Design and Access Statement The Plough Maltings ......RIBA Conservation Accredited 3 5HFHLYHG The...

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Design and Access Statement The Plough Maltings • Horninglow Street • Burton-on-Trent Fairfield Construction January 2016 Note: This document and the drawings referred to were originally produced by MSA Architects. Both have been updated on instruction from Fairfield Construction. Brealey Associates Ltd Architect Designers Innovation Centre Warwick Technology Park Gallows Hill Warwick CV34 6UW Trevor Brealey BA Hons ARCH Dip ARCH RIBA RIBA Conservation Accredited P/2016/00130 Received 27/01/2016

Transcript of Design and Access Statement The Plough Maltings ......RIBA Conservation Accredited 3 5HFHLYHG The...

Page 1: Design and Access Statement The Plough Maltings ......RIBA Conservation Accredited 3 5HFHLYHG The Plough Maltings Horninglow Street, Burton-on-Trent, Staffordshire Design & Access

Design and Access Statement

The Plough Maltings • Horninglow Street • Burton-on-Trent

Fairfield Construction

January 2016 Note: This document and the drawings referred to were originally produced by MSA Architects. Both have been updated on instruction from Fairfield Construction.

Brealey Associates Ltd Architect Designers Innovation Centre Warwick Technology Park Gallows Hill Warwick CV34 6UW

Trevor Brealey BA Hons ARCH Dip ARCH RIBA RIBA Conservation Accredited

P/2016/00130Received 27/01/2016

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The Plough Maltings Horninglow Street, Burton-on-Trent, Staffordshire

Design & Access Statement

A Background/Use

1.0 Historical background

The Plough Maltings were one of the first to be built by the Bass brewery when the company began to produce its own malt. Historic maps show that the original malting building, named after a public house on Horninglow Street, occupied the same site as the current building and nothing of the original building appears to have survived.

The current building was built c1900 by the Bass company under the direction of their chief engineer Herbert Couchman and was an early example of a pneumatic maltings. In the brewing process, malting is where the grain (normally barley) is allowed to begin to germinate – this converts the starch in the seed to sugars. The ‘malted’ seed is then heated to stop further germination. The malted barley is then taken to the brewery where it is mashed (boiled) to extract the sugars, hops added for their preserving and flavouring qualities, and finally yeast added to convert the sugars to alcohol.

In a traditional malting the grain is wetted and spread across a floor where it is allowed to germinate: temperature is controlled by means of opening windows on each side of the malting space and the grain is turned by manual labour to allow it to germinate through its depth. The process is therefore labour intensive and the need for opening windows to allow controlled cross-flow of air in part dictate the building’s design. In the new Plough Maltings the grain was steeped in tanks and then dropped into large circular drums: these drums would be rotated to turn the grain whilst air was blown in (hence pneumatic) at the correct temperature to allow the grain to germinate. Whilst this reduced labour requirements, many other aspects of the process and transfer of grain /malt around the building would still have been very labour intensive and it was a halfway-house in the process of mechanisation of the malting process

All equipment was removed when the building was converted to use for storage and subsequently sold to Allied Breweries, but a few photographs survive showing the original interior and there is some evidence of the location and form of the machinery and mechanisms involved. There is no evidence of grain or malt storage within the building and it appears to have been devoted purely to the malting process. Grain would have been brought into the hoist house (A) and transferred to walkways within the roof space of area B: from these walkways the grain was emptied into steeping tanks to soak the grain (water supplied from the prominent corner water tower). From the steeping tanks the grain was piped down into the circular drums in area C: two rows of drums ran through this space with the building grid matching the spacing of the drums. The large air pipes appear to remain embedded in the floor, now capped off, with two pipes per drum, one each side, suggesting a flow and return.

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C A B

E D

H G F

Ground Floor First Floor

The boiler house, now missing its tall chimney, remains as the external building near the water tower, but has been much modified. The kiln, used to dry the malted grain to prevent further germination, is of traditional type that could have been found in a conventional floor malting. It is not clear how the malted barley was transferred to the kiln floor (D), but some form of the conveyor system may have been employed to transport the grain back to the upper floor. Fires would have been lit in the large lower chamber (E) and the heat would have passed through the pierced clay tiles of the kiln floor. The grain would have needed to be manually spread, turned and then removed from the kiln floor area. Once dried the malted grain would have been ‘screened’ to remove loose chaff, a process that probably took place in area (F) before being fed through hoppers and pipes (holes in floors suggest this) into a bagging area (G) before leaving the building at the doorway /steps (H). Since the use of drums to malt the grain meant that a malting floor with cross ventilation was not needed, the building has a wide footprint and the processes within the building follow a broadly U-shaped layout with the product leaving the building near to where the raw materials entered. The placing of windows was also no longer as critical and so there are small utilitarian windows to many areas, but the hall containing the drums had large arched windows to illuminate the new technology and give light deep into the large space inside. After the malting ceased to be used in the mid 1960’s the equipment was removed and the building used for storage. Staircases inside the building appear to date from this change as do new enlarged openings in the north, south and west walls, a lift installation in the watertower and shelving in certain areas.

Since the building ceased to be of practical use as a malting it has continued to be used for storage, but the building was not designed and is poorly suited to such use, being multi-storey, with inconsistent internal floor levels, and lacking good access for vehicle deliveries and off-loading. As a result the building is currently redundant after previously being on the market for some time. 2.0 Significance The building was listed Grade II in 1986. It also lies in a Conservation area. Listing offers statutory protection to the building and indicates that it is of national significance in terms of architectural or historical importance. 95% of buildings are listed Grade II with 5% Grade II* and Grade I.

The building has importance as a substantial late Victorian industrial structure, but few such buildings have survived still with their original function. Modern commercial industry and processing have changed and the

Old arial view of Burton-on-Trent

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buildings that contain these processes replaced to suit these new methods.

The Maltings have special interest in having housed what was at the time a new malting process, however the machinery that would have been of particular interest, although obsolete, is now long removed. There are some clues to the function and layout of the machinery as already described, but the main obvious difference between floor malting and the Plough Maltings is in the fenestration, the large arched west-facing windows contrasting with the more traditional windows elsewhere. The principal interest in the building is that it forms part of the Victorian industrial landscape of Burton-on-Trent and its brewing heritage. Lying near to The National Brewery Centre, it is a significant landmark. Whilst the building will never again be used for its original function, it is important that it is given a long term future and that its external form is generally protected to consolidate and preserve the historic built landscape of the town.

3.0 Planning designation use and relevant planning policies

The most recent use of the site is industrial /storage. It is within an area of mixed use, historically including residential, industrial, retail, office and other. Buildings around the site include redundant former houses, shops and public houses, law courts, redundant industrial and The National Brewery Centre. The Brewery Centre (The former Bass Museum of Brewing whose archive was consulted in the preparation of the current proposals), is just opposite the south of the Horninglow Road entrance to the application site.

The site is within the Horninglow Street /Guild Street Conservation Area. And the site lies within Historic Urban Character Area (HUCA) 12: Little Burton The document describing this area is part of the Burton Upon Trent Historic Assessment dated 2012. The document describes HUCA 12 ; ‘Large-scale late 20th century industrial development dominates HUCA 12. The portion of Horninglow Street which lies within the HUCA is more domestic in scale and includes a number of Grade II listed buildings ‘ The recommendations contained within the Burton Upon Trent Historic Assessment point out; ‘The heritage significance and values have identified that the historic environment continues to contribute to the character and sense of place of the HUCA.’ And then lists the following recommendations for the area

‘The sympathetic restoration or enhancement of the historic buildings, both Listed and unlisted, would strengthen the historic character and the quality of the wider townscape and the Conservation Area for the benefit of this and future generations (Bullet Point 10 of paragraph 17373 (Core planning principles) also paragraphs 126 and 131 of NPPF) .’

The last firing of the Plough Maltings

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The heritage assets could make a positive contribution to economic regeneration of the town. In particular the promotion of the re-use of historic buildings to contribute to sustainable development is recommended (paragraphs 126 and 131 of NPFF). High quality design which is sympathetic to the historic built fabric is the key to retaining the local character of the area as identified in Bullet Point 4 of paragraph 17 (Core planning principles) and Bullet Point 4 of paragraphs 5 374 in NPPF.

There is a general Policy presumption that development within a conservation area should preserve or enhance its conservation. The conservation areas within Burton are fragmentary and highlight the groupings of key buildings within later development that have important heritage value: the key buildings within the conservation area zone occupied by the Plough Maltings, part of the law courts complex and the National Museum of Brewing. The Plough Maltings is Listed Grade II. Listing of a building is not meant to infer that future development or adaptation of the building cannot take place, but it is important that development has appropriate respect for the significance of the building and its special character. With reference to the East Staffordshire Borough Council Local Plan; ‘Planning for Change’ which was adopted by the Authority on the 15th October 2015; in the following notes SP denotes a Strategic Policy reference and DP denotes a Detail Policy. LPA is an abbreviation representing The Local Planning Authority SP 1 affirms ‘East Staffordshire Approach to Sustainable Development’. It states that development proposals will be required to demonstrate the principles of sustainable development and will be assessed against the presumption in favour of sustainable development as interpreted and applied locally to East Staffordshire Borough Council The Proposals forming the Planning Application include the upkeep, reuse and preservation of an historic Listed Building that is very much a part of the character of Burton-Upon-Trent. The building has stood empty for many years. The reuse of an existing structure on a Brownfield site represents a massive energy saving in terms of the embodied energy represented by the existing fabric. Retaining and converting existing buildings is a fundamentally sustainable strategy particularly so as the conservation and upkeep of a Listed Building is included.

SP 1 requires that the assessment of sustainability includes consideration in respect of the following principles:

located on or with good links to the Strategic Highway Network;

convenience to allow safe walking, cycling and travelling by public transport;

it is convenient and safe to walk, cycle and travel by public transport between (and for larger sites,

around) the site and existing homes, workplaces, shops, education, health, recreation, leisure, and

community facilities and between any new on-site provision;

re-uses existing buildings where this is practicable and desirable in terms of the contribution the

buildings make to their setting;

integrated with the character of the landscape and townscape, provides for archaeological

investigation where this is appropriate and conserves and enhances buildings of heritage importance,

setting and historic landscape character

Part 3 – Strategic Policies also lists the following: Reference 3.180

Lists ‘The protection and enhancement of the significance of the historic environment and heritage assets forms part of sustainable development as set out in the NPPF, especially paragraphs 7 protection and enhancement), 9 (improvements in quality) and 126 (irreplaceable heritage assets). Such heritage assets include listed buildings, conservation areas,

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Reference 3.181 Development proposals may provide opportunities to enhance the historic environment either through new innovative and contextual development and design or through sensitive and informed repair which reinforces sense of place. Such development proposals should be encouraged as sustainable development that has economic, environment and social (cultural) benefits for the Borough. Reference 3.183 Due to the significant quality of the historic environment within the Borough, any new development which may impact upon heritage assets should be protected and enhanced through high quality design and using the key principles that are set out in the Design SPD. Reference 3.184 Opportunities to enhance conservation areas are welcomed, whether this is to a building or to the wider setting, such as public realm improvements. Implementation can be through heritage led regeneration or small scale interventions to safeguard the integrity of the conservation area and its character, especially for Conservation Areas at Risk within the Borough. There are important elements of a conservation area, not just the buildings which are contained within in it which should be considered as part of development proposals including spaces, street patterns, views and trees. SP 21 is headed ‘Managing Town and Local Centres’: ‘Town Centres’

This states that new developments should (related clauses only listed):

be designed to meet a very high standard of quality, respecting and reflecting the town centre’s

historic environment and helping to improve the sense of place and legibility to the Town Centre

experience;

‘Respect and enhance the Historic fabric encouraging housing opportunities.’

SP 24 ‘High Quality Design’

Development proposals must contribute positively to the area to which they are proposed and:

help to create a sense of place, building on the urban, suburban and rural local character,

respecting local patterns of development and the historic environment, and using heritage assets

to their best advantage;

reinforce character and identity through Local distinctiveness;

be adaptable in order to enable a change of use where this is appropriate;

minimise the production of carbon through sustainable construction and reuse of materials where

possible and promote the use of renewable energy source technology where possible.

SP .25 ‘Historic Environment’. This policy includes the following:

Development proposals should protect, conserve and enhance heritage assets and their settings, taking

account of their significance, as well as the distinctive character of the Borough’s townscapes and

landscapes. Such heritage assets may consist of undesignated and designated assets including

conservation areas, listed buildings, scheduled monuments, archaeological sites, registered parks and

gardens and historic landscapes which contribute to the Borough’s historic environment and local

distinctiveness;

This should include the use of high quality design as stipulated in the NPPF and the Borough Council’s

Design SPD. Development proposals that are likely to have negative impacts on the historic environment

should demonstrate how harm can be effectively and justifiably mitigated (refer to the Heritage

Statement; note: the LPA is allowed to consider relaxations of other policies where this may promote or

facilitate the enhancement of a conservation area or enhance the potential to give historic buildings ‘a

new lease of life’);

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Development proposals should be informed by the various information sources and evidence bases that

are available; Reference Consultations and Principles.

The previous Planning Authority Conservation Architect (Alan Taylor) had been party to and instrumental

in determining the previous proposals. The application of the advice gained from these consultations and

the Application of Conservation knowledge and experience have fashioned the Proposals described in the

Application documentation. The following notes are specific to their design and content;

As an important historic building the primary design aim is to ensure that the external appearance is as

unaltered as practical and this means that many of the assessment criteria identified in the policy have

limited applicability in this case. Compatible materials closely matching the existing will be used in repairs.

Also care has been taken to ensure that external landscaping respects the key views of the building but

provides appropriate amenity space for users. Regarding detailed design, care is being taken that new

elements are honest and archaeologically clear but also recessive and subservient in appearance

compared with historic fabric. In terms of external design impact the most significant change is the

insertion of a limited number of new windows: the design of these windows, to create simple ‘slots’ within

existing masonry to maintain the monumentality of the basic structure and with the new windows distinct

from the small-paned windows of the original. The design of the new walkways and staircases (hidden

inside the buildings) will be appropriately high quality but simple form to reflect the industrial history of

the building.

The towns of Burton-upon-Trent and Uttoxeter, including their historic retail centres, should be a focus for

heritage-led regeneration and the repair of key heritage assets will be supported. Such regeneration

should be informed by relevant historic environment evidence bases (continued).

Policies relevant to the Flood Risk, SP27, are considered within the appended Risk Assessment.

Detailed Policies applying; these are prefixed ‘DP’ DP1 ‘Design of New Development’ Development proposals are to be assessed with regard to the following factors where appropriate to the type of development:

How the design of the development responds to the historic environment context and conserve and enhance heritage assets, including their setting.

Under DP1 there are other factors listed which are not relevant to this project.

DP2 ‘Designing in Sustainable Construction’ This Policy lists considerations that the developments will be expected to respond to. In the case of the proposals forming the Planning Application and in terms of sustainable construction, the following should be noted:

The reuse of an existing structure on a Brownfield site represents a massive energy saving in terms of the embodied energy represented by the existing fabric. Retaining and converting existing buildings is a fundamentally sustainable strategy particularly so as the conservation and upkeep of a Listed Building is included.

The existing constructions will be brought up to modern day performance standards in excess of the requirements of Building Regulations. The means of doing this will be agreed with the Local Authority Conservation Officer as a Condition of a Granted Planning Approval.

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DP5 ‘Protecting the Historic Environment: All Heritage Assets, Listed Buildings and Conservation Areas and Archaeology’. Our main reference here is to the Heritage Statement and the associated drawings. This Detailed Policy describes in more detail the Local Plan’s expectations in respect of the Conservation of Heritage Assets. Central to this is the basic premise of SP 25; ‘Development proposals should protect, conserve and enhance heritage assets and their settings, taking account of their significance, as well as the distinctive character of the Borough’s townscapes and landscapes.’ Of particular relevance to the proposals to reuse The Plough Maltings are the following:

There may be an opportunity to introduce innovative development which complements the existing historic environment through high quality contemporary architecture and energy efficient technology, where such technology would not cause harm to the character, setting or fabric of the heritage asset.

The reuse of heritage assets contributes to viable places and should be seen as a positive opportunity. The reuse of a heritage asset should continue in its original function where possible, but where this is not economically viable, a sensitive change of use should be considered which retains the significance of the heritage asset. Development Proposals should articulate how the heritage asset can accommodate the new use without causing significant harm to the context and fabric of the asset.

It should be noted that within the Planning Policies, mechanisms are described that allow the consideration of alterations to the Listed Historic fabric by informed and enlightened interventions. The same applied to proposals for alterations or additions to a Conservation Area. Our reference here again is to the Heritage Statement and the referred to drawings.

4.0 Proposed use

The building has been marketed for some considerable time previously. The building is no longer suitable for malting and brewing processes. Although most recently used for storage, the varying floor levels and access restrictions limit practical use and such use could not commercially compete to an extent that would generate income to carry out the necessary conservation and maintenance of the structure. All other uses of the building would be likely to require substantial subdivision of internal spaces. Vehicle access and location count against retail use and there is already over provision of office space in the area. Many Victorian industrial buildings have been converted to residential use. ‘Loft living’ remains popular. Although much of the fitting out for residential use can be considered ‘reversible’, in practical terms conversion to residential use guarantees that the building has a long term future: long leases and management fees ensure that the building is properly maintained. It is proposed to convert the former malting to residential use in the form of self-contained apartments. Taking into consideration the factors identified in this and other reports, in this case this would seem to be an appropriate response to the need to secure the sustainable future of a Listed building. In an area close to Burton town centre and its facilities, where a move to mixed-use development has been identified by the AAP as an important factor in allowing regeneration and as a means to secure the future of key heritage buildings. Regeneration is required and the restoration and conversion of the Plough Maltings would be a positive signal and would be helpful to the process of injecting new life into the area. The location of the site, within easy walking distance of the town centre, bus and train routes, green spaces and various facilities, further shows the potential of this type of development and the promotion of a mixed use environment. As the recommendations of the AAP become reality this appropriateness will be further reinforced.

5.0 Community considerations and involvement

The existing building and its site stand empty and have an air of dereliction. The suitable reuse as proposed

will add much needed life and vitality to this city centre locality and will bring this historic Grade II Listed asset back into use.

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There is an established and stated need for low cost housing and the East Staffordshire Borough Council Housing Strategy Manager and a copy of his communication of 19 August, 2014 is appended to this Design Statement. The proposed supply of private market rented units was welcomed by the Housing Department and it was acknowledged that they would be a positive contribution to the local community.

B Previous Consultations The designs, drawings and original Design and Access and Heritage Statements were put together by MSA

Architects for Roxdan Developments. The Statements have been updated by Brealey Associates Ltd (Chartered Architects). These updates also reflect current Planning Policy documentation and the contents of the Local Plan adopted late 2015. The proposals were the subject of pre-Application consultations with the Planning Authority at the beginning of 2009. The designs, their content and specifications were put together and agreed with Mr Alan Taylor (the Staffordshire County Council Principal Conservation Officer). None of the content of the drawings and specification has been altered since then.

The premises stood empty and were on the market for sale until they were purchased by the current owner

early 2014. Pre-Application consultations were recommenced via Christina Farrer (Planning Officer) in June 2014 and are documented within this Design Statement and as further described by the documents listed in the Appendix.

A fresh enquiry was put to Ms Julie Taylor of Historic England in November, 2015. Ms Taylor confirmed

that Mr Alan Taylor’s previous advice would remain valid and therefore further consultation with Historic England would not be necessary.

C Amount

1.0 Density and form

The project essentially involves the conversion of an existing building. This largely establishes the density of development which is well within the levels set by national planning policy in respect of residential development.

The building footprint will remain as per that of the current building since the proposal is to convert an

existing building without significant extension. If the formation of the courtyard within the existing building is taken into consideration then the density of development will actually represent a reduction compared to the existing built form.

2.0 Residential units

It is proposed to convert the building to provide 32 apartments in a mixture of sizes to provide a balanced community and to meet varying needs. Apartments range from modest studio apartments to three bed units and are designed to respect the internal layout and fabric of the existing building as far as practical. The creation of a new internal courtyard reduces the usable floorspace in the building but will ensure that the amenity of the proposed apartments is maximised and this is considered to be of paramount importance.

It has previously been agreed with the East Staffordshire Borough Council that the Apartments in total

would be private market rented units for a minimum of ten years secured by Legal Agreement. Communications with Christina Farrer (Planning Officer) and Steve Payne (Housing Strategy Manager, East Staffordshire Borough Council) are appended to this statement. These communications are dated 19th August, 2014. For further reference in respect of this matter please see Item H (Financial Contributions).

3.0 Amenity Space

In the context of an historic townscape characterised by industrial use, the introduction of appropriate amenity and green space must be balanced against avoiding harm to the setting of important buildings and views. The land around the former Coors Visitor Centre has been softened by landscaping which is attractive, but has removed the original hard setting of the buildings in that site and impacted on the

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character of the conservation area. With the Plough Maltings the primary amenity space is provided on the side of the building farthest from

the main road and viewpoints: as well as providing privacy, this also protects the principal view of the building. Other green spaces and planting are provided to give visual relief but without changing the core character of the industrial buildings setting as seen from Horninglow Road or the side road.

The amount of amenity space, concentrated to the building rear but with pockets elsewhere within the

courtyard and routes around the building, provide a mix of viewpoints and environments for residents and a quantity of space appropriate for the size of development.

4.0 Car Parking

Parking is provided to ensure that all apartment holders will have access to spaces within a secure parking area with additional visitor spaces at the front of the building.

5.0 Refuse and recycling facilities

Refuse storage is provided within the former boiler house, a location convenient for residents to encourage responsible disposal of refuse and recycling of other materials, being close to the main site and building entrance.

The boiler house will be modified to incorporate ventilated panels to ensure that the area is pleasant to use

and is not in close proximity to any one unit and will not result in any nuisance to residents. The location of the refuse /recycling facilities should ensure easy access for waste collection vehicles;

provision for refuse vehicle turning has been allowed for. In addition to the standard recycling facilities, there is scope for collection and recycling of compostable

waste arising from the communal gardens. 6.0 Bicycle and other storage

A new modest vernacular building is provided to the north-east corner of the site. This building will provide bicycle storage and also for storage of equipment for maintenance of the building and grounds.

D Layout 1.0 Existing building

The positioning of the Listed building and the need to conserve its layout has determined the planning of the scheme so as the need to preserve important features and protect the setting of the building.

2.0 Site & travel access

DTA Transportation have provided their Specialist Statement and this is appended to this Design and Access Statement. Christina Farrer’s (Planning Officer) communication dated 9th July, 2014 is appended to this Design and Access Statement outlining initial report requirements. In conclusion the Transport and Travel Statement states ‘that the proposals will have no adverse impact on the safety or operation of the surrounding road network and there are no transport reasons for refusing planning Permission.’ The location of the site is within easy walking distance of the town centre, bus and train routes, green spaces and various facilities.

The proposals include the closing of the Horninglow Road access to vehicles and the creation of a new vehicle access from the unnamed side street. This is a change that would apply to any new use of the building. However, pedestrian access from the front entrance to Horninglow Road will remain so helping to keep separate pedestrians and vehicles at critical safety points. To maintain the security and safety of the site, access is limited to these two points of entry.

3.0 Site design

The new access maintains the front of the building as a publicly accessible space. The majority of car parking is to the rear of the building where it is within a secure area and where there is less visual impact on the main public views of the Listed building. The details of the landscaping proposals are discussed in more detail below.

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4.0 Building layout

The placing and size of the proposed apartments respect the structural logic of the existing building. Generally existing wall lines and columns /beams define the positions of the main party walls. To access the apartments it is proposed to make the central bay of the building into an open courtyard. In addition to facilitating access, this arrangement helps with the natural lighting and ventilation of the dwellings and avoids the problems with noise and fire escape /smoke control that would result from an enclosed communal space. Apartments are laid out to ensure that efficient and effective use is made of natural light and virtually all habitable rooms have access to direct light and ventilation. In the majority of cases the main living spaces have views outward from the external walls rather than within the courtyard. The ground floor apartments are single storey, although those above the existing cellar have cellar space for storage only. The majority of first floor apartments are duplex, having bedroom space in the roof spaces reflecting the design of roof trusses intended to support galleries and walkways. The internal layout of apartments also ensures that bedrooms have a protected route to the entry door in the event of fire.

5.0 Design for crime prevention

The front part of the site is publicly accessible; however the nature of the landscaping and gated accesses will show that the land is privately controlled. The site will be demarked by railings of 2 metres height approximately, but with new railings and gates being of design appropriate for the setting of a Listed building. Car parking for residents will be secured by means of a controlled access gate. This, together with a pass gate, will be full height to reduce risk of car break-ins as well as car theft. The single vehicular access point is immediately opposite the magistrates courts which may provide further visual deterrent. Although generally CCTB is not planned, this would be easily installed to provide further deterrent effect if necessary. The nature of the layout of the apartments is such that virtually all external aspects will be overlooked from at least some apartments, including the internal courtyard. The only parts of the site that will be less well overlooked are the extreme corners of the rear car park and the entrance pathway from Horninglow Road; these could be areas protected by CCTV if found necessary. Of the two entry points to the building, the rear doors are within the secure car park area and both sets of doors into the kiln building would be fitted with a door entry system. A gate screen is to be installed to the front archway with an entry system control to the courtyard area. Where practical, doors and windows will be to ‘secured by design’ standards, the possible exceptions being any retained doors and window which will be upgraded to a level appropriate to their design and historic significance. A secure external store is provided for the storage of cycles. This is an enclosed store and internally will be provided with fixing points for security chains as well as a locked secure external door. The old boiler house, to be the refuse /recycling centre, will also be locked and accessible only to key holders.

E Scale /Context 1.0 Scale

The building sits along a line of north-south oriented plots, but extends westward in the north-west part of the site. This is an area where railway lines were historically located which was previously part of the private breweries tracks. There are no plans to extend the existing building footprint, other than the construction of a small ancillary storage building. The external appearance, and therefore scale, of the building will be unchanged.

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2.0 Context

The area is mixed use but historically incorporated residential use, principally along Horninglow Street: industry related to the brewing industry grew up around and behind the older street-fronting properties. At one time, the private train lines ran to the north and east sides of the malting. Although some brewing industry remains to the south of Horninglow Road and at a distance to the north-west, the character of the area is still one of mixed use, but with an increasing need for the older buildings within the conservation area to be found new uses to ensure that the special architectural and historic nature of the area can be preserved and enhanced. The Maltings building is not directly attached to any other historically relevant structures. New development facing the malting to the east, to the rear of the courts, has not been carried out in a manner that shows especial respect to Listed buildings or the conservation area and offers no useful precedent for future development. The group of buildings embraced within the south-east corner of the site are different in character to the general industrial heritage in this part of Burton, but are important in reflecting the smaller properties that once ran along Horninglow Road. Similarly, the remaining site with industrial buildings behind houses and other road frontage buildings are significant in showing a form of historic development that appears to have survived outside the ownership of major brewers. Across the road to the south, The National Brewery Centre reflects some industrial heritage but the removal of street-frontage buildings and the soft landscaping is somewhat at odds with the historic realities. The proposals for The Maltings will have a key effect of preserving the external appearance of a key building within the conservation area and giving it a sustainable future. Since The Maltings is a considerable presence set well back from the road, and changes to the immediate context of the building in respect of parking, etc. are likewise screened from the road, the development will have a neutral impact in terms of planning considerations, but a positive impact taking into consideration the realities of ensuring a sustainable future for redundant industrial heritage.

F Appearance /Design 1.0 Respecting existing fabric

The existing malting building was conceived by an engineer as a functional structure. As with many Victorian industrial structures, this has given it brutal, massive and sublime qualities that contrasts with the ephemeralness of modern equivalents and therefore engendered wider interest and appreciation of such buildings. In particular the building is important in terms of townscape value and the historic landscape of Burton. The proposals therefore protect and maintain the outward form and appearance of the structure. Structurally the building currently remains in good order despite its lack of function. However, the proposals will allow for conservation of the original fabric, including brickwork repairs, re-roofing (salvaging and reusing original slates as far a possible), repairs and refurbishment of retained joinery and metal windows, and similar.

Some new windows will be needed in external walls. This would probably be true for any viable re-use of

the buildings and care has been taken to keep the insertion of new windows in external wall faces to a practical minimum. Where installation is required, new windows are honest in appearance and do not compromise the appearance of the originals – this is significant in protecting the archaeological understanding of the original fenestration. New windows will be metal with minimal dark-coloured frame sections deep-set into walls to create shadow forms that will contrast with the repaired original metal (and some timber) windows.

A key change to the building is the creation of an internal courtyard. This is important in that it allows natural light into the centre of the deep-plan building and in doing so, reduces pressure on the need to insert windows into the outer walls. The courtyard will be invisible from outside the building and so the townscape value of The Malting will be unharmed. The practical benefits of the creation of the courtyard in terms of allowing natural light, ventilation and assisting in meeting the requirements for fire escape

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provision and sound control are here balanced against the retention of building fabric. Since the removal of the original machinery from the building has reduced its significance in part, the retention of the majority of the remaining building fabric elsewhere, the fact that none of the fabric to be removed is not replicated elsewhere in retained areas, and retention of roof trusses with part glazed roof mean that the understanding of the building will not significantly be further diminished. The treatment of the new courtyard elevations and walkways is modern and honest to maintain the archaeological clarity. Where possible the internal layouts of the new apartments respect the structural layout of the existing building. New internal divisional walls will be in studwork and new floor structures generally in timber meaning that they are reversible insertions. The Malting originally had a significant number of large glazed rooflights that had been slated-over in a subsequent re-roofing. In order to allow increased natural light and ventilation into the building, rooflights of conservation type will be reintroduced where necessary, the siting of these on hidden roof pitches where possible. The former boiler house is to be repaired and enhanced to provide for bin storage and recycling facilities. External landscaping measures are described below.

2.0 Flood risk A Flood risk Assessment is appended to this Statement. The ground floor level is dictated by flood risk modelling. The level required is approximately that of the former bagging hall area meaning that the floor levels in the kiln area and malting hall will need to be raised. The new floors are to generally be of timber where inside buildings, beam and block to the courtyard area: this will create a useful service void. The existing cellar area will be for limited storage only.

3.0 Amenity

The flats have been arranged so that all have access to windows and natural light to key rooms and zones. All have access to windows in external elevations, backed up by light from the internal courtyard or rooflights. The courtyard also provides natural ventilation to the apartments. Noise

Hepworth Acoustic Noise Specialists have carried out an inspection/survey and have provided a Statement which is appended to this Design and Access Statement. We request that any further detail survey requirements are Conditional to Planning Permission being granted. The noise consultant will be advising on provisions for sound control from external and internal transmission. Secondary glazing is proposed for existing windows for sound reduction and thermal performance. The Noise Assessment Statement concludes that ‘there are no overriding noise issues for the proposed residential development. Acceptable noise levels for the new residents, as defined in British Standard 8233:2014, can be achieved straightforwardly by standard noise mitigation methods. The necessary sound insulation measures for the building envelope can be detailed at a later stage once planning permission has been granted. Thus a noise measurement survey, assessment and detailing of a noise mitigation scheme should be carried out at reserved matters stage. This can be ensured at this stage by a suitably worded planning condition’.

Lighting

New lighting on the exterior of the proposed development will be low-lux, cowled (directed downwards to prevent light splay), and used on timers or motion sensors. This is to comply with the Ecological Report previously referred to and appended to this statement.

See also the items of this report relating to access and security lighting.

External parking is provided for all residents along with bicycle storage facilities. External amenity areas include the courtyard and external private garden areas. Although The Maltings requires a predominantly industrial setting, this has been softened with some planting with the majority of planting and garden areas to the north, as described below.

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4.0 Sustainability Statement

The proposals are centred upon the reuse of a vacant Grade II Listed building and its site. These premises have stood empty for a considerable amount of time. The reuse of an existing structure on a Brownfield site represents a massive energy saving in terms of the embodied energy represented by the existing fabric. Retaining and converting existing buildings is a fundamentally sustainably strategy particularly so as the conservation and upkeep of an historic asset is included. The existing constructions will be brought up to modern day performance standards in excess of the requirements of the Building Regulations. The site is in a city centre location with good links to the strategic highway network. Its location allows safety for walking and cycling. Travel by public transport is easily available. These matters are referred to in the Transport Statement. Local work opportunities are available so are shops, education, health, recreation, leisure and community facilities. The proposals are in direct compliance with Strategic Policy 1.

5.0 Listed building consent conditions relating to design and materials

The purpose of the Planning and Listed Building Consent applications is to allow the principal of the development to be established in respect of the major planning and LBC policy considerations. We would anticipate the attachment of Conditions to an approval to allow the satisfactory resolution of detailed matters of design and execution appropriate for a Listed Building at an appropriate stage and to allow adequate flexibility and scope for further discussion with Planning Officers and specialist advisers. We would anticipate that a Planning /LBC approval to provide for the Conditional later approval of the following information where not approved as part of the current application process: (i) Provision of samples of proposed materials to be used in external elevations and roofs:

- bricks for use in repairs and alterations and in the construction of the new external store - slates for use in re-roofing - colours for external decoration

(ii) Provision of the following detailed drawings /information:

- typical roof and verge details (to show how insulation may be satisfactorily incorporated) - typical details of secondary glazing to existing windows - typical details of new windows - typical details of new external joinery - typical details of upgrading of existing floors including kiln floor - typical details of new partitions and relationship to original structure - typical details of the courtyard wall treatment and new walkways - typical details of new ventilation provision to open air - details of planting

G The Site, Landscaping /Environmental Management 1.0 Protected species

An Ecology Report has been produced by Dr Stefan Bodfar. This is dated November, 2015 and is appended to this Design and Access Statement. This document states that the majority of the site is of ‘low ecological value’ and requires that further specific site surveys are carried out subject to Planning Permission being granted. The Report also lists requirements in respect of the timing of site works, comments as to the nature of lighting utilised on the site and recommendations for accommodating and encouraging shared occupation with wildlife. The lighting requirements are listed previously in this document.

2.0 Archaeological

The Staffordshire County Council Principal County Archaeologist’s has been consulted; a building record of the structure is to be put into place in advance of any stripping out works to the building. Also, an archaeological watching brief is to be implemented during the ground works. These requirements are to be put into place strictly in accordance with the Staffordshire County Council Principal County Archaeologist’s requirements and as described by the Conditions attached to the Planning Approval. A copy of the County

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Archaeologists communication dated 21st September, 2015 is appended to the Design and Access Statement.

3.0 Ground Conditions

Mr Harry Spilman BSc (Engineering & Geology) MSc Chartered Geologist of Spilman Associates Geotechnical and Environmental Engineers has been consulted. His advice is that bearing in mind that the site has previously been used for food related purposes there is a low risk of contamination. We ask that any further survey requirements in respect of the nature of the ground be a Conditional requirement of any granted Planning Permission.

4.0 Christina Farrer’s (Planning Officer) communication of 8th July, 2014

Confirms that Environmental Health do not require an Air Quality Assessment is not required. 5.0 Impact of Landscaping in the Setting of the Building

A key aspect of the proposals is the need to protect the setting and townscape of the malting. The original setting of the building would have included sett paving, railway lines, sacks and activity. There is need to create a mixture of amenity spaces including garden space for residents, but a complete change of visual context to the malting would harm its integrity.

Because of this, the zone of the front of the building (south elevation) is to be kept hard paved using new

block paving resembling setts. The access road to the side will be broken with areas of setts within the tarmac and with areas of planting beginning to soften the area. To the private rear area will be more significant garden areas to provide amenity for residents.

A new road access is to be provided from the side street with the existing access from Horninglow Street

being made pedestrian only. An existing small outbuilding will be removed from the boundary and new railings provided, and the access made suitable for use and turning by refuse vehicles. Further into the site, railings and motorised gates will allow to a secure parking area.

6.0 Internal Courtyard

The new internal courtyard will be semi-external space. Patent glazing mounted on some of the existing roof trusses will keep the access stairs dry, but the space will be partially open to the air to aid the natural ventilation and lighting of apartments. Essentially hard-surfaced, it will be possible for the space to be softened by means of planting containers. Walkways, stairs and decking will be of contemporary design in galvanised steel: this echoes the industrial past of the building. Open mesh walkways will allow light to pass through and the walls will be covered with a white acrylic render to help maximise and enhance the benefits of natural light.

7.0 Management

A management company will be responsible for the general management and maintenance of the site by means of a management maintenance fee charged to leaseholders. This arrangement enshrined with the lease agreements a mechanism that has the benefit of ensuring that the building and site is maintained in the long term. A small new building in the north-eastern corner of the site provides for secure bicycle storage and also storage of equipment for the maintenance of the grounds.

8.0 Existing trees and plant species

Reference the Ecology Report which has been produced by Dr Stefan Bodfar and is appended hereto. This states that there are no trees or plant species of note on the site.

9.0 Listed building consent conditions relating to the site

The purpose of the Planning and Listed Building Consent applications is to allow the principal of the development to be established in respect of the major planning and LBC policy considerations. We would anticipate the attachment of Conditions to an approval to allow the satisfactory resolution of detailed matters of survey at an appropriate stage and to allow adequate flexibility and scope for further discussion with Planning Officers and specialist advisers.

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We would anticipate that a Planning /LBC approval to provide for the Conditional later approval of the following information where not approved as part of the current application process:

(i) Additional survey requirements as listed in the Ecology Report (ii) Any further land contamination check requirements (iii) Any additional noise assessment requirements

H Access /Facilities for People with Disabilities 1.0 Context

The site is relatively close to the city centre, within modest walking distance of the main shopping area, the railway station and other transport links. Bus routes also run close by. Although there is a rise up to the railway station, in general the streets around this part of Burton are relatively flat and level, aiding the infirm and wheelchair users. Although traffic on Horninglow Road can be busy, a traffic light controlled crossing point is located nearby, outside the courts, from whence there is a good access route to the town centre.

2.0 Access and approaches to the building (see also Item D.2.0 Site & Travel Access)

Note: We also refer the Specialist Traffic Statement as previously referred to and Appended to this Design and Access Statement. Access to the site for vehicles will be from the side street to the east of the malting. A separate pedestrian access, available direct from Horninglow Street, will provide additional safety for pedestrians. Accessible parking spaces complying with BS8300 are provided immediately opposite the main entrance into the courtyard. The width of carriageway between the malting and boiler house is restricted by Listed buildings and we have been advised during Pre-Application discussions by the Conservation Officer that the boiler house should remain. The southern end of the malting is also the primary entrance to the apartments. The roadway will therefore need to be shared surface, being surfaced and designed with speed control humps to reduce the speed of vehicles. However, any speed humps, ramps or cobbled surfaces will be designed to allow wheelchairs to pass unheeded. External lighting will be provided to ensure that all key access areas have adequate artificial lighting including to any locks /access control systems. Access control systems will be of a type suitable for use by people with sight impairments, auditory impairments and limited dexterity.

3.0 Common areas

A ramp, deigned to a maximum incline of 1 in 15, less if possible, leads into the courtyard area. This allows the courtyard level to be at the same height as the ground floor apartment level, giving level access whilst meeting the requirements of the flood risk assessment for floor levels. All ground floor apartments are on a single level and therefore all are wheelchair accessible. Level access will also be provided into the kiln building. Common stairs will be designed to comply with ambulant disabled standards. Steps into apartments that require stepped access will be to ambulant disabled standard, although level access will be provided where this can be accommodated within the limitations of the existing floor levels of the listed structure. It is likely that most ground floor apartments will have level access. Artificial light to common areas and parking areas will be low level residential type lighting designed to achieve adequate illumination levels with special attention paid to main access points and places of special

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access risk, e.g. staircases. Signage throughout the building will be consistent and comply with standards recommended by RNIB or other equivalent. Colour and contrast will be taken into consideration in the choice of finishes to allow the general themed highlighting of risks, routes, doors, special fittings, etc. Any further access control systems will be designed to meet the needs of people with special access needs. No lift is currently shown for access to the first floor – this is not a requirement of either Planning controls or Building Regulations and within a two storey building is considered to have limited appeal to potential occupiers, especially since many of the upstairs apartments are duplex. The costs of a lift installation together with annual maintenance cost currently appear disproportionate to likely usage and would mean the inflation of the sale price and annual maintenance charge to residents without an adequate level of meaningful benefit. However, it is intended to construct a shaft within the kiln building that would be capable of accepting a lift at a future date for access to the main upper floor and walkway level. This would allow for potential future changes in legislation, market demand or technological advances to justify its installation.

4.0 General design and detailing

Apartments and common areas will be designed to comply with Part M of the Building Regulations as a minimum standard. Where it is practical to comply with the enhanced recommendations of BS8300 or other relevant standards, this will be attempted. This will include layout of flats to provide adequate turning for wheelchairs in accessible areas; light switches and socket positions at accessible heights, accessible toilets complying with the domestic requirements of part M on main storey levels, use of colour contrast in common areas, etc.

I Financial Contributions

There is the constant issue of the financial viability of this project particularly bearing in mind the work and associated expenditure required to convert and repair the Listed Building and also the cost of its continued upkeep. A similar Grade II Listed Building was granted Planning Permission for the incorporation of 60 Apartments in 2006 (Ref: PA/07932/027). This permission has not been implemented apparently due to the conversion not adding up financially. The 60 Apartments have not been constructed. It has previously been agreed with the East Staffordshire Borough Council that the Apartments in total would be private market rental units for a minimum of ten years secured by Legal Agreement. Communications with Christina Farrer (Planning Officer) and Steve Payne (Housing Strategy Manager, East Staffordshire Borough Council) are appended to this statement. These communications are dated 19th August, 2014. On the basis of this provision it is understood that there will be no Affordable Housing requirement or no requirement for any financial contribution to the Local Authority. Please see also Item A 5.0 Community considerations and involvement. Any financial contribution required from the site owner in respect of the proposed site conversion/proposals would not be acceptable and would deem the project to be not viable.

Planning Reference: PA/07932 027 The Goat Maltings Anglesey Road Burton-on-Trent DE14 3PD

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APPENDIX TO THE DESIGN AND ACCESS STATEMENT

The following documents form part of the Planning Application: 1.0 Drawings as existing

1523-01 Existing Ground Floor Plan 1523-02 Existing First Floor Plan 1523-03 Existing Basement/ Second Floors 1523-04 Existing North West Elevations 1523-05 Existing South East Elevations 1523-06 Existing Sections /Outbuildings

2.0 Drawings as proposed 1523-07 Proposed Location Plan 3D 1523-08 Proposed Ground Floor Plan 3D 1523-09 Proposed First Floor Plan 1523-10 Proposed Second Floor Plan 1523-11 Proposed Roof Plan 1523-12 Proposed Basement Plan 1523-13 Proposed North West Elevations 1523-14 Proposed South East Elevations 1524-15 Proposed Sections 1524-16 Proposed Cross Section 1524-17 Proposed Detail Section 1524-18 Proposed Outbuildings 1524-19 Proposed Railings 1524-20 Proposed Site Plan

3.0 Specialist Reports Flooding Risk Assessment - Flood Risk Assessment – January 2016 Ecological Appraisal by Dr Stefan Bodnar – November 2015 Noise Statement Site Inspection & Noise Statement by Hepworth Acoustic Noise Specialists – December 2015 Traffic Statement Transport Statement by DTA Transportation – December 2015 Drainage Statement _January 2016

4.0 Communications referred to this Statement: Requirements of the Staffordshire County Council’s Principal Archaeologist dated 15 September 2015 Christina Farrer’s email dated 9 July, 2014 stating requirement for a Transport Statement Christina Farrer’s (Planning Officer) and Steve Payne (Housing Strategy Manager) communications of 19 August, 2014 relating to the supply of private market rented accommodation

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APPENDED COMMUNICATIONS REFERRED TO IN THIS STATEMENT

Requirements of the Staffordshire County Council’s Principal Archaeologist dated 15

September 2015 Dear Mr. Brealey,

Thank you for sending through the information on the Plough Maltings, Horninglow Street, Burton-upon-

Trent. As you are no doubt aware, the structure is a Grade II listed building (PRN 12767) and as such is

considered to be of national importance. This clearly does not preclude its development or conversion

although it does mean that a degree of sensitivity should be employed in designing the scheme and the

programme of works which will achieve its realisation. Listed Building Consent is also likely to be

required and in the first instance I note that you have prepared a Heritage Statement in support of your

application.

Regarding the Heritage Statement you should note that PPG15 was superseded by PPS5 (Planning and

the Heritage) in 2010. This has itself been superseded by the NPPF (2012). The Planning (Listed

Buildings and Conservation Areas) Act 1990 is still enacted. East Staffordshire Borough Council should

be consulted at the earliest opportunity to discuss Listed Building Consent and potential impacts (or

enhancements) that the scheme may offer the Conservation Area. . As a final point I would suggest

that you include within your amended Heritage Statement that you have consulted with the Staffordshire

County Council Principal Archaeologist regarding the scheme. Once amendments have been made

(see above), can I ask that you provide me with a copy of the amended Heritage Statement (hard copy

and a digital copy on CD Rom) for inclusion in the Historic Environment Record (HER)?

Regarding the need for further works, your Heritage Statement contains a significant amount of

information which could be incorporated into a subsequent archaeological report on the building. I would

also point you to the Burton Extensive Urban Survey (held on the SCC webpages, search under EUS)

as the site lies within Historic Urban Character Area (HUCA) 12: Little Burton. However, I can confirm at

this stage that archaeological mitigation may be advised bearing in mind the significance of the structure

and the scale of proposed works. As a steer (and please do bear in mind that I have not yet seen the

detailed scheme and therefore my advise may change) I would be minded to advise the following:

A Level 3 Building Recording of the structure in advance of any stripping out works to the building. This work must be undertaken by a suitably experienced archaeological organisations following the relevant Historic England guidance, the appropriate Chartered Institute for Archaeologists (CIfA) standard and guidance and a brief prepared by this office.

An archaeological watching brief during all groundworks. This is advised as there remains the potential for the presence ‘maltings associated’ evidence to survive as below ground remains. There also remains the potential for evidence associated with late medieval/post medieval development along Horninglow Street out of what had previously been Burton’s agricultural hinterland.

I would suggest that both elements of archaeological work be reported on in a single volume.

I trust that this email provides you with sufficient detail but please do get back in touch with me should

you require clarification of any points that I have raised

Kind regards,

Stephen

Stephen Dean MA BA HND ACIfA

Principal Archaeologist

Historic Environment Team

Staffordshire County Council

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Christina Farrer’s email dated 9 July, 2014 stating requirement for a Transport Statement

Dear David,

The Highway Authority has confirmed that the application would need to be supported by a Transport

Statement rather than a Transport Assessment.

It requires a Transport Statement that ‘takes into account the existing and proposed Use Class Orders,

site sustainability, explains the access strategy and also how the site will be serviced in terms of

waste/recycling. This latter aspect should be informed by your Authority’s Waste and Recycling Section.’

We have a guide regarding waste collection in relation to new development that it on our web site. This provides

guidance on issues such as bin storage access/turning facilities for refuse lorries etc.

Kind regards,

Chrissy

Christina Farrer

Planner

East Staffordshire Borough Council

The Maltsters

Wetmore Road

Burton upon Trent

DE14 1LS

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Christina Farrer’s (Planning Officer) and Steve Payne (Housing Strategy Manager) communications of 19 August, 2014 relating to the supply of private market rented accommodation

Dear Richard,

I have received the comments below from our Housing Strategy Manager (HSM) regarding affordable housing.

Under current policy we would be looking for a commuted sum (as detailed) rather than on site provision, as it is

recognised that a registered social landlord would not want to take on 10% of the units whilst the remainder

were in private hands as they prefer to have complete control of buildings/blocks.

The emerging policy is mentioned (i.e. 100% of the units be private market rented units for a minimum of 10

years secured by a Section 106 Agreement). The HSM has advised me verbally that we would support such an

approach before the emerging policy is actually adopted (June 2015 at the earliest I believe).

Kind regards,

Chrissy

Christina Farrer

Planner

East Staffordshire Borough Council

The Maltsters

Wetmore Road

Burton upon Trent

DE14 1LS

From: Steve Payne

Sent: 19 August 2014 10:06

To: Christina Farrer

Subject: RE: Plough Maltings, rear of 143 Horninglow Street

Dear Chrissy

Apologies for the delay in replying.

I would welcome provision of housing through conversion of this building.

Under current policy we would require 10% Affordable Housing. I understand this is a single

building, which means that Affordable Housing could not be provided in a separate block. It

would therefore be appropriate to accept a commuted sum in lieu of on-site provision. The

current formula for calculation of the commuted sum is as follows:

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10% x aggregate internal floorspace of dwellings (m2) x £504 x 85%

Under emerging proposed policy an affordable housing requirement would not be required if the

development was to deliver Market Housing for Rent – which means if subject to a S106

obligation ensuring that the properties would be owned by an institutional investor or Registered

Provider of Social Housing which would let the individual dwellings to individual household

occupiers at market rents for at least 10 years following completion.

Steve

Steve Payne

Housing Strategy Manager

East Staffordshire Borough Council

01283 508826

From: Christina Farrer

Sent: 08 July 2014 08:58

To: Steve Payne

Subject: Plough Maltings, rear of 143 Horninglow Street

Hi Steve,

I am dealing with a pre-app scheme for the above.

It is a large listed malting building that the LPA would wish to see brought back into a viable use and the

building restored. It has been vacant for quite a while now.

The draft scheme (one that English Heritage appears to generally support from a listed building point of

view) is a conversion consisting of 32 apartments. These would be:

1 bedsit type

8 1 bed flats

23 2 bed flats (7 over 1 floor and 16 as duplex flats over 2 floors)

Can I have your comments from an affordable housing viewpoint.

Thanks,

Chrissy

Christina Farrer

Planner

East Staffordshire Borough Council

The Maltsters

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Wetmore Road

Burton upon Trent

DE14 1LS