APPLICATION NO

	APPLICATION NO.	P19/V3211/FUL & P19/V3212/LB
	SITE	Austin House, 76 Bath Street, Abingdon, OX14 1EB
	PARISH	ABINGDON
	PROPOSAL	Demolition of a modern flat roof extension to Austin House, the remodelling of Austin House, a new building to provide boarding accommodation and a link corridor to link the new building to Austin House. (as amplified and amended by plans and documents received 10 September 2020; 6 November 2020 and 09 February 2021).
	WARD MEMBER(S)	Eric de la Harpe Robert Maddison
	APPLICANT	Mr Justin Hodges
	OFFICER	Luke Veillet

	RECOMMENDATION
	That, planning permission and Listed Building Consent is granted, subject to the following conditions;
	Planning Permission (P19V3211/FUL) Standard conditions 1. Full Planning Permission – three-year commencement 2. Development in accordance with the approved plans Pre-commencement conditions 3. Tree Protection (submission of final AMS and details) 4. Construction Traffic Management Plan 5. Schedule of Materials (Photographs) 6. Archaeology (WSI) Pre-occupation conditions 7. Submitted Landscaping implementation 8. Submitted Drainage implementation 9. Sustainable Design Features - as approved Compliance conditions 10. Submitted Ecology mitigation 11. Piling Method Statement submission – if necessary 12. Submitted External Lighting - no further lighting with LPA approval
	Listed Building Consent (P19/V3212/LB) Standard conditions 1. Commencement three-year commencement 2. Approved plans Prior works/relevant works 3. Schedule of Materials 4. Details of glazed bridge

1.0	INTRODUCTION AND PROPOSAL
1.1	Introduction This application, as a ‘major’ scale development, has been referred to the planning committee as your officers’ views conflict with those of the Town Council.
1.2	The application site comprises a large residential property and its curtilage (Austin House), which incidentally forms part of the surrounding wider Abingdon School site. Abingdon School is a well-established independent day and boarding school for boys aged 11-18, also with a Prep School for boys aged 4-13.
1.3	Austin House (previously known as Waste Court) is a Grade II Listed Building (listing entry 1368292), as are the Wall and Gate Piers to Waste Court (1284079), located to the south of the main building. Austin House is an existing boarding house which accommodates the Housemaster and his family and 29 boarding pupils. The site is located within the Albert Park Conservation Area (CA) and Albert Park, which is a Grade II Registered Park and Garden (RPG), is located some 250m to the west. There are two listed buildings in Albert Park itself (Grade II Monument to Prince Albert and Grade II Conduit House) and numerous others within the wider area. Several listed buildings are located along Bath Street, with the closest being 61 Bath Street, some 60m to the south-east of the site. The site is also in a wider area of archaeological interest, being located within Abingdon Towns core (reference DOX16321M). A map of the site and constraints is shown in figure 1 below. Figure 1. Location and constraints map Key 1. Austin House (Application site) 2. Grade II Wall and Gate Piers to Waste Court 3. Crescent House (School Boarding accommodation) 4. Cobban House (School Boarding accommodation) 5. Glyndowr House (School Boarding accommodation) 6. Grade II Albert Park (Registered Park and Garden) 7. Grade II Listed Monument to Prince Albert 8. Grade II Conduit House 9. Grade II 61 Bath Street 10. Roysses’ Alley (PRoW) 11. School House (School Boarding accommodation)
1.4	Proposal Abingdon senior school currently has just over 1,000 boys from age 11-18, of which around 140 are boarders (comprising 110 full boarders and 30 weekly boarders). This total number of boarders has remained static in recent years and represents the capacity. Boarders are housed in three boarding houses: School House (53 boarders), Crescent House (56), and Austin House (29). Crescent House consists of three separate buildings - Glyndowr, Cobban House, and Crescent House. Each boarding house also provides pastoral care for a number of dayboys such that the total number of boys (day + boarding) in each boarding house is c.100. There are 6 other purely dayboy houses in the school plus a Lower School division for the first and second years. The mixing of dayboys and boarders helps aid integration of boarders into school life more generally and vice versa.
1.5	Abingdon School has been subject to expansion of their facilities in recent years. Most notable are the large three-storey ‘Yang Science Building’ which is located directly behind Crescent House to the north and the three-storey Beech Court Sixth Form Centre located to the south-west of Austin House.
1.6	The proposed development follows on from several pre-application enquiries starting 2017, which have sought to explore the potential to extend the existing boarding accommodation. Initially focussed on extending all the buildings at Crescent House, the latest enquiry in 2019 (P19/V1099/PEM) sought to resolve previous concerns in extending all three Villas around Park Crescent, by using Austin House. This application was supported by an updated site wide ‘Masterplan’, which detailed future development of the school, as well as articulating the rationale for selecting Crescent House and Austin House as most appropriate to extend. The 2019 Masterplan is attached at Appendix 1.
1.7	Therefore, this specific application seeks both Planning Permission and Listed Building Consent to demolish the existing two-storey flat roof rear extension of Austin House and erect a three-storey linked extension in its place. The actual works to the listed building comparably, are fairly minor, constituting some internal alterations/remodelling of a small number of rooms to provide en-suites and the walkway connections to the new extension at first/ground floor level. Extracts of the key proposed plans are attached at Appendix 2.
1.8	The scheme has been amended since its original submission, in response to officer concerns. The main differences are that the extension has been shifted further south to mitigate views from Bath Street, avoid the Root Protection Area (RPA) of T6 (Lebanon Cedar) and detailing has been added to the eastern elevation of the extension to avoid blank gable.
1.9	Finally, it important to note that this application has been submitted in conjunction with applications to extend Crescent House (P19/V3213/FUL) which also seeks a three-storey extension to consolidate boarding accommodation on the western part of the school site. Whilst this is a separate application under consideration (thus considered on its own merits), it is part of the wider masterplan to upgrade the schools boarding facilities. Neither applications are seeking an increase in the number of pupils attending or boarding at the site but seek to consolidate existing accommodation which are scattered amongst different buildings. The schemes propose not to materially change the number of boarders from the current 140, but to even out the number of boarders in each of the three main houses to around an optimum level of 50 beds per house. This will enable the future proofing of the school’s accommodation, better management and improve pupil cohesion. It will also free up existing buildings for other school activities. The applicant’s rationale for the accommodation is attached at Appendix 3.

2.0

SUMMARY OF CONSULTATIONS & REPRESENTATIONS

2.1

Full comments are available on the application pages on the council’s website, www.whitehorsedc.gov.uk. A summary of comments submitted, and main issues highlighted are shown below;

1. P19/V3211/FUL – Planning Application

Abingdon Town Council	First Consultation Objection · Harm to the Albert Park Conservation Area · Out of keeping and cause substantial harm · Public benefits do not outweigh the harm · The Council considers that the proposals represent an overdevelopment of the site in terms of size, scale, bulk and massing. Amended Scheme Objection · Concurred with Historic England’s comments sent to the District Council, particularly that the current scheme would still entail a degree of less than substantial harm to the setting of the listed building and the character and appearance of Albert Park conservation area.
Countryside Officer	First Consultation No objection, subject to condition · The site has been subject to ecological surveys and the proposed works are not considered likely to impact any roosting bats. · Trees with bat roosting potential are being retained in the development. · Development will involve the loss of amenity grassland and garden planting, but compensatory planting will be provided in the landscaping of the site. · As such, subject to the addition of the following condition, I am satisfied that there would be no significant ecological impacts if planning permission were to be granted Amended Scheme No objection, previous comments stand
Drainage Engineer	First Consultation No objection · Satisfied with drainage detail, no conditions required.
Environmental Protection Team	First Consultation Comments · Acoustic measures to be implemented · Construction working hours secured Amended Scheme No further comments
Oxfordshire County Council Single Response	First consultation and amended scheme Highways No objection, subject to condition for CMP · No overall increase in pupils, so no highway impact · The nature of boarding pupils is that they walk to school from the boarding accommodation and, therefore, a reduction in vehicular trip generation potential may result from the proposals or no net increase is likely, in any case · CMP required for construction Local Lead Flood Authority No comments Archaeologist No objections, subject to conditions An archaeological evaluation has revealed the presence of medieval features in the form of ditches and pits containing domestic material · Conditions to secure WSI/staged investigation/recording and reporting of any finds.
Thames Water Development Control	First consultation No objection, subject to condition · There is capacity of the scheme in relation to the local water and drainage infrastructure. · However, being close to a strategic sewer, a condition is required to secure a piling method statement to avoid damage to important sub surface water/drainage infrastructure. Piling has the potential to significantly impact / cause failure of local underground sewerage utility Infrastructure.
Urban Design Officer	First Consultation Holding objection · The location of the proposed development is not a concern from an urban design perspective despite the proximity of the Grade II listed building ‘Austin House’, and the context of the Albert Park Conservation Area · The overall approach is acceptable from an architectural perspective, the links themselves work to minimise the impact on the overall envelope and fabric of the listed building · Potential issues of shading to the south · Needs to move away from T6 Amended scheme Holding objection · Beyond the potential issue around light available for rooms where the relationship between the Austin House and the new boarding school is close. Previous key issues discussed regarding the impact on T6 tree location, have been resolved from an urban design perspective. · The building itself maintains robust design principles with an applicable but contemporary vernacular with materials and detailing sympathetic to Austin House and is consistent with associated development across the wider site.
Waste Management Officer	First Consultation No comments Amended scheme No comments
Tree Officer	First consultation Holding objection; · The proposed development will require the removal of several trees shown as T1, T2, T3, T5, T7, T9, T10 and T11 and a hedge shown as H1. I have no objections to the removal of these trees and hedge as they are of low arboricultural quality and should not be considered a constraint to the proposed development. · Conflict with T6 and retaining wall · Numerous landscaping conflicts · Services plans required Amended scheme No objection, subject to conditions · Conflicts and services plans resolved, but AMS has not assessed issues around services connections to the substation. Tree protection and AMS condition required.
The Garden Trust	First consultation Comments · We agree with your pre-application advice that the School have taken care to work sensitively in relation to the impact of this proposal upon designated heritage assets. The new building and link corridor are further from the Grade II listed registered Albert Park (RPG) than the Crescent House application (P19/V3213/FUL) and the trees along the frontage of the application site should obscure views from within the RPG and the setting of the buildings in Park Crescent. · We are confident that should your officers approve this application, they are sufficiently aware of the sensitivities of the RPG and conservation area to ensure that if any additional arboricultural conditions are required to provide necessary long-term screening, these will be imposed
Chief Fire Officer	First consultation *No response received*
Abingdon Civic Society	See comments below on listed building application
Historic England	See comments below on listed building application
Local resident and Neighbour comments (1)	First consultation Comments · Will not enhance or preserve the listed building or conservation area, due scale and location Amended scheme Comments · I object. I believe the proposals will cause heritage harm outweighing any 'public benefits arising' and the character and appearance of the Albert Park Conservation area will not be enhanced · It is the building which has the Grade II Listing and not the School, which has ownership since 1928 · Erode views to and from Crescent House · The size, scale and character of these buildings feature significantly in views from the public realm within the Albert Park Conservation Area

2. P19/V3212/LB – Listed Building Consent

Abingdon Town Council

First consultation

Objection

· Harm to the Albert Park Conservation Area

· Out of keeping and cause substantial harm

· Public benefits do not outweigh the harm

· The Council considers that the proposals represent an overdevelopment of the site in terms of size, scale, bulk and massing

Amended scheme

Objection

· Recommend refusal. Notwithstanding the amended proposal, the Committee still expressed concerns regarding this application and concurred with Historic England s comments sent to the District Council, particularly that the current scheme would still entail a degree of less than substantial harm to the setting of the listed building and the character and appearance of Albert Park conservation area.

Conservation Officer

First consultation

Holding objection

· Holding objection to this application subject to further detail and amended plans.

· There is insufficient detail about the direct impact to the listed building to make a recommendation on the acceptability of the proposals to the historic fabric.

· The supporting documentation has failed to appropriately assess the direct impact to historic fabric. It states that the new building is entirely separate from the listed building which is not correct as the proposed link requires the removal of an original timber sash window and the installation of acoustic, thermal and fire proof partitions through the ground and first floors to separate the housemaster’s accommodation from the student bedrooms.

· From the south, the new building will sit alongside an area where large new sports facilities have been built and in this context the advice was that the massing of the new boarding house would be fairly discreet

· Valid concerns have been raised by Historic England on the impact of the proposal on the significance of the listed building and by the Civic Society on the impact to the conservation area

· Having visited the site it is clear that the proposed new boarding house sits in the context of a number of new large structures and the existing house which is itself one of the larger domestic properties in the Conservation Area. As such, I believe there is scope to accommodate a large structure here

Amended scheme

Comments

· Amended plans have been submitted which have moved the proposed extension to the south slightly, reducing the closing effect on the gap between Austin House and the former Coach House when perceived from Bath Street

· A new window has also been proposed to provide some activity to the elevations that are visible in the Bath Street street-scene. Overall, this improves the impact on the conservation area from the previous proposals

· Further assessment of the main listed building changes has been submitted and I am satisfied that the proposed alterations do not erode the special interest of the listed building

· Harm to setting of the Listed building – less than substantial

Historic England

First consultation

Comments

· The application site is within the Albert Park Conservation Area. Austin House, a grade II listed building sits on the eastern boundary of the site. The proposal is for the demolition of a late 20th century extension to Austin House and for the erection of a 3- storey linked extension on a much larger footprint.

· This will impact on the setting of the listed building and obscure some key views into the conservation area.

· The contribution of the site to the character and appearance of the conservation area and its setting has not been fully assessed, nor has the impact on views into the conservation area been taken into account.

· Whilst Historic England has no objection to the demolition proposed, we are concerned that it has not been demonstrated how the proposed new building will preserve the setting of the listed building nor preserve or enhance the character or appearance of the conservation area

Amended scheme

Comments

Setting of the listed building

· In previous advice we expressed concerns about the adverse contextual impact that

the considerable footprint and scale of the proposed addition would have on the

listed building, notwithstanding its articulated design in three stepped elements.

· The intended structure, in close proximity to Austin House to which it would be linked by a

glazed bridge, would result in erosion of its surviving garden setting and associated

domestic character.

· The current scheme has not altered footprint, massing and scale of the previous proposals and, therefore, our concerns remain

· Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use

Impact on the Character and Appearance of the Albert Park Conservation Area

· In recognition of the contribution that the site gives to the character and appearance of the conservation area, especially as seen from Bath Street, current proposals have been amended to mitigate the impact on its significance

· Changes from the previously submitted scheme see the re-siting of the proposed extension southwards by 1,5 metres in order to reduce its visibility from the main thoroughfare. In addition, an elongated window introduced to the east elevation, and a brickwork more closely relating to that of Austin House’s return elevation are

proposed to soften the impact and produce some visual interest.

· The shift in the location of the new structure has limited the potential impacts on the retained trees, by increasing separation between the cedar and the proposed development, and by reducing the amount of new hardstanding within the garden through a new landscaping scheme.

· Cumulatively, these amendments have reduced the level of adverse impact of the proposals on the significance of the conservation area.

Friends of Abingdon Civic Society

First Consultation

Objection

The recommendation from Historic England is clear and substantial, and contains several reasons why the application should be refused as it stands unless and until it is substantially amended.
Pre-application advice is flawed as it does not mention correct legislation
Officer at pre-application should not consider this scheme as their approach is wrong.

Amended scheme

Objection

We do not consider that the points raised in our earlier objection with respect to preserving, and preferably enhancing, the character and appearance of the Albert Park Conservation Area and the character and special interest of the listed building have been sufficiently addressed in this amended application.
Draft conservation area appraisal should be taken into account in the consideration of this application.

Local resident and Neighbour comments (1)

First consultation

Comments

· Will not enhance or preserve the listed building or conservation area, due scale and location

Amended scheme

Comments

· I object. I believe the proposals will cause heritage harm outweighing any 'public benefits arising' and the character and appearance of the Albert Park Conservation area will not be enhanced

· It is the building which has the Grade II Listing and not the School, which has ownership since 1928

· Erode views to and from Crescent House

· The size, scale and character of these buildings feature significantly in views from the public realm within the Albert Park Conservation Area

3.0	RELEVANT PLANNING HISTORY
3.1	P19/V3213/FUL - (not yet determined) Demolition of modern side and rear extensions, the remodelling of Crescent House, a new building to provide boarding accommodation and a link corridor to link the new building to Crescent House. P18/V2481/FUL – Approved (10/01/2019) Erection of a three-storey education building to accommodate a lodge, house rooms, computer science and economic teaching space P18/V0902/FUL – Approved (29/05/2018) Removal of existing gates from the grade II listed piers and wall at Waste Court, Abingdon School, erection of black metal railings set further back. P18/V0903/LB – Approved (29/05/2018) Removal of existing gates from the grade II listed piers and wall at Waste Court, Abingdon School, erection of black metal railings set further back. P16/V2529/FUL – Approved (03/01/2017) Demolition of existing building and erection of a new three storey building to accommodate a sixth form centre, centre for independent learning and art department and external storage building. Minor changes to cafe and new pedestrian access to Roysee's Alley to the north. P16/V1480/DIS - Approved (05/07/2016) Replacement of grass tennis courts, laying artificial multi-use sports pitch (MUSA), with associated fencing and access. P16/V0741/FUL Conditions(s) 4 - Arboricultural Method Statement. P16/V0741/FUL - Approved (12/05/2016) Replacement of grass tennis courts, laying of a new artificial multi-use sports pitch (MUSA), with associated fencing and access. P12/V2374/CA - Approved (24/01/2013) Demolition of existing school building (Medical Centre). P12/V2373/FUL - Approved (24/01/2013) Demolition of existing school building (Medical Centre). Erection of a three storey Science Centre and the reconfiguration of the existing coach park, including alterations to the points of ingress and egress. P05/V0490/LB - Approved (07/06/2005) Proposed internal modifications and revisions to existing windows. P94/V0775/LB - Approved (03/10/1994) Extension rendering to south elevation and part of east and north elevation. P93/V0756/LB - Approved (15/07/1993) Provision of a covered link between Wate Court & Waste Court Annexe. P93/V0755 - Approved (15/07/1993) Provision of a covered link between Waste Court and Waste Court Annexe. P88/V0972 - Approved (18/05/1988) Formation of a first floor escape door and provision of an external iron staircase. P83/V0661/LB - Approved (26/09/1983) Change of use and alterations from storage to form additional boarding accommodation.
3.2	Pre-application History P19/V1099/PEM - (18/06/2019) Erection of boarding house accommodation.
3.3	Screening Opinion requests None

4.0

ENVIRONMENTAL IMPACT ASSESSMENT

4.1

Screening is not required, and the development does not constitute EIA development. It does not involve development over the thresholds for urban development projects under Schedule 2, 10 (b). The site is not

in a ‘sensitive area’ defined by the Town and Country Planning Environmental Impact Assessment Regulations 2017.

5.0	MAIN ISSUES
5.1	The main issues to consider in context of these scheme are discussed in section five below; · The principle of development · Layout, Design and Impact on Heritage Assets · Residential amenity · Traffic, parking and highway safety · Environmental matters · Impact on the special architectural or historic interest of the listed building · Other matters
5.2	The principle of development
5.3	Section 70 (2) of the Town and Country Planning Act 1990 provides that the local planning authority shall have regard to the provisions of the Development Plan, so far as material to the application, and to any other material considerations. Section 38 (6) of the Planning and Compulsory Purchase Act 2004 requires where regard is to be had to the Development Plan, applications for planning permission must be determined in accordance with the Plan unless material considerations indicate otherwise. In this case, the most relevant parts of the Development Plan are the adopted Local Plan 2031 Part 1 (LPP1) and Part 2 (LPP2).
5.4	LPP1 policy CP01 broadly reflects the presumption in favour of sustainable development set out in the NPPF. Policy CP03 then sets out a settlement hierarchy, which is one of the policies which underpins the districts overarching spatial strategy for development. This policy defines Abingdon-on-Thames as one of the Market Towns, which given its size and services, has the ability to support the most sustainable patterns of living. It notes the Market Towns have the greatest long-term potential for development. Abingdon School is firmly located within the built-up area of the Town.
5.5	The development plan does not have any specific policies which guide development on its established school sites in the built-up areas of the Towns. However, LPP2 policy DP8 does recognise schools to constitute community facilities, which play a key role in creating and sustaining healthy and inclusive communities. Policy DP8 notes that extending community facilities will be supported in the built-up areas of settlements. The fact Abingdon School is an independent school, in your officer’s view, does not exclude it from being a community facility. It is still a school which serves the local community and beyond, both for education and use of its sports and leisure facilities to the wider public. Indeed, appeal decisions have confirmed that private facilities can be considered as community facilities (such as an Osteopathic Clinic, for example - appeal ref: APP/D1780/C/19/3222884).
5.6	It is also noted that Paragraph 20 (c) of the NPPF recognises education facilities to constitute ‘community facilities’. Paragraph 94 then recognises the importance of having , ‘a sufficient choice of school places is available to meet the needs of existing and new communities’ and at 94 (a), it notes that Local Authorities should give, ‘great weight to the need to create, expand or alter schools through the preparation of plans and decisions on applications’.
5.7	Therefore, having regard to the development plan and above policy context, your officers consider that the principle of extending the school facilities in the manner proposed is acceptable, supported by LPP1 policy CP03, LPP2 policy DP8 and national guidance. This would of course be subject to consideration of the detailed issues and other material considerations examined below.
5.8	Layout, Design and Impact on Heritage Assets
5.9	It is evident that the layout, scale and design of the scheme in context of the various impacts on the historic environment, is one of the main issues raised. As identified, the site is constrained by several designated heritage assets. It is located within the Albert Park Conservation Area (CA) and wider setting of Grade II Albert Registered Park and Garden (RPG). There are also numerous listed buildings amongst the wider setting of the site. The site is also located in an area of archaeological interest, considered to be a non-designated heritage assets.
5.10	In context of these constraints, there are two main sub-issues to consider. These are the impact on the character and appearance of the CA, the impact on the setting of listed buildings and RPG and impact on the area of archaeological interest. The impact on the special architectural or historic interest of the listed building itself, will be considered under sperate section.
5.11	Impact on the character and appearance of the Conservation Area LPP1 policy CP37 requires that all new development is of a high-quality design and responds positively to the character of the area. The design should also conserve and enhances historic character and reinforce local identity. Policy CP39 seeks to ensure new development conserves, and where possible enhances, designated heritage assets and non-designated heritage assets and their setting in accordance with national guidance and legislation. LPP2 policy DP36 then sets out the general approach in assessing the impact on heritage assets, broadly reflecting the policy guidance in the NPPF.
5.12	LPP2 Policy DP37 specifically address’s conservation areas. Proposals for development within or affecting the setting of a conservation area must demonstrate that it will conserve or enhance its special interest, character, setting and appearance. It also sets out several criteria for consideration. These include ensuring development takes into account important views, sympathetic to building curtilages, open spaces and respect local distinctiveness through its design. This policy sits alongside the duties set out in the Planning (Listed Building and Conservation Areas) Act 1990. Section 72 details that the Local Authority has a duty to pay special attention to the desirability of preserving or enhancing the character of appearance of that area.
5.13	Turning to the National policy guidance set out in the NPPF, Paragraph 190 of the details that the LPA should identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset) taking account of the available evidence and any necessary expertise.
5.14	Paragraph 193 of the NPPF details that when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. ‘Significance’ is defined in the NPPF as, ‘The value of a heritage asset to this and future generations because of its heritage interest. The interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting’.
5.15	Paragraph 194 details that any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification.
5.16	Paragraph 196 requires where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal.
5.17	Paragraph 197 notes that 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.
5.18	Paragraph 200 details LPA’s should look for opportunities for new development within Conservation Areas and within the setting of heritage assets, to enhance or better reveal their significance.
5.19	Paragraph 201 details that not all elements of a Conservation Area or World Heritage Site will necessarily contribute to its significance. Loss of a building (or other element) which makes a positive contribution to the significance of the Conservation Area or World Heritage Site should be treated either as substantial harm under paragraph 195 or less than substantial harm under paragraph 196, as appropriate, taking into account the relative significance of the element affected and its contribution to the significance of the Conservation Area or World Heritage Site as a whole.
5.20	In this case, there is no formal CA appraisal for Albert Park. It is acknowledged that local parties, on behalf of the Town Council, are currently producing one. It is the Districts Council’s responsibility to review CA’s and produce appraisals where necessary and is subject to a formal process (review, public consultation etc). This can involve community collaboration and input, but at this time, it is understood this has not commenced. As such, limited weight is attached to this appraisal at this time. Notwithstanding, the draft document circulated on the internet highlights the importance of Albert Park, its formal layout, the areas general symmetrical plan form and Victorian architecture. The appraisal also seems to put the application site within the sub school-character area.
5.21	The pre-application submission contained a supporting Conservation Appraisal, which sought to identify the important assets within they area, the area’s history and significance, but mainly focussed on the school site. It identified the school as a distinct ‘zone’ within the conservation area, with ‘sub-zones’ of varying significance. The appraisal identifies the application site has having a ‘high’ level of significance’ (area ‘4’ Figure 2 below). Figure 2. Conservation Appraisal 2019 - Asset Heritage Consulting
5.22	The application is then supported by a specific Heritage Impact Assessment (HIA), which assesses the significance of the relevant assets. It notes the contribution the listed building (Austin House) makes to the significance of the CA and the CA’s character and appearance, as a substantial and sizeable building prominently located in the conservation area street scene. The elevations to Bath Street are mainly of stone, with a prominent two-storey roughcast canted bay, while the south (entrance) elevation is constructed of Georgian red brick and is visible over the roadside boundary wall. The appraisal highlights these as the most important elevations. It notes the impact from Bath Street between buildings (which is outside the CA) is not a ‘key’ or ‘important’ view, but does note there would be obvious views of the building from within the school site/CA, from Waste Court Field (number 12 in figure 2.) The HIA sees these views as less impactful, as the west elevation has less historic interest.
5.23	In terms of the development proposed in the application, there is no doubt that it is a very large extension to the building. However, there is certainly merit in removing the existing attached two-storey wing. As noted by Historic England, the amended scheme has also certainly improved upon the original. Whilst the amendments may seem minor overall, your officers are of the view that the 1.5m shift of the building south is a significant improvement in how the this part of the CA would be experience and perceived, particularly from the public realm outside the CA in Bath Street. This building shift will ensure that inter-visibility and views from Bath Street and the trees within the CA are retained, ensuring the sense of space between buildings and spatial separation is preserved. The improved detailing on this eastern facing elevation will also ensure a high-quality design which, in your officers’ view, will be read as part of the wider school site (figure 3 below). Views of the building will only be glimpsed from other public areas (such as the PRoW), thus will cause limited harm. As noted by Historic England, cumulatively, these amendments have reduced the level of adverse impact of the proposals on the significance of the CA. However as pointed out in the HIA, the scale of the scheme is undeniable. In your officer’s view, given the new building’s scale and presence, this will alter to some extent the pattern of development of this domestic character plot, within the CA. Therefore, you officers consider there will be ‘less than substantial harm’ to the significance of this designated asset. Whilst your officers are of the view the harm is “less than substantial” when viewed as a whole, and at the lower end of this category, it is clear that harm will be caused. As such, the designated asset will not be preserved or enhanced, contrary to policy DP37 and the NPPF advises that great weight must be given to this harm, even though it is considered ‘less than substantial’. The NPPF makes it clear this harm is required to be weighed in the planning balance, against any public benefits arising from the scheme. I will turn to this matter later. Figure 3. Photomontage from bath street (applicant)
5.24	The impact on the setting of listed buildings and RPG In addition to the relevant policies already described, LPP2 policy DP38 notes specifically in relation to Listed Buildings, that proposals for additions or alterations to a Listed Building and for development within their setting, will need demonstrate that they will preserve or enhance its special architectural or historic interest and significance. Proposals directly affecting a Listed Building must demonstrate that they will be sympathetic to the Listed Building and its setting in terms of its siting, size, scale, height, alignment, materials and finishes design, form and character. This policy sits alongside the duties set out in the Planning (Listed Building and Conservation Areas) Act 1990. Section 66 details that the Local Authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.
5.25	In this context, your officers consider the impact is isolated to the setting of Austin House and the listed Gate Piers and Wall. The RPG is some distance away and development will not be experienced from within or around this asset. It will not be readily seen. The same can be said in context of other listed buildings in the vicinity. Given the scheme’s location, largely screened from the public realm and some distance from other designated heritage assets, officers consider it is not going to materially impact on their significance. Their settings would be preserved.
5.26	The main issue in this context is the impact on the setting Austin House and the listed Wall and Gate Piers itself. In your officers’ view, the new extension has gone some way to reduce the impact. It is of a high-quality design, which will remove a poor-quality existing extension and is designed to sit separately from the building via a small glazed linked corridor. In this sense, it is largely separated from the original building. From Bath Street, Austin House, and the Wall and Gate Piers will appear dominant. Even though the scheme is a very large extension, a sense of separation of ‘old and new’ will be established. This will help one understand the asset, it’s history and evolution of the site over time. This is achieved by splitting the new building into three sections with ‘steps’, which are expressed on the elevations as more open, glazed elements. By stepping the form and introducing pitched roofs and gables, the massing of the new building reflects the massing and form of Austin House, albeit on a larger scale. It is also worth noting that the highest ridge point of the new building (western wing) is slightly lower in height than the highest point of Austin House (northern wing roof lantern) and the remainder sitting lower and subservient to this. Notwithstanding this, it is apparent that from other vantage points within the school site the extension will fundamentally change how the building and its domestic character is experienced. It is appreciated the rear elevation has arguably less interest. Nonetheless, there will be a degree of harm to the significance of the listed building by developing within its setting at this scale. Again, this harm is considered to be ‘less than substantial’, at the lower end of this category. As above, a matter to be reviewed later in the planning balance.
5.27	Impact on the area of archaeological interest LPP2 policy DP39 notes that Development will be permitted where it can be shown that it would not be detrimental to the site or setting of Scheduled Monuments or nationally important designated or non-designated archaeological remains. Where the assessment indicates known archaeological remains on site, and development could disturb or adversely affect important archaeological remains and / or their setting, applicants will be expected to: i. submit an appropriate archaeological desk-based assessment, or ii. ii. undertake a field evaluation (conducted by a suitably qualified, archaeological organisation) where necessary For non-designated archaeological remains, the effect of a development proposal on the significance of the remains, either directly or indirectly, will be taken into account in determining the application. As such assets are also irreplaceable, the presumption will be in favour of the avoidance of harm. Where harm to or loss of significance to the asset is considered to be justified, the harm should be minimised and mitigated by a programme of archaeological investigation, including excavation, recording and analysis. Planning permission will not be granted until this programme has been submitted to, and approved by, the local planning authority, and development should not commence until these works have been satisfactorily undertaken by an appropriately qualified organisation.
5.28	In this case, the application is supported by an archaeological evaluation. As noted by the County Council Archaeologist, this revealed a dense concentration of medieval features and post medieval quarry pits. These features included a mixture of pits and ditches. One of the former contained animal bones, and charred cereal remains indicating domestic activity. Although no earlier material was found there is still likelihood that there was activity here during the Roman period and the presence of burials of that date could also be present. Therefore, it is reasonable to conclude that groundworks may result in disturbing artefacts. Therefore, in line with policy DP39, the applicant should be responsible for implementing a staged programme of archaeological work. This can be secured by condition.
5.29	Residential amenity
5.30	LPP2 policy DP23 seeks to protect neighbouring resident’s amenity from adverse impact of new development in context of loss of privacy/daylight, visual intrusion, noise, vibration and external lighting (amongst others). LPP2 policy DP24 seeks for proposals to be appropriate to their location and should be designed to ensure that the occupiers of new development will not be subject to adverse effects from existing or neighbouring uses.
5.31	In this case the school, including the application site, is an established residential institution and there will be no material increase in the number of boarders. The scheme will simply consolidate the boarding accommodation across the site. Directly neighbouring buildings are in the school’s use, with private neighbouring dwellings on the other side of Bath Street, set back far from the frontage behind a stone wall and trees. Therefore, it is not expected the development will have any adverse neighbour impact. Elements that may cause noise (such as air source heat pumps) are located within the school site, behind landscaping, close to the northern elevation. However, given the scale of scheme, there will likely be some noise and disturbance during construction, but conditions can secure a Construction and Traffic Management Plan to mitigate the impact. The scheme would comply with policy DP23.
5.32	In terms of impact on future students, the Urban Design Officer’s comments regarding sunlight being affected are noted. Invariably, there will parts of the existing building and central courtyard spaces which will attract less sunlight, due to the positioning of the new extension. However, the spaces it will affect are not student living areas (such as bedrooms), but the House Master’s Office and Master’s Accommodation. These need to be positioned where proposed so staff can monitor the children and comply with school accommodation regulations. The garden is also south facing, thus by lunchtime, these areas will generally be exposed to sunlight. The scheme is not harmful in this context. In terms of the outdoor space for the students, the scheme will retain communal outdoor areas, as well as being adjacent to the other outdoor school facilities (Waste Court Field). There will be no adverse by on the students by neighbouring uses, complying with policy DP24.
5.33	Traffic, parking and highway safety
5.34	LPP1 policies CP33 and CP35 expect the council to work with Oxfordshire County Council to ensure new development links well to facilities and services and supports sustainable transport methods. This is reinforced in LPP1 policy CP37 which in requiring good design, seeks sites to be well connected to provide safe and convenient ease of movement by all users. LPP2 policy DP16 requires development to demonstrate adequate provision will be made for loading, unloading, circulation, servicing and vehicle turning on a site.
5.35	In this context, again, given there is not a material increase in students or staff, there will be a very limited impact on the highway network, safety or parking. The site is also clearly in a sustainable location. The existing access is retained, proving vehicular access in an emergency, but overall, no further parking or access is required. The Local Highways Authority (OCC) are content with the scheme, subject to securing a CTMP by condition. As such, the subject to this, the development would accord with policies CP33, CP35, CP37 and DP16 in this context.
5.36	Environmental matters
5.37	There are few key environmental matters, which require consideration in the sub sections below. These pertain to the impact on biodiversity and potential protected species; trees; the drainage system and building sustainability;
5.38	Biodiversity and potential protected species LPP1 policy CP46 sets out how the council will approach important areas which contribute to the districts natural environment, biodiversity, habitats and species. Development that will conserve, restore and enhance biodiversity in the district will be permitted and opportunities for a net gain in biodiversity will be sought. Harm to habitats and species will require mitigation. In this case, the application is supported by an Ecological Appraisal and biodiversity calculations. The former has concluded in a Phase 1 habitat survey that only amenity habitats of low ecological importance are identified on the site. There will be some loss of this habitat, but with additional planting, the biodiversity calculations show a net biodiversity gain. The buildings are not expected to be habitats for bats, although there is potential for bats and birds in the wider environment. Mitigation (bat/bird boxes) is proposed in the appraisal, which can be secured by condition. The council’s Countryside Officer has not raised an objection. The development accords with policy CP46.
5.39	Trees LPP1 policy CP44 details that key features in the landscape will be protected, such as trees, hedgerows, woodland, field boundaries, watercourses and water bodies. The site has numerous trees in and around the site. Some are of a low quality and proposed to be removed to facilitate the development and some which contribute positively to the character of the area are of a high quality (such as T6 to the north and trees around the southern perimeter) which are to be retained. In any event, all trees are protected due to their location in the Conservation Area. The application has been accompanied by a variety of assessments, tree protection plans and services plans, which have been submitted to respond to initial concerns from the council’s Forestry Officer. Your officers are now satisfied that the development can be brought forward without damaging important trees on the site to be retained, but some further information is required, particularly on where electrical cabling is proposed to connect to and existing substation to the east of the site. Subject to conditions to secure the detail in the final Arboricultural Method Statement (AMS) and tree protection, the development is acceptable.
5.40	Drainage LPP1 policy requires that all development provides a drainage strategy, which includes sustainable drainage systems. In this case, the scheme is supported by a drainage report which demonstrates feasibility of suitable foul and surface water drainage facilities. The scheme and connective works around the site’s constraints and trees, avoid root protection areas. The council’s Drainage Engineer is content with the scheme. Subject to conditions to secure its implementation, the scheme is acceptable in this context.
5.41	Building sustainability LPP1 policy CP40 encourages developers to incorporate climate change adaption measures to combat the effects of changing weather patterns. The application in this case is supported by a sustainability statement, which highlights numerous measures (air source heat pumps, building fabric, air tightness), which will mean the scheme will result in a significant improvement above building regulation baselines, to reduce carbon emissions. This is a positive benefit of the scheme, raising design standards and development accords with the mentioned policy.
5.42	Impact on the special architectural or historic interest of the listed building
5.43	This matter pertains specifically to consideration of the works which require listed building consent and the direct impact on the listed building and its historic fabric, in order to facilitate this project. As mentioned, the works to the actual building are limited, as the extension for the most part stands alone, connected only by a first-floor single walkway and canopy at ground level. Even these connections are proposed to be structurally independent for the existing Austin House facade. Numerous minor internal alterations are required to improve the accommodation in the listed building and functioning of rooms but are largely limited to additional wash facilities or removal of more modern patriation walls/new doorways/openings. There is some lack of detail regarding the linked walkway and its connection to the old building/interaction with building fabric, but this can be secured by condition. Neither Historic England or the Conservation Officer have raised concerns about the works to the listed building itself.
5.44	Overall, given the scheme removes poor quality existing extensions and leaves the listed building largely unaltered, there will be no harm to it or special interest directly. As already highlighted, the harm to its significance is derived from the new building within its setting and its connection to it, not from the works to the building itself in isolation. The development therefore accords with LPP1 policy CP39 and LPP2 policy DP38 in this context. It also complies with Section 16 of the Planning (Listed Building and Conservation Area) Act 1990 which require, when considering whether to grant listed building consent for any works, the LPA shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses. The actual works to listed building as described in the application would achieve these requirements, subject to final details of the linked openings.
5.45	Other Matters
5.46	Water infrastructure Thames Water has confirmed that the water and foul drainage infrastructure has capacity to support the scheme. However, they have noted that the proposed development will be in proximity to the strategic sewer, where piled foundations could cause an impact. They have therefore required should piling be used, a method statement is first agreed. This is reasonable in the circumstance, given damage to the strategic sewer network could cause wider environmental or pollutive impacts on future occupiers and neighbours, or potential flood risk issues. Such a condition would ensure the scheme accords with LPP1 policy CP42 and LPP2 policy DP24 and DP23. Waste The scheme will not materially change how the school deals and processes with its waste, as there will be no material increase in pupils. Pre-commencement conditions Where applicable, pre-comment conditions have been agreed with the applicant.

6.0	PLANNING BALANCE AND CONCLUSION
6.1	Planning Permission (P19V3211/FUL) It is evident from analysis of the proposed scheme, there are several issues to consider in the planning balance. As detailed, planning law requires that applications for planning permission are to be determined in accordance with the Development Plan unless material considerations indicate otherwise.
6.2	It is evident that there are several benefits to this scheme. The school is a large established community facility and well located in the Town. Such facilities are encouraged to expand to accommodate future schooling needs and provide choice for the local community and beyond. Indeed, the NPPF notes that ‘great weight to the need to create, expand or alter schools’ should be applied to decisions. The proposed building is of a high quality and sustainable design, which has explored the constraints of the site and the most viable locations that could feasibility accommodate expansion of this nature. Throughout the application, the design has evolved to significantly improve the layout to limit the harm to the heritage assets as much as possible, whilst balancing the commercial and functionality needs of the school. Your officers are of the view that supporting the enhancement of this community facility in principle and the quality and care in the design of the new building attracts some weight; the latter raising design and sustainability standards for development in the district.
6.3	Notwithstanding these benefits, in your officers’ view, the development, by virtue of its scale, will cause a degree of harm to the character and appearance of the Conservation Area and the setting of Austin House (Waste Court)/Waste Court Gate piers and Wall. As such, the development will have an adverse impact on the significance of these designated assets, which is largely derived from this relatively well preserved large Victorian domestic building, in a formal plot, amongst a wider spacious but formulaically planned Victorian area of architecture. Spatially, given the size of the extension, it will erode the spacious setting and domestic character of the listed buildings setting with, in turn, an impact on the character and appearance of the CA. Given the contribution the site and building make to the area’s significance, this will result in some harm overall. Whilst in your officers’ view this harm is ‘less than substantial’ in context of the NPPF, the starting point is that, alongside the statutory duty to pay special attention to the desirability of preserving or enhancing the character of appearance of a Conservation Area and the desirability of preserving the buildings setting and historic interest, great weight must be given to these assets’ conservation. Therefore, the development is contrary to development plan policies CP39, DP36, DP37 and DP38. However, the PPG does note that, ‘within each category of harm (which category applies should be explicitly identified), the extent of the harm may vary and should be clearly articulated’ (Paragraph: 018 Reference ID: 18a-018-20190723). In this context, as discussed at paragraphs 5.23 and 5.26 above, the careful design of the scheme has gone some way to ensure the impact is not significant and the level of harm within this category would be at the lower end of the scale.
6.4	In identifying the harm as ‘less than substantial’ to the significance of the designated heritage assets, it is necessary that this identified harm is weighed against the public benefits of the proposal. As described in the PPG (Paragraph: 020 Reference ID: 18a-020-20190723), this could be anything that delivers economic, social or environmental objectives. In this case, your officers are of the view that the great weight attached to the harm to the designated heritage assets on one hand, needs to balance against the great weight also attached to the need to the expand and alter this school on the other.
6.5	The school, a community facility, clearly has wider social benefits and to consolidate and modernise its boarding accommodation demonstrates a reasonable plan to future proof this facility. This is likely more critical than ever, given the pandemic and the impact on how schools have had to operate. Whilst the future of this issue is uncertain, it seems reasonable to assume that to operate safely and efficiently and attract students to stay in these schools in the short and medium terms, schools like this will likely require more space and higher standards of accommodation. Therefore, in the round, securing this community facilities medium to long term viability by developing in the manner proposed, is a clear public benefit. In this context, it is also evident from the sites masterplan and constraints there is limited capacity to do this, thus the site proposed (in addition the application at Crescent House) seemingly make the most appropriate choice. There is limited scope elsewhere around the school site, due to likely loss of open space and playing fields.
6.6	The applicant has also put forward other beneficial aspects which would flow from the development, which they consider public benefits. The school estimates, based on a ‘calculator’ by Oxford Economics and the Independent Schools Council, that directly and indirectly the school supports over 650 jobs locally; contributes over £23m of GDP to the local economy (0.35% of the area’s total); and saves the UK taxpayer over £7m a year by reducing the number of pupils in state education.
6.7	The school also has many established local community partnerships, where students and staff build relationships with a wide variety of other local schools, charities, leisure and arts facilities in and around the town, all contributing to social cohesion. This has resulted in contribution to Air Quality Monitoring projects, for example. The latter has received the recognition of professional scientists, who are considering the potential for engaging schools in further research nationally and internationally. The school also shares its leisure facilities with the local community, such as the sport centre, theatre, swimming pool etc. In your officer’s view, securing the future viability of the school’s income, by attracting students via the higher quality accommodation, contributes significantly to sustaining and increasing these wider public benefits.
6.8	Having regard to all these identified public benefits, the development will ultimately secure more modern accommodation for students, and the enhanced functionality and management of the schools boarding accommodation. It will provide a high quality and environmentally aware building, of a high-quality design, which some weight is attached. From these benefits, this will aid in future proofing the school and attract students securing its long term economic commercial viability. In turn, this will ensure that significant public benefits from the school are enhanced and continue to flow from the site. Whilst your officers give great weight to the conservation of the identified heritage assets, it is considered that the combination of the public benefits of the proposal and the great weight attached to expanding and altering the school as a valued community and educational facility outweigh the identified ‘less than substantial harm’ to the designated heritage assets.
6.9	It is also acknowledged there is some conflict with the development plan’s heritage policies. Overall, however, your officers are of the view that the principle of development of the school would accord with the development plan when taken as a whole and the public benefits and other material considerations identified outweigh the heritage harm identified. Therefore, it is recommended that the application is approved, subject to the conditions noted at the start of this report.
6.10	Listed Building Consent (P19V3212/LB) As described in paragraphs 5.43 and 5.44 above, the works to the listed building in isolation are not significant. The removal of the existing extension would be beneficial, and the internal/external works required to facilitate the rest of the project will not harm the historic significance of the building, it’s setting and preserve features of special architectural or historic interest. Therefore, the works accord with the development plan and relevant legislation and it is recommended Listed Building Consent is approved. The identified harm in heritage terms is attributed to those elements for the scheme which require planning permission, not necessarily Listed Building Consent i.e. the new external development of the extension.

7.0	The following development plan planning policies have been taken into account:
7.1	Vale of White Horse Local Plan 2031 Part 1 policies (LPP1);
	CP01 - Presumption in Favour of Sustainable Development CP03 - Settlement Hierarchy CP08 - Spatial Strategy for Abingdon-on-Thames and Oxford Fringe Sub-Area CP33 - Promoting Sustainable Transport and Accessibility CP35 - Promoting Public Transport, Cycling and Walking CP37 - Design and Local Distinctiveness CP39 - The Historic Environment CP40 - Sustainable Design and Construction CP42 - Flood Risk CP43 - Natural Resources CP44 - Landscape CP45 - Green Infrastructure CP46 - Conservation and Improvement of Biodiversity CP47 - Delivery and Contingency
7.2	Vale of White Horse Local Plan 2031 Part 2 policies (LPP2);
	CP08A - Additional Site Allocations for Abingdon-on-Thames and Oxford Fringe Sub-Area CP47A - Delivery and Contingency DP08 - Community Services and Facilities DP21 - External Lighting DP23 - Impact of Development on Amenity DP24 - Effect of Neighbouring or Previous Uses on New Developments DP25 - Noise Pollution DP26 - Air Quality DP28 - Waste Collection and Recycling DP31 - Protection of Public Rights of Way, National Trails and Open Access Areas DP36 - Heritage Assets DP37 - Conservation Areas DP38 - Listed Buildings DP39 - Archaeology and Scheduled Monuments
7.3	Neighbourhood Plan (NP) It is understood that the Town Council has started the process of creating NP, but it is at a very early stage. The formal process as not yet started (i.e. Stage 1 – designation of the plan area), as such, carries no eight at this time.
7.4	Supplementary Planning Guidance/documents Vale of White Horse Design Guide 2015 (VoWHDG)
7.5	Other relevant guidance
	National Planning Policy Framework 2019 (NPPF) Historic England guidance notes Planning Practice Guidance (PPG) - Historic Environment
7.6	The following legislation and case law has been taken into account;
	· The Town and Country Planning Act 1990 (amended) · The Planning and Compulsory Purchase Act 2004 · Town and Country Planning (Development Management Procedure) · (England) Order 2015 (amended) · Planning (Listed Buildings and Conservation Areas Act) 1990 · Community & Infrastructure Levy Legislation · Human Rights Act 1998 · Section 149 of the Equality Act 2010 · Section 17 of the Crime and Disorder Act 1998 · Barnwell Manor Wind Farm Limited v East Northamptonshire District Council and Others [2014] EWCA Civ 137 · R (on the application of Forge Field Society) v Sevenoaks District Council [2014] EWHC 1895 (Admin)