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Section 5: Place Shaping Policies Sandhurst


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

Contents

Policy STR/SA 1: The Strategy for Sandhurst Parish

Comment No.

Name/Organisation

Response

DLP_8306

NHS West Clinical Commissioning Group

General Observation

The CCG notes that it is expected that contributions will be required towards health/medical facilities to mitigate the impact of the development. These will be requested, as necessary, in line with CCG Policy which is currently for developments of over 20 houses or more; noting that the allocations currently detailed are for less than 20 houses.

DLP_600

Sport England

Policy STR/SA 1

Sport England supports bullet point h the improvements to the football pitch as it is in line with adopted Playing Pitch Strategy.

DLP_3358

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

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

Paragraph 4 - “Maintenance and enhancement of, and/or linkages to, public footway network, public rights of way…”

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

The specific speed limit changes and call for traffic calming requested in point e) are not acceptable to the Local Highway Authority and should be removed. The Transport Assessment will highlight specific mitigation measures: should not be pre-empted at this stage.

Public Rights of Way and Access Service

The specific reference to PRoW in paragraph 4 is supported. It is requested that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development.

DLP_5741

Sandhurst Parish Council

please find attached a copy of the plan for Sandhurst playing fields which highlights the area purchased by the Parish Council which could be used potentially as the site for a new village hall – please see below.

Please also see our comments below which we believe should be included in the Local Plan:

View of the possible long term strategy of the Sandhurst Parish Council for developments and improvements

Changes in the number of new houses planned for the village and surrounding areas immediately fringing the parish are likely to mean an increase in the range, number and volume of demands on local services.  This effect is largely divorced from the wishes of the local village residents as shown in the work undertaken so far in the preparation of the “Neighbourhood Plan” . This work suggests that small increases in numbers of houses in various small locations over a period of time is the preferred way forward.  

The principal resources within the village are confined to the Old School Hall (a Victorian building limited by the construction criteria of its time); two  Children’s Play Areas (one adjacent to the “Old Orchard” Development and another, larger facility, located at the junction of Marsh Quarter Lane and the A268 main Rye Road.  Other  activities are generally confined to the Primary School built around 1910 with later additions and some church buildings of various denominations.

Open air recreational facilities are available on the village Playing Fields with a recently upgraded and extended Sports Pavilion.   The fields provide facilities for football and cricket teams and storage for equipment mainly in storage containers.

Car parking is a constant source of difficulty within the village centre, especially where the Primary School  access opens virtually directly onto the A268.  These factors add to the problem of speeding traffic through the village and pose an increasing risk to children and adults alike.

The Parish Council are facing increasing costs for the maintenance of the Old School Hall and given the construction and age of the building its “long" term future must be in doubt.  

The recent proposal to increase the number of houses on land to the South of Ringle Green concerns  the residents of the village and therefore the Parish Council.  This strengthens the Council view that the main Play Area for children on the  corner of the junction of Rye Road and Marsh Quarter Lane may need to be relocated to a safer area of the Playing Fields. An additional area of land purchased by the Parish Council a few years ago to the South of the existing Playing Fields for just such a use could be made available – see attached plan.

Summary of possible costs involved in such a strategy could be:

- Re-locate Childrens Play area to safer area with replacement equipment - £75,000 +  
- Re-surface Playing Fields Car Park  -  £35,000
- Improvements to Car Parking in village  -  £25,000
- Re-surface Old School Hall car parking area -  £10,000
- Re-placement Village Hall  - on land owned by the Parish Council £600,000 (Possible partial off-set by sale of existing hall) Grants would also be sought.

DLP_4153

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

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.  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_4566

Historic England

Policy STR/SA 1: The Strategy for Sandhurst 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_5747

Kent Design Studio for Mrs C Hinves

Please see attached a site we require consideration under the current call for sites process attached to this email.

I can confirm the address of the site is;

Sharps Hill Farm,
Queen Street,
Sandhurst,
Kent
TN12 7LE

[TWBC: see site location plan].

Policy AL/SA 1: Land on the south side of Sayville, Rye Road and west of Marsh Quarter Lane

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_3574

Barton Willmore for Clarendon Homes

Support with conditions

TWBC: no supporting documents were submitted with this representation.

Clarendon Homes, as promoters to this site, broadly supports this policy as including the objective of securing approximately 10 – 15 dwellings at the site. Clarendon does however make the following representations concerning the site.

1. Site Area

Clarendon has promoted the site (inc. submission to the Call for Sites) on the basis of a larger site area encompassing land to the south of the allocation area (SHELAA reference – 149).

The allocation land therefore only concerns the northern part of the wider site. Whilst supporting the allocation of this parcel, Clarendon fails to see why the southern parcel has been omitted from the allocation.

Within the Draft Local Plan evidence base, only the Sustainability Appraisal makes reference to the division of the site, yet this is not clear. Table 47 (page 99) within the SA provides an assessment of the whole site (as per the map on the previous page - 98) as against a number of sustainability indicators and thus confirming the acceptability of the whole site in sustainability terms. Of particular note, “Heritage” and “Landscape” indicators are scored as “Slightly Negative” and “Neutral/Slightly Negative” respectively.

Conversely, at Appendix S (page 215), the whole site receives a worse SA scoring for “Heritage” and “Landscape” being “Slightly Negative/Negative” and “Negative” respectively.

Clarendon has undertaken background surveys for the site and in particular does not agree with the “Heritage” scoring in the latter SA (Appendix S) as above for the whole of the site. There are limited heritage implications for the southern part of the site (as well as the northern element). We would therefore recommend that the “Heritage” scoring for the entire Clarendon land is rated as “Neutral”.

In landscape terms, whilst the site is in the AONB (which washes over all of Sandhurst), Clarendon considers that appropriate mitigation can be secured towards the southern boundary of the whole site (with regard to the relationship/views to the wider AONB to the south). This can be secured through a package of landscape measures including the provision of meadow land/open space/SuDS/landscape planting along the Clarendon submitted southern boundary. In “Landscape” terms, we therefore consider a “Neutral/Slightly Negative” scoring to be appropriate.

Notwithstanding the above comments, a negative grading in terms of landscape does not necessarily preclude a site (parcel thereof) from development. This is evident at Hawkhurst Golf Club, which receives a “Negative/Very Negative” scoring in the SA in landscape terms – a worse grading than the wider (southern) Clarendon site.

2. Quantum of Development

Clarendon considers that the site, including the southern parcel, is able to accommodate a greater level of development than that allocated in the Draft Local Plan.

In this regard, the National Planning Policy Framework 2019 (Section 11 – Making Effective Use of Land) seeks for development proposals to make optimal use of land and achieve appropriate densities.
Clarendon has undertaken numerous background surveys for the site including landscape/visual, heritage, ecology, arboriculture and highways and these surveys have informed emerging development proposals for the site.

In this regard, Clarendon considers that the whole site is capable of accommodating up to c. 30 dwellings whilst respecting inter-alia, heritage assets and landscape character. This level of development would make a more meaningful contribution to the Council’s housing supply (inc. affordable housing) and mix.

The Draft Local Plan seeks to make provision for a total supply of 14,776 units up to 2035/36. As against the Government’s current requirement during the same period (13,560 units) this amounts to a 9% uplift on the housing need.

The total identified supply is however based on an average figure whereby sites and settlements are identified to deliver ranges/parameters of development. For example, Hawkhurst is identified for development of 643 – 693 dwellings during the Plan period. Within this quantum, Hawkhurst Golf Club (AL/HA 1) is allocated for c. 400 – 450 units and thereby an average of 425 units for this site is used in the housing supply for the Local Plan.

We do not dispute this approach however it may be the case that the Local Plan does not achieve the full anticipated levels of growth. Increasing the quantum of development on this site (and potentially others) would enable the Council to achieve a higher buffer and thus provide for more flexibility in the market for new homes. We would therefore recommend that the policy/allocation is amended to “providing approximately 30 dwellings” and also to encompass the southern parcel of the whole Clarendon site.

3. Off-Site works

The policy refers to the following off-site works:

- Provision of a new crossing on Rye Road (Criterion 2); and
- Provision of improvements to footways along Rye Road (Criterion 3).

Clarendon does not necessarily object to the principle of these provisions, however such provisions should be made by virtue of “proportionate contributions” towards S278 highways works as undertaken by the Highway Authority.

It is thereby recommended that the criteria be amended as follows:

- “Proportionate contributions towards” the provision of a new crossing on Rye Road (Criterion 2); and
- “Proportionate contributions towards” the provision of improvements to footways along Rye Road (Criterion 3).

The above contributions to be made from the site must be (as per NPPF – para 56):

- Necessary to make the development acceptable in planning terms;
- Directly related to the development; and
- Fairly and reasonably related in scale and kind to the development.

4. Other Planning ObligationsCriterion 8 refers to “Improvements to existing” allotments, amenity/natural green space, parks and recreation grounds, and child and local play space. This is supported by Clarendon.

Conversely Policy STR/SA 1 – Strategy for Sandhurst (Criterion 5) refers to “Provision of” allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space.

Policy STR/SA 1 assumes the provision of new facilities, whereas AL/SA 1 correctly relates to improvements to existing facilities. It is therefore recommended that STR/SA 1 is amended for consistency.

The policy (AL/SA 1) also refers to contributions towards:

- Public realm at the centre of Sandhurst;
- Other highways related works; and
- Measures to enhance bus travel.

Clarendon does not necessarily object to the principle of these provisions, however the contributions to be made from the site must be (as per NPPF – para 56):

- Necessary to make the development acceptable in planning terms;
- Directly related to the development; and
- Fairly and reasonably related in scale and kind to the development.

DLP_3359

Kent County Council (Growth, Environment and Transport)

Support with conditions

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

Paragraph 1 – “Provision of vehicular access informed by Highways Assessment (to include assessment of junction with A268) and landscape and visual impact assessment”

Paragraph 2 – “Investigation and provision of pedestrian crossing facilities on Rye Road”

Paragraph 3 – “Scheme to demonstrate (or provide for) pedestrian connectivity between the site and Sandhurst Primary School

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 links between the site and Public Footpath WC295 are supported. It is requested that contributions will also be made towards off-site improvements along this PRoW, to mitigate the impact of the development.

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

Low archaeological potential

Policy AL/SA 2: Land adjacent to Old Orchard and Stream Pit Lane

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_2119

Terry Everest

Object

Object

Its an orchard or was an orchard and should be protected or replanted as such.

DLP_3360

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:

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

It should also be noted that Old Orchard appears to be a private drive.

Heritage Conservation

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

Low archaeological potential