DEVELOPMENT CONTROL COMMITTEE – 16 NOVEMBER 2010
APPLICATION NO DC/10/1060/COU
EXPIRY DATE
20 October 2010
APPLICATION TYPE
Change of Use
APPLICANT
Mr N Wilson
9
LOCATION
International Boat Training College
7 Sea Lake Road
Lowestoft
Suffolk
NR32 3LQ
PARISH
PROPOSAL
Change of Use from B1(office use) to C2 (student accommodation
associated with school or college) and construction of a single storey front
extension with landscaped amenity area
DO NOT SCALE
Reproduced from the Ordnance Survey mapping with the permission of the Controller of Her Majesty’s
Stationery Office © Crown Copyright. Unauthorised reproduction infringes Crown copyright and may
lead to prosecution or civil proceedings.
SUMMARY
This application is for the use of an existing but unused office building on the Harbour Road Oulton
Broad Industrial Estate, adjacent to the International Boatbuilding Training Centre on Sea Lake
Road/ Craftsman’s Way, as living accommodation for students attending the college. Existing
Adopted policy and emergent policy do not provide a clear measure of comfort for residential
forms of use on industrial sites. There is however, staunch support from the Economic
Development Officer and the Urban Regeneration Company, First East for this, and the emergent
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Area Action Plan now nearing adoption is specific in its support for the growth of this educational
establishment.
SITE DESCRIPTION
The site is bounded to the southeast by cleared land formerly occupied by Oulton Brewery and
now open storage for Pilot Drilling. To the north there is another former office building that had
been used as a martial arts training centre, though this was never a regularised planning use. To
the west is a small open area in front of the existing International Boatbuilding training centre,
itself, to the south west. Due south 30m away are framed industrial sheds that have had their
cladding removed, giving views currently towards Lake Lothing, though re-cladding will lose this.
The land falls away sharply towards the lake. An area between these sheds and the proposed
building has been proposed as landscaping.
PROPOSAL
The proposal is for change of use of the office building to Class C2 Residential (Technical)
Educational Use (if one considers the training centre and this site to be linked), with minor internal
alterations and small extensions to provide accommodation for students at the adjacent
International Boatbuilding Training Centre.
CONSULTATIONS/COMMENTS
No neighbouring industrial users or residential occupiers have commented
Lowestoft College were consulted on the 2 September 2010. See planning considerations.
Urban Regeneration Company / 1st East were consulted on the 2 September 2010. See
planning considerations.
Env. Health - Environmental Protection were consulted on the 2 September 2010. See
planning considerations.
WDC - Economic Regeneration were consulted on the 2 September 2010. See planning
considerations.
SITE NOTICES
The following site notices have been displayed:
WDC General Site Notice
Reason for site notice: Change of Use, Date posted 03.09.2010
Expiry date 23.09.2010
RELATED APPLICATIONS
Reference No
Proposal
DC/10/1060/COU Change of Use from B1(office use)
to C1 (student accommodation) and
construction of a single storey front
extension with landscaped amenity
area
Decision
Application Refused
Date
PLANNING POLICY
E2 Existing industrial areas and adjacent sites (Waveney Local Plan, Adopted November 1996)
CS07 Employment (Adopted Core Strategy, January 2009)
CS05 Lake Lothing and Outer Harbour Area Action Plan (Adopted Core Strategy, January 2009)
Planning Policy Statement 4: Planning for Sustainable Economic Growth (2009)
DM08 Existing Industrial Areas and Other Employment Sites (Development Management Policies,
Submission June 2010)
PLANNING CONSIDERATIONS
Introduction
There has been a boat-building training centre on this site since 1975 and the crafts based skills
taught here do suit the light industrial character of the area and the E2 Employment Land
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designation in the Adopted Plan in as much that while not strictly a B Class use it supports such
industrial activities especially where they relate to the ship construction type uses prevailing
locally.
Bringing residential activity into this area would however offer poor amenity, to the residents of the
facility. The proper consideration of such use therefore revolves around whether the precise
character of this residential activity, the benefits to the ITBC and the wider area and the suitability
of conditions to control the residential activity to ensure the use remains suitably and narrowly
defined are sufficient to render the proposal acceptable.
The current layout of the industrial estate has residential uses but confined to the areas next to the
railway and to the east end, where there are homes dating back to Victorian times around Harbour
Road and Lothing Street. The site itself is fringed on the east by the former Oulton Brewery, open
storage for PDT drilling and to the west by the boat training centre complex.
Back History:
Pre-application advice was that this use was not in accordance with Adopted and emergent policy
and an application might fail. There is a back history of refusal for on site accommodation for the
ITBC dating to W1627/17 of 1992, although this relates to a site immediately to the west of the
current proposal. That application was turned down as against employment land policy and for
parking space loss concerns, whereas the earlier refusal reference DC10/0270FUL was refused
on the poor amenity offered to potential students sited within an industrial area and on the lack of a
Contaminated land Study. This Contaminated Land Study has now been satisfactorily submitted
and that refusal reason no longer pertains.
Policy status of the Area:
The applicant has quoted PPS4 as supporting the application, by accepting that uses other than
employment uses that generate economic activity can justify relaxation of policy with regard to
other uses. This is accepted, however, the existing D1 (non-residential institution) educational use
is in itself an acceptance of this economic driver. It remains however a further step to argue that a
residential type of use is desirable, or that the ITBC could not develop further without approval for
on-site residential accommodation. The ITBC could expand in other ways.
PPS4 EC10.2c asks whether the proposal secures a high quality and inclusive design which takes
the opportunities available for improving the character and quality of the area and the way it
functions and EC10.2d, about the impact on economic and physical regeneration in the area,
including the impact on deprived areas and social inclusion objectives. It is considered that the
small area of planting will do little for the character of the area on a comprehensive basis. The
proposal will clearly have some economic benefits from expansion of the ITBC, however the
impact on a wider basis is not considered to be of a scale where the deprived area benefits, and
the loss of the site for industrial expansion might in the longer term be more serious, especially
when other local high quality manufacturers have indicated that they are looking to expand.
The land is currently shown in the Adopted plan as for B type industrial uses, (policy E2) so
residential or educational uses do not comply with Adopted Policy in the 1996 plan.
The emergent Area Action Plan for Lake Lothing does however suggest that more mixed use
development might take place within the industrial area.
Planning policy in the emergent AAP (latest draft) dated September 2010 supports the training
centre. At paragraph 3.1.5 the policy states: "The Harbour Road Industrial Estate in particular
provides an important employment location within the AAP area with a focus upon maritime
activities. Proposals in this area must ensure that this important employment function is retained
and enhanced. This may include uses that complement employment activities such as enhanced
training associated with the International Boat Training College." and at page 23 "Balancing
employment and other uses The Lake Lothing and Outer Harbour area retains an important role as
an active waterfront with a diverse focus of employment activities. The distribution of land uses
must be carefully planned so as not to undermine the ongoing employment potential of the
waterfront and ensuring that conflicting land uses are positioned away from each other".
The policy team comment that: The latest version of the AAP refers to ancillary uses in the text
and policy but doesn't specifically refer to residential accommodation, (although this might be
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included if at a low numeric level, where the prime character of the training college remains the
educational facility and the accommodation small in comparison). The intent for the area is still to
protect it for employment uses but the boat building training centre is also considered important for
the area. We need to think about the long-term aims for the area, which could have implications for
the future if the residential element is allowed without proviso. (Thereby suggesting that conditions
could serve to restrict residential use to a carefully controlled form).
AAP Policy EMP1-4: “The protection, enhancement, expansion and relocation of existing and new
businesses within existing employment areas and other mixed use areas”.
This policy makes it clear that existing business needs to be fostered, however, it also hints that
relocation might be necessary, to enable expansion in some cases, this relates principally to the
relocation of businesses displaced by powerpark.
AAP policy EMP1 Employment Sites
Employment sites identified on the Proposals Map will be protected and enhanced for B1 (light
industrial), B2 (general industrial) and B8 (storage and distribution) and appropriate ancillary uses.
Development will be promoted within this location that enables relocation and expansion of local
businesses.
Where development requires existing businesses to be relocated the Council and 1st East will
work with owners (and occupiers) to relocate to appropriate premises in employment or mixed use
areas defined within the AAP area, or other locations within the sub-region.
The AAP has been presented for approval to Cabinet and Full Council and a final version
considered by the Planning Inspectorate, following the recent Examination in Public.
The AAP would therefore seem to oppose the proposal because of the conflict in amenity terms of
residential and industrial activity, but support it where diversity is seen to be beneficial, and
employment will be created by an expanded IBTC.
The case for allowing development submitted by the applicant:
The applicant has argued that the location makes the training facility easily accessible, pointing out
that the intensive short courses, with hands on evening study ideally suit an on campus
accommodation. The business case that the building is available, within the ownership of the
IBTC, easy to convert and therefore of low conversion cost enabling cheap accommodation to
students, especially when in the summer months, there is less local accommodation as a result of
Tourism uses.
Comment:
There is however access to the town and the cheaper housing suited to student life along
footpaths and cycle paths only a mile away, so the "sustainable" location is not considered a
compelling reason for approval.
It is not usually a material planning argument that the premises are cheap, though the viability of
low cost accommodation being made available to the students can be, enabling access to poorer
students, though no indication of charges for the accommodation has been made.
Lowestoft College also offer some craft skills training, the IBTC talked to a previous now retired
principal, but it would appear there is little common ground in terms of the kind of training offered.
It is known that the Lowestoft College is looking to develop student accommodation and it was
suggested that some sort of mutual arrangement could be devised, though at the time of writing
Jan Sutton, in charge of student accommodation projects, says no approach has been made by
the applicant in order to establish whether other accommodation could be made available nearby.
There is support from the Urban Regeneration Company:
Having seen the valuable work of the International Boatbuilding College, we consider their efforts
and activities a valuable asset to Lowestoft and potentially capable of making a significant
contribution to the AAP and broader areas economic development objectives.
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The IBTC experiences difficulties in accommodating their students, some of whom are from
overseas. However we also respect that the area within which the site is located is currently
designated for employment uses, and is likely to predominately remain so.
On balance we would support the application on a basis that it does not set any precedent for
residential uses on that specific site in itself at this time.
We would suggest that were any recommendation to approve the application be conditional upon
clause/s: to ensure that any occupiers of the proposed International Boatbuilding College student
accommodation is carefully restricted to registered and demonstrably current, active students of
the International Boatbuilding Training College only and at all times.
Comment:
It is agreed that the proposal is not considered to set a general residential precedent in the area,
and that conditions would be effective in ensuring only student occupation of the premises occurs.
(The IBTC has also supplied a list of the countries that have sent students to the college, 20
different countries were identified).
Economic Regeneration Team response:
The IBTC are a long established and well respected niche training provider who have built up an
enviable reputation and provide specialist skills training for students from the UK and overseas.
This is a valuable resource to the industry and an asset to Lowestoft helping to contribute to the
economic development of the area. The site is in the AAP area and is currently zoned for
employment use. There are however ongoing issues and difficulties with regard to sourcing
reasonably priced, suitable accommodation for students in the local area within travelling distance
of the IBTC. This could potentially have a negative affect on the future sustainability of this
important and unique facility. On balance I believe that this application should be supported
provided it does not set a precedent apart from the proposals on nearby areas which are being
supported by 1stEast and Suffolk County Council, and that the proposed student accommodation
facilities are restricted solely for the use of registered IBTC students.
Comment:
Clearly the concern that there is a shortage of industrial land for business displaced by the power
park is not relevant with regard to this particular location (i.e. the existing buildings and site layout
and access would not suit those displaced businesses).
The debate must therefore be over the reasonableness of placing accommodation in a location
with poor residential amenity and whether a refusal might lead to the IBTC closing. This
application differs from the refused application in that a landscaped area immediately in front of the
facility measuring 26 x 12m has been provided. Other land within the immediate area that is also
leased or owned by the IBTC is not included within the overall landscaping plan. It is considered
that to maximise the collegiate character outlined in the applicant’s statement the rest of the
College grounds should be treated in a more comprehensive way in order to overcome the
industrial character and resulting amenity deficiency.
It should also be noted that the extreme west side of the estate and 75m to the northwest of the
application site there are two railway cottages that are in residential use.
It is considered that industrial noise will not lead to complaint by students causing curtailment of
Industrial activity under Environmental Health legislation. This estate attracts small scale ship and
boatbuilding rather than very heavy industry and working times appear to generally focus in social
hours. In addition convincing data has been supplied that shows how noise levels can be
controlled within the building from external sources.
The site’s location is close to shops and hostelries and other services likely to be required by
students. It is noted that there are shops in Bridge Road, with permitted development rights for
flats above that could provide as much accommodation as is suggested on this site.
With only eight Bedrooms and shared kitchen and living room, this development could be seen to
be an HMO and therefore regarded as to be measured against policy H12 of the Adopted Plan, the
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applicant has however submitted that the provision of on site laundry services and the presence of
other common room type amenity space within the college site, provides the additional facilities to
the students. A drawing received 18/10/10 shows the other facilities within the site. A condition
regarding the character of occupation and the style of use could require the serviced nature of the
facility be maintained as a residential educational type use within C2 of the Use Class Order.
A contamination survey has been submitted with this application (whereas the previous application
was deficient in this matter).
The applicant has noted the 100 student per annum attendance at the facility with the prospect of
expansion by the provision of the eight bed accommodation that if intensively use on the 2 week
courses could increase throughput to 8 x 25 or 200 additional students or permutations of this
figure.
There is a prospect of the IBTC moving elsewhere if this is not granted.
Two sources have indicated that students may already be staying overnight on site, though the
applicant's agent was not aware of this when asked what " living under the rudder" meant. If this
is the case, then the application could be viewed as indicating a need being fulfilled and providing
proper accommodation albeit with degraded amenity by virtue of the industrial location.
CONCLUSION
On balance there still seems to be no greater policy comfort offered to residential uses on
industrial estates, in this latest version of the AAP. The modest numbers suggested lend
themselves to alternative local accommodation and do not seem to justify accommodating people
in a location generally unsuited to residential activity.
RECOMMENDATION
Recommend refusal on amenity grounds.
If members are minded to approve, conditions should be added requiring:
The accommodation solely to be for the benefit of students attending the ITBC and registered on
courses at the college. (In order to prevent general residential use being established).
The accommodation shall be provided with laundry services and be cleaned by the ITBC and its
contractors. (In order to prevent the student accommodation from taking on the character of an
House in Multiple Occupation).
A log of students should be kept on site so that at any reasonable time this can be examined by
enforcement officers to establish the bona fide nature of the residents.
The permission should only be for the benefit of the ITBC as a training entity, in order to link the
residential usage to the training function in a clear manner.
Student numbers should be limited to eight at any time, in order that the character of the
accommodation remains ancillary to the training D1 use rather than becoming an established use
in its own right.
BACKGROUND PAPERS
CONTACT
Case File DC/10/1060/COU held in Planning Office, Mariners
Street, Lowestoft
Chris Green, Area Planning and Enforcement Officer, 01502
523022
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