised that it would not be a viable proposition, although the Council is of the view that they have not seen any evidence of the feasibility of its re-purposing.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision Whether this was discussed as part of the earlier pre- application enquiries as the appellants say or not, the Council have not specifically raised the viability of the conversion of the existing building within the SoCG, nor has it sought to provide any substantive evidence to dispute what the appellants have said. Based on the evidence before me, I have no reason to disagree with the appellants view regarding its re-use being unviable. 50. The issue of the sustainability of building materials has been raised. I note that this was not part of the matters in dispute between the parties as set out within the SoCG. Based on the information before me, I also found no such conflict with the policies of the development plan that are most relevant to the appeal proposal. 51. BH made me aware that they are currently surveying the area around the appeal site, to try and justify it being part of a designated Conservation Area. Be that as it may, the site as it stands is not within a Conservation Area, and I have no certainty that such work would find a designation of the area justified. Planning Balance and Conclusion 52.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision The community benefits associated with the proposed development, as set out above, provide clear public benefits, of which I attribute moderate weight, particularly given that some of them are already undertaken from the Beulah Centre and Clifford Hall, and there appears to be no threat to them continuing in the event the appeal was to be dismissed. There would also be some economic benefits associated with the construction of the scheme, although these would be temporary and are likely to be limited. 53. In addition, there would also be environmental benefits through its use of environmentally sustainable design features, however, it was said the proposal would not be built to any recognised sustainable building standard, and it is uncertain based on the information provided how effective these would be, as such this aspect attracts limited weight in favour of the proposal. It is also acknowledged that the entire complex of buildings at the appeal site could be demolished, however this appears very unlikely to occur based on the appellants evidence, although this possibility does to a small extent weigh in favour of the proposal.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision I recognise that no other harm has been found other than that outlined in the main issues above, although this is a neutral factor that neither weighs in favour or against the proposal. 4 Appeal Ref: APP/U1430/W/21/3284583 https://www.gov.uk/planning-inspectorate 10

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — Appeal Decision I recognise that no other harm has been found other than that outlined in the main issues above, although this is a neutral factor that neither weighs in favour or against the proposal. 4 Appeal Ref: APP/U1430/W/21/3284583 https://www.gov.uk/planning-inspectorate 10 Appeal Decision APP/U1430/W/24/3342573 54. Whilst I have found that the loss of The Sanctuary as a NHDA could be acceptable subject to the acceptability of its replacement, the proposed development does not positively contribute to the character and appearance of the existing complex of buildings and the surrounding area. I have also identified harm to protected species. Accordingly, there is conflict with the development plan when taken as a whole, and there are no other material considerations, including those outlined above, that indicate the appeal should be determined otherwise. The scheme also fails to accord with the requirements of the Framework. 55. For the reasons given above, I conclude that the appeal should be dismissed.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — A Hunter INSPECTOR https://www.gov.uk/planning-inspectorate 11

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — A Hunter INSPECTOR https://www.gov.uk/planning-inspectorate 11 Appeal Decision APP/U1430/W/24/3342573 APPEARANCES FOR THE APPELLANTS: Philip Winch RIBA MCI Arb CPL Architects – Managing Director Paul Burgess MRTPI Lewis & Co Planning Consultants Reverend David Lockwood Minister – Beulah Baptist Church FOR THE LOCAL PLANNING AUTHORITY: Rossella De Tommaso BA(Hons) MSc RDC - Senior Planning Officer Simon Richards PG Dip Bldg Cons IHBC RDC - Conservation Officer Matthew Worsley RDC - Major Applications Team Leader David Chambers BSc(Hons) MA RCA PGCert ARB RIBA, RDC - Design Team Leader Deborah Gardner PG Dip (Bldg Cons) IHBC Heritage Consultant INTERESTED PARTIES: Cllr Christine Bayliss RDC - Central Ward Cllr Andrew Crotty RDC - Bexhill Central Ward Viv Taylor-Gee Bexhill Hub - Coordinator Steve Johnson Bexhill Heritage - Chairman DOCUMENTS SUBMITTED AT THE HEARING Letter supporting the proposal, dated 23rd July 2024, from Mrs A Hammill, Head Teacher, St Peter & St Paul Church of England (VA) Primary School. DOCUMENTS SUBMITTED AFTER THE HEARING Copy of Appendix 4 referred to within Policy EN3 of the Rother Local Plan, Core Strategy, adopted September 2014, provided by email on 26/7/2024.

Beulah Baptist Church, Clifford Road, BEXHILL-ON-SEA, TN40 1QA — Rother District Council — A Hunter Copy of the main parties agreed wording for suggested condition 11 (bats) and additional condition 12 (ecological enhancements), provided by email on 26/7/2024. https://www.gov.uk/planning-inspectorate 12