We write on behalf of our clients, the Church Commissioners for England, to make representations
on the Core Strategy Consultation Draft (published in November 2009). In particular, our clients
object to Policy CS33, which they consider to be unsound because it is not consistent with national
policy.
The Council proposes to 'strictly control' development within the rural areas, outside the Service
Villages. Policy CS33 states that "small-scale new employment development will only be permitted
within or adjacent to non-service villages where it would increase self containment or meet the
needs of an existing local employer. Employment development will not be permitted in the open
countryside". In addition, new housing development will only be permitted where it is affordable
housing (within or adjacent to a non-service village), a replacement dwelling, or an agricultural
dwelling. This policy does not provide any support for the economic or residential re-use of
buildings that are located in the open countryside, nor does it make clear how proposals affecting
the re-use of buildings that are within or adjacent to non-service villages will be treated.
Policy EC6 of PPS4 sets out the approach that local planning authorities should adopt in their
Development Plan Documents (DPDs) towards economic development in rural areas. Part (c) of
the policy states that local authorities should "support the conversion and re-use of appropriately
located and suitably constructed existing buildings in the countryside (particularly those adjacent or
closely related to towns or villages) for economic development". Whilst proposals for the re-use of
buildings adjacent or closely related to villages should be 'particularly' supported, proposals
outside these areas (i.e. within the countryside) should also be supported. Currently, Policy CS33
of the draft Core Strategy is not consistent with this approach.
In addition, Policy EC6(d) of PPS4 states that local planning authorities should "set out the
permissible scale of replacement buildings and circumstances where replacement of buildings
would not be acceptable" in their DPDs. Development control policy EC12(d)(v) of PPS4 states
that local authorities should favour the replacement of buildings in rural areas where they provide a
more sustainable building for a proposed re-use, than the conversion of the existing building.
Should the Council believe that PPS4 provides sufficient policy guidance to determine an
application for a replacement building in the countryside; this approach should be recognised in the
Core Strategy. Policy CS33 of the draft Core Strategy currently does not set out the criteria for
when a replacement building would be acceptable.
Policy EC12 of PPS4 also states that the "re-use of buildings in the countryside for economic
development purposes will usually be preferable, but residential conversions may be more
appropriate in some locations and for some types of building". This provision is also not currently
included in the Core Strategy, where new housing is restricted to affordable housing (adjacent to
existing settlements); replacement dwellings; and dwellings for agricultural workers. This part of the
policy is therefore also not consistent with national policy.
Our clients recognise that development in the countryside should be controlled, however it is
important that the Council does not prohibit all development in rural areas. Buildings which are no
longer required for their original use should not be left to degrade because there is no local
planning policy in place to support their change of use. The Council should revisit Policy CS33 to
include support for the re-use or replacement of existing buildings in the countryside for economic
or residential uses, so that the policy is in accordance with PPS4. As it stands, Policy CS33 is not
consistent with national policy and is therefore unsound.