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Section 5: Place Shaping Policies Cranbrook and Sissinghurst


This response report contains comments received on Section 5: Place Shaping Policies – Cranbrook and Sissinghurst section.

Contents

General comments

Comment No.

Name/Organisation

Response

DLP_8267

Ann Gibson

How can decisions and statements about traffic and transport be made, when the research on critical services such as bus times is incomplete?

DLP_3060

Councillor Nancy Warne

I support Tunbridge Well Borough Council’s goal to produce a Local Plan, and I would like to praise the dedication and hard work of the TWBC planning policy officers over the past few years in trying to bring this incredibly difficult task to its draft Regulation 18 stage.  Given the level of complexity of the draft plan, the limited resources available, the additional demands placed upon the department, it is commendable that this draft plan has been produced at all, and in such a short time-frame.

However, in trying to reach this milestone so quickly I feel that there are fundamental flaws of policy and process which still need to be addressed before the plan is in a position to come to the council for approval.

The political climate and framework within which the planning policy department is operating has internal contradictions which act to make their job almost impossible.  As if the positive planning approach adopted in the NPPF and the increase in housing targets (and pressure to deliver them) set by the government were not a challenge enough, the TWBC planners are also now expected to deliver these goals in an age of austerity politics, a market-driven ideology fuelled by an over-heated London economy, a duty to co-operate with neighbouring boroughs, a requirement to consider the needs and concerns of a host of other sectors and interest groups and the emergence of amateur planners trying to fulfil the localism agenda for community-led planning.

My concern is that in the process of trying to balance all these competing and conflicting demands the approach taken by the local planning authority has resulted in a tipping of the scales of influence and power even further in the favour of those with the most, at the direct expense of local communities and those trying to safeguard our environmental heritage.

I would urge the planning policy team to revisit the three central tenets of sustainable development (economic, social and environmental), and suggest that these should not be mutually exclusive, contradicting or grossly unbalanced, as they are in this draft document, but should be equally weighted and in harmony in order to enable the delivery of truly sustainable growth.

My fear is that the adopted approach of the policy-makers in this case displays a lack of awareness of how ingrained in their collective psyche the neo-liberal agenda has become.  They have blinkered themselves to it in the belief that it is the norm, and that no other ideologies or methodologies exist or can be considered.  This becomes especially apparent in their lack of accommodation of any alternative policy frameworks and delivery mechanisms for development, as evidenced in their approach to neighbourhood planning and other community-led initiatives such as the community land trust (Crane Valley Land Trust) and self-build projects.  Even the government recognises the current need for alternative and complementary delivery mechanisms through its release of £163 million in the Community Housing Fund initiative.

Instead, this parish has witnessed large house-building companies apparently being given a “green light” to invest in large tracts of our protected countryside (AONB) in the knowledge that their development aspirations will be supported by the borough’s planners, despite the planners’ knowledge of local opposition to such activity.

I understand the reasons for this approach, as a demonstration of the risk management of speculative development, but I feel that in acting to mitigate these threats the officers have overlooked the necessity to enable the community to take ownership of the development process.  This is absolutely essential if delivery is to be achieved.

As leader of the Cranbrook and Sissinghurst Neighbourhood Development Plan Steering Group, I (and my colleagues) have attempted to collaborate with the TWBC Planning Policy team over the past three years in bringing forward draft planning policies and a spatial development strategy for the parish which reflect the evidence gathered both through extensive engagement with our community and that by a government-sponsored body, AECOM.   This attempt at collaboration has been the most frustrating and dispiriting experience of my life.  As a result, the aspirations for our local community to be able to shape future development in our parish, as set out in the National Planning Policy Framework, have been thwarted.

Our local community and the hard-working volunteers of the Cranbrook & Sissinghurst NDP Steering Group have actively and positively participated in the process of trying to find the best way to deliver the benefits of growth in our parish without causing substantial harm both to our built & landscape heritage and to our community.  Given the scale and distribution of the housing allocations now proposed for the parish, the community now feels it is being unfairly punished for being willing participants in this process.

I would welcome further conversations between the TWBC Head of Planning (and other officers in the planning policy team) and the local community representatives in order to reach a mutual understanding and agreement as to a positive way forward out of the regrettable stalemate in which we currently find ourselves.  A re-building of trust between the planners and the community is desperately needed.  I would particularly like policy officers to consider what role it sees for the neighbourhood plan, one which is in conformity with both the NPPF and the Localism Act.  It is not good enough to simply consign it to a set of local development management policies, but should be a true reflection of the local community’s wish to be our own decision-makers and produce a master-plan for our parish.  This has been enabled in other communities across the country and it would be good to get a greater understanding of how this was achieved.

Until such an agreement is reached I cannot support this plan.

DLP_3551

Lynne Bancroft

AONB – It is incorrect to say that Sissinghurst is adjacent to the AONB as part of SIssinghurst is in the AONB. The AONB should be extended to cover the remainder of the parish of Sissinghurst to protect the sensitive and historic landscape of the areas, including Sissinghurst Castle

Other– Sissinghurst is also a tourist destination with 200,000 plus visitors a year coming through the village with the associated traffic issues it brings. The rural area and landscape around Sissinghurst should be protected from over development as it is a well-known walking area with The High Weald trail, The 1066 Harolds Way, Walk in Time series of walks and the “Green Book” walks going through the area encouraging green tourism.

Main employment – the fact that there is no employment sites noted in the Local Plan emphasises that Tunbridge Wells should not include development sites in this village as they are unsustainable. Development should be near key employment sites or areas with facilities, better transport such as Tunbridge Wells and areas near the already dualled A21

DLP_3993

Brian Swann

"General Comments"

Cranbrook needs green spaces between settlements in Cranbrook, Hartley, Wilsley Sissinghurst.

We need small scale development, not large estates.

I would like to move from my 4 bedroomed house to a much smaller dwelling thus freeing up my house for a growing family. But there are no 1 or 2 bed properties to move too. Many others are in the same position. We do however want to remain in Cranbrook.

Please ensure more smaller affordable houses are built.

There is a general feeling that T.W.B.C. are not co-operating with the Parish Council Neighbourhood Development Plan steering group. Please take into account the research done by them. Local people's views should be accepted as long as the housing numbers required are met.

Most of the Local Plan is very sound but please ensure it is adhered to and strong enforcement of the plan and development conditions are carried out: "Thank you"

DLP_6451

Cranbrook & Sissinghurst Parish Council

  1. RESPONSE TO SITE SPECIFIC ALLOCATION ACROSS THE PARISH AS CONTAINED IN THE DRAFT TWBC LOCAL PLAN

A considerable number of residents have contacted the Parish Council with their concerns over particular sites which we have attached as summary in a separate response [TWBC: see Comment Numbers DLP_6125-6141]. These bring to your attention the draft sites that are causing our parishioners most concern. We submit these on their behalf, so you are aware of where the focus lies at this time. We urge you to treat these concerns with the utmost seriousness, as they are borne from a familiarity with the sites that TWBC will not have.

However, The Parish Council is reserving judgement on all the allocated sites contained within the draft TWBC plan that lie within its boundaries, until such time that the following issues are satisfactorily resolved:

  • Development Assumptions and the NPPF: We need to reach common ground on the assumptions behind the “distribution of development” paper and the interpretations placed upon provisions within the NPPF. These two issues are critical in setting off a chain of events that leads to the high numbers being proposed across the Parish, significantly at odds with our own HNA numbers, and therefore a range of sites needed to accommodate those high numbers, many of which we feel are unacceptable. To make comments on a site-by-site basis makes no sense until the driving forces behind those allocations are properly explained and, then, resolved to our satisfaction.
  • Landscape Sensitivity Report (LUC, 2017): This report concludes there are significant areas of “high” sensitivity across the Parish, yet significant numbers of new homes are proposed. How can the conclusions of this report be squared with the content of the draft TWBC Local Plan? Until such time there is confidence that TWBC takes its own reports seriously, we cannot comment on the individual sites.
  • Neighbourhood planning needs to be consulted: The relationship between neighbourhood plans and the TWBC Local Plan needs to be better defined and the ability for neighbourhood plans to make direct allocations needs to be restored. This ability has effectively been removed by the publication of the draft TWBC Local Plan that contains allocated sites across the whole Borough.
  • Revision of strategic polices: The strategic polices that relate to the Parish need to be revised and adjusted to meet our concerns, including STR/CRS 1 – see earlier in this submission – before we are in a position to comment on specific sites.
  • Improved engagement: The process of engaging local communities with the Local Plan preparation needs to be much improved. We would suggest extra events and further, extended periods of consultation are needed, during which time TWBC can try to better explain its assumptions and reasonings before there will be the level of acceptance needed about the individual sites being put forward.

Only when significant progress is made on all four of these issues, can the Parish consider a site-by-site response to the Local Plan draft allocations.

[TWBC: see full response].

Policy STR/CRS 1: The Strategy for Cranbrook & Sissinghurst Parish

Comment No.

Name/Organisation

Response

DLP_29

Tom Durie

A key priority for new housing is Sissinghurst must be a focus on some housing for the elderly and also provision of 1 and 2 bedroom houses (starter homes) for to enable local individuals and small families to be able to the main in the village. The recent focus on 3 and 4 bedroom houses (away from affordable housing provision) has failed to deliver this outcome.

Housing for the elderly

The recent development of Church Mews missed an opportunity to include provision for elderly housing in the heart of the village. The two single bedroom elderly house in Cobnut Close are located too far from the centre of the village and the village shop. The two residents of these single bedroom elderly houses have been forced to catch the bus into the centre of the village to be able to get to the village shop. The proposed development RRS 14 is a perfect opportunity to address this need for housing for the elderly in the heart of the village. (CRS12/CRS13/CRS15/CRS16 are not suitable sites)

This will have the advantage of releasing to families 2- 3 bedroom houses in the village occupied by a single elderly person.

I and 2 bedroom houses ( starter homes)

In addition to any affordable housing provision, any open market houses included in developments must include 1 and 2 bedroom flats or houses ( starter homes) to offer young people or couples to living is Sissinghurst the opportunity buy properties in Sissinghurst, other than 3-4 bedroom houses. We need to be able to keep the young

DLP_216

Mr Michel Cosh

I have grave concerns over the lack of strategy concerning the provision of adequate additional parking in Cranbrook. The Brick Kiln Farm and Turnden developments will already create significant additional demand for parking space in the town. This has not been addressed so far in the planning submissions that are in the public domain. The development of additional sites such as Rammel Field and Jaeger's Field will further stress parking provision. The assumption that residents from newly developed sites will walk or cycle in to town for shopping is entirely unrealistic. Where are they expected to park when existing car parks are often full to capacity now?

DLP_7899

Michael and Jane Love

We object to the above developments on the ANOB that is Cranbrook and the High Weald . These are beautiful areas that you will ruin and once lost you can not get them back for future generations

DLP_7901

Michael and Jane Love

We object to the development of housing on the AONB that is Cranbrook and Hartley

DLP_7905

Fiona Dagger

The number of new dwellings allocated within the AONB in Cranbrook is too high. Planning Practice Guidance (PPG), revised July 2019, states ‘The National Planning Policy Framework makes clear that the scale and extent of development in [AONBs] should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. Paragraph: 041 Reference ID: 8-041-20190721.

TWBC has failed to limit the scale and extent of development proposed in the AONB and, contrary to PPG, has sought to meet the needs of adjoining non-designated areas within the borough through allocating increased numbers to the AONB (see STR1) .

DLP_7979

Sharon Pickles

Please find below my specific objections to your proposed development plan.  I am appalled at the disregard for the views of the local communities that these proposals will have a massive impact on.

* In addition to my points made in the table below, I would like to add that I have deep concerns with regard to the increased traffic that would result from such a development.  I am uniquely situated to observe the many car accidents that have occurred regularly each year over the many years I have lived in the area.  Traffic travelling between Hawkhurst and Cranbrook is heavy and often exceeding the speed limits.  My house overlooks the junction to Swattenden Lane, with the Glassenbury Road turning on one side and the entrance to a busy farm shop on the other.  Numerous serious accidents have occurred on this small stretch of road, particularly at the Glassenbury Road turning.  To increase the volume of traffic in the area due to the proposed development for housing in this particular vicinity causes me grave concerns.  It is evident that the serious traffic congestion through Goudhurst village (particularly with the hairpin bend by the church) is already at a critical level, and an increase in the number of houses in this area would only increase the volume of traffic going through Goudhurst to an unmanageable level. There seems to be no concern with how the above issues will be addressed.

I strongly urge TWBC to re-engage with NDPs, review the district's true development requirements, ensure appropriate infrastructure is included in all developments and share the impact more fairly across all communities.

DLP_8038

Rose May McAuley

This is about what you want Sissinghurst to look like in the future but it does not say what you are intending for us.  We do not want to be just a place where people come to get their children into private schools, then they work in London and shop at Waitrose and do not take part in the village.  We tried to run a Newcomers Evening for people from Bramling Gardens, Sissinghurst, and one couple turned up.  They do not care about our village and do not want to be a part of it.  We do not want or need more estates like this or Sissinghurst will be killed off as a village after at least seven hundred years of being a successful place to live.

DLP_443

Mr Adair Robson

The village is up in arms about this proposal and streets are lined with  objection posters. See below.

If you go ahead with this proposal you will alienate thousands of people.

DLP_8052
DLP_6497
DLP_6512
DLP_6542
DLP_6650
DLP_6708
DLP_6731
DLP_7678

Sophie Foster
Clare Govan
Philip Govan
Rory Govan
Stephanie Govan
Edward Govan
James Govan
Joe Hughes

TWBC: the standard response was submitted by the list of responders on the left:

The Housing Allocation to Cranbrook & Sissinghurst (also to Hawkhurst), is hugely disproportionate to local needs, as demonstrated by the following table

Population

Maximum housing allocation

%age allocation per person

6,700

918

13.7%

4,991

731

14.6%

48,324

1,320

2.7%

Item no.3 requires that development proposals will be required to establish the impact on Hawkhurst and the Flimwell crossroads. But of much bigger significance is the impact on the A262 in Goudhurst which is the route used  by the entire Parish to travel to work or to shop in Royal Tunbridge Wells.  Support services, including HGVs, also use this route, notwithstanding the warning sign “unsuitable for long vehicles”.  The A262 through Goudhurst is narrow and the corner by St Mary’s Church is notorious for problems when large vehicles travelling in opposite directions meet there.  There is no scope to widen the road.  This regularly causes extended hold-ups and there has been damage to buildings and to the churchyard wall. New housing in Cranbrook & Sissinghurst parish should be restricted to local need and not used to meet the housing requirement generated by Royal Tunbridge Wells.

DLP_8140

Hume Planning Consultancy Ltd for Meadow View Construction Ltd

Policy STR/CRS 1 – The Strategy for Cranbrook and Sissinghurst Parish

As noted above in our comments on Policy STR 1 [TWBC: see Comment No. DLP_8137], we support the proposed expansion of Cranbrook, and encourage the Council to maximise the development potential for this sustainable settlement in order to help meet the Borough’s identified housing needs. In this context, we consider that the land west of Freight Lane (as identified at Appendix 1) represents a significant opportunity to deliver a sustainable residential extension of the existing town, and would provide a number of notable benefits.

Whilst the site currently comprises undeveloped, greenfield land, an important consideration to be taken into account is the allocated land immediately to the west. This allocation covers the area from the western boundary of our client’s land, up to Hartley Road and extending to the edge of the existing limits of the existing built form on Green Way to the north. This land (known as ‘Land adjacent to the Crane Valley’ or ‘Land at Brick Kiln Farm’) has been allocated for residential development (by Policy AL/CR 4) of the adopted Site Allocations Local Plan, and benefits from a resolution to grant planning permission (from March 2018) for the delivery of up to 180 dwellings (LPA ref. 16/502860/OUT). As such, the character of this parcel of land will change significantly as a result of the proposed adjacent development, and the land west of Freight Lane would comprise a logical second phase to this development, infilling the gap between the proposed development at Brick Kiln Farm to the west, and Freight Lane, to the east.

As part of this second phase of development to the east of Brick Kiln Farm, there would be the potential to provide a vehicular, cycle and pedestrian route through both parts of the development to link Hartley Road and Freight Lane. This would assist to disperse traffic currently travelling along Hartley Road and the High Street and provide an additional, safe and convenient route for traffic to travel east-west through Cranbrook without the need to enter the town centre. It is not possible to delivery this road link through the allocation of the Brick Kiln Farm (Policy AL/CR 4) in isolation.

In addition to this, the allocation of the site promoted in these representations would allow for the land to the east of Freight Lane to come forward for the future delivery of further homes. This SHLAA review of this site (site ref. 25) identified that the reason it was not suitable for allocated was due to vehicular access. This was concluded on the basis that the site’s redevelopment would add further highways pressure onto Freight Lane, Frythe Way and through the town centre. The development of the land subject to these representations would allow the provision of the alternative vehicular link onto Hartley Road to relieve this matter and unlock this site for redevelopment.

SHELAA Review

With regard to the suitability of the land west of Freight Lane for residential development, we note that the July 2019 SHELAA, which was prepared to inform the current consultation document, considers that the Site would “make a logical extension of an existing allocation adjacent” and is both available and deliverable.

Furthermore, the Council’s SHELAA assessment considers (site ref. 396) that the site scores “largely neutral with some benefit to housing provision” in terms of the sustainability assessment. However, the assessment goes on to note the potential for negative landscape impacts due to the loss of an historic field in the AONB. We disagree with this aspect of the Council’s assessment, and consider that the perceived impact on the landscape and AONB has been overstated. Whilst the SHELAA does not provide further evidence to justify the assumed harmful landscape impact, we note that the site is well contained and would represent a logical infill of the gap between Freight Lane and the forthcoming development at Brick Kiln Farm, thereby resulting in a limited and acceptable landscape impact.

In addition to this, the SHELAA’s assessment of the eastern part of Site Allocation AL/CR 4 (identified as Site 292 – ‘Land at South of High Street’) assesses it to be “a mostly negative site”, which is scored “highly negatively for many environmental objectives”. However, the assessment goes on to state that given the site is part of an existing allocation and is adjacent to the settlement edge it is likely to be considered sustainable. We would therefore suggest that there is an inconsistency in the approach to site allocation having regard to the SHELAA assessment; the land west of Freight Lane is not assessed any more negatively than the adjacent allocation, and consequently, in our view it would be unjustifiable to allocate one site but rule out the allocation of another given the similarities between them (and arguably the greater suitability of the land promoted in these representations). We therefore contend that the proposed exclusion of the land west of Freight Lane from the list of allocations for Cranbrook is unjustified, having regard to the tests of soundness at paragraph 35 of the NPPF.

We anticipate that future development of the land west of Freight Lane has the potential to incorporate significant landscape buffers and an appropriate layout to mitigate any impacts on the landscape. We are not aware of any significant constraints that would prevent the future development of this site, and development proposals would be informed by detailed technical studies to ensure any proposals would be entirely acceptable with regard to all relevant technical considerations. As part of any redevelopment proposals there would also be the opportunity to provide the necessary offset from adjoining Ancient Woodland and the opportunity to enhance the existing boardwalk pedestrian footpaths toward the town centre.

Cranbrook

In the wider context, development to the south of Cranbrook is considered the most appropriate, and least constrained option, for the growth of the town. As identified on the draft Proposals Map, there are many constraints to development to the north, east and west of the town, including; Historic Park and Garden designations, recreation and sport, Ancient Woodland, and Designated Sites. By contrast, the land to the south is relatively unconstrained and the land west of Freight Lane could be easily included within the updated settlement boundary and incorporate a generous landscape buffer to its southern boundary to create a logical ‘rounding off’ of the settlement.

Development in this location would make a significant contribution towards the housing need identified in the Local Plan and is capable of being delivered at an early stage of the Plan period, thereby assisting the Council to maintain a robust supply of housing as required by paragraph 67 of the NPPF. The redevelopment of the site would also support the vitality and viability of local services and facilities, and as part of the proposals there may be the potential to provide enhancements to the nearby Crane Valley Local Nature Reserve and create additional green infrastructure and accessible green open spaces for the benefit of the local community.

Having regard to the above points, we therefore encourage the Council to reconsider its strategy for Cranbrook and to allocate the land west of Freight Lane for residential development at Policy STR/CRS 1, in order to ensure that the proposed strategy is positively prepared and justified, and thus sound.

The draft Plan includes nine housing allocations in Cranbrook accommodating between 474-559 dwellings and a number of these sites lie in more peripheral positions than the land promoted in these representations. In particular, Draft Site Allocation CRS4, Turnden Farm, Hartley Road has been allocated for up to 134 additional dwellings and is more visually prominent and more poorly related to the existing settlement. Whilst Draft Allocation CRS7, Land off Golford Road has been allocated for approximately 150 dwellings and is referenced as being “detached from the existing Cranbrook Limits to Built Development”. The site is considered to be comparatively more open and exposed in landscape terms as well as being more distant from the town centre. In this regard it is considered that the land to the west of Freight Lane would make a more suitable allocation than these parcels and should therefore be considered further for allocation in the emerging plan.

Summary

We have set out above our comments, on behalf of Meadow View Construction, on the Regulation 18 consultation draft of the Tunbridge Wells Borough Local Plan (September 2019), and we welcome the opportunity to work collaboratively with the Council to identify a sound development strategy. We support the intention to meet the identified housing needs of the Borough, and to accommodate a portion of this housing need at Cranbrook, which represents a sustainable and suitable location for growth.

However, we encourage the Council to ensure the development strategy for Cranbrook is sufficiently justified, and in this regard, we consider that there is a compelling case for the allocation of the land west of Freight Lane for residential development given the positive SHELAA conclusions. We therefore request that the Council reconsiders the merits of allocating this site for development within the Regulation 19 draft of the Plan.

The site is in single ownership and there are guaranteed access rights across the already allocated site to the west (Allocation AL/CRS 9) to deliver a road connection between Angley Road and Freight Lane to bypass the High Street, this would deliver transport benefits to the wider community and existing residents.

The site also has the ability to deliver up to 100 dwellings by 2023, and would be able to do so in an approach is consistent with Paragraph 172 of the Framework.

We respectfully ask that our comments are considered and that the necessary modifications are made to ensure the soundness of the Plan. In the meantime we would be pleased to discuss this site in further detail with officers should the opportunity arise.

DLP_8175

Highways England

No/Type:

Distance to SRN:

Impact:

Current traffic flows:

Recommendations

100-115 residential dwellings (5 sites)

+15km

A21 / A299

+25km

M20 J7/J8

No / minimal impact

NA

NA

718-803 residential dwellings (9 sites)

Some large developments proposed >100  dwellings

Community uses, employment uses, playing fields and sports facilities

Safeguarding land for future primary school expansion

+12km

A21/A268

Some impact expected at the A21/A268 (Forstal Farm roundabout) – even though it is >10km from the sites, this is primary route for vehicles joining A21 northbound.

Current traffic levels show as reasonable at the A21/A268 roundabout during weekday AM and PM peak.

Given multiple proposals are for >100 dwellings, we recommend a full transport assessment accompanies proposal. TA should include junction modelling for A21/A268 roundabout.

TWBC: see Technical Note. See also full representation].

DLP_658

Michael and Marie Cowman

We have lived in Sundial Cottage Golford Road Cranbrook TN17  3NW since 1978, and have enjoyed the peaceful, tranquil surroundings.

We wish to object to the above planning application for 900 houses to be built on land at Golford Road for the various reasons:-

Over the past ten years the traffic past our house has increased beyond all recognition.

We have had several near misses when cars, lorries  and buses frequently cross the white lines especially round the dangerous bend near the sewer works doing excessive speed. We are unable to cycle to the shops in the town now because we have both nearly been knocked off our bikes by passing traffic. We feel speed restrictions should be put in place near this dangerous bend.

More property being built will cause the volume of traffic to increase so much it will be unbearable and more dangerous for pedestrians and residences in and around the Golford Road, Chapel Lane and Sissinghurst areas.

The parking facilities in Cranbrook is becoming a nightmare and will only get worse with more houses being built. As we are both retired we rely on using our own transport to use the local shops which we have always supported.

The size of the proposed development will destroy the lovely community of Cranbrook and Sissinghurst and will affect the wildlife habitat.

We strongly object to this plan and trust you will take these points into account and refuse permission.

We are happy for you to proceed to pass our comments onto Policy  STR/ CRS 1 as we believe this relates to future developments right opposite our property which is our main concern as it will ruin the beautiful rural outlook. This will also have a knock on effect which will result in devaluing our property.

The proposals of nine sites in this area will still have a disastrous affect on Cranbrook and Sissinghurst, mainly the safety of all its residence with the increased volume of traffic, lack of parking facilities and its amenities, as we feel enough development has taken place here over the last five years.

We look forward to receiving any correspondence concerning future stages on Local Plan preparation including meetings we can attend.

DLP_707

Patricia Preston

Firstly general objections and observations on the Cranbrook and Sissinghurst Draft Local Plan

TWBC doesnot need to accept nor should it, the level of housing proposed by the Government. The national policy allows for development to be reduced where valued landscape can be damaged (NPPF Para 11), 70% of the borough is protected as an AONB.

Why hasn't TW assessed the harm that cumulative development can do to the AONB landscape and its communities and argue for a lower housing number as a result.

The Parish Council has assessed the housing need which is a lower figure than TWBC have chosen. (Truly)Affordable housing is needed. None of which appears to be available on the TWBC plan.

Surely all housing allocations made should be small scale reflecting the small scale character of the high Weald AONB, which was created by people, by hand and is one of the best preserved medieval landscapes in North West Europe.

Why has TWBC ignored its own policy set out in the draft local plan, its AONB Management Plan to focus development on small scale sites. The following are not small deveopments:  90 houses for AL/CRS6 Map 49- Gate Farm and Bull Farm, even larger AL/CRS7 Golford Cross 150 and AL/CRS4 Turnden 134.

Paragragh 172 of the NPPF states major development should be refused in an AOBN unless there are exceptional circumstances. In view of the fact that the AONB designation is a national designation, then by logical inference exceptional circumstances should be national in character. TWBC just wishing to put housing in an AONB is not good enough justification.

STR1. Bullet 8. TWBC have not demonstrated that the major development tests set out in the NPPF, Para 172 have been adequately considered and therefore met for sites in the AONB. Furthermore that consideration by TWBC of the adverse impact of development on the AONB is cursory at best. Therefore, TWBC have not demonstrated that the 'duty of regard' for the conservation and enhancement of the AONB, placed on them by Section 85 of the Countryside Rights of Way Act 2000 has been properly discharged.

TWBC needs to assess the harm that cumulative development can do to the AONB landscape

The small country lanes are already busy, if 900 houses are built in Cranbrook and Sissinghurst parish that would be a minimum of 2000 vehicles. So greatly increasing queues, driver frustration and accidents. There is not the infastructure to cope with this amount of housing especially when it is not needed by the local community. Doctors' surgerys already at full capacity. So more driving to out of parish doctors.

Employment centres are all 14 miles or more away - Maidstone, TW, Hastings, Ashford etc. So require a car to get there. There are already 'pinch points' - Goudhurst, Flimwell and Hawkhurst. As well as severe conjestion for traffic heading to Maidstone and Ashford. Staplehurt and Marden station car parks already full at peak times.

Bull Farm. CRS6

In 1999 when Bull Farm was sold a 'blue line' was put around the barns and fields by TWBC. This was to stop the farm being broken up and sold off in more profitable smaller units. This now appears to be exactly what TWBC are trying to do. That is not taking any notice of your own legislation.

West of Glassenbury Road B2085.This land is at 125m, a high ridge. Consequently it can be seen for miles across Bedgebury Forest. Filmwell radio mast is over 3 miles away, (as the crow flies) can be seen and Kilndown. So any development here will be visible across Bedgebury Forest and Combwell woods etc. Goudhurst is only 126m. A blight on the skyline. Bedgebury Forest and ancient woodlands are approx 200m away. Close by is Robins Wood SSSI. A truely rural area. TWBC will destroy these view in an AONB.

Bull Farm B1/B2/B8 are proposed as employment units. There are approx 4 farm buildings in this area but by far the greater proportion is permanent pasture. The development would potentially destroy species rich grassland and its associated soil micro-fauna and mycorrhizal fungi. The long- established features on site, and particularly adjacent species rich grassland which is a priority habitat for protection nationally as well as locally, support critical characteristic wildlife species.

As this area is so high there will also be noise and light pollution from industrial units (so called employment units), and houses. Any lights will be visible across the whole of Bedgebury Forest and more of the surrounding AONB.

If employment units are built there will be increased traffic - probably more than just cars. These larger vehicles will require access to B2085 which will either be at the Bull Farm entrance or Bishops Lane. Bishops lane is an unpaved bridleway used by horses, rambler, D of E children totally unsuitable for traffic. This lane joins the B2085 about 10m from the junction with the A229 an already busy, dangerous  junction. All exsisting pinch points- Hawkhurst. Flimwell, Goudhurst will be worsened.

I strongly object to the proposed Draft Local Plan for Cranbrook and Sissinghurst. Especially development at Bull Farm as it is in an AONB, visible and audible for miles as on top of a ridge. Traffic generated would cause congestion and danger on Glassenbury Road and junction with the A229. Many would be travelling to Staplehurst station causing more traffic on the A229. Or going to Tunbridge Wells through Goudhurst causing more conjestion in that village, the  A262 already has suggested HGV limitation as the corners by the church are so tight.

DLP_8293

NHS West Clinical Commissioning Group

General Observation

The CCG notes that the policy details that it is expected contributions will be required towards health and medical facilities, to mitigate the impact of the development in Cranbrook.

There are currently three small general practices located in Cranbrook. The current premises are not suitable for the longer term and do not have the capacity to accommodate the level of growth proposed in the area (estimated c1900 new patient registrations from Cranbrook and c2500 in total within boundaries of practices). This is an identified priority area in the CCG Estates Strategy and the three practices submitted a proposal to the CCG in October 2018 to explore and develop plans for a new general practice premises in Cranbrook for all three practice to re-locate to. The three practices have also signalled that it is their intention that they will merge into a single general practice at the point new premises is available. An options appraisal of potential sites is to be undertaken. The General Practices will be required to identify capital funding for the scheme. Provision of land as part of the local plan will be required to support a new general practice along with contributions from other allocated sites.

Planning for growth in general practice is complex; physical infrastructure is one element but alongside this workforce is a critical consideration both in terms of new workforce requirements and retirements. Any plans developed need to support delivery of sustainable services for the future. It is therefore important that in order to ensure proactive development of premises capacity the trigger of any healthcare contribution should be made available linked to commencement or at an early stage of development.

As plans are developed they will be considered in line with the CCG’s premises development policy and process; this is a three stage process with final approval provided at Stage 3.

DLP_958

Mrs A Marley

In Distribution of Development Topic Paper in Development Constraints 70% to the Borough in High Weald AONB. I consider this a severe constraint and should be regarded accordingly.

DLP_966

Mrs A Marley

Development Constraints 70% of Borough in High Weald AONB. I consider this is a severe constraint and should be regarded accordingly.

DLP_1023

Tim and Sheenagh Nicholson

Summary

The numbers of houses proposed is far too high. Tunbridge Wells is protecting itself by pushing enormous developments out to the small towns and villages around it, when there are clear options elsewhere for development on this huge scale, for example the corridor between TW and Tonbridge along the A21.

Our community should expect the Borough Council to offer it some protection; clearly that is thought too troublesome. It should be conducting a tough defence of the AONB.

We need clear commitments to the mix of affordable homes. Hundreds of new “executive” homes may suit developers, but will not suit this community. We need this in advance of building.

There are sites where development would be acceptable, even welcome, but the numbers proposed for each are far too high. There should be no mass development in the inner town bounded by Angley Road, High Street, Stone Street and Waterloo Road.

Your proposals mean at least another 2200 people and 1000 cars; you offer no commitments to infrastructure other than vague comments that such matters will be dealt with later “if thought necessary”. If local support is wanted (as it should be though we get the feeling that the plan is already set) then a detailed infrastructure plan, covering all of the matters mentioned below, should be submitted for scrutiny and consultation in advance of any building.

You brush aside concerns over conservation and bio-diversity with such extraordinary sentences as “… to be informed by a comprehensive Landscape and Visual Impact Assessment, ecological studies and a heritage assessment…” Where are they? Please explain how you can put down 900 houses on green field sites and enhance conservation and bio-diversity.

Introduction

We have read the local plan with some care. We can only comment on that section of it that applies to Cranbrook. We have lived in TWBC since the early 80s and in the Parish of Cranbrook and Sissinghurst since 1995. Our three children attended Cranbrook School, the first from 1983. We have a stake in this town. We are extremely concerned about the proposals put forward in the TWBC draft borough-wide Local Plan. We do not feel able to comment on the proposals for Sissinghurst, although the additional people and vehicles there will add to the overwhelming impact for the Parish as a whole. We note the many references to other documents and policies; these are meaningless to us. We cannot be expected to source all of these; it is for you, the professional planners, to present the key information in a complete way. This feels like a simple numbers game, not a serious and thought through plan.

We understand that Cranbrook School has been engaged in discussions with the TWBC planners. If that is so then any comments we make regarding allocation of land now in school use will be from the point of view of town residents, and not the school itself. The mooted “masterplan” for the school will make interesting reading if we ever see it.

It is unlikely that any realistic resident of this Parish believes that Cranbrook should not take some development. Indeed, some will be welcome. The key issues are about numbers, infrastructure, conservation and the environment. The entire development draft proposal lies within the High Weald AONB although this does not seem to offer any protection, and it is noted that the local plan already being developed within the Parish has been largely ignored, and that building is already underway on several sites. We note that Tunbridge Wells with a population of around 120,000 people will take an increase of hardly any more than Cranbrook, with 7000.  The A21 corridor for example, is an obvious option for development on the scale you are proposing. These proposals swamp this and other small communities.

We consider that TWBC is shirking its duty by deciding not to “push back” against excessive development. We cannot see what difference it makes to infrastructure supply if we agree with an imposed solution or not. The decision of where houses are to be built is being taken out of our hands anyway; frankly we appear to have nothing to lose and may have something to gain from a strong response which does not meekly accept Central Government diktat. It look as if TWBC is protecting its own position, rather than the needs and expectations of the towns and villages in its Borough. Clearly it will not support us in any fight to find an acceptable level of development. More encouragingly our MP, Helen Grant, takes a contrary view that our towns and villages must not lose their character. To quote from an email received from her recently “The message on housing is very clear. Whilst people recognise the need for more homes to be built; they do not wish it to be at the expense of our unique rural communities. I will therefore continue to only support housing developments which are in the right numbers, in the right places and, crucially, supported by the required infrastructure.” We wish TWBC shared this view.

The TWBC Approach

On the second page of your note covering the TWBC Plan you write “The borough has adopted a “bottom up” approach to its allocations, based on the supply of land put forward in the “Call for Sites”. The motives for putting forward sites will invariably be commercial and the value of agricultural or amenity land included will be hugely enhanced. It is a given that little or no consideration to conservation, heritage and the needs and wishes of the people of the Parish has been given by those with land to dispose of profitably. To simply work on the assumption that any site put forward can be taken over, and houses slotted in to a commercially advantageous size and style in some computer generated density is irresponsible. We object to this simplistic and frankly callous approach.

Affordable Homes

Even at this early stage (and as building is going on at several sites already, there is little time to resolve this and the many  other issues arising from this Local Plan) there should be clear commitment to homes designed to suit the town’s local people, including a good proportion of housing association or similarly protected properties. Top priority should be homes for local people: a high proportion of the “executive” properties, preferred by developers will be priced way above the pockets of most of those in the town looking for a home. At the entrance to the currently under development Turnden Lane site is a large billboard with the message “2, 3 and 4 bed luxury homes”. Will all the young people in Cranbrook, who will never be able to afford one of those “luxury homes”, have to look elsewhere to live, whilst developers make handsome profits? We want to see clear commitment to a fair proportion of genuinely affordable homes, as part of permitting any development. There must also be control by the community over the number of house that are sold to other authorities with a view to them shipping out their “homeless”, who are likely to need a great deal of medical and social support. It is no good saying that all this “detail” will be dealt later; it must be dealt with now, before building starts.

Sites

We do not propose to comment on every proposed site. At such as Turnden, Brick Kiln Farm and Golford Road there is space for some development, but the numbers proposed are far too high. They should be reduced and much more attention within them paid to amenity space and parking. We do object to development within the area bounded by Angley Road, High Street, Stone Street, and Waterloo Road up to its junction with Angley Road. Building in this area will cramp the town, and remove amenity and leisure space for those living in the inner town. It is absolutely vital that our primary school is not hemmed in, as appears to be the plan, as it will need considerable expansion.

Infrastructure.

Current situation. We suggest that Cranbrook infrastructure just about supports the current population. It cannot support these proposals. We have heard nothing from anyone about the infrastructure upgrades that will be need for homes already being built, except for arrangements for access to the Brick Kiln site at the top of the High Street. Angley Road takes a lot of traffic away from the town centre; people can see a doctor, get a school place, go for a walk in pleasant surroundings, and, eventually, find somewhere to park. There is a lot of cultural and sporting activity. Whilst things are far from perfect we should regard ourselves as fortunate, compared with many other communities. It would seem that all that is about to end, as our country town becomes a much more urban area, congested and uncomfortable to live in. Until there are firm plans to meet medical and educational requirements, with road enhancements and large vehicle restrictions, and greatly increased parking places, with enforceable commitments to upgrades to utilities’ capacity, how can you possible expect support from the local community? Further comment on infrastructure below under several headings.

Numbers. 900 new homes will, according to the Office for National Statistics (ONS), have on average 2.5 occupants, a surprisingly low figure but no doubt takes account of inner city numbers with many low occupancy small flats. Even at this rate there will be 2250 more people living in the Parish. We believe that the current population is around 7000, so an increase of more than 30%. If we take the lower figure of 5000 homes in the next five years this is 1250 more people. According to STATISTA average car ownership in the South East is 1.4 cars per household, so 1260 more vehicles from 900 homes or 700 from 500.

People. It is truly astonishing that any Local Plan on whatever scale can dismiss residents’ needs in such a cavalier way. Paragraph 11 on page 196 waves away the problems that these sort of numbers will create, with sentences such as “it is expected that contributions will be required towards the following if necessary”… (our highlighting). Of course they will be necessary, and should be detailed. To say, for example, with no consultation with patients, nor perhaps with medical practitioners in the town, that “the three medical practices in the town will be combined into one” is simply dismissive of what people are likely to want. “You will get what you are given” appears to be the attitude. It is unacceptable for a response to comments of this kind to be that these matters will be addressed at some future date. They need to be addressed in detail, and consulted on, now, before any more builders move in.

Parking. We note that the three car parks are to be retained. At present the Tanyard car park is always full, mostly we think with residents’ cars as they are there night and day. Jockey Lane is full for much of the day, and parked cars back up along Wheatfield Drive and Carriers Road, causing obstructions. The Regis/Co-op car park generally has a few spaces at the Co-op end at any given moment. The High Street has parking along some of its length, sometimes on both sides. These places are taken most of the day and much of out of hours. On the High Street, from the Co-op exit uphill, cars and especially larger vehicles often cannot progress because of parked vehicles, but have to wait, which also makes crossing the road quite difficult at times for pedestrians. That is now; it will get unmanageably worse. We will need a lot more, 200 plus, public parking spaces; any belief that people will walk into town for their shopping from the outlying development areas is, we suspect deliberately, naive. And no homes should be built without at least two dedicated parking spaces, excluding garages.

Roads. Vehicles navigate through town one way or another, with, as noted above, through traffic using Angley Road. The High Street and Stone Street can barely manage the traffic volumes at times during the day as it is. Buses struggle (and find their stopping zones obstructed by parked cars “just for a minute”). TWBC probably feel that as roads are not their concern they can ignore the topic in their planning. Short of knocking houses down the roads cannot be made any wider. Any development plan on the scale proposed must also include a detailed traffic plan which recognises limitations to what can be achieved and does not imply that a magic wand can be waved by some insightful planner. These people are supposed to be professional town planners; do they expect residents to come up with deliverable road and other infrastructure plans?

Conservation. We have noted that being in an AONB appears to mean nothing and gives no protection. It is a requirement (page 196 paragraph 4) that “it should be demonstrated that the proposal will make a positive contribution towards achieving the objectives of the most recent AONB management plan…” Such sentences as “the location of built development to be informed by a landscape and visual impact assessment and by a heritage assessment” and mention of “net gains for nature…and biodiversity”, or “informed by a comprehensive energy and climate change strategy” are inserted to deceive the reader and are effectively meaningless. Where are these assessments and studies, so that we can study them? Mere words will not clean the air nor encourage wild life.

Heritage. We are not sure what precisely might come under this heading, but we can be sure that the character of this old High Weald town will be changed forever. Open space will be filled with development, streets will be blocked with more cars than the roads can handle with cars parked everywhere including where they should not be, school places will be at a premium, patients will find themselves with a “pass the parcel” system rather than one in which patient and doctor can know each other, air quality will decrease and water sewage and energy provision will be under stress.

Conclusion. Development numbers need to be greatly reduced, halved at least, and there should not be any multiple building within the inner town area, as defined above. The numbers of housing association or other covenanted homes needs to be agreed now for each site.  A detailed infrastructure assessment needs to be done NOW, proposed, consulted on and agreed, and not after the houses are up and sold. TWBC is shirking its responsibilities to look after its residents and despite what are intended to be comforting, oft repeated assurances about impact assessments and reference to uncounted other documents somewhere in the TWBC archives, conservation, heritage, and quality of life will all be losers. As it stands, this will be bad for our town.

DLP_1025

Mr and Mrs Copping

In summary; I appreciate that people need to be housed.  I question whether a standard calculation can be used borough wide to ascertain and forecast how many houses will be needed. Each village and town have different characteristics which will attract or prevent people wanting to live there. Once the developments have been built; people may not actually want to move in!! Cranbrook’s population is currently estimated at 6,500; the proposed development will increase that by 1000 - people may start actually moving away if the infrastructure  cannot support it 

A new development of 200 houses  in Cranbrook would realistically have 400 cars if  two working adults lived in each house.  800 cars if each house had 2 grown up children.  The Roads in Cranbrook would not cope with the extra congestion.  Within the Draft Plan it states Developers would have to carry out assessments to minimise traffic impact. ANY development will impact the existing infrastructure.  How will the Council fund upgrading the roads to accommodate the extra congestion when our existing road surfaces are full of pot holes now ? 

Other concerns

Strain on an existing medical service which is at breaking point now

DLP_2493

Mr John Wotton

Policy STR/CRS 1 The Strategy for Cranbrook and Sissinghurst Parish

object to this policy. Cranbrook & Sissinghurst Parish has a number of characteristics which militate against significant growth in population or employment. Cranbrook lies wholly within the AONB. It is a town of immeasurable historic and architectural interest, replete with listed buildings and other heritage assets and having an important Conservation Area at its historic core. As the Conservation Area assessment recognises, the rural setting of the town contributes greatly to its interest and importance. It is a small town with narrow streets, both features which contribute to its architectural interest and to its attraction as a place to live and a destination for visitors, who contribute to the local economy.

In addition to the historic core of the town, there are nearby settlements in the Parish of great architectural and historic interest, notably Sissinghurst and Wilsley, each of which contains a Conservation Area, the rural setting of which merits protection. Elsewhere in the Parish, both inside and outside the AONB, are small settlements, such as Collier's Green and Hartley and isolated farmsteads, all reflecting the historically dispersed settlement pattern of this part of the High Weald. Throughout the Parish are traces of the field boundaries of the medieval farming landscape, which is I understand better preserved in the High Weald AONB than anywhere else in the country.

Having regard to these considerations, growth in Cranbrook & Sissinghurst Parish should be limited to well-designed, small scale developments, either (i) on brownfield sites within existing LBDs, (ii) on sustainable greenfield sites well-related to existing settlements; or (iii) on existing historic farmsteads in sustainable locations and in accordance with the Council's policies on farmstead developments. No such development should harm the AONB or any of the Conservation Areas in the Parish.

No major development site in the AONB should be allocated in the Parish. The tests of exceptional circumstances and public interest under paragraph 172 NPPF, which must be met for any such developments to be permitted, are not satisfied. My reasons for reaching this conclusion are set out in my comments on the Distribution of Development Topic Paper

This approach would require a much lower housing allocation than the 713-803 new homes provided in this Policy. I consider that it requires a lower allocation than the 612 new homes estimated by consultants retained by the NDP Group. Neither level of expansion of Cranbrook & Sissinghurst could be achieved, making use of the sites put forward for development, without (1) permitting a number of major developments within the AONB, for which no exceptional circumstances exist and on sites with a negative sustainability assessment; and/or (2) allowing some or all of the distinct settlements of Cranbrook, Wilsley, Sissinghurst and Hartley to coalesce and thereby prejudice the historic settlement pattern of this part of the AONB.

I support the comments made by CPRE Kent on Local Plan Policies relating to the Parish and those made by the High Weald AONB Unit. I support the general approach taken by the Cranbrook & Sissinghurst NDP Group to development in the Parish, though not necessarily all the allocations they propose.

I declare interests as a member of the Cranbrook Conservation Areas Advisory Committee and a Trustee of Cranbrook School. I do not comment on any allocation policies affecting land owned by Cranbrook School Trust or Cranbrook School..

DLP_2513

Mr Guy Dagger

The number of new dwellings allocated within the AONB in Cranbrook is too high. Planning Practice Guidance (PPG), revised July 2019, states ‘The National Planning Policy Framework makes clear that the scale and extent of development in [AONBs] should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. Paragraph: 041 Reference ID: 8-041-20190721.

TWBC has failed to limit the scale and extent of development proposed in the AONB and, contrary to PPG, has sought to meet the needs of adjoining non-designated areas within the borough through allocating increased numbers to the AONB (see STR1) .

DLP_3022

Cranbrook Conservation Area Advisory Committee

OBJECT

The number of houses planned for Cranbrook and Sissinghurst is too high, at least 50% above the AECOM study of Housing Need prepared for the Neighbourhood Plan in 2017. So much housing in a relatively short space of time will have a detrimental impact on the historic character of both settlements.

See also comments above on 4 4.7; 4 38; 4.59 and 2 2.25 which relate to local housing need

The scale of housing, with many large estates of new houses, to be built by a single developer, is also inappropriate. Smaller, individually designed new housing which can add to the character of both settlements. is what is required.

There is too much development proposed on the AONB land surrounding Cranbrook and Sissinghurst, which is recognised as one of ‘the best surviving medieval landscapes in Northern Europe’ as quoted in TWBC’s own policy EN21. This rural landscape provides an important context to the Conservation Areas of Cranbrook, Sissinghurst and Wilsley and the many listed buildings outside the CAs. Development on AONB is also contrary to the NPPF which states that ‘great weight should be given to conserving and enhancing landscape …in the AONB.

DLP_3023

Cranbrook Conservation Area Advisory Committee

INDIVIDUAL SITE ASSESSMENTS FOR CRANBROOK AND SISSINGHURST

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

On this basis Cranbrook and Sissinghurst could deliver around 40% of the housing numbers, a more achievable target in addressing locally assessed housing need and easier to integrate successfully over the Plan period. Although this clearly involves some regrettable development, these proposals fit better with the sustainability principles of the NPPF, being nearer to settlement centres and also does less damage to the heritage of Cranbrook and its surrounding AONB landscape.

DLP_3433

High Weald AONB Unit

The number of new dwellings allocated within the AONB in Cranbrook is too high. Planning Practice Guidance (PPG), revised July 2019, states ‘The National Planning Policy Framework makes clear that the scale and extent of development in [AONBs] should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. Paragraph: 041 Reference ID: 8-041-20190721.

In our view TWBC has failed to limit the scale and extent of development proposed in the AONB and, contrary to PPG, has sought to meet the needs of adjoining non-designated areas within the borough through allocating increased numbers to the AONB. Cranbrook and Sissinghurst Neighbourhood Plan assessed the local housing need of these settlements as 610. The draft Local Plan allocates 918 to these settlements. The difference between these two figures clearly represents need from outside of the AONB which should not be accommodated within it.

We support point 4.

Point 6 should be amended to read ‘All development proposals will ensure that landscape gaps between individual areas of the parish and between villages, hamlets and their surrounding farmsteads are retained to prevent coalescence of development.

DLP_2937

Garry Pethurst

I feel there are many fundamental errors in the process adopted by TWBC in the creation of the Draft Local Plan in general, and the place shaping policies, in particular. I have attached a document that the individual elements of Policy STR/CRS 1 on a line-by-line basis; some I feel can be supported, but many need to be looked into much more closely.

[TWBC:  attachment has been entered, as follows]:

Policy STR/CRS 1

The Strategy for Cranbrook and Sissinghurst Parish

At the parish of Cranbrook and Sissinghurst, as defined on the draft Policies Map, proposals shall accord with the following requirements:

1. Approximately 718-803 new dwellings will be delivered on nine sites (*) allocated in this Local Plan in this plan period (Policies AL/CRS 1-9) and approximately 100-115 new dwellings on five sites in Sissinghurst (Policies AL/CRS 12-16) in this Local Plan in the plan period. (*) Of these sites, the following already have planning permission: AL/CRS 4 for 36 dwellings and CRS 8 for 28 dwellings;

The overwhelming feeling within the community is that the numbers are too high for a small town and village like Cranbrook and Sissinghurst. The DLP covers the period 2016-36, yet the numbers do not take into account any building carried out across the parish in the last three years. The numbers also do not recognise the Housing Needs Assessment carried out on behalf of the emerging Neighbourhood Development Plan, which identified a need for 610 houses. The proposed number of new dwellings is clearly based upon land put forward through the ‘Call for Sites’ process, and not on the needs of the parish. This is supported by the comments made by Cllr Alan McDermott during the Parish Council meeting of 9th August 2019. It is clear that this is a policy adopted by TWBC across the east of the borough, and having a detrimental effect on Hawkhurst and Horsmonden, as well as our parish.

2. Additional housing may be delivered through the redevelopment of appropriate sites and other windfall development in accordance with Policy STR 1;

With the number of potential farmstead type developments within the area, the cumulative impact on the parish could be significant, with limited opportunities to establish control over developments, or recognise the local need for truly affordable housing. There are already a number of proposals for ‘the magic nine’. A more realistic figure for windfall development would be, say, six.

3. All development proposals will be required to establish the impact of the proposed development upon Hawkhurst and the Flimwell crossroads (junction of A21 and A268);

This is a nonsense requirement and, clearly, shows the ignorance of TWBC in terms of the predominant direction of travel from the parish; there is no recognition of the major bottleneck at Goudhurst, the subsequent impact on the junction of the A21 at Lamberhurst, or the fact that the majority of train journeys will commence at Staplehurst.

4. Where a site is within the AONB, it should be demonstrated that the proposal will make a positive contribution towards achieving the objectives of the most recent AONB Management Plan and show how relevant guidance from the AONB Joint Advisory Committee has been considered to meet the high standards required of the other policies in this Plan for the High Weald AONB landscape;

All the sites in Cranbrook are within the AONB, and just four of them are intended to provide nearly 700 dwellings. These large-scale developments are totally against the principle of the AONB, and should provide an opportunity for TWBC to resist the numbers of dwellings imposed by government. That they do not diminishes any faith we may have that they will enforce the high AONB standards on developers.

5. Sites outside the AONB but within the High Weald National Character Area, or close to the boundary of the designated AONB landscape, will have similar characteristics and are likely to contribute to the setting of the designated landscape. The AONB Management Plan and any supporting guidance will be a material consideration for these sites;

Sissinghurst will take a lot of convincing that this is the case.

6. All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development;

There are major concerns that so much green space will be lost that coalescence is inevitable; witness Brick Kiln Farm and Turnden, Wilsley Farm, Mill Lane.

7. Maintenance and enhancement of, and/or linkages to, public rights of way or the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility; to include contributions towards the proposed Bedgebury to Sissinghurst cycle path route;

Supported, but this is a minimum requirement.

8. The following public car parks within Cranbrook and Sissinghurst, and as defined on the draft Policies Map, will also be retained in accordance with Policy TP 4: Public Car Parks:
* Tanyard 
* The Regal/Co-Op
* Jockey Lane

Supported, however it must be recognised that more parking will be required as a result of the proposed high development. I understand there may be some availability at the Rugby Club.

9. Provision of allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation;

Supported.

10. Provision of a framework for a positive heritage strategy, including enhancements in accordance with the NPPF and adherence to Policy STR 8;

What precisely does this mean? Greater detail required. At the very least, we should resist the expansion of the LBD’s.

11. Where necessary, undertaking a rapid Conservation Area appraisal for those absent or out of date.

Agreed.

It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development:

a. Primary and secondary education;

Vague. More detail required?

b. Health and medical facilities; the three existing medical practices to be combined into one practice. Provision of land and new premises to deliver one GP practice and associated services;

This merely reflects what is currently being proposed for Cranbrook, but there is no recognition that an expanded Sissinghurst will require its own medical facilities. Centralising medical facilities means more car journeys, and greater parking issues.

c. New community centre;

Agreed, on the assumption that this is for Cranbrook only. If this is the case, make it clear in the policy.

d. The provision of buildings and spaces to provide cultural infrastructure;

What does this mean?

e. The provision of allotments, amenity/natural green space, parks, and recreation grounds, children’s play space and youth play space to include improvements to the cricket pavilion, improvements to the Tomlin Ground (Cranbrook Rugby Club), including to the changing rooms and club house, improvements to pitches at King George Field in Sissinghurst, including converting adult pitches to junior pitches;

This is confusing; it barely seems to recognise the different needs of Cranbrook and Sissinghurst, and seems to muddle them all together. This is indicative of the apparent lack of understanding demonstrated by TWBC towards this parish. There is also no mention of Cranbrook Football Club, and our hope to return it to the town.

f. Extending the Crane Valley public access route westwards and eastwards with consideration for biodiversity and ancient woodland;

Supported.

g. A feasibility study to investigate the potential of creating pedestrian and cycle route between the settlements in the parish, building upon existing footways and Public Rights of Ways; to include contributions towards the proposed utility and leisure cycling routes within the Borough Cycling Strategy and the proposed Bedgebury to Sissinghurst cycle path route;

Who commissions and pays for this study? What happens next? Why do we need a feasibility study when we already know we want pedestrian/cycle access from Bedgebury to Sissinghurst Castle?

h. A replacement of St George's Hall (Sissinghurst);

Agreed.

i. Provision of electric vehicle charging points and car share facilities in accordance with Policy TP 2: Transport Design and Accessibility;

Agreed.

j. Bus services, including contributions towards a feasibility study to investigate the potential of creating a Demand Responsive Bus service for the parish and beyond;

Agreed.

k. Other mitigation measures identified through the pre-application process and planning application.

Agreed.

Any major development larger than approximately 100 residential units on greenfield windfall sites is expected to provide suitable employment floor space, to be discussed with the Local Planning Authority and Cranbrook and Sissinghurst Parish Council through pre-application discussions.

This doesn’t make sense; a windfall site is for fewer than 10 sites, surely? This requires much more detail; is the employment space supposed to be mixed within residential dwellings, what constitutes suitable, should the figure be lower? This appears to be sneaking additional large sites in through the back door, a policy which is very much against the wishes of the community.

The Limits to Built Development around Cranbrook and Sissinghurst are defined on the draft Policies Map. It is noted that these now include the sites/part sites to be allocated at Policies AL/CRS 1, 2 (part), 3 (part), 5 (part), 8, 9 (part), 10-11, 12 (part), 13 (part), and 14, 15 and 16, but exclude AL/CRS 4 (open gap/landscape buffer between existing LBD and developable part of site allocation), 6 (no existing LBD at Hartley), 7, and 17 (safeguarded land). As above at Policy STR 10, a further/separate LBD is proposed at Sissinghurst around existing built development to the west of the settlement and incorporating proposed residential site allocations AL/CR 13 (part), CR 15 and CR 16, with an open landscape gap retained between the two LBDs.

This cannot be supported, as it provides a precedent for continually extending the LBD to enable the creation of even more developments.

DLP_2768

Lee Hatcher

Part one doesn't consider other bottlenecks, such as Goudhurst (most direct route from Parish to A21) or Staplehurst crossroads, Linton crossroads etc on A229, or Glassenbury junction in Hartley.

Part 2 is worthy but all developments in Cranbrook are in AONB and the plan includes hundreds of houses and the site specific polices hardly take this into consideration.

DLP_2283

Jackie Bourne

I Object

Policy Number: Section 5 Cranbrook and Sissinghurst (Ref: Pages 196 – 234)

An additional 900 dwellings in Cranbrook and Sissinghurst means approximately an additional 3,000 people, ( an increase of approximately 40% on the population), and 2,000 vehicles. This will have a significant impact. Although there will be some positive aspects to this influx of diversity, it could also have negative and detrimental results on all the local services, the roads/junctions and car parking.

Where are all these people expected to come from, and where are they living now. There will certainly be some extra housing required, but where is the proof so many are needed?

How does building hundreds of houses square with energy conservation, of particularly water and electricity, but also light and noise pollution?

DLP_2077

Terry Everest

Query

Is this historic village able to retain its character in the face of such huge development?

I suggest a reduction of at least 50% up to 75% of these housing developments in order to balance the needs with those of maintaining local character and the sense of history in the village.

DLP_2650

Hobbs Parker

Introduction

The site is a triangular shaped arable agricultural field of approximately 3.623 hectares (ha). The eastern boundary is formed from a mature hedgerow that lies adjacent to Tilsden Lane, where the site is raised above the level of Tilsden Lane. There is no natural boundary to the south, where further arable agricultural fields continue southwards to a frontage with Swattenden Lane.

The site slopes downwards towards the north-west, where the site boundary is formed from a belt of Ancient Semi-Natural Woodland separating the site from the residential development within the built confines of Cranbrook located along Dorothy Avenue. The site is located approximately 650m to the south-east of Cranbrook, where there are a range of services and facilities (as detailed in the draft Local Plan), making the site a sustainable location for additional residential development, to enable future occupiers to access the existing services. As part of any residential development proposal a new pedestrian route would be created from the site to the west, through the wooded area, to provide a connection into Cranbrook via Dorothy Avenue. This would mean that the main centre of Cranbrook would be within a 5 to 10 minute walk, via dedicated pedestrian footways to provide a safe route and to reduce the reliance on the private motor vehicle.

Much of the site is contained within a ‘bowl’ like depression, which helps to reduce intervisibility with the surrounding landscape. Tilsden Lane is, in parts, a sunken lane and therefore the site is raised above the level of the lane along the eastern boundary. The greatest level difference of 3-4m occurs at the northern-extent of the site as Tilsden Lane approaches Baker’s Cross. As the lane heads southwards the level difference reduces to about 1m at the mid-point of the eastern site boundary, before increasing again to 1-2m at the south-eastern corner.

SHELAA

The SHELAA provides an assessment of land availability to identify a potential future supply of land that is suitable, available and achievable for development. The site was considered as part of a larger parcel of land (47.97 hectares), referenced as Site 92 (Land South of Grove Cottage, Tilsden Lane, Cranbrook TN17 3PJ) in the SHELAA.

A smaller site was put forward in July 2016 as part of the Council’s ‘Call for Sites’ process covering 2.587 acres with a capacity of approximately 10 units. It appears that this smaller site has not be considered as part of the SHELAA process, although this site still remains available. Given that this smaller site was put forward at the outset of the plan-making process it appears that due consideration has not been given of this smaller site through the SA and SHELAA.

This representation forms a resubmission of the smaller site (although the boundary has been slightly enlarged) and forms the northern component of Site 92, covering approximately 3.623 ha of land close to the Cranbrook settlement boundary. The client’s promoter Charterhouse Strategic Land have followed the Council’s SA criteria and assessed the 3.6 ha site. The 3.6ha site (and the previously submitted 2.587 acre site) would have passed the initial screening exercise and been considered further as a reasonable alternative. CharterHouse Strategic Land’s assessment has been submitted as part of this representation.

One point of clarification, the site is owned by Keith Roberts and Venetia Carpenter, a married couple, and should not be considered to be in multiple ownership.

Deliverability

Our client is working with a promoter, to pursue a medium sized scheme of approximately 50 units, although the exact figures would be determined as part of the Development Management process taking into account a number of factors, such as topography, the proximity to Ancient Woodland and landscape impact. A scheme of this nature would allow for a mix of unit sizes and tenures: Higher density housing could be located closer to the existing built form (at the north of the site), gradually moving outwards to lower density detached houses in more spacious plots on the edge of the open countryside. Working with a promoter, the development of the site is anticipated to come forward in the first 5 years of the plan, which will be deliverable as the promoter is committed to ensure that the site will come to the market within this time period.

Access

Access to the site will be taken from Tilsden lane via a new simple priority T-junction at the site’s north eastern boundary. Evidence of speed surveys will be submitted as part of any planning application, and a technically compliant access will be delivered to support the residential development of the site.

Landscape Impact

Due to the site’s location within the AONB, a Landscape and Visual Technical Note has been commissioned which explains that whilst the site lies in a sensitive location in the countryside near the edge (but beyond) the settlement boundary of Cranbrook, the sloping site topography and surrounding boundary vegetation result in relative well enclosed and nestled within a ‘bowl’ like depression formed from the ghyll valley topography. The Note concludes that it is considered the intrinsic qualities of the site itself could be addressed through a sensitive development approach that would respect key sensitivities and not intrude on the wider rural landscape. Taking account of the supporting material that would be produced as part of a planning application, the studies to date conclude that development of this site would be possible whilst respecting the function of the adjoining Ancient Woodland and wooded valley, without intrusion into the wider AONB landscape and respecting the character of Tilsden Lane.  Any development proposal would take account of the recommendations made in the supporting material to date, and would incorporate the following:

  • The creation of a planted boundary to the south of the site, potentially created on a bund to accentuate the ‘bowl’ characteristics of the site’s natural topography. This intention would be for this area to provide net biodiversity gain
  • A 15 metre buffer from the canopy line of the Ancient Woodland, to minimise the impact of development
  • Development of a woodland management plan
  • Planting within the development and also to the boundaries
  • Protection and enhancement of the inherent character of Tilsden Lane

Conclusion

To summarise, the plan as currently drafted is unsound: The 3.623 ha site at Tilsden Lane should be allocated within the plan as it has a realistic prospect of delivery, is in a more sustainable location than some of the other draft allocations, and has fewer constraints to development. Whilst the NPPF provides the national framework to guide development to the most suitable locations, it is not necessary to repeat the detail within our representation to the Plan as Officer’s will be familiar with its content. However, as part of any planning application the supporting material will conclude that development of the site would support the social, economic and environmental dimensions of sustainability, as defined within the NPPF. We would welcome further engagement with you as the Plan progresses to submission and Examination in Public. Please do not hesitate to contact me should you require any additional information.

Attachments (3 in total)

1. Red Line Site Plan

2. SA scores for land at Tilsden Lane

3. Landscape and Visual Technical Note

DLP_2064

Canterbury Diocesan Board of Finance Ltd

The Limits to Built Development Boundary for NE Cranbrook (existing and proposed) include the Vicarage site. The site met all of the requirements for inclusion as a housing allocation just three years ago and nothing material has changed since then. So, the Vicarage site needs to retain its correct status as a formal housing allocation.

DLP_2160

Andrew Davidson

I object to the sheer number of houses planned for Sissinghurst and Cranbrook. They are much higher than the numbers that were circulated after an assessment done by the parish as part of its own Neighbourhood Plan. The traffic created, and demand on services, is unsustainable.

I also object to the number of houses the borough is being asked to take as a whole. Why has the council not objected?

DLP_2161

Andrew Davidson

I object to the number of houses being planned for Sissinghurst. There are already severe traffic congestion problems in the village at certain times of day. With the recent announcement by the National Trust that it plans to open Sissinghurst Castle Gardens for 12 months of the year – and I see no mention of that in this draft plan - these housing plans have to be scaled back. The volume of charabancs and buses that the gardens attract already adds to the problems in summer.

I also object to placing so many new houses in a area that is mainly designated AONB. The distinctive beauty and aesthetic of the High Weald area stems from its rural nature of smallholdings and low-scale settlements. The decision to put so many houses in the area all at once is contrary to any desire to preserve a landscape of so much value. This point about landscape and the rural nature of Cranbrook and Sissinghurst has not been addressed in this plan.

DLP_2434

J Coleman

I agree with this policy as public transport is very poor currently and it takes a long time to get to any major towns.

Buses need to be more frequent, cheaper and coordinate with trains times at Staplehurst station.

DLP_2471

G Baker

I support this policy as public transport is very expensive, infrequent and slow currently.

Buses need to be more frequent, cheaper and coordinate with train times at Staplehurst station

DLP_2654

Benenden Parish Council

Policy STR/CRS 1 - Benenden Parish Council are concerned at the level of residential development proposed for the area with regard to the impact it will have on our local roads.

DLP_2892

Victoria Groves

We support the acknowledgement that Hartley forms part of the wider settlement of Cranbrook and that this neighbourhood can support sustainable housing development which benefits from easy access to the wide range of facilities and services Cranbrook offers.

Cranbrook is one of the most sustainable villages within the district and offers a full range of facilities which meets the everyday needs of its residents.  This includes two secondary schools, a primary school, supermarket, a range of sports facilities including a leisure centre and rugby club and access to health facilities. Whilst we acknowledge that Cranbrook is within the Area of Outstanding Natural Beauty we consider the settlement is capable of supporting a greater number of housing than identified and the Council has not fully considered all suitable sites, in particular SHLAA sites LS_37 and LS_54. Our objections to the Council's assessment of these sites are set out in full in our comments to Appendix 6 of this document.

DLP_3101

Caroline Taylor

TWBC has ignored advise from the PArish Council regarding suitability of sites. A larger proportion of lower cost housing is required & the total figure is too high.

DLP_3148

Nigel Bell

Object

The number of new dwellings (718-803) proposed for Cranbrook to be built on ANOB designated land is excessive and far too many, beyond the needs of the local community. ANOB land should be protected and not developed as proposed by the Plan.

Large scale housing estate type developments are inappropriate in Cranbrook and smaller scale, sympathetic building in line with the character of the existing village should be proposed, not what has been proposed in the Plan.

DLP_3155

Nigel Bell

Object

I do not agree that there is demand for 718-803 new dwellings in Cranbrook from residents in the parish . A large proportion of these new dwellings will ultimately be purchased by families who do not currently live in Cranbrook and Sissinghurst parish who earn their living by commuting to London. In Cranbrook many workers in our shops, restaurants and in small local industries do not live in Cranbrook, but in cheaper accommodation in other areas within travelling distance- they cannot afford what the developers are building, even the so -called low cost houses, on their local salaries.  Hence, valuable AONB land is being proposed for use for developers to build houses for London commuters- only a small proportion for local people.

DLP_3285

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested

Paragraph 3 - “All development proposals will be required to establish the impact of the proposed development upon the Hawkhurst crossroads junction (A229/A268) and the Flimwell crossroads junction (A21/A268)

Paragraph 7 - “Maintenance and enhancement of, and/or linkages to, public footway network, public rights of way and the local strategic cycle network..”

Additional paragraph - The impact of the development in Cranbrook on the Hawkhurst junction is a concern. However, a blanket objection by the Local Highway Authority to all residential allocations in Cranbrook would be unsuitable owing to the likelihood of the majority of traffic from each site heading north rather than south on the A229.

Public Rights of Way and Access Service.

The specific reference to PRoW in paragraph 7 and the expected contributions towards PROW enhancements, including the proposed Bedgebury to Sissinghurst cycle route (g), are supported.

DLP_3436

Sally Marsh

Object 

Policy Number: STR/CRS 1

The number of new dwellings allocated within the AONB in Cranbrook is too high. Planning Practice Guidance (PPG), revised July 2019, states ‘The National Planning Policy Framework makes clear that the scale and extent of development in [AONBs] should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. Paragraph: 041 Reference ID: 8-041-20190721.

TWBC has failed to limit the scale and extent of development proposed in the AONB and, contrary to PPG, has sought to meet the needs of adjoining non-designated areas within the borough through allocating increased numbers to the AONB (see STR1) .

DLP_3566

Kent & East Sussex Regional Office

National Trust

Object 

The National Trust has concerns about the existing capacity at the waste water treatment works (WWtW) in Sissinghurst to accommodate the level of development being proposed. Development will put additional pressure on the WWtW which is located on the western boundary of the Sissinghurst Castle Estate. All the waste water from the village is treated at this WWtW prior to being discharged into the Hammer Stream which flows through the National Trust Estate. The National Trust needs certainty from the LPA and Southern Water that should development be delivered on the proposed allocations management processes will be in place to prevent water quality deterioration of Hammer Stream. The National Trust support the use of environmentally sustainable methods of treating waste and should improvements to the existing infrastructure be necessary we would welcome dialogue with Southern Water in relation to this site.

The proposed Bedgebury to Sissinghurst cycle path route referred to in criterion 7 should be identified on the Policies Map. This route is also not shown within the Borough Cycling Strategy 2016-2020 and so it is not clear whether the route will affect National Trust land. Although access is a key priority for the National Trust cycling is currently prohibited within the Sissinghurst Castle Estate.

DLP_4370

British Horse Society

Support with conditions 

The proposed Bedgebury to Sissinghurst cycle route should be dedicated as a public bridleway or restricted byway, so that equestrians from Cranbrook and Sissinghurst can safely access the bridleways in Bedgebury forest via the bridleway at Hartley, instead of having to drive there with a horsebox.

DLP_4120

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

The planned delivery of 718-803 new dwellings on nine sites (point 1) cannot be accomplished in accordance with the NPPF, or the High Weald AONB Management Plan. Such expansion greatly exceeds the anticipated local housing need during the plan period, approximately 600 new homes, as identified by consultants on behalf of the Cranbrook & Sissinghurst NDP group. Neither level of expansion of Cranbrook & Sissinghurst could be achieved, making use of the sites put forward for development, without (1) permitting a number of major developments within the AONB, for which no exceptional circumstances exist and on sites with a negative sustainability assessment; and/or (2) allowing some or all of the distinct settlements of Cranbrook, Wilsley, Sissinghurst and Hartley to coalesce and thereby prejudice the historic settlement pattern of this part of the AONB.

CPRE agree that the AONB Management Plan will be a material factor in relation to sites outside the AONB but within the High Weald national character area or close to the AONB boundary (point 5).

In our view, growth in Cranbrook and Sissinghurst should, in conformity with policies adopted under the current local plan (but regrettably not followed in the allocation of land adjacent to the Crane Valley under existing policy C3), be by way of small, well and sympathetically designed developments, located within or adjacent to existing settlements, or in sustainable farmstead locations, avoiding harm to the three conservation areas and to the AONB. All such developments should be to the highest standards of sustainability. We appreciate that this approach places considerable restrictions on growth in Cranbrook and Sissinghurst but it is, in our submission, the effect of the NPPF and other relevant planning policies and documents, properly interpreted in relation to this Parish.

Employment

We are also concerned that the part of this policy referring to developments larger than 100 residential units could encourage applications for major developments which are thoroughly unsuitable in the AONB.  Arguably, for sustainability, any development of more than 20 dwellings in villages and the rural area ought at least to provide some employment possibilities, for example through live/work units.

DLP_4554

Historic England

Policy STR/CRS 1: The Strategy for Cranbrook and Sissinghurst Parish et seq. – as with the foregoing comment, we would expect the allocation of sites following on from this Strategy policy to be subject to appropriately robust and detailed heritage impact assessment prior to the allocations being adopted.

DLP_4686

CBRE Ltd for Dandara Ltd

Policy STR/CRS1: The Strategy for Cranbrook and Sissinghurst Parish - Dandara notes the following:

4.112 Dandara supports growth at Sissinghurst and allocation AL/CRS13. This section specifically addresses Dandara’s comments in relation to Policy STR/CRS1.

4.113 In respect to paragraph 3 of Policy STR/CRS1, this paragraph requires that all development proposals establish the impact of the relevant proposed development on the Hawkhurst and Flimwell crossroads (junction of A21 and A268).

4.114 In relation to Section 11, final paragraph of Policy STR/CRS1, Dandara supports the extension of the Limits to Built Development in relation to AL/CRS13, the allocation for Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road. Dandara notes that this is a part extension, which excludes the southern portion of the site (which is subject to a TPO).

4.115 Dandara requests clarification as to how this part extension interacts with the access and junction requirements of the allocation (Policy AL/CRS13 paragraphs 1-5). This clarification is required to ensure that the allocation is positively prepared (NPPF paragraph 35) and the vision for its development can be fulfilled. Housing Trajectory

4.116 In TWBC’s Draft Local Plan housing trajectory, the parcel CRS13 will be delivered in one phase commencing in 2025/26.

4.117 The site is suitable for housing, available and deliverable now. Should planning permission be granted for the current application (LPA ref. 19/00308/FULL), circa 40 new homes could be delivered as soon as 2021/22. Dandara therefore request that TWBC’s housing trajectory is revised accordingly.

[TWBC: see full representation].

DLP_3890

Mrs June Bell

General Observation

The first requirement should be that early collaboration is expected of developers with the Parish Council, the Neighbourhood plan development group and the community in acknowledgement of paragraph 4.72 of the DLP ‘to allow communities the opportunity to take the lead in developing a shared vision to shape their localities.’

This enormous scope to encourage the use of deliberate and timely engagement has been identified as 1 of 8 priorities for reform in the Interim report of the ‘Building Better, Building Beautiful Commission ‘ proposition 19: ‘Collaboration not just consultation’ available at:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf

DLP_3891

Mrs June Bell

Support with conditions 

3. All development proposals will be required to establish the impact of the proposed development upon Hawkhurst and the Flimwell crossroads (junction of A21 and A268);It is expected that contributions will be required towards the following if necessary to mitigate the impact of the development

Please add to list

* Visitor Facilities: Coach Park and toilets in Cranbrook

* New Facilities for Cranbrook Football Club

* All development proposals should be required to establish the accumulative impact of proposed development within C&S Parish and surrounding parishes on A229 linking Hawkhurst & Cranbrook and Staplehurst; A262 linking Sissinghurst & Goudhurst to the A21; the junction of the B2085 and the A229 at Hartley.

DLP_3899

Mrs June Bell

Support

f. Extending the Crane Valley public access route westwards and eastwards with consideration for biodiversity and ancient woodland;

As water flows it any contamination potentially risks habitats and ecosystems further along the Crane Brook and ponds along the valley. Calumma Ecological Services have identified protected species (Great Crested Newt )breeding in 2 ponds I close proximity to AL/CRS 7 and the Crane Valley.

DLP_3885

Mrs June Bell

Object

Policy Number: STR / CRS 1 The Strategy for Cranbrook and Sissinghurst Parish

1. approximately 100-115 new dwellings on five sites in Sissinghurst (Policies AL/CRS 12-16)

The scale of development is not appropriate for the situation and setting of this village

Reasons for objection:

Policy ED 8 states that development should be appropriate to the size and function of the centre within which it is to be located. Sissinghurst is:

* An historic village with a designated Conservation Area (TWB Local Development Framework 2012)

* The Conservation Area itself coincides with the historic core fronting onto the Street, the main ridgetop throughfare through the village which is already experiencing large increases of traffic, HGV and lack of parking provision for residents and visitors.

* It is within the setting of the world renowned Sissinghurst Castle which provides an essential revenue to the parish tourist trade and associated services.

* The ability to mitigate against the disproportionate and rapid increase of new dwellings adequately and in keeping with preserving and protecting the historic character and appearance of the village is limited.

* It is the duty of the Local Planning authority and principal guardians (residents and business people who live and work in the village to protect and enhance the conservation area.1

* The scale of development is greater for this village than those villages in the borough such Rusthall, Speldhurst and Lamberhurst which have employment, a variety of public transport modes, retail, sport and recreation, easier access to district general hospital and financial service hubs closer to development.

Town / Village Population Dwellings

Rusthall 4,976                15

Speldhurst             4,973 20

Lamberhurst           1,706 60

Sissinghurst             1,068 115

Benenden               2,400 129

1Sissinghurst Conservation Area Appraisal adopted by TWBC 2012. Available at: http://www.tunbridgewells.gov.uk/__data/assets/pdf_file/0020/27911/Sissinghurst-Conservation-Area-Appraisal_adopted-Oct-2012.pdf

DLP_3881

Mrs June Bell

Object

Policy Number: STR/CRS1

The Strategy for Cranbrook and Sissinghurst Parish

Reasons for objection:

1. Scale and distribution of allocations conflicts with TWBC Topic Paper ‘Landscape Sensitivity Assessment’ (LUC July 2018). The maps show Medium/High sensitivity for small development (2/2.5 storey residential dwellings assuming 30-40 dwellings/Ha except for AL/CRS4

Approximately 718-803 new dwellings will be delivered on nine sites(*) allocated in this Local Plan in this plan period (Policies AL/CRS 1-9) and approximately 100-115 new dwellings on five sites in Sissinghurst

Why has TWBC not limited housing development in AONB communities to the numbers that meet the local need and insisted that homes are truly affordable?

The Parish Council has assessed C&S Parish housing need for the plan period at a lower figure of 610 and that the need is for truly affordable housing. Available at:

http://cranbrookandsissinghurstndp.co.uk/wp-content/uploads/2019/03/Cranbrook-Sissinghurst-HNA-Final-Draft.pdf

2. My concern is that Tunbridge Wells has not fully assessed the harm that cumulative development (13,560 new dwellings plus infrastructure & economic development) can do to the AONB Landscape and its communities and argued for lower housing numbers?

Is there evidence to support that TWBC has challenged Government levels of housing numbers on grounds of national policy for the protection of AONB?

NPPF paragraph 11b stipulates that national policy allows for the overall scale, type & distribution of development to be restricted where valued landscapes can be damaged. I question whether TWBC needs to accept the levels of housing proposed by the Government as 70% of the borough is protected as an Area of Outstanding Natural Beauty.

DLP_3882

Mrs June Bell

Support with conditions

Policy Number: STR/CRS 1 - 7. Maintenance and enhancement of, and/or linkages to, public rights of way or the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility; to include contributions towards the proposed Bedgebury to Sissinghurst cycle path route;
A safe cycling route linking settlements would be very much appreciated as the narrow historic roads, scale and speed of traffic on the roads make it extremely risky especially with families wishing to travel together to shops or school.

DLP_5071

Tally Wade

Policy STR/CRS 1 (page 200)

I object to the Limits to Built Development being redrawn to accommodate new development – the reasoning being that the new site is annexed to the existing LBD. This means that LBDs can redrawn to accommodate new development with little regard for the sensitive nature of AONB and historic settlement patterns.

Transport

Policy STR/CRS 1, point 8 (page 201)

I object to the lack of provision for new car parking infrastructure in the centre of Cranbrook. This is not infrastructure led. The supporting document Topic Paper 4 for Parking Strategy 2016-2026 uses different data for number of houses proposed for Cranbrook and therefore the demand for parking. It states 259 new houses in Cranbrook instead of the Local Plan’s proposed average of 900. It is simply not enough to retain the current car parks – if people can’t park they can’t use the town and this undermines the policy to encourage rural business, as described in Policy ED 8 (page 478) and supporting paragraphs 6.472 and 6.473 (page 477).

DLP_3563

Lynne Bancroft

STR/CRS 1 point 1

Object 

The housing need numbers in Cranbrook and Sissinghurst which have been assessed by the Cranbrook and Sissinghurst Parish Council are lower than the housing numbers included in the Local Plan by TWBC for this parish. The number of houses to be developed in Sissinghurst should therefore be reduced to those shown in the draft Neighbourhood Development Plan.

The planning permission for the 60 homes at Bloomsbury Gardens, Common Road, Sissinghurst was only given on appeal on 21st March 2016 so the number of properties developed here should be deducted from the number of homes (100-115) required in Sissinghurst in this Local Plan. The 9 houses to be developed in Cobnut Close has also not been deducted from these numbers so much fewer homes shodlbe developed in Sissinghurst

The Parish Council/draft Neighbourhood Development Plan has already assessed and allocated sites for the Parish which show that some sites selected by TWBC, for example site CRS 13 (Map 56 Policy AL/CRS13), are unsuitable and unsustainable and should not be developed. TWBC have ignored these assessments.

The planning permission for the 60 homes at Bloomsbury Gardens, Common Road, Sissinghurst was only given on appeal on 21st March 2016 so the number of these properties should discounted from the number of homes (100-115) required in Sissinghurst in this Local Plan. In addition, the 9 new homes to be built in Cobnut Close should also be deducted from the number of houses to be developed in the village of Sissinghurst in this Local Plan.

Site CRS 13 should be excluded from the TWBC Local Plan.

DLP_3564

Lynne Bancroft

Support with conditionspoint 3

Development proposals in Cranbrook and Sissinghurst will also impact on the congestion within The Street, Sissinghurst, Goudhurst village centre and non-dualled section of the A21 between Lamberhurst and Blue Boys, none are which are recognised as issues in this policy and which cause major problems for residents trying to travel in these areas. The impact of development on these congestion hotspots should also be considered.

DLP_3631

Lynne Bancroft

Object

The further/separate Limits to Build Development (LBD) within Sissinghurst is not acceptable as it has only been put in place now to allow TWBC to put more housing in the area. The new LBD around Wilsley Pound and Mill Lane will start to connect two previously separate settlements (Mill Lane and Wilsley Pound) as TWBC policy will then allow infilling as shown in their assessment of Site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road). This site has been assessed in the Cranbrook and Sissinghurst draft Neighbourhood Development Plan and development here is not supported by them so should not happen. This infilling is not acceptable in a newly defined LBD especially given the rural and historic nature of Mill Lane. Mill Lane is part of Sissinghurst Village and not Wilsley Pound and should not be included in the new LBD. Point 3 of STR/CRS 1 states that landscape gaps between individual areas of the parish will be maintained so development of this site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road) is in contradiction to this proposed strategy.

DLP_3632

Lynne Bancroft

Support

point 7

I support an enhancement of the cycle way between Bedgebury and Sissinghurst Castle which will help Cranbrook and Sissinghurst with green tourism, increase economic factors in the area, improve connectivity between settlements by green transport and provide additional health benefits for all ages.

DLP_3633

Lynne Bancroft

Support

point 9

I agree with this policy

DLP_3634

Lynne Bancroft

Support with conditions

point F

I agree with this policy to extend public access east and west along the Crane Valley. However, it should be extended East to beyond Chapel Lane in Sissinghurst and the landscape needs to be protected and maintained with no further development.

DLP_3635

Lynne Bancroft

Support

point G

I support an enhancement of the cycle way between Bedgebury and Sissinghurst Castle which will help Cranbrook and Sissinghurst with green tourism, increase economic factors in the area, improve connectivity between settlements by green transport and provide additional health benefits for all ages.

DLP_3636

Lynne Bancroft

Support

point H

I agree with this policy.

DLP_3637

Lynne Bancroft

Support with conditions

point I

Electric vehicle charging points should only be put into new developments not in existing streets. There is already restricted parking and losing parking bays to electric charging units would cause more difficulty in parking in the village and may cause more congestion further along The Street.

DLP_3638

Lynne  Bancroft

Support

point J

I agree with this policy as the public transport system is very poor currently and it is very time consuming to get to any major towns.

The bus timetable does not coincide with the train timetable from Staplehurst station and the last bus does not wait if the London train is a little late meaning that people are left at the station unable to get home. Buses need to be more frequent and cheaper.

DLP_3639

Lynne Bancroft

Support with conditions

The proposed policy says that any major development on with more than 100 residential units on greenfield windfall sites should provide employment floor space.

I believe that ALL sites allocated through the Local Plan should provide employment space or provide monies to a nearby employment site in the same Parish and that the 100 houses is too high a target and all sites should provide employment space. This is especially required in Cranbrook and Sissinghurst as non of the allocated sites are likely to meet this criteria and the Parish will have additional residents but no additional employment, forcing people to travel on already congested roads to major towns with poor and slow public transport links.

DLP_3640

Lynne Bancroft

Object

Limits to Build

The further/separate Limits to Build Development (LBD) within Sissinghurst is not acceptable as it has only been put in place now to allow TWBC to put more housing in the area. The new LBD around Wilsley Pound and Mill Lane will start to connect two previously separate settlements (Mill Lane and Wilsley Pound) as TWBC policy will then allow infilling as shown in their assessment of Site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road). This site has been assessed in the Cranbrook and Sissinghurst draft Neighbourhood Development Plan and development here is not supported by them so should not happen. This infilling is not acceptable in a newly defined LBD especially given the rural and historic nature of Mill Lane. Mill Lane is part of Sissinghurst Village and not Wilsley Pound and should not be included in the new LBD. Point 3 of STR/CRS 1 states that landscape gaps between individual areas of the parish will be maintained so development of this site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road) is in contradiction to this proposed strategy.

DLP_5177

Bloomfields for Fernham Homes

Place Shaping Policies

The place shaping policies establish the spatial priorities for different areas in the Borough. For each area, there is an overarching policy that development should adhere to and details are provided for individual allocated sites that will deliver the quantum of development proposed. The site-specific allocations provide both strategic and development management guidance.

Cranbrook and Sissinghurst Policy STR/CRS1

This sets the proposed strategy for Cranbrook and Sissinghurst and states that approximately 100-115 new dwellings on five sites in Sissinghurst, including land subject to this representation, under allocation reference AL/CRS14.

This Policy says that it is expected that contributions will be required towards the following requirements, if necessary, to mitigate the impact of the development:

a. Primary and secondary education;

b. Health and medical facilities; the three existing medical practices to be combined into one practice. Provision of land and new premises to deliver one GP practice and associated services;

c. New community centre

d. The provision of buildings and spaces to provide cultural infrastructure;

e. The provision of allotments, amenity/natural green space, parks, and recreation grounds, children’s play space and youth play space to include improvements to the cricket pavilion, improvements to the Tomlin Ground (Cranbrook Rugby Club), including to the changing rooms and club house, improvements to pitches at King George Field in Sissinghurst, including converting adult pitches to junior pitches;

f. Extending the Crane Valley public access route westwards and eastwards with consideration for biodiversity and ancient woodland

g. A feasibility study to investigate the potential of creating pedestrian and cycle route between the settlements in the parish, building upon existing footways and Public Rights of Ways; to include contributions towards the proposed utility and leisure cycling routes within the Borough Cycling Strategy and the proposed Bedgebury to Sissinghurst cycle path route;

h. A replacement of St George's Hall (Sissinghurst);

i. Provision of electric vehicle charging points and car share facilities in accordance with Policy TP 2: Transport Design and Accessibility;

j. Bus services, including contributions towards a feasibility study to investigate the potential of creating a Demand Responsive Bus service for the parish and beyond;

k. Other mitigation measures identified through the pre-application process and planning application.

Having regard to these draft requirements, the general thrust of the Policy is supported. In particular, from discussions with the Parish Council and local community figures, it is particularly important that this site can be used to deliver a replacement of the St George’s Institute with a new community hall.

The provision of such a new community asset is sought to be achieved as part of any delivery of housing at this site and there is therefore an issue of viability that must be taken into account. Put simply, it will be viably impossible to expect any housing developer at this site to deliver both replacement of St George's Hall together with other contributions that might otherwise be required with respect to the provision of affordable housing.

[TWBC: see Comment Numbers DLP_5171, 5174, 5176, 5177 and 5180]

DLP_4042

John Badcock

I write as a retired teacher and Cranbrook resident who has lived on the town's highstreet since 1974.

Because of poor health I am unable to respond as fully as I would wish to the Local Plan proposals, but I have thought about them long and hard.

I have had to accept that rather than reply to individual policies, my main contribution to the preservation of the character of Cranbrook (whether concerning historic buildings or new additions) lies in:

(a) the 30 years I served on the Cranbrook Conservation Area Advisory Committee (CCAAC), for many years as chair of the planning sub. committee and writer of reports to the Council.

(b) Co-authoring the CCAA appraisal document, in 2010, with Peter Allen, to provide a valuable reference for the ensuing 10 years.

I want to register my serious concern that TWBC has appeared to accept the standard methodology for assessing the housing need in the borough (resulting in a figure of 13,560) and not sought to challenge them on the grounds of protecting the AONB, which constituted 70% of the borough.

I actually support the proposed garden town at Tudeley and several of the smaller site proposals for Cranbrook but strongly object to the larger ones (AL/CRS 4 second phase, AL/CRS 7 and 9).

Regretably, in failing to challenge the total housing allocation of Goudhurst, TWBC's decision is likely to result in irreversible damage to Cranbrook's historic settlement, located entirely within an Area of Outstanding Natural Beauty.

DLP_3500

Tara McCumiskey

Myself & Partner do not agree with Sissinghurst having so much proposed new large developments as the village can't cope with the traffic as it is.

DLP_4027

Steve Lillywhite

As a resident at Hartley I would like to make a comment regarding the local plan consultations.

We have now lived here for twenty years and one of my principal concerns is the impact that blocks of houses or estates as they used to be known will make towards joining up the villages and hamlets in the area. At the moment these are just about still defined, Hawkhurst, Hartley, Cranbrook and Sisssinghurst for instance, still have small margins of rural spaces between them. But these spaces are getting smaller and with it the the identity of these ancient places is receding. Blocks of houses in Hartley for instance will quickly link these villages up, and as in the case of Surrey, (I was brought up in Horley) these precious places will loose their identity and become as one. The balance is very fragile and once we, the custodians, have over developed them they will be lost as individual communities for ever. Whilst I understand that sensitive building is part of the development of communities I am also terrified that we will be the generation that lost what we all cherish.

Hartley dates back to the Roman times and is much older than Cranbrook. It is a place where several droves or trackways met. The Weald of Kent, originally called 'Andredsweald' refers to a dense forest.  These places are unique and beautiful. For the sake of all the reasons that we are very familiar with, please be careful.

DLP_4076

Margaret Prince

There is a great deal of building and building plans going on at the moment in our local area and I have some great concerns:

900 houses in Harley and Cranbrook, my concerns are:

  1. The infrastructure, to my knowledge, there does not seems to be any extra provision for utility services; provision for extra sewerage provision, Drs surgeries etc.
  2. With all these new houses the population of school age children will increase dramatically, has any thought been given to the provision for education, the local primary and secondary schools will struggle to cope
  3. Jobs where are all these people going to work, a large percentage of people in this area work in London, if they work in local jobs they probably will not be able to afford one of the new houses
  4. All these houses are beyond the reach of first time buyers, plus many of the new houses built, for example Hawkhurst and Paddock wood are not selling quickly and one wonders if some will sell at all.  Plus some of the houses should be for cheaper(affordable) rent and affordable to first time buyers.
  5. The south east is very overcrowded in many areas and we need our green spaces for sustainability such as farming (which we need to increase so we are more self-sufficient) areas growing more trees some for coppicing others to reduce greenhouse gases, besides the psychological effects on welfare and of course for recreation, which people in the towns need use to relax .  Plus this is an Area Of Outstanding Natural Beauty, though I know this doesn’t carry a lot of weight these days.
  6. The increase in cars will be a problem, hopefully the planners will insist on plenty of ‘off road’ parking, but the congestion will be a problem as well as added pollution.
  7. The provision of special facilities, special needs, care in the community  and extra care home facilities.

These are only some major points that I feel have not been addressed.

Thank you for your patience and I look forward to your response.

DLP_4405

Mill Lane and Cramptons Residents Association

OBJECT 

The number of houses planned for Sissinghurst is too high, above the AECOM study of Housing Need prepared for the Neighbourhood Plan in 2017. So much housing in a relatively short space of time will have a detrimental impact on the historic character of the settlement and certainly no way enhance it.

See also comments above on 4 4.7; 4 38; 4.59 and 2 2.25 which relate to local housing need

There is too much development proposed on the AONB land surrounding Cranbrook and Sissinghurst, which is recognised as one of ‘the best surviving medieval landscapes in Northern Europe’ as quoted in TWBC’s own policy EN21. This rural landscape provides an important context to the Conservation Areas of Cranbrook, Sissinghurst and Wilsley Green and the many listed buildings outside the CAs.

DLP_6446

Cranbrook & Sissinghurst Parish Council

At the Parish of Cranbrook and Sissinghurst, as defined on the draft Policies Map, proposals shall accord with the following requirements:

  1. Approximately 718-803 new dwellings will be delivered on nine sites (*) allocated in this Local Plan in this plan period (Policies AL/CRS 1-9) and approximately 100-115 new dwellings on five sites in Sissinghurst (Policies AL/CRS 12-16) in this Local Plan in the plan period. (*) Of these sites, the following already have planning permission: AL/CRS 4 for 36 dwellings and CRS 8 for 28 dwellings;

    Cranbrook and Sissinghurst PC Response > The overwhelming feeling within the community is that the numbers are far too high for a small town and village like Cranbrook and Sissinghurst. The draft TWBC LP covers the period 2016 – 2036 yet the numbers do not take into account any building carried out across the Parish in the last three years.

    The numbers also do not recognise the Housing Needs Assessment (HNA) carried out by an accredited and internationally recognised professional consultancy on behalf of the emerging neighbourhood plan, which identified a need for no more than 610 houses. This HNA figure was shared with TWBC Local Plan team.

    Therefore, we can only presume that the proposed number of new dwellings for the Parish is based upon land put forward through the call-for-sites process, and not on the needs of the Parish. This is supported by the comments made by Cllr Alan McDermott during the Parish Council meeting of 9th August 2019 – “In response to Cllr. Beck, Cllr. McDermott advised that if no one had put any sites forward then it would have been unlikely that we would have been allocated any new homes.”

  2. Additional housing may be delivered through the redevelopment of appropriate sites and other windfall development in accordance with Policy STR 1;

    Cranbrook and Sissinghurst PC Response > With the number of potential farmstead type developments within the area, the cumulative impact on the Parish could be significant, with limited opportunities to establish control over developments, or recognise the local need for truly affordable housing. There are already a number of proposals for “the magic nine” and therefore a more realistic threshold figure for windfall development would normally be five or six homes.

  3. All development proposals will be required to establish the impact of the proposed development upon Hawkhurst and the Flimwell crossroads (junction of A21 and A268);

    Cranbrook and Sissinghurst PC Response > This requirement cannot be proven or disproven and, therefore, cannot be verified – what does “establish the impact” mean in practice? It appears to show the unfamiliarity of TWBC regarding the predominant direction of travel from the Parish. There is no recognition of the major traffic bottleneck at Goudhurst to the west, likely to be made much worse with the development proposed (see above), the subsequent impact on the junction of the A21 at Lamberhurst, and the extra strain on capacity between this junction and Kippings Cross. Of equal importance is the fact that the majority of train journeys will commence at Staplehurst or Marden.

  4. Where a site is within the AONB, it should be demonstrated that the proposal will make a positive contribution towards achieving the objectives of the most recent AONB Management Plan and show how relevant guidance from the AONB Joint Advisory Committee has been considered to meet the high standards required of the other policies in this Plan for the High Weald AONB landscape;

    Cranbrook and Sissinghurst PC Response > A significant proportion of the Parish is within the AONB, including all the sites in Cranbrook, and just four of these are intended to provide nearly 700 dwellings. These large-scale developments are totally against the reasons for protection as afforded by the AONB designation and should provide an opportunity for TWBC to resist the numbers of dwellings imposed by government – see para. 11 b)i and b)ii of the NPPF. The fact the numbers have not been discounted, diminishes any faith that the local community may have had that TWBC development management team will enforce the high standard required by building in the AONB at the time planning permission is sought.

  5. Sites outside the AONB but within the High Weald National Character Area, or close to the boundary of the designated AONB landscape, will have similar characteristics and are likely to contribute to the setting of the designated landscape. The AONB Management Plan and any supporting guidance will be a material consideration for these sites;

    Cranbrook and Sissinghurst PC Response > The community in Sissinghurst will take a lot of convincing that this is the case. Given the apparent lack of attention and concern being paid to land that actually is within the AONB, there is little faith within Sissinghurst that land that is technically outside but shares the same characteristics will receive any particular consideration from the policy or development management teams in TWBC.

  6. All development proposals will ensure that landscape gaps between individual areas of the Parish are retained to prevent coalescence of development;

    Cranbrook and Sissinghurst PC Response > There are major concerns that so much green space will be lost that coalescence is inevitable; witness Corn Hall/Brick Kiln Farm/Turnden, Wilsley Farm, and Mill Lane. Unless there is a spatial plan that clearly demonstrates how this coalescence can be prevented, then there is no faith this aspect of the policy can be implemented.

  7. Maintenance and enhancement of, and/or linkages to, public rights of way or the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility; to include contributions towards the proposed Bedgebury to Sissinghurst cycle path route;

    Cranbrook and Sissinghurst PC Response > We can support this as a minimum requirement but much more needs to be done to support a more local cycle network of routes for short distance utility trips – e.g. between where people live, where they go to school, where they shop and so on. Without convenient and direct cycle infrastructure for trips of 2-3 kms, making people feel safe when they ride, and encouraging them to switch travel modes, there is no hope of meeting climate change targets, reducing congestion or meeting health and wellbeing targets for the Borough.

    Furthermore, the type and range of access and movement policies contained within the emerging Cranbrook and Sissinghurst NDP need to be considered by this strategic Local Plan policy. These include policies designed to ensure effective traffic-calming, the routing of HGVs and mitigating the impact of through traffic on heritage areas. None of these issues appear to be addressed by policy STR/CRS1. Such infrastructure requirements demand master-planning across all sites at the outline planning stage.

  8. The following public car parks within Cranbrook and Sissinghurst, and as defined on the draft Policies Map, will also be retained in accordance with Policy TP 4: Public Car Parks:
    • Tanyard
    • The Regal/Co-Op
    • Jockey Lane

    Cranbrook and Sissinghurst PC Response > We support this, however it must be recognised that parking demand will increase as a result of the proposed high levels of development. Additional sites, such as the Rugby Club, should be investigated thoroughly. See earlier comment about the need to provide viable alternatives to the car if this issue is to be fully reconciled.

  9. Provision of allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation;

    Cranbrook and Sissinghurst PC Response > This aspect of the policy is supported, and will be expected to be considered early in the planning process.

  10. Provision of a framework for a positive heritage strategy, including enhancements in accordance with the NPPF and adherence to Policy STR 8;

    Cranbrook and Sissinghurst PC Response > What precisely does this mean? Greater detail required. At the very least, there is resistance to the redrawing of the limits to built development boundaries.

  11. Where necessary, undertaking a rapid Conservation Area appraisal for those absent or out of date.

Cranbrook and Sissinghurst PC Response > This aspect of the policy is supported.

It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development: 

a. Primary and secondary education;

Cranbrook and Sissinghurst PC Response > Too vague and more detail is required.

b. Health and medical facilities; the three existing medical practices to be combined into one practice. Provision of land and new premises to deliver one GP practice and associated services;

Cranbrook and Sissinghurst PC Response > This merely reflects what is currently being proposed for Cranbrook, but there is no recognition that an expanded Sissinghurst will require its own medical facilities. Centralising medical facilities means more car journeys, and greater parking issues. This requires a rethink.

c. New community centre;

Cranbrook and Sissinghurst PC Response > This aspect of the policy is supported for Cranbrook only. See separate proposal for St George’s Hall, Sissinghurst.

d. The provision of buildings and spaces to provide cultural infrastructure;

Cranbrook and Sissinghurst PC Response > Too vague and more detail is required.

e. The provision of allotments, amenity/natural green space, parks, and recreation grounds, children’s play space and youth play space to include improvements to the cricket pavilion, improvements to the Tomlin Ground (Cranbrook Rugby Club), including to the changing rooms and club house, improvements to pitches at King George Field in Sissinghurst, including converting adult pitches to junior pitches;

Cranbrook and Sissinghurst PC Response > This is confusing. It barely seems to recognise the different needs of different parts of the Parish, and seems to muddle them all together. This is indicative of the apparent lack of understanding demonstrated by TWBC towards this Parish. New facilities will be required in proximity to development and also at the activity centres; the Planning Department should demand their inclusion at the pre-planning stage. There is also no mention of Cranbrook Football Club, and our hope to return it to the town.

f. Extending the Crane Valley public access route westwards and eastwards with consideration for biodiversity and ancient woodland;

Cranbrook and Sissinghurst PC Response > This aspect of the policy is supported.

g. A feasibility study to investigate the potential of creating pedestrian and cycle route between the settlements in the Parish, building upon existing footways and Public Rights of Ways; to include contributions towards the proposed utility and leisure cycling routes within the Borough Cycling Strategy and the proposed Bedgebury to Sissinghurst cycle path route;

Cranbrook and Sissinghurst PC Response > Who commissions and pays for this study? What happens next? Why do we need a feasibility study when we already know we want pedestrian/cycle access from Bedgebury to Sissinghurst Castle?

h. A replacement of St George's Hall (Sissinghurst);

Cranbrook and Sissinghurst PC Response > This aspect of the policy is supported.

i. Provision of electric vehicle charging points and car share facilities in accordance with Policy TP 2: Transport Design and Accessibility;

Cranbrook and Sissinghurst PC Response > This aspect of the policy is supported.

j. Bus services, including contributions towards a feasibility study to investigate the potential of creating a Demand Responsive Bus service for the Parish and beyond;

Cranbrook and Sissinghurst PC Response > This aspect of the policy is supported.

k. Other mitigation measures identified through the pre-application process and planning application.

Cranbrook and Sissinghurst PC Response > This aspect of the policy is supported.

Any major development larger than approximately 100 residential units on greenfield windfall sites is expected to provide suitable employment floor space, to be discussed with the Local Planning Authority and Cranbrook and Sissinghurst Parish Council through pre-application discussions.

Cranbrook and Sissinghurst PC Response > This makes no sense at all. How can a site of around 100 homes ever be classified as windfall? Surely a windfall site is for less than 10 homes, the minimum threshold set for your site allocations work? In any event, this requires much more detail. Is the employment space supposed to be mixed within residential dwellings? What constitutes suitable employment? And should the approx. 100 number be set lower if we are to get any employment at all?

The Limits to Built Development around Cranbrook and Sissinghurst are defined on the draft Policies Map. It is noted that these now include the sites/part sites to be allocated at Policies AL/CRS 1, 2 (part), 3 (part), 5 (part), 8, 9 (part), 10-11, 12 (part), 13 (part), and 14, 15 and 16, but exclude AL/CRS 4 (open gap/landscape buffer between existing LBD and developable part of site allocation), 6 (no existing LBD at Hartley), 7, and 17 (safeguarded land). As above at Policy STR 10, a further/separate LBD is proposed at Sissinghurst around existing built development to the west of the settlement and incorporating proposed residential site allocations AL/CR 13 (part), CR 15 and CR 16, with an open landscape gap retained between the two LBDs.

Cranbrook and Sissinghurst PC Response > This cannot be supported, as it provides a precedent for continually extending the LBD to enable the creation of even more developments. The LBD issue in Sissinghurst is confused with policy EN6 not extending as far as it should within the Great Swifts Estate. This leaves sections of the village and its setting unnecessarily vulnerable to development. Furthermore, the AONB coverage should be extended up to Sissinghurst Castle to provide parity of protection for both Cranbrook and Sissinghurst.

[TWBC: see full representation].

DLP_7629

Mr J Boxall

AONB – It is incorrect to say that Sissinghurst is adjacent to the AONB as part of SIssinghurst is in the AONB.  The AONB should be extended to cover the remainder of the parish of Sissinghurst to protect the sensitive and historic landscape of the areas, including Sissinghurst Castle

Other– Sissinghurst is also a tourist destination with 200,000 plus visitors a year coming through the village with the associated traffic issues it brings.  The rural area and landscape around Sissinghurst should be protected from over development as it is a well-known walking area with The High Weald trail, The 1066 Harolds Way, Walk in Time series of walks and the “Green Book” walks going through the area encouraging green tourism.

Main employment – the fact that there is no employment sites noted in the Local Plan emphasises that Tunbridge Wells should not include development sites in this village as they are unsustainable.  Development should be near key employment sites or areas with facilities, better transport such as Tunbridge Wells and areas near the already dualled A21

DLP_7640

Mr J Boxall

STR/CRS 1 point 1

The housing need numbers in Cranbrook and Sissinghurst which have been assessed by the Cranbrook and Sissinghurst Parish Council are lower than the housing numbers included in the Local Plan by TWBC for this parish.  The number of houses to be developed in Sissinghurst should therefore be reduced to those shown in the draft Neighbourhood Development Plan.

The planning permission for the 60 homes at Bloomsbury Gardens, Common Road, Sissinghurst  was only given on appeal on 21st March 2016 so the number of properties developed here should be deducted from the number of homes (100-115) required in Sissinghurst in this Local Plan. The 9 houses to be developed in Cobnut Close has also not been deducted from these numbers so much fewer homes shodlbe developed in Sissinghurst

The Parish Council/draft Neighbourhood Development Plan has already assessed and allocated sites for the Parish which show that some sites selected by TWBC, for example site CRS 13 (Map 56 Policy AL/CRS13), are unsuitable and unsustainable and should not be developed.  TWBC have ignored these assessments.

The planning permission for the 60 homes at Bloomsbury Gardens, Common Road, Sissinghurst was only given on appeal on 21st March 2016 so the number of these properties should discounted from the number of homes (100-115) required in Sissinghurst in this Local Plan.  In addition, the 9 new homes to be built in Cobnut Close should also be deducted from the number of houses to be developed in the village of Sissinghurst in this Local Plan.

Site CRS 13 should be excluded from the TWBC Local Plan.

STR 1/CRS 1 point 3

Development proposals in Cranbrook and Sissinghurst will also impact on the congestion within The Street, Sissinghurst, Goudhurst village centre and non-dualled section of the A21 between Lamberhurst and Blue Boys, none are which are recognised as issues in this policy and which cause major problems for residents trying to travel in these areas.  The impact of development on these congestion hotspots should also be considered.

STR 1/CRS 1 point 6

The further/separate Limits to Build Development (LBD) within Sissinghurst is not acceptable as it has only been put in place now to allow TWBC to put more housing in the area.  The new LBD around Wilsley Pound and Mill Lane will start to connect two previously separate settlements (Mill Lane and Wilsley Pound) as TWBC policy will then allow infilling as shown in their assessment of Site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road).  This site has been assessed in the Cranbrook and Sissinghurst draft Neighbourhood Development Plan and development here is not supported by them so should not happen.  This infilling is not acceptable in a newly defined LBD especially given the rural and historic nature of Mill Lane.  Mill Lane is part of Sissinghurst Village and not Wilsley Pound and should not be included in the new LBD.  Point 3 of STR/CRS 1 states that landscape gaps between individual areas of the parish will be maintained so development of this site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road) is in contradiction to this proposed strategy.

STR 1/CRS 1 point 7

I support an enhancement of the cycle way between Bedgebury and Sissinghurst Castle which will help Cranbrook and Sissinghurst with green tourism, increase economic factors in the area, improve connectivity between settlements by green transport and provide additional health benefits for all ages.

STR 1/CRS 1 point 9

I agree with this policy

Policy Number:   STR 1/CRS 1 - f

I agree with this policy to extend public access east and west along the Crane Valley. However, it should be extended East to beyond Chapel Lane in Sissinghurst and the landscape needs to be protected and maintained with no further development.

Policy Number:   STR 1/CRS 1 - g

I support an enhancement of the cycle way between Bedgebury and Sissinghurst Castle which will help Cranbrook and Sissinghurst with green tourism, increase economic factors in the area, improve connectivity between settlements by green transport and provide additional health benefits for all ages.

Policy Number:   STR 1/CRS 1 - h

I agree with this policy.

Policy Number:   STR 1/CRS 1 - i

Electric vehicle charging points should only be put into new developments not in existing streets.  There is already restricted parking and losing parking bays to electric charging units would cause more difficulty in parking in the village and may cause more congestion further along The Street.

Policy Number:   STR 1/CRS 1 - j

I agree with this policy as the public transport system is very poor currently and it is very time consuming to get to any major towns.

The bus timetable does not coincide with the train timetable from Staplehurst station and the last bus does not wait if the London train is a little late meaning that people are left at the station unable to get home.  Buses need to be more frequent and cheaper.

The proposed policy says that any major development on with more than 100 residential units on greenfield windfall sites should provide employment floor space.

I believe that ALL sites allocated through the Local Plan should provide employment space or provide monies to a nearby employment site in the same Parish and that the 100 houses is too high a target and all sites should provide employment space.  This is especially required in Cranbrook and Sissinghurst as non of the allocated sites are likely to meet this criteria and the Parish will have additional residents but no additional employment, forcing people to travel on already congested roads to major towns with poor and slow public transport links.

STR 1/CRS 1 – Limits to Build

The further/separate Limits to Build Development (LBD) within Sissinghurst is not acceptable as it has only been put in place now to allow TWBC to put more housing in the area.  The new LBD around Wilsley Pound and Mill Lane will start to connect two previously separate settlements (Mill Lane and Wilsley Pound) as TWBC policy will then allow infilling as shown in their assessment of Site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road).  This site has been assessed in the Cranbrook and Sissinghurst draft Neighbourhood Development Plan and development here is not supported by them so should not happen.  This infilling is not acceptable in a newly defined LBD especially given the rural and historic nature of Mill Lane.  Mill Lane is part of Sissinghurst Village and not Wilsley Pound and should not be included in the new LBD.  Point 3 of STR/CRS 1 states that landscape gaps between individual areas of the parish will be maintained so development of this site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road) is in contradiction to this proposed strategy.

DLP_7316

Mr Richard Gill

Policy Number: STR/CRS1 

The number of new dwellings allocated within the AONB in Cranbrook is too high. The NPPF makes it clear that the scale and extent of development in AONBs should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty.

I also object to the Limits to Built Development being redrawn to accommodate new developments with no regard for the sensitive nature of the AONB landscape and historic settlement patterns.

DLP_7626

Mr James Peace

Object

3. Reference is made to the Hawkhurst and Flimwell crossroads. Whilst Hawkhurst is relevant to travel south of Cranbrook bearing in mind the absence of employment locally or to the south of the town the principle points of impact will be on the A229 in Staplehurst and on the A262 at Goudhurst. Both these pinch points struggle to cope currently at peak times and would not be easily expanded to cope without substantial cost/impact. Goudhurst would need a bypass.

4. Permission has already been given for a substantial development on AONB. Little or no consideration was given to availability of sites for development within the LBD. In the absence of local employment and adequate infrastructure the plan to use AONB for future development cannot be justified.

DLP_6027

Kember Loudon Williams for Cranbrook School

Object

A separate report has been prepared to accompany these representations which seeks to increase the current housing allocation given to the Cranbrook and Sissinghurst Parish – see Chapter 3 for more details.

[TWBC: see full supporting statementattached to this comment. Chapter 3 is copied below]:

3 Strategic Growth

Relevant Policies: STR1, STR/CRS 1 and Key diagram 4. Housing

3.1 Policy STR1 of the Tunbridge Wells Borough Council Local Plan Regulation 18 Consultation details the development strategy for the Borough. Part 5 of the Policy lists the Parish of Cranbrook and Sissinghurst as being suitable for further housing development and table 3 lists the proposed allocations for housing as a maximum of 803.

3.2 For the reasons set out in Chapters 6 & 7 (Big Side and Rammell Field), we consider there is the potential to increase the total housing allocations in Cranbrook in the region of 50-60 more dwellings. The first opportunity is to extend the proposed housing allocation at Big Side Playing Field to the north of the town by 10 dwellings in order to accommodate up to 25 units; and the second is to reconsider part of Rammell Field as a suitable housing site for 40-50 units.

3.3 The development strategy (STR1) has already recognised Cranbrook as being a sustainable location for new housing due to the range of services and facilities offered within the town. In addition, being located outside of the Green Belt, Cranbrook is considered more suitable for new development than many other locations in the Borough.

3.4 Rammell Field is considered well suited in terms of its central location to accommodate new local needs housing, particularly in light of the surrounding residential character to the site and, potentially, playing a key role in supporting local housing needs – discussed more fully in Chapter 7. Although the site is proposed as a Local Green Space designation under the Regulation 18 consultation we are objecting to this classification for the entire site, and would argue that a part green space allocation and part housing allocation, to include affordable and local needs housing, would make more efficient use of land within this central location, whilst representing an overall gain to the local community.

3.5 The north/east corner of Big Side Playing Field, to the north of the town, has already been considered as a suitable site for a housing allocation of up to 15 units. However, given the proposed location of housing has already been accepted here within the Draft Local Plan and would already involve the partial loss of a playing field, in our view, it would make sense to expand the housing allocation to reach a capacity of up to 25 dwellings. Chapter 6 considers this proposition in more detail in relation to draft allocation AL/CRS 2 and the option of being able to replace the displaced playing pitch in a more suitable location closer to the School.

3.6 The Key Diagram Figure 4 of the Draft Local Plan illustrates the spatial strategy and broad distribution of housing development across the Borough. In light of the above comments, we propose this Diagram be updated to reflect the additional growth proposed at the Big Side and Rammell Field sites. We also seek an amendment to Table 3, which follows Policy STR1 and identifies the scale and distribution of development. To account for the additional development in Cranbrook being sought through our representations we seek an increase to the current maximum number of allocations provided for the settlement of Cranbrook of up to 863 units.

3.7 In line with the above proposals we recommend Part 1 of draft Policy STR/CRS 1 (The Strategy for Cranbrook and Sissinghurst Parish) also be updated to reflect the 50-60 additional housing units proposed to be accommodated in Cranbrook. We refer to part two of the policy which acknowledges that additional housing to the draft allocations may be delivered through the redevelopment of appropriate sites and other windfall development. Given the number of additional units proposed at Rammell Field, we consider it appropriate to include this site as an additional allocation, under Part 1 of the Policy.

Playing Fields

3.8 Cranbrook School has a rich sporting heritage and the School is committed to ensuring that sport continues to thrive in the future. The School continues to successfully compete with the best locally available School opposition (including larger independent Schools) and the keen intent, high quality facilities and teaching is a major contributing factor to the School’s appeal for boarders. It is therefore vital that the School continues its commitment to improve the existing sports equipment and facilities.

3.9 Three of the sites we are promoting/supporting through this Local Plan process involve existing playing fields, two of which are already proposed to be allocated in part for some housing development in addition to the retention of the majority of the respective sites as playing fields. It is therefore important we consider the national guidance relating to proposals which affect existing playing fields, as part of our representations for these sites.

3.10 It should be noted that Sport England’s policy is to oppose the granting of planning permission for any development which would lead to the loss of, or prejudice the use of, all or any part of a playing field, unless one or more of the five exceptions stated in its policy apply:

Sport England Policy

Summary of Exceptions

Sport England Policy

Summary of Exceptions

An assessment has demonstrated that there is an excess of playing fields in the catchment and the site has no special significance for sport

The development is ancillary to the principal use of the playing field and does not affect the quantity/quality of pitches

The development only affects land incapable of forming part of a playing pitch and would lead to no loss of ability to use/size of playing pitch

Playing field lost would be replaced, equivalent or better in terms of quantity, quality and accessibility

The proposed development is for an indoor/outdoor sports facility of sufficient benefit to sport to outweigh the detriment caused by the loss of playing field

3.11 In this case of Rammell Field, Jaegers Field and Big Side Field the main exceptions are likely to fall under ‘E1’ or ‘E4’.

3.12 The school is committed to improving its facilities including the quality of sports provision. Currently playing fields are dispersed and fragmented which is not ideal in terms of overall efficiency, pupil safety and maintenance. There are opportunities to consolidate and improve the quality and quantity of pitches and for pitches to be provided more centrally within the campus. This may include opportunities to create additional levelled playing pitches on land adjacent to the ‘grounds maintenance complex’ as well as potential opportunities to look to expand the land available in these locations.

3.13 In the case of Rammell Field, our proposal will result in the loss of a playing pitch which may need to be relocated elsewhere subject to further analysis. However, there will be general recreational provision provided in the form of the open space to be retained at the north of the field, fronting Bakers Hill. This recreational space will now be publicly accessible which will be a major benefit to the community.

3.14 The school intends to produce a comprehensive Playing Fields Assessment and Strategy in due course that would inform future planning applications on all three sites.

DLP_7235

Elizabeth Daley

Policy Number: STR/CRS1

The proposed number of houses for the Parish of Cranbrook and Sissinghurst is unjustifiable as most of the areas where development is proposed, lie within the AONB.

An independent consultee has assessed the need for Parish housing and returned a lower figure which is deliverable on small scale sites.

Cranbrook should not be categorised in the same settlement hierarchy as Paddock Wood which has a significantly larger population and a railway station connecting directly to London.

DLP_6199

Marion Cranmer

The designation by TWBC of Cranbrook as an urban area is a fundamental flaw in the draft plan, affecting all further considerations. Cranbrook, a small rural town, being considered in the same category as Tunbridge Wells and Southborough, has resulted in many totally inappropriate decisions by TWBC.

It is vital that any housing in the parish of Cranbrook and Sissinghurst should be well above the minimum standards of construction required, in the best combination of designs, sizes and types of tenure to meet local needs, and in the places that have the least amount of negative impact on the parish and its wider environment.

The public response to NDP consultations in Cranbrook and Sissinghurst parish has shown a strong preference for small housing developments, rather than large developments.

DLP_6203

Marion Cranmer

Policy STR/CRS 1

  1. The housing numbers for the parish of Cranbrook and Sissinghurst proposed by TWBC do not take into account the recommendations by the NPPF, the protection of AONBs, or recommendations by the CPRE.
  2. The high number for allowance of development as windfall means that the parish may take many more houses than those shown in current allocations.
  3. It is not just the A21 and A268 junction that need to be considered when looking at the housing numbers for the parish of Cranbrook and Sissinghurst proposed by TWBC. There are already significant bottlenecks at Hawkhurst, Goudhurst and Staplehurst. All of these need to be considered.
  4. The number of dwellings proposed for within the AONB is outrageous.
  5. Just putting more housing along the AONB borders will significantly impact on it.
  6. Although developers are paying lip service to landscape gaps between settlements, token strips of green along the road edges do not, and will not prevent coalescence. The current development allocations within the parish of Cranbrook and Sissinghurst will mean that an aerial view of the area in 5 years will show broadly one large settlement that encompasses Cranbrook, Hartley, Sissinghurst and Wilsley.
  7. Truly safe and efficient links between the settlements need to be provided between current areas and future developments.
  8. Car parking in central Cranbrook is already very well used, sometimes already at near capacity. More housing will need increased parking, particularly to maintain the attractiveness of the area for shoppers and tourists. Sissinghurst already has difficulty reconciling the need for safe access/ through traffic, with the need for parking.
  9. Green spaces could be increased by widening the width of the buffers provided to protect areas of ecological importance.
  10. The significance of heritage in the importance of heritage in Cranbrook and Sissinghurst parish has been totally underestimated by TWBC, in terms of the need to preserve buildings, non-built environments, gardens (such as Sissinghurst), woodlands and natural areas for the future. They also attract tourists, with their related economic importance, for both the local and wider areas. They are also of great importance to the people living and working in the parish.
  11. It is of great concern that extensions to, and the introduction of a new LBDs will have a hugely negative impact on the conservation areas in the parish of Cranbrook and Sissinghurst.

a. The proposed extension to Cranbrook Primary School will necessitate very careful consideration of safe access and parking. It will also have a huge environmental impact in terms of journeys made to and from the school.

b. Current health facilities in Cranbrook are woefully inadequate (not the fault of the doctors), and promises of a future health centre are not certain enough for any confidence in future provision. The lack of medical facilities in Sissinghurst also have a very negative impact in terms of journeys made to other medical facilities.

c. The proposed Cranbrook community centre needs to truly be a community centre. Despite the advantages of having many different services in one place, the danger is that it will become a cheaper multi-purpose building that does not provide any of its services adequately, let alone well.

f. The importance of the Crane Valley as an area of environmental value is greatly underestimated by TWBC. The width of protective strips that developers are required to provide is totally inadequate, especially as they are often at least partly destroyed during the building phase of a development, but cannot simply be recreated.

DLP_6204

Marion Cranmer

OTHER

Putting most employment opportunities in the Tunbridge Wells area greatly increases the impact of residents in the borough having to travel long distances to work, with the associated negative impact on the environment.

Proposals to incorporate Cranbrook Library into one multi-purpose community building.

There has not been any recent formal engagement with the community on this proposal.

Libraries provide so much more than a way of borrowing books. Any change to the current provision would have to improve on it, not just equal it.

TWBC must ensure that any future development, of any kind, does not have a negative impact on dark skies.

DLP_7043

Philippa Gill

Policy Number: STR/CRS1 

Object

The number of new dwellings allocated within the AONB in Cranbrook is too high. The NPPF makes it clear that the scale and extent of development in AONBs should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty.

I also object to the Limits to Built Development being redrawn to accommodate new developments with no regard for the sensitive nature of the AONB landscape and historic settlement patterns.

DLP_6992

Nigel Tubman

Object 

The proposal to include up to 813 dwellings in Cranbrook and 115 dwellings in Sissinghurst is totally at odds with the housing need assessments carried out over the years. This proposal is designed to bring in a large number of new residents into the area and create urban sprawl and thus detract from the area’s attractiveness. The way the area has grown naturally over the years is one reason why people like to live here and tourists and others like to visit. Such a large scale building programme will overwhelm this small town and surrounding area.

The infrastructure is totally inadequate. To expect statutory organisations such as BT, water and sewage, gas, electricity to provide an adequate service to existing and future needs is unrealistic. The infrastructure is already under severe strain due to lack of investment over the years.

The area needs new jobs but access to training for local people is very poor so local employers with vacancies find it difficult to get properly trained and qualified staff. Public transport is very poor and the existing bus services have irregular timetables to Tenterden, Tunbridge Wells and Staplehurst and Maidstone which makes it very difficult for working people to use the buses to get to their place of work.

Tourism has huge potential in this part of the Weald. Why no strategy to encourage it? There is a wide network of public footpaths but many are neglected and poorly signposted and maintenance non-existent.

There should be an intention to improve the local roads to allow cyclist, walkers and car users to use the roads in safety. The centre of Cranbrook is very congested with cars and delivery vehicles and car park spaces are few and far between. Stone street in particular is very unsafe for pedestrians. More cars and vehicles will reduce the quality of life and discourage even more people from walking into town.

There should not be any building on playing fields in Cranbrook and Sissinghurst. These should be retained for future generations to enjoy as open spaces and for exercise and social activities. If as a society we want to encourage people to exercise more, what sort of signal does it give if playing fields can be built on?

DLP_5736

Bruce Seton

I have looked at this Strategy paper and have put my comments into the text of your online text. Briefly I think you have failed to follow your own Strategy. You have said in your 3rd point that developers only have to establish the impact of any development on the crossroads in Hawkhurst. Traffic from Cranbrook does NOT pass through this crossroads so it is easy for any developer to satisfy this requirement. It is a ridiculous requirement.

Your Pointv 6 - Developments should ensure landscape gaps are retained to prevent coalescence of development – who uses these words. ALL the proposals are ribbon developments.

My comments in more details are below.

The Strategy for Cranbrook and Sissinghurst Parish

Policy STR/CRS 1

The Strategy for Cranbrook and Sissinghurst Parish.

At the parish of Cranbrook and Sissinghurst, as defined on the draft Policies Map, proposals shall accord with the following requirements:

1. Approximately 718-803 new dwellings will be delivered on nine sites(*) Why this number? The last survey for the 2 parishes indicated a need for some 610 units. Was this number produced from a survey or ? allocated in this Local Plan in this plan period (Policies AL/CRS 1-9) and approximately 100-115 new dwellings on five sites in Sissinghurst (Policies AL/CRS 12-16) in this Local Plan in the plan period. (*) Of these sites, the following already have planning permission: AL/CRS 4 for 36 dwellings andCRS 8 for 28 dwellings;

2. Additional housing may be delivered through the redevelopment of appropriate sites and other windfall development in accordance with Policy STR 1;

3. All development proposals will be required to establish the impact of the proposed development upon Hawkhurst and the Flimwell crossroads (junction of A21 and A268); Traffic from Cranbrook does NOT pass through these two crossroads. It will thus be simple for the developer to show that their proposal has no impact on these crossroads. The proposals should show that the increase in traffic will make no serious impact on the various pinch points in and around Cranbrook/Sissinghurst including the crossroads in Staplehurst and traffic through Goudhurst. Both of these are already a major concern during the obvious times and are surrounded by buildings precluding road widening measures.

4. Where a site is within the AONB, it should be demonstrated that the proposal will make a positive contribution towards achieving the objectives of the most recent AONB Management Plan and show how relevant guidance from the AONB Joint Advisory Committee has been considered to meet the high standards required of the other policies in this Plan for the High Weald AONB landscape;

5. Sites outside the AONB but within the High Weald National Character Area, or close to the boundary of the designated AONB landscape, will have similar characteristics and are likely to contribute to the setting of the designated landscape. The AONB Management Plan and any supporting guidance will be a material consideration for these sites;

6. All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development; The sites discussed are (deliberately?) in locations between ‘individual areas of the parish’ and thus create the certainty of ‘coalescence of development’ ratherthan prevention. Thus CRS 2 is by the description in 5.73 “The site is located within the AONB and is adjacent to Wilsley Conservation Area”.

The combination of CRS 4 (Turnden Farm) and CRS 9 (200-250 dwellings) ensures that the development will result in a ribbon of development from Cranbrook to Hartley ensuring an extended “Coalescence of Development”. This will be further emphasised by CRS 6 at the other end of Hartley heading off towards Hawkhurst.

7. Maintenance and enhancement of, and/or linkages to, public rights of way or the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility; to include contributions towards the proposed Bedgebury to Sissinghurst cycle path route;

8. The following public car parks within Cranbrook and Sissinghurst, and as defined on the draft Policies Map, will also be retained in accordance with Policy TP 4: Public Car Parks: These car parks are already close to full at many hours of the day (and night) and the approved plan (16/503953) with 28 dwellings, a community centre, one A1 retail unit and possibly a medical centre, the probability of sufficient parking being included in the development rather than causing over parking in these Public Car Parks seems remote. And that is before the rest of CRS 8 is developed.

* Tanyard

In short, your developments fail many of your own Policies. Commenting on the details are not worth the time taken.

DLP_5931

S J Ireland

My personal interest is as a local resident of Cranbrook with professional experience as past Director of Open Spaces for City of London (recently retired), a career in Landscape Management and a Fellow of the Landscape Institute.

  1. Having reviewed the retail study and your proposals for Tunbridge Wells, I object to the number of houses you have allocated to the main urban area. Your report accepts that the retail sector is changing significantly and yet your proposal to locate on average 1271 houses (whilst for example, requiring Cranbrook to take 761) is proportionately wrong. This is the ideal location for apartments- particularly one and two bed accommodation aimed specifically at younger and older elements of the population; where all the services are located close by and limited transport requirements. needed. By increasing the housing in the main urban area, your sustainability requirements will be easily achieved.
  2. Cranbrook has substantial AONB landscapes. I found no explanation , within the plan, as to why you are ignoring government policy which allows the Council to reduce the housing pressure by 50% in such cases. You have a duty to protect theses landscapes.
  3. The use of the term " affordable housing" is unhelpful because such units are not affordable by local people. I would encourage you to review your policy and instead focus on 1 & 2 bed properties, which can better suit need.
  4. The Leisure and Recreation policy makes no reference to Cranbrook schools sports pitches which are used in part by the community. At the very time you are proposing increasing housing and thus population; a full assessment of future recreation needs is required. Once sports facilities have been lost it is much harder to replace, particularly in a "rolling" landscape where flat or level land is limited.

DLP_5749

William and Georgina Owen

For the following reasons we wish to object to the draft Local Plan for housing in respect of the Cranbrook and Sissinghurst:-

The plan should be based on local housing requirements and the proposals considerably exceed local needs.

The scale of the proposals is contrary to NPPF, paragraph 172 which states that 'Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues.

Cranbrook and Sissinghurst are situated in an 'An area of Outstanding Natural Beauty' where there is a presumption against development ,unless it is for local needs or for exceptional circumstances.

The scale of development is also contrary to Tunbridge Wells Borough Council adopted policy for the High Weald AONB as set out in the AONB management plan 2019-2024 as adopted by TWBC in March 2019.Objective 2 of which is to 'protect the historic pattern and character of the settlement and the distinctive character of towns, villages, hamlets and farmsteads and to maintain hinterland and other relationships (including separation) between such settlement that contribute to local identity' (page 33).

This region is an important tourist region dependant on its wide open spaces and natural beauty.

The allocation of homes to the countryside is disproportionate to the allocation to the urban townships such as Tunbridge Wells and Sevenoaks.

It is the townships that have the infrastructure to support expansion not the rural villages and hamlets.

The roads in the area are already busy and dangerous and not capable of supporting a large traffic increase.

50% of residents in the Borough already commute out of the Borough to work. This percentage can only increase as there is insufficient employment in the area to sustain any sizeable increase in population.

A large traffic increase is an inevitable consequence.

With the prospect of England becoming a non EEC Country we need our brown field sites to support agriculture to feed our growing population.

The proposals would threaten wildlife habitat.

On behalf of those of us living in the rural community we would request that Tunbridge Wells Borough Council reconsider their position and the suitability of the Local Plan.

DLP_5980

Steve Rix

Policy STR/CRS 1 (page 200) I object to the Limits to Built Development being redrawn to accommodate new development – the reasoning being that the new site is annexed to the existing LBD. This means that LBDs can redrawn to accommodate new development with little regard for the sensitive nature of AONB and historic settlement patterns.

DLP_5985

Steve Rix

Policy STR/CRS 1, point 8 (page 201) I object to the lack of provision for new car parking infrastructure in the centre of Cranbrook. This is not infrastructure led. The supporting document Topic Paper 4 for Parking Strategy 2016-2026 uses different data for number of houses proposed for Cranbrook and therefore the demand for parking. It states 259 new houses in Cranbrook instead of the Local Plan’s proposed average of 900. It is simply not enough to retain the current car parks – if people can’t park they can’t use the town and this undermines the policy to encourage rural business, as described in Policy ED 8 (page 478) and supporting paragraphs 6.472 and 6.473 (page 477).

DLP_6038

Laura Rowland

Policy Number: STR/CRS 1

The number of new dwellings allocated within the AONB in Cranbrook is too high. Planning Practice Guidance (PPG), revised July 2019, states ‘The National Planning Policy Framework makes clear that the scale and extent of development in [AONBs] should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. Paragraph: 041 Reference ID: 8-041-20190721.

TWBC has failed to limit the scale and extent of development proposed in the AONB and, contrary to PPG, has sought to meet the needs of adjoining non-designated areas within the borough through allocating increased numbers to the AONB (see STR1) .

DLP_6148

Turley for Taylor Wimpey UK Ltd

Whilst our client supports the need for and benefits of strategic growth at Cranbrook, they contend the Sustainability Appraisal (September 2019) and SHELAA (July 2019) that informed this Draft Local Plan Policy contained fundamental site assessment errors and inconsistencies, which appear to have contributed significantly to the omission of SHELAA Site Ref: 25 in favour of less sustainable and peripheral sites to the west and east of the settlement (Draft Allocations CRS6, CRS7 and CRS4).

For example, the conclusion of the SHELAA (July 2019) indicates Site 25 may be unsuitable for housing, owing to a perceived ‘…concern about ability to provide an appropriate means of vehicular access to the site, which is likely to require access through adjacent site’. However, we can confirm that an ‘adjacent site‘ is not needed to form a suitable and appropriate means of access to this site. Taylor Wimpey is working with local housing association, Town & Country Housing (TCH) to deliver this site. TCH own the land and properties at the end of Frythe Way, from which access is proposed to be taken. We attach a letter from TCH confirming this forms part of the red line site submission and is readily deliverable without the need for an ‘adjacent site’ (See Document A).

This factual inaccuracy within the assessment of the site in both the SHELAA (July 2019) and Sustainability Assessment (September 2019) has in our view incorrectly underscored the accessibility credentials of this site. In doing so, our client contends the Council has incorrectly discounted this option in favour of less accessible peripheral options. Our client instructed consultant transport engineers i-transport to examine and conclude on this in further detail (see appended Document B). I-transport’s assessments conclude that Site Ref:25 has indeed been significantly underscored against the transport sustainability objectives of the Council’s Sustainability Assessment (SA). Our clients respectfully request therefore that the site be reassessed in light of these factual corrections.

The second stated ground for concluding that Site 25 is unsuitable for housing relates to a perceived negative impact on landscape from the loss of a greenfield site in the AoNB adjacent to this settlement. Yet a similar comment is absent in the SHELAA in respect of draft allocations CRS7, CRS4 or CRS6, which are also in the AoNB, yet comprise lands we contend are far less contained and related to the settlement than Site 25. Site 25 is surrounded and contained by existing landscaping that is capable of being enhanced further; comprising a highly accessible location for a modest development of the scale proposed by our clients (around 70 homes). Our client instructed landscape consultants CSa to independently assess site 25 and compare this with draft allocation sites CRS6, CRS4 and CRS7 (see Document C). The conclusions highlight landscape impacts in respect of CRS6, CRS4 and CRS7 that appear to have been understated and/or inconsistently assessed and compared with those arising from Site 25.

For example, draft allocation CRS7 is in the AoNB, detached from the urban area and was categorised in the Council’s own landscape assessment [2 Landscape Sensitivity Assessment of Additional Settlements in Tunbridge Wells (Paddock Wood, Horsmonden, Hawkhurst and Cranbrook), LUC, July 2018.] as having a ‘strong separation from adjacent settlements’ and ‘very sensitive to any strategic development’. The western half of Site CRS7 is also stated as playing ‘a significant role in the setting of the Cranbrook Conservation Area’. Yet, unlike the assessment undertaken on Site 25, the SHELAA seeks to assess different densities and forms of development that may be acceptable in this location. The SHELAA concludes that whilst the site is detached from the settlement, it lies in proximity to it, has pedestrian access to the centre of Cranbrook and is likely to be sustainable in this context. Site 25 is conversely attached / part of the settlement, contained by existing landscaping and has arguably better pedestrian access to the centre of Cranbrook. It is therefore unclear how the Council concludes that Site 25 is not sustainable in this context. Our client can only assume that the Council have not accounted for the evidence highlighted in this letter, including that now confirmed regards a suitable access and its landscape containment credentials. Our client contends that had such evidence been accounted for, the SHELAA and SA would have concluded that Site 25 is a logical, suitable and sustainable integrated extension to Cranbrook. One that has notable advantages over one or more of the alternatives proposed at sites CRS6, CRS7 and CRS4 and should be ranked sequentially higher on its sustainability credentials as a consequence.

In addition, Draft Local Plan allocations CRS4 and CRS6 seek to locate development to a far more peripheral location at and beyond the settlement edge. Options that taken together seem set to contribute to the sprawl of the settlement towards the south west into Hartley. Options that do little to respect each settlements identity, nor reduce the need to travel by car to local services and facilities, almost all of which are located in Cranbrook. Site CRS7 is detached from the urban area and at odds with the Council’s own Landscape Sensitivity Assessment [3 Landscape Sensitivity Assessment of Additional Settlements in Tunbridge Wells (Paddock Wood, Horsmonden, Hawkhurst and Cranbrook), LUC, July 2018. ]. Conversely, Taylor Wimpey’s Frythe Way proposal is better located and contained; and comprises a relatively modest development (around 70 homes) that respects the character and context of its location. Our client therefore respectfully requests that TWBC re-assesses the benefits of this modest site in liaison with the Parish Council and Neighbourhood Plan Steering Group as soon as possible.

[TWBC: see full representation and supporting document A, supporting document B , supporting document C, and supporting document D]. 

DLP_6275

Susan Heather McAuley

Sissinghurst is an international tourist centre and is at least as important as Cranbrook for tourism – more than 200,000 visitors between April and October - but has not been mentioned.  The importance of tourism in Sissinghurst should contribute to the decisions made about the natural and built environment, approaches to the village etc.

DLP_6303

Susan Heather McAuley

Policy Number: STR/CRS 1

This is the place-shaping policy for Sissinghurst.  The people of Sissinghurst are interested to know what shape is proposed for Sissinghurst.  The proposed building suggests we are planned to be a new Staplehurst.  TWBC should be transparent about what their plan for our small village is. Is it because Bramling Gardens eventually got permission that we are seen as damaged and fair game for all excess housing need?  We are not Cranbrook.  We have traditionally been a hamlet of Cranbrook.  This scale of building will destroy the fabric of our village, our sense of pride and our sense of place.

Some people want to live in towns, others in villages.  Their reasons for this choice are distinct.  While extra house building in a town will not change life for most people in that town, building large numbers of extra houses in a village very quickly can take away the features that made people want to live on that village – a sense of belonging, of safety, of knowing the people that walk past your house.

We have always had new houses built in Sissinghurst – over the last twenty years – Hop Pocket Close, Church Mews, Cobnut Close (not yet completed) – this growth has been small-scale and organic.

In a town your group of friends may be made up of people from different streets, that you know through work, or clubs or sporting activities.  You may not know further than your immediate neighbours that well and usually don’t mind that. In a village you know everybody and everybody knows you.  That does not suit everyone but it does suit the people who choose to live in a village.  Organic growth enables new people to be assimilated into a village structure.  Fill the village with so many houses in a short time that you have no hope of knowing everyone, put those houses in giant cul-de-sacs (Bramling Gardens in Sissinghurst) where people have no need to mix with other parts of the village and you destroy that village and the reason for living there.  Extra buses and parking spaces will not mitigate this.

If you have had village people work on this Local Plan they will have explained this difference to you.  Village people have the same right to a chosen way of life as town people have.  You want to enhance Tunbridge Wells town by have extra work and shops and cultural activities which is wonderful for the people of Tunbridge Wells.  It will create a ‘well designed and sustainable’ community that will endure into the future.  For some of our villages this Local Plan will create a totally unsustainable community that will be a dormitory with no social structure.  This Local Plan is socially unsustainable for a Wealden village like Sissinghurst.

Point 1 – 110-115 more houses for Sissinghurst is totally out of scale with the existing settlement.  People live in Sissinghurst because they want to live in a village, not an urban-sprawl dormitory which is what this Local Plan would move us towards.  Sissinghurst is identified as a Village Centre in Policy ED8, not a Neighbourhood Centre.  There is no justification for the level of building proposed for Sissinghurst – it is not economically, environmentally of socially sustainable.

TWBC have not given due regard to the assessed and allocated sites for the Parish already made by the Parish Council Draft Neighbourhood Development Plan.  Some sites such as AL/CRS13 are unsuitable and unsustainable and should not be developed.  Local knowledge has informed this conclusion. Site AL/CRS/13 should be excluded from the TWBC local plan.

Point 6 – the proposed building at Mill Lane will close the gap between Wilsley Pound and Sissinghurst – there will be no green space between the two.  This is against principles stated in this Local Plan – against coalescence – and also against the policy in our emerging NDP.

The LBD should not be changed here – this is being done simply to allow AL/CRS/13 to go ahead.

DLP_6324

Persimmon Homes South East

Cranbrook Distribution of Development

The draft Plan includes nine housing allocations in Cranbrook accommodating between 474-559 dwellings.

We consider that the Draft Plan has allocated two sites in Cranbrook which are less sustainable and less suitable than our Site:

  • Firstly, Draft Site Allocation CRS4 Turnden Farm, Hartley Road has been allocated for 124-134 additional dwellings. This site has been allocated on the back of a planning permission for the redevelopment of the farm building complex. The allocation extends beyond the previously developed land to include wholly greenfield land. It is considered that the allocated greenfield land is more exposed than our Site and also relates far less well to the settlement. This land is also less accessible and thereby less sustainable. The allocation appears to have progressed on the basis that extensive green infrastructure will be provided which would mitigate the landscape impacts.

Our Site is more sustainably located and is less sensitive in landscape terms. Furthermore, as discussed above any landscape impacts can be dealt with by way of comprehensive green infrastructure.

  • Secondly, Draft Allocation CRS7 Land off Golford Road has been allocated for approximately 150 dwellings. As noted in the supporting text this site is “detached from the existing Cranbrook Limits to Built Development”. The site is entirely separate from the settlement and is very open and very exposed. It is demonstrably more sensitive in landscape terms than our Site.

    The supporting policy text suggests that the site has proximity to the settlement centre. However the site is some 900m from the centre of the town, which is further than our Site. It is also noted that Godford Road does not have a footway along the northern side.

It is evident that our Site is a more sustainable and suitable site than either of the above sites. However it is not suggested that these sites should be struck out of the draft Plan. Rather, it is considered that Cranbrook requires additional allocations to ensure that the development strategy is sound. This is discussed further below.

Cranbrook - Scale of Growth

The draft Plan includes nine housing allocations in Cranbrook accommodating between 474-559 dwellings. We note that allocation CRS9 has now been partially approved for 180 dwellings and the allocation should be amended accordingly. The total allocated housing figures for Cranbrook will need to be amended accordingly. It is consider that insufficient growth has been directed towards Cranbrook for the following reasons:

Sustainable settlement - Cranbrook is a sustainable location with a good range of services, facilities and good public transport accessibility.

The ‘Settlement Role and Function Study’ (February 2017) demonstrates that Cranbrook is the most sustainable settlement in the Borough outside of Main Urban Area (i.e. Tunbridge Wells and Southborough). On all four scoring criteria Cranbrook scores significantly better than its nearest competitors Paddock Wood (19% lower score) and Hawkhurst (32% lower score) as shown in the table below.

Score

1st Method

2nd Method

3rd Method

4th Method (average)

166

178

127

157

135

143

103

127

112

124

79

105

It is noted that significant growth is being directed towards Paddock Wood despite the settlement being less sustainable than Cranbrook (albeit not located within the AONB).

  • Local Housing Need - Cranbrook is a as a high value area and thereby has a high need for entry level housing to allow local people to get on to the housing ladder in the town. In addition there is a high need for affordable housing in the town.
  • Vital and vibrant town centre – The Tunbridge Wells Borough Retail Study has undertaken Health Check Assessments for the main retail centres in the Borough, the conclusion for Cranbrook indicate that the town centre has “a strong independent comparison goods retail offer” but also highlights that “the centre’s market share of comparison goods spending from local residents – and the indicative number of visitors to the centre from the recent Nexus pedestrian counts – have both fallen since the previous Study”.

The study also shows that both comparison and convenience spending in Cranbrook has fallen between 2013 and 2016. There is expected to be some limited increase in demand over the plan period.

It is clear that additional population growth will help support the vitality and vibrancy of the town centre over the plan period.

Some additional growth in Cranbrook above the level proposed, on suitable and sustainable sites, will ensure that best use is made of the settlements existing services, facilities and infrastructure, and help ensure that these services and facilities remain vital and viable in the years to come.

Summary

Whilst the Council have taken a proactive approach to accommodating the housing requirement over the plan period, the development strategy as current conceived is subject to several shortfalls which make is ‘unsound’. These issues can be addressed by directing additional growth toward sustainable locations around Cranbrook, most notably toward the Site [TWBC: land at Freight Lane, Cranbrook].

6. Summary and Conclusion

These representations have been prepared by Persimmon Homes in respect of the Land West of Freight Lane, Cranbrook, Kent.

These representation have demonstrated that the Site is a situated in a sustainable location on the edge of Cranbrook which is the most sustainable settlement in the Borough outside of the Main Urban Area.

These representation have shown that, whilst the Site is subject to some limited environmental constraints, these can be mitigated through careful design and the delivery of a comprehensive green infrastructure scheme.

Whilst the Council have taken a proactive approach to accommodating the housing requirement over the plan period, the development strategy as current conceived is subject to several shortfalls which make is ‘unsound’. These representations have highlighted that, these issues can be addressed by directing additional growth toward sustainable locations around Cranbrook, most notably toward the Site. 

In light of the preceding analysis, these representations have demonstrated that, whilst the Site is situated within the AONB, directing major development toward the Site would be entirely in accordance with the NPPF Paragraph 172 tests. There is a clear need for the development which cannot be accommodated in locations outside of the AONB and furthermore the limited detrimental environmental impacts of the development can be mitigated through sensitive design. 

In summary, these representations have demonstrated that the Site can deliver sustainable development and we respectfully request that the Site is allocated in the emerging Plan.

[TWBC: see full representation. Also see Comment Nos. DLP_6319, 6323-6326, 6328, 6830-6835, 6837-6839].

DLP_6575

Myrtle Newsom

Policy Number: Section 5 Cranbrook and Sissinghurst – Overview – Other Matters p198

Sissinghurst is an international tourist centre and is at least as important as Cranbrook but has not been mentioned. The importance of tourism in Sissinghurst should contribute to the decisions made about the natural and built environment, approaches to the village etc.

Policy Number: STR/CRS 1 Point 1

TWBC have ignored the assessed and allocated sites for the Parish already made by the Parish Council Draft Neighbourhood Development Plan. Some sites such as AL/CRS13 are unsuitable and unsustainable and should not be developed. Local knowledge has informed this conclusion. Site CRS/13 should be excluded from the TWBC local plan.

Policy Number: Section STR/CRS1

Point 6 – says coalescence will be prevented. However some proposals for building will remove the gap between Sissinghurst and Wilsley Pound (AL/CRS12 & AL/CRS13). These are two separate settlements.

DLP_6792

G M Whitehead

Policy STR/CRS 1

Where a site is within the AONB, it should be demonstrated that the proposal will make a positive contribution towards achieving the objectives of the most recent AONB Management Plan and show how relevant guidance from the AONB Joint Advisory Committee has been considered to meet the high standards required of the other policies in this Plan for the High Weald AONB landscape.

This is blatantly not true. How can the amount of development proposed for Cranbrook and Sissinghurst possibly make a positive contribution to the landscape of the HWAONB? 

All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development.

But will they be appropriate gaps and leave the vital views between buildings through to the landscape beyond? 

Bus services, including contributions towards a feasibility study to investigate the potential of creating a Demand Responsive Bus service for the parish and beyond;

The bus services in Cranbrook are totally inadequate now for the number of people wishing to use them to go to work places, especially to Staplehurst for a train to London. If you insist on allowing building on the scale proposed, especially allowing the developers to put up the sort of ‘executive’ houses from which they make more profits, you will be encouraging more and more cars onto the already inadequate roads.

DLP_7163

Kay Margaret Goodsell

What is the overall plan for Sissinghurst – to wipe it out and join it to Cranbrook?  This is what will happen with this plan – building at Golford, Crane Valley, between Wilsley Pound and Sissinghurst – it will be one big urban sprawl.

Point 1 – 110-115 more houses for Sissinghurst is totally out of scale with the existing village.

Point 6 – the proposed building at Mill Lane will close the gap between Wilsley Pound and Sissinghurst – there will be no green space between the two.  .

DLP_7367

Andrew Ford

The number of new dwellings allocated within the AONB in Cranbrook is too high.  Planning Practice Guidance (PPG), revised July 2019, states ‘The National Planning Policy Framework makes clear that the scale and extent of development in [AONBs] should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. Paragraph: 041 Reference ID: 8-041-20190721.

In our view TWBC has failed to limit the scale and extent of development proposed in the AONB and, contrary to PPG, has sought to meet the needs of adjoining non-designated areas within the borough through allocating increased numbers to the AONB. Cranbrook and Sissinghurst Neighbourhood Plan assessed the local housing need of these settlements as 610. The draft Local Plan allocates 918 to these settlements. The difference between these two figures clearly represents need from outside of the AONB which should not be accommodated within it.

, and amounts to approximately the numbers allocated to the three largest ‘major’ sites which are likely to cause the most harm to the landscape and natural beauty of the AONB. These major allocations are not necessary and should be dropped.

We support point 4.

Point 6 should be amended to read ‘All development proposals will ensure that landscape gaps between individual areas of the parish and between villages, hamlets and their surrounding farmsteads are retained to prevent coalescence of development.

DLP_7495

Margaret and David Firminger

These are our thoughts on this plan we were promised small developments. The traffic in the morning especially at school times is overwhelming . The plan at site near sewage works any traffic can only descend on a narrow street through an old Wealden town or down Chapel Lane to Sissinghurst , an awful dangerous exit  in to the high street parking on both sides of the road .

Infrastructure entirely inadequate as it is at present , what are your plans for adding to this . Are the residents being considered in anyway and the effect this has on a medieval town ,not an urban area is this  what you are planning ???

DLP_7572

James Lloyd

Object

I find much of the overall policy for Cranbrook and Sissinghurst to be unnecessary or unpersuasive. Much of what follows can also be said of individual allocation policies, so I am making the comments here in order to avoid duplication.

The figure of 718-803 new homes is ridiculously vast. Assuming that each house will contain an average of four people, then even the lower estimate would see the parish’s population increase by 2,872. The population in the last census was 6,717. The proposed development, if on the scale envisaged, must increase the parish’s population by around a third. This is a staggering increase in a small town over a brief space of time. The infrastructure to sustain it does not exist.

The policy proposes to retain the existing car parks. This is obvious but the envisaged population increase means that the existing facilities will be no where near adequate. At weekends, Jockey Lane and the Tanyard are nearly at capacity as things are and even the Regal/Co-op car park would struggle to accommodate the increased number of shoppers, especially at such peak times as Saturday afternoon.

Assuming that about half of the projected population increase will be children, over a thousand new school places will be needed. That is the equivalent of an entire, large school, yet it is existing schools that will be expected to accommodate them. The Borough Council may well have been told re-assuring things by their Governors but it is not credible that they can expand significantly. The Grammar School already occupies a considerable proportion of the town’s land and has built over most of what it owns, bar playing fields and. It is currently struggling to accommodate the two new entrance years (which are disproportionately small at present). The Primary School’s site is enclosed and it would have to sacrifice the play ground to expand further. Only the High Weald Academy, which is currently seriously under-subscribed, might accommodate hundreds of new pupils but HWA is a comprehensive and not all parents will want to send their children there. Despite its current small roll, numerous parents of comprehensive-school children choose to send their children out to schools in Maidstone and Tunbridge Wells, in preference to HWA. It is these schools that will have to assume the thousand-or-so new children who will be brought into the parish by the development.

Where are these people to be employed? Apart from a small number of retired people, each of these new houses will have at least one worker in it, most of them two. Circa 800 new houses do not equate even to circa 800 new jobs, still less to circa 1,600. Expansion of existing employment in Cranbrook can only be slight, so the overwhelming majority of these new inhabitants will have to work, as most of the adults in Cranbrook already work, in other towns, mainly Maidstone, Tunbridge Wells and London. This will involve a considerable increase in use of the roads, buses and trains, all of which are already crowded at peak times.

In sum, the proposed development plan is far too large to be feasible for a parish as small as Cranbrook. It would dramatically increase the population of the town, putting unbearable pressure on school places and road use and extremely limited local employment. The Parish Council, which is in a better position than the Borough Council to know and is also closer to the views of the community affected, conducted its own survey of local housing needs and came to a much lower figure of around 600 new homes. If introduced incrementally, this would allow the local infrastructure to keep pace and would form a much more realistic proposal that the people who will have to live with it might support.

DLP_7695

Alison Nicholls

All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development 

If the following go ahead (CRS 1, 2, 3, 4, 6, 7, 9, 12, 13, 15, 16, 17) then I fear that the landscape gaps referred to in this paragraph will be so decreased as to be negligible leading to the coalescence of development that is supposed to be prevented.

In addition I have serious concerns about limited access to CRS9 – how many roads will go and out of here? It appears on the plan that there is just one. Is this sufficient?

I have already expressed reservations in my objections online about the dangers of access to CRS 12 and 13. The current access onto both the A262 and the A229 from Mill Lane is difficult with limited vision onto fast moving roads. Increased traffic here (as both sites are sufficiently removed from Sissinghurst and Cranbrook meaning that new inhabitants would be car users) will create further dangers. I live along the A262 and used to frequently walk into the village but fear doing so now because of the increase in traffic and the speed of the vehicles using this road.

No regard seems to have been given to the important historical nature of Mill Lane.

Policy AL/CRS 1: Land adjoining Wilsley Farm, adjacent to Angley Road and Whitewell Lane

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1030

B M Body

Object

Ref: Site 125

I wish to register objections to the proposed development.

Considering that Whitewell Lane is now virtually one way the entrance on to the A229 Angley road has a very short window of view of traffic coming in the Hawkhurst direction.

The entrance on to the Goudhurst road, at the other end, is also afflicted. The exit from the Goudhurst road on to Whitewell Lane produces a hazard due to the hill in the Goudhurst direction

The traffic generated by the development of 15-20 houses will add considerably to these hazards.

This is a AONB and of historic buildings and a cluttered development of houses in no short a space would be of a cluttered effect.

DLP_3024

Cranbrook Conservation Area Advisory Committee

Object

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 1 Land adjoining Wilsley Farm, corner of A229 and Whitewell lane. (15-20 dwellings). Within and adjacent to Wilsley Conservation Area (CA), AONB, with nearby listed buildings and on high quality agricultural land. Proposal would transform unspoilt rural space within Wilsley CA into a substantial housing estate at great visual cost. Also would require crossing busy A229 to connect with most Cranbrook services. Conflicts with TWBC’s own policies on heritage and landscape (EN21). RED

DLP_3435

High Weald AONB Unit

Object

The front part of the site is within the Wilsley Green Conservation Area. The Conservation Area Appraisal states the following: “Relationship of the Conservation Area to its Surroundings Wilsley Green and Wilsley Pound developed as two scattered groups of buildings along the roads and around small areas of open space. This pattern of development has continued through ribbon development along the A229 to the north of the Conservation Area, including the area of the proposed extension to the north and along the A262 towards Sissinghurst. The Terracotta Restaurant, formerly The Windmill Public House and Windmill Cottages continue the settlement to the south along Waterloo Road. The buildings within the Conservation Area are now largely screened from the surrounding countryside because of the many mature trees which now lie within, and surround, the Conservation Area” (paragraph 4.2). “the most significant views from within the Conservation Area are those more contained along the roads, such as the views along Angley Road from the south west towards Wilsley Green, which include Wilsley Oast, Upper Willesley House and the cottages on the north west side of Angley Road” (paragraph 6.20). The proposed allocation would affect these views by the removal of vegetation for the access and exchanging a rural setting of trees and hedgerows for modern houses. The hedgerow affected is identified in the Conservation Area Appraisal as “significant tree lines and hedgerows” (Figure 3 on P27).

DLP_3292

Kent County Council (Growth, Environment and Transport)

 

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 1 – “Minimal vehicular access points into the site in the interests of highways safety and to reduce any impact upon the Conservation Area...”

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

The site has some potential for prehistoric and later remains, especially post medieval remains associated with the neighbouring post medieval farms and parklands.

Archaeological programme of works may be required.

DLP_4420

Lambert & Foster LLP for Mr Steven Sault

Support with conditions

Paragraph 5.71 and Policy AL/CRS 1

Further to our initial submission of the 15th March 2018 regarding land at the above, we respond to the proposed draft allocation of this land within the emerging local plan. In this regard we would comment as follows:-

a. The area identified within the allocation is noted. We do not find any historical or physical attributes as to either the spatial or land character which justify the delineation of the proposed allocation. It is understood subject to appropriate detailing, addressing the points set out in the policy criteria, with appropriate justification reconsideration at the area for residential development will be taken into account.

b. A design can be brought forward with minimal access points to reduce impact on the conservation area. This will be designed in such a way to comply and satisfy criterion 5 of policy EN1 and policy EN7.

c. Improvements to pedestrian crossings can be incorporated within this proposal subject to the agreement of the appropriate statutory authorities.

d. Appropriate landscaping detailing to protect where appropriate established trees and hedgerow to comply with Policy EN14 as well as a spatial and landscape layout which protects existing views, landscape, visual impact and heritage assessments to comply with policies EN1, EN7, EN20 and EN21 can be incorporated within the design proposals to the satisfaction of the planning authority.

e. It is noted there will be requirements to support offsite improvements. Similarly, the proposals will have to comply with the overarching policies, particularly related to affordable housing.

With regard to this proposed draft allocation, there has been much interest from the developer community. There is a range of proposals being put before the landowners to consider. These are from small local developers through to plc’s. It is probable details can be satisfied within the design which can be worked on over the winter period to bring forward a relatively early delivery of development for approximately 20 – 22 modest sized residential units.

DLP_4008

Brian Swann

Support

Near a main road and some other properties on a bus route (Cranbrook has very few)

Within easy walking distance of the Town Centre.

A small number of dwellings (15-20)

Please ensure that up to 1/2 are 1,2 & 3 bedroomed and affordable for local people.

Policy AL/CRS 2: Big Side Playing Field, adjacent to Quaker Lane and Waterloo Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_26

Garry Pethurst

Object

I object to the development of this site as it is considered by many as a "gateway" view into the town. I have further concerns regarding the access from Waterloo Road, as this can only be at the top of a hill and may impact the existing access to the Court Stile estate via Quaker Lane. Finally, I am concerned for the safety of the significant trees which stand inside the field running parallel to Quaker Lane.

DLP_963

Mrs A Marley

Object

Building on Part of Big Side of Quake Lane and Waterloo Road is not acceptable. I object. I consider it is essential that Cranbrook School retains all playing fields in view of increased pupil numbers. outdoor exercise, team spirit and regular fitness outdoors is essential and healthy.

DLP_3025

Cranbrook Conservation Area Advisory Committee

Object

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 2 Big Side playing field (10-15 dwellings) by Waterloo Road. Although a small scheme it is in the CA and involves considerable loss of hedges and trees, which are so much a positive feature and contribute to the green character of Cranbrook. It would seriously mar the much loved view from the West including the ancient cricket field. Access is off an already busy road. RED

DLP_2079

Terry Everest

Object

Object

Site is a playing field a should remain so.

DLP_3293

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 9 - “The provision of a pedestrian footway from Waterloo Road to Angley Road such that pedestrians can avoid the unsafe route along Quaker Lane, and from the southwest of the site linking to the town centre...”

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

The site has potential for prehistoric and later remains especially associated with the discovery of some Neolithic flints on the site itself. There is some potential for post medieval burials as there is a known Quaker burial site on the site of Quaker House. It may be that some of these burials have extended southwards in to the allocation site.

An Archaeological DBA would be appropriate to inform details of this scheme.

DLP_3926

Mrs June Bell

Object

Reasons for objection:

I. This allocation risks coalescence of the 2 currently distinct conservation areas; Cranbrook Conservation Area and Wilsley Green Conservation Area and contravenes the Requirement in Policy STR/CRS1 6. ‘All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development;’

II. This allocation risks loss of open green space on the entrance approach to Cranbrook and will risk a negative impact on the attractive downhill entry from the north as identified in the Cranbrook Conservation Area Appraisal which was prepared by TWBC in partnership with the Cranbrook Conservation area Advisory Committee.

III. This allocation risks loss Protected Views: 1

View 15 Townscape from Quaker Lane looking SW to Saint Dunstans & Windmill

1 http://cranbrookandsissinghurstndp.co.uk/wp-content/uploads/2019/09/152_QR_190724_Protected-Views-MAP-PHOTOS.pdf

DLP_4016

Brian Swann

Support with conditions

Support for 10-15 houses only in N.E. Corner-Front Waterloo Rd

Cranbrook School must produce a masterplan with CRS 3 & CRS 10

Houses to be mainly for their own staff & workers only.

Green area on map to be retained as a playing field.

DLP_4622

Anne Watson

Object

Cranbrook School’s offered sites        Objection

As a former PE teacher I am horrified at the amount of land dedicated to sports fields which Cranbrook School is offering for houses. Surely at this time of greater emphasis on school children becoming more physically active it can’t be right that Cranbrook School is proposing to submit all of its available playing areas.

DLP_6132

Cranbrook & Sissinghurst Parish Council

Object

Considered essential that Cranbrook School retains all playing fields in view of increased pupil numbers.

DLP_6137

Cranbrook & Sissinghurst Parish Council

Object

Objection because this allocation risks coalescence of the two currently distinct Conservation Areas. This allocation also risks loss of open green space and protected views.

DLP_6028

Kember Loudon Williams for Cranbrook School

Support with conditions

Whilst the trustees support the housing allocation they query the rationale behind the size of the allocated area and make the case to enlarge this area, given the existing allocation already results in a partial loss of playing fields and includes development on the site frontage.  An allocation for housing that better relates to the character and pattern of existing development is considered more suitable in this context. See Chapter 6 of the supporting report prepared for more details and for individual comments on the policy requirements.

[TWBC: see full supporting statement. Chapter 6 is copied below]:

6 Big Side Playing Field

Relevant Policies: AL/CRS 2

6.1 The site is located to the south of Quaker Lane, to the west of Waterloo Road, to the north of Cranbrook and adjacent to the established housing on Wilsley Green. The site is adjoined, on three sides by the limits to built development for Cranbrook and set within the AONB. It is also adjacent to the Wilsley Green Conservation Area.

6.2 The site is owned by the Governors of Cranbrook School and used as playing fields, primarily in the summer for cricket purposes and in the winter months for rugby. A pavilion is situated to the western boundary, and the site is adjacent to residential properties and a former pub fronting Waterloo Road to the east.

6.3 The site is proposed for part residential development of up to 15 dwellings under draft policy AL/CRS2 as shown below. The remainder of the site will continue to be used as playing fields. Housing development in the north eastern quadrant of this site is considered to be in keeping with the prevailing character of the surrounding area.

[TWBC: for Figure 5 site plan, see full supporting statement].

6.4 We consider the site has the potential to provide a greater capacity of residential housing without a significant change in visual impact terms. It is therefore suggested that the maximum capacity for the site be moderately increased to offer a maximum of 25 houses rather than the current total of 15 dwellings. The suggested change to the proposed residential allocation is shown in the below diagram.

[TWBC: for Figure 6 site plan showing allocation amendment, see full supporting statement].

6.5 Here we suggest the outline to the proposed housing site be extended slightly to the north- west. It is considered that the boundary suggested above would represent a well-defined and logical edge to development, lining through with Quaker Drive to the north-west and with established residential properties and curtilages, to the south. It is envisaged that a new landscape buffer could be included to the western boundary of the proposed allocation.

6.6 Proposed development would need to be respectful of the adjacent Wilsley Conservation Area and AONB in terms of its character and appearance. We understand also that any development would also need to acknowledge draft policy EN18 which refers to development respecting areas of important open space.

6.7 The revised boundary to the housing site at Big Side would provide more space and a less constrained shape of site, thereby offering more options and flexibility in terms of potential layouts. Furthermore, it is proposed that the proposed extension to the housing allocation takes account of the likely need for a degree of setting back between the road and new development, given the exposed corner location of the site and views from Waterloo Road. In order to account for this, more land to the west should be included within the allocation as shown in Figure 6.

6.8 It is felt that in light of TWBC already accepting housing development in this location in principle, that a further slight extension to the existing allocation is logical. Our suggested extension (Figure 6 above) would not have any materially greater impact in either visual or landscape terms subject to appropriate design and landscaping, and the extended land would be away from the Conservation Area boundary.

6.9 The topography at this part of the site is such that wider views of Cranbrook town cannot be gained, due the levels changing considerably, and falling away towards the town and meaning that there are no associated coalescence concerns between Wilsley and Cranbrook, given the areas of retained open space between the two main built up areas. This has already been accepted by TWBC in the proposed allocations of land west of this site, and north of the Primary School (draft policy AL/CRS 5). Furthermore, the dense tree and landscaping belts located to the east and northeast of the site, enclose the site from wider views in these directions.

6.10 The proposed development lies adjacent to the Wilsley Green Conservation Area Boundary, shown in figure 7 below. The Conservation Area boundary was amended in 2012 to include the cottages on Quaker Lane to the west of the site, and the former pub (Windmill Inn) and row of late 19th Century cottages on Waterloo Road to the south, as these were felt to represent positive buildings within the Conservation Area. It is noted that a residential allocation is proposed on land adjacent to this part of the Conservation Area, under policy AL/CRS 5. The post war housing development opposite the site to the north is outside of the Conservation Area. Any new development in addition to the existing allocation would seek to enhance the quality, character and appearance of the existing Conservation Area, through the use of appropriate materials, design and landscaping and will endeavour to respond to the visions and opportunities set out in the Conservation Area Appraisal.

[TWBC: for Figure 7 map showing Wlsley Green Conservation Area Boundary, see full supporting statement].

6.11 The housing allocation proposed by draft policy AL/CRS 2 involves the partial loss of an existing defined playing pitch. Given that the functional use of the entire playing pitch in this part of the site will be lost should the housing development go ahead, the suggested expanded housing allocation will not result in any further loss of usable playing pitches. There would still be room to accommodate a second smaller cricket pitch on land to the west of the proposed allocation in the summer. The loss of the defined playing pitch forms a small part of the overall playing fields at “Big Side” and will be considered fully as part of a comprehensive Playing Fields Assessment/Strategy to be prepared in support of any future planning application and in accordance with draft policy requirement 5 of AL/CRS2 and Exception 4 of Sport England Playing Field’s Guidance.

6.12 The School is mainly supportive in terms of the remainder of policy AL/CRS 2 requirements but do have some reservations as follows.

6.13 Whilst we do understand that any future application would need to respond fully to certain policy requirements, we would ask TWBC to reconsider the removal of parts 1 and 2 of the policy which refer to the submission of a masterplan as part of any proposals for the development of the site.

6.14 Essentially any application submitted on the basis of this allocation should be considered on its own merits and whilst any proceeds from the residential development will be used to assist the School, this is not an official ‘enabling development’ situation. Therefore, we consider that it would be more relevant if any applications relating to the proposed allocation in AL/CRS 2 be accompanied by a Playing Pitch Assessment/Strategy instead of a Comprehensive Masterplan as required by the current policy. As such we would request that requirements 1 & 2 be deleted and replaced with a requirement to submit a Playing Pitch Assessment/Strategy which is already covered in part 5 of the draft Policy.

6.15 With reference to part 3 of the policy (requirement of a landscape and visual impact assessment and heritage assessment) we suggest that the wording be amended to read “The siting and design of new development to be informed…” rather than: “The location of new development to be informed…” (our emphasis).

6.16 We query the inclusion of Part 8 regarding improvements to existing allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space as part of the “on site” development requirements. We seek the removal of part 8 of the policy given the last section of the policy relates to likely expected development contributions. It is therefore felt that such requirements can adequately be included within improvements to the public realm which will be considered fully as part of any future application.

DLP_6993

Nigel Tubman

Object

This site is within the AONB and should not be considered for building housing. To even consider let alone building on such an iconic space in Cranbrook is extraordinary. This proposal cuts across most of the policies and cannot be supported. The playing fields are an important aspect of the approach into the town of Cranbrook and should be preserved. It would be a bad precedent to allow building even a relatively small number of houses on the playing field.

DLP_5938

S J Ireland

Object

Policy CRS2 - Big Side Playing Field

I object to the proposal of 10- 15 dwellings, as this will significantly impact on the existing sports pitches; reducing the facilities by at least one rugby pitch, one cricket square and one athletics grass track.

DLP_6082

Gwenneth Heyking

Object

Traffic on Waterloo Road from Quaker Lane towards the High Street is already very heavy and vehicles from this proposed site onto Waterloo Road would cause even more congestion which is extreme at and along its junction with Stone Street.  Large numbers of lorries, refuse collection vehicles, buses and school coaches use the road every day, all of which cause blockages and significant pollution added to by the traffic-calming road-narrowing at the 20mph sign plus the sleeping policemen all the way past Cranbrook School.  Waterloo Road is crossed daily by Cranbrook School pupils from Cornwallis House whose safety should be considered. My house is side on, and very close, to Waterloo Road with a narrow pavement.  Open windows and sills quickly become filthy with black particulates. This pollution is far worse than south London where I lived until 3 years ago. I am totally against the potential increase in traffic caused by this development, and the development itself.  I suggest an exit onto Quaker Lane would be preferable giving the choice of turning left towards Angley Road (for primary and secondary schools) or right to Waterloo Road.  ‘Green lungs’ are known to benefit communities and Big Side Playing Field is one such. It appears to me that Cranbrook has been allocated a far larger number of new houses than officially required and I suggest this development should not proceed.

Policy AL/CRS 3: Jaegers Field, Angley Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_962

Mrs A Marley

Object

I object to this application. All playing fields should be retained with increasing number of pupils. Outdoor exercise, team spirit and regular fitness outdoor activity is essential

Secondly this field is a badger crossing point between Angley Woods and the stream below the Primary School

DLP_3027

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 3 Jaegers field - another Cranbrook school site. (30-35 dwellings) Field part retained, part developed. GREEN

DLP_2080

Terry Everest

Object

Object

Site is an open green space and playing field and should not be developed.

DLP_3297

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following change is requested:

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is some potential for prehistoric and later remains.

DLP_4020

Brian Swann

Object

To be part of a masterplan.

Top part of sports field to be retained as a green space only Angley Road maximum 30 dwellings \ ONLY in the bottom of the field.

At least 1/2 to be 1,2 & 3 bed dwellings affordable (in price) so local people can continue to live in Cranbrook.

Footpath to be retained/created to walk into town (via site CRS 5)

DLP_4623

Anne Watson

Object

Cranbrook School’s offered sites        Objection

As a former PE teacher I am horrified at the amount of land dedicated to sports fields which Cranbrook School is offering for houses. Surely at this time of greater emphasis on school children becoming more physically active it can’t be right that Cranbrook School is proposing to submit all of its available playing areas.

DLP_6133

Cranbrook & Sissinghurst Parish Council

Object

Considered essential that Cranbrook School retains all playing fields in view of increased pupil numbers.

DLP_6033

Kember Loudon Williams for Cranbrook School

Support with conditions

Essentially the trustees support this allocation and agree with the approach taken.  However, detailed comments have been made in Chapter 5 of our report, which relate to the individual policy requirements.

[TWBC: see full supporting statement]. Chapter 5 is copied below]:

5. Jaegers Field

Relevant Policies: AL/CRS 3

5.1 The site is located south of A229 Angley Road and adjacent to the current limits of built development for Cranbrook. The site is set within the AONB. The surrounding character of the area is mixed with the Weald Sports Centre opposite the site (to the north); the High Weald Academy to the north west of the A229; residential properties in Oatfield Close in the south west; and properties fronting Angley Road to the north-east. Adjoining the south-east boundary to the site is Cranbrook Church of England Primary School. It is felt that a part residential use of this site is in keeping with the character of its immediate surroundings and will be visually unobtrusive having regard to local topography and established landscaping.

5.2 The field is owned by the Governors of Cranbrook School and contains one defined and reasonably level rugby pitch at the north of the field, which is often used by the Cranbrook Rugby Club. The levels fall gradually towards the south of the site, and this part of the field is moderately sloping, therefore is not a defined playing field, but has still been used in connection with sports purposes.

5.3 The site is proposed to be allocated for residential development of approximately 30-35 dwellings under Policy AL/CRS 3 of the draft Local Plan Reg 18 consultation version (see Figure 4 below). The allocation for housing is to the southeast of the field, with the remaining area to continue to be used as playing fields in connection with the School.

[TWBC: for Figure 4 site plan, see full supporting statement].

5.4 We fundamentally agree with the intent of draft allocation AL/CRS 3 and the level of housing proposed. However, whilst we understand that any future application would need to respond fully to certain policy requirements, we would ask TWBC to reconsider parts 1 and 2 of the policy which refer to the submission of a masterplan as part of any proposals for the development of the site.

5.5 Essentially any application submitted on the basis of this allocation should be considered on its own merits and whilst any proceeds from the residential development will be used to assist the School, this is not an official ‘enabling development’ situation. Therefore, we consider that it would be more relevant if any applications relating to the proposed allocation in AL/CRS 3 be accompanied by a Playing Pitch Assessment/Strategy instead of a Comprehensive Masterplan as required by the current policy. As such we would request that requirements 1 & 2 of this policy be deleted and replaced with a requirement to submit a Playing Pitch Assessment/Strategy which is already covered in part 8 of the draft Policy.

5.6 We would also query whether the landscape buffer indicated on the proposed allocation plan (above) is excessive in terms of ‘land take’ and unduly uniform. The wish to retain a good quality landscaped perimeter is understood however relationships to any proposed development will be largely informed by the appropriate Arboricultural assessments. The degree of buffer indicated appears substantial, particularly at the northern end of the site where the established trees are largely located off-site.

5.7 Finally, we query the inclusion of Part 10 regarding improvements to existing allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space as part of the “on site” development requirements. We seek the removal of part 10 of the policy given the last section of the policy relates to likely expected development contributions. It is therefore felt that such requirements can adequately be included within improvements to the public realm which will be considered fully as part of any future application.

DLP_6994

Nigel Tubman

Object

Another proposed site with the AONB which should not be considered for housing development. It would be surprising if part of this playing field is surplus to requirements as it has always been useful to the school and Cranbrook rugby club.

We should never allow house building on playing fields.

DLP_5939

S J Ireland

Object

Policy CRS3 - Jaegers Field

I object to this proposal, which also impacts on Sports facilities, taking out at least 2 rugby pitches. Reducing sports facilities without a full recreation and open spaces policy review is unwise.

DLP_6555

Diana Badcock

Support

Policy Number: AL/CRS3

This seems to be a reasonable development on part of the field, leaving the remainder as either a playing field as stated, or potentially for uses as defined in point 8.

DLP_7573

James Lloyd

Object

In 2013, there was some considerable local controversy over rumours that Rammell Field, also owned by Cranbrook School, was to be made available for housing. Rammell Field was acquired in 1921 as a memorial to Old Boys of the School who had been killed in the Great War. To destroy the field was therefore identical to destroying a war memorial and highly disrespectful. The plans were dropped in response to the controversy.

Similar arguments apply to Jaeger’s Field. Although not a war memorial officially, it has strong commemorative connotations. It is named after Bill Jaeger, a teacher at the School in the 1930s, who owned the field. During the Second World War, he made the field available to pupils at the School for growing vegetables. Although above the age of conscription, he volunteered for the Royal Air Force but his aeroplane went missing over the English Channel. After his death, his field was inherited by his mother, from whom its ownership passed to Kent County Council, from which it passed to the School in 1991. During all that time, Jaeger’s Field has been used continuously by the School. Its association with Bill Jaeger means that it serves as the Second World War counterpart to Rammell Field. As with Rammell, its history makes the proposal to build houses on it seem highly disrespectful.

There are also practical reasons why Jaeger’s Field should be considered unsuitable. The School makes the field available to Cranbrook Rugby Club, so that the Club, as well as the School, would lose a resource. If I have interpreted Map 46 correctly, the proposal is to build houses on only one part of the field, while the remainder will continue as landscape buffer and, presumably, still be available for playing Rugby. Yet the houses will need to have access to Angley Road. This could be achieved only by cutting a line across the landscape buffer, yet this is not indicated in the map, an omission that suggests either dishonesty or lack of planning. Such a road would, of course, further reduce the portion of the surviving field available for the use of the School or Rugby Club.

Any games that continued to be played on the field would be played in front of people’s houses. There would have to be trees, fences or high hedgerows established to maintain privacy in the separate spheres but these would even further reduce the size of the playing field in real terms. Finally, the portion of the field assigned to housing is uneven and slides downhill. Ironically, the flat land closer to Angley Road would make more sense for housing but must be ruled out for the reasons already stated.

The policy cites an anonymous assessment that supposedly establishes that the portion of the field allocated for development either is surplus to requirements or can be replaced by land equally good or better. The latter claim is hard to believe. As was pointed out during a public debate on the aforementioned proposed development of Rammell Field, all fields suitable for games pitches in Cranbrook are already owned by the School. No replacement is available. The idea that it is surplus to requirements must be based on the grounds that more than half of Jaeger’s Field will apparently remain as a games pitch but, for the reasons already given, even that will be compromised out of use.

In sum, it is difficult to think of any positive comments to be made of building on Jaeger’s Field at all. No matter how conservative on the ground, any development would practically rob both School and Rugby Club of a whole pitch, while the historical association between the field and one of the School’s war dead makes the destruction of any part of it distasteful.

DLP_7577

Susie Oakenfold

Support with conditions

Any development in Cranbrook itself is a terribly sad prospect and, once ruined, this very special, historic little town will never have its village atmosphere back again.  I note only 15-20 dwellings planned for the moment on BIG SIDE PLAYING FIELD AL/CRS 2, but the LAND ADJACENT TO CRANBROOK PRIMARY SCHOOL AL/CRS 5  proposes  35-45 houses and JAEGERS FIELD AL/CRS 3 has 30-35 houses planned.

Policy Number JAEGERS FIELD AL/CRS 3 – support with reduced number of houses

Policy NumberLAND ADJACENT TO CRANBROOK PRIMARY SCHOOL AL/CRS 5 – support with half the number of houses

Policy AL/CRS 4: Turnden Farm, Hartley Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_7780

Annie Hopper

Object

Policy Number: AL/CRS 4

Why has TWBC allocated this major development (160 +36 homes) in the AONB and right next to another development for 250 homes (AL/CRS 9 Brick Kiln and Corn Hall) and ignored:

* Its own policy in the DLP STR 8 Conserving and Enhancing the Natural built and Historic environment, in particular point 5 relating to the AONB

* The AONB Management Plan

* The draft Parish Neighbourhood Plan to focus on small scale sites and avoid large scale sites.

* NPPF para 172: Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. …….The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances and where it can be demonstrated that development is in the public interest.

* DEFRA Landscape review 2019 highlights the CPRE report (2017 CPRE & AONB ‘Landscapes for Life’ available at: https://landscapesforlife.org.uk/application/files/5315/5552/0923/Housing-in-AONBs-Report.pdf ) revealing that approvals for housing units within AONBs and within 500m beyond their boundaries have increased by 82% between 2012-2016, numbers of affordable units have gone down and the risk that paragraph 172 ‘exceptional circumstances’ is being used to argue for major development on the grounds that no other sites outside the AONB are available.

* This allocation for large scale development is outside the LBD.

Proposed extensions of LBD shown on Map reference 14.1 in order to ‘qualify’ as in 5.76 ‘adjacent to the existing Cranbrook Limits to Built Development in the AONB is contradicting “The purpose of this designation/policy approach to LBD was to “restrict the encroachment of built form into the surrounding landscape”. as defined in the Limits of Built Development Topic Paper for DLP Reg 18 Consultation. Aug 2019 and will set a precedence for further development of valuable AONB landscape.

These allocations risk coalescence and contravenes the Requirement in Policy STR/CRS1 6. ‘All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development;’

Local research for the NDP indicates that local residents are against large scale development as a method of delivering housing in the Parish.

This development is unsustainable, being too far from employment centres and train hubs, necessitating residents to use cars.

There is absolutely no indication of potential employment provision except during any construction phase.

This allocation risks the loss of Protected Views: 1

* View 15 Townscape from Quaker Lane looking SW to Saint Dunstans & Windmill

* View 25 AONB Landscape from Mount Ephrahim looking North East

* View 26 AONB Landscape from Mount Ephrahim looking West towards Hartley

* View 27 AONB Landscape from Mount Ephrahim looking North to Cranbrook

* View 35 AONB Landscape from footpath at Turnden Farm

as identified in the emerging Cranbrook and Sissinghurst Draft Neighbourhood Plan

http://cranbrookandsissinghurstndp.co.uk/wp-content/uploads/2019/09/152_QR_190724_Protected-Views-MAP-PHOTOS.pdf

DLP_7844

Mr R M Todd-Young

General Observation

Our fields shown on the current AL/CRS9 draft Local Plan show a large Buffer Zone on the north side which includes the area leading to the existing CoOp gate right of way. Under the original AL/CR4 allocation, Brick Kiln have 180 houses and Corn Hall have 70 houses thus making up the total of 250 houses allocated to this site. With the Buffer Zone as now shown, there is not enough land on the Corn Hall fields for the 70 houses allocated.

DLP_7898

Michael and Jane Love

Object

We object to the above developments on the ANOB that is Cranbrook and the High Weald . These are beautiful areas that you will ruin and once lost you can not get them back for future generations

DLP_7906

Fiona Dagger

Object

Major development is not appropriate in the AONB. TWBC have accepted that Turnden is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

Turnden reflects the High Weald’s typical Medieval character. It lies within a distinct Medieval den which formed part of the Manor of Godmersham and its character remains agricultural, unlike the adjoining den of Cranbrook which developed into a town. Turnden represents a significant survival of a Medieval farmstead surrounded by its own fields and associated with other Medieval features typical of the High Weald including a historic routeways (Hartley Road and a PROW), a Medieval common/ green (Goddards Green) and ancient gill woodland (Crane Valley).

Appendix 3 of the Distribution of Development Topic Paper which deals with major development in the AONB claims that the land around the historic farmstead of Turnden has ‘no clear function’ and that development provides an ‘opportunity to resolve land use issues and to provide a green and permanent gap between Hartley and Cranbrook’. This is nonsense.

With the allocation of the adjoining site of Brick Kiln Farm for housing, the green fields of Turnden form the last remaining separation between Cranbrook (with the character of a town) and Hartley (with the character of a hamlet). The site is highly visible from well used footpaths which cross the fields and allow local people to experience a feeling of naturalness and rurality along the Crane Valley. Despite its recent use as horse pasture, a large proportion of the site retains its Medieval field pattern (Early-post Med) with intact field boundaries which are often thick and woody. These fields and their associated habitats continue to function effectively to deliver a range of benefits (ecosystem services) including buffering the ancient woodland and water quality of the Crane.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met? It is clear that the land at Turnden does have a clear function. The case for major development at Turnden has not been made, and the mitigation measures assumed are spurious.

Half of the site lies along the Crane Valley between areas of Ancient Woodland and high priority woodland. Maintaining this area as open undeveloped land is essential to achieving the Local Plan and Neighbourhood Plan objectives to restore and enhance the Crane Valley as wildlife habitat; to provide greenspace to support people’s health and wellbeing through contact with nature; and to protect water quality and enhance natural Flood management (these are also AONB Management Plan objectives).

These objectives would best be served by land use which promotes regenerative agriculture supporting rural jobs and livelihoods, grassland restoration or natural wilding and woodland regeneration.

Paragraph 102 of the NPPF, requires the environmental impacts of traffic and transport to be considered at the start. The impact of creating new access to this site, which will essentially introduce a suburban character to a rural historic routeway appears not to have been considered.

The Neighbourhood Development Plan undertook a detailed assessment of this site using the recommended AECOM template. The site was assessed as unsuitable for development. TWBC have not explained why they have come to a different decision.

DLP_8053

Sophie Foster

Object

This site is not suitable for major development. No attempt has been made to demonstrate that there are exceptional circumstances, taking account of the following factors which are required to be assessed under in accordance with para 172 of the NPPF

  • development of this size is not needed for growth of the local community
  • it would have an adverse impact on Cranbrook’s status as a tourist attraction
  • there are better opportunities for developing outside the AONB
  • it would have a detrimental effect on the landscape and recreational opportunities, with no realistic scope for this to be moderated

Development of this site would be contrary to Policy EN 21: “All development within, or affecting the setting of, the High Weald AONB shall seek to conserve and enhance its landscape and scenic beauty, having particular regard to the impacts on its character components, as set out in the High Weald AONB Management Plan.”  It cannot seriously be argued that development on this scale seeks to conserve and enhance the AONB’s landscape and scenic beauty.

The agreed policy in the AONB Management Plan seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.  In no way could this development be seen to meet that objective.

Turnden lies within a distinct Medieval den which formed part of the Manor of Godmersham and its character remains agricultural.  It represents a significant survival of a Medieval farmstead surrounded by its own fields and associated with other Medieval features typical of the High Weald including a historic routeways (Hartley Road and a PROW), a Medieval common/ green (Goddards Green) and ancient gill woodland (Crane Valley).  Any development of this site would cause devastating and irreversible damage to the landscape and scenic beauty for which the local community and future generations will not forgive those responsible.

Appendix 3 of the Distribution of Development Topic Paper contains the absurd statement that the land around the historic farmstead of Turnden has ‘no clear function’ and that development provides an ‘opportunity to resolve land use issues and to provide a green and permanent gap between Hartley and Cranbrook’.  If this were true it could be applied to any green space that is not being actively used.  Planners should surely realise that some landowners deliberately avoid putting land to good use purely to enhance the prospect of getting planning consent.

The green fields of Turnden form the last remaining separation between Cranbrook (with the character of a town) and Hartley (with the character of a hamlet). The site is highly visible from well used footpaths which cross the fields and allow local people to experience a feeling of naturalness and rurality along the Crane Valley. A large proportion of the site retains its medieval field pattern with intact field boundaries which are often thick and woody. These fields and their associated habitats continue to function effectively to deliver a range of benefits including buffering the ancient woodland and water quality of the Crane brook.

The permanent grassland on this site plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. How does the Local Plan ensure that this commitment is met?  The case for major development at Turnden has not been made.

Part of the site lies along the Crane Valley between areas of ancient woodland and high priority woodland. Maintaining this area as open undeveloped land is essential to achieving the Local Plan and Neighbourhood Plan objectives to restore and enhance the Crane Valley as wildlife habitat; to provide greenspace to support people’s health and wellbeing through contact with nature; and to protect water quality and enhance natural flood management.

Transport issues are required by para 102 of the NPPF to be considered from the earliest stages.  The following have not been addressed:

  • The impact of creating new access to this site, which will essentially introduce a suburban character to a rural historic routeway, will have an adverse environmental impact
  • The A262 via Goudhurst is the route used by the entire Parish to travel to work or to shop in Royal Tunbridge Wells. Support services, including HGVs, also use this route, notwithstanding the warning sign “unsuitable for long vehicles”. The A262 through Goudhurst is narrow and the corner by St Mary’s Church is notorious for problems when large vehicles travelling in opposite directions meet there.  There is no scope to widen the road. This regularly causes extended hold-ups and there has been damage to buildings and to the churchyard wall.  There is no obvious alternative route and the additional traffic generated by the development would be detrimental to the character of the historic village of Goudhurst, with consequent impact on its economy.

DLP_8376

Nicola Gooch

Support

AL/CRS4

Turnden Farm has the potential to operate extremely well as a functional extension to Cranbrook, as well as providing improvements and enhancements to the public rights of way network and local biodiversity. If it were possible to increase the densities of this allocation and the two other larger allocations in Cranbrook a little (perhaps by another 10 to 20 units) this would take the pressure off the smaller sites and allow a more strategic approach to be taken to growth in the village.

DLP_971

Mrs A Marley

Support with conditions

Land at Turnden Farm. Its close proximity to Crane Valley should be a severe constraint to protect the flora and fauna of the region.

DLP_2494

Mr John Wotton

 

AL/CRS 4 Turnden

Object

This would be a major development within the AONB (see Distribution of Development Topic Paper (“DDTP”), para 6.35) of 160-170 new homes (of which 36 already have permission). It is a greenfield site (apart from the area which is subject to an existing permission) and is outside the LBD. There are no exceptional circumstances within the meaning of NPPF 172 which would justify this development. Together with policy AL/CRS 9 (carried forward from the existing plan) this development would eliminate the green gap between Cranbrook and Hartley, thereby obliterating and historic distinct settlement pattern. The site has a highly negative sustainability score (particularly on environmental grounds. I oppose this policy and consider that no development should be permitted on this site in addition to the 36 new homes already permitted on brownfield land.

DLP_2514

Mr Guy Dagger

Object

Major development is not appropriate in the AONB. TWBC have accepted that Turnden is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

Turnden reflects the High Weald’s typical Medieval character. It lies within a distinct Medieval den which formed part of the Manor of Godmersham and its character remains agricultural, unlike the adjoining den of Cranbrook which developed into a town. Turnden represents a significant survival of a Medieval farmstead surrounded by its own fields and associated with other Medieval features typical of the High Weald including a historic routeways (Hartley Road and a PROW), a Medieval common/ green (Goddards Green) and ancient gill woodland (Crane Valley).

Appendix 3 of the Distribution of Development Topic Paper which deals with major development in the AONB claims that the land around the historic farmstead of Turnden has ‘no clear function’ and that development provides an ‘opportunity to resolve land use issues and to provide a green and permanent gap between Hartley and Cranbrook’. This is nonsense.

With the allocation of the adjoining site of Brick Kiln Farm for housing, the green fields of Turnden form the last remaining separation between Cranbrook (with the character of a town) and Hartley (with the character of a hamlet). The site is highly visible from well used footpaths which cross the fields and allow local people to experience a feeling of naturalness and rurality along the Crane Valley. Despite its recent use as horse pasture, a large proportion of the site retains its Medieval field pattern (Early-post Med) with intact field boundaries which are often thick and woody. These fields and their associated habitats continue to function effectively to deliver a range of benefits (ecosystem services) including buffering the ancient woodland and water quality of the Crane.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met? It is clear that the land at Turnden does have a clear function. The case for major development at Turnden has not been made, and the mitigation measures assumed are spurious.

Half of the site lies along the Crane Valley between areas of Ancient Woodland and high priority woodland. Maintaining this area as open undeveloped land is essential to achieving the Local Plan and Neighbourhood Plan objectives to restore and enhance the Crane Valley as wildlife habitat; to provide greenspace to support people’s health and wellbeing through contact with nature; and to protect water quality and enhance natural Flood management (these are also AONB Management Plan objectives).

These objectives would best be served by land use which promotes regenerative agriculture supporting rural jobs and livelihoods, grassland restoration or natural wilding and woodland regeneration.

Paragraph 102 of the NPPF, requires the environmental impacts of traffic and transport to be considered at the start. The impact of creating new access to this site, which will essentially introduce a suburban character to a rural historic routeway appears not to have been considered.

The Neighbourhood Development Plan undertook a detailed assessment of this site using the recommended AECOM template. The site was assessed as unsuitable for development. TWBC have not explained why they have come to a different decision.

DLP_3029

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

  • AL/CRS 4 Turnden farm (124-135 dwellings) on the AONB. Too far from Cranbrook, forcing people to use car for most journeys and therefore non-sustainable. Involves loss of ancient woodland and trees and contributes to undesirable coalescence of settlements towards Hartley. RED

DLP_3438

High Weald AONB Unit

Object

Major development is not appropriate in the AONB.

Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of: g) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; h) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and i) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.

TWBC have accepted that Turnden is major development but have not explained how the sequential tests required by para. 172 have been met. This policy is therefore, not justifiable.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

Turnden reflects the High Weald’s typical Medieval character. It lies within a distinct Medieval den which formed part of the Manor of Godmersham and its character remains agricultural, unlike the adjoining den of Cranbrook which developed into a town. Turnden represents a significant survival of a Medieval farmstead surrounded by its own fields and associated with other Medieval features typical of the High Weald including a historic routeways (Hartley Road and a PROW), a Medieval common/ green (Goddards Green) and ancient gill woodland (Crane Valley).

Appendix 3 of the Distribution of Development Topic Paper which deals with major development in the AONB claims that the land around the historic farmstead of Turnden has ‘no clear function’ and that development provides an ‘opportunity to resolve land use issues and to provide a green and permanent gap between Hartley and Cranbrook’. This is nonsense.

With the allocation of the adjoining site of Brick Kiln Farm for housing, the green fields of Turnden form the last remaining separation between Cranbrook (with the character of a town) and Hartley (with the character of a hamlet). The site is highly visible from well used footpaths which cross the fields and allow local people to experience a feeling of naturalness and rurality along the Crane Valley. Despite its recent use as horse pasture, a large proportion of the site retains its Medieval field pattern (Early-post Med) with intact field boundaries which are often thick and woody. These fields and their associated habitats continue to function effectively to deliver a range of benefits (ecosystem services) including buffering the ancient woodland and water quality of the Crane, and storing soil carbon.

Half of the site lies along the Crane Valley between areas of Ancient Woodland and high priority woodland. Maintaining this area as open undeveloped land is essential to achieving the Local Plan and Neighbourhood Plan objectives to restore and enhance the Crane Valley as wildlife habitat; to provide greenspace to support people’s health and wellbeing through contact with nature; and to protect water quality and enhance natural Flood management (these are also AONB Management Plan objectives).

These objectives would best be served by land use which promotes regenerative agriculture, grassland restoration or natural wilding and woodland regeneration.

DLP_2769

Lee Hatcher

Object

Development of this site should be on a much smaller scale. It neighbours already large developments so a larger development on this site will mean the settlements of Cranbrook and Hartley will coalesce and we will loose green space. It is completely within the AONB, meaning any development here should be much more carefully considered. It is not supported, at all, by local people, or the emerging NDP.

DLP_2081

Terry Everest

Object

Strongly Object

Site has much of the character and naturalness of countryside and should be left undeveloped and protected as green belt.

DLP_3151

Nigel Bell

Object

Development proposed (124-134 dwellings) is too large on protected ANOB greenfield land. I have no objections to a smaller development of the existing farmhouse and surrounding properties on this site in a sympathetic farmyard type development. Infrastructure and access to the amenities in the village are not adequate to support this number of new houses.

DLP_3298

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested: Additional paragraph: The speed limit reduction scheme proposed as part of the planning application 18/02571 should be carried forward as part of this allocation.

Additional paragraph: The impact on the Hawkhurst junction will require assessment.

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

Public Rights of Way and Access Service

The specific references to PRoW in paragraphs 6 and 7 are supported. In addition to these requirements, it is requested that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development.

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is some potential for prehistoric and later remains.

DLP_3437

Sally Marsh

Object

Major development is not appropriate in the AONB. TWBC have accepted that Turnden is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

Turnden reflects the High Weald’s typical Medieval character. It lies within a distinct Medieval den which formed part of the Manor of Godmersham and its character remains agricultural, unlike the adjoining den of Cranbrook which developed into a town. Turnden represents a significant survival of a Medieval farmstead surrounded by its own fields and associated with other Medieval features typical of the High Weald including a historic routeways (Hartley Road and a PROW), a Medieval common/ green (Goddards Green) and ancient gill woodland (Crane Valley).

Appendix 3 of the Distribution of Development Topic Paper which deals with major development in the AONB claims that the land around the historic farmstead of Turnden has ‘no clear function’ and that development provides an ‘opportunity to resolve land use issues and to provide a green and permanent gap between Hartley and Cranbrook’. This is nonsense.

With the allocation of the adjoining site of Brick Kiln Farm for housing, the green fields of Turnden form the last remaining separation between Cranbrook (with the character of a town) and Hartley (with the character of a hamlet). The site is highly visible from well used footpaths which cross the fields and allow local people to experience a feeling of naturalness and rurality along the Crane Valley. Despite its recent use as horse pasture, a large proportion of the site retains its Medieval field pattern (Early-post Med) with intact field boundaries which are often thick and woody. These fields and their associated habitats continue to function effectively to deliver a range of benefits (ecosystem services) including buffering the ancient woodland and water quality of the Crane.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met? It is clear that the land at Turnden does have a clear function. The case for major development at Turnden has not been made, and the mitigation measures assumed are spurious.

Half of the site lies along the Crane Valley between areas of Ancient Woodland and high priority woodland. Maintaining this area as open undeveloped land is essential to achieving the Local Plan and Neighbourhood Plan objectives to restore and enhance the Crane Valley as wildlife habitat; to provide greenspace to support people’s health and wellbeing through contact with nature; and to protect water quality and enhance natural Flood management (these are also AONB Management Plan objectives).

These objectives would best be served by land use which promotes regenerative agriculture supporting rural jobs and livelihoods, grassland restoration or natural wilding and woodland regeneration.

Paragraph 102 of the NPPF, requires the environmental impacts of traffic and transport to be considered at the start. The impact of creating new access to this site, which will essentially introduce a suburban character to a rural historic routeway appears not to have been considered.

The Neighbourhood Development Plan undertook a detailed assessment of this site using the recommended AECOM template. The site was assessed as unsuitable for development. TWBC have not explained why they have come to a different decision.

DLP_4121

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

This would be a major development within the AONB (see Distribution of Development Topic Paper (“DDTP”), para 6.35) of 160-170 new homes (of which 36 already have permission). It is a greenfield site (apart from the area which is subject to an existing permission) and is outside the LBD. There are no exceptional circumstances within the meaning of NPPF 172 which would justify this development. Together with policy AL/CRS 9 (carried forward from the existing plan) this development would eliminate the green gap between Cranbrook and Hartley, thereby obliterating and historic distinct settlement pattern. The site has a highly negative sustainability score (particularly on environmental grounds. CPRE Kent opposes this policy and considers that no development should be permitted on this site in addition to the 36 new homes already permitted on brownfield land.

DLP_3838

Government Team
Natural England

Object

Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.

DLP_4859

DHA Planning for Berkeley Homes (Eastern Counties) Ltd

Support

1 Introduction

1.1 Purpose of this report

1.1.1 This representation has been prepared on behalf of Berkeley Homes (Eastern Counties) Ltd (herein referred to as ‘Berkeley’) in response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until an extended deadline of 15th November 2019.

1.1.2 Our client controls land at Turnden, Hartley Road, Cranbrook and is promoting part of it for residential redevelopment as part of the wider Development Plan review.

1.1.3 Part of Turnden Farm already benefits from residential planning permission (18/02571/FULL and 18/02564/LBC), whilst the wider land was promoted via the initial ‘Call for Sites’ process. It has subsequently been included as a draft allocation within the draft regulation 18 plan (ref. AL/CRS 4).

1.1.4 Based on the current national and local planning context, we consider the proposed land to be a suitable area to release land and we consider there to be ‘exceptional circumstances’ to prioritise this site in the High Weald Area of Outstanding Natural Beauty (‘AONB’). Further, the site is of a size and scale to play a role in accommodating the wider overspill of housing need from London and elsewhere within the South East of England, including identified local housing needs.

1.1.5 This representation responds to the content of the draft plan (and relevant supporting documents), reinforces why the site represents a suitable location to accommodate growth and outlines how development could be delivered on site.

1.2 About Berkeley Homes

1.2.1 Berkeley Homes is a dynamic and innovative company with a passionate commitment to provide high quality homes and neighbourhoods across London, Birmingham and the South-East of England.

1.2.2 Founded in 1976, Berkeley Homes is the largest division of the Berkeley Group Holdings PLC, and FTSE 250 Company. Berkeley Homes has a significant annual turnover (in excess of £500m).

1.2.3 Berkeley Homes take a holistic approach to place making, which goes beyond the conventional role of a developer and puts the strength and well-being of the wider community at the heart of every plan. Every development has a unique, locally inspired masterplan with a mix of beautiful public spaces, natural landscapes and amenities that bring people together to enjoy community life.

1.2.4 Berkeley Homes has an unrivalled expertise in creating sustainable communities. Although the location, size and complexity of the sites vary, Berkeley Homes always delivers superbly designed and built homes which create a real sense of place and community while providing homes for everyone; from families to first-time buyers, students to older people, and a mix of affordable homes which meet the needs of the local community.

1.2.5 Berkeley Homes operates through a number of autonomous regional companies which provide specialist local knowledge. This enables them to enjoy the advantages of being part of a large public company, whilst retaining the ability to understand local issues and deal with customer needs on an individual basis.

1.2.6 Berkeley Homes (Eastern Counties) Ltd is one of the regional offices for the wider Berkeley Group. The company is a local employer, based in Sevenoaks with around 100 direct employees and nearly 600 operatives employed in the region’s sites in Kent, London and the South East.

[TWBC: see full representation and separate Appendix 4 (a) and 4 (b) attached].

2.4 Place Shaping Policies

2.4.1 The place shaping policies establish the spatial priorities for different areas in the borough, organised according to non-parish and parish areas. For each area, there is an overarching policy that development should adhere to and details are provided for individual allocated sites that will deliver the quantum of development proposed. The site specific allocations provide both strategic and development management guidance.

2.4.2 In respect of Cranbrook, policy STR/CRS 1 states that circa 718-803 new dwellings will be delivered on nine sites. Berkeley control Turnden, Hartley Road (policy AL/CRS 4), which is allocated for approximately 160-170 dwellings (124-134 additional dwellings) and significant green infrastructure.

2.4.3 Policy AL/CRS 4 outlines an extensive criterion that new development should adhere to and stipulates that development should be located on the areas not indicated in green on the draft Policies Map. It states that the areas in green shall be used to deliver green infrastructure in the form of:

  • retained and improved meadows, woodlands, hedgerows, and water features;
  • landscape buffers to existing woodland;
  • the reinstatement of historical field boundaries with hedgerows, shaws, and woodlands; and
  • retained and enhanced water bodies and water courses.

2.4.4 Berkeley support the inclusion of Turnden as a residential allocation and as a matter of principle they would be happy to deliver green infrastructure as part of the proposal. However, to make more efficient use of this site, the proposal map for the policy should be modified to extend the developable area and increase the quantum of development that can be achieved.

2.4.5 It is however considered that the Council underestimate the capacity of the site and that approximately 165 additional dwellings could be broadly delivered in the development parcels referred to in the Council’s draft Policy Map, rather than 124 -134 as the Council suggest. Moreover, the landscape work set out in Section 3.0 and Appendix 4, of this statement outlines that these development parcels however can be extended south west in line with historic field boundaries in order to deliver a further 40 homes, resulting in an approximate delivery of 205 additional homes which can be suitably delivered in landscape terms all within land in Berkeley’s control.

2.4.6 An indicative concept plan is included as Appendix 1 and shows how this additional development could be incorporated, whilst also delivering the extensive green infrastructure required by policy AL/CRS 4. Berkeley have also produced an updated proposals map to illustrate this extended developable area, which is included as Appendix 2.

2.4.7 Moreover, we set out a more tailored policy below that should be read in conjunction with this updated proposals map. In summary, we would ask that the policy is modified so historic field boundaries are reinstated, but only when it is appropriate to do so. Also, the policy should be modified to remove the need to provide on-site allotments and formal parks and recreation grounds within the developable area, given that there is insufficient space. I

2.4.8 In addition, to avoid placing undue requirement to landscape land to the west of the site which is to be retained in their existing form and privately managed in agricultural/equestrian use, thus providing a landscape buffer to Hartley. Whilst public access will be permissible via existing and proposed new public rights of way, the primary intention for this area of land is to retain a landscape buffer between the development and Hartley, by retaining the land in its existing form.

Turnden Farm, Hartley Road (SHELAA reference: Site 430)

This site, as defined on the Cranbrook draft Policies Map, is allocated for approximately 205 new additional dwellings and significant green infrastructure.

Development on the site shall accord with the following requirements:

1) The design, layout, extent and final number of dwellings to be informed by a comprehensive Landscape and Visual Impact Assessment, ecological studies, and a heritage assessment (to include archaeology and landscape heritage), and consideration of cumulative effects of any other planned development in the vicinity (see Policies EN 1: Design and other development management criteria, EN 7: Heritage Assets, EN 11: Net Gains for Nature: biodiversity, EN 12: Protection of designated sites and habitats, and EN 20: Rural Landscape and EN 21: High Weald AONB). Development shall be located on the areas not indicated in green on the draft Policies Map;

2) Extensive green infrastructure shall be provided, where relevant, in the form of:

i. Retained and improved meadows, woodlands, hedgerows, and water features (see Policy EN 14: Trees, Woodlands, Hedges, and Development);

ii. Landscape buffers to existing woodlands (see criterion 3 of Policy EN 1: Design and other development management criteria and Policy EN 14: Trees, Woodlands, Hedges, and Development);

iii. The reinstatement of historical field boundaries with hedgerows, shaws, and woodlands, where it would be appropriate to do so (again see Policies EN 1 and EN 14 above, as well as Policies EN 20: Rural Landscape and EN 21: High Weald AONB);

iv. Retained and enhanced water bodies and water courses (see Policies EN 11: Net Gains for Nature: biodiversity and Policy EN 26: Water Quality, Supply, and Treatment). 

3) The provision of, and adherence to, a Landscape and Ecological Management Plan to cover all public spaces, retained and restored habitats, and any retained agricultural land (see Policies EN 11: Net Gains for Nature: biodiversity and EN 12: Protection of designated sites and habitats and criterion 3 of Policy EN 1: Design and other development management criteria);

4) This site lies within, or very close to, the relevant impact risk zone for Robins Wood SSSI and so an assessment of potential adverse effects on the SSSI as a result of the development will be required as part of any application and, if required, the proposal shall include adequate mitigation measures, both during construction and on completion, to the satisfaction of Natural England to ensure no adverse effects on the SSSI as a result of the proposed development (see Policies EN 11: Net Gains for Nature: biodiversity and EN 12: Protection of designated sites and habitats);

5) A suitable and safe access from Hartley Road A229, with a secondary emergency access if required;

6) Provision of accessible, safe, non-vehicular routes for pedestrian and cyclists through the site connecting to:

i. The corresponding routes on the allocated site to the north (and on into Cranbrook);

ii. The footway on Hartley Road;

iii. The existing Public Rights of Way network to the south;

7) Improvements to the Public Rights of Way on site;

8) Provision of amenity/natural green space, children’s play space and youth play space where appropriate in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation;

9) The design and layout to be informed by a comprehensive energy and climate change strategy (Policies EN 4: Energy Reduction in new buildings and EN 5: Climate Change Adaptation).

It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development:

a. Improvements to the public realm;

b. Any other highways related works;

c. Improvements to bus services and infrastructure, e.g. improved bus stop locations;

d. Provision of electric vehicle charging points and car share facilities in accordance with Policy TP 2: Transport Design and Accessibility.

2.4.9 In addition, we note that the pre-amble to policy EN14 (paragraph 6.160) states that the Council will “assume a buffer of 25m from the edge of [ancient] woodland, expecting through assessment for developers to confirm that this or any other distance is appropriate and that the priority for such buffers will be ecological mitigation and enhancement for woodland rather than the amenity of the proposed development.”

2.4.10 However, the advice from the Governments statutory advisor on biodiversity, Natural England, states that “for ancient woodlands, you should have a buffer of at least 15 metres to avoid root damage. When assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone”.

2.4.1 Whilst it is recognised that every case will need to be treated on its own merits, the Council has provided no justification for imposing a new starting point of 25m, which is nearly double the standard minimum requirements set out by Natural England. This increased buffer zone does not appear to have been based on any evidence. It will simply reduce the quantum of development that can be achieved on many sites, which will in turn increases the risk that additional land is likely to be required elsewhere to meet development needs. We object to this proposed buffer, and request that the standard accepted minimum distance of 15m should be stated instead.

2.4.2 Furthermore, we would ask the Council to permit greater flexibility within the wording of policy H11, which currently requires all developments of more than 100 dwellings to deliver 5% self build or custom housebuilding plots. Indeed, it is not considered that this requirement would suitable for land at Turnden nor will it be suitable for a number of other sites allocated in the plan.

[TWBC: see full representation and separate Appendix 4 (a) and 4 (b) ].

3 The Site and Illustrative Proposals

3.1 Overview

3.1.1 We support the inclusion of Turnden as a draft allocation and outline below why it is deliverable.

3.1.2 By way of background, Turnden is located to the south of Hartley Road (A229), Cranbrook. The land within Berkeley’s control consists of the residential curtilage of Turnden - a Grade II listed building - and wider parcels of land that fall with a range of commercial (B Class) and equestrian (agricultural) use classes.

3.1.3 Turnden itself is a 17th Century Farmhouse that was subsequently altered in the twentieth century. The Historic England listing reads as follows:

‘Farmhouse, now house. C17, altered in C20. Timber framed and clad in red brick on ground floor and tile hung on first floor. Some exposed framing on first floor with plaster infilling. Plain tiled roofs, hipped to right and half hipped to left with projecting half hipped wing to left, jettied at end over ground floor, and lower gabled wing to right of centre, with catslide outshute on left re-entrant face. 2 storeys. Irregular fenestration of 5 windows on first floor and 4 on ground floor, mixture of C19 wood framed casements and C20 metal-framed lattice casements.

Boarded and ribbed door in end of right hand wing. Large C20 extensions to left.’

3.1.4 The building has been damaged by fire damaged and has lost some of its historical and architectural significance as a result. However, the listing remains in place.

3.1.5 South east of the main property was a large equestrian complex that consisted of a stable block, outdoor riding arena, and other ancillary riding buildings and to the south was a mix of modern buildings previously used for wine storage and as a depository for wine for exhibition/tasting and a range of other agricultural buildings. Planning permission has subsequently been secured to clear these existing uses and to construct 36 new homes along with the refurbishment of the listed farmhouse.

3.1.6 The surrounding land is a mixture of agricultural/equestrian grazing land.

3.1.7 The north-western boundary edge of the site is defined by Hartley Road. The south-eastern boundary of the site is defined by the Crane Brook, which is surrounded by a belt of woodland. Areas immediately to the south and south-west of the site include open fields, and land and lakes associated with Hartley Lands Fishery. The north-western part of the site frontage follows the boundary established by the rear gardens of houses orientated north-west onto Hartley Road, which are mainly detached.

3.1.8 The topography of the land varies, with the land generally dropping away from Hartley Road to the lowest level adjacent to the Crane Brook, which then rises again and providing some enclosure to the site.

3.1.9 It should also be noted that adjoining north east of the site, land is allocated for development within the Tunbridge Wells Site Allocations DPD for between 200 – 250 dwellings (Ref. AL/CR 4). The western element of this site is controlled by Hillreed Developments Ltd (part of Persimmon Homes), whilst the eastern side with links to the town centre is in control of Countryside Properties. The land is allocated in the draft local plan under policy CRS 9.

3.1.10 An outline planning application for the first 180 dwellings was granted at Planning Committee on 28th March 2018 but is currently awaiting a signed Section 106 agreement (reference 16/502860/OUT).

3.1.11 The Planning Committee report makes the following conclusion:

“The site is located within the LBD of Cranbrook, a tier 2 settlement and is allocated for residential development and considered to comprise sustainable development. Public transport links and the amenities within Cranbrook are located in close proximity to the site and pedestrian/vehicular links are proposed to access these. The scheme would provide a suitable access, onto Hartley Road, to serve the entire allocation, and in a manner that would be sensitive to the landscape and historic approach into Cranbrook. The scheme would contribute towards the acute housing shortage, whilst providing choice and variety, and would provide a suitable level of affordable housing. It is considered that the application addresses paragraph 115 and 116 of the NPPF thoroughly and that the submission leads to the conclusion that the proposal would result in less than substantial harm to designated heritage assets. In the balance of issues, with the clear need for new housing development, it is not considered that there are any other material considerations that would indicate the application should be refused.”

3.1.12 Once the development has been constructed, this will extend the settlement boundary of Cranbrook adjacent to Turnden. Accordingly the allocation of land at Turnden will represent a logical extension to the settlement.

3.2 The Surroundings

3.2.1 The site lies to the south west of Cranbrook, approximately 1km walking distance from the centre of the town.

3.2.2 In respect of public transport, there are bus services that provides links to Maidstone, Tunbridge Wells and Tenterden. The closest bus stop is approximately 350 meters walk distance from the site boundary.

3.2.3 The closest railway stations are Staplehurst (10km) and Headcorn (13.5km). Cranbrook is not on a designated cycle route.

3.2.4 In respect of the adopted strategy for the distribution of development, the Council’s Core Strategy states that the majority of development should take place in the Main Urban Areas; namely Royal Tunbridge Wells and Southborough. However, smaller rural towns such as Cranbrook, Hawkhurst and Paddock Wood fall within the middle tier and are a greater priority for development than the Rural Villages that represent the third tier of the hierarchy.

Settlement Hierarchy

Main Urban Area

Royal Tunbridge Wells; Southborough

Small Rural Towns

Cranbrook; Hawkhurst; Paddock Wood

Villages:

Benenden; Bidborough; Brenchley; Five Oak Green; Frittenden; Goudhurst; The Moor (Hawkhurst); Horsmonden; Iden Green; Kilndown; Lamberhurst; Langton Green; Matfield; Pembury; Sandhurst; Sissinghurst; Speldhurst.

3.2.5 Cranbrook is a sustainable location and offers a good basic range of services and facilities, including convenience shopping in the form of a Co-op supermarket and a small range of local comparison shopping options. Within Cranbrook there are secondary and primary schools, a post office, a convenience store, a pharmacy, a bakers, two butchers, greengrocers, banks and a number of specialist / comparison shops. The town also benefits from having public houses, churches, doctor and dentist surgeries, a sports centre and other recreational facilities that offer opportunities for everyday needs to be met without the need to travel.

3.3 Site Constraints

3.3.1 The most significant constraint is the site’s location within the High Weald Area of Outstanding Natural Beauty (AONB), a nationally protected landscape. However, it is important to stress that this is a blanket designation that covers the whole of Cranbrook. Accordingly, there are no ‘non AONB’ sites available.

3.3.2 Turnden Farmhouse is a Grade II listed building (albeit recently fire damaged). The Grade II listed Hartley Gate Farmhouse also lies adjacent to the site.

3.3.3 The application site is well-connected by pedestrian footpaths, which run along Hartley Road and provide safe pedestrian access into the centre of Cranbrook (less than 500 metres) and Hartley (approximately 350 metres). A public right of way also runs through the site.

3.3.4 The site is also within 280 metres walking distance from the nearest bus stop situated on the A229 Hartley Road to the west of the site. This provides regular daily services into Maidstone, Hawkhurst and surrounding urban settlements.

3.4 Planning History

3.4.1 Tunbridge Wells’ online planning register provides a detailed set of records relevant to the site, the majority of which are of limited relevance to future residential redevelopment.

3.4.2 Nonetheless, it is important to note that planning permission was granted for an initial 36 homes and refurbishment of the listed farmhouse by virtue of planning permission 18/02571/FULL and 18/02564/LBC), as shown by figure 2 overleaf. The expansion of the wider site will build upon this consented scheme.

[TWBC: see Figure 2 on page 18 of full representation].

3.5 Illustrative Proposals for Turnden Farm, Cranbrook

3.5.1 Policy AL/CRS 4 of the plan allocates Turnden for development which includes the part of the site where 36 homes have recently been granted planning permission. Accordingly, the site is proposed to be allocated for an additional 124-34 dwellings.

3.5.2 The site was assessed in the Councils Strategic Housing and Economic Land Availability Assessment (‘SHELAA’), which concluded that it would be suitable as a local plan allocation. The relevant SHELAA extract is included as Appendix 3.

3.5.3 The policy goes on to detail how new development will address the strategy for Cranbrook and Sissinghurst - outlined by Policy STR/CRS 1 – which includes both strategic and development management considerations. These are summarised below:

1. Design – to be informed by a Landscape and Visual Impact Assessment, ecological statement and heritage assessment, taking into account wider cumulative effects of any other planned development in the vicinity.

2. Green Infrastructure – to be provided on the areas indicated in green on the policies map.

3. Landscape Ecological Management Plan – to cover all public spaces, retained and restored habitats and any retained agricultural land

4. Impact on Robin Wood SSI – assessment of potential adverse impacts on the SSI as a result of the development and the inclusion of mitigation measures as necessary.

5. Access – a safe and suitable access from Hartley Road, with a secondary emergency access if required

6. Pedestrian and Cycle Routes – provision of safe, non-vehicular routes for pedestrian and cyclists through the site connecting to; the corresponding routes on allocated sites to the north (an into Cranbrook; the footway on Hartley Road; and the existing public rights of way network to the south.

7. Pubic Rights of Way – improvements to existing PROW

8. Provision of on-site allotments, amenity space, parks and recreation – to be included with the proposal.

9. Energy and Climate Strategy – design to be informed by an energy and climate strategy

10. Contributions – contributions toward public realm improvements, highway related works, improvements to bus services/infrastructure and the provision of electric vehicle charging points and car share facilities.

3.5.4 We have included a concept masterplan with this representation at Appendix 1, to show how development of the site could be delivered to meet with the aforementioned criteria. An extract is also included below for ease of reference (Figure 3).

[TWBC: see Figure 3 on page 20 of full representation].

3.5.5 The masterplan breaks down the site into a number of residential zones, which broadly correspond with the developable areas on the allocation policy map.

3.5.6 These developable areas have been informed by a number of technical studies, but particularly detailed landscape work carried out by LDA Design. This work was commissioned to determine the most appropriate development strategy for the site, having regard to important landscape features and the likely effects of development on the wider landscape. It places particular emphasis on an approach to development that seeks to retain the identity of the settlements of Hartley and Cranbrook.

3.5.7 The Landscape Visual Appraisal (’LVA’) was carried out in January 2019 and concluded that to retain the identity of both Cranbrook and Hartley, development associated with Hartley should remain off the valley sides and be kept to areas of high ground to the north of Hartley Road. Further, it stated that the settlement pattern of Cranbrook should continue along the valley floor and valley sides, contained within the Crane Brook corridors. The landscape strategy sets out a framework within which potential development areas could be located, providing a definitive edge to Cranbrook separated from Hartley by areas of landscape and open space.

3.5.8 This landscape work has informed the concept masterplan and should be read in full. It will be sent to the Council under separate cover to be included as Appendix 4 to this submission.

3.5.9 The layout shows that a suitable development can be achieved without compromising the delivery of the extensive green infrastructure required. For example, the layout makes provision for the reinstatement of historic tree belts within the site and the provision of open space for both amenity and recreational purposes. Moreover, waterbodies would be retained and enhanced with landscape buffers are incorporated to protect ancient woodland.

3.5.10 Berkeley consider approximately 165 additional homes can be broadly delivered in the development parcels referred to in the Council’s Draft Policy Map. The landscape work outlines that these development parcels however can be extended south west in line with historic field boundaries in order to deliver a further 40 homes, resulting in an approximate delivery of205 additional homes which can be suitably delivered in landscape terms within land in Berkeley’s control, as per the appended policy plan provided by Berkeley.

3.5.11 In addition, pedestrian and cycle footpaths permeate the site, which will attend to the neighbouring developments, as well as the wider the PROW network.

3.5.12 It is considered that a safe and suitable point of access could be achieved from Hartley Road, as inactively located on the plan.

3.6 Exceptional Circumstances

3.6.1 Paragraph 172 of the NPPF states that great weight should be given to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection. It goes on to state that planning permission should be refused for major developments in AONB areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

3.6.2 Consideration of such major applications should include an assessment of:

(1) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

(2) the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and

(3) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

3.6.3 It is important to stress that footnote 55 of the NPPF is clear that for the purposes of paragraphs 172 and 173, whether a proposal is ‘major development’ is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined. The term has no direct correlation with the definitions set out in the Town and Country Planning (Development Management Procedure) (England) Order 2015.

3.6.4 Whilst this document supports the promotion of the land rather than a formal planning application, we set out below why we consider exceptional circumstances exist for the release of this land within the AONB.

The need for the development

3.6.5 As outlined by the plan, there is an overriding and growing housing need within the Borough. The Council’s SHMA findings initially identified the future need to plan for some 648 new homes per year. This in turn has seen a further uplift as a result of the standard methodology for calculating housing need, which based on the most credible set of population projections suggests a further uplift to circa 680 new homes per year.

3.6.6 In addition to the need moving forward, the previous difficulties in keeping pace with delivery has resulted in a need to accommodate a significant number of dwellings in the short term with a deficit in five year supply.

3.6.7 Given the current development plan has seen documented difficulties in meeting the existing core strategy housing target, the need for new housing is compelling and indisputable and must be addressed by the new plan as a priority.

3.6.8 Indeed, it is our view that housing need alone is an exceptional circumstance to direct development to the AONB.

The cost of, and scope for, developing elsewhere

3.6.9 Tunbridge Wells is a constrained borough. There are a number of archaeological and heritage sites, including 45 Historic Parks and Gardens, 25 Conservation Areas and 11 Scheduled Ancient Monuments. In addition, there are approximately 3,000 Listed Buildings.

3.6.10 The landscape of the High Weald AONB contains numerous historic landscape features, including field patterns, settlements and ancient woodland, whilst the borough also hosts a number of, or is close to, areas of ecological importance. These include:

(1) Ancient Woodland (approximately 16% of the borough)

(2) Circa 60 Local Wildlife Sites (approximately 11% of the borough)

(3) Ten Sites of Special Scientific Interest (SSSI)

(4) Five Local Nature Reserves (including one Community Woodland)

(5) One Regionally Important Geological Site, at Scotney Castle Quarry.

3.6.11 The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA).

3.6.12 Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells borough.

3.6.13 Given the above constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy.

3.6.14 In respect of Cranbrook, the village is not located within the 22% of the borough that is Green Belt and where an ‘in principle’ objection to development applies. Furthermore, there are no non-AONB alternative sites available given the entire extent of Cranbrook (albeit not all of Sissinghurst) is washed over by the designation. Any growth that will provide a meaningful input of market and affordable homes is going to have a degree of adverse impact. The priority must therefore be prioritising the sites with the lesser impact.

3.6.15 The supporting landscape work carried out by LDA has shown that the site can be developed whilst retaining the individual identifies of Hartley and Cranbrook. Moreover, a landscape strategy has informed the proposal to minimise impact to the AONB and ensure proposals respond to and integrate with the sites landscape setting.

3.6.16 Taking into account landscape sensitivity, AONB impact and wider planning constraints, land at Turnden is the most suitable for site for development in Cranbrook, as concluded in the LVA.

Any detrimental effects and the extent to which that could be moderated

3.6.17 Opportunity exists to moderate the effects of development, including substantial areas of landscaping and associated ecological and heritage buffers and the opportunity to increase public access to the land.

3.6.18 The landscape strategy outlined by LDA has informed the proposal to minimise impact to ensure that proposals respond to and integrate with the sites landscape setting, as detailed within the LVA.

In summary, we support the Council’s conclusions that exceptional circumstances exist to justify the allocation of sustainable AONB land.

4 Conclusion

4.1.1 This representation has been prepared on behalf of Berkeley in response to the plan consultation.

4.1.2 Berkeley control Turnden, Hartley Road, Cranbrook and are promoting it for residential redevelopment as part of the wider development plan review. Part of the site already benefits from residential planning permission and the wider land was promoted via the initial ‘Call for Sites’ process and is included as a draft allocation (ref. AL/CRS 4) within the draft regulation 18 plan.

4.1.3 The purpose of this representation is to provide comment on the Council’s proposed development strategy and specific proposals for allocated sites within the plan.

4.1.4 In this respect, we commend the Council for aspiring to meet their housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Further, we support the inclusion of Berkeley’s land as a residential allocation.

4.1.5 However, notwithstanding our in-principle support, the strategy relies heavily on the delivery of strategic sites that require the provision of supporting infrastructure. Moreover, the Council have applied overly optimistic projections to the delivery of housing for the extension of Paddock Wood and the Tudeley Garden Village, largely disregarding the NLP 2016 report and the time it would take to deliver the required infrastructure and agree a comprehensive masterplan with the numerous relevant stakeholders. Indeed, by applying the assumptions in the NLP document the plan would fall short of its projections for Paddock Wood and Tudeley by nearly 4,000 homes.

4.1.6 In our view, a more realistic trajectory would see some housing delivered at these strategic sites, albeit not at the suggested build out rates and much later in the plan period. Accordingly, we would stress the importance of making efficient use of proposed site allocations to ensure that enough housing is brought forward early in the plan period. Likewise, additional sites are available within the borough that are suitable for development.

4.1.7 Berkeley consider the development site outlined by the Council can deliver circa 165 homes. However, for the reasons outlined in this statement and the attached appendices there is an opportunity to modify policy AL/CRS 4 and extend the developable area, delivering a further 40 homes, resulting in an approximate delivery of 205 additional new homes. A concept masterplan is included with this submission to demonstrate that this could be achieved, whilst delivering the required green infrastructure and without prejudice to the strategic and development management requirements that need to be fulfilled. The development parameters have been informed by detailed landscape work which seeks to minimise impact to the AONB and ensure proposals respond to and integrate with the sites landscape setting. It also shows that land at Turnden is the most suitable for site for development in Cranbrook.

4.1.8 Notwithstanding the work carried out to date, we look forward to working with the Council as proposals evolve in the lead up to an application, including the layout of new homes and open space as well as more detailed considerations such as housing mix.

[TWBC: see full representation and separate Appendix 4 (a) and 4 (b) ].

DLP_5561

Mr Paul Hewitt

Object

Local research for the NDP indicates that local residents are against large scale development as a method of delivering housing in the Parish. It is not compatible with the way Wealden villages and towns emerged.

Moving the LBD is an underhand way of sanctioning this allocation which is in the AONB….. there are other areas not in the AONB which would serve better.

This development is unsustainable, being too far from employment centres and train hubs, necessitating residents to use cars.

There is absolutely no indication of potential employment provision except during any construction phase.

DLP_3901

Mrs June Bell

Object

Reasons for objection:

Why has TWBC allocated this major development site in the AONB and ignored:

I. Its own policy in the DLP STR 8 Conserving and Enhancing the Natural built and Historic environment, in particular point 5 relating to the AONB

II. The High Weald AONB Management Plan which has been adopted by all the Councils with land in the AONB as their policy for the management of the area and for the carrying out of their functions in relation to it.

III. The draft Parish Neighbourhood Plan to focus on small scale sites and avoid large scale sites

IV. NPPF para 172:’ Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. …….The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances and where it can be demonstrated that development is in the public interest.’

V. DEFRA Landscape review 2019 highlights the CPRE report (2017 CPRE & AONB ‘Landscapes for Life’ available at: https://landscapesforlife.org.uk/application/files/5315/5552/0923/Housing-in-AONBs-Report.pdf ) revealing that approvals for housing units within AONBs and within 500m beyond their boundaries have increased by 82% between 2012-2016, numbers of affordable units have gone down and the risk that paragraph 172 ‘exceptional circumstances’ is being used to argue for major development on the grounds that no other sites outside the AONB are available.

In addition: this allocation risks coalescence of the 2 currently distinct areas; Cranbrook Conservation Area and Hartley and contravenes the Requirement in Policy STR/CRS1 6. ‘All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development;’

Please refer to Draft Neighbourhood Plan Map identifying Green Gaps between Settlements

I. This allocation is outside the current LBD. Proposed extensions of LBD shown on Map reference 14.1 in order to ‘qualify’ as in paragraph 5.76 ‘adjacent to the existing Cranbrook Limits to Built Development in the AONB is contradictingThe purpose of this designation/policy approach to LBD was to “restrict the encroachment of built form into the surrounding landscape”. as defined in the Limits of Built Development Topic Paper for DLP Reg 18 Consultation. Aug 2019 and will set a precedence for further development of valuable AONB landscape

II. This allocations risks loss of Protected Views: 1

* View 26 AONB Landscape from Mount Ephrahim looking West towards Hartley

* View 35 AONB Landscape from footpath at Turnden Farm

as identified in the emerging Cranbrook and Sissinghurst Draft Neighbourhood Plan

1 http://cranbrookandsissinghurstndp.co.uk/wp-content/uploads/2019/09/152_QR_190724_Protected-Views-MAP-PHOTOS.pdf

DLP_5073

Tally Wade

Object

Policy AL/CRS 4 (page 208)

I object to the allocation of land for housing for Turnden Farm. Phase 2 of this development will create a coalescence of it with the annexed development at Brick Kiln Farm, both are outside of the LBD and I object to this being redrawn to accommodate more houses. Despite steps proposed to mitigate the appearance of coalescence from the road, the reality will be a fundamental change to this historic landscape. Turnden represents a significant survival of a Medieval farmstead surrounded by its own fields and associated Medieval features typical of the High Weald including historic route ways. It is also a decimation of yet more AONB. The land at Turnden is classified as ‘Best and Most Versatile’ Grade 3 Agricultural land so development here is contrary to paragraph 6.227 in the plan.

DLP_4021

Brian Swann

Object

There is already planning approval for 35 houses for this Farmstead-acceptable but NOT for an Estate

It is outside the LBD and in an A.O.N.B.

With the allocation of the adjoining site of Brick Kiln Farm it would become one big housing estate over 350+ houses. The green fields of Turnden form the last remaining seperation between Cranbrook (with the character of a Town) and Hartlehy (with the character of a hamlet) We must keep this "green space".

The site is highly visible from well used footpaths which cross the fields behind and allow local people experience a feeling of open space, naturalness and rurality along the Crane Valley.

Local research for the N.D.P indicates that local residents are against large scale development as a means of developing housing. It is not the way Wealden village emerged. Moving the LBD is an underhand way of sanctioning this allocation which is in the AONB.

If you must build here then there should be at least 50% affordable to buy for 1st time buyers and sized for people who want to retire to smaller houses, thus freeing up their (local) larger properties.

DLP_4596

Keith Stockman

Object

The large scale development proposed is not compatible with the way Wealden villages and towns emerged and building on AONB land
is incompatible with TWBC’s stated policy. To move the LBD would be a deceitful way of permitting this development to take place. Local residents are unilaterally against large scale development as a method of delivering housing in the Parish, as evidenced by independent local research commissioned for the NDP. The proposed development is a long way from the designated new employment centres and from the nearest train station, necessitating new residents to use personal transport to and from these locations. This is entirely unsustainable.

DLP_5458

Resident of Hartley

Object

As a resident of Hartley, I feel that I must object to the continued destruction of our beautiful countryside and the proposed for Gate Farm and Bull Farm.  We chose to live in this area because of its natural beauty – that is what attracts so many visitors and keeps local business thriving.

We live on the borders of Cranbrook and Hawkhurst and find that the roads are becoming more and more congested each day.   The plan for 900 new homes in Cranbrook will bring the roads to a standstill without even contemplating all the developments planned for Hawkhurst.  Our roads can’t cope.

How can our beautiful villages sustain all these extra people?  Doctors surgeries are jammed packed as it is.

It seems to me that the majority of the new housing are large houses which are totally out of reach for the majority of local residents and young people looking for first time buys.

Also, the Management Plan is to focus on small scale sites which would be more acceptable  but this is being ignored with large scale developments being planned.

Why doesn’t Tunbridge Wells Council kick back on the requests being made for so many new homes in our beautiful countryside.

It will just turn our villages into big towns which is not what local Residents want.

DLP_6125

Cranbrook & Sissinghurst Parish Council

Object

Major development sites allocated in the AONB ignoring Tunbridge Wells own policy set out in the draft Local Plan, its AONB Management Plan and the draft Parish Neighbourhood Plan to focus development on small-scale sites.

DLP_6130

Cranbrook & Sissinghurst Parish Council

Object

Objection because conflicts with Policy STR/CRS1 6 (non-coalescence), conflict with Policy EN20, harm to historic landscape farmsteads and hamlets. It is in proximity to Crane Valley should be a severe constraint.

DLP_7317

Mr Richard Gill

Object

Policy Number:  AL/CRS 4   Turnden Farm, Hartley Road 

I object to the allocation of land for housing at Turnden Farm. Phase 2 is a major development within the AONB, outside the LBD and its size is inappropriate and detrimental to such an important historic farmstead which still retains intact medieval field boundaries.  With its rich habitats and ecosystems, no amount of mitigation is going to create net gains for nature biodiversity (EN11).  The site scored highly negatively for landscape and environmental objectives in the SHELAA.  The level of harm both in landscape and beauty that would arise in the AONB is substantial. Turnden embodies the sense of rurality and tranquillity which is so typical of the High Weald AONB. It promotes the health and well-being of the local residents who use the PROWS. Together with the Brick Kiln Farm development it will create a coalescence between Cranbrook and Hartley which is contrary to national planning policy. The High Weald AONB has the highest status of protection nationally in relation to landscape and scenic beauty, equal to that of National Parks, this allocation would contribute drastically to the increasing suburbanisation of the AONB. The land at Turnden is classified as Grade 3 Agricultural land, as a finite resource and a store for carbon and water surely this is at odds with TWBC Carbon Zero policy 2030.

DLP_5609

Mrs Jacqueline Hewitt

Object

Local research for the NDP indicates that local residents are against large scale development as a method of delivering housing in the Parish. It is not compatible with the way Wealden villages and towns emerged.

Moving the LBD is an underhand way of sanctioning this allocation which is in the AONB….. there are other areas not in the AONB which would serve better.

This development is unsustainable, being too far from employment centres and train hubs, necessitating residents to use cars.

There is absolutely no indication of potential employment provision except during any construction phase.

DLP_7230

Elizabeth Daley

Object

Policy Number: AL/CRS 4

Local research for the NDP indicates that local residents are against large scale development as a method of delivering housing in the Parish. It is not compatible with the way Wealden villages and towns emerged.

Moving the LBD is an underhand way of sanctioning this allocation which is in the AONB….. there are other areas not in the AONB which would serve better.

This development is unsustainable, being too far from employment centres and train hubs, necessitating residents to use cars.

There is absolutely no indication of potential employment provision except during any construction phase.

DLP_7044

Philippa Gill

Object

Policy Number:  AL/CRS 4   Turnden Farm, Hartley Road

I object to the allocation of land for housing at Turnden Farm. Phase 2 is a major development within the AONB, outside the LBD and its size is inappropriate and detrimental to such an important historic farmstead which still retains intact medieval field boundaries.  With its rich habitats and ecosystems, no amount of mitigation is going to create net gains for nature biodiversity (EN11).  The site scored highly negatively for landscape and environmental objectives in the SHELAA.  The level of harm both in landscape and beauty that would arise in the AONB is substantial. Turnden embodies the sense of rurality and tranquillity which is so typical of the High Weald AONB. It promotes the health and well-being of the local residents who use the PROWS. Together with the Brick Kiln Farm development it will create a coalescence between Cranbrook and Hartley which is contrary to national planning policy. The High Weald AONB has the highest status of protection nationally in relation to landscape and scenic beauty, equal to that of National Parks, this allocation would contribute drastically to the increasing suburbanisation of the AONB. The land at Turnden is classified as Grade 3 Agricultural land, as a finite resource and a store for carbon and water surely this is at odds with TWBC Carbon Zero policy 2030.

DLP_5981

Steve Rix

Object

Policy AL/CRS 4 (page 208) I object to the allocation of land for housing for Turnden Farm. Phase 2 of this development will create a coalescence of it with the annexed development at Brick Kiln Farm, both are outside of the LBD and I object to this being redrawn to accommodate more houses. Despite steps proposed to mitigate the appearance of coalescence from the road, the reality will be a fundamental change to this historic landscape. Turnden represents a significant survival of a Medieval farmstead surrounded by its own fields and associated Medieval features typical of the High Weald including historic route ways. It is also a decimation of yet more AONB. The land at Turnden is classified as ‘Best and Most Versatile’ Grade 3 Agricultural land so development here is contrary to paragraph 6.227 in the plan.

DLP_6042

Laura Rowland

Object

Major development is not appropriate in the AONB. TWBC have accepted that Turnden is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

Turnden reflects the High Weald’s typical Medieval character. It lies within a distinct Medieval den which formed part of the Manor of Godmersham and its character remains agricultural, unlike the adjoining den of Cranbrook which developed into a town. Turnden represents a significant survival of a Medieval farmstead surrounded by its own fields and associated with other Medieval features typical of the High Weald including a historic routeways (Hartley Road and a PROW), a Medieval common/ green (Goddards Green) and ancient gill woodland (Crane Valley).

Appendix 3 of the Distribution of Development Topic Paper which deals with major development in the AONB claims that the land around the historic farmstead of Turnden has ‘no clear function’ and that development provides an ‘opportunity to resolve land use issues and to provide a green and permanent gap between Hartley and Cranbrook’. This is nonsense.

With the allocation of the adjoining site of Brick Kiln Farm for housing, the green fields of Turnden form the last remaining separation between Cranbrook (with the character of a town) and Hartley (with the character of a hamlet). The site is highly visible from well used footpaths which cross the fields and allow local people to experience a feeling of naturalness and rurality along the Crane Valley. Despite its recent use as horse pasture, a large proportion of the site retains its Medieval field pattern (Early-post Med) with intact field boundaries which are often thick and woody. These fields and their associated habitats continue to function effectively to deliver a range of benefits (ecosystem services) including buffering the ancient woodland and water quality of the Crane.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met? It is clear that the land at Turnden does have a clear function. The case for major development at Turnden has not been made, and the mitigation measures assumed are spurious.

Half of the site lies along the Crane Valley between areas of Ancient Woodland and high priority woodland. Maintaining this area as open undeveloped land is essential to achieving the Local Plan and Neighbourhood Plan objectives to restore and enhance the Crane Valley as wildlife habitat; to provide greenspace to support people’s health and wellbeing through contact with nature; and to protect water quality and enhance natural Flood management (these are also AONB Management Plan objectives).

These objectives would best be served by land use which promotes regenerative agriculture supporting rural jobs and livelihoods, grassland restoration or natural wilding and woodland regeneration.

Paragraph 102 of the NPPF, requires the environmental impacts of traffic and transport to be considered at the start. The impact of creating new access to this site, which will essentially introduce a suburban character to a rural historic routeway appears not to have been considered.

The Neighbourhood Development Plan undertook a detailed assessment of this site using the recommended AECOM template. The site was assessed as unsuitable for development. TWBC have not explained why they have come to a different decision.

DLP_6150

Turley for Taylor Wimpey UK Ltd

 

The development of Site CRS4 would continue built form substantially south west of Cranbrook and the existing adopted allocation to the immediate north east of the site. The cumulative impact of both these sites would be the substantial sprawl of Cranbrook south westwards away from its core, eroding the sense of separation and separate identities of Cranbrook and Hartley. Development in the eastern part of the site would also be highly visible from the public footpath to the south, which currently experiences open rural views across this area. Independent assessments of this site, versus SHELAA Site Ref:25 have been undertaken and are appended as Documents B and C. In the interests of brevity, we refer to our strategic level comments at STR/CRS1, which summarise the objections raised to the omission of SHELAA Site Ref: 25.  We respectfully recommend that Site 25 be re-assessed in this context, as we contend this site merits allocation as a suitable, logical and sustainable site for around 70 homes, either in addition to CRS4, CRS6 and CRS7, or in place of one of these. All of which we contend score less favourably against the Council’s SA objectives than site 25.

[TWBC: see full representation and supporting document A, supporting document B, supporting document C, and supporting document D]. 

DLP_6498
DLP_6514
DLP_6544
DLP_6651
DLP_6709
DLP_6732
DLP_7679

Clare Govan
Philip Govan
Rory Govan
Stephanie Govan
Edward Govan
James Govan
Joe Hughes

Object

The following comment was submitted by the list of responders on the left:

This site is not suitable for major development. No attempt has been made to demonstrate that there are exceptional circumstances, taking account of the following factors which are required to be assessed under in accordance with para 172 of the NPPF

  • development of this size is not needed for growth of the local community
  • it would have an adverse impact on Cranbrook’s status as a tourist attraction
  • there are better opportunities for developing outside the AONB
  • it would have a detrimental effect on the landscape and recreational opportunities, with no realistic scope for this to be moderated

Development of this site would be contrary to Policy EN 21: “All development within, or affecting the setting of, the High Weald AONB shall seek to conserve and enhance its landscape and scenic beauty, having particular regard to the impacts on its character components, as set out in the High Weald AONB Management Plan.”  It cannot seriously be argued that development on this scale seeks to conserve and enhance the AONB’s landscape and scenic beauty.

The agreed policy in the AONB Management Plan seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.  In no way could this development be seen to meet that objective.

Turnden lies within a distinct Medieval den which formed part of the Manor of Godmersham and its character remains agricultural.  It represents a significant survival of a Medieval farmstead surrounded by its own fields and associated with other Medieval features typical of the High Weald including a historic routeways (Hartley Road and a PROW), a Medieval common/ green (Goddards Green) and ancient gill woodland (Crane Valley).  Any development of this site would cause devastating and irreversible damage to the landscape and scenic beauty for which the local community and future generations will not forgive those responsible.

Appendix 3 of the Distribution of Development Topic Paper contains the absurd statement that the land around the historic farmstead of Turnden has ‘no clear function’ and that development provides an ‘opportunity to resolve land use issues and to provide a green and permanent gap between Hartley and Cranbrook’.  If this were true it could be applied to any green space that is not being actively used.  Planners should surely realise that some landowners deliberately avoid putting land to good use purely to enhance the prospect of getting planning consent.

The green fields of Turnden form the last remaining separation between Cranbrook (with the character of a town) and Hartley (with the character of a hamlet). The site is highly visible from well used footpaths which cross the fields and allow local people to experience a feeling of naturalness and rurality along the Crane Valley. A large proportion of the site retains its medieval field pattern with intact field boundaries which are often thick and woody. These fields and their associated habitats continue to function effectively to deliver a range of benefits including buffering the ancient woodland and water quality of the Crane brook.

The permanent grassland on this site plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. How does the Local Plan ensure that this commitment is met?  The case for major development at Turnden has not been made.

Part of the site lies along the Crane Valley between areas of ancient woodland and high priority woodland. Maintaining this area as open undeveloped land is essential to achieving the Local Plan and Neighbourhood Plan objectives to restore and enhance the Crane Valley as wildlife habitat; to provide greenspace to support people’s health and wellbeing through contact with nature; and to protect water quality and enhance natural flood management.

Transport issues are required by para 102 of the NPPF to be considered from the earliest stages.  The following have not been addressed:

  • The impact of creating new access to this site, which will essentially introduce a suburban character to a rural historic routeway, will have an adverse environmental impact
  • The A262 via Goudhurst is the route used by the entire Parish to travel to work or to shop in Royal Tunbridge Wells. Support services, including HGVs, also use this route, notwithstanding the warning sign “unsuitable for long vehicles”. The A262 through Goudhurst is narrow and the corner by St Mary’s Church is notorious for problems when large vehicles travelling in opposite directions meet there.  There is no scope to widen the road. This regularly causes extended hold-ups and there has been damage to buildings and to the churchyard wall.  There is no obvious alternative route and the additional traffic generated by the development would be detrimental to the character of the historic village of Goudhurst, with consequent impact on its economy.

DLP_6549

Diana Badcock

Object

I did not object to the 36 dwellings currently being built, but I strongly object to any further development of this site in the AONB. The NDP opposes this as the scale is inappropriate and it would result in loss of the green space and a coalescing of Cranbrook (town) and the Hartley (‘hamlet’) settlements, which should be avoided in this historic landscape.

DLP_7368

Andrew Ford

Object

Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

  1. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
  2. the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
  3. any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.

TWBC have accepted that Turnden is major development but have not explained how the sequential tests required by para. 172 have been met. This policy is therefore, not justifiable.

Major development of this scale is not appropriate in an AONB. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

Turnden reflects the High Weald’s typical Medieval character. It lies within a distinct Medieval den which formed part of the Manor of Godmersham and its character remains agricultural, unlike the adjoining den of Cranbrook which developed into a town. Turnden represents a significant survival of a Medieval farmstead surrounded by its own fields and associated with other Medieval features typical of the High Weald including a historic routeways (Hartley Road and a PROW), a Medieval common/ green (Goddards Green) and ancient gill woodland (Crane Valley).

Appendix 3 of the Distribution of Development Topic Paper which deals with major development in the AONB claims that the land around the historic farmstead of Turnden has ‘no clear function’ and that development provides an ‘opportunity to resolve land use issues and to provide a green and permanent gap between Hartley and Cranbrook’. This is nonsense.

With the allocation of the adjoining site of Brick Kiln Farm for housing, the green fields of Turnden form the last remaining separation between Cranbrook, with the character of a town, and Hartley, with the character of a hamlet. The site is highly visible from well used footpaths which cross the fields and allow local people to experience a feeling of naturalness and rurality along the Crane Valley. Despite their recent use as horse pasture, a large proportion of the site retains its Medieval field pattern (Early-post Med) with intact field boundaries which are often thick and woody. These fields and their associated habitats continue to function effectively to deliver a range of benefits (ecosystem services) including buffering the ancient woodland and water quality of the Crane, and storing soil carbon.

Half of the site lies along the Crane Valley between areas of Ancient Woodland and high priority woodland. Maintaining this area as open undeveloped land is essential to achieving the Local Plan and Neighbourhood Plan objectives to restore and enhance the Crane Valley as wildlife habitat; to provide greenspace to support people’s health and wellbeing through contact with nature; and to protect water quality and enhance natural Flood management (these are also AONB Management Plan objectives).

These objectives would best be served by land use which promotes regenerative agriculture, grassland restoration or natural wilding and woodland regeneration.

DLP_7581

Susie Oakenfold

Support with conditions

I appreciate that development is needed to meet government targets but why destroy the integrity of the beautiful town centre and historic buildings and overall appearance.  At least the LAND ADJACENT TO CRANE VALLEY Map 52 Policy AL/CRS 9 proposal contains modern buildings in one area without blighting the town centre’s old buildings, is walkable to the shops and schools, and will have vehicle access onto a wider stretch of the road that could reasonably have traffic control measures.  The same applies to TURNDEN FARM ON HARTLEY ROAD AL/CRS 4 – it is at least self contained and does not threaten the appearance or character of the town.  However, the sheer number of the two combined is very worrying for the future impact of so many more people on the town and, of course, resulting enormous increase in traffic.

Policy AL/CRS 5: Land adjoining Cranbrook Primary School, Quaker Lane

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_7907
DLP_2515
DLP_6044
DLP_7369

Fiona Dagger
Mr Guy Dagger
Laura Rowland
Andrew Ford

Object

TWBC: the following comment was submitted by the responders on the left:

This site lies in the High Weald AONB and TWBC have not demonstrated that the requirements of NPPF, para 172 have been met.

NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving, i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3.

DLP_3032

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 5 by Cranbrook primary school (35-45 dwellings). Housing will be close to Jaegers field, also near Cranbrook CA but close to Cranbrook centre and services so easy to walk and support town. Increase green space retained and reduce housing numbers. AMBER

DLP_3440

High Weald AONB Unit

Object

Ecological surveys should be carried out on the grassland, which appears to be species-rich.

DLP_2082

Terry Everest

Object

Site is green field and should not be developed, this area is currently a pleasant open space and should remain so.

DLP_3299

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The Local Highway Authority objects to this policy.

The existing vehicular and pedestrian access to site are inadequate. Vehicluar access to Angley Road has been considered at pre-stage and not supported by Local Highway Authority as only a very narrow frontage. Quaker Lane also unsuitable.

Public Rights of Way and Access Service

Improvements should be made to the PRoW that pass through the site. It is also requested that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development.

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is some potential for prehistoric and later remains

DLP_3441

Sally Marsh

Object

Policy Number: AL/CRS 5 Quaker Lane

This site lies in the High Weald AONB and TWBC have not demonstrated that the requirements of NPPF, para 172 have been met.

NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving, i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3.

DLP_3611

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Cranbrook. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. The assessment reveals that existing local sewerage infrastructure to the site has limited capacity to accommodate the proposed development. Limited capacity is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of new wastewater infrastructure.

Proposals for 45 dwellings at this site will generate a need for reinforcement of the wastewater network in order to provide additional capacity to serve the development. This reinforcement will be provided through the New Infrastructure charge to developers, and Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. Connection of new development at this site ahead of new infrastructure delivery could lead to an increased risk of flooding unless the requisite works are implemented in advance of occupation. Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is limited. Planning policies and conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure, and does not contribute to pollution of the environment, in line with paragraph 170(e) of the revised National Planning Policy Framework (NPPF) (2019).

In consideration of the above, we recommend the following criterion is added to Policy AL/CRS 5

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in liaison with the service provider.

Southern Water is the statutory wastewater undertaker for Cranbrook. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. Our assessment has revealed that Southern Water's underground infrastructure crosses this site. This needs to be taken into account when designing the site layout. Easements would be required, which may affect the site layout or require diversion. Easements should be clear of all proposed buildings and substantial tree planting.

In consideration of the above, we recommend the following criterion is added to Policy AL/CRS 5

Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes

DLP_3931

Mrs June Bell

Support with conditions

Condition:

I. The scale of this allocation risks coalescence of the 2 currently distinct conservation areas; Cranbrook Conservation Area and Wilsley Green Conservation Area and contravenes the Requirement in Policy STR/CRS1 6. ‘All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development;’

Minimise land taken for development and develop AFFORDABLE 1-3 bedroomed high quality dwellings in keeping with the setting of the 2 Conservation Areas

II. This allocation risks loss Protected View and the layout of development should be orientated to preserve view as achieved from St Dunstan’s Walk: 1

View 15 Townscape from Quaker Lane looking SW to Saint Dunstans & Windmill as identified in the emerging Cranbrook and Sissinghurst Draft Neighbourhood Plan

1 http://cranbrookandsissinghurstndp.co.uk/wp-content/uploads/2019/09/152_QR_190724_Protected-Views-MAP-PHOTOS.pdf

DLP_4624

Anne Watson

Object

Cranbrook School’s offered sites        Objection

As a former PE teacher I am horrified at the amount of land dedicated to sports fields which Cranbrook School is offering for houses. Surely at this time of greater emphasis on school children becoming more physically active it can’t be right that Cranbrook School is proposing to submit all of its available playing areas.

DLP_6136

Cranbrook & Sissinghurst Parish Council

Object

Concerns about density and the need for affordable high quality dwellings in keeping with the setting of two Conservation Areas.

DLP_7318
DLP_7045

Mr Richard Gill
Philippa Gill

Object

I object to the allocation of land for housing at Quaker Lane.  It is outside the LBD, within the AONB and will promote the coalescence between the Wilsley Green and Cranbrook which is against national planning policy. It is a sensitive site because of its proximity to the Wilsley Conservation Area and other heritage assets and would be contrary to Policy EN6.  The northern part of the site is a grassland of importance, designated in KCC Priority Habitats 2012 dataset which would contravene Policy EN12.

DLP_5940

S J Ireland

Object

Policy CRS5 - Cranbrook Primary School

This is an area which geographically has less visual impact, being located in a hollow/ depression. Houses for young families, with proximity of school and nursery would be beneficial, providing they are developed to very high sustainability criteria and sufficient informal green space is retained to support the local wildlife - on my last visit, a couple of weeks ago, I saw a party of long-tailed tits.

Policy AL/CRS 6: Gate Farm, adjacent to Hartley Road and Glassenbury Road, Hartley (plus Bull Farm)

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_972

Mrs A Marley

Object

No. 59 Gate farm off Hartley Road and Glassenbury Road. 90 houses too many on good agricultural land and too far from local facilities and shops.

DLP_973

Mrs A Marley

Object

No. 70 Land SW Lampion Crescent. 90 houses too close to overhead power lines with risk of cancer

DLP_978

Mrs A Marley

Object

Site 345 Land at Glassenbury. 95 houses. Too rural & isolated

No infrastructure.

DLP_983

Mrs A Marley

Object

Late Site 53 Land at Bull Farm Glassenbury 90 house

Too rural & isolated

No infrastructure.

DLP_7783

Annie Hopper

Object

Why has TWBC allocated this major development (90 homes) in the AONB and ignored:

* Its own policy in the DLP STR 8 Conserving and Enhancing the Natural built and Historic environment, in particular point 5 relating to the AONB

* The AONB Management Plan

* The draft Parish Neighbourhood Plan to focus on small scale sites and avoid large scale sites.

* NPPF para 172: Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. …….The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances and where it can be demonstrated that development is in the public interest.

* DEFRA Landscape review 2019 highlights the CPRE report (2017 CPRE & AONB ‘Landscapes for Life’ available at: https://landscapesforlife.org.uk/application/files/5315/5552/0923/Housing-in-AONBs-Report.pdf ) revealing that approvals for housing units within AONBs and within 500m beyond their boundaries have increased by 82% between 2012-2016, numbers of affordable units have gone down and the risk that paragraph 172 ‘exceptional circumstances’ is being used to argue for major development on the grounds that no other sites outside the AONB are available.

* This allocation for large scale development is outside the LBD.

It is also stated that ‘development on the site shall accord with the following requirements

1. ‘A masterplan approach to ensure a comprehensive scheme for the whole parcel is appropriately delivered’

This was a condition ‘imposed ‘on the developers of Brick Kiln Farm and those of the adjacent site, Cornhall Farm (Site 292) allocated in the current Local Plan 2016. To date this ‘Masterplan’ has not been produced.

How will TWBC enforced a masterplan for the development of these 5 sites.

It is obvious that significant discussion will need to be had with the local residents and infrastructure must be a priority before any development takes place.

Local research for the NDP indicates that local residents are against large scale development as a method of delivering housing in the Parish.

This development is unsustainable, being too far from employment centres and train hubs, necessitating residents to use cars.

There is absolutely no indication of potential employment provision except during any construction phase.

DLP_7896

Michael and Jane Love

Object

We object to the above developments on the ANOB that is Cranbrook and the High Weald . These are beautiful areas that you will ruin and once lost you can not get them back for future generations

DLP_7908

Fiona Dagger

Object

Major development is not appropriate in the AONB.

I am writing to object to this planning application as while I acknowledge that there is a need for additional housing within the Borough, this is not a suitable housing site. It is a largely undeveloped, greenfield site situated within the High Weald Area of Outstanding Natural Beauty (AONB) some distance away (around 2.3 klm) from the everyday facilities and services available within the central part of Cranbrook. Housing development on this site will therefore, inevitably result in increased car use adding to traffic emissions and climate change, compromising the principles of achieving sustainable development.

I understand that at this stage, the proposal is in outline form only with the principle of housing development on the site and the access to be determined by the Council. Nevertheless, the future site layout clearly has the potential to harm the rural open setting of nearby Hartley Gate Farmhouse as a Grade II listed building and the proposed means of access onto the A259 Hartley Road is likely to cause highway safety issues as well as visual harm.

While it is proposed to widen the existing access, this is currently no more than a farm track that is little used. The proposal for up to 27 houses will add significantly to vehicle movements by those turning into and out of the site in very close proximity to the already busy turning movements at the nearby junction with the B2085 Glassenbury Road located about 200m to the south west of the site. It seems inevitable that there will be a conflict in these traffic movements with more vehicles slowing and stopping to turn at both junctions.

I am aware that a recent appeal was refused for 8 dwellings on neighbouring land to the north of Hartley Gate Farmhouse (planning appeal reference no. APP/M2270/W/18/3203543 – Planning application no. 17/03481/FULL) where the appointed Planning Inspector concluded that the proposed vehicular access “would have a harmful effect on highway safety significantly increasing the risk of collisions in the area and therefore endangering life…” and that this would significantly and demonstrably outweigh the benefits of new housing notwithstanding the current shortfall in the 5-year land supply.

In addition, the widening of the existing access would result in visual harm through the loss of hedgerows and tress and increase public views into the site towards what would be a modern housing estate where at present, the application site forms part of the tranquil AONB rural setting of Hartley, which is characterised by mainly small scale and scattered ribbon development along the road frontages. This historic landscape with its traditional farmsteads and medieval build pattern which, in addition to Hartley Gate Farm House, includes a number of other listed buildings in the vicinity (such as Bull Farm House, Bull Farm Barn, Bull Farm Oast, Hartley Dyke Farmhouse, Hartley Hall and Hartley Cottages), would be irreversibly damaged through such urbanisation and built development, forever harming the rural approach to Cranbrook further to the east.

I am aware that the Council is about to publish a new draft Local Plan for public consultation at the end of next week. I am astonished to learn however, that notwithstanding the rather remote and relatively isolated location within the AONB countryside (Hartley is no more than a hamlet), the application site has been put forward as a potential larger scale allocation for 90 houses together with employment use under the provisions of draft Policy CRS6. This would not only result in the urbanisation of this unspoilt and historic part of Hartley (which currently has no development boundary), but would significantly increase traffic movements and add to highway safety and increased harmful vehicle emissions. Much greater emphasis should instead, be placed upon making more effective use of previously developed brownfield site and where greenfield sites have to be released, this should be at more sustainable locations on the edge of larger settlements that are able to support local communities and where additional car use might be minimised.

Draft Local Plan Policy CRS6 states that the land should only be developed as part of a comprehensive masterplan approach, so the current application is clearly premature in this respect. If the planning application is approved in advance of the Local Plan (and indeed the current production of the Cranbrook Neighbourhood Plan), this would render the Council’s proposed public consultation as meaningless and prejudice the proper consideration of alternative and more suitable housing sites.

Like myself, I am sure many of those living in Hartley, will be very concerned about the scale and nature of this proposed Local Plan allocation and we should be given a fair opportunity for our concerns to be submitted and taken into account before any decisions are made about the development of the land or any part of it. Furthermore, any partial development of the land would also prejudice proper consideration of the means of access to the larger area of land proposed as part of the draft allocation in the Local Plan.

I hope therefore, that these and other objections on the Council’s website in relation to this planning application, will be fairly and reasonably taken into account at the time this planning application is determined, and that the planning application will be refused as being harmful to current rural planning and landscape protection policies and having regard also to highway safety concerns. The planning application should also be refused planning permission as being prejudicial to public consultation on the Council’s proposed Local Plan draft Policy CRS6 as well as the Cranbrook Neighbourhood Plan in being likely to harm the proper consideration and assessment of suitable alternative housing sites.

TWBC have not explained why they have come to a different decision.

DLP_8002

Richard Pickles

Object

(resident of Gate Farmhouse TN17, where your proposal intends to entirely surround my property with new developments, where the proposed developer refuses to engage with me and where, showing utter disregard to my views, you use the name of my property as the name of this proposed development).

DLP_8054

Sophie Foster

Object

I object to the allocation of this site as appropriate for major development.

The site is adjacent or very near to five listed buildings and an oasthouse which together with the rural environment are fundamental to the area’s characteristics as an AONB. These heritage assets and the surrounding rural environment are complementary to each other.  The site’s location at the junction of Glassenbury Road with Hartley Road is such that its rural nature determines the character of the AONB in this area.  Any development would cause Hartley to become semi-urban and inconsistent with its history.  The listed buildings and other heritage assets would look incongruous if the historic landscape with which they are associated is covered in dwellings.

No attempt has been made to demonstrate that there are exceptional circumstances, taking account of the following factors which are required to be assessed under in accordance with para 172 of the NPPF

  • development of this size is not needed for growth of the local community
  • it would have an adverse impact on Cranbrook and Hartley as a tourist attraction
  • there are better opportunities for developing outside the AONB
  • it would have a detrimental effect on the landscape and recreational opportunities, with no realistic scope for this to be moderated

Development of this site would be contrary to Policy EN 21: “All development within, or affecting the setting of, the High Weald AONB shall seek to conserve and enhance its landscape and scenic beauty, having particular regard to the impacts on its character components, as set out in the High Weald AONB Management Plan.”  It cannot seriously be considered that any development on this very prominent site at a key location could be such as would seek to conserve and enhance the AONB’s landscape and scenic beauty. 

The agreed policy in the AONB Management Plan seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.  In no way could this development be seen to meet that objective.

It will not be possible to provide anything near the “approximately 90 dwellings” declared to be provided by this site, taking account of the specified requirements relating to vehicular access, protection of hedgerows and mature trees, and TWBC Farmstead Assessment Guidance SPD which mandates a character-based approach to change around traditional farmstead groups and their buildings.

The site reflects the predominantly rural and medieval character of the High Weald. It lies at a prominent high point with extensive views to the East towards the Greensand Ridge, and west towards Bedgebury, Flimwell and Combwell. The site consists of a complex of fields providing the setting for four historic farmsteads and lying at a prominent junction between an ancient droveway, an ancient ridge top road, and an ancient track (now a public right of way) into Bedgebury Forest connecting with a known iron working site at Furnace Farm. The site provides a rural and typically High Weald setting for the small hamlet of Hartley.  It is very visible from the road and, together with the surrounding heritage assets, effectively determines the rural nature of the area.

The northern part of the land to the East of Glassenbury Road is a known species rich grassland site. This habitat is one of the most rare and vulnerable habitats in the Weald and should be protected in order that it can form a core for nature recovery networks proposed in the Government’s 25-year environment plan and new Environment Bill. The rural environment and the remaining traditional farm buildings, albeit derelict, significantly increases the chance that protected species are present.

The agricultural land across a large part of the site is Grade 3a, amongst the best and most versatile qualities of agricultural land. The majority of the High Weald is grade 3 and 4.  Pockets of 3a like this site are vital if the aspirations of dealing with food security, growing food locally and adapting to climate change are to be delivered. The impact of permanently sealing grade 3a agricultural land with artificial surfaces and buildings cannot realistically be mitigated.

Any development of this site would cause devastating and irreversible damage to the landscape and scenic beauty for which the local community and future generations will not forgive those responsible.

The permanent grassland on this site plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. How does the Local Plan ensure that this commitment is met?  The case for major development at Gate Farm has not been made.

The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3.  Without any supporting evidence these conclusions glibly suggest that “detracting elements and poor landscape management’ can be “addressed through development”, and that “Existing site context and careful design can result in a discrete well contained development.”  The reality is that Gate Farm has been used effectively for many years to graze sheep.  It is obvious that the recent cessation of this activity was purely to enhance the development prospects.  Also the derelict farm buildings have been deliberately run down so as to become an eyesore with the same objective.  They should be restored or demolished and the site put back to agricultural use as befits its Grade 3a status.  The site is now re-wildling naturally thereby contributing to biodiversity gain.  But in any case permanently sealing the site with artificial surfaces cannot be said to address any “detracting elements and poor landscape management” alleged in the Topic Paper.

Transport issues are required by para 102 of the NPPF to be considered from the earliest stages.  The following have not been addressed:

  • The impact of creating new access to this site, which will essentially introduce a suburban character to a rural historic routeway, will have an adverse environmental impact
  • The A262 via Goudhurst is the route used by the entire Parish to travel to work or to shop in Royal Tunbridge Wells. Support services, including HGVs, also use this route, notwithstanding the warning sign “unsuitable for long vehicles”. The A262 through Goudhurst is narrow and the corner by St Mary’s Church is notorious for problems when large vehicles travelling in opposite directions meet there.  There is no scope to widen the road. This regularly causes extended hold-ups and there has been damage to buildings and to the churchyard wall.  There is no obvious alternative route and the additional traffic generated by the development would be detrimental to the character of the historic village of Goudhurst, with consequent impact on its economy.

DLP_477

Katie Goldfinch

Object

I would like to register my objection to the above proposed sites. I have read your Sustainability Appraisal  in which your own findings show that the sites in Hartley score mostly negatively  due to the loss of sensitive greenfield site in the AONB and and close proximity of a a SSSI. The only positive benefit TWBC stated  is the area could provide a significant amount  of housing. However my understanding is an AONB is not required to provide housing other than for the residents of the area ( in this case Hartley Dyke).  Therefore I would like to know :

What research has been carried out to assess the needs of housing for Hartley Dyke residents because presumably this has to form the basis of any  development proposal? 

What evidence is there to show that Hartley Dyke needs this large number of houses proposed ? 

I am also objecting on the grounds of policy  EN21

In the Sustainability Appraisal no consideration is given to this policy which is key to any development in an ANOB .

Having looked at the proposed development I cannot see how this  proposed site could be achieved in accordance with Policy EN21.

Therefore I would like to know what  evidence has been put forward to suggest this is a potential development site where by the  requirements of EN21 can be met? (The TWBC  Sustainability Appraisal suggests by its own findings this cannot be done) 

Finally I would really appreciate knowing how these questions will be considered and addressed  in the next step of the consultation process.

DLP_708

Patricia Preston

Object

In 1999 when Bull Farm was sold a 'blue line' was put around the barns and fields by TWBC. This was to stop the farm being broken up and sold off in more profitable smaller units. This now appears to be exactly what TWBC are trying to do. That is not taking any notice of your own legislation.

West of Glassenbury Road B2085.This land is at 125m, a high ridge. Consequently it can be seen for miles across Bedgebury Forest. Filmwell radio mast is over 3 miles away, (as the crow flies) can be seen and Kilndown. So any development here will be visible across Bedgebury Forest and Combwell woods etc. Goudhurst is only 126m. A blight on the skyline. Bedgebury Forest and ancient woodlands are approx 200m away. Close by is Robins Wood SSSI. A truely rural area. TWBC will destroy these view in an AONB.

Bull Farm B1/B2/B8 are proposed as employment units. There are approx 4 farm buildings in this area but by far the greater proportion is permanent pasture. The development would potentially destroy species rich grassland and its associated soil micro-fauna and mycorrhizal fungi. The long- established features on site, and particularly adjacent species rich grassland which is a priority habitat for protection nationally as well as locally, support critical characteristic wildlife species.

As this area is so high there will also be noise and light pollution from industrial units (so called employment units), and houses. Any lights will be visible across the whole of Bedgebury Forest and more of the surrounding AONB.

If employment units are built there will be increased traffic - probably more than just cars. These larger vehicles will require access to B2085 which will either be at the Bull Farm entrance or Bishops Lane. Bishops lane is an unpaved bridleway used by horses, rambler, D of E children totally unsuitable for traffic. This lane joins the B2085 about 10m from the junction with the A229 an already busy, dangerous  junction. All exsisting pinch points- Hawkhurst. Flimwell, Goudhurst will be worsened.

I strongly object to the proposed Draft Local Plan for Cranbrook and Sissinghurst. Especially development at Bull Farm as it is in an AONB, visible and audible for miles as on top of a ridge. Traffic generated would cause congestion and danger on Glassenbury Road and junction with the A229. Many would be travelling to Staplehurst station causing more traffic on the A229. Or going to Tunbridge Wells through Goudhurst causing more conjestion in that village, the  A262 already has suggested HGV limitation as the corners by the church are so tight.

DLP_8346

Joe Matthews

Object

TWBC: correspondent submitted the following comments on 20/11/19, after the close of consultation on 15/11/19:

Please find below my specific objections to your proposed development plan.  I find the entire approach entirely reprehensible, both in ignoring the views and tireless hard work of various NDPs and imposing a lazy, self-interest driven plan which severely damages a large number of smaller communities within the TWBC area.  The fact that a few greedy landowners, who clearly have no regard for their local communities, are set to benefit massively from this proposal,further justifies the rightful anger of communities.

I strongly urge TWBC to re-engage with NDPs, review the district's true development requirements, ensure appropriate infrastructure is included in all developments and share the impact more fairly across all communities.

Yours in disgust

Joseph Matthews

(resident of Gate Farmhouse TN17, where your proposal intends to entirely surround my property with new developments, where the proposed developer refuses to engage with me and where, showing utter disregard to my views, you use the name of my property as the name of this proposed development).

DLP_2495

Mr John Wotton

 

AL/CRS 6 Gate Farm, Hartley

Object

This would be a major development within AONB (see DDTP, para 6.35) of 90 new homes. The three sites allocated under this policy are partly greenfield and outside the LBD. There are no exceptional circumstances within NPPF 172 justifying the major development on these sites, which are prominent within the AONB landscape. They would constitute an extension to the existing settlement of Hartley, where there are limited shopping facilities (a farm shop, fishmonger and café). It is a long walk to Cranbrook town centre from the sites and, although the sites are on a bus route, it is likely that most daily trips from the sites would be made by car. We note that the policy has a mixed sustainability score. The sites are also close to Robin’s Wood SSSI and would lead to the loss of some best and most versatile farmland. I oppose major development on these sites.

DLP_2517

Mr Guy Dagger

Object

Major development is not appropriate in the AONB.

I am writing to object to this planning application as while I acknowledge that there is a need for additional housing within the Borough, this is not a suitable housing site. It is a largely undeveloped, greenfield site situated within the High Weald Area of Outstanding Natural Beauty (AONB) some distance away (around 2.3 klm) from the everyday facilities and services available within the central part of Cranbrook. Housing development on this site will therefore, inevitably result in increased car use adding to traffic emissions and climate change, compromising the principles of achieving sustainable development.

I understand that at this stage, the proposal is in outline form only with the principle of housing development on the site and the access to be determined by the Council. Nevertheless, the future site layout clearly has the potential to harm the rural open setting of nearby Hartley Gate Farmhouse as a Grade II listed building and the proposed means of access onto the A259 Hartley Road is likely to cause highway safety issues as well as visual harm.

While it is proposed to widen the existing access, this is currently no more than a farm track that is little used. The proposal for up to 27 houses will add significantly to vehicle movements by those turning into and out of the site in very close proximity to the already busy turning movements at the nearby junction with the B2085 Glassenbury Road located about 200m to the south west of the site. It seems inevitable that there will be a conflict in these traffic movements with more vehicles slowing and stopping to turn at both junctions.

I am aware that a recent appeal was refused for 8 dwellings on neighbouring land to the north of Hartley Gate Farmhouse (planning appeal reference no. APP/M2270/W/18/3203543 – Planning application no. 17/03481/FULL) where the appointed Planning Inspector concluded that the proposed vehicular access “would have a harmful effect on highway safety significantly increasing the risk of collisions in the area and therefore endangering life…” and that this would significantly and demonstrably outweigh the benefits of new housing notwithstanding the current shortfall in the 5-year land supply.

In addition, the widening of the existing access would result in visual harm through the loss of hedgerows and tress and increase public views into the site towards what would be a modern housing estate where at present, the application site forms part of the tranquil AONB rural setting of Hartley, which is characterised by mainly small scale and scattered ribbon development along the road frontages. This historic landscape with its traditional farmsteads and medieval build pattern which, in addition to Hartley Gate Farm House, includes a number of other listed buildings in the vicinity (such as Bull Farm House, Bull Farm Barn, Bull Farm Oast, Hartley Dyke Farmhouse, Hartley Hall and Hartley Cottages), would be irreversibly damaged through such urbanisation and built development, forever harming the rural approach to Cranbrook further to the east.

I am aware that the Council is about to publish a new draft Local Plan for public consultation at the end of next week. I am astonished to learn however, that notwithstanding the rather remote and relatively isolated location within the AONB countryside (Hartley is no more than a hamlet), the application site has been put forward as a potential larger scale allocation for 90 houses together with employment use under the provisions of draft Policy CRS6. This would not only result in the urbanisation of this unspoilt and historic part of Hartley (which currently has no development boundary), but would significantly increase traffic movements and add to highway safety and increased harmful vehicle emissions. Much greater emphasis should instead, be placed upon making more effective use of previously developed brownfield site and where greenfield sites have to be released, this should be at more sustainable locations on the edge of larger settlements that are able to support local communities and where additional car use might be minimised.

Draft Local Plan Policy CRS6 states that the land should only be developed as part of a comprehensive masterplan approach, so the current application is clearly premature in this respect. If the planning application is approved in advance of the Local Plan (and indeed the current production of the Cranbrook Neighbourhood Plan), this would render the Council’s proposed public consultation as meaningless and prejudice the proper consideration of alternative and more suitable housing sites.

Like myself, I am sure many of those living in Hartley, will be very concerned about the scale and nature of this proposed Local Plan allocation and we should be given a fair opportunity for our concerns to be submitted and taken into account before any decisions are made about the development of the land or any part of it. Furthermore, any partial development of the land would also prejudice proper consideration of the means of access to the larger area of land proposed as part of the draft allocation in the Local Plan.

I hope therefore, that these and other objections on the Council’s website in relation to this planning application, will be fairly and reasonably taken into account at the time this planning application is determined, and that the planning application will be refused as being harmful to current rural planning and landscape protection policies and having regard also to highway safety concerns. The planning application should also be refused planning permission as being prejudicial to public consultation on the Council’s proposed Local Plan draft Policy CRS6 as well as the Cranbrook Neighbourhood Plan in being likely to harm the proper consideration and assessment of suitable alternative housing sites.

DLP_3034

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 6 Hartley road/Glassenbury. On AONB and too far from Cranbrook to be sustainable in transport terms or to support CRANBROOK centre. This effectively elongates settlement towards Hartley. RED

DLP_3442

High Weald AONB Unit

Object

Major development is not appropriate in the AONB.

Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

j) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

k) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and

l) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.

TWBC have accepted that Gate Farm is major development but have not explained how the sequential tests required by para. 172 have been met. This policy is therefore, not justifiable.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

This site reflects the predominantly rural and medieval character of the High Weald. It lies at a prominent high point (130m) with extensive views to the East towards the Greensand Ridge, and west towards Bedgebury, Flimwell and Combwell. The site consists of a complex of fields providing the setting for 4 historic farmsteads and lying at a prominent junction between an ancient droveway, an ancient ridge top road, and an ancient track (now a PROW) into Bedgebury Forest connecting with a known iron working site (SAM) at Furnace Farm. The site provides a rural and typically High Weald setting for the small hamlet of Hartley.

The northern part of the land to the East of Glassenbury Road is a known species rich grassland site. This habitat is one of the most rare and vulnerable habitats in the Weald and should be protected in order that it can form a core for nature recovery networks proposed in the Government’s 25-year environment plan and new Environment Bill. The rural environment and the remaining traditional farm buildings, albeit derelict, significantly increases the chance that protected species are present.

The agricultural land across a large part of the site is Grade 3a, which is included within the definition of ‘the best and most versatile agricultural land’ (NPPF paragraph 170). The majority of the High Weald is grade 3 and 4. Pockets of 3a like this site are vital if the aspirations of dealing with food security, growing food locally and adapting to climate change are to be delivered. The impact of permanently sealing grade 3a agricultural land with artificial surfaces and buildings cannot be mitigated within a reasonable time frame.

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that ”great weight should be given to conserving and enhancing the landscape and scenic beauty” in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The ‘how’, i.e. the conserving and enhancing, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that ‘detracting elements’ and ‘poor management’ can be ‘addressed’ through development, and that the development will be ‘contained’. Why ‘containment’ is beneficial (in our view it is not) and how permanently sealing the site with artificial surfaces can ‘address’ management is not explained.

DLP_2948

Garry Pethurst

Object

My primary obejection to this is the number of dwellings proposed for the sites. There are, in reality, only two parts of this site, which, I believe, is owned by four different landowners, which can be developed - Gate Farm and the lower part of Bull Farm. Both of these sites currently have farm buildings on (in a greater or lesser state of repair), which might be developed on the basis of farmstead developments identified by the community as a preferred solutions. It must be recognised that the traffic issues are far greater than appear to be identified in this policy, and that the 'sticking plaster' of a 30 MPH speed limit is not the answer.

DLP_2771

Lee Hatcher

Object

There are multiple developers and land owners here, not all of which are willing to enter into this process. The development is next to an already busy and dangerous junction - there is little public transport nearby (one hourly bus in each direction). It is likely any travelling from here will be by car adding to this traffic. The developers were also unaware until publishing of the local plan that masterplanning here would be required. The site is in the AONB, it is far from main settlements, it is not supported at all by neighbours and will face strong opposition from them.

DLP_2083

Terry Everest

Object

Strongly Object

Another farm, another opportunity to protect the countryside and not build over it. I refer to all my previous objection comments.

DLP_3007

DHA Planning for Fernham Homes, Pickhill Developments & The Glassenbury Estate

 

1 Introduction

1.1 Purpose of this report

1.1.1 This representation has been prepared on behalf of Fernham Homes, Pickhill Developments and The Glassenbury Estate as a collective response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until 15th November 2019.

1.1.2 Collectively our clients control land allocated for development within and adjoining Gate Farm, Hartley Road, Hartley (Cranbrook). Our clients are committed to bringing forward a collective masterplan for this parcel of land. For the avoidance of doubt, the land to which this representation relates is shown in colour coded parcels below.

[TWBC: to view map/plan please see page 2 of full representation].

1.1.3 Fernham Homes control Gate Farm, which has an outline planning application for 27 units pending consideration (red land). It also controls the wider land to the north owned by the Glassenbury Estate (white land).

1.1.4 Pickhill Developments control the residual land situated between Hartley Gate Farmhouse and Campion Crescent. This site was subject to a detailed planning application including type of development, housing designs, and site layout and to a recent appeal, which found the site suitable for development in all respects except in respect of the suitability of the proposed vehicular access. However, with the potential movement of the 30mph speed limit along Hartley Road, as outlined within the emerging policy, an access to this site would also be achievable.

1.1.5 Based on the current national and local planning context, we consider the land to be suitable for formal allocation and we consider there to be the ‘exceptional circumstances’ to allow development within the High Weald Area of Outstanding Natural Beauty (‘AONB’). Given this context, this representation responds to the content of the draft plan (and relevant supporting documents), reinforces why the land is suitable and outlines how developments could be delivered on site.

2 The Tunbridge Wells Draft Local Plan

2.1 Overview

2.1.1 The TWBC Draft Local Plan (herein referred to as ‘the plan’) sets out the spatial vision, strategic objectives, and overarching development strategy for the borough. It details overarching place shaping policies for each parish and settlement, as well as site specific allocations to deliver the strategy and detailed policies to be applied to all new development.

2.1.2 The plan will set the agenda for development across the borough to 2036 and replace the current Development Plan, which comprises the Local Plan 2006 (saved policies), the Core Strategy 2010, and the Site Allocations Local Plan 2016.

2.1.3 This representation comments on the following elements of the plan:

  • Vision and Strategic Objectives;
  • Development Strategy and Strategic Policies;
  • Place Shaping Policies for the Parish of Cranbrook and Sissinghurst; and
  • Development Management Policies.

2.2 Vision and Strategic Objectives

2.2.1 The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure led and largely funded by new development. The key components of the vision are summarised below:

  • The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.
  • Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.
  • A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop into the following years).
  • High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure
  • Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

2.2.2 The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

2.2.3 In order to turn this vision into reality the plan sets a number of strategic objectives.

  1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development;
  2. To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';
  3. To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;
  4. To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;
  5. To ensure that the borough is vibrant, culturally rich, and economically buoyant;
  6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;
  7. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;
  8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;
  9. To establish garden settlements as a model for the future delivery of development in the borough;
  10. To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.

2.2.4 We support the general thrust of these objectives, which seek to meet identified housing needs in full and boosting significantly the supply of new affordable homes. However, we would suggest some minor modification to clarify that the plan is positively prepared and fully aligned with the provisions of the National Planning Policy Framework (‘NPPF’). Indeed, we acknowledge that the Plan aspires to achieve the full development needs of the borough and therefore we consider that objective 1 should be modified to make certain on this point.

“To deliver the full housing, economic and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led and high quality development”

2.3 Development Strategy and Strategic Policies (Policy STR1)

2.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where that development will be located.

2.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed. Further, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.

2.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Governments standard method and the 2014-based household projections.

2.3.4 In terms of the different supply components, the Council consider that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account; completions since April 2016 (1,552); extant planning permissions (3,127); outstanding site allocations (588) and a windfall allowance (700 dwellings). The Council have applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved.

2.3.5 We agree that TWBC is capable of meeting its need in full and support this approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach. Nonetheless, we have concerns regarding the deliverability of the strategy and the potentially over optimistic housing trajectory, particularly in respect of the delivery from key strategic sites (as outlined below).

2.3.6 We note that the emerging strategy is consolidated by Policy STR1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs of the borough over the plan period. This strategy would seek to meet the majority of the Council’s housing need through the strategic extension of Paddock Wood and via a new Garden Village at Tudeley. The remaining growth would then be dispersed proportionately to other settlements in the borough.

2.3.7 We support the general principle of proportionately spreading the benefits of growth. Adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area.

2.3.8 Nonetheless, we have some concerns regarding the balance between strategic and non-strategic scale allocations and the anticipated delivery trajectory. For example, 65% of new allocations would be delivered as part of the strategic extension to Paddock Wood (4,000 homes) and the new Garden Village at Tudeley (1,900 homes within the plan period), both of which require a fully master-planned approach, which is a time-consuming process. Furthermore, there are a significant number of existing commitments within Paddock Wood that have been slower at coming forward than had originally been envisaged. A cautious approach is therefore needed.

2.3.9 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum, although it can be as high as 301 dwellings per annum.

2.3.10 On the basis of this research, if the Local plan is adopted by 2021, planning permission approved by 2023 and delivery commences within 6 years (2029), the likely deliver for the plan period would be no more than 966 homes.

2.3.11 Despite this evidence, TWBC has set a much more optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper. The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, the Council suggests that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know how many housebuilders will be involved.

2.3.12 Taking the above into account, our view is that the Council have applied overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure.

2.3.13 Given the absence of any similar scale strategic sites in Tunbridge Wells Borough as a point of comparison, one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017).

2.3.14 Kings Hill is an extremely prudent example to consider in the context of the Paddock wood extension and new garden village at Tudeley, how deliverable this would be. Indeed, Kings Hill was a new village started in 1989 near land previously occupied by RAF West Malling. The concept was for a multipurpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum, despite multiple developers delivering concurrently. Furthermore, the earlier delivery phases we delivered at lower rates given the need to front load infrastructure.

2.3.15 Therefore, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer terms aspirations that will extend beyond 2036.

2.3.16 Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure, particularly sustainable settlements such as Cranbrook and to reduce the reliance upon Tudeley within this current plan period.

2.4 Place Shaping Policies

2.4.1 The place shaping policies establish the spatial priorities for different areas in the borough, organised according to non-parish and parish areas. For each area, there is an overarching policy that development should adhere to and details are provided for individual allocated sites that will deliver the quantum of development proposed. The site-specific allocations provide both strategic and development management guidance.

Cranbrook and Sissinghurst (including Hartley)

2.4.2 Policy STR/CR1 sets the proposed strategy for Cranbrook and Sissinghurst (including Hartley) and states that Approximately 718-803 new dwellings will be delivered on nine sites, including AL/CRS 6.

2.4.3 Collectively Fernham Homes, Pickhill Developments and The Glassenbury Estate control the eastern parcel of allocation policy AL/CRS 6, which is referred to within theplan as ‘Gate Farm, adjacent to Hartley Road and Glassenbury Road, Hartley (plus Bull Farm) (SHELAA reference: Sites 59, 70, 323 & 345, and Late Site 53)’.

2.4.4 This site is allocated for residential development (C3) providing approximately 90 dwellings (including land at Bull Farm), plus employment (B1/B2/B8), and community uses. According to the policy, development on the site shall accord with the following requirements:

  1. A masterplanning approach to ensure a comprehensive scheme for the whole parcel is appropriately delivered;
  2. Provision of improved pedestrian and cycle links to Hartley and Cranbrook, including investigations into the feasibility of a pedestrian footway on the north side of Hartley Road (see Policy TP 2: Transport Design and Accessibility);
  3. Vehicular access into the separate parts of this allocation to be informed by a highways assessment (see criterion 5 of Policy EN 1: Design and other development management criteria);
  4. Opportunities for relocation of 30mph speed zone southwards from Cranbrook to include the site to be explored, and provision of associated gateway features;
  5. Regard will be given to existing hedgerows and mature trees on site, with the layout and design of the development protecting those of most amenity value, as informed by an arboricultural survey and a landscape and visual impact assessment (see Policy EN 14: Trees, Woodlands, Hedges, and Development and criterion 3 of Policy EN 1: Design and other development management criteria);
  6. Provision of a strong and robust soft landscaping boundary along the entire far western boundary of the site and additional soft landscaping along the northern boundary;
  7. Development proposals will need to demonstrate where appropriate a positive contribution to Biodiversity Opportunity Area targets (see Policy EN 11: Net Gains for Nature: biodiversity);
  8. This site lies within, or very close to, the relevant impact risk zone for Robins Wood SSSI and so an assessment of potential adverse effects on the SSSI as a result of the development will be required as part of any application and, if required, the proposal shall include adequate mitigation measures, both during construction and on completion, to the satisfaction of Natural England to ensure no adverse effects on the SSSI as a result of the proposed development (see Policies EN 11: Net Gains for Nature: biodiversity and EN 12: Protection of designated sites and habitats);
  9. The layout and design of the scheme to give full consideration to the location of the site on the edge of the settlement, and to provide a scheme that is sensitively designed and provides a suitable urban edge to the settlement (See Policy EN 1: Design and other development management criteria);
  10. Design proposals will be required to reflect and respond sensitively to the existing farmsteads and clusters of buildings present on the site (see Policy EN 7: Heritage Assets);
  11. Design proposals to consider and minimise the impact on the listed farmhouses and buildings within the site (again see Policy EN 7: Heritage Assets);
  12. Assessment of archaeological potential (again see Policy EN 7: Heritage Assets);
  13. Development proposals to include the provision of small-scale B1/B2/B8 employment units;
  14. Opportunities to be explored to provide a community focus for the wider Hartley area as part of the development proposal;
  15. Provision of on-site amenity/natural green space and children’s play space and improvements to existing allotments, parks and recreation grounds and youth play space in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation;
  16. Avoidance of unnecessary demolition (see Policy EN 2: Sustainable Design and Construction).

It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development:

a. Improvements to the public realm;

b. Any other highways related works;

c. Improvements to bus services and bus infrastructure, e.g. improved bus stop locations;

d. Provision of new and/or improved community facilities serving Hartley; e. Cycling routes in accordance with Policy STR/CRS 1’.

2.4.5 The corresponding policy map depicts the allocation as detailed below.

[TWBC: to view map/plan please see page 10 of full representation].

2.4.6 In response to the draft allocation, our clients collectively support the inclusion of the majority of the eastern parcel, which is suitable, available and deliverable as demonstrated by the progression of Fernham’s current outline planning application and the earlier scheme advanced by Pickhill Developments. However, we have some minor concerns about the boundary of the eastern parcel, namely the area outlined in blue below.

2.4.7 This area does not fall within the scope of our clients’ control nor is there any merit including it does not benefit from vehicular access and provides an area that is not suitable for development owing to wider heritage constraints and the likely impact on Gatehouse Farm, a Grade II listed building. It is our view that the redline area of the proposed allocation should be amended to exclude this component.

[TWBC: to view map/plan please see page 11 of full representation].

2.4.8 In addition to the above, we object to the eastern parcel of land within our clients’ control being combined with Bull Farm, as they are distinctly different parcels with no shared or comment linkages other than proximity. By combining the two distinctly different parcels, in separate land ownerships, the allocation is complicating delivery and would potentially restrict the site coming forward in a timely manner given there is a distinct land of clarity in respect of what is being sought.

2.4.9 In our view the eastern parcel within our clients’ control should be identified for residential development and community open space as annotated on the attached masterplan, included as Appendix 1 [see full representation].

2.4.10 The western parcel should be identified for commercial and residential opportunities that can be brought forward at an appropriate time independent to our client’s land.

2.4.11 Turning to deliverability, as part of Fernham Home’s live planning application, it has been shown that a safe and workable access can be achieved to the eastern parcel. It is proposed that vehicular access to the eastern parcel will be derived from the A229 Hartley Road by way of a simple priority junction on the south eastern boundary, approximately 60m to the north east of the junction with the B2085 Glassenbury Road and approximately 70m to the south west of the junction with the B2086 Swattenden Lane. The internal access road will initially measure 5.5m in width, narrowing to 4.8m within the internal confines of the site. A Stage 1 access design is included as part of the pending application.

2.4.12 The access will also be provided with a 1.8m wide footway on both sides which continue into the site along either side of the internal spine road. The 1.8m wide footway also continues for approximately 25m to the north east of the site access on the north side of the A229 Hartley Road, at which point a pedestrian refuge island is proposed. This pedestrian refuge island provides connectivity with the existing footway to the south of the A229 Hartley Road which continues to the north east in the direction of Cranbrook.

2.4.13 The access is suitable for accommodating approximately 62 units as depicted on the accompanying masterplan.

2.4.14 In respect of ecology and tree elements of the policy, we would point out that a Preliminary Ecological Appraisals were carried out for both the Fernham Homes live application and the earlier scheme submitted by Pickhill Developments. The most recent was undertaken in November 2018 by Corylus Ecology. The initial PEA findings identified:

  • Two hedgerows (H2 and H3) along the boundaries meet criteria for the ‘Important’ hedgerow assessment, under the terms of the Hedgerows Regulations 1997. These hedgerows will be largely retained and a buffer of semi-natural habitat will be created between the development and the hedgerows;
  • Three trees with ‘Moderate’ to ‘High’ potential to support a bat roost were identified and further bat emergence surveys were recommended for these during May – August. A minimum of one emergence survey has been recommended for Tree T9, which has been assigned as having ‘Low’ potential due to a potentially suitable feature.
  • Six other trees with ‘Low’ potential were identified due to ivy cover. If these trees are to be impacted, a further survey including re-inspection is recommended.
  • The Site has been assessed as supporting ‘Low’ quality habitat for foraging and commuting bats. Three activity surveys were recommended during May – September; one survey should be undertaken per season (spring, summer, autumn);
  • Suitable reptile habitat has been identified in the Site and presence / likely absence surveys have been recommended;
  • The Site supports suitable terrestrial habitat for great crested newt. It is recommended that Habitat Suitability Index Assessments of six offsite ponds within a 250m radius of the Site are undertaken and further surveys may be required to determine presence / likely absence;
  • Advice to avoid the disturbance of breeding birds during the active breeding period 1st March - 1st September has been provided, relating to clearance of both vegetation and buildings; and
  • Recommended ecological enhancements include native, species-rich planting, installation of bird boxes on the proposed houses and retained trees, and measures to maintain connectivity for hedgehog.

2.4.15 In line with NPPF recommendations, it has been proposed that the following measures are included in the scheme to maintain and enhance biodiversity:

  • Species-rich hedgerows should be planted around the gardens and access roads. areas of proposed grassland, including road verges and gardens, are seeded with a species-rich grassland seed mix (such as Emorsgate ‘Flowering lawn mixture EL1’ or ‘Meadow mixture for clay soils EM4’) and a range of nectar-rich plants are considered for any landscape planting;
  • bird boxes should be provided in the proposed development
  • Any closeboard fencing be installed with 13 x 13cm holes at the base to allow hedgehogs to forage in the local habitats.

2.4.16 The following protected species surveys were recommended in the ‘Preliminary Ecological Appraisal Report’

  1. Reptile presence/likely absence surveys
  2. Great crested newt (GCN) Habitat Suitability Index (HSI) assessments and, for suitable ponds,
  3. GCN presence/absence surveys
  4. Dormouse presence/likely absence surveys
  5. Bat presence/likely absence surveys

2.4.17 These surveys have been commissioned and are either complete or ongoing. In summary:

2.4.18 A ‘Low’ population of grass snake has been recorded on Site. The current proposals will not result in the loss of any significant areas of suitable reptile habitat. However, a detailed reptile mitigation and enhancement strategy will be required to relocate the reptiles from the development area to an agreed receptor site. An outline mitigation strategy has been provided within the report, which includes the identification of an appropriate receptor site for any grass snakes caught during the construction works.

2.4.19 A Small breeding population of GCN has been confirmed present within one pond (P3) within a 100 - 150m radius of the Site. An EPS licence will be required for the project and a detailed GCN mitigation strategy will be required at the final planning stage. This will set out the times of year that suitable GCN habitat can be removed and the method of vegetation removal under ecological supervision once a licence has been granted. The mitigation strategy will also include details of any habitat compensation, receptor area and relocation exercise that will be required. An outline mitigation for GCN has been provided within the report which includes the identification of an appropriate receptor site for any GCN caught during the construction works.

2.4.20 At the time of writing dormouse presence/likely absence surveys have been undertaken between March and June 2019. To date, no dormice or evidence of dormice have been recorded within the Site. The surveys will continue until the required 20 points have been achieved, which will be by September 2019. Until then any interim results should be treated with caution and are intended for guidance until the full survey is complete.

2.4.21 The need for a licence and detailed mitigation strategy will be determined once the results of the dormouse surveys are known. However, the proposed layout has been reviewed and an outline mitigation strategy based on this layout has been provided in the report. It is considered that adequate mitigation and compensation for dormice, if recorded, can been provided within the development to ensure the favourable conservation status of this species is maintained.

2.4.22 Corylus has completed one set of bat surveys including tree emergence and activity surveys. The subsequent two are scheduled and ongoing. A bat roost has been confirmed present in an oak tree in the northern corner (outside the site boundary) and a possible bat roost is present in the oak tree in the south-western corner (T8 and T11). These trees will be retained through the proposals with a buffer of semi-natural habitat created between the development and trees. In this instance, mitigation for these bat roosts is likely to include a detailed sensitive lighting strategy to ensure that there is not increase in artificial lighting on the trees or adjacent bat flights.

2.4.23 Turning to trees, the focus of the application has been to preserve existing tree coverage and provide additional tree planting as part of the wider landscape and ecology strategy. This includes retention of the hedgerows and an adequate landscape buffer.

2.4.24 Landscape Collective have been instructed to carry out a tree survey in accordance with BS: 5837:2012 for the current live application. In total 47 items were surveyed on this parcel. In summary:

(1) 5 survey items were considered to be good quality (Category A), with a useful life expectancy of in the region of 40+ years.

(2) 6 survey items were considered to be moderate quality (Category B) with an anticipated useful life expectancy of in the region of 20+ years.

(3) 35 survey items were considered to be low quality (Category C) with an anticipated useful life expectancy of in the region of 10-20+ years.

(4) 1 survey item was considered unsuitable (Category U) with an anticipated useful life expectancy of less than 10 years.

2.4.25 Many of the trees within this aspect of the site are of important landscape value as they are visible from Hartley Road and/or Glassenbury Road, and/or residential properties near the site. The survey also flags that future management must include careful monitoring of the health of the retained trees within the site, so as to maximise the aesthetic and wildlife value of the tree resource.

2.4.26 The hedgerow resource is very undermanaged and needs strengthening in places. There are also opportunities for laying some of the hedgerow resource.

2.4.27 A tree survey was also carried out for the earlier Pickhill Developments scheme, prepared by Broadoak Tree Consultants, which too demonstrate that the development of that parcel can be comfortably accommodated without detriment to existing vegetation and trees on the site boundaries.

2.4.28 The pending application is supported by a detailed Heritage Assessment undertaken by Heritage Collective. In summary, the only heritage asset which the proposals are capable of affecting is the grade II listed Hartley Gate Farmhouse, which is visible along Hartley Road, and on approach from Swattenden Lane. The Site wraps around the south western and north western plot boundaries of the historic farmhouse, which has not been associated with the farm for over 30 years, with list description stating it was purely residential at the time of listing.

2.4.29 The report has identified that the proposed development is capable of causing a very low level of less than substantial harm due to the change in the listed building’s wider setting with some encroachment on the open fields to the rear. However, this will not detrimentally affect the understanding of the significance of Hartley Gate Farmhouse, due to the limited contribution the Site makes to its setting, which is best appreciated from Swattenden Lane and Hartley Road. In contrast, the setting to the rear involves a deep garden, which is part of historic plot boundaries. The farmhouse also has been disassociated form the farming activities a long time ago, hence the open fields to the rear no longer serve to reveal its significance. This element of significance is best understood via the historic cartographic evidence.

2.4.30 Overall, there is no indication that the proposals will harm the setting of the listed building, due to the scheme’s design, the location of the proposal and the changes in the uses within Hartley Gate Farmhouse and its wider setting which includes residential development at Campion Crescent. It is considered that the proposals are capable of meeting the local and national policy tests in relation to heritage.

2.4.31 Finally, both the current Fernham Homes application and the earlier Pickhill Developments scheme were supported by Landscape Visual Assessments prepared by Landscape Collective.

2.4.32 In summary, the results were consistent and conclude that with the proposals in place, the elements and features that characterise the site i.e. topography and trees, hedgerows and shrubs, and which contribute to the character of the wider landscape will experience some but not substantial change.

2.4.33 The result of the loss of the agricultural land use on the site and its replacement with a predominantly residential one would initially be an inevitably major adverse effect. Such a change and effect would be experienced with any greenfield development. However, except for the loss of an agricultural field, the proposals will, demonstrably be compatible and in most instances positively contribute to the AONB Management objectives.

2.4.34 Through the retention of the retained existing key landscape characteristics of topography and vegetation substantially unaltered and the establishment of new tree, hedgerow and shrub planting that will become increasingly mature, the provision of new amenity space and increased ecology, the nature of the effect on the character of the site will become increasingly beneficial overtime, from year 10 of the operational phase and beyond.

2.4.35 The proposed residential development would not materially change the key landscape characteristics or elements and features of the wider environment, identified in either the published landscape character assessment. The proposed development would be contained within the existing pattern of settlement and small to medium scale fields so that the existing landscape pattern would continue to prevail with the proposals in place. The design and form of the proposed development reflects and responds to the pattern and vernacular of the development surrounding the site.

2.4.36 The relationship of the character of the landscape containing the site and the more agricultural landscape to the south, east and west of the site and the main settlement areas would be materially unchanged with the proposed development in place. The proposals will be contained by existing development that already forms a physical and to a greater degree visual separation from the wider landscape of the countryside. This relationship will not be altered with the proposed development in place.

2.4.37 The visual assessments demonstrates that views of the proposed development from within the wider landscape would typically be restricted through the form of the local topography, the presence of existing built form and vegetation or a combination of each of these factors in the intervening landscape between the visual receptor (person/people) and the application site boundary. A selection of representative viewpoints indicate that higher level of visual effects would be experienced from closer to the site boundary, as might reasonably be expected, but the visual effects of the proposed development when in place would diminish the further one travelled from the site boundary.

2.4.38 Having regard to the above, we support the proposed allocation of the eastern parcel, which is within the collective control of our clients. Furthermore, based on current and earlier applications, prepared on a consistent basis by the same consultant team, we consider a significant degree of evidence has been provided to demonstrate that the eastern parcel is deliverable. However, the same level of information is yet to be prepared for the western parcel of land and so we have concerns in respect of the linkage as a single allocation. Accordingly, the two parcels should be subject to separate allocations with much greater clarity on what uses relate to what parcels.

2.5 Exceptional Circumstances

2.5.1 Paragraph 172 of the NPPF states that great weight should be given to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection. It goes on to state that planning permission should be refused for major developments in AONB areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

2.5.2 Consideration of such major applications should include an assessment of:

(1) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

(2) the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and

(3) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

2.5.3 It is important to stress that footnote 55 of the NPPF is clear that for the purposes of paragraphs 172 and 173, whether a proposal is ‘major development’ is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined. The term has no direct correlation with the definitions set out in the Town and Country Planning (Development Management Procedure) (England) Order 2015.

2.5.4 We set out below why we consider exceptional circumstances exist for the allocation of the eastern parcel.

2.6 The need for the development

2.6.1 As outlined by the plan, there is an overriding and growing housing need within the Borough. The Council’s SHMA findings initially identified the future need to plan for some 648 new homes per year. This in turn has seen a further uplift as a result of the standard methodology for calculating housing need, which based on the most credible set of population projections suggests a further uplift to circa 680 new homes per year.

2.6.2 In addition to the need moving forward, the previous difficulties in keeping pace with delivery has resulted in a need to accommodate a significant number of dwellings in the short term with a deficit in five year supply.

2.6.3 Given the current development plan has seen documented difficulties in meeting the existing core strategy housing target, the need for new housing is compelling and indisputable and must be addressed by the new plan as a priority.

2.7 The cost of, and scope for, developing elsewhere

2.7.1 Tunbridge Wells is a constrained borough. There are a number of archaeological and heritage sites, including 45 Historic Parks and Gardens, 25 Conservation Areas and 11 Scheduled Ancient Monuments. In addition, there are approximately 3,000 Listed Buildings.

2.7.2 The landscape of the High Weald AONB contains numerous historic landscape features, including field patterns, settlements and ancient woodland, whilst the borough also hosts a number of, or is close to, areas of ecological importance. These include:

(1) Ancient Woodland (approximately 16% of the borough)

(2) Circa 60 Local Wildlife Sites (approximately 11% of the borough)

(3) Ten Sites of Special Scientific Interest (SSSI)

(4) Five Local Nature Reserves (including one Community Woodland)

(5) One Regionally Important Geological Site, at Scotney Castle Quarry.

2.7.3 The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA).

2.7.4 Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells borough.

2.7.5 Given the above constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy.

2.7.6 In respect of Cranbrook, the village is not located within the 22% of the borough that is Green Belt and where an ‘in principle’ objection to development applies. Furthermore, there are no non-AONB alternative sites available given the entire extent of Cranbrook (albeit not all of Sissinghurst) is washed over by the designation. Any growth that will provide a meaningful input of market and affordable homes is going to have a degree of adverse impact. The priority must therefore be prioritising the sites with the lesser impact. In this respect, sites AL/BM1 and AL/CRS 6 represent logical locations for sensitive growth on the edge of established built up areas.

2.8 Any detrimental effects and the extent to which that could be moderated

2.8.1 Opportunity exists to moderate the effects of development, including substantial areas of landscaping and associated ecological and heritage buffers and the opportunity to increase public access to the land.

In summary, we support the Council’s conclusions that exceptional circumstances exist to justify the allocation of sustainable AONB land at Hartley road, Hartley.

3 Section 6: Development Management Policies

3.1.1 In addition to our comments on the strategy, we have reviewed the proposed replacement development management policies as set out in chapter 6 of the document.

3.1.2 In general terms, we would refer back to paragraph 15 of the NPPF that promotes succinct and up-to-date plans, which provide a positive vision. In contrast, the draft policies currently proposed are of such prescriptive detail that they are neither positively prepared nor flexible enough to allow for a range of different circumstances. Furthermore, many aspirations result in inevitable conflict. On this basis, we would recommend that the majority of proposed policies are simplified and where additional guidance is needed, this be included within secondary Supplementary Planning Documents.

3.1.3 Turning to detailed policies, there are a number of contradictory elements that need to be remedied before the plan proceeds to Regulation 19. For example, policy EN1 seeks to ensure development is consistent with the established character and surrounding form. However, policy EN4 places significant emphasis on measures to radically reduce greenhouse gas emissions. The provision of a step change towards more sustainable construction and climate change is, inevitably going to result in a need for a change in attitude towards design, material and construction. Accordingly, a cohesive policy approach is needed that allows innovative and different design if supported on wider environmental and planning grounds. As drafted the policies are too inconsistent.

3.1.4 A number of policies also seek to provide guidance rather than policy. For example, policy EN6 seeks to clarify what information is needed in order to assess a heritage proposal. This level of information should instead feature within a support SPD not policy.

3.1.5 In respect of the natural environment, policy EN20 seeks to protect the rural landscape. It states that development will be required to:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.6 We support the principle of the policy but consider amendments are needed to ensure that it does not result in a blanket reason to refusal otherwise sustainable greenfield development. We suggest it be amended to read:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause Include appropriate mitigation to ensure against significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore Enhance landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.7 Turning to housing policies, we have significant concerns about the drafting of several policies, that show a degree of misunderstanding of the development industry. For example, policy H1 states:

‘Unless there are exceptional circumstances due to specific site or development constraints, a condition will be attached to any grant of planning permission for new major residential development (including change of use) requiring one or the other of the following conditions:

1. That the permission be implemented within two years from the date of decision; or

2. That groundworks and the construction of the ground floor base of at least two buildings be completed within three years of the permission’.

3.1.8 Whilst the majority of developers would aspire to be ‘on site’ and under construction within 2 years, the reality is that there are often processes that need to be adhered to that are outside of the applicant’s control, including the need to formally conclude land purchases, to discharge conditions and to deliver off site mitigation. There are also ‘non planning’ consents that need to be achieved for example Section 278 Highway works, infrastructure agreements (S38 of the Water Industry Act), ecology licensing etc

3.1.9 The Council will also be aware that commencement of development is often prohibited by seasonal restrictions in respect of ecology and wider constraints.

3.1.10 The second requirement for two buildings to be commenced is arbitrary, for example what is the test for single unit schemes or conversion works? The correct test should be as set out in statute i.e. ‘a material start’.

3.1.11 With the above in mind, we consider the Council’s policy should be deleted or modified to the extent that it will endeavour to agree a two year start date based on site circumstances.

3.1.12 In respect of policy H2, and the preference for Multi-developer schemes and comprehensive masterplanning, we understand the aspiration. However, in reality such stringent requests often result in conflict and further delay and the Council should be careful not to try and impose itself on wider commercial arrangements that may prohibit rather than assist delivery. With this in mind, it is our view that the Council should shift focus away from how it wishes to change development industry practices and instead concentrate on what it can influence, namely the provision of detailed guidance for the proposed site allocations (including potential phasing plans and areas zoned for different forms of development). The Council could also consider imposing a illustrative delivery trajectory as part of the validation process.

3.1.13 We note that policies H3 and H4 have regard to housing mix and density yet provide little or no detailed requirement. On the basis that mixes must reflect market requirements, we consider any aspirational densities would be better placed being inserted into the wider reaching policy EN1.

3.1.14 Policy H5 sets out affordable housing requirements. Whilst we support the general thrust of the objectives and the securing of affordable provision, we object to the rounding up of the calculations and contributions being based on a net rather than gross number of units. For small scale proposals this will often see the proposed percentage increase to closer to 45% and 35% respectively. Such thresholds would therefore need to be tested and justified by evidence. A pragmatic approach would be to apply traditional rounding up or down.

3.1.15 The phasing of affordable provision also needs to be sufficiently flexible so as to not prohibit wider delivery. In this regard, we consider that entering into contract with a registered affordable prior ahead of the 50% occupation should provide the certainty of delivery, but without risking a wider delay in market delivery.

3.1.16 We also object to the expectation of sites that provide between one and nine units to pay a contribution towards affordable housing. This conflicts with Paragraph: 023 Reference ID: 23b-023-20190901 of National Planning Practice Guidance, which states planning obligations for affordable housing should only be sought for residential developments that are major developments. Any reduced threshold should be restricted to designated areas only and should be underpinned by detailed evidence.

3.1.17 The Council will be aware of wider country wide discussions regarding the viability of providing social rented accommodation as part of a wider offer. Such provision is becoming increasingly difficult and without robust policy in place that addresses this matter, this matter is likely to significantly slow delivery.

3.1.18 We note that the Council is only willing to allow the use of Vacant Building Credits in exceptional circumstances. However, the test proposed appear significantly more onerous than have been considered and applied elsewhere. Based on the tests proposed, we fear that there will be a delay in genuinely vacant buildings, that are entitled to use of VBC, to be delayed in coming forward in order to meet the overly onerous criteria.

3.1.19 Finally, we note that paragraph 6.160 states:

“…The Council will assume a buffer of 25m from the edge of [ancient] woodland expecting through assessment for developers to confirm that this or any other distance is appropriate and that the priority for such buffers will be ecological mitigation and enhancement for the woodland rather than the amenity of the proposed development.”

3.1.20 The advice from the Government’s statutory advisor on biodiversity, Natural England, states that:

“For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone.” [1]

3.1.21 Whilst it is recognised that every case will need to be treated on its merits, the Council has provided no justification for imposing a new starting point of 25m, which is nearly double the standard minimum requirement set out by Natural England. This increased buffer zone does not appear to have been based on any evidence. It will simply reduce the quantum of development that can be achieved on many sites, which will in turn increases the risk that additional land is likely to be required elsewhere to meet development needs. We object to this proposed buffer, and request that the standard accepted minimum distance of 15m should be stated instead.

3.1.22 In summary, whilst this overview is not exhaustive, we do have concerns about the nature of the proposed policy framework and the degree to which it appears to be trying to limit and frustrate development. Accordingly, in the interests of positive planning, we recommend that the policy framework is simplified and refined and subject to further detailed consultation and focussed on planning matters.

4 Conclusion

4.1.1 This representation has been prepared on behalf of Fernham Homes, Pickhill Developments and The Glassenbury Estate in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation. The purpose being to provide comment on the Council’s proposed development strategy.

4.1.2 In this respect, we support the aspiration to meet housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Furthermore, we support the continued allocation of our clients’ land in Hartley.

4.1.3 The deliverability of this site is proven by the outline application submitted by Fernham Homes and the full application submitted by Pickhill Developments. Both developers are local builders with many years of experience of building throughout Kent using Kent based trades and local materials suppliers.

4.1.4 Nonetheless, specific amendments are needed to the proposed allocation policy in order to differentiate the eastern and western parcels and what development is proposed for each respective element of the land.

4.1.5 It is important that sites such as our clients land are retained within the Regulation 19 draft as we consider that the Local Plan strategy relies too heavily on the delivery of strategic sites that would require the provision of costly and significant supporting infrastructure. However, regarding our clients’ site at Hartley, the main elements of infrastructure relating to this site are already in place including ease of accessibility to the main A229 Hartley Road and main drainage runs through the site with an easy mains connection. Hence only minor infrastructure improvements would be required as set out in this response and detailed in our clients planning applications.

4.1.6 Moreover, the Council have overly optimistic projections to the delivery of housing for the extension of Paddock Wood and the Tudeley Garden Village which offer very limited flexibility.

4.1.7 I trust the contents of this representation are clear and I hope the comments are useful in guiding the forthcoming stage of the plan making process.

DLP_3300

Kent County Council (Growth, Environment and Transport)

Object

Transportation

The Local Highway Authority objects to this policy.

This should be split into two sites to the east and west of the A229. With regard to eastern site - an appeal dismissed regarding access to Hartley Road for NE portion, and KCC as Local Highway Authority raised objection to proposed access to south west section also from Hartley Road. Relocation of speed limit has not been supported by Kent Police. Local Highway Authority has had no involvement in western site to date.

Public Rights of Way and access Service

Public Bridleway WC127 is located along the southern boundary of this proposed development site, providing access to a wider network of Public Bridleways to the west. These paths offer excellent opportunities for recreational cycling and equestrian activity. Considering the proximity of the site to this access resource, it should be expected that the development will contribute towards off-site PRoW enhancements, in preparation for their expected increase in use.

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is potential for prehistoric and later remains, especially associated with medieval and post medieval activity. The site seems to include the site of a 16th century beacon, which it would be preferable to retain.

DLP_3443

Sally Marsh

Object

Major development is not appropriate in the AONB. TWBC have accepted that Gate Farm is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

This site reflects the predominantly rural and medieval character of the High Weald. It lies at a prominent high point (130m) with extensive views to the East towards the Greensand Ridge, and west towards Bedgebury, Flimwell and Combwell. The site consists of a complex of fields providing the setting for 4 historic farmsteads and lying at a prominent junction between an ancient droveway, an ancient ridge top road, and an ancient track (now a PROW) into Bedgebury Forest connecting with a known iron working site (SAM) at Furnace Farm. The site provides a rural and typically High Weald setting for the small hamlet of Hartley.

The northern part of the land to the East of Glassenbury Road is a known species rich grassland site. This habitat is one of the most rare and vulnerable habitats in the Weald and should be protected in order that it can form a core for nature recovery networks proposed in the Government’s 25-year environment plan and new Environment Bill. The rural environment and the remaining traditional farm buildings, albeit derelict, significantly increases the chance that protected species are present.

The agricultural land across a large part of the site is Grade 3a, the best and most versatile agricultural land. The majority of the High Weald is grade 3 and 4. Pockets of 3a like this site are vital if the aspirations of dealing with food security, growing food locally and adapting to climate change are to be delivered. The impact of permanently sealing grade 3a agricultural land with artificial surfaces and buildings cannot be mitigated within a reasonable time frame.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that ‘detracting elements’ and ‘poor management’ can be ‘addressed’ through development, and that the development will be ‘contained’. Why ‘containment’ is beneficial; why management is deemed to be ‘poor’ when the site is re-wildling naturally thereby contributing to biodiversity gain for free; and how permanently sealing the site with artificial surfaces can ‘address’ management is not explained.

Paragraph 102 of the NPPF, requires the environmental impacts of traffic and transport to be considered at the start. The impact of creating a number of new access points to each part of this allocation, which will essentially introduce a suburban character to a rural historic routeways appears not to have been considered.

The Neighbourhood Development Plan undertook a detailed assessment of this site using the recommended AECOM template. The main parts of the site to the North and East, and all areas not currently farm buildings or derelict farm buildings were assessed as unsuitable for development. TWBC have not explained why they have come to a different decision.

DLP_4122

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

This would be a major development within AONB (see DDTP, para 6.35) of 90 new homes. The three sites allocated under this polcy are partly greenfield and outside the LBD. There are no exceptional circumstances within NPPF 172 justifying the major development on these sites, which are prominent within the AONB landscape. They would constitute an extension to the existing settlement of Hartley, where there are limited shopping facilities (a farm shop, fishmonger and café). It is a long walk to Cranbrook town centre from the sites and, although the sites are on a bus route, it is likely that most daily trips from the sites would be made by car. We note that the policy has a mixed sustainability score. The sites are also close to Robin’s Wood SSSI and would lead to the loss of some best and most versatile farmland. CPRE Kent opposes major development on these sites.

DLP_3839

Natural England

Object

Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.

DLP_3576

Ian Bull Consultancy for Jarvis Strategic Land Ltd

Support with conditions

Jarvis Strategic Land Ltd support the proposed allocation at Bull Farm, Hartley. The site lies in a sustainable location and the proposed development of approximately 90 dwellings together with the provision of small scale employment units will contribute to the strategic housing requirement and enhance the viability and vitality of Hartley. Comprehensive master planning together with strategic landscaping and ecological mitigation and enhancement will deliver a positive benefit to the area. The site is well related to the strategic highway network with good access to local services, amenities and employment opportunities.

DLP_3905

Mrs June Bell

Object

Reasons for objection:

The scale of this development site in the AONB is inappropriate because:

I. Its own policy in the DLP STR 8 Conserving and Enhancing the Natural built and Historic environment, in particular point 5 relating to the AONB

II. The High Weald AONB Management Plan which has been adopted by all the Councils with land in the AONB as their policy for the management of the area and for the carrying out of their functions in relation to it.

III. The draft Parish Neighbourhood Plan development strategy is to focus on small scale sites and avoid large scale sites

IV. The site is reflects the predominantly rural and medieval character of the High Weald, provides the setting for four historic farmsteads and lies adjacent to the ancient routeway and approach to Cranbrook. NPPF para 172:’ Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. …….The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances and where it can be demonstrated that development is in the public interest.’

V. DEFRA Landscape review 2019 highlights the CPRE report (2017 CPRE & AONB ‘Landscapes for Life’ available at: https://landscapesforlife.org.uk/application/files/5315/5552/0923/Housing-in-AONBs-Report.pdf ) revealing that approvals for housing units within AONBs and within 500m beyond their boundaries have increased by 82% between 2012-2016, numbers of affordable units have gone down and the risk that paragraph 172 ‘exceptional circumstances’ is being used to argue for major development on the grounds that no other sites outside the AONB are available.

VI. The policy does not detail how requirement 1. ‘A masterplan approach to ensure a comprehensive scheme for the whole parcel is appropriately delivered’ will be enforced nor does it detail the requirement for collaboration with the local stakeholders, community and Parish Council.

DLP_4024

Brian Swann

Object

Ensure there is a masterplan

Provide some small industrial Units / business units

2 & 3 bedroom houses only

DLP_4679

Colin Johnstone

Object

I want to comment on one particular proposal, Gate Farm and Bull Farm on Glassenbury Road/Hartley Road.

I commute almost daily along this road and it is already extremely busy at many times of the day, especially morning and afternoon peak times.  It can take some time to pull out from Glassenbury Road and there are often some near misses when people get impatient.  To add the number of vehicles that would result from putting approx. 90 houses on this site is going to make this small area into a complete blackspot.  Glassenbury Road is a tricky road with almost blind corners and fast traffic, side roads and house/farm entrances, many on corners.  90 houses could mean up to 180 more vehicles using this junction and the road and it absolutely will become a dangerous route.

These two sites are both a long way from Cranbrook town centre and people will drive everywhere as it is too far to walk anywhere.  Entrances to both sites will be onto busy roads that already have their own problems. These sites, but particularly Bull Farm and the larger number of houses proposed, are going to have a serious and bad impact on the immediate area.

DLP_6126

Cranbrook & Sissinghurst Parish Council

Object

Major development sites allocated in the AONB ignoring Tunbridge Wells own policy set out in the draft Local Plan, its AONB Management Plan and the draft Parish Neighbourhood Plan to focus development on small-scale sites.

DLP_6135

Cranbrook & Sissinghurst Parish Council

Object

In the AONB, the area concerned can be seen as far as Flimwell as it is on a 125m ridge.

The deeds have a “blue line” round them to prevent the farm being sold off in small lots. It has to be kept as one complete unit. So how can these two areas of Bull Farm be separated off?

DLP_6138

Cranbrook & Sissinghurst Parish Council

Object

Objection based on objectives S1, S2 and S3 of the High Weald AONB Management Plan because it would be detrimental to the setting of Hartley Gate Farmhouse and other listed farmsteads around the site by removing the openness and rural character and settlement pattern of Hatley as a cluster of farmsteads surrounded by their historic landholdings, replacing this character with one of suburban development

Conflicts with Policy EN12 Protection of Designated Sites & Habitats.

Conflict with Policy EN20 Harm to historic landscape farmsteads and hamlets.

DLP_7319

Mr Richard Gill

Object

I object to the allocation of land for housing at Gate Farm / Bull Farm. This site is detached from the LBD and is a major development of 90 dwellings within the AONB.  It is inappropriate and does not meet the sequential tests of NPPF Paragraph 172 where great weight should be given to conserving the landscape and scenic beauty. It would cause substantial harm to the many historical and architectural assets and the landscape.  The severe constraints are detailed in the High Weald AONB Unit’s site assessment in their response to the Draft Local Plan.  There are highway safety access considerations with the Glassenbury Road/A229/Swattenden Lane junctions.  It is not a sustainable site and it promotes more car use (2 parking spaces per dwelling).  It will contribute further to traffic congestion and pollution.  In the SHELAA it scored very negatively in travel and land use.

DLP_7232

Elizabeth Daley

Object

This proposed allocation sits in a prominent place in the AONB and can be seen for miles. It should therefore never be considered for development.

The allocation also stands well outside the LBD.

DLP_7046

Philippa Gill

Object

I object to the allocation of land for housing at Gate Farm / Bull Farm. This site is detached from the LBD and is a major development of 90 dwellings within the AONB.  It is inappropriate and does not meet the sequential tests of NPPF Paragraph 172 where great weight should be given to conserving the landscape and scenic beauty. It would cause substantial harm to the many historical and architectural assets and the landscape.  The severe constraints are detailed in the High Weald AONB Unit’s site assessment in their response to the Draft Local Plan.  There are highway safety access considerations with the Glassenbury Road/A229/Swattenden Lane junctions.  It is not a sustainable site and it promotes more car use (2 parking spaces per dwelling).  It will contribute further to traffic congestion and pollution.  In the SHELAA it scored very negatively in travel and land use.

DLP_7268

Mr Andrew Fleming

Object

Objection to proposed site AL/CRS 6 Map 49 Land at Gate Farm adjacent to Hartley Road and Glassenbury Rd. Hartley.

As a neighbour surrounded by this site I would like to put my objection on record.

In a recent speech the Prime Minister spoke about the need for new housing and said that this housing should be developed on brownfield sites. This site is so far from being a brownfield site as any site could be. It lies at one of the highest points in the Weald and is in the AONB, and well out of the Limits to Build Development,

I would refer you to a recent objection on part of the site:

“In summary, the High Weald AONB Unit strongly objects to the proposed development on the grounds that it will conflict with objectives S1, S2 and S3 of the High Weald AONB Management Plan and cause significant harm to the AONB in the following ways:

It would be detrimental to the setting of Hartley Gate Farmhouse and other listed farmsteads around the site by removing the openness and rural character of their surrounding historic landholdings; It is contrary to the historic character and settlement pattern of Hartley as acluster of farmsteads surrounded by their historic landholdings, replacing this character with one of suburban development; and alone and in combination with other developments it will reduce the separation between Cranbrook and Hartley resulting in the loss of identity of Hartley as a distinct settlement of a different character to Cranbrook.

Given the above impacts on the AONB it is considered that the proposal will have a significant adverse impact on the purposes for which the area has been designated and therefore should be treated as major development under paragraph 172 of the NPPF.

Legal and Policy Background

It is the responsibility of the Local Planning Authority to decide whether the application meets legislative and policy requirements in respect of AONBs. Section 85 of the Countryside and Rights of Way Act 2000 requires local authorities to have regard to ‘the purpose of conserving and enhancing the natural beauty of AONBs’ in making decisions that affect the designated area. The National Planning Policy Framework paragraph 172 requires great weight to be given to conserving and enhancing landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty. The conservation of wildlife and cultural heritage are important considerations in all these areas. The scale and extent of development within these designated areas should be limited. In the event that the decision-maker concludes that development is ‘major’ in terms of its impact on the AONB, paragraph 172 of the NPPF states that planning permission should be refused for major developments in these designated areas except in exceptional circumstances.”

A Bit of History of the site:

The Bull Farm part of the site was first subdivided in the 1980’s and split into 3 units. Bull Farm House, a grade 2 listed building, Bull Farm Oast for conversion into a dwelling with provision the vehicular entrance off Glassenbury Road being closed, and Bull Farm Barn, also Grade 2 listed including 113.acres of land. Some of the detached portions of Bull Farm were subsequently sold off.

The owner of Bull Farm who was living in the converted Bull Farm Barn, applied in the early 1990’s to build a Farm Workers cottage on Bull Farm, for which planning was granted. He then somehow persuaded TWBC to let him subdivide off the Barn and a field, which he then sold , and moved to the new cottage, This is the only house on what is now known as Bull Farm. We were assured at the time of the subdivision that no further subdivision would be allowed on Bull Farm! It lies to the west of Glassenbury Road. Site 59 was not in the sale and was retained by the current owners as they hoped it might be developed and have allowed the farm buildings to fall into ruins. At one point a new temporary building was constructed and used and then demolished prior to the 2017 application.

The proposed site is divided into two sections on either side of Glassenbury Road, a 50mph road of varying width without any pedestrian sidewalks. There is also an underground water feed supply into the large Glassenbury water reservoirs crossing both sites bringing water from Bewl Water dam into the Glassenbury storage reservoirs which feed a wide area, even as far as Ashford.

Whilst the plan suggests the use of part of Bull Farm as B1/B2/B8 employment units, and presumably reusing the existing farm buildings, these are immediately adjacent to two listed buildings, Bull Farm House and Bull Farm Barn, and would be seriously be detrimental to the character of those properties. Also access to these farm buildings would cross through the site between the small bottleneck access point dividing the north and south sections to make use of the two entrances onto Glassenbury Road from the North section.

Parts of the site have been considered for development in the past.

Gate Farm applied in the early 1990’s to be an light industry site and this was refused.

On the 14 February 2018 the following refusal recommendation :

REPORT SUMMARY

REFERENCE NO - 17/00795/FULL

APPLICATION PROPOSAL

Demolition of four derelict agricultural buildings and construction of four detached dwellings with associated parking, landscaping and access from Hartley Road

ADDRESS Agricultural Buildings Hartley Road Cranbrook Kent

RECOMMENDATION — Refuse (See Section 11 for the full recommendation)

SUMMARY OF REASONS FOR REFUSAL

- In the absence of a 5 year housing land supply the housing provision policies are considered to be out-of-date. Paragraph 14 of the National Planning Policy Framework (NPPF) requires that permission for sustainable development be granted unless “specific policies in this Framework indicate that development should be resisted". The footnote to para 14 includes those policies related to the Area of Outstanding Natural Beauty (AONB).

- The proposal is not considered to be sustainable development, and is considered to be harmful to the AONB.

- There are objections in highway safety terms to matters arising from the intensified use of the access onto a primary route

- The application is recommended for refusal on four grounds:

- 1. The proposal is not considered to be sustainable development and, due to the harm it would cause to the AONB the NPPF indicates that development should be restricted.

- 2. The proposal would intensify the use of an access onto a primary route with insufficient visibility, spacing between junctions and pedestrian footway provision.

Proposal fails to demonstrate the provision of a safe and suitable access.

- 3. Insufficient information has been provided to demonstrate that the proposal would not be harmful to protected species.

- 4. Insufficient information has been provided to demonstrate that the proposal would not be harmful to important trees.

- All other material considerations have been taken in to account and are not considered to outweigh the identified harm that the proposal would cause.

Site 70 section of the large site has also had an application refused under appeal:

Appeal Decision Hearing Held on 30 May 2019

Site visit made on 30 May 2019 by L Perkins BSc (Hons) DipTP MRTPI

an Inspector appointed by the Secretary of State

Decision date: 5 July 2019

Appeal Ref: APP/M2270/W/18/3203543

Land adjacent to Hartley Gate Farmhouse, Hartley Road, Cranbrook, Kent

* The appeal is made under section 78 of the Town and Country Planning Act 1990 against a refusal to grant planning permission.

* The appeal is made by Pickhill Developments Ltd against the decision of Tunbridge Wells Borough Council.

* The application Ref 17/03481/FULL, dated 18 October 2017, was refused by notice dated 19 Dec 2017.

* The development proposed is the erection of 8 no. dwellings with access, parking,landscaping and  replacement of TPO tree T2.

Decision

1. The appeal is dismissed.

Preliminary Matters

2. At the hearing it was agreed that the site address and description of development is as stated on the Council’s decision notice rather than as stated

on the application form and so I have reflected this in the heading above.

3. Since the appeal was lodged the National Planning Policy Framework (the Framework) has been revised. I have taken comments made on relevant

implications for the appeal into account in my reasoning.

4. In the statement of common ground more policies are referred to by each of the main parties than are referred to in the reason for refusal on the Council’s decision notice. The main parties agreed at the hearing that it is the policy in the latter which is most relevant to the main issue in dispute in this case.

Main Issue

5. The main issue is the effect of the proposed vehicular access on highway safety.

Reasons

6. The appeal site adjoins Hartley Road. This is part of the A229 which is a primary distributor route linking the A21 to the south and the M20 and M2 to

the north. Adjoining the appeal site the road has a 40mph speed limit. A footway exists on the opposite side of the road. Public views of the site are

restricted by planting along the site frontage. The appeal site is in a semi-rural location and the surrounding area is characterised by open agricultural land
and some residential development.

7. Policy TP4 of the Tunbridge Wells Local Plan 2006 (‘the Local Plan’) permits access to the road network subject to the satisfaction of specific criteria.

Criterion 2 is that a safely located access with adequate visibility exists or could be created. Criterion 4 is that, outside the Limits to Build Development (LBD), the development would not involve the provision of an additional access or the intensification of use of an existing access directly onto a Primary or Secondary route. The appeal site is outside the LBD.

8. Paragraphs 108-109 of the Framework states that development should be prevented on highway grounds if there would be an unacceptable impact on highway safety. In that respect criterion 2 of Policy TP4 is consistent with the Framework. However, at the hearing the main parties agreed Policy TP4 is partly consistent with the Framework as criterion 4 is based on a structure plan which is no longer in place and continued application of this criterion may frustrate housing supply. Consequently, the Council advised each new access is assessed on its merits and I have no reason to disagree with this approach.

9. There has been disagreement between the main parties over which guidance should be used to calculate the visibility splays required for the proposed vehicular access to the appeal site i.e. whether the Design Manual for Roads and Bridges should be used or the Manual for Streets 2 (MfS2). During the appeal process the Council conceded that MfS2 may be used in this case, subject to an assessment of local context. But the Council consider any reduction in splay length from this guidance would create hazards on the highway. At the hearing the main parties agreed the north splay would comply with MfS2 and so the dispute between the main parties therefore concerns the south splay.

10. MfS2 provides guidance on the calculation of visibility splays and Site Stopping Distances (SSD). These are the distances drivers need to be able to see ahead and stop within from a given speed, calculated from the speed of the vehicle, the time required for a driver to identify a hazard and then begin to brake and the vehicle’s rate of deceleration. For existing roads the 85th percentile wet-weather speed is used. Driver perception-reaction times of 1.5 seconds are recommended where the design speed is 60kph (37.3mph) and below and 2.0 seconds where it is above 60kph.

11. At the hearing the Council explained that, rather than use the appropriate deceleration rate specified in Table 10.1 of MfS2, the appellant’s case had used a different figure to achieve a shorter splay which is contrary to MfS2. The appellant’s case draws on a discussion of deceleration rates for heavy goods vehicles (HGVs) established from ROSPA1 tests in 2001 set out in MfS2.

However, those tests related to HGVs stopping from a speed of 30mph which is not the same as the speeds recorded at the appeal site.

1 Royal Society for the Prevention of Accidents

12. Moreover, paragraph 10.1.2 of MfS2 provides guidance on SSD where the 85th percentile speeds are up to 60kph (37.3mph). This is not the same as the situation at the appeal site. Therefore deceleration rates have been employed which deviate from those specified in MfS2 where vehicles are travelling in excess of 60kph. At the hearing the Council also alleged the 85th percentile speed used is not just for light vehicles but includes slower heavier vehicles,
which lowers the 85th percentile speed. The appellant advised this was an accurate summary to achieve the splay length to the kerb edge sought by the
highway authority.

13. Based on MfS2 the southern splay should be 86.73m but as proposed is some 77m. Whilst the appellant seeks flexibility in the application of MfS2 the Council considers the south splay should be maximised due to the local context in this case. At the hearing the appellant referred to MfS2 where it advises that a reduction in visibility below recommended levels will not necessarily lead to significant problems unless there is local evidence to the contrary.

14. The appeal evidence includes local crash data2 which shows there have been 8 recorded crashes within a 500m radius of the proposed access over the last 5 years. Crash 1 from this data shows a crash caused by a vehicle pulling out on to Hartley Road from a side road close to the appeal site. Crash 2 indicates a crash caused by a similar manoeuvre from a different side road. At the hearing the appellant stated that this data is limited and/or indicates driver error or other environmental conditions as causes which is not evidence of design or layout issues relating to the road.

2 Dated 4 April 2019 reporting crashes between 1 October 2013 and 30 September 2018

15. The Council’s view is that the crash data highlights difficulties drivers experience judging the speed of traffic on this stretch of road. At my site visit I viewed northbound traffic approaching the proposed access to the appeal site from a point (agreed between the main parties) where the driver of a car would be likely to be positioned whilst waiting to exit the appeal site. From this location, crouching down and looking toward oncoming traffic from the south, I saw that the nearby brow of the hill, a bend in the road and vegetation growing on the roadside, all within the length of the splay for the proposed access, combined to significantly compromise visibility for drivers approaching the proposed access/waiting to exit the appeal site. Considering the above points, including the crash data, I am not satisfied the proposed access would be safe.

16. The appellant considers an allowance should be made for the south visibility splay to be offset from the kerb line into the carriageway. This is on the basis that vehicles do not travel close to the kerb line due to the presence of drain covers and debris at the roadside that may pose a hazard to cyclists and motorcyclists in particular. If a 1m offset is applied to the south visibility splay the evidence indicates a splay length of 89m could be achieved which exceeds the length sought by MfS2. If an 800mm offset is applied the splay would comply with the length sought by MfS2.

17. Paragraph 10.5.3 of MfS2 acknowledges that vehicles will normally be travelling at a distance from the kerb but the evidence does not contain an objective standard to indicate what offset distance may reasonably be applied.

Whilst I saw drain covers during my site visit at the roadside adjacent to the appeal site, these were considerably narrower than the offsets suggested above by the appellant and the road appeared well maintained with little or no roadside debris. An offset of 1m or 800mm is not therefore justified meaning the splay length sought by the Council, based on MfS2, cannot be achieved.

18. The road outside the appeal site is relatively narrow and, as I saw on my visit, it is used by large lorries. I therefore consider it likely that road users, including cyclists and motorcyclists, would travel close to the kerb to maintain a safe distance from oncoming traffic on the opposite side of the road and in the case of cyclists and motorcyclists, traffic trying to overtake. The appellant has drawn my attention to a development at The Pines, Smallhythe Road, Tenterden, where an offset of 1m was accepted by the highway authority. However, that case concerned a nearside splay and not an offside splay as in this appeal case. I therefore do not find that case directly comparable to the appeal scheme and so I am not satisfied it means I should accept a 1m offset in this case.

19. The appellant considers Hartley Road in the vicinity of the appeal site (from the junction with Swattenden Lane northwards) provides a number of urban signals to drivers which induce drivers to anticipate potential hazards and modify their speed. The appellant identifies these signals as including road side turnings, footways, street lighting, bus stops, commercial signage and frontage development.

20. At my site visit, when travelling northbound from the junction with Swattenden Lane toward the proposed access, I found signals to drivers to be limited. In particular there was no street lighting or bus stops and the road on both sides was lined with thick planting, a situation which would not significantly change with the appeal development in place as it would be concealed behind frontage planting. I do not therefore consider there are conspicuous signals to drivers in this location which induce drivers to modify their speed and, in any event, the evidence indicates recorded speeds in this location exceed the 40mph speed limit in both directions which does not support the notion that drivers modify their speed in this location.

21. In reaching these conclusions, I appreciate that braking technology may have improved since the guidance on visibility splays was published but I have no information which enables me to quantify this effect and the guidance remains unchanged and current.

22. My attention has also been drawn to Highway Code stopping distances and various appeal decisions in support of the appellant’s case. But Highway Code stopping distances do not apply as they relate to emergencies and the appeal decisions were based on the specific local circumstances of those cases and so I cannot be certain they are directly applicable to the appeal scheme before me.

23. Overall, I conclude on this main issue that the proposed vehicular access would have a harmful effect on highway safety significantly increasing the risk of collisions in the area and therefore endangering life, I attach significant weight to this harm.

Consequently, the scheme would not comply with Policy TP4 of the Local Plan noted above or the relevant provisions of the Framework in this regard, set out above, which seek to ensure new development is served by a safe access.

Planning Balance

24. The Council cannot demonstrate a 5 year housing land supply. As such, paragraph 11 (d) of the Framework is engaged. Accordingly, permission should be granted unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits when assessed against the policies in the Framework taken as a whole.

25. I accept that the appeal scheme would provide benefits. These include the provision of a mix of new housing units in an area where there is no 5 year housing land supply, employment created during the construction of the development and local spending by future occupiers at local shops and services.

26. I also acknowledge that the Council’s decision does not indicate harm would occur to the character and appearance of the area (including the High Weald Area of Outstanding Natural Beauty) but this is a neutral point rather than a benefit of the scheme.

27. Thus even if I were to conclude there is a shortfall in the five year housing land supply on the scale suggested by the appellant, the significant weight I attach to the adverse impacts on highway safety would significantly and demonstrably outweigh the benefits.

Conclusion

28. For the reasons given above I conclude that the appeal should be dismissed.

L Perkins

INSPECTOR

Current Application

There is a current application for a major development of 27 houses on area 59 of the site which, due to the strength of the objections. We hope will be refused.

General Comments.

1. Cranbrook has a number of applications in progress that include the Brick Kiln sites for up to 250 homes, Turnden that has had phase 1 of 36 homes on part of the 68 acre site approved. This site has the potential for a large number of additional homes in future phases.

Both these sites have extremely good access to Cranbrook. The plan has also identified a further number of sites within the Cranbrook Limits to Build Development area. With all these sites it is not necessary to move furtherinto the AONB.

2. This site has extremely poor pedestrian access into the town and the infrequent bus service that is always threatened by a further reduction of service and is inadequate. Cycling in this area is unsafe.

3. There are virtually no additional employment opportunities in the local area meaning new residents would all commute to distant workplaces. This would mean that every home would require at least two cars putting additional pressure on a very hazardous set of roads and intersections.

We are 8 miles from the nearest rail service.

4.Royal Tunbridge Wells that has all the infrastructure, good bus services, a regular train service into London, and is planning for three new schools and a new business park and is, by population, being asked for a much smaller number of new homes. Please reassess this area. I am sure there are sites around the town that, given the opportunity, would only be to pleased to put themselves forward for the windfall the sale of these sites to developers would produce.

Put the housing where it is needed, not in an AONB.

5.If this site gets entrances onto Glassenbury Road, can I reopen my entrance onto it? Some of my neighbors who love to get permission to have new entrances onto the A229!

Number of Houses Needed

I wrote a letter to him with this regard and he got our local MP, Helen Grant to respond and set out the following comment from her reply:

"Planning decisions are managed at a local authority level and are dealt with by local councils drawing up a Local Plan. At a lower level, Parish Councils or local representatives can also draw up a Neighbourhood Plan. Both of these help to give control to local authorities allowing them to decide where houses are placed and in what numbers. The targets for the overall borough are not set by the Government although it is commonly thought they are, instead they are independently assessed based on population growth statistics."

I emailed TBWC and the reply to my questions about the population and number of dwellings was:

1) Total Population of the Borough: Estimated projection of 117,700 in 2017 (HNS, 2018)/2011 census data states total population as of 2011 to be 115,049. I've obtained further census 2011 data which breaks this down further by age (see table below):

0-24: 34,734
25-29: 6,809
30-34: 6,974
35-39: 8.113
40-44: 9,191
45-49: 9,071
50-54: 7,652
55-59: 6,401
60-64: 7,029
65-69: 5,487
70-74: 4,157
75-79: 3,545
80-84: 2,948
85+: 2,938

2. Total Number of Houses/Dwellings in the Borough, and 3. Number of Empty Houses in the Borough:

The HNS (2018) states that, based on 2016 Council Tax records, there are 49,442 households and 48,559 occupied dwellings in the borough (as of 2016), with 339 second homes and 731 vacant homes.

There is therefore an implied vacancy rate of 1.5%, compared with a vacancy rate of 2.6% across England (see page 34 for reference).

4. Population of Cranbrook: From 2011 census data and as written in the DLP, the population of Cranbrook and Sissinghurst is approximately 6,700.

5. Number of Houses/Dwellings in Cranbrook: From the HNS (2018) based on 2016 Council Tax records, there are 2,764 total dwellings in Cranbrook and Sissinghurst, with 2,814 total households (see page 35 for reference).

-----------------------------------------------------

From these figures I did my own calculations on the number of houses needed. As they had the 2011 census figures and a 2017 projection I used both their projected historical growth and the latest national population growth of 0.6% . I worked out an average number of persons per dwelling,then divided the projected population by this figure and came up with the following extra homes needed in a 5 and 15 year plan.

2025

2035

Cranbrook and Sissinghurst using National growth

253

439

Cranbrook and Sissinghurst using historic growth

162

276

 

2025

2035

Whole borough using National growth

3235

6428

Whole Borough using historic growth

1692

3639

The council has allowed a huge number of new homes to be built in the borough in the last few years which I am sure many have been filled from migration into the borough which will distort the figures.

I was given today a figure of 2879 homes in Cranbrook at the latest count which falls between my two projections (2860 to 2911). Few of these new dwellings are truly affordable homes.

My main interest is in my local area where we have two ANOB sites Brick Kiln (up to 250) and Turnden (rumoured to have 200+ in the pipeline). Neither of these ANOB sites should have been allowed in the first place and efforts should be made to reduce there impact on the ANOB by decreasing the number permitted to a minimum.No further ingression into the ANOB should be allowed

Local roads are at more than maximum capacity, increasing the pollution levels. As transport needs have hot been addressed in the east part of the borough. The huge number of homes proposed and the main area of new employment being in Tunbridge Wells area, which from this area can only be accessed by car through the narrow roads through villages like Sissinghurst and Goudhurst and up the over busy A21 will increase the accident levels.

Why,in the draft plan, is the borough trying to more than double the number of homes needed for natural growth. Is this finance driven, totally disregarding the need to preserve the ANOB?

The call for sites can be likened to bees being attracted to a honey-pot. Land owners are only too happy to have their land allocated for housing or business, increasing the land values exponentially. There is one large brownfield site - the Calor Gas site. This should be used with a possible field/s to the south.

DLP_5742

Anna Connett

Object

I understand the deadline to object to the above proposal is today at 5pm.  I just wanted to register my objection to the plan to build approx. 90 houses which could potentially mean up to 180 more cars using that junction and Glassenbury Road (on top of the other potential 800 or more houses proposed in and around Cranbrook), which is already difficult at peak times.

DLP_5746

Martin and Jane Lewis

Object

As residents of Cranbrook we feel very strongly about the proposed developments in the local area - especially the proposed development and Gate Farm/Bull Farm and the one at Turnden Farm.

We live on a small cul de sac off the A229 on the borders of Hartley and Cranbrook and therefore will feel the impact of both developments due to the increased amount of traffic that will no doubt arise of so many houses being built.  Today, it is fair to say, most families have two cars, some have more.  The A229 has become noticeably busier over the past couple of years and for residents living off the A229 and wanting to head towards either Cranbrook or Hawkhurst, with the increased amount of traffic, this is going to get harder and harder to do.

We moved to this part of Kent to escape the built up areas of Tunbridge Wells and now it looks as if Cranbrook/Hartley are going to become just as built up. In addition with the developments in Sissinghurst etc, the area is going to become one big residential area.

Cranbrook and the surrounding area falls within an Area of Outstanding Natural Beauty, with its green fields, forests and feeling of space, this is going to disappear. - it is going to become a concrete mass

The area doesn't have the infrastructure as far as transport is concerned to cope with additional housing nor does it have the schools or doctors surgeries to support the increased population.

Surely the Council must consider that the proposal at Gate Farm/Bull Farm is not a sustainable development and the adverse impact of the development to the local residents would significantly outweigh the benefits. Future residents would be reliant on the use of private cars for the majority of trips - e.g. shopping, which would have a huge impact on carbon omissions, something that we believe is included within the National Planning Policy Framework. 

The proposal of approx. 90 dwellings in this sensitive location will have a huge adverse affect on the rural landscape,especially as it falls within an AONB and therefore would cause significant harm to the charm and character of the countryside.  As well as having a detrimental impact on our flora and fauna, topics that are constantly mentioned, especially as so many species are disappearing from our hedgerows and gardens.  We have to protect our countryside for future generations.

Please listen to the local residents as this development will have a huge impact on our lives.

DLP_6047

Laura Rowland

Object

Major development is not appropriate in the AONB. TWBC have accepted that Gate Farm is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

This site reflects the predominantly rural and medieval character of the High Weald. It lies at a prominent high point (130m) with extensive views to the East towards the Greensand Ridge, and west towards Bedgebury, Flimwell and Combwell. The site consists of a complex of fields providing the setting for 4 historic farmsteads and lying at a prominent junction between an ancient droveway, an ancient ridge top road, and an ancient track (now a PROW) into Bedgebury Forest connecting with a known iron working site (SAM) at Furnace Farm. The site provides a rural and typically High Weald setting for the small hamlet of Hartley.

The northern part of the land to the East of Glassenbury Road is a known species rich grassland site. This habitat is one of the most rare and vulnerable habitats in the Weald and should be protected in order that it can form a core for nature recovery networks proposed in the Government’s 25-year environment plan and new Environment Bill. The rural environment and the remaining traditional farm buildings, albeit derelict, significantly increases the chance that protected species are present.

The agricultural land across a large part of the site is Grade 3a, the best and most versatile agricultural land. The majority of the High Weald is grade 3 and 4. Pockets of 3a like this site are vital if the aspirations of dealing with food security, growing food locally and adapting to climate change are to be delivered. The impact of permanently sealing grade 3a agricultural land with artificial surfaces and buildings cannot be mitigated within a reasonable time frame.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that ‘detracting elements’ and ‘poor management’ can be ‘addressed’ through development, and that the development will be ‘contained’. Why ‘containment’ is beneficial; why management is deemed to be ‘poor’ when the site is re-wildling naturally thereby contributing to biodiversity gain for free; and how permanently sealing the site with artificial surfaces can ‘address’ management is not explained.

Paragraph 102 of the NPPF, requires the environmental impacts of traffic and transport to be considered at the start. The impact of creating a number of new access points to each part of this allocation, which will essentially introduce a suburban character to a rural historic routeways appears not to have been considered.

The Neighbourhood Development Plan undertook a detailed assessment of this site using the recommended AECOM template. The main parts of the site to the North and East, and all areas not currently farm buildings or derelict farm buildings were assessed as unsuitable for development. TWBC have not explained why they have come to a different decision.

DLP_6151

Turley for Taylor Wimpey UK Ltd

 

This policy seeks to allocate a comparatively significant level of growth to a small hamlet/village with little or no facilities to the west of Cranbrook; an area characterised at present by linear and ribbon development along the A229. It lacks any notable facilities and would accordingly rely on Cranbrook to the east. As set out in i-transport’s assessment of this site (Document B), this option performs far worse than SHELAA Site 25 on its ability to reduce the need to travel by car for most trips. The village is without a settlement boundary and is therefore an area we suggest would normally only be appropriate for infill development. Not an option we consider sequentially preferable to Site 25, which forms part of the existing urban area of Cranbrook, is closer to its core and by foot; and is better suited and contained to accommodate development.

As independent landscape consultants CSa conclude (Document C), the development of Site CRS6 would introduce a substantial area of nucleated built form, at the western edge of Hartley village which is currently characterised by linear and ribbon development along the A229. Development here would adversely affect the character of the local landscape and the rural setting of the two adjacent listed farmhouses. Development of the north western field in particular would be prominent at the top of the hillside and is likely to be highly visible in views from the rural landscape to the west. As set out in comments to Policy STR/CRS1, we respectfully recommend SHELAA Site 25 be re-assessed in this context, as we contend this site merits allocation as a suitable, logical and sustainable site for around 70 homes, either in addition to CRS4, CRS6 and CRS7, or in place of one of these. All of which we contend score less favourably against the Council’s SA objectives than site 25.

DLP_6143

David Hall

Object

I strongly object to the potential development of land at Gate Farm and Bull Farm. This would be damaging to a small and historic community within an AONB. Access in and out of these developments would perilous on what is a highly dangerous double road junction.

In addition the increased traffic on surrounding roads from thease and other developments would further increase the amount of danger and also POLLUTION.

DLP_6499
DLP_6515
DLP_6545
DLP_6653
DLP_6711
DLP_6733
DLP_7680

Clare Govan
Philip Govan
Rory Govan
Stephanie Govan
Edward Govan
James Govan
Joe Hughes

Object

The following comment was submitted by the list of responders on the left:

Policy Number:  AL/CRS 6 Gate Farm, adjacent to Hartley Road and Glassenbury Road, Hartley (plus Bull Farm)

I object to the allocation of this site as appropriate for major development.

The site is adjacent or very near to five listed buildings and an oasthouse which together with the rural environment are fundamental to the area’s characteristics as an AONB. These heritage assets and the surrounding rural environment are complementary to each other.  The site’s location at the junction of Glassenbury Road with Hartley Road is such that its rural nature determines the character of the AONB in this area.  Any development would cause Hartley to become semi-urban and inconsistent with its history.  The listed buildings and other heritage assets would look incongruous if the historic landscape with which they are associated is covered in dwellings.

No attempt has been made to demonstrate that there are exceptional circumstances, taking account of the following factors which are required to be assessed under in accordance with para 172 of the NPPF

  • development of this size is not needed for growth of the local community
  • it would have an adverse impact on Cranbrook and Hartley as a tourist attraction
  • there are better opportunities for developing outside the AONB
  • it would have a detrimental effect on the landscape and recreational opportunities, with no realistic scope for this to be moderated

Development of this site would be contrary to Policy EN 21: “All development within, or affecting the setting of, the High Weald AONB shall seek to conserve and enhance its landscape and scenic beauty, having particular regard to the impacts on its character components, as set out in the High Weald AONB Management Plan.”  It cannot seriously be considered that any development on this very prominent site at a key location could be such as would seek to conserve and enhance the AONB’s landscape and scenic beauty. 

The agreed policy in the AONB Management Plan seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.  In no way could this development be seen to meet that objective.

It will not be possible to provide anything near the “approximately 90 dwellings” declared to be provided by this site, taking account of the specified requirements relating to vehicular access, protection of hedgerows and mature trees, and TWBC Farmstead Assessment Guidance SPD which mandates a character-based approach to change around traditional farmstead groups and their buildings.

The site reflects the predominantly rural and medieval character of the High Weald. It lies at a prominent high point with extensive views to the East towards the Greensand Ridge, and west towards Bedgebury, Flimwell and Combwell. The site consists of a complex of fields providing the setting for four historic farmsteads and lying at a prominent junction between an ancient droveway, an ancient ridge top road, and an ancient track (now a public right of way) into Bedgebury Forest connecting with a known iron working site at Furnace Farm. The site provides a rural and typically High Weald setting for the small hamlet of Hartley.  It is very visible from the road and, together with the surrounding heritage assets, effectively determines the rural nature of the area.

The northern part of the land to the East of Glassenbury Road is a known species rich grassland site. This habitat is one of the most rare and vulnerable habitats in the Weald and should be protected in order that it can form a core for nature recovery networks proposed in the Government’s 25-year environment plan and new Environment Bill. The rural environment and the remaining traditional farm buildings, albeit derelict, significantly increases the chance that protected species are present.

The agricultural land across a large part of the site is Grade 3a, amongst the best and most versatile qualities of agricultural land. The majority of the High Weald is grade 3 and 4.  Pockets of 3a like this site are vital if the aspirations of dealing with food security, growing food locally and adapting to climate change are to be delivered. The impact of permanently sealing grade 3a agricultural land with artificial surfaces and buildings cannot realistically be mitigated.

Any development of this site would cause devastating and irreversible damage to the landscape and scenic beauty for which the local community and future generations will not forgive those responsible.

The permanent grassland on this site plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. How does the Local Plan ensure that this commitment is met?  The case for major development at Gate Farm has not been made.

The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3.  Without any supporting evidence these conclusions glibly suggest that “detracting elements and poor landscape management’ can be “addressed through development”, and that “Existing site context and careful design can result in a discrete well contained development.”  The reality is that Gate Farm has been used effectively for many years to graze sheep.  It is obvious that the recent cessation of this activity was purely to enhance the development prospects.  Also the derelict farm buildings have been deliberately run down so as to become an eyesore with the same objective.  They should be restored or demolished and the site put back to agricultural use as befits its Grade 3a status.  The site is now re-wildling naturally thereby contributing to biodiversity gain.  But in any case permanently sealing the site with artificial surfaces cannot be said to address any “detracting elements and poor landscape management” alleged in the Topic Paper.

Transport issues are required by para 102 of the NPPF to be considered from the earliest stages.  The following have not been addressed:

  • The impact of creating new access to this site, which will essentially introduce a suburban character to a rural historic routeway, will have an adverse environmental impact
  • The A262 via Goudhurst is the route used by the entire Parish to travel to work or to shop in Royal Tunbridge Wells. Support services, including HGVs, also use this route, notwithstanding the warning sign “unsuitable for long vehicles”. The A262 through Goudhurst is narrow and the corner by St Mary’s Church is notorious for problems when large vehicles travelling in opposite directions meet there.  There is no scope to widen the road. This regularly causes extended hold-ups and there has been damage to buildings and to the churchyard wall.  There is no obvious alternative route and the additional traffic generated by the development would be detrimental to the character of the historic village of Goudhurst, with consequent impact on its economy.

DLP_6562

Diana Badcock

Support with conditions

In principle this area could be suitable for development, but the scale is too large. It is outside and detached from the LBD and within the AONB. Such a large scale proposal is Inappropriate and appears to contradict 4.40 where the Development strategy states ‘sustainable development of an appropriate scale at the smaller settlements’

DLP_7370

Andrew Ford

Object

Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

  1. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
  2. the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
  3. any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.

TWBC have accepted that Gate Farm is major development but have not explained how the sequential tests required by para. 172 have been met. This policy is therefore, not justifiable.

Major development of this scale is not appropriate in an AONB. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

This site reflects the predominantly rural and medieval character of the High Weald. It lies at a prominent high point (130m) with extensive views to the East towards the Greensand Ridge, and west towards Bedgebury, Flimwell and Combwell. The site consists of a complex of fields providing the setting for 4 historic farmsteads and lying at a prominent junction between an ancient droveway, an ancient ridge top road, and an ancient track (now a PROW) into Bedgebury Forest connecting with a known iron working site (SAM) at Furnace Farm. The site provides a rural and typically High Weald setting for the small hamlet of Hartley.

The northern part of the land to the East of Glassenbury Road is a known species rich grassland site. This habitat is one of the most rare and vulnerable habitats in the Weald and should be protected in order that it can form a core for nature recovery networks proposed in the Government’s 25-year environment plan and new Environment Bill. The rural environment and the remaining traditional farm buildings, albeit derelict, significantly increases the chance that protected species are present.

The agricultural land across a large part of the site is Grade 3a, the best and most versatile agricultural land. The majority of the High Weald is grade 3 and 4. Pockets of 3a like this site are vital if the aspirations of dealing with food security, growing food locally and adapting to climate change are to be delivered. The impact of permanently sealing grade 3a agricultural land with artificial surfaces and buildings cannot be mitigated within a reasonable time frame.

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The ‘how’, i.e. the conserving, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3.

DLP_7575

Susie Oakenfold

Object

GATE FARM & BULL FARM, HARTLEY ROAD, CRANBROOK AL/CRS 6 Sites 59, 70, 323 & 345, and Late Site 53 

It can be very very difficult pulling out from Glassenbury Road onto Hartley Road with existing traffic levels, more often than not exceeding the speed limit, and there are accidents and near accidents regularly.  I am really concerned about the traffic impact on this already tricky junction.  The fact that there is a plan for nearly 100 houses entering and exiting onto the nearby roads means a potential 150 plus additional vehicles adding to the peak time build up here is going to cause real problems.  It is a major commuter and school run route and the whole of the road area around this junction is going to be a complete bottleneck.  To put this number of houses here is just madness.  Glassenbury Road is winding and with narrow areas of poor vision, and prone to speeding cars as well as Hartley Road.  The extent of development in these two locations is going to cause enormous problems.  It is too far out of town to be walkable and residents will all use vehicles every time they need to go out.  Please please look at this proposal more carefully.

Policy AL/CRS 7: Land off Golford Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_982

Mrs A Marley

Object

Late Site 32 Land off Waterloo Rd

150 houses Too rural & isolated

No infrastructure.

DLP_7782

Annie Hopper

Object

Policy Number: AL/CRS 7

Why has TWBC allocated this major development (150 homes) in the AONB and ignored:

* Its own policy in the DLP STR 8 Conserving and Enhancing the Natural built and Historic environment, in particular point 5 relating to the AONB

* The AONB Management Plan

* The draft Parish Neighbourhood Plan to focus on small scale sites and avoid large scale sites.

* NPPF para 172: Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. …….The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances and where it can be demonstrated that development is in the public interest.

* DEFRA Landscape review 2019 highlights the CPRE report (2017 CPRE & AONB ‘Landscapes for Life’ available at: https://landscapesforlife.org.uk/application/files/5315/5552/0923/Housing-in-AONBs-Report.pdf ) revealing that approvals for housing units within AONBs and within 500m beyond their boundaries have increased by 82% between 2012-2016, numbers of affordable units have gone down and the risk that paragraph 172 ‘exceptional circumstances’ is being used to argue for major development on the grounds that no other sites outside the AONB are available.

* This allocation for large scale development is outside the LBD.

Proposed extensions of LBD shown on Map reference 14.1 in order to ‘qualify’ as in 5.76 ‘adjacent to the existing Cranbrook Limits to Built Development in the AONB is contradicting “The purpose of this designation/policy approach to LBD was to “restrict the encroachment of built form into the surrounding landscape”. as defined in the Limits of Built Development Topic Paper for DLP Reg 18 Consultation. Aug 2019 and will set a precedence for further development of valuable AONB landscape.

Local research for the NDP indicates that local residents are against large scale development as a method of delivering housing in the Parish.

This development is unsustainable, being too far from employment centres and train hubs, necessitating residents to use cars.

There is absolutely no indication of potential employment provision except during any construction phase.

DLP_250

Karen Booth

Object

Please see comments attached. We object to Policy AL/CRS7 on grounds of unsuitability due to forseeable problems with the road and traffic,  flooding risk,  lack of infrastructure to support such a develpment and the wildlife and aesthetic problems associated with building in a designated AONB.

[TWBC: attachment is copied in full below]:

AC/CRS 7 Land at Golford Road

My family has lived at xxx, Golford Road TN17 xxx [TWBC: some parts of postal address redacted] since 1998. We live half a mile or so along the road from the proposed development land site 7, Land at Golford Road. We object to this application for a number of reasons including the road and traffic problems we foresee, the environmental issues at stake and the infrastructure of Cranbrook itself, which we believe will not be able to support such a large number of new homes. In addition we question whether Cranbrook, so far from the mainline railway station and with a very limited bus service, is a good place to offer new homes when people will need to travel far to get to their places of work.

Road and Traffic issues

Golford Road is not a wide road, has some very windy parts and becomes particularly narrow and treacherous between the proposed site and Cranbrook itself. We have seen many accidents happen here, as well as accidents in the ditch opposite our property. We believe that a tiny proportion of these accidents are reported and therefore the statistics about the number of accidents on this stretch of road are highly inaccurate. It is very important that the householders along Golford Road are listened to about this as we are the ones who witness the accidents and know that there are many. This is a small country road and one not suited to 150 + more cars using it on a daily basis.

Already there are unacceptably long queues at peak times both on the approach to Cranbrook (by the Tanyard car park) and also the T junction in Sissinghurst from Chapel Lane. The traffic problems would increase considerably with 150 new houses on Golford Road.

The Environment

The proposed development is in an area of outstanding natural beauty and we believe these designated areas should remain as such to preserve the beauty of the environment. In addition, we have a good deal of wildlife in the area, badgers (we have even seen albino badgers on the road), bats and buzzards. To develop the land here would be to devastate their environment. We are not aware whether there are crested newts on the site, but it is a possibility given its proximity to water. When we as householders are made accountable for any protected species on our own land, we hope the same rules would apply here. There is the additional risk of flooding and we have seen very bad flooding many times on the road by the proposed development. Digging the land for houses may well make this worse.

The infrastructure in Cranbrook

We do not believe that Cranbrook is suited to have such a large number of new homes as is proposed. We do not have the capacity in schools, doctor surgeries, car parking and transport. We are not well located for any of the major towns – Ashford, Maidstone and Tunbridge Wells are all at least half an hour away by car and considerably longer by bus, of which there are very few. It does not seem to make sense to build so many homes so far away from the big towns.

We are not supportive of the large number of new homes proposed in Cranbrook for the above reasons, but also particularly we object the proposed development of land in Golford Road which could open up new avenues for development in an area of outstanding natural beauty and will destroy the countryside while not offering a good location for its inhabitants.

DLP_7909

Fiona Dagger

Object

Major development is not appropriate in the AONB. TWBC have accepted that Golford Road is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

The Golford Road site is misnamed. These fields are part of an essentially, agricultural landscape separated from Cranbrook by a natural barrier. The site is bounded along half of its length by ancient woodland which surrounds the Crane and its tributary (The impact on ancient woodland is not mentioned in the Distribution of Development Topic Paper, site assessment, Appendix 3). The fields provide the setting for historic farmsteads which lie along an ancient routeway (now Golford Road) and were served by Cranbrook town which was established later. Allocating this site would allow urban development to jump a natural barrier and materially change the character of an essentially agricultural area typical of the High weald AONB.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving, i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that ‘visual containment’ will mitigate harm to the AONB. This is not the case. The traditional building component of the AONB landscape is part of what makes the area outstandingly beautiful. It is the setting of these buildings in an essentially medieval landscape rich in wildlife that makes it national important. Destroying the fieldscape that provides this setting is not mitigated by planting a screen.

DLP_391

Jill Marie Hooper

Object

I have lived at [TWBC: private address redacted], Golford Road, Cranbrook since 1958.  My house and its agricultural land is adjacent to the proposed "Site 7 land.

Goldford Road is the most attractive rural entrance for visitors coming into the historic town of Cranbrook and this would be destroyed by the proposed urban scrawl outside the village envelope.

Increased traffic on Golford road would add to the existing congestion on the approach to Stone Street at the T junction by the Tanyard Car Park.  Congestion would also affect the approach to Sissinghurst via Chapel Lane at the T junction opposite The Milk House. Both these junctions have tailbacks of traffic at the regular busy times particularly related to commuters using Staplehurst Station and school traffic for the large Dulwich Preparatory School which exits solely on to Golford Road.  Pedestrians from Cranbrook who regularly walk to the cemetery to tend the graves of their loved ones and pay their respects have a dangerous passage without a footpath for the major part of the walk.

The sole access to the town sewage works access Golford Road on the double bend and is in twentiy four hour use by large tankers. The smell of tankers disgorging their sewage at the works frequently affects local residents and would be a marketing disadvantage to the proposed site 7 land development.

I wish to lodge my strong objection  to such a disruptive development in this very special Area of Natural Beauty.

DLP_7986

Barn Owl Trust

Object

The Barn Owl Trust has been informed of the alleged presence of foraging Barn Owls within the development boundary. As far as we can see no protected species surveys have yet been conducted so we recommend that these are conducted in due course. We would also recommend that all suitable structures (trees, buildings etc.) within the development footprint are surveyed for material evidence of roosting or nesting Barn Owls. 

Since the presence of protected species is a material consideration in the decision-making process it seems odd that surveys have not yet been conducted.

DLP_8249

Diane Tubman

Object

I object to the proposal to site 150 houses on land off Golford Rd for the following reasons:

- This is sited within the AONB

- Approaching Cranbrook from Dulwich Prep School there is a view across the fields to the iconic windmill, which is a unique landmark in this area. 150 houses on this field would compromise the view.

- Golford Rd would not be able to cope with traffic from this site. There could be 300 more cars coming out onto Goldord Rd. At peak times, the traffic on this part of the road is already crawling along to the junction of the Hill + Waterloo Rd. Anyone wanting to go to Maidstone/Staplehurst will have no choice but to queue to get onto Waterloo Rd, or if they went in the other direction, they will have to queue along Chapel Lane to get through Sissinhurst. One junction in Cranbrook cannot cope with the volume of traffic.

- It is not a safe place to walk into Cranbrook with existing pavements. Traffic travels fast & gets very close to pedestrians. There is no space to widen the pavement.

- These fields are home to lots of wildlife and are crossed by 2 public footpaths which are used constantly by dog walkers and people who appreciate "living in the country".

- There is a stream, the Crane, at the bottom of the field which is a haven for birds. Will this be affected by 150 houses above the level of the stream? Surely there will be run-offs from fuel on people's drives along with detergents.

- Can the sewage system cope with this extra number of houses?

- There doesn't seem to be any mention of upgrading the infrastructure of Cranbrook. The Primary School will not be big enough, the car parks won't be able to accommodate the extra cars, the High St will be a traffic jam and Stone St will be at a standstill. Will there be enough doctors' surgeries?

- It seems to me that Cranbrook is being used as a place to ofload T. Wells borough building quotas but our services are being continually cut.

We used to have a borough council office, a magistrates court and a regularly staffed police station.

Now, there is no council office, the hours have been cut to a minimum at the parish office, the library hours have been cut, we have no community centre and no medical centre and yet we are expected to take almost as many new houses as Tunbridge Wells itself.

DLP_961

Mrs A Marley

Object

150 houses are quoted in close proximity to the sewage works which may need to be extended for the 800 extra houses to be built in Cranbrook.

TWBC are quoting 356 houses on late site 17 which would be totally out of proportion in this area.

This site is also a badger crossing area.

DLP_2496

Mr John Wotton

 

AL/CRS 7 Land off Golford Road

Object

This would be a major development within AONB (see Distribution of Development Topic Papaer, para 6.35) of 150 new homes, on a greenfield site outside the LBD. No exceptional circumstances within NPPF 172 justify this policy. The site is detached from the existing settlement (Cranbrook) and is poorly related to it. It is partly in Flood Risk Zone 3I oppose this policy, as it would represent a substantial eastward extension of Cranbrook into protected AONB countryside.

DLP_2519

Mr Guy Dagger

Object

Major development is not appropriate in the AONB. TWBC have accepted that Golford Road is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

The Golford Road site is misnamed. These fields are part of an essentially, agricultural landscape separated from Cranbrook by a natural barrier. The site is bounded along half of its length by ancient woodland which surrounds the Crane and its tributary (The impact on ancient woodland is not mentioned in the Distribution of Development Topic Paper, site assessment, Appendix 3). The fields provide the setting for historic farmsteads which lie along an ancient routeway (now Golford Road) and were served by Cranbrook town which was established later. Allocating this site would allow urban development to jump a natural barrier and materially change the character of an essentially agricultural area typical of the High weald AONB.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving, i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that ‘visual containment’ will mitigate harm to the AONB. This is not the case. The traditional building component of the AONB landscape is part of what makes the area outstandingly beautiful. It is the setting of these buildings in an essentially medieval landscape rich in wildlife that makes it national important. Destroying the fieldscape that provides this setting is not mitigated by planting a screen.

DLP_3035

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 7 Land at Golford Road. (150 dwellings). This is outside former town limit and off a narrow, twisty country road - an attractive end of the town currently. Although outside the CA the proposed 150 houses would cause a substantial rise in traffic at this unspoilt end of Cranbrook. Too many houses proposed- a 50% reduction in houses might be feasible. AMBER

DLP_3444

High Weald AONB Unit

Object

Major development is not appropriate in the AONB.

Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

m) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

n) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and

o) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.

TWBC have accepted that Golford Road is major development but have not explained how the sequential tests required by para. 172 have been met. This policy is therefore, not justifiable.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

The Golford Road site is misnamed. These fields are part of an essentially, agricultural landscape separated from Cranbrook by a natural barrier. The site is bounded along half of its length by ancient woodland which surrounds the Crane and its tributary (The impact on ancient woodland is not mentioned in the Distribution of Development Topic Paper, site assessment, Appendix 3). The fields provide the setting for historic farmsteads which lie along an ancient routeway (now Golford Road) and were served by Cranbrook town which was established later. Allocating this site would allow urban development to jump a natural barrier and materially change the character of an essentially agricultural area typical of the High weald AONB.

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that “great weight should be given to conserving and enhancing the landscape and scenic beauty” in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The ‘how’, i.e. the conserving and enhancing, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that ‘visual containment’ will mitigate harm to the AONB. We do not share this view.

DLP_1311

Mr David Summers

Object

AC/CRS 7 LAND AT GOLFORD ROAD CRANBROOK

FINAL DRAFT

BASIS OF OUR OBJECTION

My wife and I have lived at Fir Tree Farm, Golford Road, Cranbrook TN17 3NW since 1977. Our property, which includes working agricultural land, faces the agricultural land in question: Site 7, Land at Golford Road (hereafter referred to as “the Land”) .We have long experience of traffic, pedestrian, and environmental issues relating to its development potential. We do not believe the Sustainability Analysis has given proper weight to these and that taken as a whole it is our view that the site is unsuitable for the large scale development of 150 houses as proposed. According to Post Office data the development would be half the size of the Frythe estate and slightly larger than the Turner Ave estate that abuts it. 1 Connectivity issues 1.1 Pressure on T junctions The land is situated on a speed unrestricted main road outside the limits of built development. Direct access to places west and north is principally achievable by passing through Cranbrook via the T junction at Waterloo Road. Alternative access to the north , and in particular to Staplehurst Station may be achieved via accessing Chapel Lane at the Golford cross roads and emerging onto the A262 at the T junction facing The Milkhouse pub. Both these T junctions constitute major pressure points in traffic flow, especially during school and working hours. The successful growth of Dulwich Preparatory School has led to a substantial increase in fast, closely packed traffic along the road at peak times.

The situation in Cranbrook is exacerbated by the position of the public car park at The Tanyard which provides a single entry and exit point directly onto the stem of the T junction. Sissinghurst’s existing traffic problems are well documented and increased flow from the “ the Land”, whether to access the local junior school, Staplehurst Station, or the A262 west can only add to them.

The SA takes no account of the Sissinghurst T junction which is frequently preferred by commuters on this side of Cranbrook to avoid congestion and speed bumps in Cranbrook.It is a weakness that it does not examine the allocation in the wider setting.

1.2 Dangerous bends

The road between “the Land” and Cranbrook winds directly along what is in effect a causeway between a large pond on one side and steeply falling land on the other and is cambered towards the falling land which encourages motorists to take a more central road position in both directions. The safety rails on the downward edge show signs of serial repairs caused by traffic hitting them. It is fringed by a narrow pavement on the pond side elevated to a two tiered step down to the road in places

Large sewage tankers enter and exit the road at the eastern end of the bend

An example of the repeated appeals made by local residents is reproduced here:

“I first wrote to the council about traffic three months after we moved here, in December 2009, after our first scrape with an overhanging car mirror on the pavement. I suggested extending the 30 mph zone (to the end of the houses) as well as making some sort of effort to enforce it where it already exists. I've contacted them again over the years, especially after we’ve witnessed major incidents, such as the one on 1 February 2014 (which was reported in the newspapers. The driver and passenger had critical injuries and the driver had to be cut out of the car which was upturned and had knocked out the electricity supply for this area).”

But there have been other incidents only some of which have been recorded by KCC

Another relatively blind bend with warning posts in the verge - at least those which have been left standing; others have been demolished by traffic -starts opposite our own property providing an additional hazard for both motorists and pedestrians.

Given the increased volume of cars and commercial vehicles that would result from the development- commuters, mothers taking their children to school in the town, tradesmen, delivery and council vehicles - these traffic problems can only become more intractable and a marketing disadvantage to any development.

1.3 Pedestrian access to and from “the Land”

1.3.1 Since 1977 I have walked into Cranbrook virtually daily to participate in the local community. but virtually no other local residents make the walk. It was more common practise when we first lived here with older people too walking to the cemetery to pay respects. Now the common way of accessing the town is by car whether shopping or socialising.Walkers are generally tourists these days accessing local footpaths or D of E students from Swattenden.

The present ”rural” public footpath on the south side from Cranbrook extends only to our house and although laid by a public authority is not maintained. The Plan envisages extending the path eastwards to the end of the developed land, I understand that this would have to pass over privately owned ditches fronting agricultural land and would therefore be opposed by the owner.

The path is only rarely used after hours of darkness and users need a torch to pass safely as there are only 3 “Parish” lamp-posts between Bakers Cross and the end of the rural path at Fir Tree Farm. The last of these is on the north side. This has always raised the issue of personal safety for single pedestrians.

To illuminate the proposed extension along its length on the south side would lead to unnecessary light pollution and a waste of energy.

We object to this extension to the existing path on the south side as the expenditure cannot t be justified in terms of both feasiblity and the benefit it brings to the community.

1.3.2 Originally there was no footpath at all around the bends at Bakers Cross and we took our lives in our hands pushing the pram, but the present inadequate footpath was created about 20 years later. We made representations  to KCC at the time that it was too narrow: people cannot pass each other without stepping into the road  and it is impossible to wheel a pram along it, let alone a mobility vehicle or a  wheelchair.

Over the years the wheelbases of lorries and buses have got longer and a danger now is that the front offside of buses travelling to Cranbrook  overlap the pavement if taking the bend sharply or  to avoid on coming traffic. I have personal experience of narrowly avoiding being hit from behind.

1.4 Stone Street

Although the SA makes reference to the Waterloo Road junction, the real obstacle to development to the east of the town is the chaotic traffic situation in Stone Street where vehicles frequently ride on pavements to avoid each other and buses and heavy lorries lock horns.. Solving this problem is at the heart of breathing continuing life into Cranbrook’s commercial activities.

The injection  of traffic from any large development on “the Land” can only elevate the chaos to new levels. It is not as if the is significant car parking  in the eastern quarter  from which motorists can proceed on foot into Stone Street.

It is essential that consideration to this allocation is given  in the context of its impact on Cranbrook town as a whole.

2 Environmental issues

2.1 Sewage Works

“The Land “ borders the  Cranbrook Sewage Works which would have received planning permission because of its situation beyond the existing built development  and its ability to discharge directly into the Crane Brook at the point at which it entered open countryside, to minimise nuisance.

These Works have had a chequered relationship with local residents during our residency with strong feelings about smell, noise, high level of tanker traffic, treating waste from other towns and National River Authority involvement. Southern Water was fined £13,500 in 2013 for an incident relating to industrial waste  there and in 2014 spent £4m updating the plant.

Although the Plan mentions obviating the risk of ‘’obnoxious smells”, it takes no account of the potential expansion of the works to cope with the additional sewage inflow result from the creation of 900+ houses in the area.  Our research indicates that 150 houses would generate a 20% increase in the sewage the works currently deal ,with an  accompanying increase in tanker traffic.

Large capacity sewage tankers already ply the concrete track to the main road and it is hard  not to image the marketing challenges  for developers of being next to this site.. Even the address listing for our post code shows “The Sewage Works” having pride of place. No matter what more picturesque names are given to the streets in any  future development , I suspect they will always be known locally  collectively as “the houses by the sewage works”.

Heaven forbid that that section of land should be allocated only to affordable housing!

The plan creates a “ sewage sandwich” with the Works placed in an envelope between two communities of residents. This cannot have been the intention when planning permission was granted for the Works originally. The Works were intended to be situated outside the town.

2.2 Flooding

Treated water from the works flows into the Crane Brook which runs at the northern and  lowest point of the Land. The volume of flow can only increase with the  sewage outflow from the  land, and other developments in the area.

With experience of tramping through the watery mud I can offer assurance that  there is flooding on“the Land”  every year  where it falls away to the Crane Brook. Indeed part of it is covered by the Environment Agency's Flood Zone 3 . Whilst it is official policy to build on flood zones, even though flooding is on the increase is it sensible in this case?  Whilst it may be argued that building  should be avoided on the part that floodable land, the building on the rest of the field will surely increase the flooding issue as the built up area will soak up less rainwater, and that increased flooding would be right next to the sewage works.

2.3 Area of Outstanding Natural Beauty

The arable land is actively farmed . This is major development in an AONB, which is contrary to national policy, see NPPF para 172: It is debatable whether the tests it sets out have been met.

One footpath runs alongside the sewage works boundary and crosses the Crane Brook onto private agricultural land where it meets the High Weald Landscape trail. The development would be locked in on the other two sides as this is the only way of accessing open countryside from the developed land and heads away from Cranbrook . Over the years however at least one other unofficial footpath to Cranbrook has been walked over this private land and given the proximity of the developed Land, the owner may be likely to experience an even higher rate of trespass in future.

CONSIDERED OBJECTION

The development of “the Land”- which is not a natural extension to existing built development since it abuts a large field belonging to a private house - would provide a stimulus for the further development of Cranbrook in an easterly direction. We would argue that this is the worst possible strategic option for the town’s growth given the wider connectivity issues.

DLP_2084

Terry Everest

Object

Object

This green field site ideally should not be developed but certainly not at the volume proposed but rather at a much lower volume such as 1/3 - 2/3.

DLP_2410

Mr Seb Fogg

Object

the village does not have the resources to cope with another 150 homes. you will be destroying an area of natural beauty that is used by wild animals who will lose their habitat. the building works will be catastrophoc to a village thta is already overwhelmed with traffic, dcotors surgeries you cannt join or get an appointment in due to demand and lack of parking for those who live here already.

DLP_1934

Dr Camilla Pashley

Object

I am objecting to proposal AL/CRS 7 -LAND OFF GOLFORD ROAD . LATE SITE 32

I object to development off the section of the Golford Road. This road is an attractive minor B road entrance to the town but with several difficult bends and numerous small scale accidents take place several times a year along the stretch to the Golford crossroads. This site is within the High Weald AONB and the site would significantly affect views from various footpaths around this beautiful area with ancient woodland and farmsteads as stated in Policies 20 and 21. The policy on AONB states that proposals that would harm the natural beauty of the AONB will not be permitted unless it is clearly in the public interest to do so. This particular development cannot argue that case.

In these sections it also clearly states that development should conserve and enhance the landscape, and not result in unsympathetic change to a rural lane. Any development should also retain the distinctiveness of local settlements whereas this proposal crosses the historical boundaries. The new development would affect the views on this beautiful rural road as the town of Cranbrook is currently obscured by historic woodland concealing the built development as one travels towards the town either by car or on foot. But this proposal would affect this adversely especially coming from the historic town of Tenterden or by the alternative route from Sissinghurst, affecting the impression of the historic town by tourists. This route is characterized by beautiful rural views all the way into Cranbrook.  In this I refer to paragraph 6.214 . So this site in particular affects the view of the boundaries of the town and is also very visible on very popular footpaths linking Cranbrook to Sissinghurst which are on higher ground so it would be hard to hide the development. One of these is the High Weald Landscape trail.

This site is also next to a hidden sewage works which struggles with the numbers already and is next to and includes areas within a Flood Zone 3b but I understand that this site was missed off the 2019 Flood Assessment report which needs to be rectified. The road itself has flooded on several occasions .

Whilst the whole of the Golford Road is unable to cope with larger volumes of traffic the junction at Waterloo Road would be become extremely difficult . In the other direction the Golford Crossroads and Chapel Lane up to Sissinghurst are prone to accidents and potholes and road subsidence and is regularly repaired. The bend coming out of the town just before the proposed site is tricky to negotiate, prone to flooding and narrow.

DLP_2169

West Kent Badger Group

Object

Proposed Building of 150 Houses near Cranbrook - CRS 7

many residents are concerned about the proposed building of 150 houses on land off Golford Road, near a sewage works. The West Kent Badger Group is very concerned about this planning application as there are a number of active badger setts in the area and therefore, support any objections to it.

I would be grateful if this could be noted in your council records.

DLP_2512

Claire Groom

Object

POLICY AL/RS 7 (LATE SITE 32)

LAND OFF GOLFORD ROAD (SHELAA reference: Late Site 32)

OBJECTION:

As residents on the Golford Road, we regularly use the road into Cranbrook and walk along it’s desegnated rural footpaths. We have a number of serious concerns regarding road safety, the location of nearby listed houses, the impact on both the environment and its wildlife, together with the suitability of siting a housing development adjacent to an already overwhelmed sewage plant.

A) SAFETY

i) Pedestrians access to Cranbrook 

The current access for pedestrians wishing to walk into Cranbrook is very narrow. Our son used to walk to school, but we quickly realised that it was far too dangerous for him to do so. The pavement adjacent to the pond (below Tilsden Lane) is not only narrow, but regularly floods. I have witnessed cars aqua-plaining across the water. In addition, the pavement stops at Fir Tree Farm and thereafter there is only a narrow verge which runs adjacent to a drainage ditch. It often becomes waterlogged and those pedestrians who choose to walk, do so in the road.

ii) Pavement width

The current width of the pavement is only 50cm. The width should be a min. of 200cm under normal circumstances or 150cm if physical constraints prevent this or 100cm if there is an obstacle (Dept of Transport). This minimum is only achieved when overgrown brambles etc. have been cleared, but for most of the year it is never more than 50cm. The Council have repeatedly told residents that the pavement cannot be widened. As a result, we no longer allow our children to walk to school, so we add to the congestion by using our car to travel to Cranbrook.

iiiVehicular access to Cranbrook/StaplehurstFor those residents who drive to Cranbrook via Golford Road to access its schools, we have to negotiate the narrow approach road with parked vehicles to the right-hand side. Due to the congestion at the Waterloo and Stone Street T-junction, I have to drop my son at the school 40 minutes before he needs to be there.

For those needing to continue into Cranbrook town, the access is via Stone Street which is only oneand a half cars width. Some cars attempt to pass one another, but unless the vehicles are small hatchbacks (they are usually 4 x 4 vehicles), one inevitably has to mount the (extremely narrow) pavement. Despite being a supporter of local businesses, I avoid coming into the town to shop because of the access problems. Increasing traffic here would exacerbate the situation and cause further safety issues for both road user and pedestrian.

With the nearest train station in Staplehurst, most cars would normally travel via Waterloo Road, but due to the congestion, most travel via Golford Road and Chapel Lane into Sissinghurst.  There are regular accidents at the Golford Road crossroads. The most recent collision resulted in a car flipping onto its roof.  We have also observed a number of near misses and approach the site with caution every day.

The approach from Chapel Lane to The Street in Sissinghurst already has severe traffic problems throughout the day. The road is narrow and residential cars park on both sides of the highway, making it difficult to proceed.

iv) Traffic speed 

Golford Road is a designated rural lane. The speed limit near the proposed site is 30mph, but drivers travelling along the Golford Road towards Cranbrook rarely obey this.

v) Road width

The Golford Road narrows significantly as it approaches Cranbrook (on the bend above Tilsden Lane). The railings are regularly dented and buckled where cars have collided, and many road users do not observe the speed limit. Buses and other wide vehicles frequently use the road and approaching vehicles have to mount the pavement to negotiate. I have witnessed cars almost colliding with wider vehicles and, even more worrying, I have seen a pedestrian forced to pin themselves against the railings to avoid being hurt.

When the Dept. of Highways objected to the expansion of the sewage plant some years ago, the reasons sighted were that the width and visibility of the rural approach roads were unsuitablefor the increase in traffic.  It was ruled that the proposal was unacceptable on highway safety grounds. TWBC itself raised objections, including the unacceptable impact of additional traffic movements on highway safety.

B) SEWAGE WORKS:

Living further along the Golford Road, our boundary abuts Crane Brook and the ancient wood known as Plantation Wood. Treated water from the sewage works is discharged into the brook which sustains much aquatic life, including the Great Crested Newt. It is well documented that the current Sewage Works is already at its maximum limit, with excessive effluent being stored in overflow tanks and with some screened effluent having to be discharged into Crane Brook. Should CRS7 go ahead, the Sewage works will not be able to cope with the additional effluent generated from an increase in properties.

C) FLOODING:

The field on the site of the proposed development is located in a flood zone and is waterlogged during the winter months. Even if the proposed houses were sited above the floodplain, water will run down into it and further impact the discharge of sewage into Crane Brook.

As a result of flooding in 2010, raw sewage was discharged into Crane Brook. A number of fish died and the impact of the discharge was observed as far away as Biddenden.

D) AONB & WILDLIFE:

In addition to the already documented Great Crested Newts and Badgers on the site of the proposal, we have personally observed Long Eared Bat (photo enclosed), which has been verified by the UK Bat Care Network. We regularly see bats flying around the area, but this one was the first we were able to photograph.

The agricultural fields adjacent to the Golford Road support a number of wildlife species and should be preserved at all costs. The fields and hedgerows provide a natural barrier and changing this would fundamentally alter the character of this AONB.

E) LISTED BUILDINGS:

There are a number of listed buildings along the Golford Road. The setting of a listed building is an essential part of the building’s character. These buildings contribute to the landscape and their surroundings produce a visual harmony which enriches the setting of the landscape. Development proposals can have an adverse affect on the listed buildings setting, particularly if it affects views, which CRS7 would.

The majority of the homes near the sewage works are only one storey high. These low impact homesteads are all opposite the proposed site and are far more suitable to this type of landscape.

DLP_2579

Dr Paul Jackson

Object

1. TRAFFIC. UNSUITABLE ACCESS. Cranbrook has a bypass, THE A229, intentionally to keep traffic OUT of the town. The bypass provides a north-south link to and from Staplehurst Station, Maidstone and Hastings. The bypass also provides access to the west via Goudhurst to the A21, Paddock Wood, Tonbridge, Tunbridge Wells, Sevenoaks and Bromley.

The bypass is also access to the High Weald Academy and Weald Sports Centre. Access to the bypass is already difficult from the East of town. ANY development on farmland to the East of Cranbrook is certain to overburden access to the bypass and make pedestrian use of the town and its narrow streets even more dangerous. Traffic frequently climbs the kerb entering town from Golford Road to the East and via a tight 120 degree, narrow downhill turn from Waterloo Road to the North.

Golford Road funnels traffic into the Cranbrook High street via a narrow s-bend unsuitable for additional traffic. It is also the access for Dulwich prep, with its dangerous ingress on the bend, and access to the cemetery. From Golford Road traffic then has to pass Cranbrook School over the large speed bumps to access the bypass. There are already long queues at St Davids Bridge at this difficult junction and queues for Cranbrook School entry. An alternative route is via Chapel Lane. Again this junction is difficult due to the heavy traffic through Sissinghurst, where it is usually impossible for traffic to flow in both directions at the same time. Chapel lane is also a minor country lane with no footpath. Finally access to the bypass, school and station is possible via Tilsden Lane and Swattenden. Tilsden Lane is a very minor and potentially dangerous road for increased traffic with no footpaths and an unsuitable rat run, with a difficult junction to the bypass

Pedestrian access to and from the town is via a narrow and leaf strewn path on a dangerous s-bend where buses and larger vehicles frequently need to cross the road centre line in order to negotiate the sharp turn. The s-bend and path cannot be changed due to restrictions either side. This footpath is unlikely to attract many residents going to town. Residents will need to use their cars for access to Schools, Shopping, amenities, work, access to the station and access to the bypass

SUSTAINABILTY APPRAISAL

The policy should include policies

1. Travel. To reduce private car use. This is given a green +. This is the site with the greatest potential increase in car use and should be brown -
2. to promote protection and enhancement of the landscape and residents enjoyment of the countryside. This is given a green +. This is the site with the damage and should be brown -.
3. Employment. Why is this a green +
4. Noise. This will increase substantially the traffic and other noise pollution in this AONB area.
5. Flooding. This is an area with the potential to flood if developed.
6. Health. I see no genuine positive indications to support this
7. Equality. I see no genuine positive indications to support this
8. Access to facilities. There is only a negative effect and no improved access to facilities.
9. Biodiversity. This will destroy this already marginal area of biodiversity.

There are no relevant positive indicators for this site which supports none of the sustainability objectives.

SUITABILITY. CRS7 is outside of the built area, in the AONB and supports our farming with agriculture. It appears to be a last minute entry for development with no justification. I suggest that development of the town along Golford Road to the East will unnecessarily destroy the character of the town and leave an isolated historical centre in the middle if this development is further considered. Other entry roads into the town are already disfigured with commercial premises, petrol stations and somewhat random and unattractive dwellings.

SEWAGE and DRAINAGE. CRS7. The sewage treatment plant, adjacent to CSR7, is already at maximum capacity with backups reported to Southern Water who are unable to increase capacity. The site drops into a poorly drained and muddy valley at Crane Brook leading to Lake Chad.

ENVIRONMENT CRS7. There is a well used footpath at the edge of the site leading to the HIGH WEALD LANDSCAPE trail and footpaths to Sissinghurst and Wilsley Pound. Development at Great Swifts was removed following complaints that it detracted from the HIGH WEALD LANDSCAPE trail.

There is no Biodiversity Assessment of this site in the local plan. This area and adjacent woodland provide home to a variety of wildlife, Buzzards, Bats, Barn Owls, Weasels, Adders, Foxes, Badgers, Jays, Woodcock, Woodpeckers, butterflies including protected European species. This is a fragile natural band which development would destroy.

SUMMARY

The proposals for additional housing in Cranbrook are very high and more than double the original estimate. They will change the character of this historical town, make parking and driving in the town almost impossible. Cranbrook is one of the few towns where it is still possible to drive, park and have a normal life without being overrun by the car. Develpoments will also cause additional misery at the Hawkhurst junction and overcrowding on the trains. There is no merit in destroying this. The burden on the Hawkhurst junction will be terminal. This junction is a highly prominent problem in all planning applications with no solution in sight.

CRS7 is the most unsuitable site for development. It should be ruled out due to the additional burden of an already congested traffic flow. All schools, work, shops, sports centre and other facilities are on the other side of the town. They will be accessed by car, not pedestrians, and bring the town to a standstill. There is insufficient parking adding to the chaos of potentionally an additional 300+ cars. Traffic going to the main hubs of Tunbridge Wells, Maidstone and Staplehurst station will have to go through the town or be gridlocked at Sissinghurst. It is unsuitable due to limitations of sewage and drainage and it will damage a very fragile environment.

It is agriculutural land, in the AONB and outside of the built area for good reasons!

DLP_2547

Phillip Tennant

Object

Policy AL/CRS 7 Late Site 32 Land off Golford Road

I strongly object to the proposed development on the grounds of the adverse environmental implications, in an AONB and the ongoing impact on Cranbrook and the surrounding areas. Specifically, this proposal will, in my opinion, result in an irreversible change in character of the town where I live and impact negativity on the quality of life of all who currently reside in this area.

DLP_2812

Sue Donaldson

Object

I object to this proposal entirely. All other substantial proposals have access to the Cranbrook bypass/ Angley/ Hartley Road. There will be a considerable generation of traffic, much of it heading to and from Staplehurst Railway station in rush hours. The current traffic infrastructure should be able to cope with these. Not so AL/CRS 7 which would require substantial road improvements and petestrian walkway just to get to the bottom of Waterloo Road which would become a bottleneck. I do not believe that the road system would cope even with a fraction of the number of houses in which case expenditure would be even more pointless.

St Davids Bridge simply would not cope and the congestion in Cranbrook together with impingement upon existing listed buildings would be quite unacceptable. To encourage drivers to access Staplehurst via Golford crossroads and Sissinghurst would be ludicrous.

PLEASE reject this proposal altogether and concentrate on sites with ready access to the A229

DLP_3152

Nigel Bell

Object

I have strong objection to such a large, inappropriate development on ANOB land in this location. This area is currently characterised by small ribbon developments along the roadside not large housing estates. Site is currently enjoyed by walkers and trail runners, rural land which should not be lost. Road access is narrow and potentially dangerous to have vehicle access to a large housing estate. Potentially too far to walk to the village so will generate increase traffic volumes as the residents use their cars. The boundary of the land slopes sharply to the rear and along one boundary to the Crane brook, which is a historic wildlife area which needs to be preserved for future generations.

DLP_3301

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The Local Highway Authority objects to this policy.

This is unsuitable for sustainable development as part of a plan led approach, owing to there being no key facilities or bus route within safe walking distance, as only a narrow, substandard footway into Cranbrook. This will result in car borne trips. Given the scale of the proposed development, this development will not be acceptable unless a minimum 1.8m wide footway can be achieved between the site and the existing footway network west of Tilsden Lane. This facility would be preferable on the northern side of Golford Road. It is unlikely that this facility can be achieved within site ownership/highway land.

Public Rights of Way and access Service

It should be expected that improvements will be made to the PRoW that pass through the site and contributions will be made for off-site PRoW network improvements that surround the site. Attention is also drawn to the High Weald Landscape Trail (HWLT) promoted route, which passes along Golford Road. It is requested that the HWLT is realigned within the site, along a new traffic-free walking route to be provided by the developer, to avoid walking along Golford Road.

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is some potential for prehistoric and later remains

DLP_3445

Sally Marsh

Object

Object 

Policy Number: AL/CRS 7 Golford Road

Major development is not appropriate in the AONB. TWBC have accepted that Golford Road is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

The Golford Road site is misnamed. These fields are part of an essentially, agricultural landscape separated from Cranbrook by a natural barrier. The site is bounded along half of its length by ancient woodland which surrounds the Crane and its tributary (The impact on ancient woodland is not mentioned in the Distribution of Development Topic Paper, site assessment, Appendix 3). The fields provide the setting for historic farmsteads which lie along an ancient routeway (now Golford Road) and were served by Cranbrook town which was established later. Allocating this site would allow urban development to jump a natural barrier and materially change the character of an essentially agricultural area typical of the High weald AONB.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving, i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that ‘visual containment’ will mitigate harm to the AONB. This is not the case. The traditional building component of the AONB landscape is part of what makes the area outstandingly beautiful. It is the setting of these buildings in an essentially medieval landscape rich in wildlife that makes it national important. Destroying the fieldscape that provides this setting is not mitigated by planting a screen.

DLP_4123

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

This would be a major development within AONB (see Distribution of Development Topic Papaer, para 6.35) of 150 new homes, on a greenfield site outside the LBD. No exceptional circumstances within NPPF 172 justify this policy. The site is detached from the existing settlement (Cranbrook) and is poorly related to it. It is partly in Flood Risk Zone 3CPRE Kent opposes this policy, as it would represent a substantial eastward extension of Cranbrook into protected AONB countryside.

DLP_4327

Environment Agency

General Observation

Please note that site CRS 7 Land off Golford Road does not appear to have been included in the Strategic Flood Risk Assessment so we would require further details on this site before we can comment further

DLP_3612

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Cranbrook. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. Our assessment has revealed that Southern Water's underground infrastructure crosses this site. This needs to be taken into account when designing the site layout. Easements would be required, which may affect the site layout or require diversion. Easements should be clear of all proposed buildings and substantial tree planting.

In consideration of the above, we recommend the following criterion is added to Policy AL/CRS 7

Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes

In addition, we note that this site is close to Cranbrook Wastewater Treatment Works (WTW), which is owned and operated by Southern Water.

Southern Water endeavours to operate its wastewater treatment works efficiently and in accordance with best practice to prevent pollution. However, unpleasant odours inevitably arise as a result of the treatment processes that occur. New development must be adequately separated from WTWs to safeguard the amenity of future occupiers. This is in line with paragraph 170(e) of the National Planning Policy Framework (NPPF, 2018), which states that planning policies should prevent 'new [...] development from [...] being adversely affected by, unacceptable levels of soil, air, water or noise pollution' and paragraph 180 which states 'Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on [...] living conditions'.

In consideration of the above, we recommend the following criterion is added to Policy AL/CRS 7

The development layout must provide sufficient distance between Cranbrook Wastewater Treatment Works and sensitive land uses, such as residential units, schools and recreational areas, to allow adequate odour dispersion, on the basis of an odour assessment to be undertaken in consultation with Southern Water.

DLP_3841

Government Team

Natural England

Object

Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.

DLP_3909

Mrs June Bell

Object

Reasons for objection:

Why has TWBC allocated a major development site in the AONB and ignored:

I. Its own policy in the DLP STR 8 Conserving and Enhancing the Natural built and Historic environment, in particular point 5 relating to the AONB

II. The High Weald AONB Management Plan which has been adopted by all the Councils with land in the AONB as their policy for the management of the area and for the carrying out of their functions in relation to it.

III. The draft Parish Neighbourhood Plan to focus on small scale sites and avoid large scale sites

IV. NPPF para 172:’ Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. …….The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances and where it can be demonstrated that development is in the public interest.’

V. DEFRA Landscape review 2019 highlights the CPRE report (2017 CPRE & AONB ‘Landscapes for Life’ available at: https://landscapesforlife.org.uk/application/files/5315/5552/0923/Housing-in-AONBs-Report.pdf ) revealing that approvals for housing units within AONBs and within 500m beyond their boundaries have increased by 82% between 2012-2016, numbers of affordable units have gone down and the risk that paragraph 172 ‘exceptional circumstances’ is being used to argue for major development on the grounds that no other sites outside the AONB are available.

VI. This allocation for large scale development is within the AONB is outside the LBD and is contradicting “The purpose of this designation/policy approach to LBD was to “restrict the encroachment of built form into the surrounding landscape”. as defined in the Limits of Built Development Topic Paper for DLP Reg 18 Consultation paragraph 3.1 (Aug 2019) and risks setting a precedence for further development of valuable AONB landscape

VII. The proposed allocation contains 2 PROW, one being the beautiful High Weald Landscape trail linking Cranbrook to Benenden & the footpath to the neighbouring village of Sissinghurst. Both are used frequently to enjoy walking, running, dog walking, bird watching and members of the community and visitors are able to enjoy, crossing the Crane Brook to gradually climb up to Great Swifts and the amazing views over to Benenden in the east and The Cranbrook Windmill and historic town to the west without enduring the noise, danger and pollution of road traffic.

VIII. Flooding – the northern boundary of the site within a flood zone classified as 3b by the Environmental Agency see comment box 8 below. Development of this scale will increase likely-hood of flooding

IX. Negative impact of development on this site to the habitats and ecosystems will exceed the boundaries of this site by the nature of the flow from the Crane Brook to Hammer Stream and into the River Beult, which is a designated SSSI and therefore impossible to be fully mitigated by the developer.

X. The site lies on the eastern historic routeway entrance to Cranbrook in the setting of three historic farmsteads; Fir Tree Farm, Grade 11 listed Paddocks Farmhouse opposite and Bakers Barn to western boundary of the site as identified on the High Weald Character Map for Cranbrook. Development will risk irreparable loss of the historic character of the town.

XI. It is not sustainable location:

The SHELAA for the Reg 18 states the site is suitable because: ‘Whilst the site is detached from the LBD it lies in proximity to it and there is pedestrian access to the centre of Cranbrook. The site is likely to be sustainable in this context’.

This is not true in practise. It is greater than 800m from the schools and services such as Post Office, shops and dentist. Road safety is already an issue for pedestrians, even walking single file and without accessibility needs ie without a child /children/pushchairs/prams, walking aids, dogs, shopping trollies. Existing pavement on the southern edge of the road is narrow especially on the dangerous bend and in the area of the road which floods during heavy rain. I have been frequently soaked by passing cars as I walked this pavement. No pavement exists beyond Fir Tree Farm. In truth regular and non-recreational access to the town will require use of a car.

The volume of traffic at peak times (school drop off and pick up) is heavy and egress from existing drives along Golford Road is challenging and in risk of life at worse and vehicle damage and disruption of traffic flow at best as speed limits are frequently ignored beyond the 20mph limit.

Local employment prospects for residents are unlikely for and the DLP has proposed borough employment hub in North Farm, Tunbridge Wells which is 16miles from this site and not on a direct bus route increasing need for using a car.

XII. Development of this parcel of land of currently farmed agricultural land risks setting a precedent for either further development along this historic route way and /or extension of the LBD

DLP_5074

Tally Wade

Object

Policy AL/CRS 7 (page 214)

I object to the allocation of land for housing for the land off Golford Road. It is detached from the LBD, represents a substantial amount of AONB designated land and is within Flood Zone 3. It also sets a precedent for development of the parish to the East which is not in keeping with historic settlement patterns.

DLP_3641

Lynne Bancroft

Object

Policy Number: AL/CRS 7 – Land off Golford Road

I object to this site being included in the TWBC Local Plan due to:

* It is contrary to the draft Strategic objective 6 as building here will impact on the AONB and the important environment of the Crane Valley

* It is contrary to the draft Policy EN18 as it is in the AONB and will impact on this area due to additional lighting and urbanisation of the area

* It is contrary to the draft Policy EN20 as it will not protect current dark skies in the AONB

* It will damage the local sense of place so is again contrary to the draft policy EN20

* It is contrary to the draft policy EN21 as it will impact on the AONB

* It is contrary to the draft policy EN10 as it give additional outdoor lighting in the area

* It is urbanising the local sense of so is again contrary to the draft policy EN20

* It is not only outside the Limits to Build but the Local Plan even states that it is detached form the Limits to Build so should not be developed.

* It is contrary to the draft policy EN22 which prevents development on best and most versatile agricultural land.

DLP_5187

Mrs Karin Moncrieff

 

My husband and I have lived on Golford Road since 2001. This site has come very late in the day in the development plan and we believe firstly that there has not been given adequate time for stakeholder engagement – particularly in the wider community, as this plan would affect the residents of central Cranbrook, access to two schools and Sissinghurst village. We have further learned that the site has been offered up for major development some years before and was turned down due to environmental concerns mainly (sewage and ANOB particularly). These grounds are no less valid now. Specifically, we believe that the proposed site is ill considered and inappropriate on the following reasons:

1. Traffic junctions

The two key pinch points into town or going north towards transport links at are at the junction of Waterloo Road and at Chapel Lane, Sissinghurst for all northbound traffic. Both these have huge implications for the town itself (which already has a chaotic traffic situation in Stone Street) as well as for the residents of Sissinghurst, and the addition of the proposed amount of housing will increase the volume of cars and therefore this pressure substantially.

2. Road safety

The existing pavement is very narrow, has high camber and is on a very dangerous double bend. Despite the speed limit, there are frequently dangerous speeding drivers and accidents (as has been well documented by other respondents). Without alternative arrangements for pedestrian/cyclist/disability scooter access to the town, the existing pavement is simply totally impossible and highly dangerous. Given that the likely residents of the proposed estate are likely to be young families, it would be totally impossible to take a buggy with a child down the existing pavement without tragic consequences. I would suggest that the only alternative would be to allocate some of land belonging the Swifts estate to create a footpath to the town.

3. Environmental impact

a) Sewage works: the current sewage site at the bottom of the proposed site which currently serves the town, as well as many tankers from private septic tanks etc, is not even adequate for current use and therefore will need to be extended and upgraded as part of the plan by at least a capacity of 20% I am told. Simply the idea of locating a new estate adjacent to a sewage works I find quite laughable and extraordinary!

b) Flooding: the land is waterlogged in winter. Assuming the new houses would not be built on the flood plain itself, increased hard landscaping will nevertheless increase the risk of severe flooding – including the sewage works which is very vulnerable even now.

c) Area of Outstanding Natural Beauty: As well as being in an AONB, this is an environmentally sensitive area. The entire region – including all of Cranbrook and downstream of the Crane Brook to Sissinghurst, Frittenden, and Biddenden – has been designated a Nitrate Vulnerable Zone by the Environment Agency. In addition, it has been designated a Drinking Water Safeguard Zone (surface water) – which is reserved for ‘water sources that are “at risk” of deterioration.’ A qualified ecologist carried out a survey in 2012 and found at least 3 downstream waterbodies supporting populations of Great Crested Newts in the immediate vicinity. CRS7 also contains several badger setts

DLP_4025

Brian Swann

General Observation

- This would be another large estate in Cranbrook.

- Not near enough or easy enough to walk into town.

- Outside L.B.D.

- Within the A.O.N.B.

- Road congestion could not cope with the extra traffic generated - to station, to schools, to town.

- Existing footpaths P.R.O.W. paths to be retained.

- At least 50% should be affordable houses of 1,2 + 3 bedrooms - starter homes & homes to enable Cranbrook people to downsize.

DLP_4456

Patrick Booth-Clibborn

Object

I Object alongside the Golford Road and Cranbrook residents for the planned hosing development. Local Plan Allocation AL/CRS7 Land off Golford Road I have been a resident for 21 years. Our objections are based on road safety, on the suitability of houses adjacent to the sewage works and on environmental grounds. In addition the proposed development contravenes several TGWC core policies

  • 62% of the Civil Parish is AONB which lies in the southern half of the parish only.
  • ALL Cranbrook's TWBC site allocations lie within the AONB including several large allocations
  • Comment from a local: 'Tunbridge Wells Borough Council does not need to accept the levels of housing proposed by the Government.' 70% of the borough is protected as an Area of Outstanding Natural Beauty (AONB) and national policy allows for development to be reduced where valued landscapes can be damaged (NPPF, Paragraph 11).
  • Why hasn't Tunbridge Wells assessed the harm that cumulative development can do to the AONB landscape and its communities, and argued for no further housing?
  • The road is dangerous and cannot cope. We complained to the highways Agency for cars in ditches outside my home when no action has been taken and it is dangerous for children at Dulwich School - we and other residents live right on the road so are at risk of fatalities with further road traffic
  • Cranbrook public services etc cannot cope
  • There are more appropriate areas to build this housing
  • environmental and ecology impact. A very rare albino badger was killed on the road outside the proposed development - this is only going to get worse: building on land which is designated an ANOB - This land is being built on Buckhurst t Farm the old gardens of Gaia run by the Bartlett family for many years and preserved by them. The land is full of rare birds, snails, fauna, bats and fauna. This includes Cranbrook's first breeding Buzzards, Tawny, Little and Barn owls and resident woodcocks.
  • 6ey risk of being near sewage works and water level - those fields are waterlogged and run off will be damaging
  • Just too far from the town and infrastructure to support this just not here
  • affordability - if the 60 houses at not currently Sissinghurst are not selling who can afford to live in the Angley or these houses as there will not be sufficient affordable housing where house prices are far too high for my working families.

DLP_5002

Dereen Bartlett

Object

My family owned the land from 1958 for 50 or so years. It has been farmed continuously for a long time before that. Though the land is not of the highest grade it is none the less good as grassland and we have a large population to be fed in this country! We lived in Paddocks Farm on the Golford Road for many years and we know that the Golford Road is very busy especially at the start and finish of school hours. The traffic moves quickly and would not allow much time for cars emerging from the site to join the general traffic. There are also public footpaths, which cross the field which are used by dog walkers and others regularly.

As to the road itself it has a dangerous bend when heading for Cranbrook and general congestion at the T junction on entering the town. Going in the other direction if people are commuting, Chapel Lane is narrow and the T junction at Sissinghurst is always very congested. For pedestrians there is no footpath to speak of and the road edge has ditches in several places.

More than anything it is unfair on the people who live opposite. They have been used to a certain amount of quiet with far-reaching views across countryside. That will be lost for them completely. The speed of change in our parish’s towns and villages is far too quick in my opinion. The roads and infrastrucure cannot deal with it and the sense of this being the English countryside is being eroded at a fast pace.

DLP_6127

Cranbrook & Sissinghurst Parish Council

Object

Major development sites allocated in the AONB ignoring Tunbridge Wells own policy set out in the draft Local Plan, its AONB Management Plan and the draft Parish Neighbourhood Plan to focus development on small-scale sites.

DLP_6129

Cranbrook & Sissinghurst Parish Council

Object

Objections are based primarily on the suitability of building houses adjacent to an already overstretched Sewage Works, on environmental grounds, and on road safety grounds. In addition, the proposed development contravenes several TWBC core policies and Assessments.

Northern boundary (adjacent to Crane Brook) is classified by Environmental Agency as Flood Zone 3b. Adverse impact on use and enjoyment of 2 PROWs, one being a section of the High Weald Landscape Trail.

DLP_7650

Mr J Boxall

Object

I object to this site being included in the TWBC Local Plan due to:

  • It is contrary to the draft Strategic objective 6 as building here will impact on the AONB and the important environment of the Crane Valley
  • It is contrary to the draft Policy EN18 as it is in the AONB and will impact on this area due to additional lighting and urbanisation of the area
  • It is contrary to the draft Policy EN20 as it will not protect current dark skies in the AONB
  • It will damage the local sense of place so is again contrary to the draft policy EN20
  • It is contrary to the draft policy EN21 as it will impact on the AONB
  • It is contrary to the draft policy EN10 as it give additional outdoor lighting in the area
  • It is urbanising the local sense of so is again contrary to the draft policy EN20
  • It is not only outside the Limits to Build but the Local Plan even states that it is detached form the Limits to Build so should not be developed.
  • It is contrary to the draft policy EN22 which prevents development on best and most versatile agricultural land.

DLP_7320

Mr Richard Gill

Object

Policy Number:  AL/CRS 7 Golford Road 

I object to the allocation of land for housing at Golford Road. This site is detached from the LBD and is a major development of 150 dwellings within the AONB.  It is inappropriate and does not meet the sequential tests of NPPF Paragraph 172 where great weight should be given to conserving the landscape and scenic beauty. The severe constraints are detailed in the High Weald AONB Unit’s site assessment in their response to the Draft Local Plan. These fields are part of the historic farmland and provide the approach and setting to the historic medieval market town of Cranbrook. Development would create an urban edge to the settlement which is contrary to AONB Management Plan and totally inappropriate for such an important historic farmstead and landscape.

The agricultural land is Grade 3 and development is contrary to Policy EN11 which specifies net gains for nature: biodiversity.  It is adjacent to the sewage works and there is land contamination. It is within Flood Zone 3.

There are highway safety issues with vehicular access and increased car use would add to congestion and pollution.  It would also have a detrimental effect on traffic flow and congestion along the road to The Hill and to the junction of Stone Street and Waterloo Road and negative impacts on the Conservation Areas and heritage assets.

DLP_7298

Dr Nick Vinall

General Observation

My background

My wife and I have lived at the above address since 1982. It is situated about 200m along the road from CRS7 towards Cranbrook centre. We are therefore very familiar with local issues such as traffic, the Sewage Works, walking the Crane Valley, across local fields and along the road.

We do not per se have outright objections to any development on the site but the scale of the proposed development (150) houses does cause us to raise objections about the suitability of the site for several reasons given below. A smaller scale development that pays regard to the various issues raised below would be considered acceptable.

1. Traffic

1.1 Congestion, particularly at school-run times. With Dulwich Prep School to the east of CRS7 and two secondary schools, one primary and one pre-school within Cranbrook town there is always congestion at the T-junction between The Hill and Waterloo Road. Policy AL/CRS 7, Point 2 recognises this issue and requires a Highway Assessment. Quite rightly. But even before the morning school-run there are delays at the above T-junction due to working people driving to Tunbridge Wells, Maidstone and the train station in Staplehurst. Some try to avoid the problem and drive via Golford and Sissinghurst but then hit delays at the T-junction where Chapel Lane meets the A262 opposite the Milkhouse pub.

This T-junction also needs to be included in the proposed Highway Assessment.

1.2 Road Safety Golford Road (officially a rural lane) runs past the site and when travelling from the east it is unrestricted for speed until it narrows just before two dangerous bends at the western end of the site. At the apex of the first bend is the access road to the Sewage Works with large tankers entering and leaving. The potential for accidents is obvious especially when the 297 bus, a farm tractor or other large vehicle is also on the bend. At the western end of the bend the verge to the north slopes down steeply and to the south there is a large pond. The road here is only 5.30m wide. Steel safety rails are in place but these get damaged quite frequently by traffic, either being forced over by oncoming large vehicles or because they have entered the bends while travelling too fast.

TWBC recognised the dangerous situation. In 1993 the Sewage Works applied to increase the quantity of liquid waste tankered in from outside. TWBC objected [1 Planning response TW/93/01090] on the grounds of highway safety and environmental concerns. As a result the Sewage Works was limited to an extra one tanker per day 2 [ Planning decision TW/92/00399, condition 5].

Since then the road has not changed but traffic has increased considerably especially at school-run times, partly due to the successful expansion of Dulwich Prep School.

The extra vehicles from 150 houses on the site, many no doubt with school-age children, will only make the situation worse.

1.3 Pedestrian safety The Draft Local Plan (Policy AL/CRS7, item 4) requires pedestrian links between the site and the centre of Cranbrook. This is obviously desirable for both health and environmental reasons. But there is a serious bottleneck for which nearby residents have been told by TWBC that there is no scope to improve. Along the southern edge of Golford Road is a narrow footpath, some of it poorly maintained. At its narrowest (by a lampost) the pavement is only 70cm wide with a 12cm drop to the road surface. A small pushchair can get through on the footpath but not the modern larger style versions. For a wheelchair or mobility vehicle user it is impossible and only a suicidal lunatic would risk taking such a vehicle onto the narrow road around the bends.

Only the most determined walkers from the site would make the trip to Cranbrook on foot, the others feeling much safer to use their car thus increasing traffic.

2. Sewage Works

2.1 Siting Planning rules require that ‘plants for treatment of waste should be constructed as far removed from human habitation as possible’. The siting of the Sewage Works is considered reasonable in that:

  • It is outside the Limits to Built Development

Crane Brook runs close by for the discharge of treated water · It is to the east of Cranbrook so the prevailing south-west wind tends to disperse the inevitable odours across agricultural land. It is very noticeable that when the wind is from the east unpleasant odours are often detected across Cranbrook.

The CRS7 site is not only immediately adjacent to the Sewage Works but also to the east of it so is downwind for much of the time. The Draft Local Plan, Policy AL/CRS 7, point 7 does recognise this aspect by requiring the undertaking of an odour assessment.

2.2 Capacity The increase in Cranbrook’s population means that the Sewage Works is already at its maximum capacity of 9995. The TWBC housing policy strategy for Cranbrook and Sissinghurst (STR CRS 1) is for an extra 800 – 900 dwellings. At an average of 4 persons per dwelling this would increase the sewage capacity requirements by at least 3200 ie 32%. Significant enlargement will be needed at the Sewage Works.

The Sewage Works is allowed to discharge treated water into Crane Brook and also untreated but screened water in times of stress. But there have been a number of overflow incidents where fish have been killed downstream in Crane Brook and the company has been fined.

Enlargement of the Sewage Works will result in more tanker movements, greater environmental and flood risk in the Crane Valley and likely increased release of odours.

2.3 Flood risk Crane Brook runs along the north edge of the CRS7 site where the ground slopes down into the valley. The area has an Environmental Agency rating as Flood Zone 3b ie a flood plain where water has to be stored in times of flood. The flooding can be caused either by run-off of heavy rain from site CRS7 or by heavy discharge from the Sewage Works.

The flood risk is exacerbated because the ground under the top soil of CRS7 is heavy clay which is almost impervious to rain. Walkers in the field know that after significant rain the soil quickly becomes very squelchy as the water oozes down the slope into Crane Brook. This is typical of the area, including my garden and Scott Field adjacent to the Sewage Works. If 160 houses are built on the CRS7 site the soakage area will be reduced by 50% or more and the problem will be significantly worsened. A ground soil survey should be included in the list of requirements for Policy AL/CRS7.

The KCC Flood History DA03 reports ‘regular flooding of Golford Road’. This occurs at the low point of the road immediately to the west of CRS7 and can be a serious hazard for traffic.

The Strategic Flood Risk Assessment (SFRA) document, Table 4-2 identifies a fluvial flood problem area due to backing up of Crane Brook between the culvert under the Tanyard car park and Bakers Cross ie the Sewage Works. This occurs when heavy discharge from the Sewage Works into Crane Brook, or heavy rain, causes its level to rise so that flow from the west is restricted. Section 10.1.2 also identifies this area of Cranbrook as being prone to flooding due to overloading of the sewage system. SFRA Table 11-1 recommends that a further Flood Risk Assessment is carried out when considering developments in the area. This SFRA must be added to the requirements identified in Policy AL/CRS7. It is a serious omission not to be included.

3. Environmental aspects

3.1 Badgers It is reported that the CRS7 site has several badger setts. I haven’t personally seen them there but they are common on Scott Field, adjacent to the Sewage Works, and I fight a losing battle trying to keep them out of my back garden.

3.2 Great crested newts The TWBC Biodiversity Evidence Base for the Draft Local Plan confirms that these amphibians have been recorded at site CRS7 and Southern Water has recorded groups of them along the Crane Valley downstream from CRS7. They are present near the pond on Golford Road, almost opposite the Sewage Works driveway, and my neighbour also sees them most summers at Millfields, Bakers Cross, close to the Crane Valley and Sewage Works. It seems likely that their presence is fairly ubiquitous in the area.

It is clear that the list of requirements in Policy AL/CRS7 should also include a survey of these protected species, and possibly others.

3.2 Crane Valley corridor TWBC policy [1 Draft Local Plan Policy STR/CRS 1 point f.] is to develop and improve the Crane Valley path both eastwards and westwards (towards Cranbrook) thus “providing an improved green route into the centre of

Cranbrook”. 2 [ Draft Local Plan Policy AL/CRS7 point 5]

This is admirable to give public access to a green route with biodiversity and ancient woodland. But it is already often squelchy walking and increased flooding in the Crane Valley may make walking impossible. A high level hard path will need to be built.

There is a serious mismatch between this desirable policy and the enhanced flood risk in the Crane Valley that the development of 150 dwellings at CRS7 will bring.

4. Non-compliance with TWBC’s own adopted strategies and assessments

There are several aspects to the proposed development at CSR7, or consequences of them, that directly contradict TWBC’s Core Strategy. These include:

4.1 Flood Risk TWBC states: “All developments will be expected to be outside of the Borough's high risk flood zones (and) produce no negative effects on existing flood patterns”. 1 [ Core Strategy (adopted 2010), Core Policy 5: Sustainable Design and Construction ]

This is clearly at odds with the likely situation after development at CRS7.

4.2 Housing within AONB TWBC rightly recognises that the whole of Cranbrook is within the AONB and that this brings special responsibilities for preservation when considering developments. Several paragraphs attest to this:

4.2.1 para 5.253 “The Borough Council will conserve and enhance the built environment and have high regard to landscape designations, which have particular importance due to the AONB washing over the whole of the settlement.”.2 4.2.2 para 5.255 “ Within Cranbrook, housing delivery will encompass small-scale market and affordable housing development that will both encourage the delivery of homes to meet local needs and create mixed and viable communities.” 2 [ Core Strategy (adopted 2010), Core Policy 12: Development in Cranbrook ] This means evelopments shall be small scale and in keeping with the locality.

Yet their own assessment states: 4.2.3 For CRS7 “the proposed housing density is considered high for this site given its sensitive landscape and edge of settlement location. The site would suit low density, farmstead style development”. 3 [Strategic Housing and Economic Land Availability Assessment for Draft Local Plan July 2019 ]

A smaller, low density development would give greater compatibility with all the issues raised above.

4.2.4 Filtering of sites proposed for allocation state “sites that were poorly related to existing settlements or had significant environmental concerns were not deemed to be reasonable alternatives”. 5 [Sustainability Appraisal of the Draft Local Plan, September 2019, p3 Sites proposed for allocation ]. The proposed 150 dwellings site CRS7 clearly causes significant environmental concerns. Yet it has not been excluded from the allocation list. Perhaps this was an oversight because it was a Late Site?

4.2.5 Policy STR/CRS 1 states that “Any major development larger than approximately 100 residential units on greenfield windfall. sites is expected to provide suitable employment floor space” CRS7 (Late site 32) was put forward for consideration after the much larger CFS3_22 (Late site 22), of

which it is a part, was considered unsuitable in July 2019. CRS7 is a likely windfall site 6 [ Core Strategy (adopted 2010), Glossary and Abbreviations defines windfall sites as: “Sites that have not been specifically identified as available through the planning process but have unexpectedly become available…….….”. ] that requires employment floor space yet no mention has been made of this aspect. It requires urgent attention.

Summary I object strongly to a development of 150 dwellings at site CRS7. It would be completely at odds with the sensitive nature of the surrounding area and would have a seriously detrimental effect on traffic, road safety and environmental aspects including increased risk of flooding.

I would have no objection to a low density, farmstead style development, as suggested by TWBC in 4.2.3 above.

DLP_7234

Elizabeth Daley

Object

Policy Number: AL/CRS7

This proposed major development is in AONB and development on this scale in AONB contravenes NPPF.

It is also outside the LBD and within greenbelt, all of which are contra-indicators for development.

DLP_7047

Philippa Gill

Object

Policy Number:  AL/CRS 7 Golford Road 

I object to the allocation of land for housing at Golford Road. This site is detached from the LBD and is a major development of 150 dwellings within the AONB.  It is inappropriate and does not meet the sequential tests of NPPF Paragraph 172 where great weight should be given to conserving the landscape and scenic beauty. The severe constraints are detailed in the High Weald AONB Unit’s site assessment in their response to the Draft Local Plan. These fields are part of the historic farmland and provide the approach and setting to the historic medieval market town of Cranbrook. Development would create an urban edge to the settlement which is contrary to AONB Management Plan and totally inappropriate for such an important historic farmstead and landscape.

The agricultural land is Grade 3 and development is contrary to Policy EN11 which specifies net gains for nature: biodiversity.  It is adjacent to the sewage works and there is land contamination. It is within Flood Zone 3.

There are highway safety issues with vehicular access and increased car use would add to congestion and pollution.  It would also have a detrimental effect on traffic flow and congestion along the road to The Hill and to the junction of Stone Street and Waterloo Road and negative impacts on the Conservation Areas and heritage assets.

DLP_7119

Nigel Tubman

Object

Policy Number: AL/CRS 7 Land off Golford Road

I object strongly to this proposal. Not only is it in the AONB but it is also outside the Limits to Built Development (LBD). If AONB and LBD are to mean anything, they must be protected from housing development and, in particular, highly unsuitable ones such as this.

Cranbrook is a rural small town and an important feature of this particular town is that the approach to the town along the road from the east is particularly scenic looking to the north and west and emphasises its agricultural roots with annual crops of cereals and brassicas etc.

This site is surrounded on 4 sides and divided in half by important bio-diversity spaces provided by trees and shrubs and hedges and 2 sides of the site have streams. These spaces provide protection and feeding (there are numerous trees (especially some fine oak tress) and shrubs providing berries) for a wide variety of birds, insects, amphibians, badgers and foxes. It is an important nesting site for migratory and non-migratory birds. There are a large number of different types of owls in the area as well as buzzards, woodpeckers, and the occasional kingfisher etc. Sustainable colonies of great crested newts are in the area and no doubt exist within the proposed site. Grass snakes and slow worms are also present in the area and Great Swifts Manor Estate erected a sign a few years ago warning people about the danger of numerous adders in the woodland by the public footpath leading to the footbridge a hundred yards east from the footbridge near the treatment works. The map for this proposed development indicates that the existing hedge and woodland dividing the site will be removed which would have a serious impact on local wildlife as it provides a much needed route for animals as well as feeding and protection for wildlife etc. Is the 25 metre buffer zone in addition to the existing woodland? There would be a serious threat to the bio-diversity of the area is 150 houses and 500 people were placed in the immediate vicinity.

The draft plan talks about active travel. The public footpaths are in constant use and provide important access to the countryside right on the doorstep of Cranbrook. It is used by walkers including people walking their dogs, runners and joggers, and people who want to enjoy the bio-diversity that the area provides. It is regularly used by people walking to and from Sissinghurst and by visitors to the town who want to ‘get out into the countryside’.

The fields that form CRS 7 (the site and surrounding fields and woodlland) experience practically no light pollution and the night skies are amazing and that is mainly because the lights of Cranbrook and Sissinghurst are hidden by trees. In particular, the road from Golford cross roads towards Cranbrook provides a great vista generally but as the sun sets, stars and planets become visible quite early on and then later as it gets dark, the skies are rather special. Building 150 houses with their associated lighting will spoil if not eliminate this amazing part of the natural world.'

The roads and footpath linking this site to the town are very poor and it quite dangerous for cyclists, pedestrians as well as car drivers. Car drivers often cut the corner coming into Cranbrook and near misses are a regular occurrence. It is particular dangerous at school commuting times. The volume of traffic has increased rapidly in recent years aided by the constant flow of delivery vans many of which find it difficult to find the address they are looking for. Sewage lorries use the entrance constantly taking waste to the treatment works that includes a public right of way and more people and more cars etc would make the route even more dangerous.

Expecting people to walk into Cranbrook from the site either along a new footpath along the Crane or along the road is unlikely to come to fruition. Most parents taking their children to school are always going to take the car thus adding to the danger to other road and pavement users as well as adding to the congestion at the junction at Waterloo Road/Stone Street.

The only part of the proposal that I would support is the provision of a football pitch and clubhouse for Cranbrook Town FC although there are more suitable locations for a pitch in other parts of the town.

DLP_5941

S J Ireland

Object

The proposal takes no account of the particularly splendid views of the High Weald from the footpath between Cranbrook and Sissinghurst (from Waterloo road)  and part of the High Weald Landscape trail. The view presents the local Windmill well, with great long views across wooded High Weald landscape, with just a few agricultural buildings. The only time the sewage works is particularly visible is when the orange street lighting has been left on by error ( The works are aware). Creating a substantial housing development will have a major impact on this view.

DLP_5982

Steve Rix

Object

Policy AL/CRS 7 (page 214) I object to the allocation of land for housing for the land off Golford Road. It is detached from the LBD, represents a substantial amount of AONB designated land and is within Flood Zone 3. It also sets a precedent for development of the parish to the East which is not in keeping with historic settlement patterns.

DLP_6050

Laura Rowland

Object

Major development is not appropriate in the AONB. TWBC have accepted that Golford Road is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

The Golford Road site is misnamed. These fields are part of an essentially, agricultural landscape separated from Cranbrook by a natural barrier. The site is bounded along half of its length by ancient woodland which surrounds the Crane and its tributary (The impact on ancient woodland is not mentioned in the Distribution of Development Topic Paper, site assessment, Appendix 3). The fields provide the setting for historic farmsteads which lie along an ancient routeway (now Golford Road) and were served by Cranbrook town which was established later. Allocating this site would allow urban development to jump a natural barrier and materially change the character of an essentially agricultural area typical of the High weald AONB.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving, i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that ‘visual containment’ will mitigate harm to the AONB. This is not the case. The traditional building component of the AONB landscape is part of what makes the area outstandingly beautiful. It is the setting of these buildings in an essentially medieval landscape rich in wildlife that makes it national important. Destroying the fieldscape that provides this setting is not mitigated by planting a screen.

DLP_6152

Turley for Taylor Wimpey UK Ltd

 

As set out in our comments to Policy STR/CS1, our client instructed landscape consultants CSa to independently assess SHELAA Site 25 and compare this with draft allocation sites CRS6, CRS4 and CRS7 (see Document C). The conclusions highlight landscape impacts in respect of CRS6, CRS4 and CRS7 that appear to have been understated and/or inconsistently assessed and compared with those arising from Site 25.

For example, draft allocation CRS7 is in the AoNB, detached from the urban area and was categorised in the Council’s own landscape assessment [4 Landscape Sensitivity Assessment of Additional Settlements in Tunbridge Wells (Paddock Wood, Horsmonden, Hawkhurst and Cranbrook), LUC, July 2018. ] as having a ‘strong separation from adjacent settlements’ and being ‘very sensitive to any strategic development’. The western half of Site CRS7 is also stated as playing ‘a significant role in the setting of the Cranbrook Conservation Area’. Yet, unlike the assessment undertaken on Site 25, the SHELAA seeks to assess different densities and forms of development that may be acceptable in this location. The SHELAA concludes that whilst the site is detached from the settlement, it lies in proximity to it, has pedestrian access to the centre of Cranbrook and is likely to be sustainable in this context. SHELAA Site 25 is conversely attached / part of the settlement, contained by existing landscaping and has arguably better pedestrian access to the centre of Cranbrook. It is therefore unclear how the Council concludes that Site 25 is not sustainable in this context. Our client can only assume that the Council have not accounted for the evidence highlighted in this letter, including that now confirmed regards a suitable access and landscape containment credentials. Our client contends that had such evidence been accounted for, the SHELAA and SA would have concluded that Site 25 is a logical, suitable and sustainable integrated extension to Cranbrook. One that has notable advantages over one or more of the alternatives proposed at CRS6, CRS7 and CRS4 and should be ranked sequentially higher on its sustainability credentials as a consequence.

Our client therefore respectfully requests that TWBC reassesses the benefits of this modest site in liaison with the Parish Council and Neighbourhood Plan Steering Group as soon as possible.

DLP_6304

Susan Heather McAuley

Object

This site should not be included.  It is outside and is far enough away from the main settlement of Cranbrook that it will create a large amount of extra car use onto a fairly quiet road.  The other side of the road is inhabited by separate, disparate detached dwellings and if there were to be any building on this site at any time in the future it should be in a similar style, matching the rest of this approach into Cranbrook.

DLP_6546

Diana Badcock

Object

This site, east of Cranbrook, adjacent to the sewage works, is totally unsuitable for development. It is within Flood zone 3. Car traffic would have to negotiate the already congested bottlenecks of the centres of Cranbrook & Sissinghurst in order to travel e.g. to employment, west to the expanded employment area at North Farm Tunbridge Wells, or to reach the A21 or drive to Staplehurst station.

Although the walking distance is small, the road into Cranbrook is already positively dangerous for pedestrians (including children walking to school), and sewage tankers drive in and out of that road regularly.

It also sets a precedent for development east of the parish which is not in keeping with historic settlement patterns.

DLP_6893

Stuart & Emily Cleary

Object

This proposal is a bad idea. The land can’t sustain this development and the houses will be un-insurable to residents. The traffic will be terrible and it will be an ugly “white elephant”. An embarrassment to everyone involved. Flooding, smelly and isolated by poor road services. Surely this planning for Cranbrook must try to improve what’s already there? The existing spaces for infill on the other sites are the best option; that’s why they were thought of first, unlike this late outsider of an idea.

Basis of objection to “Late site 32” of AL/CRS7

We have lived at Springden since 1966. We object to the plan because of the lack of sustainability for building 150 houses next to a sewage works in a known flooding valley area opposite a cemetary . The road is already clogged by traffic and the pathways aren’t safe to walk on now, let alone with hundreds more people having to use it. The plan contravenes TWBC core policies and there are more suitable parts of Cranbrook to build on than this area of outstanding beauty.

Road Safety:

Currently, the walk from Golford to Cranbrook is quite dangerous, we wouldn’t allow our kids to use the winding path on their own because cars drive quickly around the bends without thinking of pedestrians. When you meet someone coming the other way, one has to step onto the road in order to pass. Just imagine this being clogged with people trying to get to Cranbrook? They won’t use it for fear of getting run over. The only option will be to drive, and in doing so will hit the morning traffic jam that already exists, backing up from the junction in Cranbrook Stone street back to Bakers Cross at the top of Golford. This is always busy throughout the whole day because of the traffic joining from The Fryth Estate, the Benenden Road, Tanyard carpark, Cranbrook School and Stone street. Also, a lot of people going through Golford or Cranbrook to try to avoid Sissinghurst, which you lot have already totally ruined by poor planning decisions!

CRS7 Should not be built right next to a sewage works at the limit of its capacity. Those of us who live there are used to the regular smells emanating from the open sewage tanks, but surely this has to be a big reason for it to be withdrawn as a planning option. All my life I have heard that the price of having a nice rural view from our houses was living near the sewage works, we accept this as much as we accept the septic tank suck-lifts lorries driving by every 10 minutes. Other submissions have gone into more detail than ours, but it’s just wrong. It will back-up, flood and stink!

It’s a stupid place to consider for loads of houses. You would concrete all over the fields and create a big open sewer. Ridiculous!

The land is teeming with rare wildlife; loads of adders, bats, newts (Great Crested), badgers and birds. These are the natural inhabitants of CRS7 and they should remain so.

We at Springden won’t be around for ever, but if you decision makers want to condemn the inhabitants of 150 little un-insurable houses on a flooding valley next to a sewage works with little or no means of free movement into the nearest community, with the only happy person coming out of this being the already rich owner of the stately home of Great Swifts. And if you are prepared to be blamed by everyone for pushing through the wrong site of CRS7 instead of pre-chosen better existing plots, then shame on you.

This wrong decision won’t sort itself out, it will always be the wrong decision. Don’t pick this site.

DLP_6940

Hallam Land Management Ltd

 

These representations are submitted by Hallam Land Management Limited (Hallam). Hallam is a strategic land promotion company operating throughout England, Wales and Scotland, delivering land for new employment and commercial, housing and mixed-use developments.

Hallam are in agreement with the Council that Cranbrook should be identified as a sustainable settlement for additional growth in the Draft Local Plan, having scored the most sustainable settlement within the ‘Settlement Role and Function Study – February 2017’ outside of Royal Tunbridge Wells and Southborough. Furthermore, within the ‘Issues and Options Consultation – June 2017’ Cranbrook was identified for growth in Option 1 (Focused Growth), Option 2 (Semi-Dispersed Growth) and Option 3 (Dispersed Growth).

Hallam are working with the landowner of ‘Land off Golford Road’ Policy AL/CRS 7 which is identified for allocation for residential development (C3) providing approximately 150 dwellings. Cranbrook is the pre-eminent settlement in the Borough and, reflecting its role and function as a sustainable settlement, Hallam support the focus for new development in the Draft Local Plan. Further development in this location would contribute to meeting the future needs of the Borough, whilst achieving a sustainable pattern of development.

DLP_6949

Hallam Land Management Ltd

 

Table Number: AL/CRS 7

As referenced already in our representations Hallam are working with the landowner of ‘Land off Golford Road’ Policy AL/CRS 7 which is identified for allocation for residential development (C3) providing approximately 150 dwellings. We will be continuing to promote the parcel of land through the Local Plan Review and will bring together a full technical package of information which will enable to development to meet the requirements within the policy.

DLP_7372

Andrew Ford

Object

Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

  1. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
  2. the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
  3. any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.

TWBC have accepted that Golford Road is major development but have not explained how the sequential tests required by para. 172 have been met. This policy is therefore, not justifiable.

Major development of this scale is not appropriate in an AONB. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

The Golford Road site is misnamed. These fields are part of an essentially, agricultural landscape separated from Cranbrook by a natural barrier. The site is bounded along half of its length by ancient woodland which surrounds the Crane and its tributary (The impact on ancient woodland is not mentioned in the Distribution of Development Topic Paper, site assessment, Appendix 3). The fields provide the setting for historic farmsteads which lie along an ancient routeway (now Golford Road) and were served by Cranbrook town which was established later. Allocating this site would allow urban development to jump a natural barrier and materially change  the character of an essentially agricultural area typical of the High weald AONB.

The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The ‘how’, i.e. the conserving, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3.

DLP_7404

Robin Douglas

Object

I am writing to object to the potential development of land off Golford Road near Cranbrook (SHELAA reference: Late Site 32).

I live 500 metres from the proposed site of development in The Hill which turns into Golford Road as it goes East out of Cranbrook and I regularly walk my dog on the public footpath that skirts the western boundary of the site.

I am greatly saddened and annoyed that yet another part of our beautiful and historic countryside that lies within an Area of Outstanding Natural Beauty is potentially going to be built on.

My objections are based on the following points.

  1. The unsuitability of building houses adjacent to sewage works, on environmental grounds and road safety.
  2. Risk of more flooding as the built-up area will soak up less rainwater thus it will run into the floodplain into which the treated water from the sewage works is discharged and which already floods every year and remains under water for most of the winter.
  3. With an additional 150 houses on the site, the existing sewage works will be unable to cope with the increased volume of sewage needing to be treated so that untreated raw sewage will be discharged into the stream. This is an environmental hazard for wild animals and birds and is completely unacceptable in this AONB.
  4. I currently use the existing inadequate, narrow pavement to access the site from my house when walking my dog. On the bends between Bakers Cross and The Firs in Golford Road, the pavement is barely wide enough for one person and unsuitable for a mobility scooter. I have been clipped by wing mirrors of vehicles on the road and take my life into my own hands when crossing the road to gain access to the public footpath the other side of the road.

This pavement is completely unsuitable to provide pedestrian access for large numbers of adults and also children going to school in Cranbrook on a daily basis. It is only a matter of time before a fatal accident occurs here and there are already numerous vehicle accidents that have happened here as vehicles are driven too fast despite the 30mph speed limit, particularly during school runs as this is a major access route to Dulwich Preparatory School in Golford Road.

I object to you granting planning approval for this ill thought out development and the deeply damaging consequences this development will have on our beautiful countryside in an AONB and the legacy it will leave for future generations.

DLP_7717

Mr & Mrs Groom

Object

OBJECTION:

As residents on the Golford Road, we regularly use the road into Cranbrook and walk along it’s rural footpaths. We have a number of serious concerns regarding road safety, the location of nearby listed houses, the impact on both the environment and its wildlife, together with the questionable suitability of locating new homes next to an already overwhelmed sewage plant.

A) SAFETY

i) Pedestrians access to Cranbrook:

The current access for pedestrians wishing to walk into Cranbrook is very narrow. Our son used to walk to school, but we quickly realised that it was far too dangerous for him to do so. The pavement adjacent to the pond (below Tilsden Lane) is not only narrow, but regularly floods. I have witnessed cars aqua-plaining across the water. In addition, the pavement stops at Fir Tree Farm and thereafter there is only a verge which runs adjacent to a drainage ditch. It often becomes waterlogged and those pedestrians who choose to walk, have to do so in the road.

ii) Pavement width:

The current width of the pavement is only 50cm. The width should be a min. of 200cm under normal circumstances or 150cm if physical constraints prevent this or 100cm if there is an obstacle (Dept of Transport). This minimum is only achieved when overgrown brambles etc. have been cleared, but for most of the year it is 50cm or less. The Council have repeatedly told residents that it cannot be widened. As a result, we no longer allow our children to walk to school, so we add to the congestion by using the car to travel into Cranbrook.

iiiVehicular access to Cranbrook/Staplehurst

For those residents who drive to Cranbrook via Golford Road to access its schools, we have to negotiate the narrow approach road with parked vehicles to the right-hand side. Due to the congestion at the Waterloo and Stone Street T-junction, I have to drop my son at the school 40 minutes before he needs to be there.

For those needing to continue into Cranbrook town, the access is via Stone Street which is an extremely narrow road, which is only wide enough for two small hatchbacks to pass (and certainly not the usual 4 x 4's). Some cars attempt to pass one another, but one inevitably has to mount the (extremely narrow) pavement.  Despite being a supporter of local businesses, I avoid coming into the town to shop because of the access problems. Increasing traffic here would exacerbate the situation and cause further safety issues for both road user and pedestrian.

With the nearest train station in Staplehurst, most cars would normally travel via Waterloo Road, but due to the congestion, most travel via Golford Road and Chapel Lane into Sissinghurst.  There are regular accidents at the Golford Road crossroads. The most recent collision resulted in a car flipping onto its roof.  I have also observed a number of near misses and approach the site with caution every day. The approach from Chapel Lane to The Street in Sissinghurst already has severe traffic problems regardless of the time of day. The road is narrow and residential cars park on both sides of the highway, making it difficult to proceed.

iv) Traffic speed

Golford Road is a designated rural lane.The speed limit near the proposed site is 30mph, but drivers travelling along the Golford Road towards Cranbrook rarely obey this.

v) Road width

The Golford Road narrows significantly as it approaches Cranbrook (particularly on the bend above Tilsden Lane). The railings are regularly dented and buckled where cars have collided, and many road users do not observe the speed limit. Buses and other wide vehicles frequently use the road and approaching vehicles have to mount the pavement to negotiate. I have witnessed cars almost colliding with wider vehicles and, even more worrying, I have seen a pedestrian forced to pin themselves against the railings to avoid being hurt.

We understand that the Dept. of Highways objected to the expansion of the sewage plant some years ago. The reasons sited were that the width and visibility of the rural approach roads were unsuitablefor the increase in traffic.  It was ruled that the proposal was unacceptable on highway safety grounds. TWBC itself raised objections, including the unacceptable impact of additional traffic movements on highway safety. 

B) SEWAGE WORKS:

Living further along the Golford Road, our boundary abuts Crane Brook and the ancient wood known as Plantation Wood. Treated water from the sewage works is discharged into the brook which sustains much aquatic life, including the Great Crested Newt.

It is well documented that the current Sewage Works is already at its maximum limit, with excessive effluent being stored in overflow tanks and with some screened effluent having to be discharged into Crane Brook. Should CRS7 go ahead, the Sewage works will not be able to cope with the additional effluent generated from an increase in properties.

C) FLOODING:

The field on the site of the proposed development is located in a flood zone and is usually waterlogged for much of the winter. Even if houses were sited above the floodplain, water will run down into it and further impact the discharge of sewage.

As a result of flooding in 2010, raw sewage was discharged into Crane Brook. A number of fish died and the impact of the discharge was observed as far away as Biddenden.

D) AONB & WILDLIFE:

In addition to the already documented Great Crested Newts and Badgers on the site of the proposal, we have personally observed Long Eared Bats (photo enclosed), which has been verified by the UK Bat Care Network.

The agricultural fields adjacent to the Golford Road support a number of wildlife species and should be preserved at all costs. The fields and hedgerows provide a natural barrier and changing this would fundamentally alter the character of this AONB. 

E) LISTED BUILDINGS:

There are a number of listed buildings along the Golford Road. The setting of a listed building is an essential part of the building’s character. These buildings contribute to the landscape and their surroundings produce a visual harmony which enriches the setting of the landscape. Development proposals can have an adverse affect on the listed buildings setting, particularly if it affects views, which CRS7 would.

The majority of the homes along the Golford Road are only one storey high. These low impact homesteads are all on the opposite side of the proposed site and are far more suitable for this type of landscape.

PHOTO OF LONG EARED BAT TAKEN IN WOODLAND 10/11/2019: [TWBC: See image of bat]

DLP_8427

Emy Lucassen

Object

Land off Golford Road (SHELAA reference: Late Site 32)

This is incorrectly described as ‘Land off of Waterloo Road’ in the sustainability appraisal [1 Sustainability Appraisal of the Draft Local Plan for Regulation 18 Consultation September 2019 - p186] and in the Strategic Housing and Economic Land Availability Assessment for Draft Local Plan [2 Strategic Housing and Economic Land Availability Assessment for Draft Local Plan July 2019.]

Background and context

CRS7 is in an AONB outside and is detached from the LBD in Cranbrook. It is an extraordinarily beautiful spot, much loved by dog walkers and ramblers, traversed by 2 public rights of way, one of which forms part of the High Weald Landscape Trail (145 km from Horsham to Rye).

We have lived in Golford Road since 2009. Our property faces the agricultural land in question and is the closest property to its access point via the lane to the Sewage Works.

Basis of Objection

We object to the development at CRS7. Our objections are based primarily on the suitability of building houses adjacent to an already overstretched Sewage Works, on environmental grounds, and on road safety grounds.
In addition, the proposed development contravenes several TWBC core policies and assessments.

While we accept that the UK needs new houses, we cannot see that building houses adjacent to a Sewage Works, which is already so overwhelmed that it regularly floods adjacent houses with sewage, can be sustainable or desirable.

Suitability of site next to Sewage works

CRS7 is immediately adjacent to Cranbrook Sewage Works, which services all of Cranbrook’s effluent, a permitted population of 9995 from properties in Cranbrook and surrounds [3 Planning application 12/02168 – supporting statement.]. These Sewage Works were located outside the limits of built development for good reasons. Within the various planning documents, it is acknowledged that ‘plants for treatment of waste should be constructed as far removed from human habitation as possible.’

As Cranbrook expanded, the Sewage Works have struggled to keep pace, and the resultant smells and noise are well documented. When Cranbrook Sewage Works

applied for planning permission to process 20,000 gallons of industrial waste per week (brought in by tankers), local residents and the two local schools (Cranbrook School and Dulwich Prep) raised the issues of the already existent smells, noise, and traffic problems. Nevertheless planning permission was granted, but a subsequent application for expansion was rejected. TWBC acknowledged the already existent smells, noise, and traffic problems and raised objections including the likely problems of water pollution and odour arising from intensified use [4 Planning application 93/1090 – objections.]. These objections by TWBC are just as relevant to the plans under scrutiny here.

Our neighbours regularly have sewage from the Sewage Works flooding their property. They have raised the issue at every opportunity, and well before CRS7 was submitted, out of concern about the other planned new buildings elsewhere in Cranbrook eg in 2013, one neighbour submitted ‘The sewage facilities are at present inadequate for Cranbrook. We are the last household before the sewage works and have had overflows up our manholes running into sheds and over property - back and front garden.’ I use this example because it includes the response from Southern Water: ‘Southern Water has limited powers to prevent connections. This is the case even when there is insufficient capacity in the sewers resulting in unacceptable levels of service such as sewer flooding.’ [5 http://www.tunbridgewells.gov.uk/data/assets/pdf_file/0010/39871/Response-Report-7_Chapter-6-Cranbrook.pdf]

If sewage flooding into properties is unavoidable, we object to inflicting the same fate on another 150 households.

Environmental impact

Treated water from Cranbrook Sewage Works discharges directly into the Crane Brook, which borders CRS7 to the North, where the site is in Environment Agency's Flood Zone 3b (i.e. it is a functional floodplain, defined as land where water has to flow or be stored in times of flood). The field floods every year and remains under water for much of the winter.

[TWBC: for image see full representation attached].

Assuming that the houses will not be built on the actual floodplain, they will be built above the floodplain where the field slopes up towards Golford Road. This will inevitably increase flooding, as the built up area will soak up less rainwater than the agricultural field currently does, and this water can only run down into the floodplain.

At the same time, the Sewage Works will have to increase its capacity by 20-40% to cope with the additional housing [6 900 houses planned for Cranbrook. Assuming an average four people per house, the resulting population increase would be 3600. Current population served by Cranbrook Sewage Works is 9995 i.e. 36% increase.]. The staff at Cranbrook Sewage Works were unaware of the planned development. They are able to process 30L/s which is already exceeded regularly (often 75L/s) necessitating the use of overflow tanks.
When this system is overwhelmed, discharges of screened sewage (untreated but inspected for unsightly debris) into the stream are allowed.

As well as flooding local properties, flooding adjacent to the Sewage Works has a detrimental environmental impact, for example, in September 2010 raw sewage was discharged into Crane Brook resulting in ‘275 dead fish in the area immediately downstream of the works’. When Environment Agency scientists were called in, they observed the impact 6 miles downstream, in Biddenden. In the ensuing court case, Southern Water attributed the incident to heavy rain ‘when screens that normally filter debris from the waste water become blocked.’ [7 https://www.pressreader.com/uk/kent-messenger-maidstone/20111104/281758446074542 ]

Crane Brook feeds into Hammer Stream, which in turn feeds into the section of the River Beult which is a designated Site of Special Scientific Interest (SSSI), and which is also described as ‘suffering from sewage effluent [8 https://designatedsites.naturalengland.org.uk/PDFsForWeb/Citation/1005993.pdf] .’

As well as being in an AONB, this is an environmentally sensitive area. Crane Brook is ranked as ‘unhealthy’ by the Environment Agency, due to ‘pollution from waste water’ and ‘pollution from towns, cities and transport [9 https://www.wwf.org.uk/uk-rivers-map https://environment.data.gov.uk/catchment-planning/WaterBody/GB106040018290]’. The entire region – including all of Cranbrook and downstream to Sissinghurst, Frittenden, and Biddenden – has been designated a Nitrate Vulnerable Zone by the Environment Agency [10 Nitrate Vulnerable Zones 2017 Final Designations - Hammer Stream NVZ ID 496.]. In addition, it has been designated a Drinking Water Safeguard Zone (surface water) – which is reserved for ‘water sources that are “at risk” of deterioration.’ SEPARATE (SEctor Pollutant AppoRtionment for the AquaTic Environment) analysis shows that sewage treatment works already contribute 11.6% of the total nitrate load per year in this sensitive area, with Cranbrook Sewage Works contributing 5075 kg/year in consented discharge [11 http://apps.environment-agency.gov.uk/static/documents/nvz/NVZ2017_S496_Datasheet.pdf].

A qualified ecologist carried out a survey of protected species around CRS7 in 2012 and found populations of Great Crested Newts less than 250m from Sewage Works. Other protected species on CRS7 include badgers (several badger setts), dormice, water voles, adders and bats.

[TWBC: for image and map see full representation attached].

CRS7 is also in the official Impact Risk Zone of Robin’s Wood and Parsonage Wood SSSI [12 https://magic.defra.gov.uk/MagicMap.aspx and personal communication, Lady Akenhead, Chairman, CPRE Kent Tunbridge Wells District Committee]. In the sustainability appraisal, it states that reference should be made to SSSI Impact Risk Zones. Unlike other sites, no reference is made to the SSSI status of CRS7 in the scoring tables [13 eg the nearby Tilsden Lane site states ‘negative biodiversity score reflects combination of size of site and relative closeness to SSSI.’]

In summary, the combination of Cranbrook Sewage Works adjacent to CRS7 with the annual flooding of CRS7, means a development of this size on CRS7 will have detrimental impact on the environment in this sensitive AONB.

Road Safety

1) Pedestrian access to Cranbrook
The site assessment sheets state that ‘there is pedestrian access to the centre of Cranbrook.’ The pedestrian access referred to is inadequate we have regularly been told that no improvement is possible.
Where it exists, there is a narrow pavement along a treacherous stretch of road. In the other direction it stops at Fir Tree Farm, well before the boundary of CRS7 to the East.
We have had children at the local school in Cranbrook for over ten years. They take their lives into their hands every time they walk into Cranbrook. The issues with pedestrian access are apparently intractable:

a) Width of pavement
The Department for Transport states that the width of a pavement should be 200 cm as the minimum under normal circumstances. Where this is not possible because of physical constraints 150 cm could be regarded as the minimum acceptable under most circumstances. The absolute minimum, where there is an obstacle, should be 100 cm clear space [14 Inclusive Mobility 2002: a guide to best practice on access to pedestrian and transport infrastructure. Department for Transport.].

The width of the pavement on Golford Road, on the treacherous bends heading into Cranbrook, is 70 cm, well below absolute minimum recommended by the Department for Transport. Moreover, this width is achieved only when the nettles, brambles, and other overgrowing vegetation have been cleared. For most of the year, it is less than 50 cm wide i.e. not wide enough for pedestrians to walk safely as cars speed around the bends.
We have repeatedly been told that it is not possible to widen the pavement.

b) Traffic speed
Golford Road is a designated rural lane. The traffic going towards Cranbrook should be at <30 mph, but this is ignored by most.

c) Width of road
The road is narrow on the dangerous bends going into Cranbrook. Each side of the carriageway is well under the width of the school buses, farm traffic and sewage tankers using the road. Vehicles inevitably encroach on the pavement, and the pavement is not wide enough for pedestrians to avoid these.

[TWBC: for image see full representation attached].

d) Flooding
This stretch of road is also prone to flooding (as identified in the Strategic Flood Risk Assessment 2007 [15 15 TWBC Strategic Flood Risk Assessment (2007) Table 4-2: Fluvial Flooding Problem Areas.]) which exacerbates the problems. Large puddles form here, even in light showers, and cars cannot avoid driving through them, inevitably dousing any pedestrians on the pavement.

[TWBC: for images see full representation attached].

We have been writing to the council about these issues since we moved here in 2009. In particular, we have regularly requested that something is done to slow down the traffic and enforce the 30 mph zone which starts outside our home. KCC states that this is not a priority as ‘assessed by analysing the reportable personal injury crash record for the previous three years’, but the official record of personal injury crashes grossly underestimates the number of incidents on this stretch. We've contacted them many times about this, especially after we’ve just witnessed another major incident, but most crashes do not make it to the official figures. A better estimate of the number of crashes would be to obtain records for the repairs on the solid steel rungs of the barrier on the other side of the road. These are frequently replaced due to contortion when vehicles crash into them.

[TWBC: for images see full representation attached].

It has been sobering to read the various objections to expansions of the Sewage Works over the years. Letters written to the council in the early 1990s are still just as valid today: ‘The volume of traffic at rush hour; the vast majority of vehicles travelling at over 50 mph as they sweep into the bend; and the vast majority of traffic moving over the middle white line into the flow of the oncoming traffic when manoeuvring the first bend, with the attendant risk to life on the pavement as they try to swerve away from oncoming vehicles.’ [16 Planning application 93/1090 – objections.]
In previous relatively modest plans to expand the sewage works, the Department of Highways and Transportation objected because the width and visibility of the rural approach roads were unsuitable for the increase in traffic, making the proposal unacceptable on highway safety grounds. TWBC itself raised objections, including the unacceptable impact of additional traffic movements on highway safety [17 Planning application 93/1090 – decision.]. We trust that highway safety has not slipped off the agenda since then.

2) Vehicular access to Cranbrook/Staplehurst
Access to Cranbrook and to the nearest train station in Staplehurst is gained via the T-junction at Waterloo Road. This is a major pressure point. To the right is Cranbrook School, a 20 mph zone which is effectively a single track road due to parked vehicles. To the left is Stone Street, which for the most part is a single track road where cars from both sides vie for priority in the heart of Cranbrook, and/or mount the pavement. Immediately before the T-junction is Tanyard car park, which exacerbates the chaos. Intensifying traffic here is undesirable on safety grounds, as well as being detrimental to businesses in Cranbrook.
The only alternative route from CRS7 to Staplehurst is via Chapel Lane to the A262 in Sissinghurst. This is also a major pressure point. The Street in Sissinghurst already has severe traffic problems, which would only be aggravated by the proposed development.

Compliance with TWBC’s own strategies and assessments.

The proposed development runs counter to TWBC’s current core policies [18 The Core Strategy Development Plan Document (Adopted June 2010).] e.g. Core Policy 4 (Environment) states that the High Weald Area of Outstanding Natural Beauty will be conserved and enhanced, and Core Policy 5 (Sustainable Design and Construction) states that all new developments will be expected to be located outside of the Borough's high risk flood zones and produce no negative effects on existing flood patterns.

TWBC’s Site Assessment Sheets [19 Strategic Housing and Economic Land Availability Assessment for Draft Local Plan July 2019.] and the TWBC Sustainability Appraisal [20 Sustainability Appraisal of the Draft Local Plan for Regulation 18 September 2019.] both state that ‘the proposed housing density is considered high for this site given sensitive landscape and edge of settlement location. The site would suit low density, farmstead style development.’

TWBC’s 2007 Flood Risk Assessment identifies ‘backing up of Crane Brook at Bakers Cross’ as a problem flood risk area. [21 TWBC Strategic Flood Risk Assessment (2007) Table 4-2: Fluvial Flooding Problem Areas.] The same document goes on to state ‘in addition to river flooding, the areas around Cranbrook have experienced flooding as a result of overloading of the sewer system’ and ‘in the preparation of Local Development Documents and considering planning applications, local authorities in conjunction with the Environment Agency, should ... take account of increased sewage effluent flows on fluvial flood risk.’ TWBC has not done so, and these issues have only deteriorated since 2007. Our neighbours regularly have sewage from the Sewage Works flooding their property. They have raised the issue many times, and well before CRS7 was submitted, purely out of concern about the other planned new buildings elsewhere in Cranbrook eg in 2013, they submitted ‘The sewage facilities are at present inadequate for Cranbrook. We are the last household before the sewage works and have had overflows up our manholes running into sheds and over property - back and front garden’ The response from Southern Water was ‘Southern Water has limited powers to prevent connections. This is the case even when there is insufficient capacity in the sewers resulting in unacceptable levels of service such as sewer flooding.’ [22 http://www.tunbridgewells.gov.uk/ data/assets/pdf_file/0010/39871/Response-Report- 7_Chapter-6-Cranbrook.pdf]

Unfortunately the site has been entirely missed off the 2019 Flood Risk Assessment, perhaps leading to the impression that there is no flood risk. Table 13-1: Site Summary Assessment hops from 31 to 33, missing out site ref 32, presumably because the site was submitted late [23 TWBC Strategic Flood Risk Assessment (2019).].
The Sustainability Appraisal specifically states that it placed reliance on the 2019 Flood Risk Assessment in its assessment [24 Table 2 of the Sustainability Appraisal. New or upcoming relevant evidence studies and implications for the SA.], and yet CRS7 seems to have slipped through without Flood Risk Assessment. We trust that the site will be dropped from the proposals once the necessary Flood Risk Assessment has been performed.

[TWBC: for site summary assessment table see full representation attached].

TWBC’s Sustainability Appraisal of the Draft Local Plan, September 2019 states ‘sites that were poorly related to existing settlements or had significant environmental concerns were not deemed to be reasonable alternatives.’
This site is clearly has significant environmental concerns. It should be excluded from the list.

This site constitutes a significant development within the AONB. As it stands, the assessment of this site fails to meet the statutory duty placed on all public bodies by the Countryside and Rights of Way Act 2000 to have regard to the purpose of AONBs in performing any of their functions which might affect land within these areas.

Comments also relevant to:

* Policy EN 21 – AONB The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that “great weight should be given to conserving and enhancing the landscape and scenic beauty” in AONBs.
* Policy EN 28 – flood risk
* Policy EN 6 – safeguarding historic environment
* Policy EN 17 – local green space

Policy STR 1
The Development Strategy - Use of greenfield/AONB sites should be minimised. CRS7 is not a sustainable way to meet housing needs.

Policy STR 6

Transport and Parking – almost all residents of CRS7 will use their own cars to get to their place of employment. There are no more than a handful of jobs that could be reached from this site without using a car.

Policy STR 8
Conserving and enhancing the natural, built, and historic environment

Policy STR 10 Limits to Built Development Boundaries. CRS7 does not even adjoin the LBD. It is not mentioned in the document about limits to built development, but it is shown on the map and is still outside the LBD, even as amended. This map shows clearly the extent to which CRS7 is out on a limb.

[TWBC: for map showing LBD boundary amendments see full representation attached].

CRS7 in relation to nearby sites

CRS7 was submitted late and forms part of a larger plot, ‘late site 22’ that was considered but rejected [25 Strategic Housing and Economic Land Availability Assessment for Draft Local Plan July 2019.]. Amongst the issues considered were ‘AONB status, ecological interest, land contamination (sewage treatment works), and SFRA Flood Zone status’. Late site 22 was considered unsuitable for development because ‘national policy regarding major development in the AONB is clear: the tests to be met for major development in this designation are extremely high, and include demonstrating that (housing and employment) needs cannot be met outside the AONB (either in the Borough, or outside, under the Duty to Cooperate). The level of harm (landscape and scenic beauty) that would arise to the AONB is high. This SHELAA has demonstrated the availability of suitable sites outside the AONB. This site is therefore not suitable for development.’
SHELAA concludes ‘Given the strong policy protection given to the AONB (a national designation) in the NPPF, the whole site is considered unsuitable as a potential Local Plan allocation. Yet SHELAA is proceeding with the two most problematic fields of the entire site, also in AONB:
CRS7 (late site 32) consists of the two southernmost fields of late site 22. Unlike the rest of late site 22, CRS7 is in the official impact risk zone for an SSSI, CRS7 is adjacent to the Sewage Works, and CRS7 has SFRA Flood Zone status 3b. CRS7 also has poor accessibility compared to, for example, land off Waterloo Road.

Given that CRS7 is described as ‘land off Waterloo Road’, and that so many negative factors of CRS7 are not mentioned in the site assessment, we would question whether the correct piece of land has been assessed.

CRS7 is comparable to an adjacent development in Scott field, which was rejected because ‘development would represent a negative impact upon the biodiversity and natural environment objectives, in addition to possible negative impacts upon the water and flood risk objective due to the site's proximity to the Crane Valley. Loss of green space is likely to have a negative impact …’
These factors have been ignored so far in the assessment of CRS7.

Likewise, nearby site 92 has been rejected due to ‘loss of greenfield site in AONB part of which is historic fields adjacent to historic farmsteads’ – CRS7 is almost identical, except the historic farmsteads are nearer to CRS7, and it has further
negatives (flood plain and sewage). Both are in the official impact risk zone of an SSSI. It is nonsensical to proceed with CRS7 when these comparable, but slightly better sites, have been rejected.

CRS7 Historic Farmsteads & Historic boundaries

[TWBC: for maps see full representation attached].

[TWBC: for all maps and images, see full representation attached].

Policy AL/CRS 8: Former Cranbrook Engineering Site and Wilkes Field

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_30

John Williams

Object

We object to any increase in traffic from the High Street along the path between the George Hotel and Lloyds Pharmacy. It is dangerous at present, without the possibility of further cars using it as access to further development. This is a serious Health & Safety issue. A quick look by anyone would confirm this.

DLP_8294

NHS West Clinical Commissioning Group

General Observation

The CCG notes that this site is allocated for mixed use development with the possible inclusion of a medical centre.

As detailed in the CCG’s response to Policy STR/CRS 1 no site has yet been confirmed for a new general practice premises. An options appraisal of potential sites is to be undertaken.

DLP_3036

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 8 Wilkes field / engineering site. (28 dwellings). If other varied solutions develop for the proposed community hub, this site could even deliver more houses. Sensitive site as part in CA and close to heart of town so quality designs essential but sustainable in walking terms. GREEN

DLP_2319

TWBC Property and Estates
TWBC

Support

a. Inclusion of the western vehicular access via Regal Car Park particularly to the community use, should be strengthened

b. Bullet 3. The White Lion Inn ceased in the late 19th century. The building occupying this site is now a pharmacy

DLP_2804

Sue Donaldson

Support with conditions

Stone Street is very narrow, even for a one way street (which it is not). Vehicles regularly mount the pavement causing a major hazard to pedestrins. It is a bus route which causes even more problems. With another 900 homes and maybe 2000 cars this would become a nightmare.

Redevelopment of Wilke's Field provides the ideal opportunity to solve this problem as part of a general plan for coping with increased traffic.

There is a proposed community centre and possible medicalcentre on thesouthern aspect of the site with vehicle access from the Regal car park.

I believe that Cranbrook traffic flow would benefit substantially if a road linkwas created between the Tanyard and Regal car parks along the southern boundary of this site.  Stone street would be bypassed allowing it to be pedestrianised and traffic would flow freely through Cranbrook. Provided that there was sufficient parking then people could enter the town from north or south and explore and shop on foot.

I fully appreciate that this is not the primary concern of this proposed development but I am certain that this will need to happen at some stage and I think that it is vital that irreversible building does not preclude this being considered in the future.

I think that it is vital that enough space is left on the southern border of the site to allow for this although, ideally it should become part of the overall plan to enhance Cranbrook whilst accommodating the housing needs.

DLP_3302

Kent County Council (Growth, Environment and Transport)

 

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Additional paragraph - Proposals to include a servicing strategy across the site.

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

Public Rights of Way and access Service

It should also be expected that improvements will be made to the PRoW that pass through the site. It is also requested that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development.

Heritage Conservation

Scale 2 - Pre-determination assessment should be carried out to clarify whether development of any part of the site is possible.

This site has considerable potential for medieval and post medieval remains associated with the development of Cranbrook as a medieval market town and centre for the cloth industry.

The site has been subject to some archaeological assessment and this must be referenced to inform any detailed design

DLP_3613

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Cranbrook. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. Our assessment has revealed that Southern Water's underground infrastructure crosses this site. This needs to be taken into account when designing the site layout. Easements would be required, which may affect the site layout or require diversion. Easements should be clear of all proposed buildings and substantial tree planting.

In consideration of the above, we recommend the following criterion is added to Policy AL/CRS 8

Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes

DLP_3933

Mrs June Bell

General Observation

2. ‘The provision of the community centre to the south of the site, accessed via the Regal Car Park may include provision for a medical centre as part of the scheme…’

Adequate parking provision with accessibility is essential if a medical centre is proposed as part of this development.

DLP_5075

Tally Wade

Object

I object to the inclusion of the wording ‘provision of a community centre at this site’ when the Cranbrook and Sissinghurst Parish Council has formally agreed to engage with the whole community on how this project should be shaped, what provisions should be incorporated, whether a new build is needed and how the ‘parish funding’ part of the project would be delivered. Where is the evidence that this has happened? There has also been no formal consultation or engagement with the Neighbourhood Development Plan Steering Group as far as I can see any evidence for.

DLP_4030

Brian Swann

Support

I agree that this should all go ahead - it is not over intensive and design will be important in this sensitive area of the town.

The Community Centre Hub will be important in this central position to bring the whole Town together. It could work really well if it is combined with a medical centre.

Take no notice of any reference to consultation by the Parish Council as they have said that this can only take place once the legal side of the transfer of land and use of this site has been finalized.

DLP_6141

Cranbrook & Sissinghurst Parish Council

Object

General objection.

DLP_5983

Steve Rix

Object

Policy AL/CRS 8 2 I object to the inclusion of the wording ‘provision of a community centre at this site’ when the Cranbrook and Sissinghurst Parish Council has formally agreed to engage with the whole community on how this project should be shaped, what provisions should be incorporated, whether a new build is needed and how the ‘parish funding’ part of the project would be delivered. Where is the evidence that this has happened? There has also been no formal consultation or engagement with the Neighbourhood Development Plan Steering Group as far as I can see any evidence for.

DLP_7578

Susie Oakenfold

Support with conditions

The CRANBROOK ENGINEERING and WILKES site AL/CRS 8 has long been known about and in the planning for a very long time. Yes, it will provide some new facilities and but 28 houses and potentially 50+ vehicles as a result , is going to mean vehicle access will be messy here too – I assume the only reasonable entrance and exit is Stone Street or via Crane Valley car park?.  Surely half that number of houses would be more suitable and appropriate for the location.  As a long standing local resident I am really worried that the heart of this uniquely lovely little town is going to be ruined, losing treasured open spaces and pouring more people and vehicles into a very busy small high street centre.

Policy AL/CRS 9: Land adjacent to the Crane Valley

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_979

Mrs A Marley

Object

No. Site 396 Land West of Freight-Lane 117 houses. Too rural & isolated

No infrastructure.

DLP_7781

Annie Hopper

Object

Why has TWBC allocated this major development (250 homes) in the AONB and right next to another development for (160 + 36) homes (AL/CRS 4 Turnden) and ignored:

* Its own policy in the DLP STR 8 Conserving and Enhancing the Natural built and Historic environment, in particular point 5 relating to the AONB

* The AONB Management Plan

* The draft Parish Neighbourhood Plan to focus on small scale sites and avoid large scale sites.

* NPPF para 172: Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. …….The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances and where it can be demonstrated that development is in the public interest.

* DEFRA Landscape review 2019 highlights the CPRE report (2017 CPRE & AONB ‘Landscapes for Life’ available at: https://landscapesforlife.org.uk/application/files/5315/5552/0923/Housing-in-AONBs-Report.pdf ) revealing that approvals for housing units within AONBs and within 500m beyond their boundaries have increased by 82% between 2012-2016, numbers of affordable units have gone down and the risk that paragraph 172 ‘exceptional circumstances’ is being used to argue for major development on the grounds that no other sites outside the AONB are available.

* This allocation for large scale development is outside the LBD.

* Proposed extensions of LBD shown on Map reference 14.1 in order to ‘qualify’ as in 5.76 ‘adjacent to the existing Cranbrook Limits to Built Development in the AONB is contradicting “The purpose of this designation/policy approach to LBD was to “restrict the encroachment of built form into the surrounding landscape”. as defined in the Limits of Built Development Topic Paper for DLP Reg 18 Consultation. Aug 2019 and will set a precedence for further development of valuable AONB landscape.

These allocations risk coalescence and contravenes the Requirement in Policy STR/CRS1 6. ‘All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development;’

Local research for the NDP indicates that local residents are against large scale development as a method of delivering housing in the Parish.

This development is unsustainable, being too far from employment centres and train hubs, necessitating residents to use cars.

There is absolutely no indication of potential employment provision except during any construction phase.

This allocation risks the loss of Protected Views: 1

* View 15 Townscape from Quaker Lane looking SW to Saint Dunstans & Windmill

* View 25 AONB Landscape from Mount Ephrahim looking North East

* View 26 AONB Landscape from Mount Ephrahim looking West towards Hartley

* View 27 AONB Landscape from Mount Ephrahim looking North to Cranbrook

* View 35 AONB Landscape from footpath at Turnden Farm

as identified in the emerging Cranbrook and Sissinghurst Draft Neighbourhood Plan

http://cranbrookandsissinghurstndp.co.uk/wp-content/uploads/2019/09/152_QR_190724_Protected-Views-MAP-PHOTOS.pdf

DLP_7843

Mr R M Todd-Young

General Observation

Our fields shown on the current AL/CRS9 draft Local Plan show a large Buffer Zone on the north side which includes the area leading to the existing CoOp gate right of way. Under the original AL/CR4 allocation, Brick Kiln have 180 houses and Corn Hall have 70 houses thus making up the total of 250 houses allocated to this site. With the Buffer Zone as now shown, there is not enough land on the Corn Hall fields for the 70 houses allocated.

DLP_7910

Fiona Dagger

Object

The local plan states that this site has extant permission. In our view the numbers allocated to this site should be cut substantially so that any new development is focused around the now derelict farmstead site. The design of this development should reflect the agricultural character of the setting rather than the urban nature of the main settlement. The northern part of the site where it abuts the historic settlement core should be protected.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

This site represents an incursion by development into the Crane Valley, a green wedge of typical High Weald AONB fieldscape, which has provided the setting for Cranbrook for 1000 years. The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside. This still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land. This should be protected and removed from any allocation.

The site retains notable AONB features including historic field patterns, ditch and bank features representing territorial and field boundaries, ancient gill woodland and abundant characteristic High Weald species.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

DLP_8055

Sophie Foster

Object

The number of dwellings allocated to this site should be cut substantially so that any new development is focused around the now derelict farmstead site. The design of this development should reflect the agricultural character of the setting rather than the urban nature of the main settlement. The northern part of the site where it abuts the historic settlement core should be protected.

Development on this scale would be contrary to Policy EN 21: “All development within, or affecting the setting of, the High Weald AONB shall seek to conserve and enhance its landscape and scenic beauty, having particular regard to the impacts on its character components, as set out in the High Weald AONB Management Plan.”  It cannot seriously be argued that development on this scale seeks to conserve and enhance the AONB’s landscape and scenic beauty.

This site represents an incursion by development into the Crane Valley, a green wedge of typical High Weald AONB fieldscape, which has provided the setting for Cranbrook for 1000 years. The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside. This still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land. This should be protected and removed from any allocation.

The site retains notable AONB features including historic field patterns, ditch and bank features representing territorial and field boundaries, ancient gill woodland and abundant characteristic High Weald species.

The permanent grassland on this site plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. How does the Local Plan ensure that this commitment is met?  The case for major development on this scale has not been made.

DLP_8135

Hume Planning Consultancy Ltd for Meadow View Construction Ltd

 

On behalf of our client, Meadow View Construction Ltd, we hereby submit our comments on the Regulation 18 consultation draft of the Tunbridge Wells Borough Local Plan (September 2019). 

Our client has interest in the land to the west of Freight Lane, Cranbrook (hereafter referred to as ‘the Site’), as identified in the Site Location Plan at Appendix 1 and considers that this site is suitable for a residential development to provide a sustainable extension to the existing settlement. The Site measures approximately 5ha and currently comprises agricultural land. The Site is well enclosed, situated conveniently close (within 500m) to the centre of Cranbrook and adjacent to a site allocated for residential development in the adopted 2016 Site Allocations Local Plan (Site AL/CR 4 – Land adjacent to the Crane Valley). As such, our client considers that the land west of Freight Lane would represent a logical and sustainable extension to the existing settlement and provide a significant contribution towards the Borough’s housing need. 

The land has a potential capacity of up to 100 dwellings set within a landscaped framework which could provide a mixture of private and affordable housing to meet local housing needs as part of a wellconnected settlement extension with strong links to the town centre and wider area. Having reviewed the current consultation document, we provide comments below on a number of aspects of the Draft Local Plan.

[TWBC: see also the following Comment Nos. 

Policy STR1 - DLP_8137
Policy STR/CRS1 - DLP_8140

Summary

We have set out above our comments, on behalf of Meadow View Construction, on the Regulation 18 consultation draft of the Tunbridge Wells Borough Local Plan (September 2019), and we welcome the opportunity to work collaboratively with the Council to identify a sound development strategy. We support the intention to meet the identified housing needs of the Borough, and to accommodate a portion of this housing need at Cranbrook, which represents a sustainable and suitable location for growth. 

However, we encourage the Council to ensure the development strategy for Cranbrook is sufficiently justified, and in this regard, we consider that there is a compelling case for the allocation of the land west of Freight Lane for residential development given the positive SHELAA conclusions. We therefore request that the Council reconsiders the merits of allocating this site for development within the Regulation 19 draft of the Plan. 

The site is in single ownership and there are guaranteed access rights across the already allocated site to the west (Allocation AL/CRS 9) to deliver a road connection between Angley Road and Freight Lane to bypass the High Street, this would deliver transport benefits to the wider community and existing residents. 

The site also has the ability to deliver up to 100 dwellings by 2023, and would be able to do so in an approach is consistent with Paragraph 172 of the Framework. 

We respectfully ask that our comments are considered and that the necessary modifications are made to ensure the soundness of the Plan. In the meantime we would be pleased to discuss this site in further detail with officers should the opportunity arise.

DLP_968

Mrs A Marley

Object

Land adjacent to Crane Valley. I object to the size and close proximity to valley and ancient woodland on site and I query the access road to High Street. It is not wide enough to take 2 car abreast.

DLP_3056

DHA Planning for Countryside Properties

 

1 Introduction

1.1 Purpose of this report

1.1.1 This representation has been prepared on behalf of Countryside Properties – hereafter referred to as Countryside - in response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until 15th November 2019.

1.1.2 These representations relate to land within Countryside Properties’ control adjacent to the Crane Valley, Cranbrook which forms part of emerging site allocation reference AL/CRS 9.

1.1.3 Based on the current national and local planning context, we consider this site to be suitable for continued allocation and we consider there remains the ‘exceptional circumstances’ to allow development within the High Weald Area of Outstanding Natural Beauty (‘AONB’). Give this context, this representation responds to the content of the draft plan (and relevant supporting documents), reinforces why the site remains suitable and outlines how development could be delivered on site.

1.2 Context

1.2.1 The land to which this relates forms park of at Brick Kiln farm to the south of Cranbrook and is part of a wider site allocated for residential development in the Site Allocations Local Plan under Policy AL/CR4.

1.2.2 Persimmon Homes have an interest in 72% of the AL/CR4 site, with the remainder in the control of Countryside Properties. In this regard, Persimmon Homes submitted a planning application for land within its control in April 2016. This was in outline form and sought the erection of up to 180 dwellings (including up to 35% affordable) with means of access to be determined (application reference TW/16/502860/OUT). The application has a resolution to grant, pending completion of a suitably worded legal agreement.

1.2.3 Countryside remain committed to bringing the site forward at the earliest available opportunity once a suitable access is established.

2 The Tunbridge Wells Draft Local Plan

2.1 Overview

2.1.1 The TWBC Draft Local Plan (herein referred to as ‘the plan’) sets out the spatial vision, strategic objectives, and overarching development strategy for the borough. It details overarching place shaping policies for each parish and settlement, as well as site specific allocations to deliver the strategy and detailed policies to be applied to all new development.

2.1.2 The plan will set the agenda for development across the borough to 2036 and replace the current Development Plan, which comprises the Local Plan 2006 (saved policies), the Core Strategy 2010, and the Site Allocations Local Plan 2016.

2.1.3 This representation comments on the following elements of the plan:

  • Vision and Strategic Objectives;
  • Development Strategy and Strategic Policies;
  • Place Shaping Policies for the Parish of Cranbrook and Sissinghurst; and
  • Development Management Policies.

2.2 Vision and Strategic Objectives

2.2.1 The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure led and largely funded by new development. The key components of the vision are summarised below:

  • The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.
  • Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.
  • A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop into the following years).
  • High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure
  • Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

2.2.2 The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

2.2.3 In order to turn this vision into reality the plan sets a number of strategic objectives.

  1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development;
  2. To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';
  3. To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;
  4. To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;
  5. To ensure that the borough is vibrant, culturally rich, and economically buoyant;
  6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;
  7. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;
  8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;
  9. To establish garden settlements as a model for the future delivery of development in the borough;
  10. To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.

2.2.4 We support the general thrust of these objectives, which seek to meet identified housing needs in full and boosting significantly the supply of new affordable homes. However, we would suggest some minor modification to clarify that the plan is positively prepared and fully aligned with the provisions of the National Planning Policy Framework (‘NPPF’). Indeed, we acknowledge that the Plan aspires to achieve the full development needs of the borough and therefore we consider that objective 1 should be modified to make certain on this point.

“To deliver the full housing, economic and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led and high quality development”

2.3 Development Strategy and Strategic Policies (Policy STR1)

2.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where that development will be located.

2.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed. Further, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.

2.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Governments standard method and the 2014-based household projections.

2.3.4 In terms of the different supply components, the Council consider that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account; completions since April 2016 (1,552); extant planning permissions (3,127); outstanding site allocations (588) and a windfall allowance (700 dwellings). The Council have applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved.

2.3.5 We agree that TWBC is capable of meeting its need in full and support this approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach. Nonetheless, we have concerns regarding the deliverability of the strategy and the potentially over optimistic housing trajectory, particularly in respect of the delivery from key strategic sites (as outlined below).

2.3.6 We note that the emerging strategy is consolidated by Policy STR1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs of the borough over the plan period. This strategy would seek to meet the majority of the Council’s housing need through the strategic extension of Paddock Wood and via a new Garden Village at Tudeley. The remaining growth would then be dispersed proportionately to other settlements in the borough.

2.3.7 We support the general principle of proportionately spreading the benefits of growth and we recognise the opportunity to direct a greater level of growth to Cranbrook compared with previous plan periods. Furthermore, adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area.

2.3.8 Nonetheless, we have some concerns regarding the balance between strategic and non-strategic scale allocations and the anticipated delivery trajectory. For example, 65% of new allocations would be delivered as part of the strategic extension to Paddock Wood (4,000 homes) and the new Garden Village at Tudeley (1,900 homes within the plan period), both of which require a fully master-planned approach, which is a time-consuming process. Furthermore, there are a significant number of existing commitments within Paddock Wood that have been slower at coming forward than had originally been envisaged. A cautious approach is therefore needed.

2.3.9 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum, although it can be as high as 301 dwellings per annum.

2.3.10 On the basis of this research, if the Local plan is adopted by 2021, planning permission approved by 2023 and delivery commences within 6 years (2029), the likely deliver for the plan period would be no more than 966 homes.

2.3.11 Despite this evidence, TWBC has set a much more optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper. The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, the Council suggests that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know how many housebuilders will be involved.

2.3.12 Taking the above into account, our view is that the Council have applied overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure, and to maintain sites such as AL/CR9 which is already well served.

2.3.13 Given the absence of any similar scale strategic sites in Tunbridge Wells Borough as a point of comparison, one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017).

2.3.14 Kings Hill is an extremely prudent example to consider in the context of the Paddock wood extension and new garden village at Tudeley, how deliverable this would be. Indeed, Kings Hill was a new village started in 1989 near land previously occupied by RAF West Malling. The concept was for a multipurpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum, despite multiple developers delivering concurrently. Furthermore, the earlier delivery phases we delivered at lower rates given the need to front load infrastructure.

2.3.15 Therefore, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer terms aspirations that will extend beyond 2036.

2.3.16 Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure, particularly sustainable settlements such as Cranbrook and to reduce the reliance upon Tudeley within this current plan period.

2.4 Place Shaping Policies

2.4.1 The place shaping policies establish the spatial priorities for different areas in the borough, organised according to non-parish and parish areas. For each area, there is an overarching policy that development should adhere to and details are provided for individual allocated sites that will deliver the quantum of development proposed. The site-specific allocations provide both strategic and development management guidance.

2.4.2 Policy STR/CR1 sets the proposed strategy for Cranbrook and Sissinghurst and states that approximately 718-803 new dwellings will be delivered on nine sites, including AL/CR9.

2.4.3 Of our client’s land, policy AL/CRS 9 states:

‘Development on the site shall accord with the following requirements:

1. Provision of pedestrian and cycle links to provide permeability through this site and adjacent sites to the south, and to create an accessible, safe, non-vehicular route to the services provided at the centre of Cranbrook and also at Hartley (see criterion 7 of Policy EN 1: Design and other development management criteria and Policy TP 2: Transport Design and Accessibility);

2. Provision of a suitably designed green infrastructure link along the Crane Valley to link into the routes provided further south along the valley, providing an extended and improved green route into the centre of Cranbrook and Hartley (see Policy EN 16: Green, Grey, and Blue Infrastructure);

3. Consideration of secondary/emergency access required;

4. Provision of an assessment of the cumulative impact of development on the rural landscape setting (see Policies EN 1: Design and other development management criteria and Landscape Policies EN 20 and EN 21);

5. Retention of hedgerows and trees (see Policy EN 14: Trees, Woodlands, Hedges, and Development and criterion 3 of Policy EN 1: Design and other development management criteria);

6. The layout and design of the scheme to give full consideration to the location of the site on the edge of the settlement and to provide a scheme that is sensitively designed and provides suitable rural boundaries to the settlement (see Policies EN 1: Design and other development management criteria and Landscape Policies EN 20 and EN 21);

7. Provision of a landscape and ecological management plan informed by an ecological appraisal (see criterion 4 of Policy EN 1: Design and other development management criteria and EN 11: Net Gains for Nature: biodiversity);

8. An archaeological assessment of the site, including field evaluations (see Policy EN 7: Heritage Assets);

9. Provision of suitable employment floorspace;

10. If development occurs in stages, proposals for development of any one part of the site must not prejudice the overall capacity of the area covered by the allocation;

11. Provision of public electric vehicle charging points and car share facilities in accordance with Policy TP 2: Transport Design and Accessibility;

12. The design and layout to be informed by a comprehensive energy and climate change strategy ( see Policies EN 4: Energy Reduction in new buildings and EN 5: Climate Change Adaptation).

It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development:

a. Improvements to the public realm;

b. Any other highways related works;

c. Improvements to bus services.

Given the above criteria is reflective of the current development plan policy, our client has no objection to the detailed wording.

Exceptional Circumstances

2.4.4 Paragraph 172 of the NPPF states that great weight should be given to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection. It goes on to state that planning permission should be refused for major developments in AONB areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

2.4.5 Consideration of such major applications should include an assessment of:

  1. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
  2. the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and
  3. any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

2.4.6 It is important to stress that footnote 55 of the NPPF is clear that for the purposes of paragraphs 172 and 173, whether a proposal is ‘major development’ is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined. The term has no direct correlation with the definitions set out in the Town and Country Planning (Development Management Procedure) (England) Order 2015.

2.4.7 Whilst this document supports the promotion of the land rather than a formal planning application, we set out below why we consider exceptional circumstances exist remain for the reallocation of this land within the AONB.

2.5 The need for the development

2.5.1 As outlined by the plan, there is an overriding and growing housing need within the Borough. The Council’s SHMA findings initially identified the future need to plan for some 648 new homes per year. This in turn has seen a further uplift as a result of the standard methodology for calculating housing need, which based on the most credible set of population projections suggests a further uplift to circa 680 new homes per year.

2.5.2 In addition to the need moving forward, the previous difficulties in keeping pace with delivery has resulted in a need to accommodate a significant number of dwellings in the short term with a deficit in five year supply.

2.5.3 Given the current development plan has seen documented difficulties in meeting the existing core strategy housing target, the need for new housing is compelling and indisputable and must be addressed by the new plan as a priority.

2.6 The cost of, and scope for, developing elsewhere

2.6.1 Tunbridge Wells is a constrained borough. There are a number of archaeological and heritage sites, including 45 Historic Parks and Gardens, 25 Conservation Areas and 11 Scheduled Ancient Monuments. In addition, there are approximately 3,000 Listed Buildings.

2.6.2 The landscape of the High Weald AONB contains numerous historic landscape features, including field patterns, settlements and ancient woodland, whilst the borough also hosts a number of, or is close to, areas of ecological importance. These include:

  1. Ancient Woodland (approximately 16% of the borough)
  2. Circa 60 Local Wildlife Sites (approximately 11% of the borough)
  3. Ten Sites of Special Scientific Interest (SSSI)
  4. Five Local Nature Reserves (including one Community Woodland)
  5. One Regionally Important Geological Site, at Scotney Castle Quarry.

2.6.3 The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA).

2.6.4 Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells borough.

2.6.5 Given the above constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy.

2.6.6 In respect of Cranbrook, the village is not located within the 22% of the borough that is Green Belt and where an ‘in principle’ objection to development applies. Furthermore, there are no non-AONB alternative sites available given the entire extent of Cranbrook (albeit not all of Sissinghurst) is washed over by the designation. Any growth that will provide a meaningful input of market and affordable homes is going to have a degree of adverse impact. The priority must therefore be prioritising the sites with the lesser impact. In this respect, site AL/CR 9 provides an important linkage between the established built up area, and the neighbouring scheme of Turnden.

2.7 Any detrimental effects and the extent to which that could be moderated

2.7.1 Opportunity exists to moderate the effects of development, including substantial areas of landscaping and associated ecological and heritage buffers and the opportunity to increase public access to the land.

In summary, we support the Council’s conclusions that exceptional circumstances exist to justify the allocation of sustainable AONB land.

2.8 Section 6: Development Management Policies

2.8.1 In addition to our comments on the strategy, we have reviewed the proposed replacement development management policies as set out in chapter 6 of the document.

2.8.2 In general terms, we would refer back to paragraph 15 of the NPPF that promotes succinct and up-to-date plans, which provide a positive vision. In contrast, the draft policies currently proposed are of such prescriptive detail that they are neither positively prepared nor flexible enough to allow for a range of different circumstances. Furthermore, many aspirations result in inevitable conflict. On this basis, we would recommend that the majority of proposed policies are simplified and where additional guidance is needed, this be included within secondary Supplementary Planning Documents.

2.8.3 Turning to detailed policies, there are a number of contradictory elements that need to be remedied before the plan proceeds to Regulation 19. For example, policy EN1 seeks to ensure development is consistent with the established character and surrounding form. However, policy EN4 places significant emphasis on measures to radically reduce greenhouse gas emissions. The provision of a step change towards more sustainable construction and climate change is, inevitably going to result in a need for a change in attitude towards design, material and construction. Accordingly, a cohesive policy approach is needed that allows innovative and different design if supported on wider environmental and planning grounds. As drafted the policies are too inconsistent.

2.8.4 A number of policies also seek to provide guidance rather than policy. For example, policy EN6 seeks to clarify what information is needed in order to assess a heritage proposal. This level of information should instead feature within a support SPD not policy.

2.8.5 In respect of the natural environment, policy EN20 seeks to protect the rural landscape. It states that development will be required to:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

2.8.6 We support the principle of the policy but consider amendments are needed to ensure that it does not result in a blanket reason to refusal otherwise sustainable greenfield development. We suggest it be amended to read:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause Include appropriate mitigation to ensure against significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore Enhance landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

2.8.7 Turning to housing policies, we have significant concerns about the drafting of several policies, that show a degree of misunderstanding of the development industry. For example, policy H1 states:

‘Unless there are exceptional circumstances due to specific site or development constraints, a condition will be attached to any grant of planning permission for new major residential development (including change of use) requiring one or the other of the following conditions:

1. That the permission be implemented within two years from the date of decision; or

2. That groundworks and the construction of the ground floor base of at least two buildings be completed within three years of the permission’.

2.8.8 Whilst the majority of developers would aspire to be ‘on site’ and under construction within 2 years, the reality is that there are often processes that need to be adhered to that are outside of the applicant’s control, including the need to formally conclude land purchases, to discharge conditions and to deliver off site mitigation. There are also ‘non planning’ consents that need to be achieved for example Section 278 Highway works, infrastructure agreements (S38 of the Water Industry Act), ecology licensing etc

2.8.9 The Council will also be aware that commencement of development is often prohibited by seasonal restrictions in respect of ecology and wider constraints.

2.8.10 The second requirement for two buildings to be commenced is arbitrary, for example what is the test for single unit schemes or conversion works? The correct test should be as set out in statute i.e. ‘a material start’.

2.8.11 With the above in mind, we consider the Council’s policy should be deleted or modified to the extent that it will endeavour to agree a two year start date based on site circumstances.

2.8.12 In respect of policy H2, and the preference for Multi-developer schemes and comprehensive masterplanning, we understand the aspiration. However, in reality such stringent requests often result in conflict and further delay and the Council should be careful not to try and impose itself on wider commercial arrangements that may prohibit rather than assist delivery. With this in mind, it is our view that the Council should shift focus away from how it wishes to change development industry practices and instead concentrate on what it can influence, namely the provision of detailed guidance for the proposed site allocations (including potential phasing plans and areas zoned for different forms of development). The Council could also consider imposing a illustrative delivery trajectory as part of the validation process.

2.8.13 We note that policies H3 and H4 have regard to housing mix and density yet provide little or no detailed requirement. On the basis that mixes must reflect market requirements, we consider any aspirational densities would be better placed being inserted into the wider reaching policy EN1.

2.8.14 Policy H5 sets out affordable housing requirements. Whilst we support the general thrust of the objectives and the securing of affordable provision, we object to the rounding up of the calculations and contributions being based on a net rather than gross number of units. For small scale proposals this will often see the proposed percentage increase to closer to 45% and 35% respectively. Such thresholds would therefore need to be tested and justified by evidence. A pragmatic approach would be to apply traditional rounding up or down.

2.8.15 The phasing of affordable provision also needs to be sufficiently flexible so as to not prohibit wider delivery. In this regard, we consider that entering into contract with a registered affordable prior ahead of the 50% occupation should provide the certainty of delivery, but without risking a wider delay in market delivery.

2.8.16 We also object to the expectation of sites that provide between one and nine units to pay a contribution towards affordable housing. This conflicts with Paragraph: 023 Reference ID: 23b-023-20190901 of National Planning Practice Guidance, which states planning obligations for affordable housing should only be sought for residential developments that are major developments. Any reduced threshold should be restricted to designated areas only and should be underpinned by detailed evidence.

2.8.17 The Council will be aware of wider country wide discussions regarding the viability of providing social rented accommodation as part of a wider offer. Such provision is becoming increasingly difficult and without robust policy in place that addresses this matter, this matter is likely to significantly slow delivery.

2.8.18 We note that the Council is only willing to allow the use of Vacant Building Credits in exceptional circumstances. However, the test proposed appear significantly more onerous than have been considered and applied elsewhere. Based on the tests proposed, we fear that there will be a delay in genuinely vacant buildings, that are entitled to use of VBC, to be delayed in coming forward in order to meet the overly onerous criteria.

2.8.19 Finally, we note that paragraph 6.160 states:

“…The Council will assume a buffer of 25m from the edge of [ancient] woodland expecting through assessment for developers to confirm that this or any other distance is appropriate and that the priority for such buffers will be ecological mitigation and enhancement for the woodland rather than the amenity of the proposed development.”

2.8.20 The advice from the Government’s statutory advisor on biodiversity, Natural England, states that:

“For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone.” [1] https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences

2.8.21 Whilst it is recognised that every case will need to be treated on its merits, the Council has provided no justification for imposing a new starting point of 25m, which is nearly double the standard minimum requirement set out by Natural England. This increased buffer zone does not appear to have been based on any evidence. It will simply reduce the quantum of development that can be achieved on many sites, which will in turn increases the risk that additional land is likely to be required elsewhere to meet development needs. We object to this proposed buffer, and request that the standard accepted minimum distance of 15m should be stated instead.

2.8.22 Rather than increasing the size of the necessary buffers based on an arbitrary figure, the policy should instead provide clarity on the functions and forms of the buffer zones, the purpose of which is to minimise recreational pressure on ancient woodlands by preventing uncontrolled access by people and pets. Buffer zones however can also provide benefit for the schemes they fall within by forming part of open space provision and can include planting, paths and play equipment, but not buildings or roads.

2.8.23 In summary, whilst this overview is not exhaustive, we do have concerns about the nature of the proposed policy framework and the degree to which it appears to be trying to limit and frustrate development. Accordingly, in the interests of positive planning, we recommend that the policy framework is simplified and refined and subject to further detailed consultation and focussed on planning matters.

3 Conclusion

3.1.1 This representation has been prepared on behalf of Countryside Properties in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation. The purpose being to provide comment on the Council’s proposed development strategy.

3.1.2 In this respect, we support the aspiration to meet housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Furthermore, we support the continued allocation of our clients land adjacent to the Crane Valley, Cranbrook.

3.1.3 It is important that such sites are retained as we consider that the Local Plan strategy relies too heavily on the delivery of strategic sites that would require the provision of supporting infrastructure. Moreover, the Council have applied overly optimistic projections to the delivery of housing for the extension of Paddock Wood and the Tudeley Garden Village, largely disregarding the NLP 2016 report and the time it would take to masterplan the strategic sites and deliver the required infrastructure.

3.1.4 I trust the contents of this representation are clear and I hope the comments are useful in guiding the forthcoming stage of the plan making process.

DLP_2497

Mr John Wotton

 

AL/CRS 9 Land adjacent to Crane Valley (includes Brick Kiln Farm and Corn Hall Oast)

The sites allocated by this policy are already allocated for residential development in the existing plan and are allocated under the present draft plan for 200-250 homes. My home is on the opposite side of Angley Road to the development. Outline planning permission for 180 homes on Brick Kiln Farm has been sought, but not yet granted. This would represent a major development in the AONB, on mostly greenfield land and outside the LBD. Because the sites were allocated previously, they have not been assessed for sustainability for the purposes of the present draft plan. I recall that the sustainability assessment previously undertaken was negative, particularly on environmental to a greater extent than some sites not allocated under the current plan. There are no exceptional circumstances within NPPF 172 justifying this policy. Taken together with policy AL/CRS 4, this policy would eliminate the green gap between Cranbrook and Hartley, thereby obliterating historic distinct settlement patterns.

I objected to the inclusion of this policy in the current Plan and continue to object to it. I consider that the harm it would cause to the AONB landscape and to the setting of heritage assets, including my home, Goddards Green, were underestimated when the current policy was adopted. The harm is especially marked when looking at the view north west across the Crane Valley from the public footpath between Mount Ephraim and Charity Farm. The should be reassessed substantively in current circumstances, having regard to heightened concerns about sustainability in the light of the climate emergency, continuing loss of biodiversity and the other sites put forward under the call for Sites. Should the allocation under this policy be carried forward, however, a substantial green space between any housing development and Hartley Road must be a requirement, as it is under the current plan, on grounds of impact on the AONB and effect on nearby heritage assets.

DLP_2520

Mr Guy Dagger

Object

The local plan states that this site has extant permission. In our view the numbers allocated to this site should be cut substantially so that any new development is focused around the now derelict farmstead site. The design of this development should reflect the agricultural character of the setting rather than the urban nature of the main settlement. The northern part of the site where it abuts the historic settlement core should be protected.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

This site represents an incursion by development into the Crane Valley, a green wedge of typical High Weald AONB fieldscape, which has provided the setting for Cranbrook for 1000 years. The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside. This still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land. This should be protected and removed from any allocation.

The site retains notable AONB features including historic field patterns, ditch and bank features representing territorial and field boundaries, ancient gill woodland and abundant characteristic High Weald species.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

DLP_3037

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 9 Land adjacent to Crane Valley (200-250 dwellings). This needs sensitive planning as on AONB site close to the Cranbrook CA. It will need as much ‘green’ protection and enhancement as possible plus good, safe walking and cycle routes into the town centre to reduce unnecessary car journeys. GREEN

DLP_3446

High Weald AONB Unit

Object

The local plan states that this site has extant permission. In our view the numbers allocated to this site should be cut substantially so that any new development is focused around the now derelict farmstead site. The design of this development should reflect the agricultural character of the setting rather than the urban nature of the main settlement. The northern part of the site where it abuts the historic settlement core should be protected.

Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development 55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

p) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

q) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and

r) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.

TWBC have accepted that the Land adjacent to the Crane Valley is major development but have not explained how the sequential tests required by para. 172 have been met.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

This site represents an incursion by development into the Crane Valley, a green wedge of typical High Weald AONB fieldscape, which has provided the setting for Cranbrook for 1000 years. The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside. This still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land.

The site retains notable AONB features including historic field patterns, ditch and bank features representing territorial and field boundaries, ancient gill woodland and abundant characteristic High Weald species.

DLP_2085

Terry Everest

Object

Strongly Object

A site which should not be developed as it constitutes a blight on a natural and undeveloped landscape and valley which is fragile habitat and environment.

DLP_3153

Nigel Bell

Object

I have a strong objection to such a large, inappropriate housing estate development of 200-250 houses on ANOB land in this location. This is an undeveloped site of rural ANOB land on the edge of the village which should not be lost. Road access is narrow and vehicle access to a busy main road at this point would be dangerous. Cranbrook needs smaller developments appropriate to nature and style of the existing village.

DLP_3303

Kent County Council (Growth, Environment and Transport)

 

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

The County Council requests that there is mention the consent for Brick Kiln Farm (180 dwellings) in this policy.

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

Public Rights of Way and access Service

It should be expected that improvements will be made to the PRoW that pass through the site. It is also requested that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development.

Heritage Conservation

Scale 2 - Pre-determination assessment should be carried out to clarify whether development of any part of the site is possible.

The site includes a post medieval brickwork. Some areas have been quarried out but there is very high potential for large industrial kilns and brick drying and making structures to survive.

In addition, this is a largescale site directly adjacent to the historic town of Cranbrook. The impact on the significance of Cranbrook as a medieval market town needs to be thoroughly assessed.

Archaeological DBA and Archaeological Landscape are essential to inform this development scheme.

DLP_3448

Sally Marsh

Object

The local plan states that this site has extant permission. In our view the numbers allocated to this site should be cut substantially so that any new development is focused around the now derelict farmstead site. The design of this development should reflect the agricultural character of the setting rather than the urban nature of the main settlement. The northern part of the site where it abuts the historic settlement core should be protected.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

This site represents an incursion by development into the Crane Valley, a green wedge of typical High Weald AONB fieldscape, which has provided the setting for Cranbrook for 1000 years. The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside. This still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land. This should be protected and removed from any allocation.

The site retains notable AONB features including historic field patterns, ditch and bank features representing territorial and field boundaries, ancient gill woodland and abundant characteristic High Weald species.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

DLP_4124

Tunbridge Wells District Committee Campaign to Protect Rural England

 

The sites allocated by this policy are already allocated for residential development in the existing plan and are allocated under the present draft plan for 200-250 homes. Outline planning permission for 180 homes on Brick Kiln Farm has been sought, but not yet granted. This would represent a major development in the AONB, on mostly greenfield land and outside the LBD. Because the sites were allocated previously, they have not been assessed for sustainability for the purposes of the present draft plan. We recall that the sustainability assessment previously undertaken was negative, to a greater extent than some sites not allocated under the current plan. There are no exceptional circumstances within NPPF 172 justifying this policy. Taken together with policy AL/CRS 4, this policy would eliminate the green gap between Cranbrook and Hartley, thereby obliterating historic distinct settlement patterns. CPRE Kent continues to object to this policy. It should be reassessed substantively in current circumstances, having regard to heightened concerns about sustainability in the light of the climate emergency and the other sites put forward under the call for Sites. Should the allocation under this policy be carried forward, however, a substantial green space between any housing development and Hartley Road must be a requirement, as it is under the current plan, on grounds of impact on the AONB and effect on nearby heritage assets.

DLP_3842

Government Team
Natural England

Object

Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.

DLP_5562

Mr Paul Hewitt

Object

This highly contentious allocation sits outside the LBD within the AONB.

The community is against large scale development and NPPF states that no major development should take place on AONB except in exceptional circumstances. It is believed that these exceptional circumstances have still not been proven and that housing need is not a justification for large developments on AONB, particularly when it can be demonstrated that locally assessed housing need can be generated by smaller sites in the Parish.

DLP_3919

Mrs June Bell

Object

Reasons for objection:

Why has TWBC allocated major development sites in the AONB and ignored:

I. Its own policy in the DLP STR 8 Conserving and Enhancing the Natural built and Historic environment, in particular point 5 relating to the AONB

II. The High Weald AONB Management Plan which has been adopted by all the Councils with land in the AONB as their policy for the management of the area and for the carrying out of their functions in relation to it.

III. The draft Parish Neighbourhood Plan to focus on small scale sites and avoid large scale sites

IV. NPPF para 172:’ Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. …….The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances and where it can be demonstrated that development is in the public interest.’

V. DEFRA Landscape review 2019 highlights the CPRE report (2017 CPRE & AONB ‘Landscapes for Life’ available at: https://landscapesforlife.org.uk/application/files/5315/5552/0923/Housing-in-AONBs-Report.pdf ) revealing that approvals for housing units within AONBs and within 500m beyond their boundaries have increased by 82% between 2012-2016, numbers of affordable units have gone down and the risk that paragraph 172 ‘exceptional circumstances’ is being used to argue for major development on the grounds that no other sites outside the AONB are available.

VI. This allocations risks coalescence of the 2 currently distinct areas; Cranbrook Conservation Area and Hartley and contravenes the Requirement in Policy STR/CRS1 6. ‘All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development;’

Please refer to Draft Neighbourhood Plan Map identifying Green Gaps between Settlements

VII. This allocations risks loss Protected Views: 1

* View 25 AONB Landscape from Mount Ephrahim looking North East

* View 27 AONB Landscape from Mount Ephrahim looking North to Cranbrook

as identified in the emerging Cranbrook and Sissinghurst Draft Neighbourhood Plan

1 http://cranbrookandsissinghurstndp.co.uk/wp-content/uploads/2019/09/152_QR_190724_Protected-Views-MAP-PHOTOS.pdf

DLP_4031

Brian Swann

General Observation

This appears to be a foregone conclusion. Where is the promised "masterplan"

Why is it proposed to extend the L.B.D.

No further development to the South of this should be allowed.

The Crane Valley must be protected by extra legal protection (and ownership) being put in place

This site is in a A.O.N.B and no building must be allowed near the Ancient Woodland.

DLP_4597

Keith Stockman

Object

Please enter your comments here: This highly contentious allocation sits outside the LBD but within the AONB. The NPPF states that no major development should take place on AONB except in exceptional circumstances: These exceptional circumstances have still not been proven. Housing need is not itself a justification for large developments on AONB, particularly when it can be demonstrated that independently

locally assessed housing need can be met by the use of smaller sites in the Parish.

DLP_6128

Cranbrook & Sissinghurst Parish Council

Object

Major development sites allocated in the AONB ignoring Tunbridge Wells own policy set out in the draft Local Plan, its AONB Management Plan and the draft Parish Neighbourhood Plan to focus development on small-scale sites.

DLP_6131

Clerk to Cranbrook & Sissinghurst Parish Council

Object

This should be restricted, as it would have high impact on Crane Valley flora and fauna.

DLP_6134

Cranbrook & Sissinghurst Parish Council

Object

Size and proximity to valley and ancient woodland on site. Street at this point is not wide enough to take two cars abreast.

DLP_7322

Mr Richard Gill

Object

Policy Number:  AL/CRS 9   Land adjacent to Crane Valley 

I object to the allocation of land for housing at Brick Kiln Farm/ Cornhall site. The site Brick Kiln Farm should never have received outline planning permission for 180 dwellings.  This site lies adjacent to the LBD and is a major development of within the AONB.  It is inappropriate and does not meet the sequential tests of NPPF Paragraph 172 where great weight should be given to conserving the landscape and scenic beauty. This site has some of the finest intact medieval field systems in Northern Europe and it is outrageous that the allocation was made considering that AONBs along with National Parks afford the highest level of protection. The overriding importance should be the protection, conservation and enhancement of the High Weald AONB. Development should be small scale and restricted to the brown field site of Brick Kiln Farm to prevent further loss of green fields and incursion into the Crane Valley. The local community has fought hard to prevent this development. The Inspector’s findings stated that BKF and Cornhall should be subject to masterplanning and this has never taken place.  The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside.  It still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land.   With its rich habitats and ecosystems, no amount of mitigation is going to create net gains for nature biodiversity (EN11). The open rural landscape will be lost permanently and replaced with a built environment in an amenity landscape with the developers’ standard replacements of attenuation ponds, play areas, a community orchard, hedgerows.  Public exhibitions of the proposed development do not uphold Policy STR7 with regard to paragraph 2, the buildings do not “exhibit individual architectural quality within well considered public and private realms.”  They exhibit what we see all around us – pattern book building and ease of replication which is based on a financial model.  The site demands exemplary architectural design of the highest quality.

DLP_5610

Mrs Jacqueline Hewitt

Object

This highly contentious allocation sits outside the LBD within the AONB.

The community is against large scale development and NPPF states that no major development should take place on AONB except in exceptional circumstances. It is believed that these exceptional circumstances have still not been proven and that housing need is not a justification for large developments on AONB, particularly when it can be demonstrated that locally assessed housing need can be generated by smaller sites in the Parish.

DLP_7231

Elizabeth Daley

Object

This highly contentious allocation sits outside the LBD within the AONB.

The community is against large scale development and NPPF states that no major development should take place on AONB except in exceptional circumstances. It is believed that these exceptional circumstances have still not been proven and that housing need is not a justification for large developments on AONB, particularly when it can be demonstrated that locally assessed housing need can be generated by smaller sites in the Parish.

Where is the sustainability assessment for this development in the Draft Plan?

DLP_7048

Philippa Gill

Object

I object to the allocation of land for housing at Brick Kiln Farm/ Cornhall site. The site Brick Kiln Farm should never have received outline planning permission for 180 dwellings.  This site lies adjacent to the LBD and is a major development of within the AONB.  It is inappropriate and does not meet the sequential tests of NPPF Paragraph 172 where great weight should be given to conserving the landscape and scenic beauty. This site has some of the finest intact medieval field systems in Northern Europe and it is outrageous that the allocation was made considering that AONBs along with National Parks afford the highest level of protection. The overriding importance should be the protection, conservation and enhancement of the High Weald AONB. Development should be small scale and restricted to the brown field site of Brick Kiln Farm to prevent further loss of green fields and incursion into the Crane Valley. The local community has fought hard to prevent this development. The Inspector’s findings stated that BKF and Cornhall should be subject to masterplanning and this has never taken place.  The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside.  It still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land.   With its rich habitats and ecosystems, no amount of mitigation is going to create net gains for nature biodiversity (EN11).  The open rural landscape will be lost permanently and replaced with a built environment in an amenity landscape with the developers’ standard replacements of attenuation ponds, play areas, a community orchard, hedgerows.  Public exhibitions of the proposed development do not uphold Policy STR7 with regard to paragraph 2, the buildings do not “exhibit individual architectural quality within well considered public and private realms.”  They exhibit what we see all around us – pattern book building and ease of replication which is based on a financial model.  The site demands exemplary architectural design of the highest quality.

DLP_6051

Laura Rowland

Object

The local plan states that this site has extant permission. In our view the numbers allocated to this site should be cut substantially so that any new development is focused around the now derelict farmstead site. The design of this development should reflect the agricultural character of the setting rather than the urban nature of the main settlement. The northern part of the site where it abuts the historic settlement core should be protected.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

This site represents an incursion by development into the Crane Valley, a green wedge of typical High Weald AONB fieldscape, which has provided the setting for Cranbrook for 1000 years. The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside. This still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land. This should be protected and removed from any allocation.

The site retains notable AONB features including historic field patterns, ditch and bank features representing territorial and field boundaries, ancient gill woodland and abundant characteristic High Weald species.

Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?

DLP_6319

Persimmon Homes South East

 

1. Introduction

These representations have been prepared by Persimmon Homes in response to the Tunbridge Wells Borough Council Draft Local Plan (Regulation 18 Consultation).

Persimmon Homes have several interests within Tunbridge Wells Borough which are being promoted through the Local Plan process including land at Paddock Wood, land at Horsmonden and land at Cranbrook.

These representations have been prepared in respect of land west of Freight Lane, Cranbrook, hereafter referred to as ‘the Site’. Separate representations have been made in respect of our other sites.

Land West of Freight Lane

The Site is located in a sustainable location on the south eastern edge of Cranbrook, within walking distance of the town’s services and facilities.

The Site extends to approximately 6ha and comprises agricultural land. The Site is bound by existing development to the north-east, an allocated and committeed development site to the north-west. Whilst agricultural land is situated to the south, the Site boundaries are well enclosed by existing trees and hedgerows.

The Site can thereby accommodate a sensitive extension to Cranbrook delivered in accordance with AONB Design Guidance to accommodate approximately 100 dwellings in a series of ‘farmsteads’ within extensive landscaping.

Structure

These representations are structured as follows:

  • Section 2 provides a detailed overview of the Site and surroundings and the development potential of the site;
  • Section 3 sets out an analysis of the development strategy as currently conceived, identifying several risks to ‘soundness’ and setting out how these can be overcome through the allocation of the Site;
  • With reference to NPPF paragraph 172 Section 4 demonstrates that, whilst the Site is situated within the AONB, major development is acceptable.
  • Section 5 provides commentary on the development management policies in the Draft Plan
  • Section 6 provides a summary and conclusion.

2. Land West of Freight Lane

Site & Surroundings

The Site is located on the south western edge of Cranbook, approximately 600m from the centre of the town and within the High Weald AONB.

The Site extends to approximately 6ha and comprises an irregular shape field, defined by Freight Lane along the southern boundary and the Crane Brook along the northern boundary. The sight slopes from southern boundary down towards the Crane Brook along the northern edge.

Situated directly to the north west of the Site is the Brick Kiln Farm development site, which is delivered by Persimmon Homes under Planning Permission Reference 16/502860/OUT. Situated directly to adjacent to the north east corner of the Site are a cluster of properties along Freight Lane and a large residential neighbourhood of predominantly post war housing beyond that. There are small cluster, a farmstead, of properties situated immediately to the south of site accessed via a private drive (known as Mount Ephrain). Agricultural land is situated to the south of the site.

The Site comprises open agricultural land which is given over to grazing. The southern, eastern and western boundaries of the site are defined by existing trees and hedgerows. Along the northern edge of the Site is a woodland belt, through which the Crane Brook runs; part of the woodland belt is designated as an Ancient Woodland. There is an established farm track which connects the site to the adjacent field to the north which is being developed for residential; the track does not pass through the Ancient Woodland.

There are two public rights of way that pass through the site (WC96 and WC95). In addition WC118A runs along Freight Lane and WC116 runs along the southern boundary of the Site.

The established hedgerows and trees along the boundaries of the site screen views into the site. As such the Site is well enclosed with limited views from the wider countryside.

The Site is well related to the town and the adjacent development site.

Strategic Housing Economic Land Availability Assessment

The Site has been assessed as part of the Strategic Housing and Economic Land Availability Assessment under Site Reference 396.

The assessment notes that the Site is ‘available’.

The assessment notes that the Site is ‘achievable’. It is noted that the Site “would make a logical extension of an existing allocation adjacent”.

With regard to ‘suitability’ the assessment it suggests the Site is neutral when considered in isolation but negative when considered alongside the adjacent development site:

  • ‘Individually’ the analysis suggests that individually, whilst the site would “score negatively in landscape terms” this is balanced by the housing provision;
  • ‘When considered with the wider (adjacent) site allocation AL/CRS9’ the assessment concludes that the “site area is relatively large so would contribute significant benefits to housing numbers but is scored highly negatively for many environmental objectives to reflect the sensitive features that are at risk.”

Whilst it is accepted that the Site has a degree of sensitivity in landscape terms, we consider that a sensitively designed development can protect and enhance the important landscape features. Set out below are several design principles which will ensure the Site is designed sensitively.

Design Principles

Having regard to the character and appearance of the Site and the surrounding area, the following key development principles have been identified for the site:

  • Provide a mixture of private and affordable housing to meet local housing needs.
  • Provide a well-connected residential neighbourhood with strong links to the town centre and wider area:

    o Provide a vehicular connection to the A229 through from the adjacent development site.

    o Enhance existing Public Rights of Way to provide improved pedestrian and cycle connections to the wider area.
  • Respect and enhance the character and appearance of the wider AONB landscape:

o Retain and enhance the existing trees and hedgerows along the Site boundaries to ensure the Site remains visually enclosed from the wider countryside.

o Protect and enhance the Ancient Woodland along the northern boundary of the Site, including providing a 15m no development buffer.

o Respond positively to the Mount Ephrian Farmstead through the sensitive landscape design and architecture.

Development Proposals

Persimmon Homes have worked closely with Tunbridge Well Borough Council to design a scheme for 180 dwelling on the adjacent site which relates well to the Cranbrook and also respects the character and appearance of the AONB.

At this early stage a scheme for this Site has not yet been prepared for the Site. However the Design Principles identified above define the broad parameters within which the development would be delivered. Within these parameters we anticipate we could deliver a high quality scheme for approximately 100 units within an extensive Green Infrastructure Framework.

Delivery

Persimmon Homes anticipate that development of the adjacent site will commence in summer/autumn 2020 and will take approximately 3 years to build out, completing in summer/autumn 2023.

Should this site be allocated as part of the new Local Plan in winter 2021, detailed planning approval for the Site could reasonably be expected to be achieved within 18 months. This would allow the development to commence in summer/autumn 2023.

In summary, as Persimmon will already have a presence on the adjacent land, the Site could deliver units in the early part of the plan period, making an important contribution to the housing trajectory.

Summary

In summary, the Site is a situated in a demonstrably sustainable location. Whilst the Site is subject to some limited environmental constraints, these can be mitigated through careful design and the delivery of a comprehensive green infrastructure scheme.

4. Major Development in the AONB

The Site is situated within the High Weald Area of Outstanding Natural Beauty (AONB). The NPPF states that the scale and extent of development within these designated areas should be limited. The National Planning Policy Framework (NPPF) makes clear, at paragraph 172, that:

“Great weight should be given to conserving and enhancing landscape and scenic beauty in… Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues.”

Paragraph 172 goes on to state that:

“Planning permission should be refused for major developments other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest (emphasis added).

Paragraph 172 goes on to set out three considerations against which proposals for major development in the AONB should be assessed:

a) The need for development, including any national considerations, and the impact of permitting it, or refusing it, upon the local economy.

b) The cost of and scope for, developing outside the designated area, or meeting the need for it in some other way; and

c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

The Development Strategy as currently conceived has sought to minimise the development directed towards the AONB, paragraph 4.38 states that: “the Council proposes a development strategy to meet the housing needs of the Borough based on Option 3 (dispersed growth)…this also takes account of the need to maximise the amount of major development outside the High Weald AONB”.

However, as demonstrated in Section 3, the Development Strategy as currently conceived is unsound. To address the unsound aspects of the Draft Local Plan it is recommended that some growth is redirected towards demonstrably sustainable locations within the AONB (such as the Site).

Within the framework of the tests set out at NPPF paragraph 172, the following analysis demonstrates that directing further major development toward the AONB, is sound:

* Need for development

There is a clear housing need in the Borough. Specifically, as a high value area Cranbrook has a need for entry level housing to allow local people to get on to the housing ladder in the town; in addition there is a need for affordable housing in the town.

Failing to direct sufficient (i.e. additional) housing growth towards Cranbrook will undermine the future economic success and prosperity of the town as there will be a smaller employment pool and less spending power locally.

* Opportunities for development outside the AONB

As noted above the Development Strategy as currently conceived seeks to minimise the level of growth directed to towards the AONB. As a consequence the Development Strategy is reliant upon areas outside of the AONB accommodating a high level of growth.

Most notably the proposed new settlement at Tudeley Village is required to accommodate around 2000 units in the plan period. However as discussed in Section 3 the proposed new settlement is in an unsustainable location and is of insufficient scale to secure the necessary new infrastructure to make it sustainable.

It is considered that alternative locations outside of the AONB have either been allocated, such as Paddock Wood, or are unacceptably constrained. It is thereby clear that further growth should be directed towards sustainable locations within the AONB.

As demonstrated above Cranbrook is a sustainable settlement, with capacity to sustainably accommodate additional growth. Indeed it is considered that insufficient growth has been directed towards Cranbrook given it size, level of services and accessibility.

* Detrimental impacts of development within the AONB (and scope of moderation)

It is acknowledged that Section 2 of these representations that the Site has a degree of sensitivity in landscape and environmental terms, including the presence of an Ancient Woodland on the northern boundary of the Site.

However it is also highlighted in Section 2 that with appropriate design, particularly with regard to the inclusion of an extensive green infrastructure, the proposed development can protect and enhance the important landscape and environmental features.

It is also acknowledged that the site has some recreational value, by virtue of the Public Rights of Way that pass through parts of the Site and provided connectivity to the wider countryside. However these routes can be protected and indeed enhanced as part of the proposed development

It is noted that the Council have supported such an approach on the adjacent site (Land at Brick Kiln Farm) and the nearby Turnden Farm site – namely allowing development whilst protecting the key landscape and environmental features of the Site, and existing PROW through the provision of extensive green infrastructure.

In summary it is considered that the limited detrimental landscape, environmental and recreational impact of the proposed development can be effectively moderated through careful design. To this end Section 2 sets out a number of design principles for the site which would define the acceptable parameters of development on the site.

Summary

This section has shown that, whilst the Site is situated within the AONB, directing major development toward the Site would be entirely in accordance with the NPPF Paragraph 172 tests. There is a clear need for the development which cannot be accommodated in locations outside of the AONB and furthermore the limited detrimental environmental impacts of the development can be mitigated through sensitive design.

The development of the Site would thereby demonstrably be in the public interest.

6. Summary and Conclusion

These representations have been prepared by Persimmon Homes in respect of the Land West of Freight Lane, Cranbrook, Kent.

These representation have demonstrated that the Site is a situated in a sustainable location on the edge of Cranbrook which is the most sustainable settlement in the Borough outside of the Main Urban Area.

These representation have shown that, whilst the Site is subject to some limited environmental constraints, these can be mitigated through careful design and the delivery of a comprehensive green infrastructure scheme.

Whilst the Council have taken a proactive approach to accommodating the housing requirement over the plan period, the development strategy as current conceived is subject to several shortfalls which make is ‘unsound’. These representations have highlighted that, these issues can be addressed by directing additional growth toward sustainable locations around Cranbrook, most notably toward the Site.

In light of the preceding analysis, these representations have demonstrated that, whilst the Site is situated within the AONB, directing major development toward the Site would be entirely in accordance with the NPPF Paragraph 172 tests. There is a clear need for the development which cannot be accommodated in locations outside of the AONB and furthermore the limited detrimental environmental impacts of the development can be mitigated through sensitive design.

In summary, these representations have demonstrated that the Site can deliver sustainable development and we respectfully request that the Site is allocated in the emerging Plan.

[TWBC: see full representation. Also see Comment Nos. DLP_6319, 6323-6326, 6328, 6830-6835, 6837-6839].

DLP_6500
DLP_6518
DLP_6547
DLP_6654
DLP_6712
DLP_6734
DLP_7681

Clare Govan
Philip Govan
Rory Govan
Stephanie Govan
Edward Govan
James Govan
Joe Hughes

Object

The following comment was submitted by the list of responders on the left:

The number of dwellings allocated to this site should be cut substantially so that any new development is focused around the now derelict farmstead site. The design of this development should reflect the agricultural character of the setting rather than the urban nature of the main settlement. The northern part of the site where it abuts the historic settlement core should be protected.

Development on this scale would be contrary to Policy EN 21: “All development within, or affecting the setting of, the High Weald AONB shall seek to conserve and enhance its landscape and scenic beauty, having particular regard to the impacts on its character components, as set out in the High Weald AONB Management Plan.”  It cannot seriously be argued that development on this scale seeks to conserve and enhance the AONB’s landscape and scenic beauty.

This site represents an incursion by development into the Crane Valley, a green wedge of typical High Weald AONB fieldscape, which has provided the setting for Cranbrook for 1000 years. The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside. This still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land. This should be protected and removed from any allocation.

The site retains notable AONB features including historic field patterns, ditch and bank features representing territorial and field boundaries, ancient gill woodland and abundant characteristic High Weald species.

The permanent grassland on this site plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. How does the Local Plan ensure that this commitment is met?  The case for major development on this scale has not been made.

DLP_6561

Diana Badcock

Object

Policy Number AL/CRS 9 Brick Kiln

I strongly object to this large scale proposal for Cranbrook. There are far too many houses packed into a too dense a plan. The developer has not adopted the masterplanning approach that they were required to, and TWBC has not insisted on the highest quality of house design, even though the site is in the AONB, adjacent to the Cranbrook Conservation Area, and has a long stretch of ancient woodland alongside and on site. This seems to contradict the noble-sounding aspirations of ‘Vision and Objectives 1 (‘exceptional quality of the built and natural environment will have been protected and enhanced’) and Vision 2’ (esp. 2.1, 2.2, 2.6, 2.10) and I feel TWBC has shown lack of imagination and responsibility with respect to this sensitive part of a historic town.

At the very least all these houses should be designed to the highest environmental standards; a chance to show that this council does indeed take account of climate change (ref. ‘Sustainable development’ 2.15)

DLP_7373

Andrew Ford

Object

The local plan states that this site has extant permission. In our view the numbers allocated to this site should be cut substantially so that any new development is focused around the now derelict farmstead site. The design of this development should reflect the agricultural character of the setting rather than the urban nature of the main settlement. The northern part of the site where it abuts the historic settlement core should be protected.

Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

  1. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
  2. the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
  3. any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.

TWBC have accepted that the Land adjacent to the Crane Valley is major development but have not explained how the sequential tests required by para. 172 have been met. This policy is therefore, not justifiable.

Major development of this scale is not appropriate in an AONB. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

This site represents an incursion by development into the Crane Valley, a green wedge of typical High Weald AONB fieldscape, which has provided the setting for Cranbrook for 1000 years. The northern edge of the site constitutes the last remaining area where the historic core of the settlement abuts the countryside. This still retains archaeological evidence of historic field pattern and undisturbed grassland which can tell the story of the historic settlement’s strong relationship with the land.

The site retains notable AONB features including historic field patterns, ditch and bank features representing territorial and field boundaries, ancient gill woodland and abundant characteristic High Weald species.

DLP_7574

James Lloyd

Object

The site is within an Area of Outstanding Natural Beauty, within which, according to the National Planning Policy Framework, no major development ought to take place except in exceptional circumstances. This creates a presumption against this particular policy. Although the existence of Brick Kiln Farm within the site proves that some modest development is feasible, the size of the projected development is wholly impractical.

The site contains Ancient Woodland, which is a non-replenishable resource and it is upstream of the Crane Valley Nature Reserve. Although a landscape buffer is envisaged, it is difficult to believe that the Ancient Woodland and the Reserve could be unaffected by housing on this scale, particularly the former.

The site is prone to flooding and not just within the landscape buffer. The pond that is shown on the bottom mid-left of the map has been known to expand considerably after heavy rainfall and the land around it to become waterlogged. It is difficult to believe that residents would not be affected and a proposed development of this site in the 1970s was cancelled partly on those grounds.

The proposed development would be a considerable block of housing within a confined area, with only one point of access to Angley Road. 200 dwellings means at least 200 cars, all of which will enter the High Street or Angley Road from somewhere near the War Memorial. This is already a very busy Y-junction, especially during the school run, when buses mass there. In 2016 a car was struck and the driver killed just beside the War Memorial. An extra mass of 200 more cars in exactly that zone between the hours of seven and eight can only be dangerous and will certainly increase road congestion.

The site is of historical interest. At least one of its fields contains visible traces of strip farming, dating back to the middle-ages. As with the ancient woodland, this is a finite archaeological resource that would be destroyed by the development.

DLP_7579

Susie Oakenfold

Support with conditions

I appreciate that development is needed to meet government targets but why destroy the integrity of the beautiful town centre and historic buildings and overall appearance.  At least the LAND ADJACENT TO CRANE VALLEY Map 52 Policy AL/CRS 9 proposal contains modern buildings in one area without blighting the town centre’s old buildings, is walkable to the shops and schools, and will have vehicle access onto a wider stretch of the road that could reasonably have traffic control measures.  The same applies to TURNDEN FARM ON HARTLEY ROAD AL/CRS 4 – it is at least self contained and does not threaten the appearance or character of the town.  However, the sheer number of the two combined is very worrying for the future impact of so many more people on the town and, of course, resulting enormous increase in traffic.

Policy AL/CRS 10: Cranbrook School

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_3038

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* Al/CRS 10 Cranbrook school ambitions. CCAAC has concerns about development of their sites and impact on heritage as they occupy key sites across CA. Need for tree planting and landscaping on their sites plus more shared use for the whole community, as open space is inevitably being reduced under this Plan. AMBER

DLP_3154

Nigel Bell

Object

This is a huge collection of land plots. I have no objections to the use of this land to expand Cranbrook school facilities in an appropriate and sympathetically planned and designed manner but object to large scale mass housing development through sale to private developers. Any housing or dwellings should be limited to those required by the school for its own purposes, small scale developments of 15- 20 dwellings in attractive styles similar to existing village properties.

DLP_3305

Kent County Council (Growth, Environment and Transport)

Support

Highways and Transportation

The Local Highway Authority supports this policy.

Heritage Conservation

Scale 2 - Pre-determination assessment should be carried out to clarify whether development of any part of the site is possible.

There is potential for prehistoric and later archaeology, particularly associated with the post medieval development of Cranbrook. There are farms and small holdings identifiable on the 1st Ed OS map which are of local heritage importance although some are designated.

The size and scale of this proposal should lead to consideration of the wider impact of the scheme on the significance of Cranbrook itself and its surrounds.

A Full Heritage Assessment should be undertaken to inform this allocation.

DLP_3614

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Cranbrook. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. Our assessment has revealed that Southern Water's underground infrastructure crosses this site. This needs to be taken into account when designing the site layout. Easements would be required, which may affect the site layout or require diversion. Easements should be clear of all proposed buildings and substantial tree planting.

In consideration of the above, we recommend the following criterion is added to Policy AL/CRS 10

Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes

DLP_5512

Peter Bourne

Object

Negative impact of Developments in proximity of Union Windmill, Cranbrook

Along with St Dunstan’s Church and Sissnighurst Castle, Union Windmill is a Grade 1 Listed Building which opens to the public on a regular basis. Unlike Sissinghurst Castle which has special protection, none is currently provided for Union Mill.

AL/CRS10 largely relates to playing fields and other green spaces. It borders the Conservation Area, which includes, Union Windmill. This is a Grade 1 Listed building, working solely using wind power. It is an important element of Cranbrook’s attraction as a tourist destination, and nationally, one of the very few windmills which are capable of operating by wind power. Very few of the surviving windmills are Grade 1 listed, reflecting its National importance as a working example.

Unfortunately Grade 1 listing, whilst protecting the setting to some extent, does not guarantee that the building will be protected from development that could negatively affect its access to its power source, the wind.

Therefore, any development which might restrict access to the wind (from any direction) must not be permitted.

Whilst this is being addressed as part of the Cranbrook Neighbourhood Development Plan, this has not been finalised.

Therefore, the Local Plan should be amended in respect of development site AL/CR10 to include a restriction to the effect that:

  1. a) No development within 100 metres of Union Mill, including increasing the height of existing buildings.
  2. b) At distances between 100m – 400m from the Mill, development should not be allowed if it affects the wind speed at the Mill by more than 5%, against the measure at the date of this plan, from all directions, as calculated by the “Molen Biotoop” model.

DLP_4032

Brian Swann

Object

No dwelling numbers have been quoted in the Draft Plan which is unsettling.

A full masterplan (with sites CRS 2 & 3) must be produced and approved before any building works take place. Green areas and open spaces must be kept.

Any housing should be for staff and other school employees ONLY

DLP_7375

Cranbrook Windmill Association

Support with conditions

Policy AL/CRS10 Cranbrook School (CfS Reference: Site 128)

More specifically Scott Field, southern part of Site 128 

Our background Cranbrook Windmill Association (CWA) is commissioned by Kent County Council to open the windmill for public access and to operate it on a non-commercial basis as circumstances allow over the summer months. The windmill is owned by Kent County Council. It is situated 25m to the south of Site 128.

CWA is anxious to ensure that any developments on Scott Field (part of Site 128 just to the north of the windmill) do not have a significantly adverse impact on:

  • views of the windmill from the surrounding countryside
  • the windmill’s access to wind

These issues are highlighted in the Cranbrook & Sissinghurst Neighbourhood Plan, Draft July 2019

“Cranbrook Windmill is an iconic landmark within the town. Visitors and residents alike love to see it ‘come alive’ with the sails (sweeps) turning by wind power, which is a rare sight in modern day.

Furthermore, access to the wind is a vital part of the windmill’s heritage value. Protecting the windmill and its surrounding area is essential for the local identity of the parish.”

Views of the windmill

Cranbrook’s iconic windmill is Grade 1 Listed. It is the tallest and arguably the finest smock mill in England. As such it was chosen by the Science Museum to be the model for this type of windmill on its educational poster.

Sited on high ground at the top of The Hill the windmill is visible from many parts of Cranbrook and is frequently used in publicity material for the town.

The Cranbrook and Sissinghurst Neighbourhood Plan fully recognises the visual importance of the windmill and other historic buildings. The Protection of Key Views policy states:

  • Views of key buildings, roofscapes and landscapes should be protected and not harmed by new development.
  • Opportunities to improve vistas and views of significant buildings within the parish will be encouraged within any new developments.
  • Planning applications should consider and demonstrate the effect of the development on views of any one of the key buildings listed below and provide detailed intention within the planning application to sustain the visual prominence of these key buildings.

The windmill is second in the list of historic Cranbrook buildings that follows the above statement.

Summary

Cranbrook Windmill Association would object strongly to developments on Scott Field that are higher than two-storeys and which would contravene the Key Views policy in the Neighbourhood Plan.

We would not object to possible low level (two storeys maximum) development on Scott Field.

Access to wind

Cranbrook windmill is one of a small number of windmills in England that are in full working order and with much of its original drive machinery still in use. It has been featured by the Science Museum as a working example of the ability to harness wind power upon which the country depended for 700 years.

Access to the wind is a vital part of the windmill’s heritage value. Without sufficient wind the windmill simply will not work. There is also an emotional element in that people, especially children, love to see it ‘come alive’ with the sails turning. Visitor numbers shoot up when the sails start turning.

Impact of possible development on wind flow

It is not easy for lay people to assess the impact that a particular development will have on the flow of wind reaching the windmill. But wind engineers in Holland have developed a mathematical model which is used there. The Dutch title ‘Molen Biotoop’ translates as ‘Windmill Living Space’. The English version is at: ‘https://translate.google.co.uk/translate?hl=en&sl=nl&u=http://www.molenbiotoop.nl/&prev=search

The Society for the Protection of Ancient Buildings (SPAB), Mills Division, have also promoted this model to ensure that the small number of surviving working windmills continue to have access to the wind.

The Neighbourhood Plan highlights that the Molen Biotoop Model implies that:

  • In practice no development within 100m of the windmill shall be higher than the existing or adjacent buildings. This means that two storey developments would be fine.
  • At distances between 100m – 400m from the windmill development should not be allowed if it affects the wind speed at the windmill by more than 5% in any direction, as calculated by the Molen Biotoop Model. Again, two storey developments would be fine. Larger ones would depend on their size and distance away.

Summary

If the above principles are adhered to then Cranbrook Windmill Association will not object to developments on Scott Field.

For convenience the aerial view shows the approximate areas affected.

[TWBC: see full representation].

DLP_6037

Kember Loudon Williams for Cranbrook School

Support with conditions

A separate report has been prepared to accompany these representations which fundamentally support the focus and importance given to Cranbrook School within the Draft Local Plan but have considered the requirements of the policy in more detail.  See Chapter 4.

[TWBC: see full supporting statement. Chapter 4 is copied below]:

4 Cranbrook School – Main Site

Relevant Policies: AL/CRS 10

4.1 The School is constantly striving to improve and enhance the current buildings and facilities within the site and has worked hard to secure high quality development following a number of planning decisions in recent years (including: 15/507802/FULL Horsely Building, 15/507818/FULL Squash Courts). The School have been in the process of undertaking a wide range of refurbishments including the creation of a new sixth form centre within the old gymnasium, improvements to the Cornwallis House, School Library, Rootes Building, Junior School Hub and more general upgrades to equipment and facilities. The need for regular maintenance is particularly important in light of the age of some of the buildings and the wide range of listed buildings on site. These improvements are wholly self-funded by parents and governors and through individual fundraising events. Despite best efforts, the lack of available significant external funding sources is impacting on strategic reinvestment in facilities and upon the effective growth of the School.

4.2 The School welcomes the continued recognition and support of TWBC in its draft Local Plan, particularly with regards draft policy AL/CRS 10 which offers support within the land included in the policy diagram below (Figure 2: Map 53 Policy AL/CRS 10) for the purposes of education and community facilities and to include sports and leisure provision.

4.3 Paragraphs 5.82 & 5.83 refer to the School as a major employer in the town and look to support appropriate development in connection with the School, which of course is welcomed.

[TWBC: for Figure 2 site plan, see full supporting statement].

4.4 The School is, however, concerned that the comprehensive masterplan proposed at draft Policy AL/CRS10 (1) and (2) could, if required in support of any development proposals affecting the AL/CRS10 land, be seen as an onerous requirement, and where a masterplan will potentially become outdated quite quickly in an ever evolving situation where the School needs to remain responsive to evolving educational trends and needs.

4.5 The existing main campus of the School is within the Limits to Built Development for the town and therefore, provided that any proposals take careful account of design, heritage and other planning considerations in the usual way, there would be support in principle for development proposals under other established planning policies.

4.6 The eastern land parcel identified under Policy AL/CRS10 is largely outside of the Limits to Built Development but predominantly consists of various open land, including sports courts and pitches. Although outside of the Limits to Built Development, proposals for small scale improvements to existing buildings and facilities, or for improved or new sports pitches, in this area would benefit from the support of other planning policies.

4.7 Accordingly, although the overall support offered the School by AL/CRS10 is welcomed, it seems a somewhat onerous and disproportionate requirement to require a full masterplan, in support of any application proposals, of whatever scale. The School would wish to propose, therefore, that the requirement for a Masterplan is more selectively triggered, in relation to any proposals for significant new freestanding built form, such as new boarding house(s). Similarly, the Landscape Management Plan requirement at criterion (5) of AL/CRS10 should mirror the suggested approach for the Masterplan at Criteria (1) and (2) of the draft Policy.

4.8 Other potential proposals to reconfigure, improve and/or expand the playing pitches within the AL/CRS10 land will be informed by the Playing Pitch Assessment and Strategy referred to elsewhere in this report, with particular reference to the Policies relating to Big Side, Jaeger’s Field and Rammell Field.

4.9 The omission of Rammell Field from the AL/CRS10 Policy area, as referred to in supporting para. 5.83 of the Draft Local Plan is noted. It is questioned whether it is logical to omit this land parcel from CRS10, given the other representations in this report, and furthermore the simple statement that it is not appropriate for development is queried. Nevertheless, noting the School’s view on this, as explained elsewhere in this report, we are content that Rammell Field can continue to be considered and dealt with as a stand-alone mixed use allocation, sitting outside of the Policy AL/CRS10 area.

4.10 We also seek some physical changes to the red line policy map boundary to AL/CRS 10 in order to identify the School’s correct landholding area. The amended boundary is shown on the plan extract below (Figure 3), which includes the utilities area accessed via The Hill, and a further small parcel of land north of this. Both additional land parcels are identified in yellow.

[TWBC: for Figure 3 Amended Map Boundary for Draft Policy AL/CRS 10, see full supporting statement].

DLP_7576

Susie Oakenfold

Object

I also want to comment about the plans for the centre of Cranbrook, particularly around CRANBROOK SCHOOL AL/CRS 10.  I am not clear what this proposal might be – there is no mention initially of housing and I hope this would never be considered. Whatever is put there though, any resulting additional vehicles using Stone Street etc will be an utter nightmare.

Policy AL/CRS 11: Sissinghurst Castle Garden

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_2086

Terry Everest

Support

Commended

DLP_3306

Kent County Council (Growth, Environment and Transport)

Support

Highways and Transportation

The Local Highway Authority supports this policy.

Public Rights of Way and access Service

KCC welcomes the specific reference to local footpath improvements in paragraph 3, but the text should be strengthened to include the term ‘Public Rights of Way’ as there are also Public Bridleways passing through the site.

Heritage Conservation

Scale 2 - Pre-determination assessment should be carried out to clarify whether development of any part of the site is possible.

This is a highly sensitive site including designated heritage assets.  Any proposals should be informed by an Archaeological DBA

DLP_3567

Kent & East Sussex Regional Office
National Trust

Support with conditions

The National Trust supports the inclusion of a specific policy for Sissinghurst Castle Garden within the Local Plan. As identified within the supporting text, Sissinghurst Castle Garden is an important tourist destination both locally and at a national level. The National Trust would like policy wording included within Policy AL/CRS 11 that supports appropriate development in connection with the continued sustainability of its tourism function. For example, the Trust are continually looking at ways to enhance and improve the sites historic significance and visitor experience and where development is considered necessary in future a positively worded policy would help with this aim. We would therefore like to request discussions with the LPA prior to Regulation 19 to enable us to shape the wording of this site-specific policy and to ensure the deliverability of our plans for the Sissinghurst Castle Garden.

The National Trust supports Policy AL/CRS 11 criterion 1 that seeks the retention of views into, and out of, the site, and in particular views of the castle tower. The National Trust would oppose any future development that adversely impacted on the views from the Tower, garden or wider estate.

DLP_3642

Lynne Bancroft

Support with conditions

I support this policy for Sissinghurst Castle Gardens but believe that the rural character of the countryside that forms the setting and approach to the castle should be protected by widening the area of AONB to the entire ward of Sissinghurst.

I agree that access for bicycles and pedestrians to Sissinghurst Castle Gardens should be improved as currently it is along a very muddy track in a wood or along a narrow, unpaved pavement beside the fast moving A262 with hedges encroaching into the pedestrian access. There is no public transport to the Castle so access from the village of Sissinghurst should be greatly improved.

A cycle path from Bedgebury to Sissinghurst Castle will benefit locals and tourist alike and will bring enhanced economic opportunities to the area.

DLP_7651

Mr J Boxall

Support with conditions

I support this policy for Sissinghurst Castle Gardens but believe that the rural character of the countryside that forms the setting and approach to the castle should be protected by widening the area of AONB to the entire ward of Sissinghurst.

I agree that access for bicycles and pedestrians to Sissinghurst Castle Gardens should be improved as currently it is along a very muddy track in a wood or along a narrow, unpaved pavement beside the fast moving A262 with hedges encroaching into the pedestrian access.  There is no public transport to the Castle so access from the village of Sissinghurst should be greatly improved.

A cycle path from Bedgebury to Sissinghurst Castle will benefit locals and tourist alike and will bring enhanced economic opportunities to the area.

DLP_6306

Susan Heather McAuley

Support with conditions

Point 2 - Preservation of the rural character of the approach to Sissinghurst Castle is not just about the Castle and the village but also from Wilsley Pound to the village and along Common Road, Sissinghurst.  These are the main routes used by visitors to the Castle.  Recently the rural character of the route from the North along Common Road has recently been spoilt by the unsympathetic building of Bramling Gardens and it is important that the approach from the West from Wilsley Pound should be preserved and not urbanised.  The current planning application AL/CRS13  (Site 120) includes a request for urban-style street lighting outside the site. This must be rejected.  The approach to Sissinghurst is very important for tourists.

DLP_6589

Myrtle Newsom

Object

Policy Number: AL/CRS11 Para 5.85

Preservation of the rural character of the approach to Sissinghurst Castle is not just between the Castle and the village but also from Wilsley Pound to the village and along Common Road, Sissinghurst. Unfortunately the rural character of the route along Common Road has already been destroyed by unsympathetic building and it is important that the approach from Wilsley Pound should be preserved.

DLP_7580

Susie Oakenfold

Object

SISSINGHURST CASTLE AL/CRS 11 – What!!!!  This is a historic building and grounds and is of huge national importance.  Why is it even being mentioned on this consultation plan – surely you cannot be serious that it would ever be considered for any development.

Policy AL/CRS 12: Land on the east side of Mill Lane

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_31

Mrs Jan Mulrenan

Object

"Mill Lane is a narrow road with a lack of pavement".

This summarises problems with the proposed plan.

For even 5 terraced houses requiring parking spaces & storage areas for recyclable & refuse the current single point of access from the lane would need to be a good deal wider, especially if a footway were included. There is already an occupied property right by the field gate. The lane would need widening to permit construction vehicles to access the site. Drivers already park along the lane outside houses making Mill Lane a virtual single track road.

I do not see how this plan can be effected without the destruction of lengths of hedgerow & mature trees, perhaps on both sides of the lane, thus destroying its rural character. The existing trees & hedges contribute positively to the area, deadening noise from the A262. They include oak, ash & sycamore.

More houses in Mill Lane would mean more vehicle movement. The southern exit from Mill Lane on to the A262 is a dangerous one; a curve in the A262 just before the exit prevents vehicles clearly seeing traffic coming from the roundabout heading for Sissinghurst village centre. There is a speed limit of 40 mph but it is not rigorously observed.

DLP_7810

John Bancroft

Object

This site is not appropriate for large scale development due to the nature of Mill Lane.

DLP_7831

Andrew Chandler

Object

I do not support any development at this site. It is outside the existing LBD and has not been considered suitable in the consultations and work done in connection with a draft NDP. The LDB should not be expanded to cover areas such as this, which are specifically designated by TWBC as being rural (Mill Lane is a RURAL lane requiring specific consideration under your Supplemental Planning Guidance for Rural Lanes).

If it is to be developed:

- The Policy must have regard to TWBC’s designation of Mill Lane as a rural lane with particular historical importance and ensure that any development is assessed consistently with the requirements of your Supplemental Planning Guidance for Rural Lanes. This SPG requires specific assessment and mitigation given the high rated historical value of Mill Lane.

- The Policy must have regard to the fact that the site is a designated Grassland of Importance and that is adjoins a wildlife protection area created at the time the Primary School was built. There is extensive PROTECTED and other wildlife in this area and all surrounding gardens.

- The Policy must have regard to the fact the site is on a blind corner of a rural lane with no footpath and therefore poses specific dangers for the numerous adult and child pedestrians who use Mill Lane. This will be so particularly during any construction. Any traffic survey for this site must also include a survey of pedestrian use of Mill Lane during peak times (before and after school during term time, rather than during commuter rush hour).

- The houses should only be one deep (this is consistent with the proposed new LBD). This suggests that the number needs to be at the lower end of the proposed range as there is not physically enough space for more. I suggest that the number in the allocation should be reduced to five.

- Design must reflect the neighbouring 18th and 18th century houses on Mill Lane, not the unimaginative design of recent developments on the other side of the village. Particular regard should be had to preserve and enhance the setting of Mill Farm.

- Note that dwellings cannot front onto the lane all the way to the top of the site, as the triangle of land fronting the lane as it curves at the North-Western corner of the site belongs to the neighbouring property. It has not been put forward for development and is not part of this site.

- Any pedestrian (or cycle) access to the public footpath at the East of the site should run through the site and not through the adjoining wildlife area. The wildlife area is managed by the school as part of the school site under an agreement with KCC and is regularly shut off to the public when used for outdoor educational activities.

DLP_659

TJM and KM Wilson

Object

We strongly object to the inclusion of AL/CRS 12 and 13 in the plan, as they both impact totally negatively on the green gaps between Sissinghurst village and Wilsley Pound/Cranbrook Common.

  • AL/CRS 12 will require access from Mill Lane which will involve felling of a number of trees and the consequent effect on the environment.
  • AL/CRS 13 is already the subject of a totally unacceptable planning application, which we have already objected to. It has the effect of urbanising this country village, quite apart from the traffic dangers and the potential increase in street lighting which will be in contravention of the Council’s policy on dark areas.
  • In addition the local infrastructure is totally inadequate to support such developments.

DLP_8270

Ann Gibson

Object

object to the proposed development on the following grounds:

  1. Pedestrian and vehicular access to and from the site will be extremely hazardous. Crossing the A262 at the junction with Mill Lane is a nightmare due to the restricted sight lines. This situation would be made much worse with the resulting extra vehicles and people.
  2. Likewise crossing Mill Lane from the site will be extremely dangerous. The proposed crossing for pedestrians is on a narrow bendy rural lane with a speed limit of 40mph and very restricted views.
  3. Mill Lane is designated by the Borough as a “Rural Lane” and as such should be protected from urbanisation and increased traffic.
  4. A number of mature trees will have to be rmoved. This must be contrary to the guidelines for protecting the flora and fauna of our countryside.
  5. The local diverse and rich wildlife will be greatly affected. We enjoy the presence of numerous birds including owls and woodpeckers who reside on this site. There are also bats, hedgehogs, field mice, voles etc. that rely on the field.
  6. The likelihood of any local employment resulting from developing this rural countryside site is slim at best. Furthermore, the resulting traffic to employment in other places will be contrary to the sustainability plans to reduce our carbon footprint – something I thought the Government was enthusiastic about, as should we all be. The additional traffic will also further clog Sissinghurst and Goudhurst, who already suffer from excess traffic.
  7. The development of this site and site AL/CRS 13 creates a near-coalescence of development between Sissinghurst village and Willesley Green, further degrading a beautiful rural setting.
  8. The shortage of local amenities such as school places, doctors, shops and recreational facilities clearly indicates that the proposed site is unsuitable for a development.

Suggested comments/additions to Paragraph 5.87 Bullet Points: 

  1. The land in question is old parkland that used to be used for grazing cows and sheep until relatively recently.
  2. The site is adjacent to the High Weald AONB.
  3. Mill Lane is designated as a Rural Lane” of historical value. It is unsuitable for the extra volume of traffic that this further development will produce. It is dangerous to walk along due to its narrowness and bends.
  4. Access onto the A262 from Mill Lane is dangerous due to the curving road and the speed of traffic. Access onto the A262 from the proposed site will be even more hazardous.
  5. In talking to local people it is clear that large scale developments are most unwanted.

DLP_8271

Ann Gibson

Object

  1. The removal of established local farming activities on this site is hardly an act of Sustainability. The field is currently used for grazing sheep and is designated by KCC Biodiversity as “Other grassland of Importance” owing to its careful conservation management over the years.
  2. The biodiversity colour on the Table should be red not blue.
  3. Adjoining the field is the historic Mill Farm (the former village miller’s house with windmill). The Heritage colour on the Table should be pink at least.
  4. The removal of the existing group of bee-hives is not what I would expect from a Sustainability policy.
  5. Granting permission to build homes on this site will see increased carbon emissions due to the resulting increase in road traffic.
  6. More traffic will result from allocating all of the new resources to provide employment some distance from the Parish.
  7. Any removal of hedges or trees on the site is to be avoided.
  8. Housing on this site will severely impact the local species of bats, woodpeckers, owls, nightingales and other birds, hedgehogs, newts, grass snakes and slow worms etc. and have a detrimental effect on the adjacent Primary School wildlife conservation area.
  9. Road hazards created on the A262 and Mill Lane by the development must be resolved without impacting Sustainability. This should include avoiding the introduction of street lighting along the A262 and avoiding the removal of any hedges and trees.

DLP_8272

Ann Gibson

Object

object to any proposed development on this land for the following reasons:

  1. Access to Mill Lane from the site will be extremely dangerous being on a narrow bendy rural lane with a speed limit of 40mph and very restricted views.
  2. Pedestrian and vehicular access to the A262 at the junction with Mill Lane is dangerous due to the restricted sight lines. This situation would be made much worse with the resulting extra vehicles and people.
  3. A substantial landscaped buffer would be essential between the adjacent houses.
  4. Mill Lane is designated by the Borough as a “Rural Lane” and as such should be protected from urbanisation and increased traffic.
  5. The local diverse and rich wildlife including bats, birds, hedgehogs, field mice, voles that rely on the field will be greatly affected
  6. The design of any built development should be in keeping with the mainly 19th century properties in Mill Lane.
  7. The likelihood of any local employment resulting from developing this rural countryside site is slim at best. Furthermore, the resulting traffic to employment in other places will be contrary to the sustainability plans to reduce our carbon footprint – something I thought the Government was enthusiastic about, as should we all be. The additional traffic will also further clog the road through Sissinghurst and Goudhurst.
  8. The development of this site and site AL/CRS 13 creates a near-coalescence of development between Sissinghurst village and Willesley Green, further degrading a beautiful rural setting.
  9. The shortage of local amenities such as school places, doctors, shops and recreational facilities clearly indicates that the proposed site is unsuitable for this development.
  10. The site is excluded from the local draft NDP which was produced by the locally elected Parish Council.

Suggested comments/additions to Paragraph 5.87 Bullet Points:

  1. The land in question is currently used for grazing sheep and has been for many years.
  2. The site is adjacent to the “Nature Conservation Area” of the local primary school.
  3. KCC has designated the site “Grassland of Importance” in their biodiversity mapping.
  4. A Weald Bee unit of up to eight hives is situated on the proposed site.
  5. Mill Lane is designated as a Rural Lane” of historical value. It is unsuitable for the extra volume of traffic that this further development will produce. It is dangerous to walk along due to its narrowness and bends.
  6. Access onto the A262 from Mill Lane is dangerous due to the curving road and the speed of traffic. Access onto the A262 from the proposed site will be even more hazardous.

DLP_3039

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 12 Mill Lane, Sissinghurst. (5-10 dwellings) . Near school, but this 0.8 hectare field, currently grazed by sheep, is classified by Kent CC Biodiversity Dept as “Grassland of importance” owing to its careful conservation management over the years. It adjoins the Primary School’s “Nature Conservation Area”. It is also home to a Weald Bee Unit of some 8 hives. The whole site is excluded from the current draft Neighbourhood Development Plan. Mill Lane is designated by TWBC as a “Rural Lane” with a high historic value. RED.

DLP_2087

Terry Everest

Object

This goes against the commended policy above and cannot be supported.

DLP_2463

Mr Geoffrey Robbins

Object

This site is totally unsuitable for large scale development due to its position within Mill Lane, which is a designated Rural Lane. The volume and size of construction traffic will have difficulty in traversing the narrow lane and will undoubtedly destroy hedgerows and verges. The site is also used for grazing and to support Nature conservation by Sissinghurst primary school, and a valuable natural asset will be lost if developed.

DLP_3063

David Knox

Object

I object to the proposals

Addition to 5.86 bullet points

  • Mill Lane is unsuitable for any increase in traffic

Comments on policy AL/CRS12

4. Mill Lane is single track and changes would attract further unwanted traffic to a rural road

5. Pedestrian crossing would produce unwanted urbanisation

7. Design of any new dwellings should be sympathetic to existing houses in Mill Lane

8. 5 to 10 Dwellings is excessive

DLP_3065

Suzanna Knox

Object

I object to the proposals

Addition to 5.86 bullet points

  • Mill Lane is unsuitable for any increase in traffic
  • Mill Lane is a designated Rural Lane

Comments on policy AL/CRS12

4. Mill Lane is single track and changes would attract further unwanted traffic to a rural road

5. Pedestrian crossing would produce unwanted urbanisation

7. Design of any new dwellings should be sympathetic to existing houses in Mill Lane

8. 5 to 10 Dwellings is excessive, 4-5 maximum with associated cars.

DLP_3067

Suzanna Knox

Object

Site is excluded from Cranbrook and Sissinghurst Draft Neighbourhood Plan.

Sissinghurst Primary School is oversubscribed.

Loss of green field land and boundary issues with AONB, agreed.

Limited public transport options in Sissinghurst.

DLP_3307

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The Local Highway Authority objects to this policy.

The Local Highway Authority considers this site unsuitable for residential development. The location of the site significantly limits use of sustainable modes and as a result residents will be largely car dependent; the environment on Mill Lane and the A268 and the lack of footway links to local facilities raise the issue of highway safety; there is currently an unofficial link to the rear of the school via Mill Lane but this is not a PRoW and its future is not secure; the Mill Lane/A262 junction is extremely hazardous with no footway provision and very poor visibility.

Public Rights of Way and access Service

KCC supports the proposal to provide new link with Public Footpath WC75. It should also be expected that contributions will be made towards off-site improvements along Footpath WC75, to mitigate the impact of future development.

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

The site lies between some post medieval heritage sites including Crampton Mill and Farm complex.

Archaeological DBA would be advisable to inform detailed application

DLP_4033

Brian Swann

Object

Mil Lane is a small country lane. It is only wide enough for one lane of traffic and you cannot pass another vehicle unless you pull into the side.

It is quite unsuitable as a development site that would completely change the nature of this rural lane.

This junction with the A262 is completely blind at the southern end of the Lane.

DLP_4382

Mill Lane and Cramptons Residents Association

Object

The Residents Association OBJECTS to the Proposals:

Additions to Paragraph 5.86 Bullet points:

  • In current use for sheep grazing;
  • The 0.8 hectare site has a Kent County Council designation as “Grassland of Importance” on their Biodiversity mapping;
  • Complements the “Nature Conservation Area” of the adjacent Primary School;
  • Home to a Weald Bee Unit of up to 8 hives;
  • Mill Lane is designated by the Borough as a “Rural Lane” of historic value, unsuitable for any increase in traffic volume;
  • This site is excluded for housing in the Draft NDP

Comments on Policy AL/CRS 12 requirements

1. Access on a narrow blind-bend is dangerous;

2. Possible, but a bridge will have to be built to cross the pond at the eastern end of the site;

4. This is a single track rural lane, any widening would attract unwanted traffic;

5. A pedestrian crossing on the A262 Sissinghurst Road would be very undesirable urbanisation;

6. A substantial landscape buffer would be required between any built development and the adjacent Mill Farm house and buildings;

7. The design of any built development would need to complement the mainly 19th century properties in Mill Lane;

8. 5 to 10 terraced properties would be excessive to fit-in; 4 or 5 at most;

9. The remainder of the site should remain in agricultural use as its existing biodiversity designation - also serving as a green-space between Sissinghurst village and Cranbrook Common;

Contributions should include necessary work to maintain and enhance Mill Lane to continue as a designated “Rural Lane”

DLP_6139

Cranbrook & Sissinghurst Parish Council

Object

Should be retained as greenspace between the settlements of Sissinghurst and Cranbrook.

DLP_6145

Jonathan Picken

Object

Paragraph Number(s): 5.86 (Policy AL/CRS 12 Land on the east side of Mill Lane (Site 54)

I object to this proposal.

The points in 5.86 fail to mention that the site is currently used to graze sheep and that there are also extremely important bee hives located there.

They also do not make it clear that Mill Lane is an historic rural lane and simply cannot cope with any increase in traffic that further development may lead to.

As far as the listed requirements are concerned:

  1. Any access onto Mill Lane would be dangerous and would result in increased traffic on a road which is narrow, has blind bends, no pavement and is regularly used by pedestrians. The only sensible access would be onto Sissinghurst Road.
  1. No improvements are required if these will lead to more traffic using Mill Lane. It is not suitable for use as a ‘rat run’.
  1. Houses would be tiny, even if terraced, if there were going to be as many as 10 fronting Sissinghurst Road. There is surely only space for up to 5.

DLP_7202

John Gibson

Object

Adjusting the local LBD and ignoring the wishes of the elected Parish Council in order to facilitate further urbanisation of the rural village of Sissinghurst is deplorable at best.

The lack of local employment opportunities, infrastructure and local amenities makes this development a burden on the village rather than an enhancement.

DLP_7189

John Gibson

Object

object to any proposed development on this land for the following reasons:

a) Access to Mill Lane from the site will be extremely dangerous being on a narrow bendy rural lane with a speed limit of 40mph and very restricted views.

b) Pedestrian and vehicular access to the A262 at the junction with Mill Lane is dangerous due to the restricted sight lines. This situation would be made much worse with the resulting extra vehicles and people.

c) A substantial landscaped buffer would be essential between the adjacent houses.

d) Mill Lane is designated by the Borough as a “Rural Lane” and as such should be protected from urbanisation and increased traffic.

e) The local diverse and rich wildlife including bats, birds, hedgehogs, field mice, voles that rely on the field will be greatly affected

f) The design of any built development should be in keeping with the mainly 19th century properties in Mill Lane.

g) The likelihood of any local employment resulting from developing this rural countryside site is slim at best. Furthermore, the resulting traffic to employment in other places will be contrary to the sustainability plans to reduce our carbon footprint – something I thought the Government was enthusiastic about, as should we all be. The additional traffic will also further clog the road through Sissinghurst and Goudhurst.

h) The development of this site and site AL/CRS 13 creates a near-coalescence of development between Sissinghurst village and Willesley Green, further degrading a beautiful rural setting.

i) The shortage of local amenities such as school places, doctors, shops and recreational facilities clearly indicates that the proposed site is unsuitable for this development.

j) The site is excluded from the local draft NDP which was produced by the locally elected Parish Council.

Suggested comments/additions to Paragraph 5.87 Bullet Points:

a) The land in question is currently used for grazing sheep and has been for many years.

b) The site is adjacent to the “Nature Conservation Area” of the local primary school.

c) KCC has designated the site “Grassland of Importance” in their biodiversity mapping.

d) A Weald Bee unit of up to eight hives is situated on the proposed site.

e) Mill Lane is designated as a Rural Lane” of historical value. It is unsuitable for the extra volume of traffic that this further development will produce. It is dangerous to walk along due to its narrowness and bends.

f) Access onto the A262 from Mill Lane is dangerous due to the curving road and the speed of traffic. Access onto the A262 from the proposed site will be even more hazardous.

DLP_6307

Susan Heather McAuley

Object

This proposed site should not be considered.  Mill Lane is a designated rural lane with no pavement which this draft plan commits to preserving under STR6.  The top end of Mill Lane is not wide enough for two lanes of traffic.

It is outside the LBD.

Point 5 – a pedestrian crossing would be unacceptable urbanisation and would be unused anyway as few people walk along this road – cars would be used by any new residents.

Point 10 – there are no allotments in Sissinghurst which could be improved AL/CR12 would contravene all parts of Policy EN20 – it will damage the unique and diverse variety of the sense of place currently enjoyed by residents, it will cause significant harm to the landscape setting, it will damage the character of the rural lane which is of great nature conservation and historical importance in the village of Sissinghurst. This proposal also contravenes the outdoor lighting and dark skies policy EN10.

DLP_6591

Myrtle Newsom

Object

This proposed site should not even be considered. Mill Lane is a designated rural lane with no pavement which this draft plan commits to preserving under STR6.

DLP_7544

Myrtle Newsom

 

Our objections to the proposals:

The site is designated as a Grassland of Importance, used for sheep grazing.

It is adjacent to the School Nature Conservation

Mill Lane is a designated single track Rural Lane of historical importance. It is used by dog walkers and horse riders and totally unsuitable for any increase in traffic. The site is not  included in the Draft NDP

Comments on requirements.

1. The blind bend is unsuitable for access

4 Mill lane is a designated Rural Lane unsuitable for widening due to properties along the lane.

5. A pedestrian crossing from Mill Lane to the A262 would be dangerous .

8 Terraced properties are totally out of keeping with the local properties and the quantity far too many.

DLP_6938

Juliet Mellor

Object

I strongly object to this proposal and hope that there be reconsideration for the following reasons.

1. This is agricultural land where sheep graze and it is also home to a small apiary

2. 5-10 terraced properties would be excessive – 2 pairs of cottages would be in keeping with the original Mill Farm cottages in the lane.

3. The entrance to this land is on a dangerous bend where the lane is very narrow.

4. Mill Lane is designated by the Borough as a rural lane. The junctions both at the top and bottom are very dangerous and any further development will make this worse.

5. Entry from the A229 into Mill Lane does not allow for a vehicle exiting and entering simultaneously without backing up onto the A229.

Policy AL/CRS 13: Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_32

Mrs Jan Mulrenan

Object

My comments on AL/CRS 12 apply with equal force to this plan. The narrowness of the land would require the destruction of lengths of hedgerow & the felling of mature trees just to provide a footway along one side, thus destroying the rural character of Mill Lane.

The problems would be magnified if 40 houses were constructed on this site. There would be even more vehicles moving around; the period of construction & subsequent obstruction would last longer. The southern exit from Mill Lane on to the A262 would have to be remodelled due to the poor sightline to which I referred in my comments on AL/CRS 12. This would require the felling of mature trees at the southern exit along some hedgerow. The trees include healthy ash specimens. There is also an occupied property immediately on the eastern side bordered by a hedge with mature trees. Remodelling the exit would affect its curtilage & reduce its screening from the A262.

Opposite the exit from Mill Lane & slightly to the east on the southern side of the A262 stands Sissinghurst Court. It is a Historic House & Garden, TQ 78899 37397, Historic England list entry no 1000941. From the A262 it is invisible, being entirely muffled by tall mature trees against the noise of the A262.

Provision of a pedestrian crossing would be welcome if regard were had to the particular dangers of the A262. Drivers would need clear warning of the possibility of pedestrians in the middle of the road, given the speed of many drivers going in both directions. The A262 is not a pleasant road to walk beside, due to the volume of traffic it carries & the noise thus generated. People walk & run along it, but not many.

Another consideration is the increased amount of light that would be created on & near the A262, which had its street lighting turned off previously in order to promote dark skies. 40 houses would need light; Mill Lane in the dark requires careful use by drivers.

There is a risk with this plan that the built up areas of Sissinghurst & of Wilsley Pound would coalesce, which was specifically to be avoided according to an earlier development plan. It would spoil the rural character of the area & alter the nature of Sissinghurst village.

DLP_7806

John Bancroft

Object

Inappropriate for development due to road problems on both A262 and Mill Lane and street lighting would be in breach of TWBA objective of protecting the night sky.

DLP_7832

Andrew Chandler

Object

I do not support any development at this site. It is outside the existing LBD and has not been considered suitable in the consultations and work done in connection with a draft NDP. The LDB should not be expanded to cover areas such as this, which are specifically designated by TWBC as being rural (Mill Lane is a RURAL lane requiring specific consideration under your Supplemental Planning Guidance for Rural Lanes).

If it is to be developed:

- The Policy should have regard to the historical nature of the site, being the location for a windmill in the 18th and 19th centuries. Any historical assessment of the site must consider this aspect.

- The Policy should have regard to the fact that the AONB boundary is at the South of the site. Consistent with your own proposals in paragraph 2.44 of the draft Local Plan, any development at this site must respect the local distinctiveness of the environment and provide specifically for enhancements to the natural, built, and historic environment and the preservation and enhancement of local character and distinctiveness. This requires design that reflects the neighbouring houses, not the unimaginative design of recent developments away from the AONB on the other side of the village. It also requires very careful assessment of any proposal to put street lighting along the edge of the AONB.

- The Policy must have regard to TWBC’s designation of Mill Lane as a rural lane with particular historical importance and ensure that any development is assessed consistently with the requirements of your Supplemental Planning Guidance for Rural Lanes. This SPG requires specific assessment and mitigation given the high rated historical value of Mill Lane.

DLP_8039

Rose May McAuley

Object

This field is outside the village and is not the right place to cram in loads of houses.  If it to be built on about five houses would be more suitable as that would match what is around it.  Your map makes it look like an unused plot of land between loads of houses but it is not that.  It is an open space and a wildlife haven.

DLP_660

TJM and KM Wilson

Object

We strongly object to the inclusion of AL/CRS 12 and 13 in the plan, as they both impact totally negatively on the green gaps between Sissinghurst village and Wilsley Pound/Cranbrook Common.

  • AL/CRS 12 will require access from Mill Lane which will involve felling of a number of trees and the consequent effect on the environment.
  • AL/CRS 13 is already the subject of a totally unacceptable planning application, which we have already objected to. It has the effect of urbanising this country village, quite apart from the traffic dangers and the potential increase in street lighting which will be in contravention of the Council’s policy on dark areas.
  • In addition the local infrastructure is totally inadequate to support such developments.

DLP_8268

Ann Gibson

Object

object to the proposed development:

  1. Pedestrian and vehicular access to and from the site will be extremely dangerous. Crossing the A262 at the junction with Mill Lane is extremely hazardous due to the restricted sight lines. This situation would be made much worse with the resulting extra vehicles and people.
  2. Crossing Mill Lane from the site will be extremely dangerous. The location of the proposed crossing of pedestrians is on a narrow bendy rural lane with a speed limit of 40mph and very restricted views. It is designed for the benefit of children attending the local primary school by a permissive footpath.  The start of the permissive footpath is safeguarded by a “ransom” strip for which permission is currently refused.
  3. Mill Lane is designated by the Borough as a “Rural Lane” and as such should be protected from urbanisation and an increase in vehicular traffic.
  4. In order to accommodate the density of the 44 houses proposed a number of mature trees will have to be removed. Also, trees in neighbouring gardens will inevitably be cut back. This must be contrary to the guidelines for protecting the flora and fauna of our countryside. Has the Tree Officer been notified?
  5. The very close presence of tall houses to the adjacent bungalows in Cramptons means that they will be overlooked. A reasonable buffer zone of semi-mature trees and a “green area” is needed. Similarly, Mill Farm house will be overlooked and should be protected.
  6. The external appearance of the proposed affordable houses is out of keeping with the surrounding properties. They are boxlike, look cheap, have no chimneys and lack any character. The proposed plan shows them all congregated at the north end of the site in a ghetto. They should be integrated amongst the other houses in the development.
  7. The likelihood of any permanent local employment resulting from developing this rural countryside site is nil. Furthermore, the resulting number of vehicles travelling to employment in other places, Maidstone 14 miles, Tunbridge Wells 13 miles, Ashford will be contrary to the sustainability plans to reduce our carbon footprint which the Government is extremely enthusiastic about.  The additional traffic will also further clog Sissinghurst and Goudhurst, which already suffer from logjams.
  8. The development of this site and site AL/CRS 12 creates a near-coalescence of development between Sissinghurst village and Wilsley Green, further degrading a beautiful rural setting.
  9. The shortage of local amenities such as school places, doctors, shops clearly indicates that the proposed site is unsuitable for a development of this size. Sissinghurst has already had approved plans for a development of 66 houses, currently under construction, plus the development of the old school site.
  10. The site is excluded as outside the Limit to Built Development in the NDP.

DLP_8269

Ann Gibson

Object

I object to the application. This will result in the loss of Greenfield Land. The site is adjacent to the High Weald AONB boundary and is old parkland. It was used for grazing cattle and then sheep until fairly recently. Its use for housing is hardly an act of Sustainability. It forms a green-gap between Sissinghurst village and Wilsley Green.

The Biodiversity should be at least pink in the Table, not blue. Housing on this site will severely impact the local species of bats, woodpeckers, owls and other birds, hedgehogs, newts etc. and have a detrimental effect on the nearby Primary School wildlife conservation area.

The Landscape should be red in the Table. This is old Parkland with many fine, mature trees and valuable agricultural land.

Granting permission to build homes on this site will see increased carbon emissions due to the resulting increase in road traffic.

By allocating all of the new resources to provide employment some distance from the Parish more traffic will result.

Any removal of hedges or trees on the site must not be permitted. The ancient rural countryside should be protected

The severe road hazards created on the A262 and Mill Lane by development must be resolved without impacting Sustainability. This should include avoiding the introduction of street lighting along the A262 and the removal of hedges and trees.

The site was excluded from the NDP produced by our locally elected Parish Council.

DLP_2498

Mr John Wotton

Object

This development of 40 new homes would be on a greenfield site outside the LBD and adjoining the AONB boundary. I object to this policy on grounds of harm to the setting of the AONB and the reduction it causes to the green gap between Sissinghurst and Wilsley, thereby blurring distinct, historic settlement patterns.

DLP_3040

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 13 Land east of Camden lodge off A 262 (40 dwellings) . Potentially dangerous access but more important will contribute to coalescence of settlements and add to undesirable ribbon development along this road. Site is adjacent to AONB and in close proximity to Sissinghurst Court a substantial listed country house. Also high level LED Street lighting is proposed along the boundary with the High Weald AONB from Wilsley Pound to Sissinghurst Village. This would involve substantial trimming of the mature tree canopies and would be visually disastrous both day and night. The whole site is excluded from the current draft Neighbourhood Development Plan. RED

DLP_3447

High Weald AONB Unit

Object

The site is outside but immediately adjacent to the High Weald AONB but is within the High Weald National Character Area. The land was part of the parkland setting to Camden Lodge with a wooded shaw to the southern and eastern boundaries. Two oaks remain within the site as remnants of the parkland. The site is relatively flat and sits on a wide ridge and appears historically to have been put to pasture. Development of the site would result in the loss of semi improved grassland which complements the hedgerows and trees and the species they support. With appropriate management the grassland would become more species-rich.

DLP_2088

Terry Everest

Object

Object

This policy goes against policy AL/CRS11 and cannot be supported.

DLP_2214

Mr Geoffrey Robbins

Object

Policy AL.CRS 13. Site Ref 120 - Land to the east of Camden Lodge. I have already lodged my objection to this development on the original planning application, and nothing has changed my views. I am concerned that a SHELAA assessment on behalf of Cranbrook and Sissinghurst NDP dated March 2018 that declared to site to be unsuitable, now appears on the TWBC plan as being assessed by SHELAA now to be suitable ! How can this be ??.

This same report now dated July 2019 states that the site is in 'PROXIMITY' to the LBD, which actually means that it is OUTSIDE the LBD !

Is it acceptable for two story dwellings on this site to be built against the southern boundary of the bungalows in Cramptons, thus destroying privacy ?

Also and most telling of all is the fact that nothing has been mentioned about the only access to/from the site is onto a very dangerous blind bend on the A262 which is also of concern to KCC Highways. Proposals by the developer to destroy hedgerows and the adjacent treeline frontage, and erect streetlighting are totally unacceptable for environmental reasons.

I urge that TWBC rejects this application.

DLP_3064

David Knox

Object

I object to the proposals

Addition to 5.87 bullet points

  • Proposed access to the site from the A262 is wholly unsuitable and dangerous being on a bend in the road without safe sight lines
  •  

Comments on policy AL/CRS13

1, Proposed access onto the A262 is unsuitable and dangerous

5, Any changes to the Mill Lane and Sissinghurst road junction is likely to increase unwanted traffic onto the existing narrow single track Mill Lane.

9, Street lighting and/or road pinch-points would add to unwanted urbanisation of the area.

10, A housing development of this size is not sustainable for the historic village of Sissinghurst in terms of local facilities, education, public health and employment.

DLP_3066

Suzanna Knox

Object

I object to the proposals

Addition to 5.87 bullet points

  • Proposed access to the site from the A262 is wholly unsuitable and dangerous being on a bend in the road without safe sight lines
  • Mill Lane is designated Rural Lane of historic value unsuitable for any increased volume of traffic.
  • The southern boundary adjoins the High Weald AONB.

Comments on policy AL/CRS13

1, Proposed access onto the A262 is unsuitable and dangerous

3, A pedestrian crossing and the associated lighting would urbanise the approach to Sissinghurst and dilute the character of an historic settlement.

4,There is no accessibility to footpaths or pavements.

5, Any changes to the Mill Lane and Sissinghurst road junction is likely to increase unwanted traffic onto the existing narrow single track Mill Lane.

9, Street lighting and/or road pinch-points would add to unwanted urbanisation of the area.

10, The proposed housing development is not sustainable in terms of access to local facilities, pavements, public transport, education, public health and employment. Just crossing the road to leave the site is dangerous either on foot, by bicycle or in a car.

DLP_3068

Suzanna Knox

Object

Loss of green field site adjacent to AONB boundary

Site is excluded from Cranbrook and Sissinghurst Neighbourhood Development Plan.

There is no access to a safe walking path from the site to the school and public transport.

Journeys would be taken by car to access schools, public transport, and health and employment facilities.

The primary school is oversubscribed.

It is a green gap between Sissinghurst village, an historic settlement and Willesley Pound.

DLP_3308

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The Local Highway Authority objects to this policy.

KCC considers this site unsuitable for residential development. The location of the site significantly limits use of sustainable modes and as a result residents will be largely car dependent; the environment on Mill Lane and the A268 and the lack of footway links to local facilities raise the issue of highway safety; there is currently an unofficial link to the rear of the school via Mill Lane but this is not a PRoW and its future is not secure; the Mill Lane/A262 junction is extremely hazardous with no footway provision and very poor visibility; the visibility splays required for the measured speed of traffic on the A262 where the site access road would be located cannot be accommodated within the site boundary/highway ownership.

Public Rights of Way and access Service

KCC supports the proposal to create link with Public Footpath WC75. It should also be expected that contributions will be made towards off-site improvements along Footpath WC75, to mitigate the impact of future development.

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is potential for prehistoric and later remains, especially associated with the development of the historic settlement of Sissinghurst.

DLP_4125

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

This development of 40 new homes would be on a greenfield site outside the LBD and adjoining the AONB boundary. CPRE Kent has objected to a recent planning application for a smaller number of homes on this site and objects to this policy on grounds of harm to the setting of the AONB and the reduction it causes to the green gap between Sissinghurst and Wilsley, thereby blurring distinct, historic settlement patterns.

DLP_4685

CBRE Ltd for Dandara Ltd

 

Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road

4.95 The site comprises undeveloped land, in close proximity to the existing Sissinghurst Limits to Built Development. The site is adjoined by residential properties to the north and west, Sissinghurst Road (the A262) runs along its southern boundary, beyond which lies fields, and Mill Lane (narrow, with no pavement) runs along its eastern boundary, beyond which lies residential properties and fields including Sissinghurst Court Historic Park and Garden to the south-east. Access is currently via an existing field gate in the south-east corner of the site. A Site Location Plan is included in Figure 5 below.

[TWBC: for Figure 5, see page 28 of full representation].

4.96 The site (site ref. CRS13) is allocated for residential development for approximately 40 dwellings. The development of the site will require highways assessment and works, in terms of access.

4.97 In the current Development Plan, the site borders the Limits to Built Development of Sissinghurst to the north and east. There is a Tree Preservation Order (TPO) along the part of the western boundary of the site. The site is located opposite (opposite side of A262) the High Weald Area of Outstanding Natural Beauty (AONB).

4.98 It is noted that Land to the east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road, Sissinghurst, was assessed as part of the Strategic Housing and Economic Land Availability Assessment in July 2019. The assessment concluded that the site is likely to be sustainable, due to its proximity to the Limits to Built Development and adjoining existing built development. The assessment also noted the availability of the site and its ability to be delivered within the Plan period.

4.99 Dandara supports the allocation of this site, in respect of which it submitted a planning application in February 2019 which is currently pending consideration (LPA ref. 19/00308/FULL) for:

“Development of land to the west of Mill Lane and north of Sissinghurst Road, Sissinghurst to provide 44 new dwellings, including affordable homes, alongside car parking, cycle parking, drainage, internal road network and the creation of a principal access off Sissinghurst Road (A262) alongside public open space, including a play area, and associated landscaping”.

4.100 The proposed scheme will deliver a mix of market and affordable homes as part of the comprehensive development of the site including new access, parking and landscaping. The provision of circa 40 new homes is based on robust viability testing and consideration for the site’s constraints.

4.101 Based on the technical findings, Dandara considers the proposed delivery of circa 40 homes to represent efficient use of land and is policy compliant. Moreover, the provision of circa 40 units is consistent with TWBC’s aspiration for the site as set out in the draft site allocation / Draft Policy AL/CRS13.

4.102 In order to ensure that the site allocation is in accordance with the NPPF (paragraph 35) tests of soundness; positively prepared, justified, effective and consistent with national policy Dandara have provide the following comments in relation to this site:

4.103 Under Policy AL/CRS13 the site is allocated for residential development for approximately 40 dwellings. Dandara supports this allocation.

4.104 The pending application (LPA ref. 19/00308/FULL) presents a detailed and robust planning case for the development of this site. In summary, this undeveloped site is located in a prominent and sustainable location off the A262 Sissinghurst Road with the opportunity for direct access off the A262 and/or Mill Lane. The site is flat in topography and is located in Flood Zone 1.

4.105 The site is therefore suitable for housing, would constitute appropriate infill development, and would be a suitable and sustainable extension to Sissinghurst.

4.106 The site is available.  The development of circa 40 homes is of an appropriate scale and will not pose any delivery challenges. Policy AL/CRS 13 Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road - Dandara notes the following:

4.107 Dandara supports the inclusion of site allocation AL/CRS13 in the Draft Local Plan and promotion for housing. The site is suitable for housing, available and deliverable within the first 5 years of the Plan period.

4.108 Dandara makes the following comments in respect to the detailed wording of Policy AL/CRS 13:

4.109 In relation to paragraph 5 of Policy AL/CRS13, this requires that the development of the site includes improvements to the road junction with Mill Lane and Sissinghurst Road, including exploring opportunities to improve visibility from Mill Lane across the corner of the site, with minimal loss of boundary features. Dandara is seeking clarification as to how this would be funded. For example, would be considered as part of the site allocation development, or will it be included in the highways works in the contributions expected (Policy AL/CRS 13: paragraph 8b).

4.110 This clarification is required to ensure that the allocation is positively prepared (NPPF paragraph 35) and the vision for its development can be fulfilled.

4.111 The red line indicating the proposed site allocation policy boundaries appears to include land belonging to an adjacent residential property (on the western side of the site). Dandara suggest TWBC redraw the policy allocation based on up to date land registry data to ensure the effectiveness of the allocation (required under NPPF paragraph 35).

[TWBC: see full representation].

DLP_3643

Lynne Bancroft

Object

Policy Number: AL/CRS 13 – Land east of Camden Lodge, adjacent to Mill Land and Sissinghurst Road

I object to this site being included in the TWBC Local Plan due to:

* It has been assessed as unsuitable and unsustainable by the Cranbrook and Sissinghurst Parish Council / Draft Neighbourhood Development Plan

* It is contrary to the draft Strategic objective 6 as building here will impact on the adjacent AONB, the historic rural lane of Mill Lane and the historic Sissinghurst Court Historic Park and Gardens

* It is contrary to the draft Policy EN 7 as building here will impact on the historic rural lane of Mill Lane and the historic Sissinghurst Court Historic Park and Gardens

* It is contrary to the draft Policy EN18 as it is on the edge of the AONB and will impact on this area due to additional lighting and urbanisation of the area

* It is contrary to the draft Policy EN20 as it will result in unsympathetic change to the character of an adjacent rural lane, Mill Lane, and will not protect current dark skies in the area

* It will damage the local sense of place so is again contrary to the draft policy EN20

* It is contrary to the draft policy EN21 as it will impact on the adjacent AONB and be visible from the AONB

* It is contrary to the draft policy EN10 as it give additional outdoor lighting in the area as well as along the A262 which is currently unlit.

* It is urbanising the local sense of place by providing a street crossing across the A262 so is again contrary to the draft policy EN20

* The access to the A262 is on a dangerous stretch of road will little visibility and access to this site will cause road accidents

* Mill Lane cannot cope with any increase in vehicular traffic

* The development will impact on the current one storey buildings in Cramptons and the historic buildings in Mill Lane

* Any development here will be contrary to Tunbridge Wells Borough council’s Landscape Sensitivity Study for PW, Horsmonden, Hawkhurst and Cranbrook

I also disagree with the new proposed Limits to Build which include this site as they will allow the coalescence of Mill Lane to Wilsley Pound and will start to create a new settlement outside of the Sissinghurst village centre.

DLP_3495

Tara McCumiskey

Object

We live at [TWBC: House name redacted] (rear of) the access/exit onto the A262 is very dangerous, as a family we always turn left then I turn left onto Mill Lane if I'm going to Staplehurst, or I turn right opposite Mill Lane to come back on myself. The previous vendors that owned Camden House had a bad accident exiting onto the A262 over 12 years ago & the road is extremely busy now days. The development is unsuitable for that number of house's on the A262 & Mill Lane.

DLP_4383

Mill Lane and Cramptons Residents Association

Object

The Residents Association OBJECTS to the proposals:

Additions/ Comments to Paragraph 5.87 Bullet points:

  • This old parkland deliberately left to go derelict over a number of years rather than grazed with farm livestock;
  • The adjacent Mill Lane is designated by the Borough as a “Rural Lane” of historic value, unsuitable for any increase in traffic volume which is a certainty if the proposed housing development is given planning consent;
  • The southern boundary of the site adjoins the boundary of the High Weald AONB
  • The proposed access/exit onto the A.262 is dangerous owing to lack of sight-lines along the gently curving road. There is no simple remedy to this without damage to environmental considerations – which are incompatible with the AONB Management Plan and the NPPF.

Comments on Policy AL/CRS 13 requirements

1. Access/exit onto the A.262 is dangerous; Concern already expressed by KCC Highways. No obvious remedy that fulfils environmental requirements;

2. No safe link for pedestrians to cross the A.262 to the existing pavement;

3. A pedestrian crossing would urbanise this country road and would therefore be totally out of character;

4. Pedestrian links with footpath WC75 may not be possible owing to privately owned land;

5. Mill Lane is a TWBC designated “Rural Lane”. Any altering of the junction with Sissinghurst Road is likely to encourage use of the narrow lane by more

vehicles which would be highly undesirable;

6. A substantial landscape buffer of semi-mature trees would be required between any built Development and the adjacent Mill Farm house and buildings, and the gardens of Nos.8 to12 in Cramptons;

7. The design of any built development would need to complement the mainly 19th century properties in Mill Lane and be in accordance with the latest NPPF criteria on exterior design and layout;

8. The exterior design of the proposed “Affordable” homes is particularly poor and not in accordance with the NPPF. They should also be scattered amongst the freehold homes and not in a “ghetto” on the north side of the site;

9. The proposed homes on the north of the site should be bungalows or chalet bungalows so as not to have high roof ridges or overlook the homes and gardens in Cramptons;

10. The southern boundary of the site adjoins the High Weald AONB. The A.262

This attractive tree-lined Sissinghurst Road should not be urbanised in any way and the status-quo maintained. That is the 40 MPH speed limit should remain, and there should be no street lighting or pinch-points or such-like;

11. There is little or no employment opportunities in Sissinghurst, so residents in the proposed new homes will have to drive to Staplehurst Station, or to Tunbridge Wells, Ashford or farther afield. The proposed housing development, particularly of this size, is not sustainable development;

12. This site is excluded for housing in the Draft NDP.

Contributions from the developer should

a) Include necessary work to maintain and enhance Mill Lane to continue as a designated “Rural Lane” and

b) Pay for high-speed fibre broadband to be available to all properties in Mill Lane and Cramptons

DLP_6140

Cranbrook & Sissinghurst Parish Council

Object

Should be retained as greenspace between the settlements of Sissinghurst and Cranbrook.

DLP_7652

Mr J Boxall

Object

I object to this site being included in the TWBC Local Plan due to:

  • It has been assessed as unsuitable and unsustainable by the Cranbrook and Sissinghurst Parish Council / Draft Neighbourhood Development Plan
  • It is contrary to the draft Strategic objective 6 as building here will impact on the adjacent AONB, the historic rural lane of Mill Lane and the historic Sissinghurst Court Historic Park and Gardens
  • It is contrary to the draft Policy EN 7 as building here will impact on the historic rural lane of Mill Lane and the historic Sissinghurst Court Historic Park and Gardens
  • It is contrary to the draft Policy EN18 as it is on the edge of the AONB and will impact on this area due to additional lighting and urbanisation of the area
  • It is contrary to the draft Policy EN20 as it will result in unsympathetic change to the character of an adjacent rural lane, Mill Lane, and will not protect current dark skies in the area
  • It will damage the local sense of place so is again contrary to the draft policy EN20
  • It is contrary to the draft policy EN21 as it will impact on the adjacent AONB and be visible from the AONB
  • It is contrary to the draft policy EN10 as it give additional outdoor lighting in the area as well as along the A262 which is currently unlit.
  • It is urbanising the local sense of place by providing a street crossing across the A262 so is again contrary to the draft policy EN20
  • The access to the A262 is on a dangerous stretch of road will little visibility and access to this site will cause road accidents
  • Mill Lane cannot cope with any increase in vehicular traffic
  • The development will impact on the current one storey buildings in Cramptons and the historic buildings in Mill Lane
  • Any development here will be contrary to Tunbridge Wells Borough council’s Landscape Sensitivity Study for PW, Horsmonden, Hawkhurst and Cranbrook

I also disagree with the new proposed Limits to Build which include this site as they will allow the coalescence of Mill Lane to Wilsley Pound and will start to create a new settlement outside of the Sissinghurst village centre.

DLP_6149

Jonathan Picken

Object

5.87 (Policy AL/CRS 13 Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road (Site 120)

I object to this proposal.

The points in 5.87 fail to mention that Mill Lane is an historic rural lane which is totally unsuitable for any increase in traffic that development of this site will involve unless access into Mill Lane from the Sissinghurst Road end is prevented.

As far as the listed requirements are concerned:

  1. Access on to Sissinghurst Road by vehicles for so many houses will be extremely dangerous. There is a blind bend adjacent to the access and, whatever speed restrictions or traffic calming measures are implemented, vehicles will exceed the speed limit.
  2. The footway is little used as it is extremely narrow, making walking towards Sissinghurst village an unpleasant experience. It will be little used in practice even with an pedestrian link.
  1. This is not possible as access is over private land.
  2. It is imperative that Mill Lane is not subject to increased vehicle levels. The only way of achieving this is to prevent cars going up Mill Lane from Sissinghurst Road. Turning left onto Sissinghurst Road will not become less dangerous even with improved visibility.
  3. Existing hedgerows along the boundary must be protected.  Indeed, boundary features must be improved and a gap between them and any buildings on the development imposed so as to protect the privacy of houses in Mill Lane and The Cramptons.  Any houses close to these boundaries must be single storey bungalows

DLP_6834

John Gibson

Object

object to the proposed development on the following grounds:

a) Pedestrian and vehicular access to and from the site will be extremely hazardous. Crossing the A262 at the junction with Mill Lane is a nightmare due to the restricted sight lines. This situation would be made much worse with the resulting extra vehicles and people.

b) Likewise crossing Mill Lane from the site will be extremely dangerous. The proposed crossing for pedestrians is on a narrow bendy rural lane with a speed limit of 40mph and very restricted views. It is suggested that this will provide access to children attending the local primary school. This is too dangerous to contemplate.

c) Mill Lane is designated by the Borough as a “Rural Lane” and as such should be protected from urbanisation and increased traffic.

d) In order to accommodate the density of houses proposed a number of mature trees will have to be removed. Also, trees in neighbouring gardens will inevitably be cut back in order to achieve the high density proposed. This must be contrary to the guidelines for protecting the flora and fauna of our countryside. Has the Tree Protection Officer been consulted, as I previously requested?

e) The local diverse and rich wildlife will be greatly affected. We enjoy the presence of numerous birds including owls and woodpeckers who reside on this site. There are also bats, hedgehogs, field mice, voles etc. that rely on the field.

f) The very close presence of tall houses to the adjacent bungalows in Cramptons means that they will be overlooked. A reasonable buffer zone of semi-mature trees and a “green area” would be essential. Similar consideration should be provided to Mill Farm House.

I object to the proposed development on the following grounds:

a) Pedestrian and vehicular access to and from the site will be extremely hazardous. Crossing the A262 at the junction with Mill Lane is a nightmare due to the restricted sight lines. This situation would be made much worse with the resulting extra vehicles and people.

b) Likewise crossing Mill Lane from the site will be extremely dangerous. The proposed crossing for pedestrians is on a narrow bendy rural lane with a speed limit of 40mph and very restricted views. It is suggested that this will provide access to children attending the local primary school. This is too dangerous to contemplate.

c) Mill Lane is designated by the Borough as a “Rural Lane” and as such should be protected from urbanisation and increased traffic.

d) In order to accommodate the density of houses proposed a number of mature trees will have to be removed. Also, trees in neighbouring gardens will inevitably be cut back in order to achieve the high density proposed. This must be contrary to the guidelines for protecting the flora and fauna of our countryside. Has the Tree Protection Officer been consulted, as I previously requested?

e) The local diverse and rich wildlife will be greatly affected. We enjoy the presence of numerous birds including owls and woodpeckers who reside on this site. There are also bats, hedgehogs, field mice, voles etc. that rely on the field.

f) The very close presence of tall houses to the adjacent bungalows in Cramptons means that they will be overlooked. A reasonable buffer zone of semi-mature trees and a “green area” would be essential. Similar consideration should be provided to Mill Farm House.

g) The external appearance of the affordable houses is out of keeping with the surrounding properties. They are boxlike, look cheap, have no chimneys and lack any character. They will stand out like a sore thumb being next to an Area of Natural Beauty and on an access road to the internationally renowned Sissinghurst Gardens. The proposed plan shows them all congregated at the far end of the site in a ghetto-like enclave which is most regrettable.

h) The likelihood of any local employment resulting from developing this rural countryside site is slim at best. Furthermore, the resulting traffic to employment in other places will be contrary to the sustainability plans to reduce our carbon footprint – something I thought the Government was enthusiastic about, as should we all be. The additional traffic will also further clog Sissinghurst and Goudhurst, who already suffer from excess traffic.

i) The development of this site and site AL/CRS 12 creates a near-coalescence of development between Sissinghurst village and Willesley Green, further degrading a beautiful rural setting.

j) The shortage of local amenities such as school places, doctors, shops and recreational facilities clearly indicates that the proposed site is unsuitable for a development of this size.

k) The site is excluded from the local draft NDP which was produced by the locally elected Parish Council.

Suggested comments/additions to Paragraph 5.87 Bullet Points:

a) The land in question is old parkland that used to be used for grazing cows and sheep until relatively recently.

b) The site is adjacent to the High Weald AONB.

c) Mill Lane is designated as a Rural Lane” of historical value. It is unsuitable for the extra volume of traffic that this further development will produce. It is dangerous to walk along due to its narrowness and bends.

d) Access onto the A262 from Mill Lane is dangerous due to the curving road and the speed of traffic. Access onto the A262 from the proposed site will be even more hazardous.

e) In talking to local people it is clear that large scale developments are most unwanted.

g) The external appearance of the affordable houses is out of keeping with the surrounding properties. They are boxlike, look cheap, have no chimneys and lack any character. They will stand out like a sore thumb being next to an Area of Natural Beauty and on an access road to the internationally renowned Sissinghurst Gardens. The proposed plan shows them all congregated at the far end of the site in a ghetto-like enclave which is most regrettable.

h) The likelihood of any local employment resulting from developing this rural countryside site is slim at best. Furthermore, the resulting traffic to employment in other places will be contrary to the sustainability plans to reduce our carbon footprint – something I thought the Government was enthusiastic about, as should we all be. The additional traffic will also further clog Sissinghurst and Goudhurst, who already suffer from excess traffic.

i) The development of this site and site AL/CRS 12 creates a near-coalescence of development between Sissinghurst village and Willesley Green, further degrading a beautiful rural setting.

j) The shortage of local amenities such as school places, doctors, shops and recreational facilities clearly indicates that the proposed site is unsuitable for a development of this size.

k) The site is excluded from the local draft NDP which was produced by the locally elected Parish Council.

Suggested comments/additions to Paragraph 5.87 Bullet Points:

a) The land in question is old parkland that used to be used for grazing cows and sheep until relatively recently.

b) The site is adjacent to the High Weald AONB.

c) Mill Lane is designated as a Rural Lane” of historical value. It is unsuitable for the extra volume of traffic that this further development will produce. It is dangerous to walk along due to its narrowness and bends.

d) Access onto the A262 from Mill Lane is dangerous due to the curving road and the speed of traffic. Access onto the A262 from the proposed site will be even more hazardous.

e) In talking to local people it is clear that large scale developments are most unwanted.

DLP_6852

John Gibson

Object

Adjusting the local LBD and ignoring the wishes of the elected Parish Council in order to facilitate further urbanisation of the rural village of Sissinghurst is deplorable at best.

The proposed Dandara development fails many of the TWBC Council’s sustainability and environmental policies.

The lack of local employment opportunities, infrastructure and local amenities makes this development a burden on the village rather than an enhancement.

DLP_6308

Susan Heather McAuley

Object

This site has been assessed as unsuitable infilling and unacceptable because it creates coalescence between Wilsley Pound and Sissinghurst village as stated in CTR/CRS1 Point 3  In this case TWBC has not taken into account the assessments made by the Parish Council draft Neighbourhood Development Plan.

Point 4 – a pedestrian crossing would be unacceptable urbanisation and would not be used anyway.

Point 7 – it will create coalescence.  It cannot avoid it.  It will also destroy this Arcadian area created by Camden House and Camden Lodge in a parkland setting.

Point 8 – there are no allotments in Sissinghurst to be improved.

AL/CR13 would contravene all parts of Policy EN20 – it will damage the unique and diverse variety of the sense of place currently enjoyed by residents, it will cause significant harm to the landscape setting, it will damage the character of the rural lane which is of great nature conservation and historical importance in the village of Sissinghurst.  It is alongside the main entry point to the village from the busy western side and presents Sissinghurst as a typical small Wealden village.  This proposal also contravenes the outdoor lighting and dark skies policy EN10.

DLP_6592

Myrtle Newsom

Object

This site has been assessed as unsuitable infilling and unacceptable because it creates coalescence between Wilsley Pound and Sissinghurst village as stated in CTR/CRS1 Point 3 TWBC has ignored the assessments made by the Parish Council draft Neighbourhood Development Plan.

DLP_7545

Myrtle Newsom

Object

The parkland has not been grazed for a considerable time and is a haven for wildlife including resident tawny owls, green and spotted woodpeckers, tree creeper, long-tailed tits etc.

The design of the proposed housing is particularly poor and not in accordance with policies in the Draft Local Plan concerning appropriate and sympathetic housing design, taking into account the local vernacular.

Mill Lane is designated a single-track rural lane of historical importance and is totally unsuitable for any increase in traffic which would arise from the use of Mill Lane as a short cut between the A262 and A229.  The residents already have parking problems due to the width of the lane.

The proposed exit to the A262 is most dangerous due to the lack of visibility and amount of traffic.  A pedestrian crossing from Mill Lane is urbanisation and not in keeping with the rural aspect.

The proposed exit onto the A262 should not be splayed as this would not be in keeping with the setting and therefore sight lines for people exiting will be very restricted.  Any widening of the exit onto the A262 would encourage even more traffic to take a short cut to the A229 along a lane which is only really suitable for residents and deliveries.

Concern about the access has already been expressed by KCC Highways.

Pedestrian links with footpath WC75 may not be possible as they would need to cross privately owned land.

It will be essential to plant extra trees to act as a barrier between the development and the gardens of Cramptons bungalows and Mill Farm, on the other side of Mill Lane.

DLP_6946

Juliet Mellor

Object

I object to these proposals:

1. This is parkland providing a green gap between housing and is outside the village

2. This land is close to an ANOB and Mill Lane which is designated by the Borough as a rural lane. It is too narrow for cars to pass.

3. Traffic from this site is very likely when going towards Staplehurst/Maidstone to use Mill Lane as a rat run.

4. The junction of Mill Lane and the proposed junction to the site with A262 is very dangerous because of reduced site lines.

5. Trees on the south east corner of the site has always been inhabited by owls – I have lived at Mill Farm for over 30 years and the owls were there prior to that.

6. The proposed housing density is far too high for the area.

7. Lack of local employment would mean that the residents would have to travel far by car as public transport is scarce and unreliable thereby increasing the traffic on roads that are already overcrowded particularly at rush hour in Sissinghurst village. Ecologically this is very unsound.

8. The 40 mph limit between Wilsley Pound and Sissinghurst village is not adhered to and neither would a 30 mph limit.

9. Any 30 mph limit is unlikely to be adhered to and in order to have the necessary lighting a huge number of trees would have to be felled next to the ANOB.

10. Extra lighting and tree felling is very unecological.

Policy AL/CRS 14: Land south of The Street

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_8040

Rose May McAuley

Support with conditions

There aer too many houses planned for this field.  It will make the road even more congested and dangerous.  There wil pnly be one way out and that is onto the buisy Street.

The Local Plan idea will eb overbearing for nearby houses and there should only be a few houses built away from the Street and away from the footpath at the back.

I don’t see the point of a new large Village Hall, we already have the School if we want to hire a barn-like space.  It is important to keep small village halls as well.  If this new large hall is built who will rent it, who will clean and insure and decorate and maintain it?  New people moving into the village are not interested in doing any of that and the ones who do it now are getting old and do not want the extra work.

DLP_923

Mrs Jan Mulrenan

Object

1] vehicular access. this site was proposed for development before, maybe 6 years ago. The developers held a meeting to allow Sissinghurt's residents to see the proposal. It foundered, chielfy, I believe, over the issue of access. The only way an access road could be conceived was by knocking down two privately owned garages. It was proposed that two new garages should be provided for the owners within the new development. I donot think this proposal appealed to them. The access road will still have been rather narrow and sight lines on to The Street would have been poor. The Street is used for residential parking on both sides as few houses fronting the Street have parking spaces, particularly on the north side. Large lorries cause frequent jams in The Street and builders' vehicles would do the same while construction proceeded. Just west of the proposed access road are a bus stop and a public convenience which both cause much vehicular movement during the working day. An added complication is the need for buses coming south down Common Road to swing right on to The Street, for which they need a lot of turning room. Access for rubbish collection vehicles will also need consideration.

2] the number of properties suggested. The site seems very tight for the 20 buildings proposed together with their parking spaces and their rubbish and recycling containers. Will it be possible to avoid overlooking the rear of homes along The Street, some of which are small terraced properties? The new builds would need a design that sympathised with them. I do not think a new community hall is needed as the church has a hall. The primary school does too, although it is available for fewer hours.

3] the proximity of the tennis club and the opinions of its members about the proximity of buildings to their leisure facility.

4] the effect on the hedges and mature trees running along footpath WC104. This is a buffer between the built up village and the agricultural land to the south. The rough land that might once have been paddock had a couple of sheep on it in March this year, so somebody used it and somebody must own it.

DLP_3041

Cranbrook Conservation Area Advisory Committee

 

As a positive suggestion to aid the process of site prioritisation, we have looked at individual sites across Cranbrook and Sissinghurst in terms of conservation, heritage and sustainability. Sites have been ranked using a red, amber and green system, where RED means no development, AMBER means some issues or reduced numbers and GREEN indicates probably acceptable for housing.

* AL/CRS 14 Land south of the Street, Sissinghurst. (20 dwellings) Adjoins Sissinghurst CA but already considerable development on this side of the Street and will be close to services and school. The design and layout of any new build will be crucial. Less dense single-storey development for the elderly would be ideal. AMBER

DLP_2437

J Coleman

Object

I would only support this site being developed if the houses are one-story bungalows. Any taller buildings will impact adversely on the adjacent homes which are in the conservation area and will impact on the dark skies and the adjacent AONB

DLP_3309

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Additional paragraph - Provision of adequate visibility splays within site and/or highway land (again see criterion 5 of Policy EN 1: Design and other development management criteria)

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

Public Rights of Way and access Service

Provision of a pedestrian link to Public Right of Way WC104, is supported. It should also be expected that contributions will be made towards off-site improvements along Footpath WC104, to mitigate the impact of future development.

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is potential for prehistoric and later remains, especially associated with the development of the historic settlement of Sissinghurst.

DLP_3644

Lynne Bancroft

Support with conditions

Policy Number: AL/CRS 14 – Land south of The Street

I support this site being allocated for a new village hall and housing only if there is no impact on the adjacent AONB, the rural nature of the site and adjoining land or the current dark skies as the issues with development of this site are as follows:

* It is contrary to the draft Policy EN18 as it is on the edge of the AONB and will impact on this area due to additional lighting and urbanisation of the area

* It is contrary to the draft policy EN21 as it will impact on the adjacent AONB and be visible from the AONB

* Access to the A262 is an issue

* It is contrary to the draft policy EN10 as it give additional outdoor lighting in the area

* Development will cause flooding in adjacent land and on public footpaths to the south of the site.

However, the village desperately needs housing for older people in a central village location so I would support smaller homes suitable for older people as defined under Policy H9. This is a key central village location, near to the shop, pub, take-away and transport links, so if it is to be developed it should meet the requirements of Policy H9.

DLP_5171

Bloomfields for Fernham Homes

 

This representation has been prepared on behalf of Fernham Homes in response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until 15th November 2019.

Context

The application site consists of an area of residential garden land to the rear of those properties which align the south side of The Street, and an adjacent field which has historically been used for sheep grazing. The site is subdivided into a series of paddocks by post and wire fencing. There is a narrow northern strip closest to the houses fronting onto The Street which is separated from the main part of the site to its south by a chain link fence. This area has itself been divided into a series of smaller plots by fencing, and there is a garden shed in the eastern part of this area. The larger southern area is in use for sheep grazing, and is divided into smaller paddocks by post and wire fencing, with a timber field shelter in its eastern part.

The topography of the site is gently undulating with a natural decline of around 1 metre from the northwest corner to the southeast corner of the site. There are no trees or any substantial planting within the interior of the site, which is well-defined by existing hedgerow boundary planting. The site falls immediately adjacent to the Limits to Built Development as defined by the Tunbridge Wells Local Plan of 2006.

As laid out within the Landscape and Visual Assessment (June 2017), the northern boundary runs along the rear garden boundaries of the houses to the north and is marked by low garden fences and hedges, with some trees and shrubs along the boundary line and also within the gardens to the north. There is a field gate roughly in the centre of this boundary, with access along a surfaced drive from The Street, and the trees and hedges are generally taller and provide a more effective screen to the site to the east of this gate.

There is also back-land residential development to the east of the site. The eastern boundary runs along the rear garden boundaries of the houses to the east of the site, both the row of cottages fronting onto the road and also the large detached property (Galleons Lap) accessed via a side road off The Street to the south - there are also some properties to the east of this side road, behind the roadside properties. There is a tall, mixed hedge comprising mainly hazel and hawthorn along this boundary, with some lower sections and also some tall trees including oaks just beyond it and within the adjoining gardens.

The recreational fields also lie to the west. The southern part of the western boundary runs alongside the tennis courts, and is marked by a dense hazel and hawthorn hedge around 6m in height. To the north of the tennis courts there is a taller hedge of hawthorn and blackthorn with some tall oak and ash trees, and a field gate from the recreation ground roughly in the centre of this part of the boundary. The site therefore retains a sense of enclosure from the wider landscape to the west.

The southern boundary is marked by a post and wire fence, with the public footpath running just to the south of the fence line. To the south of the footpath is a dense hedgerow comprising holly and hazel with some tall oak trees at either end, which effectively encloses the site and demarcates it from the boundary of the High Weald Area of Outstanding Natural Beauty.

The site also extends to the north, to meet The Street along the line of the proposed access. Here there is a mixed species hedge (including some privet) around 4m in height between this part of the site and the St George’s Institute (the village hall), and a garden boundary fence between the site and the property to the east, number 4 Oliver’s Cottages.

Site History

The site has historically been owned by the Bringloe family, which has been a part of the Sissinghurst community for a considerable number of years. The land which is currently occupied by the Sissinghurst Tennis Courts and the extension to the village hall, known as St George’s Institute were both carried out on land that was previously ‘gifted’ to the community by the Bringloe family.

In 1979, a planning application for the construction of three dwellings with rear access and additional parking areas was permitted (under reference TW/79/00802/FUL). This was accompanied by an application for Listed Building Consent to demolish 3 storage sheds, 1 garage and a block of two garages (permitted under ref. TW/79/0804/Listed Building Consent). The planning application permitted in 1979 included not only the construction of three dwellinghouses but also the construction of five double garages and one single garage to the rear.

That scheme was implemented by virtue of the construction of the two properties now known as Farnol Cottages and two of the permitted garages were constructed in accordance with the approved plans. That permission is therefore extant following the construction of part of that scheme. This means that the single dwelling-house and garages which have not yet been constructed could now lawfully be constructed at any time. The current planning application would therefore supersede the implementation of that part of the previously approved scheme.

[TWBC: See plans and figures in full representation].

A planning permission was also previously granted in February 2015 for the construction of two detached garages at a part of this site (under reference TW/14/504825/FUL). This current planning application would therefore supersede the implementation of that planning permission. It is also noteworthy that within the Council’s report for that application it was acknowledged that the fore-mentioned planning permission (in 1979) for the construction of three dwelling and parking garages is extant.

Sissinghurst

The site is located very close to the centre of the village of Sissinghurst and so is within easy walking and cycling distance of a range of shops and community facilities. This includes a post office and newsagents, a primary school, the village hall, a public house, takeaway food premises, the adjacent recreation field and play equipment, and bus stops. These are all located within only a few hundred metres of the site.

It is noted by the Council’s Planning Environmental Officer from within the Proof of Evidence relating to the recent appeal against the outline planning application for a residential development of up to 60 new homes at land off Common Road, Sissinghurst (under reference APP/M2270/W/15/3006768), that, within the LBD of Sissinghurst village, there are 176 dwellings and 405 residents. The Planning Inspector dealing with that appeal noted that “for a village of this scale it does have a reasonable range of facilities. It also has relatively good bus services which would be increased…and these offer good access to a wider network of public transport services including rail services from Staplehurst station”.

Furthermore, the Inspector for that appeal noted that, “Sissinghurst has a range of services and infrastructure, which include the primary school, a recreational ground, a village hall, two shops including a Post Office, a pub/restaurant, a hot food take-away, Rankins party catering and party venue and a church, which are all within reasonable walking distance of the appeal site. Cranbrook provides a wider range of local services and facilities including Cranbrook School, High Weald Academy, medical and dental facilities, a supermarket and shopping area. The No 5 bus service runs along Common Road adjacent to the site. It provides links to Maidstone, Staplehurst, Cranbrook, Hawkhurst and Sandhurst. There is a railway station at Staplehurst with regular services to London Charing Cross and Tunbridge Wells” (see Paragraph 15).

Sissinghurst is located in between and approximately equal distance to Royal Tunbridge Wells, Maidstone and Ashford to the west, north and east respectively. Each of these towns is approximately 15 miles away by road, and bus services are available in each of these directions. The A229 lies approximately 0.2km north-west of Sissinghurst, with the main approaches to the village being from Common Road and Sissinghurst Road.

The village also has several historic interest features with numerous listed buildings in the area and a conservation area centred on the village. The busy A262 between Lamberhurst and Biddenden runs through the settlement and Conservation Area and therefore a high volume of traffic passes through the settlement.

Nearby planning applications

There has been a number of relevant planning applications relating to land in and around Sissinghurst recently. Principally, this application follows a recently determined appeal in relation to a proposal for 60 residential units (which was changed from 65 units during the course of the appeal) at land off the nearby Common Road, Sissinghurst, Cranbrook, Kent.

Common Road

The appeal relating to that proposal for 60 houses at Common Road was allowed (under reference APP/M2270/W/15/3006768). This was on the basis that, in terms of the economic and social dimensions of sustainable development, the increased supply and choice of housing in an area given that there is not a Framework compliant supply of housing land, would be positive.

That application was supported by a social-economic impact assessment and it was considered that the contribution to the supply of housing should carry very considerable weight in favour of the proposal, and although identified as causing some harm to the landscape character and visual amenity of the area and loss of countryside, this harm is outweighed given the absence of a Framework compliant supply of housing land.

Despite being recognised as being at odds with the Council’s adopted Core Strategy, it was considered that, “given its location on the edge of the existing village within fairly close proximity to these services/facilities…the site is a reasonably sustainable location for the development”.

With regard to sustainability, the Inspector considered that there are good facilities within Sissinghurst itself relative to its size, and other services not catered for within the village itself are provided locally within neighbouring settlements. The Inspector went on to highlight the bus service serving this area and the fact that this would be enhanced through contributions by the developer for a period of 3 years. The current proposal, while itself not of a scale to warrant any financial contribution, would benefit from the service improvements afforded by the Common Road scheme.

Cobnut Close

A planning application for nine new dwellings was approved in May 2016 at land adjacent to Cobnut Close, Sissinghurst (under reference 15/505629). This scheme consists of two semidetached three-bedroom properties, six detached four-bedroom properties, and one detached five-bedroom property with associated car parking and landscaping.

The summary of the Officer’s Committee Report for this application confirms that “in the absence of a five year supply of housing, the housing supply policies (including those related to the Limits to Built Development (LBD) are “out-of-date”. Paragraph 14 of the National Planning Policy Framework (NPPF) requires that where relevant policies are out-of-date that permission for sustainable development should be granted unless specific policies in the NPPF indicate that development should be restricted (and all other material considerations are satisfied)”.

The Council notes that the services at Sissinghurst “can be easily accessed from the site with a footway adjacent to Common Road. Other services such as medical care are provided within the neighbouring settlements of Cranbrook and Staplehurst which are approximately 1.7 miles and 4 miles away respectively. Whilst it is true that future residents are likely to travel by car to these other villages for some services, this is unlikely to cause significant harm at the scale of development proposed, or when taking the cumulative impact of 60 dwellings on the Common Road site into account”. This is considered to be noteworthy given that the scale of that development (i.e. the number of residential units) is equal to the scale of this current proposed scheme.

With regards to the nine houses proposed in that case, the Council noted that significant weight can be attached to this in considering whether the proposal comprises sustainable development. The Council noted that, as the Cobnut Close site is as equally sustainable as the fore-mentioned Common Road appeal site and would be less visually intrusive, it should be supported. It is put forward that the same conclusions could be met with regard to the site rear of The Street.

School site

Planning permission was granted in May 2014 for nine houses at the former Sissinghurst Primary School (under reference 13/00439). Whilst that site is located within the Limits to Built Development, it is noteworthy that this development required the widening of the pre-existing access and the removal of a section of the wall at the front of the school, and this was considered acceptable from a conservation and highways perspective.

Fernham Homes

Fernham Homes are a Kent based developer, with headquarters in nearby Tonbridge and a workforce predominantly from the local area.

Each Fernham Home is built to the highest standards with meticulous craftsmanship and combines the latest in product design and technology with a 10 year NHBC warranty.

The company directors are committed to respecting the environment, seamlessly blending each home with the surrounding area. The design ethos is to provide landscape led schemes that retain and enhance existing landscaping and boundary treatments, whilst providing small to large size family homes of a range of tenures for which there is the greatest need.

The Tunbridge Wells Draft Local Plan

The TWBC Draft Local Plan (herein referred to as ‘the plan’) sets out the spatial vision, strategic objectives, and overarching development strategy for the borough. It details overarching place shaping policies for each parish and settlement, as well as site specific allocations to deliver the strategy and detailed policies to be applied to all new development.

As outlined by the plan, there is an overriding and growing housing need within the Borough. The Council’s SHMA findings initially identified the future need to plan for some 648 new homes per year. This in turn has seen a further uplift as a result of the standard methodology for calculating housing need, which based on the most credible set of population projections suggests a further uplift to circa 680 new homes per year.

In addition to the need moving forward, the previous difficulties in keeping pace with delivery has resulted in a need to accommodate a significant number of dwellings in the short term with a deficit in five year supply.

Given the current development plan has seen documented difficulties in meeting the existing core strategy housing target, the need for new housing is compelling and indisputable and must be addressed by the new plan as a priority. The plan will set the agenda for development across the borough to 2036 and replace the current Development Plan, which comprises the Local Plan 2006 (saved policies), the Core Strategy 2010, and the Site Allocations Local Plan 2016.

This representation comments on the following elements of the plan:

  • Vision and Strategic Objectives;
  • Development Strategy and Strategic Policies; and
  • Place Shaping Policies for the Parish of Cranbrook and Sissinghurst.

[TWBC: see Comment Numbers DLP_5171, 5174, 5176, 5177 and 5180]

DLP_5180

Bloomfields for Fernham Homes

Support with conditions

This states that the land is allocated for a mixed use scheme, including residential development (C3) providing approximately 20 residential dwellings, and a replacement community hall.

Development on the site shall accord with the following requirements:

1. Vehicular access into the site to be informed by a highways assessment (see criterion 5 of Policy EN 1: Design and other development management criteria);
2. Provision of a pedestrian link to Public Right of Way WC104;

3. Development to have regard to the setting of the Sissinghurst Conservation Area and nearby listed buildings (see Policy EN 7: Heritage Assets);

4. Demonstration that the design of the scheme reflects the historic linear pattern of Sissinghurst village;

5. Provision of replacement village hall and associated parking (see Policy EN 1: Design and other development management criteria and Policy TP 3: Parking Standards);

6. Provision of on-site amenity/natural green space, and improvements to existing allotments, parks and recreation grounds, children’s play space and youth play space in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation
Having regard to these draft requirements, the general thrust of the Policy is supported, which largely reflects proposals that have been discussed with Officers as part of pre-application enquiries. Comments are provided below with respect to each of the Policy criteria;

1. Following the submission of an earlier planning application, previous access issues have been addressed by virtue of the inclusion of land to the west of the site, under the ownership of both the Parish Council and the St George’s Institute. This means improved visibility splays can now be provided without reliance of third party land.

2. Indicative layouts have now been presented to Planning Officer’s as part of recent preapplication discussions. These show that not only would a pedestrian link be maintained to the Public Right of Way to the rear of the site, but the proposed layout would be designed to be permeable allowing linkage to the right of way at several points.

3. Pre-application discussions have steered the design of indicative schemes and the potential impact upon views from the Conservation Area. In practice, it is the inevitable location of the replacement of the St George’s Institute which will dominate any views into the site from the Conservation Area. There are a number of Listed Buildings along The Street but Officers have indicated that the proposed development of this site would not be likely to impinge upon the setting of these buildings.

4. Any dev