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more than “minor alterations”. Such renovation would constitute a 'new build' in Green Belt land;
but with no very special circumstances. In their place would be new buildings not in the same use.

Paras 89 and 90 of the NPPF clearly state that (a) the re-use of existing buildings in the Green Belt is
permissible – provided they are of permanent and substantial construction. The stables and barn are
not and (b) that the replacement of a building is permissible, provided the new building is in the
same use. This is not the case here. The planned “conversion” of these buildings would constitute a
'new build', contrary to what is permitted in the Green Belt, unless there are very special
circumstances. There are none.

Para 81 states that once a Green Belt has been defined, the local authority should then plan positively
to enhance its beneficial use, e.g. to retain and enhance landscapes, visual amenity and biodiversity.
This aim is supported by Bexley's Policies CS01, ENV4 and ENV22. Establishing a school is not
stated as a 'beneficial use' in this paragraph, nor in any other part of the NPPF guidance. Nor would a
school on this site be beneficial to the environment in any way. On the contrary, it would be
inappropriate and harmful – with no very special circumstances.

Nature of site
The site is on high ground, visible from two viewpoints and lies in Green Belt/Heritage Land that is
open and Semi-Rural. It is not land within an Urban area and - unless all dwellings with a garden
and ancillary outbuildings are regarded as previously developed (brownfield) land - we dispute that
this is the case here.

The site is residential, not commercial. The house was built over 50 years ago when it was then
occupied by a nurseryman working for the large nursery business which, we understand from local
knowledge, owned it. Local knowledge also confirms that no commercial business was ever
conducted from the site and the nurseryman left over 40 years ago.

Since then, the site has continued to be residential comprising a dwelling with ancillary garden
outbuildings. Until the property's recent sale to the applicant, with its large acreage of grazing land,
it was owned by an international pony & carriage competitor. He built the stables and barn for this
purpose. Two of these, the stables and the barn, are “redundant” only because the new owner does
not wish to use them for the purpose for which they were built. We have to point out, too, that this
site (with its adjoining land and private equestrian outbuildings) was sold as a residential property –
and with a price reflecting its Green Belt limitations!

We stress again, the site was never a commercial one and so should not be considered
brownfield land.

Change of use
As stated above, the impact on the character of the neighbourhood arising from a change of use from
residential to a school would be severe. For Bexley's Green Belt, this Application is the most
inappropriate and potentially damaging we have yet seen and at odds with Policies CS06 and CS17.

Apart from the remnant of Gattons Plantation (ancient woodland area) to the east of the site, a stud
farm to the north, and woodland and a cemetery to the west, the area is predominantly residential.
The presence of a school would significantly change the character of the area. Moreover, granting
permission for a change of use of a residential plot into a highly profitable commercial venture
(which the proposed school would be) would also signal the gradual destruction of Bexley's Green
Belt as other site owners in the area (residential or agricultural) look to take advantage of such a
change of policy. Indeed, allowing a change of use for number 48 Parsonage Lane from residential

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