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Section 5: Place Shaping Policies Lamberhurst


This response report contains comments received on Section 5: Place Shaping Policies - Lamberhurst.

Contents

General comments

Comment No.

Name/Organisation

Response

DLP_3572

Kent & East Sussex Regional Office

National Trust

Scotney Castle Estate has been identified by the National Trust as having significant potential to develop its visitor offer and to accommodate growth. Scotney Castle is very accessible being located just off the A21. The property has seen year on year increases in visitor numbers and at peak times the visitor infrastructure cannot cope with demand. The National Trust therefore has long-term plans to develop key elements of the visitor infrastructure, to ensure adequate parking, toilets, catering and retail provision is in place to cope with the increasing number of visitors to the property and to improve the visitor experience. As a key visitor attraction and income generator within the Borough it is essential that the property can facilitate growth over the plan period. The National Trust would therefore like dialogue at the earliest opportunity with the LPA prior to Regulation 19 to ensure local policy provision is in place to support and enable Scotney Castle to maximise the benefits of tourism and to ensure that the property can reach its full potential. Similar to Policy AL/CRS 11 we would seek the Local Plan to have a site-specific policy for the Scotney Castle Estate.

DLP_3992

Lamberhurst Parish Council

Lamberhurst Parish - Allocated Land

The 60 housing units proposed for Lamberhurst Parish, which lies wholly within the High Weald AONB, constitutes a large increase for a parish of its size and is not considered sustainable due to limited local facilities and services. Public transport is poor; and whilst rail services at Wadhurst, Paddock Wood, Tonbridge & Tunbridge Wells are good accessing them is dependant on private car usage which will result in a significant increase in traffic movements onto an already congested road network. (The present A21 is highly congested during rush hours.). There is a distinct lack of connectivity to town centres, hospitals and places of commerce and employment. There are no designated cycle routes within the parish

Suggest that the Role & Function Study (Which was responded to, see p.315) should be updated to note the change in circumstances which may impact on the housing number allocation.

Policy STR/LA 1: The Strategy for Lamberhurst Parish

Comment No.

Name/Organisation

Response

DLP_2930

ASP Planning for Wellsbridge Estates

Please see attached letter on behalf of our client Wellsbridge Estates Ltd.

DRAFT LOCAL PLAN (REGULATION 18) CONSULTATION

LAMBERHURST CAR PARK, BREWER STREET, LAMBERHURST, KENT

We write on behalf of our client Wellsbridge Estates Ltd who wish to make representations regarding the policy approach to Lamberhurst. We acknowledge that the Tunbridge Wells Draft Local Plan 2019 proposes to allocate between 50 - 60 houses in the village of Lamberhurst. In light of the proposed allocations we consider that as a matter of principle residential development in Lamberhurst is acceptable and that the settlement performs adequately in terms of sustainability. Within the context of this we would like to make representations on two sites identified in the draft local plan and an additional site we believe the council should consider for allocation. The sites are as follows:

*           Misty Meadow, Furnace Lane

*           Land to the West of Spray Hill

*           Car Park for former Slaughterhouse, Brewer Street Lamberhurst and Land at 36 Brewer Street, Lamberhurst (see attached SHELAA assessment entries). [TWBC: see full representation].

Misty Meadow, Furnace Lane

Following on from the SHELAA assessments the Draft Regulation 18 Local Plan has proposed in policy AL/LA 2 to allocate 25-30 residential dwellings on land known as Misty Meadow, Furnace Lane. Having reviewed the SHELAA entry for the land it is clear that there are several concerns regarding the allocation. Firstly, the land is distanced from the village development boundary by approximately 100 metres and as such is poorly integrated. Secondly, Furnace Lane is predominantly characterised by a ribbon form of residential development. As such the proposed allocation would result in backland development which would be contrary to policy and out of keeping with the surrounding residential character of the locality.

Irrespective of this fact the site has still been brought forward for allocation. Lastly, the SHELAA entry for the site notes that ‘parts of the site are sensitive in landscape terms.’ The site is very exposed and poorly contained in relation to adjacent residential development. In this regard it is considered that there are more appropriate alternative sites which would be more appropriate in Lamberhurst as will be detailed in subsequent paragraphs.

Land to the West of Spray Hill

It is acknowledged that the council proposes to allocate land to the west of Spray Hill for 25-30 residential dwellings within policy AL/LA1. We do not wish to contend this allocation and have no objection. It is clear that this allocation provides wider benefits to Lamberhurst including an extension to Lamberhurst Primary School and the intention to provide improved pedestrian and cycle linkages in the locality and in relation to the Scotney Castle Estate.

Car Park for former Slaughterhouse, Brewer Street Lamberhurst and Land at 36 Brewer Street, Lamberhurst.

The land known as ‘Car Park for former Slaughterhouse, Brewer Street’ and ‘Land at 36 Brewer Street, Lamberhurst’ has been assessed by the council as part of the Strategic Housing and Economic Land Availability Assessment (SHELAA) produced in conjunction with the Draft Regulation 18 Local Plan under two separate entries; references 1 and 363 respectively. After consideration the council concluded that both sites were ‘unsuitable as a potential site allocation’. It is our view that when viewed as one entity these sites represent an ideal allocation for residential development as will be explored in more detail below.

Briefly in regard to the specifics of the site. The sites accumulate to measure approximately 1.22 hectares and comprise a former car park previously used in association with a slaughterhouse. The site also contains a residential property and its curtilage. The site is adjoined by residential properties, allotments and fields. The boundaries of the site are a series of hedgerows. At present the area of land containing the former car park is accessed via a track which runs up to the southern boundary adjacent to the allotments. There also exists a vehicular driveway from Brewers Street which at present serves a single residential dwelling and its curtilage.

The SHELAA entries for the sites have expressed several concerns which have led to the council determining that the site is unsuitable for allocation. The entry for reference 1 states that ‘there is a landscape concern about the allocation of this site and concern about deliverability’. In relation to entry reference 363 the council considered that the ‘allocation of this site would result in unacceptable back land development’. Whilst these points have been acknowledged it is our view that if the sites are considered collectively as a single entry, as is proposed by our client that the issues raised can be overcome. In this respect we have the following comments:

  • First, the SHELAA assessment noted that there were   highway issues in relation to site reference 1. By considering sites   referenced 1 and 363 together, an acceptable means of access can be achieved   by using the access from Brewers Street associated with reference 363. It is   considered that with improvements, this access is suitability located and   capable of providing access to the site in its entirety. In terms of   deliverability, it is considered that this access solution can provide the council   with more certainty as it is within the ownership of 36 Brewers Street.
  • Second, it is noted that the council reached the   conclusion that the land at reference 363 would result in unacceptable   backland development. By considering the two sites as a single entity, a more   comprehensive and coordinated form of development can be achieved, such that   the suggestion of backland development is no longer relevant.
  • Third, a more coordinated development of the site will be   in keeping with the character of residential development adjacent at   Hopgarden Close. The location of the allotments will be a buffer from   existing housing. In terms of the potential wider effect of the development the SHELAA assessment of site ref 1 mentions landscape concerns as a factor   that contributes to the unacceptability of the site, such that it is   unsuitable for allocation, although it remains unclear as to the how this   conclusion has been drawn. The overall assessment of the potential for sites   1 and 363 to collectively accommodate 37 dwellings is potentially unhelpful   in this respect; it is not clear how the council’s capacity analysis has been   reached. A smaller development is entirely practicable, and would facilitate a less dense, more open form of development that would respect the location   of the sites on the edge of the village. In our view this would produce a   more appropriate form of development.
  • Fourth, in locational terms it has been noted that the   site ‘is let down by a lack of key services and options for public   transport’. As expressed earlier it is considered that the council having   proposed to allocate 50-60 houses in Lamberhurst have considered that as a   matter of principle residential development in Lamberhurst is acceptable and   performs adequately in terms of sustainability. It is therefore considered   that this site is located adjacent to the development boundary for   Lamberhurst and thus there is sufficient opportunity to access key services   and facilities. It is also apparent from the manner in which the council has considered   other allocations in Lamberhurst that the question of access to services and   location of public transport has not been seen as a definition reason for not   allocating land for development as is clear from the proposed allocation at   Misty Meadow, Furnace Lane in which the SHELAA entry recognises that there   would be ‘dependency on private car use’.

In light of the above the allocation of the land at site refs 1 and 363 should be obvious; it is a logical and acceptable location for additional small-scale development adjacent to the village boundary. The allocation should be made as a single entity. At present the absence of the allocation leads us to believe that the plan is not justified, in that it is not putting forward an appropriate strategy taking into account reasonable alternatives. As such, the plan at present cannot be considered to be robust nor reliable. This representation demonstrates that the council must reconsider that land at reference 1 and 363 as a single entity for allocation. The land represents an excellent opportunity and we consider that the site allocation be modified accordingly. It is clear that opportunity does exist here.

DLP_3128
DLP_7582
DLP_7605
DLP_7607
DLP_7611
DLP_7711
DLP_7722
DLP_7731
DLP_7736
DLP_7747
DLP_7754
DLP_7820
DLP_7824

Bernard Couchman
Andrew Ashe
Laura Gendt
Mike Couchman
Mr and Mrs G Playfoot
Jenny Couchman
Rosie Ashe
Franklin Ashe
Anna Walsh
P and M Ashford
Phil Smith
Stephen Farris
Jennifer Farris

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

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools:

The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:

There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is 7.6 miles away, and really only reachable by car.  The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service:

There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking 35 minutes, costing £6.00 per journey, and with limited frequency. Furthermore, the bus is always full with school children in the morning. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

Doctors:

There is a very small and busy Doctors surgery that is at full capacity trying to cope with the amount of patients they have from Lamberhurst but also other villages.

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_3345

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

The Local Highway Authority conditionally supports this policy. The following changes are requested:

Paragraph 5 - “Maintenance and enhancement of, and/or linkages to, public footway network and public rights of way and the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility”

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 reference to PRoW in paragraph 5 is supported. It is requested that PRoW enhancements are also included in the list of expected contributions, to mitigate the impact of future development.

DLP_3997

Lamberhurst Parish Council

STR/LA1 – Strategy for Lamberhurst

Generally support  – With reservations

  1. The allocation of 50-60 new dwellings appears unsustainable. Given the rural location, lack of connectivity, public amenities and transport links. The two allocated sites lie wholly within the High Weald AONB.
  2. Windfall sites should be included within the total allocation.
  3. The whole parish lies within the AONB.
  4. The Public Car Park on The Down below the Brown Trout has been omitted and should be added and retained in accordance with Policy TP4: Public Car Parks
  5. Agreed although there are no designated cycle routes in the parish or that connect to other settlements and the PROW network does not cross the Bayham Estate to link to Pembury, Frant or Tunbridge Wells.
  6. The allotment site south of Brewer Street may in future be needed for the provision of parking for statutory allotments north of Brewer Street and should be removed from the Local Green Space list.

LPC support the proposed minor changes to the LBD at Lamberhurst referred to in Policy STR10

DLP_4143

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE object to both the proposed developments which comprise greenfield sites within the AONB.  Please see our comments on AL/LA1 and 2.

We are 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 and its setting.  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_4437

Hugh and Susanna Smith

We wish to comment on the draft Local Plan and Sustainability Appraisal please. Our concern is principally with Lamberhurst and its suitability to absorb additional housing, and particularly with the appropriateness of the Land to the West of Spray Hill (Map 85 Policy AL/LA1.)

With regard to the Borough’s planning strategy and to Policy STR/LA1:

  • You will be aware that the recently drafted Neighbourhood Development Plan for Lamberhurst focuses on developments in keeping with and amplifying the local character of the area. The new housing identified in the TWBC draft Local Plan comprises a housing estate approach, creating a suburban feel – features which are quite foreign to the existing composition of the settlement.
  • The results from the Distribution of Development Topic Paper for Draft Local Plan – Regulation 18 Consultation and these proposals now for the high relative level of new housing in Lamberhurst, which is the 4th smallest settlement in the plan area, do not seem to be consistent.
  • Similarly, the proposals as they affect Lamberhurst comprise dispersed or semi-dispersed growth, with its suburbanising effect, in contrast to the growth corridor approach that emerges in the Topic Paper above. This is a further inconsistency with the consultation findings in the Topic Paper.
  • The proposals will in addition have a more negative climate-change impact than alternatives focused on locating new housing where existing population and service densities are already significant and well-established. Public transport from Lamberhurst is very limited; school capacity in the village is full; local shopping options are quite restricted.

We would like these comments to be taken into account as part of the consultation please.

DLP_4563

Historic England

Policy STR/LA 1: The Strategy for Lamberhurst Parish et seq. - as with the foregoing comments, 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_4669
DLP_4675

Mandy Cornick
Sue Ashe

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

I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site at Misty Meadow Farm on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools:

The nursery school is already oversubscribed, and the primary school has only four spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:

There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco at the Pembury junction of the A21 – which is about 6 miles away, and  only reachable by car. The shortest and most direct route ( 6.2 miles) is via Clay Hill Road, a small (and in some places single track road) unsuitable for heavy traffic.  The village shop is generally inaccessible as cars are always parked outside.

Bus service:

There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking anything from 33 minutes to 1 hour 27 minutes. There are six buses per day in total; two at the same time in morning on schooldays only, one at 10am, two at around lunchtime and one at 5.13 in the afternoon.    Furthermore, the bus is always full with school children in the morning. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

DLP_5024

34 households in Lamberhurst

We are writing to you as our local Councillor regarding the Tunbridge Wells Local Plan. As you will know, TWBC need to deliver a quota of houses across the Borough, Whilst we understand the principle of the need to build more affordable housing, we object to the proposal to build 30 houses on a particular site in the historic village of Lamberhurst

We enclose for you a copy of our objections for your information. This letter is signed by 34 households across Lamberhurst who are actively involved in our objections. They have all given me permission to share their details with you.

We are writing to you to register our concerns and objections to the following:

  • the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy
  • the suitability of Lamberhurst to accommodate additional dwellings
  • the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that 60% of respondents would like to see housing growth along “growth corridors”, whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. The Council would need to be able to demonstrate that it has reacted appropriately to the consultation feedback so a far greater emphasis on growth in established centres rather than rural locations would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private cars as a means of travel – which surely must be of paramount importance given climate change commitments.

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the Limits to Build Development boundary, but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using private car for both work and transporting children to school (as the current bus is already over capacity)

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

[TWBC: the following comment has also been entered under Policy AL/LA 2 - see Comment Number DLP_5032].

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use the private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra- low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

4) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

5) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

TWBC: Submitted by the following residents of Furnace Lane, Furnace Avenue, Hoghole Lane, and The Slade:

Nicky & Neill Scott
David & Janet Doble
Joan Burns
Mark Burns
Andrew & Sue Ashe
Bernie & Jen Couchman
Ian & Gemma Cooper
James & Jeannine Mackrill
Sue & Russ Kirton
Vanessa & Andy McConnell
Maria Jeffery
Alicia & Jenny Fox
Elizabeth 
David & Emma Bullen
Nick  &   Jenny   Staines
Andrew & Frenella Blamey
Angela & Alan Pascoe
Steve & Jenny Farris
Dennis Haskell
Mandy & Tim Cornick
Jo Harvey
Victoria & Yvonne Settle
Lesley Young
Mike Couchman
Hamish Bett
Tony & Eliann
Debbie Edwards
Ashwini
Clare Martins
Caroline Lambert
Colin & Margaret Crawford
Jan Stocker
Maddy Church
Phil Smit

DLP_5935

Rachel Jones

We writing to you to register our concerns and objections to the following:

  • the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy
  • the suitability of Lamberhurst to accommodate additional dwellings
  • the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for 30 dwellings (site reference AL/LA2).

Planning Strategy

1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that 60% of respondents would like to see housing growth along “growth corridors”, whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. The Council would need to be able to demonstrate that it has reacted appropriately to the consultation feedback so a far greater emphasis on growth in established centres rather than rural locations would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on private cars as a means of travel – which surely must be of paramount importance given climate change commitments.

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the Limits to Build Development boundary, but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a clear and consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity).

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

DLP_5974

Simon Steddon & Sue Cox

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for 30 dwellings (site reference AL/LA2).

Planning Strategy

1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that 60% of respondents would like to see housing growth along “growth corridors”, whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. The Council would need to be able to demonstrate that it has reacted appropriately to the consultation feedback so a far greater emphasis on growth in established centres rather than rural locations would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on private cars as a means of travel – which surely must be of paramount importance given climate change commitments.

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the Limits to Build Development boundary, but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a clear and consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity).

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

DLP_6266

Victoria Settle

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is … miles away, and really only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village. Furthermore, the bus is always full with school children in the morning. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

DLP_6340

Fenella Blamey

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

Further to my comments above, Lamberhurst is a very small village which has developed slowly over time. Today it has very limited services for its residents and would not be able to accommodate the substantial increase in population that this new development would bring.

Schools: both the nursery school and the primary school are either oversubscribed or full. New families would have to look further afield for education which would result in them having to use their private motor cars

Shop: there is now only one shop which is poorly stocked, therefore poorly supported. In addition, there is limited parking in the village resulting in residents driving on through the village to the supermarkets further afield for their supplies.

Public transport: there is a very limited bus service for the village with the bus to and from Tunbridge Wells only a couple of times a day. This service cannot be relied upon on those wanting to commute for work. There are specially designated school buses to Wadhurst and Paddock Wood but these are not generally available for public use.

The proposed site is remote from the village and not readily accessible by pedestrians. While there is a pavement along one side of Furnace Lane, it is narrow, very uneven and poorly lit. Furnace Lane is a busy road to cross and the hill down to or up from the village is steep. It is likely therefore that any future residents would use their motor car for access, creating yet more traffic along Furnace Lane and through the village and causing increased carbon footprint.

Finally, consideration must be given to maintaining the open countryside, the trees, access to public footpaths and the diversity of nature that occupies the area.

I trust my comments and objections will be taken into account when considering this housing proposal further.

DLP_6352

Andrew Blamey

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability

Appraisal. These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is … miles away, and really only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking. The bus service is infrequent could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using the private motor car for both work and transporting children to school.

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

DLP_6529
DLP_6567

G and J Moger
Lesley Young

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

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Misty Meadow, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools:

The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:

There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is 7.6 miles away, and really only reachable by car.  The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service:

There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking 35 minutes, costing £6.00 per journey, and with limited frequency. Furthermore, the bus is always full with school children in the morning. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

Doctors:

There is a very small and busy Doctors surgery that is at full capacity trying to cope with the amount of patients they have from Lamberhurst but also other villages.

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

DLP_6632
DLP_6641
DLP_6701
DLP_6725
DLP_6745
DLP_6769
DLP_6782
DLP_6978

Nicky Scott
Isla Tompsett
Alan Bearfield
Nicholas Fogg
Maria Palmieri
Alicia Longley-Coomber
Jenny Fox
Chris Hill

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

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity).

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

DLP_7293

Miranda Hungerford

Draft Local Plan and Sustainability Appraisal

We are writing to you to register our concerns and objections to the following:

  • the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy
  • the suitability of Lamberhurst to accommodate additional dwellings
  • the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for 30 dwellings (site reference AL/LA2).

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity).

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will be heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

DLP_7424

Neill Scott

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above [TWBC: see Comment No. DLP_7420 Policy STR 1], the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:  There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car.  The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity).

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7492

Freya Alder

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above [TWBC: see Comment No. DLP_7490 Policy STR 1], the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:  There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car.  The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity).

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7533

Ruth Murphy

Draft Local Plan and Sustainability Appraisal

We are writing to you to register our concerns and objections to the following:

  • the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy
  • the suitability of Lamberhurst to accommodate additional dwellings
  • the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for 30 dwellings (site reference AL/LA2).

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity).

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will be heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

DLP_7552
DLP_7603
DLP_7706
DLP_7742
DLP_7761
DLP_7788
DLP_7811
DLP_7814
DLP_7818
DLP_7849
DLP_8250

DM and SE Woodcock
H and D Cheales
C and A Schweitzer
Mrs J A Staines
Joan Burns
Ross Wingfield
Sarah and David Blake
Julia Goldfinch
Sarah Bearfield
Daniel and Amelia York
Y Settle & O Settle

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

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

  1. The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously.  5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

    Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst.  For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.

  2. With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment.  Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included.  Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason.  There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services and infrastructure as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car.  The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service:There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking approximately half an hour and with an extremely limited frequency.   Additionally, twice a day, and more,, the bus is full with school children. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7724

Ian Cooper

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2). Of which we STRONGLY OBJECT to this proposed allocation, please see below rationale and reasoning why Misty Meadow should be disqualified as a proposed site.

Notwithstanding the COVENT that protects this land, which clearly states this land can only be used for Agricultural purposes...

Planning Strategy

  1. The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously.  5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

    Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst.  For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.

  2. With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment.  Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included.  Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason.  There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

    A good example of this, is land on the Vineyard was rejected due to concerns over ridgeline views being affected, Misty Meadow is a minimum of 25ft higher than the Vineyard, and the ridge line can be seen from the Wadhurst road and South of Lamberhurst, notwithstanding the public footpaths that would be greatly affected by this proposed development. The proposed development on Misty Meadow is also detached from the LBD/Village envelope, so it’s surprising to see that this site qualified.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services and infrastructure as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car.  The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service:There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking approximately half an hour and with an extremely limited frequency.   Additionally, twice a day, and more,, the bus is full with school children. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major negative impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7771

John McNamara
The Old Down Stores

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

  1. The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously.  5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

    Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst.  For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.

  2. With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment.  Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included.  Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason.  There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services and infrastructure as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car.  The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service:There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking approximately half an hour and with an extremely limited frequency.   Additionally, twice a day, and more,, the bus is full with school children. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.  I know local authorities have targets to build affordable homes but the Misty Meadow plan is flawed and has the characteristics of something that is wrong on so many levels.

DLP_7828

Mr & Mrs Kirton

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst.  For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.

With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment.

Examples include:

  • Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included.
  • Some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason.
  • Comments appear to not be applied with equity, some sites seemingly being discounted with statements such as ‘Lack of key services and facilities in the settlement’ and Lack of options for public transport’ which would appear to apply to other sites.
  • The Strategic Housing and Economic Land Availability Assessment details the Site Assessments for Lamberhurst Parish (July 2019), shows that the average proposed density of housing on each of the sites offered for development was calculated at an average of 12 houses per acre, apart from the two sites (285 and 279) that are now proposed in the Local Plan. These are clear outliers at a density of 1 to 2 houses per acre.

There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner allowing comparable data of the other long list option sites for Lamberhurst Parish.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst.

The Local Plan identifies that Lamberhurst needs to build ‘50-60 new dwellings’ to achieve the nationally set goal (ref: Page 20 Tunbridge Wells Local Plan) but in the plan only identifies two sites (285 & 279), both of which are identified as potentially accommodating 25-30 new dwellings, meaning that in order to meet the required level of Lamberhurst housing development both sites will be required. As such the consultation in relation to Lamberhurst offers no meaningful option and as such appears to propose a level of predetermination that contravenes the first Gunning Principle. As a Local Plan, it fails to identify how the plan for Lamberhurst can be addressed if one of the two identified sites fails to progress as expected.

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result.  Developing two large sites, rather than a number of smaller sites will place a disproportionate rate of growth on the village.

The Lamberhurst Neighbourhood Development Plan states ‘ New housing development in Lamberhurst parish has been strictly controlled over many years by various policies in local planning documents produced by TWBC. This is because Lamberhurst is a “lower tier” settlement with relatively fewer facilities and poorer access to public transport and employment opportunities in comparison with larger, more sustainable, settlements in the Borough. In addition, Lamberhurst parish has a number of protective designations in both the village and surrounding countryside, particularly the High Weald AONB. These local planning policies seek to contain most development within “limits to built-development”, as defined in “saved” policy LBD1 of the Tunbridge Wells Local Plan (2006) … This policy aims to prevent the unrestricted sprawl of development beyond towns and villages and to restrict development in the countryside to that required by agriculture, forestry and other uses requiring a rural location. (ref: Page 48 Draft Lamberhurst Neighbourhood Development Plan)

It is noted in the Tunbridge Wells Local Plan, that ‘Minor changes are proposed to the limits of built development at Lamberhurst as set out in the Topic Paper referred to in policy STR 10 above.’ (ref: Page 313 Tunbridge Wells Local Plan).

Development of new dwellings in Lamberhurst has been ‘modest’ (ref: Page 48 Draft Lamberhurst Neighbourhood Development Plan) with an average of 4 new dwellings per year over the last 3 years. Table below extracted from Page 48 Draft Lamberhurst Neighbourhood Development Plan.

Although the Tunbridge Wells Local Plan targets of 50/ 60 new dwellings, over the lifetime of the local plan average 4.6 new dwellings per year. The fact that these are proposed to be in two large sites, will by all reasonable assumptions be built over a concentrated timeframe by developers at each site. This could mean that at best, if the two development sites were staggered, that the average increase in new dwellings could be 15 in one year, an increase of 320% on previous years rates of growth.

Period

2006-2011

(5 year period)

2011-2016

(5 year period)

2016-2019

(3 year period)

TW Local Plan proposed level of new dwellings

2020-2033

(13 year period)

Dwelling completed

15

7

12

60

Annual average completions

3

1.4

4

4.6

This will have an impact on the limited range/capacity of services but are not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site, on a ridge, will be visible to traffic passing north bound from Wadhurst to Lamberhurst on the B2100, on their approach to the village the road looks up to views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

The Strategic Housing and Economic Land Availability Assessment details the Site Assessments for Lamberhurst Parish (July 2019) and for site ref number 285, Misty Meadows, Page 317 to proposes that ‘the southern area of the site to be returned to agricultural purpose before the first occupation’

It is not clear how this will be a viable option, given that the farm infrastructure will have been removed in order to create a viable housing development site

The Strategic Housing and Economic Land Availability Assessment details the Site Assessments for Lamberhurst Parish (July 2019) and for site ref number 285, Misty Meadows , Page 317  it sets out requirements for the site 285, for residential development (C3). It proposes that there is ‘Single point of access using existing track’. The land that this track runs over is owned by a number of different owners and not the sole ownership of the land owners of Misty Meadows Farm.

In addition, the ‘Provision of adequate visibility splays’ will require land on either side of the existing track, which is owned by a number of neighbouring households. There is also a natural pond on land required for visibility splays and on occasion this results in surface water to the B2169, Furnace Lane.  The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents. The Local Plan, with regards to site 285, the Strategic Housing and Economic Land Availability Assessment for Lamberhurst Parish (July 2019) is in conflict with Lamberhurst Draft Neighbourhood Development Plan policy number L2 and Draft Lamberhurst Neighbourhood Development Plan policy number H1.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1), in two large sites, will have a disproportionate impact and cannot be supported by existing infrastructure as a slower growth rate of a greater number of smaller sites within the village centre, reducing reliance on car journey for daily local trips to schools and shop.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7858

Mrs J H Fox

I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

My interest is as a walker of the footpaths in the Lamberhurst area and as a relative of a resident in Furnace Lane.  It can be very uplifting and therapeutic to walk down one of the local footpaths in the Furnace Lane area, and in just a few minutes one can experience being in a ‘different place’ in the country.  Currently the area has some farming and the old stone cottages on the ridge, the proposed Furnace Lane site would be located on the ridge and would detract from views of the Area of Outstanding Natural Beauty, including from nearby footpaths, and would have a harmful impact on the character and appearance of the AONB.

The village of Lamberhurst has developed slowly over time and has limited facilities. The nursery school is oversubscribed and the primary school has only a few spaces. There is one small shop in the village with a very limited range. There are only five buses a day to Tunbridge Wells and these are busy at school times.

Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by the existing infrastructure and will be heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding my objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

I trust that these comments will be taken into account.

DLP_8185

Highways England

Location:

No/Type:

Distance to SRN:

Impact:

Current traffic flows:

Recommendations

Lamberhurst

50 – 60 residential dwellings (2 sites)

Safeguarding land for future expansion of primary school.

Small scale developments

< 2km

A21

Interested in impact to A21 /B2169  Forstal Farm roundabout and Scotney Castle roundabout.

Given small scale, unlikely developments will have major impact on junctions.

Current traffic data on Googlemaps does not flag any issue at Scotney Castle roundabout.

Forstal Farm roundabout shows some congestion currently. See screenshot below.

Roundabout modelling recommended at Forstal Farm roundabout.

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

DLP_8302

NHS West Clinical Commissioning Group

General Observation

The CCG confirms that it is expected that contributions will be required towards Lamberhurst Surgery (improvements/ reconfiguration etc.) to mitigate the impact of the development.

DLP_8343

James and Emma Young

TWBC: correspondent submitted the following comments on 27/11/19, after the close of consultation on 15/11/19:

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst.  For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment.  Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then othercomparable sites have been included.  Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services and infrastructure as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car.  The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service:There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking approximately half an hour and with an extremely limited frequency.   Additionally, twice a day, and more,, the bus is full with school children. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility.  Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Policy AL/LA 1: Land to the west of Spray Hill

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_172

Ian Bull Consultancy for Jarvis Strategic Land Ltd

Support with conditions

Jarvis Strategic Land Ltd. supports the principles set out in draft Policy AL/LA 1. It is assumed that the pedestrian and cycle link provision/improvements set out in requirements 1, 2 and 3 of the policy, can be delivered within existing highway land or other land within public ownership without the need for any third party land acquisition. It is also submitted that the additional development contributions required should be subject to viability considerations.

DLP_984

Mr Mark Ellis

Object

Policy AL/LA1

When the Lamberhurst neighbourhood Plan was drawn up utilising numerous meetings for all residents within the Parish and the sunsequent discussions arising from the findings of numerous consultants taken on by the Parish Council it was widely agreed that the following points should be paramount when deciding on appropriate sites:

1.Infill development was preferred to linear build that would stretch the village was not required

2.Leave areas adjacent to Scotney and Bayham alone if possible

3.Use existing brown field not virgin sites

Within the Lamberhurst Neighbourhood Plan it also states that we should protect and enhance bio diversity and the natural enviroment, conserve ancient woodland and conserve water resources. It would seem that the location of this site is therefore against the findings of the survey results

DLP_2109

Terry Everest

Object

Object

This should be reduced severely as to not adversely affect the character of the surrounds.

DLP_2844

Mrs Stephanie Gilbert

Object

The site is located within the AONB and on the edge of the conservation area. (Lamberhurst Down & Scotney Castle) this proposed development would impact on the rural environment and surrounding areas. The road infrastructure would not be able to cope with the considerable influx of traffic created by the proposed development 25-30 houses. The A21 is already gridlocked at peak times and has a significant impact on many of the surrounding quiet lanes and in particular the B1269.

The proposed residential access onto the B2169 is already very busy taking traffic from the A21 towards Tunbridge Wells and Wadhurst. It should be noted that a number of road traffic calming chicanes were added to the B2169 over recent years to reduce both traffic volumes and avoid heavy goods vehicles from travelling along this narrow road.

This road also has a very limited number of footpaths that are used by parents with young children to gain access St Marys Primary School and any increase in traffic volumes could be considered as very dangerous. If this site was to be considered further any pedestrian or vehicular access should be via Spray Hill which is a wider and safer road and of course has direct access to both the A21 and village shops etc. A pedestrian footway could then run straight down into the village which would be much safer for adults and children gaining access to the afore mention primary school. The proposed layout with housing on the south end of site would impact on the rural landscape and create more noise for the environment.

DLP_2854

Mrs Stephanie Gilbert

Object

Policy AL/LA 1 ref site 279

The site is located within the AONB and on the edge of the conservation area. (Lamberhurst Down & Scotney Castle) this proposed development would impact on the rural environment and surrounding areas. The road infrastructure would not be able to cope with the considerable influx of traffic created by the proposed development 25-30 houses. The A21 is already gridlocked at peak times and has a significant impact on many of the surrounding quiet lanes and in particular the B1269.

The proposed residential access onto the B2169 is already very busy taking traffic from the A21 towards Tunbridge Wells and Wadhurst. It should be noted that a number of road traffic calming chicanes were added to the B2169 over recent years to reduce both traffic volumes and avoid heavy goods vehicles from travelling along this narrow road.

This road also has a very limited number of footpaths that are used by parents with young children to gain access St Marys Primary School and any increase in traffic volumes could be considered as very dangerous. If this site was to be considered further any pedestrian or vehicular access should be via Spray Hill which is a wider and safer road and of course has direct access to both the A21 and village shops etc. A pedestrian footway could then run straight down into the village which would be much safer for adults and children gaining access to the afore mention primary school. The proposed layout with housing on the south end of site would impact on the rural landscape and create more noise for the environment.

DLP_3346

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 1 - “The provision of pedestrian links from the proposed residential area in the south through the site to the north leading to the village, and from the site westwards along Sand Road to link into the wider footway network”

Paragraph 4 - “Residential development to be located on the southern part of the site only, with location of access to be informed by a Transport 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 provision of pedestrian and cycle linkages to PRoW WT387 and WT388 are supported, but consideration will need to be given to upgrading these Public Footpaths for cycling access, to enable onward connectivity. It is requested that enhancements will be made to the PRoW, where they pass through the site. Contributions will also need to be made towards off-site PROW improvements to improve their accessibility, facilitate cycle access and improve active travel links with the Scotney Castle Estate

Heritage Conservation

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

The site has potential for post medieval remains associated with the settlement of Lamberhurst. There are several designated historic buildings adjacent or close to the site.

Development should be supported by an Archaeological DBA

DLP_3569

Kent & East Sussex Regional Office
National Trust

Support with conditions

The National Trust are the owners and custodians of Scotney Castle located to the east of the proposed site allocation. Whilst the National Trust does not object to limited residential development within the Parish of Lamberhurst we have concerns about the potential adverse impact’s residential development in the southern part of the site may have on the wider ecological network. The National Trust has aspirations to enhance and extend the existing green corridor from the roundabout toward Sweet Bourne stream and northwards through the Scotney Castle Estate and through future potential land acquisitions alongside the Lamberhurst Bypass. Residential development located in the southern part of the site may prejudice any future green corridor from the roundabout toward the village as well as undermine the ecological benefits of the existing land bridge used by wildlife over the Lamberhurst Bypass. The land bridge is used by different species and known dormouse populations within the surrounding area. We feel that the residential element including an appropriate landscape buffer would be more beneficial in the central area with closer links to the school, with the southern part of the site providing ecological mitigation for the build development and providing greater connectivity with existing green corridors.

The National Trust need to better understand the ecological impacts from any proposed development on the SSSI Scotney Castle and therefore it is essential that the Trust are engaged with the LPA at the earliest opportunity and any potential developer in the design of any proposal coming forward in this respect.

The Brown Trout public house and Down Farm Oasts are significant buildings in the history of the Scotney Castle estate and although some of the original character of these buildings has been lost from more recent developments, any impact on their historical significance should be a consideration as part of any future development within Lamberhurst.

DLP_3570

Kent & East Sussex Regional Office
National Trust

Object

The National Trust object to Policy AL/LA1 criterion 3 as we have identified potential operational and other impacts associated with the provision of a direct pedestrian/cycle link into the Scotney Estate at the West Lodge entrance and would like dialogue with the LPA prior to Regulation 19 to discuss access options for linking with the new development.

DLP_3623

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Lamberhurst. 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 30 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/LA 1

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 Lamberhurst. 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/LA 1

Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes

We also note that this site is in close proximity to Lamberhurst 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/LA 1

The development layout must provide sufficient distance between Lamberhurst 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_3994

Lamberhurst Parish Council

Support with conditions

Policy AL/LA1 - Land West of Spray Hill:

LPC welcomes the recognition in this policy that this site is very close to a SSSI location and has great biodiversity potential which requires special care if development were to take place.

It is within a dark skies zone and although we welcome the policy EN10 there should be little requirement for outside lighting.

Footpaths/pavements should be laid down Spray Hill to connect with those in the village at the bottom of the hill.

Site lies wholly within the AONB & affects two Conservation Areas

Confirmation that numbers reflected in this policy would not increase should other sites be found to be unsuitable.

Strongly support the provision of a pedestrian footway from the site westwards along Sand Road to link to the wider foot way network. Also links to Scotney and other PROW's

If this site is developed it is important that there is sufficient on site parking for residents and visitors to prevent parking on adjoining roads.

Site access should be considered from Spray Hill as opposed to the B2169 which is a very busy road.

DLP_4144

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

This is a large greenfield site in the AONB, partly adjacent to the Conservation Area but (apart from its northern section) well away from the existing and proposed Limits to Built Development.  CPRE do not object to the proposed safeguarding of the northern part of the site for future expansion of Lamberhurst Primary School or to the proposed landscape buffer.  However, we consider that if the site is allocated, the area to be developed should be limited to the area which is already partly previously developed land, i.e. the part south of Public Footpath WT388, and the proposed landscape buffer should be extended.   We agree with the other requirements of the proposed policy.

DLP_4439

Hugh and Susanna Smith

Object

We wish to comment on the draft Local Plan and Sustainability Appraisal please. Our concern is principally with Lamberhurst and its suitability to absorb additional housing, and particularly with the appropriateness of the Land to the West of Spray Hill (Map 85 Policy AL/LA1.)

With regard to the draft Local Plan Allocation AL/LA1, Land to the West of Spray Hill:

  • This allocation would have a substantial negative effect on a number of aspects of the neighbourhood.
  • The land is well outside the Limits to Built Development, even the LBD as recently extended, and should therefore not feature as an option in the Local Plan without compelling need. Alternative and more appropriate siting could for example be beside the revised LBD boundary adjacent to and west of the school.
  • The AL/LA1 land directly abuts the Lamberhurst Conservation Area, and its development would significantly diminish that Area.
  • In connection with Policy EN7 Heritage Assets, the properties neighbouring the land are listed buildings and include the unique and striking group of four Lamberhurst Down oast kilns. If developed, the new housing on the land would destroy the setting of these assets.
  • The removal of much wild woodland vegetation that would be required to develop the site would result in these historic assets being set visually within a modern housing environment. From Lamberhurst village centre itself, and from all viewpoints beyond, extending to the Goudhurst ridge, these oast kilns form a prominent and striking feature emerging from the trees and greenery of the Lamberhurst Down ridge. Development of this site would result in the oasts appearing in an incongruous semi-urban setting.
  • Moreover, in respect of Policy EN6 Historic Environment, these buildings on the Lamberhurst Down still comprise a contiguous series of assets, visually connected to and once part of the Old Scotney Estate, with its Scheduled Ancient Monument and its other historic buildings. The development of this site for housing would destroy the flow of this continuity.
  • The replacement of this woodland area with housing would diminish biodiversity in the area significantly. There would be marked habitat loss, and reduction of vegetation and tree density and diversity.
  • The building of 25-30 housing units on site AL/LA1 in this Area of Outstanding Natural Beauty could not be compliant with National Planning Policy, which requires exceptional circumstances / public interest for such development which are absent in this case.

We would like these comments to be taken into account as part of the consultation please.

DLP_8371

ASP Planning for Wellsbridge Estates Ltd

 

Please attached letter on behalf of our client Wellsbridge Estates Ltd.

Land to the West of Spray Hill

It is acknowledged that the council proposes to allocate land to the west of Spray Hill for 25-30 residential dwellings within policy AL/LA1. We do not wish to contend this allocation and have no objection. It is clear that this allocation provides wider benefits to Lamberhurst including an extension to Lamberhurst Primary School and the intention to provide improved pedestrian and cycle linkages in the locality and in relation to the Scotney Castle Estate.

Policy AL/LA 2: Misty Meadow, Furnace Lane

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_7

Phil Smith

Object

I am opposed to the proposed development at Misty Field Lamberhurst. The area is already a busy through road and the local amenities will not handle such a development. I am very concerned about he environmental impact of the proposed development. This is already very close to an area of environmental pollution from the local plans. It is also directly behind an area that suffers from surface water flooding.

I will be opposing the development throughout. There are other areas of land which could handle such a development nearby.

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7754 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_986

Mr Mark Ellis

Object

Policy AL/LA2

When the Lamberhurst Neighbourhood Plan was drawn up utilising numerous meetings for all residents within the Parish and the subsequent discussions from the findings on many consultants taken on by the Parish Council it was widely agreed that the following points should be paramount when deciding on potential sites:

1. Infill development was preferred to linear build that which stretch the village and was not required

2. Leave areas adjacent to Scotney and Bayham alone if possible

3.Use existing brownfield sites not virgin sites

Within the Lamberhurst Neighbourhood Plan it also states that we should protect and enhance bio diversity and the natural enviroment, conserve ancient woodland, do not encourage building within close proximity to Conservation Areas or listed buildings. It also states that there is a huge concern regarding traffic flow and safety and the existing entrance to this site is off a busy road with multiple road signage, width restrictions and limited sight lines. As the site is also at the far end of the village it would encourage more local traffic particularly for the school run and access for the elderly to the centre of the village.

DLP_1013

Ian Cooper

Object

WE OBJECT TO THIS APPLICATION

Policy Number: AL/LA2 (Misty Meadow, Furnace Lane - SHELAA referenfence; site 285)

This application should be disqualified on the below factual reasons.

Aside from being aware of the convent protecting the land being proposed for development (K575382)

The adverse effect on the the residential amentiy of neighbours (among other factors) Noise, disturbance, directly overlooking properties, loss of privacy, overshadowing, effecting the natural night light

Unacceptably high desnity / over development of the site, especially if it involves loss of open aspect (garden grabbing) There is a lack of demand for housing in Lamberhurst (on average a property takes 11months to be sold here) The infrastruture is already at capacity within the local Nursery, the primary school and local doctors.

The proposed site is outside of the village enevolope, meaning it will have an adverse impact on village community life with the large increase in car traffic having to head into the village and beyond.

There are endangered species within the proposed developmennt; the lesser spotted woodpecker and newts which can't be distrubed in their natural habit

This area is an Area of Outstanding Natural Beauty (AONB) which can't be built on due to drastic impact it will have on the visability of the ridge (loss of view) and surrounding areas, not just for neighbouring properties but also from a public view point. The adverse effect of the development on the character and appearance of the conservation area/AONB will drastically impact the bio-diversity of this area and will damage the landscape of Lamberhurst and it's far reaching views.

Conclusions; The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a MAJOR NEGATIVE IMPACT on the appearance of the AONB, with NO exceptional circumstances to justify such an allocation in such a highly visible location (highest point on the ridge). Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site's location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

I trust that these comments will be taken into account.

DLP_1359

Tim Cornick

Object

Site 285 – land at Misty Meadow, Furnace Lane, Lamberhurst

This site is on Furnace Lane, which is not well served by public transport. It is a 15 to 20 minute walk to the centre of Lamberhurst (and the same back again), which is too much for some.  Children would not be able to walk safely to school from the site.  Residents in this area therefore tend to rely on private cars to get around.

Construction of 30 houses on this site would likely mean up to 60 further private cars in this area.  Furnace Lane is already busy (and noisy) and traffic calming was put in place some time ago.  A traffic calming “chicane” exists almost opposite the site entrance.  Additional traffic in and out of the site would potentially cause congestion/hazard. The traffic calming already causes a lot of noise as cars brake as they come round the corner from the direction of Tunbridge Wells. On a number of occasions the bollard on the chicane has been smashed by cars failing to stop in time.

In addition the site has just the single access onto/from Furnace Lane.  At present the access is quite small and so presumably would have to be enlarged.

The above considerations indicate that developing this site would not be conducive to the following Sustainability Objectives identified in the Sustainability Appraisal of July 2019 –

Objective 1 (Air) - reduce air pollution

Objective 4 (Climate change) – reduce carbon footprint

Objective 13 (Landscape) – protect and enhance landscape/townscape

Objective 14 (Noise) – reduce noise pollution

Objective 17 (Travel) – improve travel choice and reduce the need to travel by private vehicle

Finally, it is not clear how developing this site and its access to Furnace Lane would affect the public right of way which runs from Furnace Lane on down the western boundary of Site 285.

Thank you

DLP_1502

David Doble

Object

Objection to draft local plan Misty Meadow Farm Lamberhurst.

  1. The proposed development site at Misty Meadow Farm is outside of the village curtilage, and is not within reasonable walking distance of Lamberhurst School, shop, or village hall for social functions, thus involving the use of a car on all occasions. Traffic conjestion is already a problem in the village centre. Additional traffic and pollution will only make things worse with little public transport in the area. Other places nearer the village should be reconsidered.
  2. The new houses are to be built on a fully exposed ridge, overlooking existing properties in Furnace Lane, lower on the north face of the hill. The area is designated as an area of outstanding natural beauty which will be blighted by this development of highly visible houses right on the ridge. The intended site has already been protected by an agricultural covenant for many years, because of its exposure from the area around.
  3. High Weald ANOB management plan is a statutory document Required by law. The plan guides local authority planning and Decision making to fufill their section 85 duty, of conserving and enhancing the ANOB. The development of housing behind dwellings running along a key road is is in direct conflict with the ANOB. Management plan.
  4. Misty meadow farm bungalow had planning permission turned down, for a second story extension for reason of a height restriction,as it would stand out on the ridge. Why the change now!

DLP_2110

Terry Everest

Object

Object

A meadow which should be protected.

DLP_2366

Paul Richardson

Support

Support

DLP_2476

John & Madeleine Church

Object

We write regarding the draft Local Plan and Sustainability Appraisal with regard to the Council's proposed housing strategy, the suitability of Lamberhurst to accommodate additional houses and the proposed allocation of a site on the south side of Furnace Lane for 30 houses.

We understand that the Council does not favour dispersed growth and the Furnace Lane site would provide high levels of new housing on the edge of a very small village, whereas growth in more established centres would be more sustainable given that this site would require reliance on private car transport. This is against climate change commitments. Because this proposed site is on the edge of the village it would be severely detrimental to the overal character of Lamberhurst and the High Weald AONB settlement pattern. Lamberhurst has a very limited range of services, examples being

  • Oversubscribed nursery + primary school, no secondary school leading to potential transporting children further afield.
  • One small shop with limited Post Office facilities
  • Very limited bus service, requiring use of motorcars.

The aims of the new Neighbourhood Plan offer insights into how developments could be designed to reflect the local character and rural location and avoid the danger of creating a more suburban character in the village.

In addition to the above mentioned limited available services to a site such as Furnace Lane, the site is located on a ridge and is therefore prominent in views from within the AONB, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, creating a disproportionately harmful impact on the character and appearance of the AONB.

One of the key concerns is the site's remoteness from the village, being 1.5km walking distance to the very limited services and to walk involves using narrow, unlit, steep access which also involves road crossing without designated crossing points. These aspects suggest the likelihood of new residents using private cars and parking in the village is very limited.

Also to have adequate access to the site by service vehicles the junction would need to be considerably enlarged, causing a harmful urbanising influence.

We feel that the scoring for the site contained in the SHLAA is unclear (site 285). The constraints identified as 'neutral' offer no explanation of their measurability against other sites and so it is an inadequate status given that the National Planning Policy framework gives AONB the 'highest status and protection'. This states that planning permission should be refused for major development other than in exceptional circumstances. 'Neutral' does not mean 'exceptional circumstances'.

Development of the site would have significant negative impacts in terms of climate change due to reliance on cars, biodiversity due to habitats of protected species , and landscape.

We trust that these comments will be seriously considered.

DLP_2780

Mr Andrew McConnell

Object

I firmly believe that the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, which has had a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst.

The Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools:   The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:      There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is … miles away, and really only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service:     There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking …. Minutes, costing £ ….. per journey, and with a frequency of just ……. Furthermore, the bus is always full with school children in the morning. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work.  New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Furthermore, I strongly object to development on this site for the following reasons:

9. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

10. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

11. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

12. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

13. “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

14. For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

15. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

16. The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

DLP_2845

Mrs Stephanie Gilbert

Object

Increase in traffic along the B2169 which is already a busy road taking traffic from A21 towards Tunbridge Wells and surrounding areas. It has also come to light that Misty Meadow has an agricultural covenant on the land and therefore should be occupied by a person employed or associated with working the land. Therefore should not be considered for development.

During the recent council planning meeting it was suggested that the land north of the Lamberhurst village should be considered for building the additional housing as this would have direct access to both the A21 and Lamberhurst village. This land clearly has the capacity to build the numbers of houses required and will have much less impact on traffic, existing properties and restrictive covenants.

DLP_2849

Janet Doble

Object

Objection to draft local plan Misty Meadow Farm Lamberhurst.

Loss of good farmland and wild life protected by covenant K575382. These will have to be removed. ANOB section 85 duty objective and LB 1 supports this,

It is furthest from village centre. Cars will be used making more traffic on busy B2169, more village parking needed, more pollution (ANOB section 85 OQ4 supports this.)

Villages should expand from centre out.

Far from village sewage works.

This is a water shed area into the Teise/ Medway. AONB Objective section G1 supports this.

This development is on a ridge and can be seen by many houses . AONB section OQ4 support’s this. The bungalow Misty Meadow Farm built in app. 2007 has a hight restriction on it ,and is lower than the ridge ,so more hidden .Application to take the restriction off has being turned down recently.

The only access is from the busy commuter road to Tunbridge Wells, the B2169. This access road will have to be widened and include the north south footpath that crosses the B 2169 here. More land would be involved if ever a roundabout or splayed entrance is considered. This junction will be expensive, and effects several more landowners.

DLP_2850

Mrs Stephanie Gilbert

Object

Misty Meadow Al/LA2 SHELAA ref site 285

Increase in traffic along the B2169 which is already a busy road taking traffic from A21 towards Tunbridge Wells and surrounding areas. It has also come to light that Misty Meadow has an agricultural covenant on the land and therefore should be occupied by a person employed or associated with working the land. Therefore should not be considered for development.

During the recent council planning meeting it was suggested that the land north of the Lamberhurst village should be considered for building the additional housing as this would have direct access to both the A21 and Lamberhurst village. This land clearly has the capacity to build the numbers of houses required and will have much less impact on traffic, existing properties and restrictive covenants.

DLP_2960

Emma Bullen

Object

Policy AL/LA2

I wholeheartedly object to this Policy for the reasons outlined below:

  • The Council's housing strategy conflicts with the consultation responses provided at the Issues and Options stage and has a direct influence on the proposed allocation of housing units in the village.
  • The Council's strategy of allocating poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern.
  • Lamberhurst is a very small traditional village with a limited range and capacity of services. The limited range and capacity in terms of Schools, Shops, Doctors and Bus Service is not reflected in the assessment of sites set out in either the SHLAA (Strategic Housing Land Availability Assessment) or the Sustainability Appraisal.
  • The Draft Local Plan is diverging form the aims and aspirations of the Neighbourhood Plan - the latter promotes developments that are well designed and reflect local character but the former will be far more suburban in character and will not reflect the rural location of Lamberhurst.
  • The site itself is located on a ridge and is therefore prominent in views from within the area of AONB, including footpaths.
  • The site will be viewed in the foreground of views towards the traditional built areas of the village and will therefore have a disproportionately harmful impact on the character and appearance of AONB.
  • The position of the site will only increase vehicle use further to access necessary service and the fact that there is not sufficient parking to utilise the current limited services in the village would only increase this issue.
  • The junction into the site would likely need to be highly engineered increasing the urbanising influence on the village.
  • Paragraph 172 of the National policy planning Framework gives AONB areas the "highest status of protection" and states, "planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest".  This can certainly NOT be substantiated under this proposal.

These are just a few but by no means exhaustive reasons I object to this plan and the objection will continue to be pursued.

There are far many sensible and suitable alternatives in urbanised areas elsewhere that have more services, better public transport and less damaging influences on the environment.  Furthermore, we should look to protect our areas of AONB, rather than jeopardise them.  I see no viable reason to support this plan.

DLP_3092

Anne Copeman

Object

Im objecting to this policy AL/LA2 Misty Meadow Farm furnace lane lam. I own this property Norton Cottages and look west across fields but I always understood to be green belt land. I have lived in Lamberhurst 81 years and sincerely object to this plan as it will take the value off my property. And cause even more traffic to drive down the Slade Road.

DLP_3095

G R Backshall

Object

I object on the grounds of building houses on ridge of skyline

DLP_3119

Bernard Couchman

Object

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Misty Meadow, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst.  For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required.  Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included.  Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_3135

Bernard Couchman

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Misty Meadow, Furnace Lane site.

  • The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  • The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  • The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  • Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  • In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Misty Meadow site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would be to allow for a series of small developments to be allowed within Lamberhust village nearer to the services.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_3158

C. J. & M. O. Crawford

Object

We object to this proposed development as 30 houses create a suburban image in a rural area.

The sudden volume demand on local services such as schools & doctors would cause unnecessary grief in Lamberhurst where such services are at full capacity.

The requirement of new houses in the area would be better met (in our opinion) by windfall development and the use of smaller sites which would occur over a longer time-span, giving local services time to adjust.

DLP_3347

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 - Link to existing footway network on Furnace Lane must be achieved.

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 policy requirement to protect and enhance the amenity of PRoW WT383 (paragraph 4) is supported. The expectation that contributions will be required towards improved access and footpaths is also welcomed.

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

Low archaeological potential

DLP_3466

High Weald AONB Unit

Object

The proposal is major development in the AONB which has not been adequately justified under paragraph 172 of the NPPF.

DLP_3995

Lamberhurst Parish Council

Object

Policy AL/LA2 - Misty Meadow

The site is in a highly sensitive area within the High Weald AONB. Paragraph 6.409 of the DLP indicates that when allocating sites that the AONB Management Plan needs to be taken into consideration.

It would also clearly impact on Settlement Objectives S2 to protect the historic pattern and character of settlements.

This site is well outside the Limits to Built Development in an AONB and does not respect the historic pattern of settlement.

The methodology for decisions on whether a site is a major development indicates that the impact on the settlement pattern would make this site “major”.

The NPPF clearly states that there have to be exceptional circumstances to build major developments in the AONB.

DLP_4145

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

The proposal for 25-30 dwellings is major development in the AONB which has not been adequately justified under NPPF paragraph 172.  The site is well outside the proposed Limits to Built Development and is likely to produce a suburban satellite to the village which is out of character with the traditional pattern of Wealden development.  The proposal, apparently, to use the public footpath as the access road to the proposed development is also a matter of concern.

DLP_4660

J N C Staines

Object

With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment.  Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included.  Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason.  There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

The Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern. Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.

I consider Misty Meadow - Site reference 285 (new Local Plan Allocation AL/LA2) unsuitable for development for the reasons given below and therefore oppose the plan for the following reasons:-

The Gunning Principles clearly set out the requirements that public bodies MUST follow when planning any changes. The Gunning Principles are the legal process by which public bodies must involve and inform members of the public at an informative stage in any proposals. They are always reviewed during any legal challenge. The Gunning Principles state that the public must be able to give an informed consideration and response. In this proposal, it is stated that Lamberhurst requires a minimum of 55 houses. These houses will be split across 2 identified sites meaning that the proposals do not offer any degree of option for local residents to comment on. On that basis, I feel that this plan does not meet the basic Gunning Principles and therefore should not go ahead.

Using the scoring matrix from the Local Plan I object to the proposals based on the following reasons:

Land use

  • There is a covenant on the larger of the two fields which restricts development. The covenant number is K575382. The land is currently designated for agricultural use only
  • By changing the agricultural land it would have a significant impact on the landscape and the hill top pattern
  • The site is firmly within the High Weald AONB who also opposes the proposal.
  • The AONB which is a statutory document outlines a number of objectives which are contradicted by this proposal including:
    • AONB objective FH4 to protect the archaeology and historic assets of field and health
    • Objective FH2 to maintain the pattern of small irregularly shaped fields bounded by hedgerows and woodlands which characterises the High Weald AONB
    • The fields and boundaries are rare survivals of a medieval landscape
    • Objective LBE1 to resist the removal of agricultural occupancy conditions
  • A key issue identified by the AONB is the reduction of livestock grazing leading to a loss of farm infrastructure and degradation of pasture and soil. The Misty Meadow site is currently used for livestock grazing.
  • One to the top issues for the AONB is the loss of green fields to development

Landscape

  • The proposed site is on a ridge line and so would be visible for some distance. Certainly most houses in the village would be affected in some way
  • A key characteristic of the AONB is the distinctive settlement pattern with dwellings built along ridge roads such as Furnace Lane. The High Weald AONB identifies a key issue where the layout and design of developments fail to respond to the AONB which is the case with this proposal. Organisations MUST fulfil their Section 85 duty to have regard to the purpose of conserving and enhancing the AONB. These proposals do not demonstrate that regard
  • Objective OQ4 in the AONB management plan is to protect and promote the perceptual qualities that people value
  • I have significant concerns about the ability to provide an appropriate means of access onto the B2169

Heritage

  • The development of housing behind an existing row of single dwellings along a key road is in direct conflict with the Settlement pattern as outlined by the AONB management plan which is a statutory document.
  • The plans would affect a significant number of listed buildings associated with the site including some pre 1750 dwellings

Climate change

  • Residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. Even when allowing for the rural context of the site, where opportunities to maximise sustainable transport will be inherently more limited than in urban areas, the site is not well placed with relatively easy access to services and facilities. I am aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds
  • This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.
  • The increased lighting and noise is an issue to be taken into consideration. The AONB management plan which is a statutory document states clearly the importance of dark skies and dark qualities. This part of the village is not currently well lit so these proposals would change the light pollution dramatically

Biodiversity

  • The impact of additional cars on the B2169 to Hook Green and on to Tunbridge Wells will be significant and raises concerns about the impact on wildlife
  • Clay Hill Road is a cross country route which residents at Misty Meadow will use to get to the A21. This road has designated Roadside Nature Reserves which have been specially designated as a habitat at risk. Roadside Nature Reserves are home to rare or notable species and can serve as a link for wildlife enabling plants and animals to flourish. The additional traffic on Clay Hill Road would place these Nature Reserves at risk
  • The plans do not propose a net gain in biodiversity

Travel

  • Of the 8 sites identified in the Local Plan, 7 of them were discounted based on the distance from the village and the lack of public transport options. The Misty Meadow site is the furthest site from the village of all the 8 sites considered. I would like to draw attention to the scoring matrix on page 207 of the Local Plan.
  • The site is too far for the average homeowner to walk to the local amenities such as the shop and the school. This will generate a number of short vehicle trips into the village which would occur frequently due to the absence of a safe alternative means of travel.
  • I am aware of a recent planning submission in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) in which an appeal was dismissed on the grounds of the inherently car-dependent nature of the location, particularly with regard to access to employment. This case was based on 8 houses whereas Misty Meadow will host 30 houses meaning the travel impact will be much greater than in this case which was turned down. I believe this sets a legal precedent.
  • The plans propose a single access road into the site and would have to be upgraded to serve 30 houses including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lane, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  • The access is not solely within the Misty Meadow plot and affects land boundaries of more than 3 properties.
  • The impact of additional vehicles travelling on the already busy and dangerous B2169 raises concerns about safety. School buses regularly drop school children off on the verges of this road which doesn’t have pavement risking danger to life.
  • New residents are likely to commute to London using the already overcrowded facilities at Bells Yew Green (Frant) station. The community at Bells Yew Green already has challenges with station users parking in the village and causing blockages on the roads. The car park is already at full capacity every day at Bells Yew Green
  • The AONB management plan Objective G3 states that developments must support travel alternatives but this site does not meet that requirement

Services & Facilities

  • There are no additional services or facilities planned to support this development
  • The site is challenging and not accessible to services and amenities
  • The village school is at capacity and would not be able to house the additional children from 30 houses
  • The village nursery reports being at full capacity with long waiting lists for prospective children
  • UK Power networks report 6 known power outages since July 2019 in the immediate area around Misty Meadow. All the houses in the area were without power for several hours as recent as 26th October 2019 requiring immediate works as advised by Chris Smith at Avidety Ltd on behalf of UK Power Networks
  • There is no mains gas supply to the village of Lamberhurst meaning the dependence on a reliable electricity service is more important
  • The TWBC Local Plan identifies a need for children play areas but the nearest playground is over a mile away

Business Growth

  • There are no benefits to business growth in this proposal

Deprivation

  • There is a recognised need for affordable housing within the Village but there are no details about how this site will address that need.
  • All residents would require a car as the site is too far away from the village and the site is let down by poor public transport links

Noise

  • Naturally the levels of noise will increase in what is a very quiet part of the village. Because this development is on a ridge line, the sound (and light) will carry down into the village too

Resources

  • There are no plans to improve resources in this proposal

Water

  • The site is already very water logged. The development of an additional 30 houses raises concerns about the impact of surface water on the existing dwellings
  • The draft plan identifies this area as a Groundwater Source Protection Zone
  • The AONB Management plan which is a statutory document states in Objective G1 to avoid development close to water courses. The proposed site is adjacent to multiple water courses

Health

  • The Primary Healthcare / GP Practise in Lamberhurst is a major concern. The Infrastructure Plan proposes a cluster area based in Horsmonden and covering Horsmonden, Lamberhurst, Matfield, Brenchley and Goudhurst. This is not an acceptable solution

Air

  • The aim of Air Quality Management Areas (AQMA) Policy EN 24 is to improve and maintain levels of air pollutants in Air Quality Management Areas (AQMA) and surrounds. The area currently registers as “low “, any development will impact this

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

DLP_4671

Mandy Cornick

Object

Proposed Development of 30 houses at Misty Meadow Farm, Furnace Lane, Lamberhurst

I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site at Misty Meadow Farm on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Issues specific to Furnace Farmhouse

Furnace Farmhouse faces south and is directly opposite the present entrance to Misty Meadow Farm.   I  am unclear as to what alterations are proposed for the access to the new estate. However, as the exit from Misty Meadow Farm onto Furnace Lane is presently narrow, wooded and immediately adjacent to the traffic calming, the alterations are likely to be extensive and will significantly affect the house in a variety of ways.

  1. The house presently has a rural outlook both to the south and the north. Road alterations are will suburbanise us.
  2. Our privacy will be severely impacted by as many as 60 cars emerging opposite our south facing bedroom, particularly in the winter when it is dark. This is an entirely different privacy issue to cars passing both ways along Furnace Lane.
  3. There are likely to be additional street lights outside the house which will cause us significant light pollution. The lamppost installed above the traffic calming already throws a lot of light into our bedrooms.
  4. There will be a lot more noise and air pollution from cars.
  5. There is likely to be significant congestion in front of the house. The traffic calming already causes congestion and traffic noise as cars do not see it coming up the hill and around the corner towards the village so often brake at the last minute. Cars have collided with the bollard on a number of occasions.

DLP_4672

Mandy Cornick

Object

Proposed Development of 30 houses at Misty Meadow Farm, Furnace Lane, Lamberhurst 

I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site at Misty Meadow Farm on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lane, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.” For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

I trust that these comments will be taken into account.

DLP_4676

Sue Ashe

Object

Proposed Development of 30 houses at Misty Meadow Farm, Furnace Lane, Lamberhurst

I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site at Misty Meadow Farm on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Issues specific to Furnace Farmhouse

Furnace Farmhouse faces south and is directly opposite the present entrance to Misty Meadow Farm.   I  am unclear as to what alterations are proposed for the access to the new estate. However, as the exit from Misty Meadow Farm onto Furnace Lane is presently narrow, wooded and immediately adjacent to the traffic calming, the alterations are likely to be extensive and will significantly affect the house in a variety of ways.

  1. The house presently has a rural outlook both to the south and the north. Road alterations are will suburbanise us.
  2. Our privacy will be severely impacted by as many as 60 cars emerging opposite our south facing bedroom, particularly in the winter when it is dark. This is an entirely different privacy issue to cars passing both ways along Furnace Lane.
  3. There are likely to be additional street lights outside the house which will cause us significant light pollution. The lamppost installed above the traffic calming already throws a lot of light into our bedrooms.
  4. There will be a lot more noise and air pollution from cars.
  5. There is likely to be significant congestion in front of the house. The traffic calming already causes congestion and traffic noise as cars do not see it coming up the hill and around the corner towards the village so often brake at the last minute. Cars have collided with the bollard on a number of occasions.

DLP_4677

Sue Ashe

Object

Proposed Development of 30 houses at Misty Meadow Farm, Furnace Lane, Lamberhurst 

I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site at Misty Meadow Farm on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lane, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.” For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

I trust that these comments will be taken into account.

DLP_5032

34 households in Lamberhurst

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use the private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra- low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

4) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

5) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

TWBC: Submitted by the following residents of Furnace Lane, Furnace Avenue, Hoghole Lane, and The Slade:

Nicky & Neill Scott
David & Janet Doble
Joan Burns
Mark Burns
Andrew & Sue Ashe
Bernie & Jen Couchman
Ian & Gemma Cooper
James & Jeannine Mackrill
Sue & Russ Kirton
Vanessa & Andy McConnell
Maria Jeffery
Alicia & Jenny Fox
Elizabeth 
David & Emma Bullen
Nick  &   Jenny   Staines
Andrew & Frenella Blamey
Angela & Alan Pascoe
Steve & Jenny Farris
Dennis Haskell
Mandy & Tim Cornick
Jo Harvey
Victoria & Yvonne Settle
Lesley Young
Mike Couchman
Hamish Bett
Tony & Eliann
Debbie Edwards
Ashwini
Clare Martins
Caroline Lambert
Colin & Margaret Crawford
Jan Stocker
Maddy Church
Phil Smit

DLP_5779

Mrs Vanessa McConnell

Object

POLICY AL/LA2

The impact of additional cars on the B2169 to Hook Green will impact the wildlife.  Already a 'rat run' this road has designated roadside nature reserves.   Reserves are home to rare or notable species putting these at risk.  The plans to not demonstrate a net gain in bio diversity.  Population of Great Crested Newts in gardens along Furnace Lane believed to travel up to 500m between water sources.

Climate change - residents in this plan would also have to drive to the village. Short and frequent journeys.  Lack of parking in the village also. As such carbon emissions with 30 householders would have a significant impact.  The accessbility of the site is challenging and does not promote the health benefits of walking and cycling due to steep hill and inconsistent pavements.

There is a need for affordable housing within the village but building within AONB can only be carried out under exceptional circumstances which this scoring does not demonstrate.  Can we ensure that the housing being built is indeed affordable housing only?  There are no details about whether this site will address these needs.

There is a convenant on the site restricing use to agricultural use only K575382. The land is currently used for grazing.  Loss of green fields to development.  The fields and boundaries are rare legacies of a medieval landscape.  The views from the footpath will be compromised.  This is a popular walking route for villagers to walk to Hook Green. Objective OQ4 on AONB management plan is not being adhered to.

The proposed site on the ridge line would be visible for some distance. The site is located on a ridge and so is prominet in views adjacent to the footpath. Section 85 obligation appears to not have been considered.

TP2 & OSSR 2- Services and Facilities - Lamberhurst is a small rural village with limited services and accessibility.  The nursery school is oversubscribed and the primary school is also almost full.  There is no secondary school so pupils will have to be transported.

Only one shop where it is already hard to park and people park on a sharp corner with no crossing which is very dangerous.

Limited bus service to the village.  The bus is always full with school children in the morning.  This means that the bus service could not be reliably used by anyone living ni Lamberhurst and wanting to commute.

In addition to the above there is a concern that the Draft Local Plan is not consistent with the aims of the Neighbourhood Plan.    That devlopments reflect rural character.

I trust that these comments will be taken into account.

DLP_5840

Mr Gerard Thraves

Object

I wish to express my objection to any further significant housing developments in Lamberhurst and in particular the proposed Misty Meadow development. Whilst this particular site has unique features which make it unsuitable for development some of my comments could be applied to any significant development within villages.

Misty Meadow is on the ridge-line and as such this proposed development will further degrade the rural skyline of the AONB.

Misty Meadow is a green field site, in a rural location not adjacent to an urban built environment, loss of natural habitat within the AONB.

The Misty Meadow development falls within the river catchment of the Teise, the increased rate of run-off from new housing, roads and pavements, particularly on this site which presently drains to the west of the village will increase the risk of flooding in the centre of an historic village. With anticipated increased frequency and intensity of rainfall incidents as a consequence of climate change any development in the Teise valley will increase flood risk.

Lamberhurst is a traffic calmed village and yet planning policy in this and other instances appears to render less effective the measures put in place to calm the traffic.  The  B2169 Furnace Lane already has significant east/west traffic. Traffic from other developments in locations such as Hawkhurst are degrading the natural environment and turning what was once a relatively quiet rural road in to major  trunk route without the highway enhancements that are desired to maintain public safety. The Misty Meadow development will feed traffic onto this road.

More generally what appears to be arbitrary allocation of housing developments to rural locations is not a "planned" and "sustainable" practice. Most, if not all, of the residents of such developments will work outside the village and thus have to drive to work. Because of this undisputed fact the Borough Council is grid-locking the entire rural network of roads every morning and evening with journeys that would be unnecessary if the required housing was build adjacent to urban areas and better public transport was provided, to enable commuting form the outskirts of Tunbridge Wells to the centre.

No attention seems to be given to provision for young people, housing developments like Misty Meadow will have teenage residents as well as adults. There are no clubs for teenagers in Lamberhurst and the bus service is so poor that young people passing through challenging years can't get to entertainment facilities on North Farm estate. Some young people left to their own devices can develop undesirable habits, such as vandalism, graffiti, and drug misuse. Housing all these young people out in rural locations where there is less provision for their needs does not reflect well on the judgement of the Borough Council.

Finally small hamlets and villages are quite unique habitats, just as are urban centres, putting more than penny numbers of housing into small villages will destroy a unique part of the cultural heritage of England, this heritage is cherished by many people throughout the world. Creeping urbanisation of our rural communities which lack the benefit of economies of scale found in urban centres incubates a second class of citizen that the local authority lacks the resources to serve.

DLP_5882

Hamish Bett

Object

I would like to oppose the plan to develop the land around Misty Meadow Farm, Lamberhurst.  The plan as I understand it includes the building of approximately 30 dwellings.  Although I welcome the addition of new homes in the village, the site in question is, in my view unsuitable for the following reasons:

Situation

The site is 1.5km from the center of the village and associated services including shop and primary school.  Inhabitants of the new estate are unlikely to walk to these services and will favour (as outlying residents already do) the use of private cars. This will exacerbate the issue of lack of parking in the village as well as the environmental impact.

Local Services

The nursery and preschool are already oversubscribed and have no room to expand. The primary school has only four spaces currently available and would need to expand to accommodate the children from 30 plus new households. Any expansion on the existing enclosed site would be difficult and expensive.

Aspect

Misty Meadow Farm is situated on a ridge line and any development would be clearly visible from the public footpath running along side. This stands contrary to the guidelines set out by the Weald AONB.

In my view, a more organic solution to the housing needs of the area can be met with smaller, more sustainable pockets of housing.

DLP_5886

Mr James Mackrill

Object

I write to comment on the proposal to include this site as having the potential for a development of 30 houses.

It is recognised that more housing needs to be provided generally, although the formula for ascertaining the target number of houses and the subsequent scoring of this site is questioned. Those aspects are not addressed in detail in these comments.

The Misty Meadow site appears to fail on a number of aspects…

i) Environmental: It is a large prominent development within an AONB that will be visible because its size and the height of the land.

ii) Environmental: There is no reasonable option for the residents to walk or cycle to the shops, school, village hall or sports fields, except for the very energetic. The consequence will be an increase in the existing traffic and parking problem in the village for all residents. There is minimal public transport and no bus stop near the site.

iii) Economic: The necessity to drive to amenities implies that further business will be lost for the local shop and pubs to the bigger centres of Wadhurst and Tunbridge Wells, as now, providing little economic advantage to Lamberhurst.

iv) Social: The isolated nature of the development, beyond the village envelope, makes engagement and neighbourly contact with the wider village more difficult, especially for older residents or those with dependents.

v) Alternative sites: There are numerous smaller, less obtrusive sites with pedestrian access, where new development can be subtly woven into the existing fabric of the village that would have value and contribution from environmental, economic and social perspectives.

The sustainability requirements of the proposed site do not appear to have been met.

DLP_5888

Alan Pascoe

Object

I am writing to register my objections to the local plan and the proposal to allocate 30 new dwellings on the south side of Furnace Lane at Misty Meadow

The councils Topic paper Distrrubution of Development confirms that 8% supported dispersed growth and 1% semi dispersed growth. This is such a low amount of support that it is strange that the council is proposing high levels of new housing in a small visit like Lamberhurst. This does not reflect the feedback that has been given from local residents.

There seems to be inconsistencies with selection of sites using the C ouncils Strategic Housing Land Availibility Assessment and the Sustainability Appraisal. Certain sited have been rejected but then comparable sites have been included. Some have been included despite for example negative scores for dependency on private car use – which with current importance to climate change awareness.

Proposing 60 homes as a whole in Lamberhurst conflicts with the consultation repsonses provided at the Issues and Options stage. Large poorly connected sights within the village is detrimental to the character of Lamberhurst and ANOB settlement pattern. Lamberhurst is a small traditional village developed over hundreds of years and has a limited range of services not reflected in the site assessment in SHLAA and the Sustainability Appraisal.

The local school that both my children attend are all ready full. There is no secondary school. Additional children from the extra 60 houses would not be able to be accommodated at the school. The local nursery is all ready over subscribed.

There only one small village shop which is limited and not adequate for a weekly shop. There is not enough village parking for the extra vehicles that would result. The development is outside the centre and people would choose to drive and not walk to the centre and lack of parking spaces or cars parked on roadsides would cause disruption.

Public transport is very limited. A very poor bus service from Lamberhurst to Tunbridge Wells is always full with school children in the morning and could not be relied on for residents and commutes. New residents would therefor likely to be using private cars for transportation again raising environmental conerns.

The draft Local Plan is conflicting to the emerging wishes of the residents Neighbourhood plan. The proposed developments are also against the wishes of the Parish Council.

The Furnace Lane site is located on a ridge is in prominent views with the ANOB. The area includes foot paths. I believe that the Lamberhurst Vineyard proposed site for development was rejected as this is on a ridge. The Furnace Lane ridge is even higher so surely this should be ruled out.

As mentioned earlier the site is remote from the village. There is pedestrian access but the walk is unfriendly into the village – narrow pavements and poor lighting again it would promote reliance on cars promoting extra journeys and vehicle emissions.

The existing access would need to be upgraded and there is an issue of multiple owners of the land

The land is known to have a covenant which has previously prevented planning permission of Misty Meadow.

I have recently discovered Bats at my property just opposite the proposed site. It is highly likely that they will be present in the area marked for development. The construction  disturbance and extra light generated as a result of the new homes would have a severe impact on these endangered species. A recent proposal for approximately 7 homes in the centre of Lamberhurst was rejected I believe this was one the reasons.

In Conclusion the approach taken for the provision of housing is contrary to the consultation response. Lamberhurst is a small rural village with limited services. Proposals for 60 extra houses can not be supported with the current infrastructure. It will promote greater reliance on the use of motor cars. Focusing on established urban areas with greater services and public transport is a more appropriate  way of increasing housing whilst taking into account climate change concerns.

This development would have a major change on the appearance of the ANOB with no justification. It would not be in keeping with the rural nature of the village.

I trust that these comments will be taken into account

DLP_5912

Angela Pascoe

Object

Re Misty Meadow site reference AL/LA2

I am writing to register my objections to the local plan and the proposal to allocate 30 new dwellings on the south side of Furnace Lane at Misty Meadow

The councils Topic paper Distrrubution of Development confirms that 8% supported dispersed growth and 1% semi dispersed growth. This is such a low amount of support that it is strange that the council is proposing high levels of new housing in a small visit like Lamberhurst. This does not reflect the feedback that has been given from local residents.

There seems to be inconsistencies with selection of sites using the Councils Strategic Housing Land Availibility Assessment and the Sustainability Appraisal. Certain sited have been rejected but then comparable sites have been included. Some have been included despite for example negative scores for dependency on private car use – which with current importance to climate change awareness.

Proposing 60 homes as a whole in Lamberhurst conflicts with the consultation repsonses provided at the Issues and Options stage. Large poorly connected sights within the village is detrimental to the character of Lamberhurst and ANOB settlement pattern. Lamberhurst is a small traditional village developed over hundreds of years and has a limited range of services not reflected in the site assessment in SHLAA and the Sustainability Appraisal.

The local school that both my children attend is already full. There is no secondary school. Additional children from the extra 60 houses would not be able to be accommodated at the school. The local nursery is all ready over subscribed.

There is only one small village shop which is limited and not adequate for a weekly shop. There is not enough village parking for the extra vehicles that would result. The development is outside the centre and people would choose to drive and not walk to the centre and lack of parking spaces or cars parked on roadsides would cause disruption.

Public transport is very limited. A very poor bus service from Lamberhurst to Tunbridge Wells is always full with school children in the morning and could not be relied on for residents and commutes. New residents would therefor likely to be using private cars for transportation again raising environmental concerns.

The draft Local Plan is conflicting to the emerging wishes of the residents Neighbourhood plan. The proposed developments are also against the wishes of the Parish Council.

The Furnace Lane site is located on a ridge is in prominent views with the ANOB. The area includes foot paths. I believe that the Lamberhurst Vineyard proposed site for development was rejected as this is on a ridge. The Furnace Lane ridge is even higher so surely this should be ruled out.

As mentioned earlier the site is remote from the village. There is pedestrian access but the walk is unfriendly into the village – narrow pavements and poor lighting again it would promote reliance on cars promoting extra journeys and vehicle emissions.

The existing access would need to be upgraded and there is an issue of multiple owners of the land

The land is known to have a covenant which has previously prevented planning permission of Misty Meadow.

I have recently discovered Bats at my property just opposite the proposed site. It is highly likely that they will be present in the area marked for development. The construction disturbance and extra light generated as a result of the new homes would have a severe impact on these endangered species. A recent proposal for approximately 7 homes in the centre of Lamberhurst was rejected I believe this was one the reasons.

In Conclusion the approach taken for the provision of housing is contrary to the consultation response. Lamberhurst is a small rural village with limited services. Proposals for 60 extra houses can not be supported with the current infrastructure. It will promote greater reliance on the use of motor cars. Focusing on established urban areas with greater services and public transport is a more appropriate  way of increasing housing whilst taking into account climate change concerns.

This development would have a major change on the appearance of the ANOB with no justification. It would not be in keeping with the rural nature of the village.

I trust that these comments will be taken into account

DLP_5937

Rachel Jones

 

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment Nos. DLP_5932 (Policy STR1 The Development Strategy) and DLP_5935 (Policy STR/LA 1)], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

  • The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  • The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  • We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.
  • The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  • Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  • In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.
  • The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_5975

Simon Steddon & Sue Cox

 

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment Nos. DLP_5976 (Policy STR1 The Development Strategy) and DLP_5974 (Policy STR/LA 1)], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

DLP_6267

Victoria Settle

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

4) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_6336

Fenella Blamey

Object

Draft Local Plan and Sustainability Appraisal reference Lamberhurst site AL/LA2

I write with regard to the proposed site for the building of around 30 houses on land currently known as Misty Meadow Farm, Furnace Lane and wish the Council to take note of my comments and objections.

It seems unnecessary, in view of the new housing developments already proposed in other areas of Kent, such as Horsmonden, Tudely, Five Oak Green and Paddock Wood that a small rural and historic village such as Lamberhurst should have to accommodate up to 60 new homes, 30 of which are proposed at Misty Meadow Farm. This would not be a small infill development within the village settlement but a large urbanisation along the outskirts of the village. This proposal does not take into account the aims of the emerging Neighbourhood Plan, and it is totally contrary to the High Weald AONB’s Statement of Significance when referring to the development of small villages in the area. Village settlements are an important part of the High Weald AONB which advises any new building should be kept within the village limits, ie smaller numbers of houses built in infill locations; not a large housing development on important farm land on the outer reaches of the village. This proposed development would be along an exposed ridge line where houses would be clearly visible from afar, thus drastically changing the character of the High Weald and the village of Lamberhurst.

DLP_6353

Andrew Blamey

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route is narrow, largely unlit. Features. The residents consider using the limited village services, would be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

4) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

I trust that these comments will be taken into account.

DLP_6531

Gareth and Joanne Moger

Object

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Misty Meadow, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: See comment DLP_6528], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Misty Meadow, Furnace Lane site.

  • The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  • The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  • The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  • Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.” 

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  • In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Misty Meadow site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would be to allow for a series of small developments to be allowed within Lamberhust village nearer to the services.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

DLP_6565

Lesley Young

Object

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Misty Meadow, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: See comment DLP_6528], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Misty Meadow, Furnace Lane site.

  • The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  • The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  • The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  • Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.” 

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  • In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Misty Meadow site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would be to allow for a series of small developments to be allowed within Lamberhust village nearer to the services.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

DLP_6633

Nicky Scott

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

4) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

5) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

7) The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_6642

Isla Tompsett

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

4) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

5) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

7) The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_6702

Alan Bearfield

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

4) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

5) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

7) The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_6726

Nicholas Fogg

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

4) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

5) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

7) The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_6746

Maria Palmieri

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

(insert footpath photo) [TWBC note: no images were attached]

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

4) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_6770

Alicia Longley-Coomber

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

4) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_6783

Jenny Fox

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

4) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_6952

T & L E Rodgers

Object

We believe that the proposed plan for the development of some 30 houses on this site is inappropriate and fails to satisfy several important criteria.

The development would have a highly visible and adverse impact on this AONB and its biodiversity.

There is already a serious lack of public transport,primary school places and retail and other amenities. New residents would be highly dependent on private cars and service vehicles seriously adding to the traffic pressures on this already busy village New infrastructure investments would be needed to remedy these problems.

DLP_6979

Chris Hill

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

4) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

5) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

7) The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

DLP_7294

Miranda Hungerford

Object

Draft Local Plan and Sustainability Appraisal

We are writing to you to register our concerns and objections to the following:

  • the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy
  • the suitability of Lamberhurst to accommodate additional dwellings
  • the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  • The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  • The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  • We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.
  • The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  • Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  • In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.
  • The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will be heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

DLP_7427

Neill Scott

Object

As noted above [TWBC: see Comment Nos. DLP_7420 Policy STR 1 and DLP_7424 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.
  4. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  5. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

7. The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7494

Freya Alder

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  • The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  • The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  • The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  • Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  • In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7534

Ruth Murphy

Object

Draft Local Plan and Sustainability Appraisal

We are writing to you to register our concerns and objections to the following:

  • the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy
  • the suitability of Lamberhurst to accommodate additional dwellings
  • the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  • The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  • The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  • We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.
  • The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  • Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  • In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.
  • The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will be heavily reliant on the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

DLP_7553

DM and SE Woodcock

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7552 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7583

Andrew Ashe

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7582 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7604

Helen and David Cheales

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7603 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7606

Laura Gendt

Object

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

4) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

5) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

7) The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7608

Mike Couchman

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7607 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7613

Mr and Mrs G Playfoot

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7611 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7707

Carolyn and Adrian Schweitzer

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7706 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7712

Jenny Couchman

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7711 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7723

Rosie Ashe

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7722 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7727

Ian Cooper

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7724 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.  There are endangered species which use this habit throughout the year, which have not been taken into consideration. They are the Newt and Lesser Spotted Woodpecker.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major negative impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7732

Franklin Ashe

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7731 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7737

Anna Walsh

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7736 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7743

Mrs J A Staines

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7742 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB. [TWBC: see Image 1 and Image 2].
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7748

Phillip and Maureen Ashford

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7747 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7763

Joan Burns

Object

I have attach my disgust and reject your proposed building on the Misty Meadow site at Lamberhursl.

On a personal note I cant cross Furnace lane outside my house at certain times as to the traffic already there. I used to walk to the village and to the church but struggle now as i am not quick enough to cross the road.

The area is an AONB site that you don't seem to care about.

I have Greater Crested Newts that live there and are protected

Constant Electricity cuts wit no mains gas

There is a covenant on the land so not to build on it

Your proposed number of houses means every house will have over an acre of garden do we really need 30 houses priced at over a million pounds each in the village.

Finally i now lots of other elderly villagers that would like to complain about the preposed site but cant as you have made it impossible for the elderly. If you are not computer literate and literate in your planning assessments the you cant complain and if you could it would be taken seriously as it is not in the planning format you want.

Attached is my complaint so open it

Outraged and disgusted old person

[TWBC: attachment as follows]:

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7761 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7772

John McNamara
The Old Down Stores

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7772 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB. I know local authorities have targets to build affordable homes but the Misty Meadow plan is flawed and has the characteristics of something that is wrong on so many levels.

We trust that these comments will be taken into account.

DLP_7789

Ross Wingfield

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7788 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7812

Sarah and David Blake

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7811 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7815

Julia Goldfinch

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7814 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7819

Sarah Bearfield

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7818 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7821

Stephen Farris

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7820 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7825

Jennifer Farris

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7824 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

DLP_7839

Mr & Mrs Kirton

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst.  For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required.  Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.

With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment.

Examples include:

  • Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included.
  • Some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason.
  • Comments appear to not be applied with equity, some sites seemingly being discounted with statements such as ‘Lack of key services and facilities in the settlement’ and Lack of options for public transport’ which would appear to apply to other sites.
  • The Strategic Housing and Economic Land Availability Assessment details the Site Assessments for Lamberhurst Parish (July 2019), shows that the average proposed density of housing on each of the sites offered for development was calculated at an average of 12 houses per acre, apart from the two sites (285 and 279) that are now proposed in the Local Plan. These are clear outliers at a density of 1 to 2 houses per acre.

There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner allowing comparable data of the other long list option sites for Lamberhurst Parish.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7828 Policy STR 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site, on a ridge, will be visible to traffic passing north bound from Wadhurst to Lamberhurst on the B2100, on their approach to the village the road looks up to views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

The Strategic Housing and Economic Land Availability Assessment details the Site Assessments for Lamberhurst Parish (July 2019) and for site ref number 285, Misty Meadows, Page 317 to proposes that ‘the southern area of the site to be returned to agricultural purpose before the first occupation’

It is not clear how this will be a viable option, given that the farm infrastructure will have been removed in order to create a viable housing development site

The Strategic Housing and Economic Land Availability Assessment details the Site Assessments for Lamberhurst Parish (July 2019) and for site ref number 285, Misty Meadows , Page 317  it sets out requirements for the site 285, for residential development (C3). It proposes that there is ‘Single point of access using existing track’. The land that this track runs over is owned by a number of different owners and not the sole ownership of the land owners of Misty Meadows Farm.

In addition, the ‘Provision of adequate visibility splays’ will require land on either side of the existing track, which is owned by a number of neighbouring households. There is also a natural pond on land required for visibility splays and on occasion this results in surface water to the B2169, Furnace Lane.  The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents. The Local Plan, with regards to site 285, the Strategic Housing and Economic Land Availability Assessment for Lamberhurst Parish (July 2019) is in conflict with Lamberhurst Draft Neighbourhood Development Plan policy number L2 and Draft Lamberhurst Neighbourhood Development Plan policy number H1.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1), in two large sites, will have a disproportionate impact and cannot be supported by existing infrastructure as a slower growth rate of a greater number of smaller sites within the village centre, reducing reliance on car journey for daily local trips to schools and shop.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7846

Dr Katherine Eden-Green

Object

I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Using the scoring matrix from the Local Plan I object to the proposals based on the following reasons:

Land use

  • There is a covenant on the larger of the two fields which restricts development. The covenant number is K575382. The land is currently designated for agricultural use only
  • By changing the agricultural land it would have a significant impact on the landscape and the hill top pattern
  • The site is firmly within the High Weald AONB who also opposes the proposal.
  • The AONB which is a statutory document, outlines a number of objectives which are contradicted by this proposal including:
    • AONB objective FH4 to protect the archaeology and historic assets of field and health
    • Objective FH2 to maintain the pattern of small irregularly shaped fields bounded by hedgerows and woodlands which characterises the High Weald AONB
    • The fields and boundaries are rare survivals of a medieval landscape
    • Objective LBE1 to resist the removal of agricultural occupancy conditions
  • A key issue identified by the AONB is the reduction of livestock grazing, leading to a loss of farm infrastructure and degradation of pasture and soil. The Misty Meadow site is currently used for livestock grazing.
  • One to the top issues for the AONB is the loss of green fields to development

Landscape

  • The proposed site is on a ridge line and so would be visible for some distance. Certainly most houses in the village would be affected in some way
  • A key characteristic of the AONB is the distinctive settlement pattern with dwellings built along ridge roads such as Furnace Lane. The High Weald AONB identifies a key issue where the layout and design of developments fail to respond to the AONB which is the case with this proposal. Organisations MUST fulfil their Section 85 duty to have regard to the purpose of conserving and enhancing the AONB. These proposals do not demonstrate that regard
  • Objective OQ4 in the AONB management plan is to protect and promote the perceptual qualities that people value
  • I have significant concerns about the ability to provide an appropriate means of access onto the B2169

Heritage

  • The development of housing behind an existing row of single dwellings along a key road is in direct conflict with the Settlement pattern as outlined by the AONB management plan which is a statutory document.
  • The plans would affect a significant number of listed buildings associated with the site including some pre 1750 dwellings

Climate change

  • Residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. Even when allowing for the rural context of the site, where opportunities to maximise sustainable transport will be inherently more limited than in urban areas, the site is not well placed with relatively easy access to services and facilities. I am aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds
  • This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.
  • The increased lighting and noise is an issue to be taken into consideration. The AONB management plan which is a statutory document states clearly the importance of dark skies and dark qualities. This part of the village is not currently well lit so these proposals would change the light pollution dramatically

Biodiversity

  • The impact of additional cars on the B2169 to Hook Green and on to Tunbridge Wells will be significant and raises concerns about the impact on wildlife
  • Clay Hill Road is a cross country route which residents at Misty Meadow will use to get to the A21. This road has designated Roadside Nature Reserves which have been specially designated as a habitat at risk. Roadside Nature Reserves are home to rare or notable species and can serve as a link for wildlife enabling plants and animals to flourish. The additional traffic on Clay Hill Road would place these Nature Reserves at risk
  • The plans do not propose a net gain in biodiversity

Travel

  • Of the 8 sites identified in the Local Plan, 7 of them were discounted based on the distance from the village and the lack of public transport options. The Misty Meadow site is the furthest site from the village of all the 8 sites considered. We would like to draw attention to the scoring matrix on page 207 of the Local Plan.
  • The site is too far for the average homeowner to walk to the local amenities such as the shop and the school. This will generate a number of short vehicle trips into the village which would occur frequently due to the absence of a safe alternative means of travel.
  • I am aware of a recent planning submission in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) in which an appeal was dismissed on the grounds of the inherently car-dependent nature of the location, particularly with regard to access to employment. This case was based on 8 houses whereas Misty Meadow will host 30 houses meaning the travel impact will be much greater than in this case which was turned down. We believe this sets a legal precedent.
  • The plans propose a single access road into the site and would have to be upgraded to serve 30 houses including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lane, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  • The access is not solely within the Misty Meadow plot and affects land boundaries of more than 3 properties.
  • The impact of additional vehicles travelling on the already busy and dangerous B2169 raises concerns about safety. School buses regularly drop school children off on the verges of this road, which doesn’t have pavement risking danger to life.
  • New residents are likely to commute to London using the already overcrowded facilities at Bells Yew Green (Frant) station. The community at Bells Yew Green already has challenges with station users parking in the village and causing blockages on the roads. The car park is already at full capacity every day at Bells Yew Green
  • The AONB management plan Objective G3 states that developments must support travel alternatives but this site does not meet that requirement

Services & Facilities

  • There are no additional services or facilities planned to support this development
  • The site is challenging and not accessible to services and amenities
  • The village school is at capacity and would not be able to house the additional children from 30 houses
  • The village nursery reports being at full capacity with long waiting lists for prospective children
  • UK Power networks report 6 known power outages since July 2019 in the immediate area around Misty Meadow. All the houses in the area were without power for several hours as recent as 26th October 2019 requiring immediate works as advised by Chris Smith at Avidety Ltd on behalf of UK Power Networks
  • There is no mains gas supply to the village of Lamberhurst meaning the dependence on a reliable electricity service is more important
  • The TWBC Local Plan identifies a need for children play areas but the nearest playground is over a mile away

Business Growth

  • There are no benefits to business growth in this proposal

Deprivation

  • There is a recognised need for affordable housing within the Village but there are no details about how this site will address that need.
  • All residents would require a car as the site is too far away from the village and the site is let down by poor public transport links

Noise

  • Naturally the levels of noise will increase in what is a very quiet part of the village. Because this development is on a ridge line, the sound (and light) will carry down into the village too

Resources

  • There are no plans to improve resources in this proposal

Water

  • The site is already very water logged. The development of an additional 30 houses raises concerns about the impact of surface water on the existing dwellings
  • The draft plan identifies this area as a Groundwater Source Protection Zone
  • The AONB Management plan which is a statutory document states in Objective G1 to avoid development close to water courses. The proposed site is adjacent to multiple water courses

Health

  • The Primary Healthcare / GP Practise in Lamberhurst is a major concern. The Infrastructure Plan proposes a cluster area based in Horsmonden and covering Horsmonden, Lamberhurst, Matfield, Brenchley and Goudhurst. This is not an acceptable solution

Air

  • The aim of Air Quality Management Areas (AQMA) Policy EN 24 is to improve and maintain levels of air pollutants in Air Quality Management Areas (AQMA) and surrounds. The area currently registers as “low “, any development will impact this

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

I trust that you will take the aforementioned concerns into consideration,

DLP_7850

Daniel and Amelia York

Object

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7849 Policy STR/LA 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians.  The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

    “Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

    For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

  5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_7857

Mrs J H Fox

Object

I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

My interest is as a walker of the footpaths in the Lamberhurst area and as a relative of a resident in Furnace Lane.  It can be very uplifting and therapeutic to walk down one of the local footpaths in the Furnace Lane area, and in just a few minutes one can experience being in a ‘different place’ in the country.  Currently the area has some farming and the old stone cottages on the ridge, the proposed Furnace Lane site would be located on the ridge and would detract from views of the Area of Outstanding Natural Beauty, including from nearby footpaths, and would have a harmful impact on the character and appearance of the AONB.

The village of Lamberhurst has developed slowly over time and has limited facilities. The nursery school is oversubscribed and the primary school has only a few spaces. There is one small shop in the village with a very limited range. There are only five buses a day to Tunbridge Wells and these are busy at school times.

Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by the existing infrastructure and will be heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding my objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

I trust that these comments will be taken into account.

DLP_8154

Vicki Berry

Object

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Lamberhurst is a small traditional village that has developed slowly over time and has just a limited range of services as a result.  The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal.  These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper.  Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is 6 miles away, and practicably only reachable by car.

Bus & train service:  There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking 45 minutes, costing £3 for a single journey, and with a frequency of just five buses per day. Furthermore, the bus is always full with school children in the morning. Trains to London go from Frant, which is also only practicably accessible by car (the Bayahm Road is lethal for cyclists) so car journeys from the village would be dramatically increased.

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan.  The Neighbourhood Plan is promoting developments that are well designed and reflect local character.  The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

There are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings.  Such concerns are amplified with regard to the Furnace Lane site.

  1. The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
  2. The site is remote from the village and not readily accessible by pedestrians.
  3. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
  4. Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5. In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village.  A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

DLP_8251

Ms Yvonne Settle & Mrs Olive Settle

Object

Draft Local Plan and Sustainability Appraisal 

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard tothe Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

(insert footpath photo)

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access.  With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

4) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account and would appreciate confirmation of receipt of this email.

DLP_8370

ASP Planning for Wellsbridge Estates Ltd

 

Please  see attached letter on behalf of our client Wellsbridge Estates Ltd.

Misty Meadow, Furnace Lane

Following on from the SHELAA assessments the Draft Regulation 18 Local Plan has proposed in policy AL/LA 2 to allocate 25-30 residential dwellings on land known as Misty Meadow, Furnace Lane. Having reviewed the SHELAA entry for the land it is clear that there are several concerns regarding the allocation. Firstly, the land is distanced from the village development boundary by approximately 100 metres and as such is poorly integrated. Secondly, Furnace Lane is predominantly characterised by a ribbon form of residential development. As such the proposed allocation would result in backland development which would be contrary to policy and out of keeping with the surrounding residential character of the locality.

Irrespective of this fact the site has still been brought forward for allocation. Lastly, the SHELAA entry for the site notes that ‘parts of the site are sensitive in landscape terms.’ The site is very exposed and poorly contained in relation to adjacent residential development. In this regard it is considered that there are more appropriate alternative sites which would be more appropriate in Lamberhurst as will be detailed in subsequent paragraphs.

DLP_8345

James and Emma Young

Object

TWBC: correspondent submitted the following comments on 27/11/19, after the close of consultation on 15/11/19:

Draft Local Plan and Sustainability Appraisal 

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard tothe Furnace Lane site.

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points.  There is a steep incline/decline between the site entrance and the village.  Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles.  Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

4) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents).  The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites).  However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion.   The council should not be making a large housing allocation on the most visible edge of a traditional village.   A far better approach would to allow for a series of small developments to be allowed within Lamberhust village.  Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB.  Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car.  Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location.  Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.