Section 5: Place Shaping Policies Hawkhurst

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

Contents

General comments

Comment No.

Name/Organisation

Response

DLP_1715

Peter Hay

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course and the potential for 80 houses within the land off Copthall Avenue AL/HA6.

The proposed development on the Hawkhurst Golf Club site in particular would destroy the character of an important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

The proposed development off Copthall Avenue is still split into two sections. The first application by Dandara was rejected at the planning committee and is now subject to appeal. The second is the development of Westfield which is still in the process of TWBC planning trying to decided whether or not to support the development or perhaps try and encourage Leander to “give up” for other reasons?

Non-compliance with Hawkhurst Neighbourhood Development Plan

None of the major proposed developments are compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify any of them. There is no local need for developments of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. All it does is encourage urban sprawl which is what is exactly happening now.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament.

The proposed developments aforementioned would impact unacceptably on an AONB

Paragraph 172 of the revised National Planning Policy Framework (NPPF) states that

‘Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated’.

Furthermore, paragraph 175 of the NPPF should be adhered to ‘When determining planning applications, local planning authorities should apply the following principles: c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists’.

The Draft Local Plan fails to show how the proposed development of the Golf Course and land allocation AL/HA6 (Land off Copthall Avenue) would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are very limited local employment opportunities and no secondary schools within walking distance.

The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution.

In an e-mail dated 4^th September 2017 the Principle Transport and Development Planner opposed all future development in Hawkhurst because the effect would be severe on the notorious traffic light junction of the A268 and the A229 in the middle of the village. There is an ongoing complaint regarding KCC Highways that is now destined for the Obbudsman.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. It would involve the removal of many mature trees and damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

The so-called “relief road” would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area.

As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes.

Kent Fire & Rescue Services also have serious concerns but were not even consulted UNTIL I CONTACTED THEM !

DLP_6369

Hawkhurst Parish Council

The table below summarises HPC’s feedback on pages 235 to 239.

Hawkhurst overview
		Hawkhurst Highgate	Hawkhurst (the Moor)	Gills Green
Conservation area		Change east to west of centre	Change village pond to church pond
Transport – rail (shortest distance to by road)	There is no bus service to Etchingham station. Generally, no buses link to train times
Health facilities		Hawkhurst Community Hospital serves West Kent and beyond not just Hawkhurst
		Dentists, Osteopath private not NHS
Retail			Change retail very limited to no retail	Delete close by (Great House is in Gills Green)
Services		Change three to two small village halls
Recreational		Add Royal British Legion	Remove cricket club (moved to Gills Green)
			Only 1 tennis court

DLP_6423

Hawkhurst Parish Council

p.241, para. 5.92

One of the few references to the TWBC NDP for Hawkhurst but the number caveats effectively makes the NDP redundant. Why can the draft TWBC Local Plan not use the TWBC NDP for Hawkhurst as the starting point of the new Local Plan policy for the parish?

The Hawkhurst NDP has passed independent examination and received a wholehearted endorsed by the local community through a referendum. In February 2018, with a turnout of 35% of those on the electoral roll 91% voted to support the draft plan as the statutory planning document to shape and influence new development across the parish.

It should be noted that only 32% of those on the electoral roll in Hawkhurst and Sandhurst voted in the May 2019 Borough Council elections.

TWBC then made NDP in 26th March 2018 so that it is the TWBC Neighbourhood Development Plan for Hawkhurst and runs until 2033 – that is another 13 years during which it is expected to be the plan that guides the future of Hawkhurst village and the wider parish.

However, without any justification, specific parts of the draft TWBC Local Plan effectively overwrites the key aims, objectives and adopted policies of their own made NDP, and. In the view of the Parish Council, the content of the draft TWBC Local Plan demonstrates that the TWBC is effectively acting in a non-compliant manner with an adopted statutory planning document. Moreover, this is an adopted plan that is part of its own Development Framework, the suite of documents that comprise the planning policy coverage for the whole borough. Within this framework, “made” neighbourhood plans are a vital part of the policy coverage.

It is not clear to us why TWBC believe it is able to overwrite part of its own statutory framework (TWBC Neighbourhood Development Plan for Hawkhurst) that still has another 13 years to run while also arguing it needs to abide by national and local policies in other policy areas.

This inconsistent approach has resulted in a lack of trust between residents plus the Parish Council and the TWBC over both the planning process at large, and over the details of the local plan process that lies ahead over the short to medium term. Neighbourhood plans are the only part of the planning system that requires consent through a local referendum, yet the draft TWBC Local Plan takes aim at their own TWBC Neighbourhood Development Plan for Hawkhurst, less than two years after an overwhelming public vote in favour of it.

Policy STR/HA 1: The Strategy for Hawkhurst Parish

Comment No.

Name/Organisation

Response

DLP_210

Julian Wilson

The proposed number of new houses being built in Hawkhurst is ludicrous, mostly because it is very difficult and dangerous to travel through Hawkhurst crossroads. The Housing allocation has no justification, unless the Local Plan includes a proper improvement to HGV use and congestion of the A229 and the road network becomes suitable for the increase in residents.

Housing is needed, but TWBC must be prepared to properly manage the major improvements to Transport and Infrastructure which are essential to support its Housing objectives. This makes the Hawkhurst ‘strategy’ utterly flawed and is why there is so much objection to new developments from existing residents.

The Transport Strategy Document is very weak in all aspects, the above just being one example. [TWBC: see also Comment Number DLP_211]

DLP_249

Rosanna Taylor-Smith

7. Landscape gaps

I agree that there should be landscape gaps or Green Wedges between areas of development. This Policy has not been instigated thus far, however.

I agree also that historic Assets should be preserved, even those with no formal listing status such as The White House, for example,

8. ALL of Hawkhurst is within the AONB - TWBC seem not to be aware of this in many instances of recent planning applications.

DLP_1674

Hobbs Parker

We object to Policy STR/HA1 - The Strategy for Hawkhurst Parish as being unsound for failure to include land at Trewint Farm, Slip Mill Lane. A much larger area has been previously assessed under SHELAA reference 392.

In response to this assessment the landowner is putting forward part of the site, 0.81 acres, fronting Slip Mill Lane as being suitable for a small residential scheme of approximately 6 units. A scheme of this size takes into account the existing residential properties opposite (Wellington Cottages) and to the north along Slip Mill Lane making best use of a previously developed site. Accordingly a low rise residential development scheme would have no greater landscape impact than the existing use, with any new build set against the backdrop of the existing frontage development located to the north. In order to respond to the local characteristics the intention would be to retain the front hedgerow, accessing the properties via the existing access, and providing parking to the rear. Small sites are important to housing delivery and can be phased in the early part of the plan.

DLP_2044

Penelope Ennis

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

TWBC cannot misunderstand the local opposition to this development and the destruction of the character of our village which this would cause. We have experience of TWBC pushing for approval of a large scale near us of 49 houses. We are aware of how undemocratic and oppressive TWBC and KCC Highways can be when they 'decide' on a plan. There is an opportunity with this consultation to listen to our community.

I have already stated that this and many other large scale developments are not compliant with our Neighbourhood Development Plan. We have no need for this quantity of housing or this type.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. For many years there has been a requirement to merge the 2 doctors surgeries for reasons of economy and to attract doctors to rural practices with specialisms that would save patients traveling. This is obviously a desirable plan but burdening our village with 120 additional houses as suggested by the Fowlers Field plans is too heavy a price to pay.

Southern Water suggests that it would take 2 years for them to improve our sewerage system adequately. This has been discussed in Parliament.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that the great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And, that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development.

Existing facilities and services are scaled for the needs of a village; they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are limited local employment opportunities and no secondary schools within walking distance. Building on the Golf Course removes two of the very few local sports facilities and I suggest that a sports facility should have been included in the plans.

Our Parish Council make it clear that roadside air pollution is already breaching guidelines and that where traffic is static at the traffic lights there are health implications for residents even at first floor level. They are making a request for better monitoring and you should wait for reliable data before ignoring this factor.

There are few viable transport alternatives to the car which means Hawkhurst would not be an appropriate location for a development of this size. Public transport services are limited and expensive. They do not match with demand for rail services at commute times and certainly do not adequately provide for young people to travel socially or for Travelling East to West by bicycle would perhaps be fine (if you didn't die in the process) but the topography is a deterrent for the developers idealistic view of us all popping to the shops on bicycles. Maybe in 20 years time electric bicycles will be so cheap that we can all afford them but for the moment this is not realistic.

As a community we feel that KCC Highways have provided incorrect data for traffic modelling and have relied heavily upon the traffic surveys of the developers. The traffic data for the Golf Course development included March readings during the 'Beast from the East' and ignores the seasonal variations of coast bound Camber traffic.

Traffic at a standstill does not add economically to our space paired as it is with inadequate central parking facilities. The relief road merely moves the issue down the road (quite literally) and shoppers will not use a car park so far from the centre. This road is being relied upon in the Sustainability Assessment but it is just a road that would have to be provided to service the properties and is substandard in terms of width and construction. It is a residential road and not fit to take the volume of heavy goods vehicles that will use it. It will crumble. Upon the closure of the top end of Cranbrook Road there is no allocation for a turning space further along if a vehicle should take a wrong turn. Only recently there was a well documented incident of a lorry trying to turn around at the top of Cranbrook Road at the junction with Peter Buswell's office. There appears to be no plans for buses returning to the village centre via the relief road and Cranbrook Road residents will be marooned form the centre of the village by the closure of the Cranbrook road at the top of the hill.

Kent Fire and Rescue have also commented upon the impact that this road closure would have on them.

This development is contrary to the NPPF which requires significant development should be focused on locations that are or can be made sustainable, by limiting the need to travel and offering a genuine choice of transport modes. Congestion, emissions and public health concerns over them will be raised by this development.

There is no environmental benefit to the proposed development. The removal of mature trees and habitats are of concern to the Woodland Trust who say that there is no wholly exceptional reason for the development as required by the NPPF.

The 'relief road' will not work.

The road would not provide the benefits which have been claimed. The adverse impact would extend beyond the boundaries of TWBC into Rother DC and beyond KCC into East Sussex CC. None of this seems to have been considered. The displacement of traffic across minor lanes is already a cause for concern in our village and Slip Mill, Delmonden, Whites, Water and Stream Lane all suffer damage, accidents and flooding due to poor management.

Unless Highways England have substantial plans for reclassification of the major haulage routes taking HGV's down from Maidstone to the A21 and not via Cranbrook and Hawkhurst south the road does not provide relief. Major alterations are required to the junction with the A21 at Flimwell to enable HGV's to turn left out of the relief road and turn right at the crossroads in the centre of the village to travel south down Highgate Hill and join the A21 at Coopers Corner/Hurst Green. This is likely to make the crossroads in the centre of the village more congested and less safe for the pedestrians.

DLP_2091

Terry Everest

STR/HA1

A reduction in the scope and pace and size of develppment is argued for here, and I will object to several unsustainable developments.

DLP_2146

Michael O'Brien

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

I have already stated that this and many other large scale developments are not compliant with our Neighbourhood Development Plan. We have no need for this quantity of housing or this type.

Lack of adequate infrastructure

Southern Water suggests that it would take 2 years for them to improve our sewerage system adequately. This has been discussed in Parliament.

The proposed development would impact unacceptably on an AONB

The proposed development would not constitute sustainable development.

Kent Fire and Rescue have also commented upon the impact that this road closure would have on them.

The 'relief road' will not work.

DLP_2411

Rosanna Taylor-Smith

Policy STR/HA1 Strategy for Hawkhurst

My comments relate to the village of Hawkhurst.

You state that 'developments to be delivered before the relief road (Policy STR1) will be expected to demonstrate with clear evidence that there is sufficient additional capacity at the crossroads of A268 and A299' in addition to the Flimwell traffic light junction with A21 (in East Sussex and not within the Borough).

TWBC does not produce documented evidence of consultation with East Sussex County Council or Highways England to evaluate A21 and Flimwell crossroads or the impact of the proposed 'Relief road' on the A268 and A299 to the various towns, villages and communities nearby so I therefore conclude that the 'Duty to Co-operate' has not been met.

The so-called ' Relief Road' is a total misnomer and why does TWBC and KCC see it as a cure-all for the traffic issues experienced day in, day out in Hawkhurst? Surely it is merely an 'incentive' being offered by a developer who wishes to demolish and build on the Golf Club site, resulting in the loss of wide areas of important green space, historic woodlands and wildlife habitats, not to mention an important sports and leisure venue, used by a wide variety of residents for golf, squash, Pilates classes, U3Aart classes, social events and much more. This proposed relief road is in no way capable of solving traffic issues currently experienced daily; it is shown to be narrower a than Highgate Hill, for example, and would merely move traffic from the top of Cranbrook Road, thereby causing delay to Fire Engines, other emergency services and lost time before attending incidents; residents would face longer journeys as well. This relief road would cause more vehicle movements along the A268 to the traffic lights at Highgate, resulting in even longer queues to turn RIGHT not the A299 towards Hurst Green.

HGV traffic should be re-routed away from Hawkhurst to access the A21 to avoid the centre of Hawkhurst. Unless and until this happens, I cannot see any improvement to Air Quality and quality of life for residents and all those who use the local centre of shops, cinema, cafes, public houses, library, Doctor's surgery, etc. in the centre of Hawkhurst.

DLP_2499

John Wotton

STR/HA 1 Strategy for Hawkhurst Parish and allocation policies for Hawkhurst

I object to this policy to the extent that it provides for major development within the AONB, on the grounds that the tests for such development under paragrpah 172 NPPF are not satisfied (see my comments on the Distribution of Development Topic Paper). I also object to each of the allocation policies for Hawkhurst which would constitute such major development.

DLP_2521

Guy Dagger

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

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

DLP_2570

Jane Pyne

STR/H1 I disagree with the amout of new dwellings you have allocated for Hawkhurst. This is really beyond sensible.You are treating the ANOB with no repsect which is what Hawkhurst comes under.

STR/2 There is some reason for going with windfall sites. The made NDP is part of this process but there is no recognition of the made NDP by TWBC

STR/3 The relief road has to be looked at in light of its use and this will not be a relief road in any form. The amount of traffic will be hardly any different but will cause more traffic problems and I am at a loss why planners cannot see this. The few that will use the right hand turn to Flimwell off the estate road will be negilgible as what seems to be forgotten is that many large vehicles and traffic in general go to Tenterden or Rye or to the other side of Hastings as opposed to using the A21 to Hastings They do go to Heathfield. Then they would stick to the route they know and not Flimwell. This traffic also comes back as well and for a lorry to turn left at the traffic lights with ease to a relief road would not be easy as there is not the room. There is a tight turn round the roundabout. The new road is not as wide as Highgate and for the cost will be substandard and not man or woman to stand up to the constant traffic. Because there is such a problem with traffic and numbers the developer has homed in on this and is an excuse to build houses which TWBC has jumped at as a large amount for the housing allocation. This road is not needed and would break the village up with the Cranbrook Road closed and it has been stated by emergency services that this is not right and cause many problems with care to people and fires etc . With 1500 extra cars with the new houses and you have to look at a family having say two to four children that drive as well as parents that would be required to get people to work etc as there is not any work in Hawkhurst. This would be a disaster and I cannot understand the thinking behind this or even including this as an option. I think that TWBC should look at this sensibly and not allocating houses. There is also the question of why they wanted more of an allocation of housing when they could have had less?

STR/4 I agree with this as we have light industry here and employers. Here it is agreed that the area must retained as it is.

STR/5 I agree with this

STR/6 There is not the capacity for more traffic at Flimwell. Therefore the amount of building should be as such as is stated in the made NDP. I do not agree with a contribution to Flimwell there would be better use of the money in helping Hawkhurst and the community centre and other things required in Hawkhurst.

STR/7 I feel that with the large scale of development that is proposed will make this difficult.

STR/8 I am extremely worried that a serious mistake has been made by TWBC. Hawkhurst is completely in the AONB. I wrote to Mr Johnston and received a letter from the Ministry of Housing etc regarding the lack of respect of our made NDP and other points. You are going against all guidelines with these large proposals for Hawkhurst. You have no respect for our made NDP and you have no respect for the AONB which is the last place for developement and sympathetic even then, not 400 plus houses. You should not be considering such a large scale development for Hawkhurst with no infrastructur . You are riding roughshod over Hawkhurst which is a village and a part of AONB. The made NDP should be looked as a part of your plan. Thats what it is there for.

STR/9 That is correct. More is needed for the population as it is, let alone having anymore planning applications passed. You should be seriously looking at parking as it is at bursting point on all side roads.

STR/10 This is a good idea in principle but not what is needed for the majority of residents who would prefer a smaller ride. With Bedgbeury just up the road people take their cars and start from Park Lane for their cycle ride.

STR11This is absolutely necessary for everyone in Hawkhurst. You are though prepared to sacrifice the golf club and the nine hole course which could be sold as they are much required and then retained as a golf club. Plus you have the squash club.

STR/12 That is appropriate.

STR/13 I think you are well out of date the shops at the Moor went years ago.

STR/A This seems a bit vague. No input at all. I am concerned that on the proposed layout on HA4 that the layout seems all wrong.

STR/B Health and medical facilities who seem to favour this site and I wonder if they have other sites to consider for the Medical Centre if this does not go through? You have the proposed new school away from the present one. It would seem sensible to still use what is a relatively new building joined to a new one if so required and if not built on the ground immediately could surely be used for activities. The layout is all wrong.

STR/C Not too sure what this is suggesting and seems a vague statement.

STR/E This is a good idea but there is no good suggesting the golf course as a possibility if it went through as it is too far and too steep for people to access Hawkhurst. People will need a car to get in from there to Hawkhurst.

STR/F I really cannot understand your thinking and what a waste of money. The Forest of Dean it is fine in and other large forests or Agincourt or any other large ride like the Cuckoo Trail where lots of people go! This is Hawkhurst a village. No one is going to want that when money could be spent where everyone could see it in the centre. People seem to forget it is not all bikes and mobile phones.

STR/G As before too far away and too long for families.

STR/H This is important and in design at the moment .If you want art works then place them here for everyone to see.

STR/i I think this would not be worth doing. People will only travel on buses if necessary. People have cars because of the distances to work. There is the distance to rail stations at Staplehurst or Etchingham or Wadhurst the latter and first one have approximately two trains an hour. The feasibility study would be useless and a waste of money. The buses never go to the right place at the right time and it would be more buses going with no passengers.

STR/j This is fine but HGV roads are becoming a problem. The parish wants them rerouted away from Hawkhurst and surrounding villages.

STR/k Allotments and other open spaces and childrens playgrounds are essential. This further lends evidence that the golf club is retained for pleasure and in an AONB area/

STR/l Agree

DLP_2655

Benenden Parish Council

Policy STR/HA 1 - Benenden Parish Council are concerned about the proposed level of residential development at Hawkhurst Parish with regard to the impact it will have on our local roads. Further development in this area will encourage further use of roads through Iden Green and Benenden.

DLP_2942

Mrs Helena Waters

Please note my concerns on the draft Local Plan in terms of the impact upon Hawkhurst:

Lack of Appropriate Infrastructure

The “relief road” associated with the Golf Club site does not relieve traffic at the already congested Hawkhurst crossroads. As part of an additional 400 housing development it will add to the current traffic congestion and poor air quality.

The draft Local Plan does not consider the interaction between proposals in other neighbouring areas. For example, the wider impact on Hawkhurst and its infrastructure, from the development in areas such as Hartley an additional 300 houses, Cranbrook 600 houses and Rother District 6,180 houses.

As commented on in the House of Commons, by Greg Clark MP, development must be accompanied by infrastructure, such as sewage removal. There is no consideration of the lack of current capacity in the sewage system and no plan for the additional development proposed in the draft Local Plan.

Lack of Recognition of Neighbourhood Development plans

There is no real acknowledgement of the made TWBC Neighbourhood Development Plan for Hawkhurst (NDP) in the draft Local Plan. There also appears to be no recognition that the NDP for Hawkhurst was updated in March 2019.

The proposed development in Hawkurst is completely at odds with the aims and objectives of the NDP. Hawkhurst is a village in the AONB and is not an urban area ripe for development.

Failure to follow National Planning Policy Framework (2019) - Paragraph 11bi and ii

Due to the significant area of the AONB within the borough there should be a review of the Standard Housing Formula housing figures for the borough. Infact, instead of challenging these housing figures TWBC decided to increase it by 900 houses borough-wide.

The number of houses is disproportionately hitting Hawkhurst as there has been enthusiatic response from landowners in the call for sites. Whereas, there has been a failure to consider NPPF paragraph 172 to maximise the call for sites opportunities within Tunbridge Wells and Southborough prior to allocating housing / development within the AONB.

Unsustainable Development

The scale of the proposed development in Hawkhurst, without appropriate infrastructure, does not respond to the declared Climate Emergency. This draft Local Plan is proposing houses where there are no suitable jobs or facilities. More cars driving to work, school and shops.

Poor Consultation Process

Finally, I have found this consultation method, cumbersome and a barrier to widespread contribution.

DLP_2951

Mr D F Mansell

I fully concur with the concerns raised by Hawkhurst Parish Council, as stated below:

Failure to follow National Planning Policy Framework (2019)

The failure to consider the NPPF paragraph 11bi and ii to review the Standard Housing Formula housing figures for the borough as a whole, due to the significant area of the AONB within the borough. Thus the failure to reduce the housing / development within the borough as a whole.

Indeed, TWBC decided to increase it by 900 houses borough wide

The failure to consider NPPF paragraph 172 to maximise the call for sites opportunities within Tunbridge Wells and Southborough prior to allocating housing / development within the AONB

Failure to consult

The limited consultation - in Hawkhurst only one weekday session between 4- 7pm when many residents could not attend to offer their views

The limited access to the online consultation – not on TWBC home page and hidden “four clicks” away buried in planning section of website

A complex consultation form to complete that many residents have found baffling

Inappropriate Distribution of Development Policy

The failure to consider the results of previous consultation where only 8% supported the “Distribution Development policy” proposed by the draft local plan

The entirety of Hawkhurst parish is within the AONB. This means that all sites in Hawkhurst are within the AONB. STR /HA1includes a worrying mistake from the TWBC LP team who consider that some sites may not be in the AONB and reveals a deeper problem with the way TWBC consider the parish as suitable for large scale development.

The fundamental mistake to include Hawkhurst as an urban area in the TWBC draft Local Plan – thus implementing urban strategic planning policies to a village in the AONB

The parish council also has serious concerns about the scale, pace and location of new development being proposed for Hawkhurst, most of which is at odds with the aims, objectives and planning policies of the made TWBC Neighbourhood Development Plan for Hawkhurst.

Failure to proactively engage the Neighbourhood Development plans

The lack of conformity with, and recognition afforded by the TWBC draft Local Plan for the made TWBC Neighbourhood Development Plan for Hawkhurst (NDP)

The lack of recognition of the updated NDP for Hawkhurst March 2019

The lack of any coordinated support through the TWBC draft Local Plan for the neighbourhood planning process as a means of delivering the aims and aspirations of the TWBC draft Local Plan on the ground.

Failure to develop appropriate infrastructure

The proposed “relief road” is a substandard additional road to facility housing development with the AONB. It will not relieve anything. It will add to traffic, add to congestion and add to air quality problems.

The TWBC draft Local Plan has not considered the wider impact on Hawkhurst of development in neighbouring areas such as Hartley an additional 300 houses, Cranbrook 600 houses and Rother District 6,180 houses.

Complete failure to consider the lack of current capacity in the sewage system let alone plan for the development proposed in the TWBC draft Local Plan.

DLP_2970

Richard & Judy Piper

We are writing to comment on the draft local plan for Hawkhurst.

We are concerned that Twbc consider the village as a town which it is not.

The infrastructure is not sufficient to sustain large development ,the drains cannot take further effluent without much enlargement ,the school would need extending and there would need to be greater medical facilities .

Hawkhurst cannot cope with any further traffic.The proposals in the draft plan will make matters worse in the village centre,development needs to be severely restricted until a full bypass is built.

The whole village is within an AONB and this must be fully respected and considered.Historically Hawkhurst is made up of 3 separate parts the moor,Highgate and gills green with fields in between ,and these must be retained to keep the character of the village intact.

Finally we are concerned that there is little employment to support the proposed new housing,the new occupants having to drive to their jobs increasing congestion and traffic pollution .

We are happy for this letter to be kept on your website to comply with the current privacy regulations .

DLP_3000

Lightfoot Alpacas

Object

When are you going to listen to the people who live in the village. It is an area of ANB which will be completely ruined for the sake of a few people who are greedily selling their land to make millions but they don’t live in the village won’t have to put up with the mess that will be left. The Hawkhurst Neighbourhood Development Plan is not even being considered.

Once the green land is gone it is gone forever, it will never be able to be reclaimed we will be left with houses that no one wants to live in as there is not enough public transport, Surgeries, schools, jobs we will be living with a broken sewerage system, there isn’t enough water with no new reservoirs, fire services and police can’t cope now. We will have a relief road going nowhere. The thought of the state of the village is a very depressing one.

Please see above comments. I could sit down and comment on everything that is in this Draft Local Plan but it is very clear that no notice at all is taken of what the residents think and we are all wasting our time.

DLP_3224

Noel Craythorne

I would like to point out my objection to the proposed plan for the development of hawkhurst . The village is already overt developed with to many cars no parking .the school is to small and the doctors over subscribed

DLP_3313

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

The Local Highway Authority objects to this policy.

It is not yet evident that the changes to the main junction proposed through the Golf Club application will be acceptable (i.e. achieve nil detriment or decrease the level of traffic/congestion/journey time through the junction thereby not causing a severe impact) for the number of dwellings proposed on the Golf Club site - not including further allocations affecting the junction. There is a presumption that the road diversion will relieve the junction significantly in order to allow more development in the village. This is not the case at the time of writing. Until the Golf Club application is assessed (currently awaiting more information,) the cumulative impact of all allocations at Hawkhurst would be likely to cause a severe impact on the junction with no mitigation proposed. KCC as Local Highway Authority therefore objects to the allocation of these sites and any subsequent planning applications.

It is recommended that the Borough COuncil undertake:

a) an assessment of the cumulative impact of all proposed allocations - excluding the Golf Club - on the junction as it is currently, and

b) assessment of the cumulative impact of all proposed applications - including the Golf Club - with the proposed A229 diversion across the Golf Club site in place.

This will assist Tunbridge Wells Borough Council and KCC Highways in understanding the impact of development in this area.

Public Rights of Way and Access Service

The specific reference to PRoW in paragraph 10, including contributions towards the proposed Bedgebury to Sissinghurst cycle route, is supported.

DLP_3449

High Weald AONB Unit

Object

DLP_3451

Sally Marsh

Object

Policy Number: STR/HA 1 Hawkhurst

DLP_3844

Liane & Alan Chambers

Object

Policy Number: STR1/HA1

The proposed housing numbers for Hawkhurst are unsustainable and the relief road is not an appropriate solution to the already significant transport issues in the village.

As set out in comments on policies STR1 and STR6, this development would have a detrimental impact on the AoNB. As well as landscape impacts, there would be additional negative impacts on air quality, noise, biodiversity and climate change.

The proposals are contrary to the Hawkhurst Neighbourhood Plan. The community have agreed a plan which clearly states policies promoting small infill, brownfield development (Policy HD1a). Policy HD1b states that larger developments (defined as 10 or more) should only proceed if they effectively mitigate their impacts on the environment. Given the very large nature of many of the proposed developments for Hawkhurst, it cannot be concluded that the negative effects on the village and its AoNB setting are fully or effectively mitigated.

The proposal includes reference to a new relief road for the village. The proposal would increase traffic congestion in the High Street area, as all traffic wishing to travel north of the crossroads (down Cranbrook Road) would be re-routed down the High Street. The High Street is already very congested at peak times, with long tailbacks and this would get worse. An additional 700 houses (417 houses at the Golf Course in particular) could add another 1500 cars to the locality, causing adverse cumulative impacts.

DLP_4126

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE considers that the number of dwellings allocated to Hawkhurst is too high, particularly in view of the number of dwellings in excess of those previously allocated that have recently been given planning permission there. This Strategy proposes major development in the AONB without proper justification.

AONB

Paragraph 172 of the NPPF:

“Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited”.

Planning Practice Guidance, July 2019, states:

“The National Planning Policy Framework makes clear that the scale and extent of development in these areas should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas. [CPRE Kent emphasis]

AONBs together with National Parks have the highest status of protection in relation to landscape and scenic beauty. For National Parks “the Government recognises that the Parks are not suitable locations for unrestricted housing and does not therefore provide general housing targets for them. The expectation is that new housing will be focused on meeting affordable housing requirements, supporting local employment opportunities and key services”. This principle equally applies to AONBs through paragraph 11(b)(ii) of the NPPF to ensure that the scale and extent of development proposed does not harm the purposes for which these areas were nationally designated.

Employment areas

Please see our response to Policy ED1.

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

Proposed relief road through golf course

It appears to CPRE that the Council’s strategy in allocating such a large number of dwellings to Hawkhurst may have been unduly influenced by the offer of a new “relief road” through the golf course which accompanies the proposal for 400-450 dwellings on the golf course (AL/HA1).

In 2017 research commissioned by CPRE showed that building new roads tends to induce traffic, rather than relieve it, see https://www.cpre.org.uk/resources/transport/roads/item/4542-the-impact-of-road-projects-in-england and https://www.cpre.org.uk/resources/transport/roads/item/4543-the-end-of-the-road-challenging-the-road-building-consensus . The relief road proposed as part of this strategy might perhaps have a marginal effect on traffic congestion in the centre of Hawkhurst, but the additional 700 or so homes proposed under this Strategy together with those recently approved will mean at least twelve hundred owned vehicles and several thousand additional vehicle movements per day, which will more than outweigh the effect of the relief road, leaving the village in a worse situation than the unsustainable one today. This cannot justify the number of houses proposed to be allocated to this village in the AONB.

DLP_4227

East Sussex County Council

Thank you for the opportunity to comment on the Tunbridge Wells Borough Draft Local Plan. The following are officer comments from East Sussex County Council.

Policy STR/HA1 – The Strategy for Hawkhurst Parish

We support the inclusion in the Policy (requirement 6) for development proposals to establish their impact upon the Flimwell crossroads (junction of A21 and A268) and if necessary to provide contributions towards works at this junction to mitigate the impact.

However, we believe that the Policy wording should be extended to include the A21 junctions at Hurst Green specifically the junction of the A21 and A229 and the junction of the A21 and A265. These junctions form part of a key east/west route, therefore traffic generated from development proposals within the area are likely to have an impact on these junctions and an exercise needs to be undertaken to determine the impact and whether any mitigation is required.

It will be necessary for Tunbridge Wells Borough Council to agree a methodology with Highways England, as well as East Sussex County Council, for undertaking localised junction modelling of the Flimwell crossroads and the two A21 junctions in Hurst Green, as part of the transport assessment work which will support the Local Plan at Regulation 19 publication.

We welcome the acknowledgement in requirement 6 that any mitigation measures may need to be funded by development contributions. However, for further clarity and to ensure the implementation of necessary mitigation measures it would be helpful if this requirement was covered either generally under the contributions section of the policy, maybe (d) which refers to improvements to highway and transportation infrastructure, or within each of the individual site criteria set out in Policies AL/HA 1 to AL/HA 10.

DLP_4235

Rother District Council

Policy STR/HA 1 (requirement 1)

General comment

The increase in the number of new dwellings compared to the previous Regulation 18 consultation is noted. However, provided any necessary improvements to the Flimwell crossroads are secured, as detailed below, no objection is raised over this matter.

Policy STR/HA 1 (requirement 6)

Support

Reference within the policy strategy for Hawkhurst Parish to establish the impact of the proposed developments on the Flimwell crossroads, and if necessary provide contributions towards works to this junction to mitigate that impact, is welcomed.

DLP_4371

British Horse Society

Support with conditions

The BHs is concerned about the serious effect that the increase in vehicular traffic on the rural lanes around Hawkhurst is already having on equestrians’ ability to access the bridleways in the parish, including those in Bedgebury Forest. This effect will be magnified by the further housing that is proposed. Therefore this policy should include a commitment to improve public bridleway provision and particularly to provide safe links between existing bridleways in the parish with those in Bedgebury Forest. If necessary the Council should be prepared to use its compulsory powers under Section 26 of the Highways Act 1980.

DLP_4530

Mr Alec Travers

I have to say that I find the Comments Page on the Draft Local Plan website intricate and confusing to use, so following my recent conversation with Chris of your staff, I am enclosing my comments in an email, suitably entitled to enable you to slot it in to your Comments section.

I refer to the Draft Local Plan recently issued by the Tunbridge Wells Borough Council relating to Hawkhurst and wish to comment on the impact on infrastructure by the road and housing proposals included as follows:

The current sewage treatment plants for foul water are already inadequate and incapable of handling the sewage arising from the present levels of housing let alone the housing recently added. This has been the situation for some considerable time, stretching back into the last century. Therefore to foist an additional 718 households on to an under-resourced system with its negative environmental consequences makes no sense whatsoever.
The Kent Fire Brigade has already expressed serious concern over the redesign of the road layout in the centre of Hawkhurst denying them rapid access to residents on the Moor side of the village and this would need to be addressed before any housing is put in place.
It is proposed that the existing primary school be extended: it currently has spaces for 210 pupils. As it is estimated that the proposed housing is increasing the population of Hawkhurst by approximately 40%, the increase in pupil places should logically be increased by a similar percentage, i.e. 84 pupils. This would of course necessitate additional parking for parents and visitors. It is significant that the senior staff at the primary school have heard nothing about this and I wonder whether the relevant Education Authorities have committed themselves to this expansion.
It is proposed that the existing primary school playing-fields are to be built over to provide this extra accommodation and additional housing and that replacement playing-fields are to be built beyond Fowlers Park. These are some distance from the School (thus putting children at risk from traveling a distance on foot in what could be sudden inclement weather) and access will be across what will be the proposed service road for the planned 100 houses and the Medical Centre adjacent to the school, thus putting the children at risk from traffic.
There has been no indication of any new electrical sub-stations or water pumping stations for services supply to the new estates. Given the substantial increase in housing the investment in providing these services will need to be significant, has any firm commitment been made by the relevant service providers concerned? The disruption to the rest of the village by any such provisions, such as digging up roads and trenching, is likely to be considerable and prolonged.
The negative environmental impact arsing from the increase in residential traffic, conservatively estimated at 1,000 extra vehicles is likely to be substantial, not only commuting to work, but for shopping and taking children to school. The current bus services for pupils travelling to secondary schools located at Cranbrook are barely adequate and there is no guarantee that these services will continue to operate. Has any firm commitment been obtained from the relevant companies involved?

I therefore wish to object to the proposed additional housing due to the negative impact on the infrastructure as indicated above.

DLP_4555

Historic England

Policy STR/HA 1: The Strategy for Hawkhurst 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_4688

CBRE Ltd for Dandara Ltd

Policy STR/HA1: ‘The Strategy for Hawkhurst Parish’ - Dandara notes the following:

4.134 Dandara supports growth at Hawkhurst as a sustainable location in the settlement hierarchy and allocation AL/HA6. This section specifically addresses Dandara’s comments in relation to Policy STR/HA1.

4.135 Paragraph 3 of Policy STR/HA1 states that for developments expected to be delivered before the Hawkhurst relief road is fully operational, the applicant will be required to demonstrate with clear evidence that there is sufficient capacity at the Hawkhurst crossroads (junction of A229 and A268) to serve the proposed development.

4.136 In reference to planning application LPA ref. 18/1063/FULL, it is noted that the application was refused for access reasons despite KCC Highways Authority confirming that the impact on the highway was acceptable. Dandara suggests further clarity is required in assessing the highway impact of development.

4.137 The timescales for the implementation of the relief road need to be clarified in order to ensure that the strategy for the Parish and relevant allocations are positively prepared, justified and effective under NPPF paragraph 35.

4.138 Dandara emphasises the importance of supporting transport infrastructure as a catalyst for new development. New transport infrastructure should be delivered to strict and realistic timescales in order to facilitate, not prevent, development.

[TWBC: full representation is attached to Comment Number DLP_4614].

DLP_4988
DLP_5110
DLP_5128
DLP_7303
DLP_7459
DLP_7590
DLP_7647
DLP_7865
DLP_8094
DLP_8239
DLP_8318

Kristina Edwards
Mr Peter Brudenall
Alistair Nichols
Kylie Brudenall
Catherine Pearse
Victoria Dare
Keith Peirce
Andrew Hues
Mary Curry
Jan Pike
Pam Wileman

TWBC: the following standard response was submitted by the list of responders on the left. See also their corresponding comments on Policy STR 1 The Development Strategy (Section 4)

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

There are very limited local employment opportunities and no secondary schools within walking distance.

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

TWBC: the following responders submitted the above standard response, with the following additional comments:

DLP_7647

Keith Peirce

Standard comment as above, plus the following additional comment:

I would further add that on 24/1019 Mr James Finch Assistant Director - Corporate Services Kent Fire & Rescue Service wrote on the TWBC planning portal regarding his serious concerns for his organisations ability to provide fire and rescue services to the area around Hawkhurst should the Golf Course proposal be granted. When are TWBC planners going to realise what is glaringly obvious to all but themselves that Hawkhurst cannot entertain the numbers of houses being put forward in this ill thought out Draft Local Plan.

DLP_8094

Mary Curry

Standard comment as above, plus the following additional comment:

OS Plot 3100 Fieldways Hawkhurst Application no. 18/01063. This proposed development would make for a very dangerous junction between Highgate Hill and Copthall Avenue. The entrance of Copthall Avenue is not wide enough to allow a car to enter whilst one is waiting to exit onto Highgate Hill. In the last 4 years there have been 3 accidents at this junction. 2 of them ending up with broken fences and cars in my garden. I feel that by proposing to build on this site you are not fully aware of just how dangerous the extra amount of traffic would be. Many residents do not have anywhere other than Copthall Avenue to park therefore limiting the width of the road even further. The building site is in an area of natural beauty and would also make more demands on the existing sewerage system which is struggling to cope with the existing amount. Many of the following comments in respect of the Golf Course also apply to this proposed build.

DLP_8239

Jan Pike

Lack of adequate infrastructure

DLP_8318

Pam Wileman

End of additional comments submitted with standard response

DLP_5712

Frances Travers

Hawkhurst has turned many fields I not new housing complexes and the burden of traffic queues in this AONB is detrimental to the environment I realise people need houses but I think hawkhurst has taken on its fair share and any more will be intolerable

DLP_5745

Linda Barnes

I should like to make the following observations (and apologies for the email but the consultation form was just too complicated and time-consuming to complete):

The entirety of Hawkhurst is in the AONB, therefore all potential sites are in the AONB - this is a fact and cannot be ignored.

Hawkhurst is a village, not an urban area, and cannot be treated as such.

The Neighbourhood Development Plan for Hawkhurst which was accepted by TWBC appears to have been virtually ignored in the TWBC Draft Local Plan.

The sub-standard infrastructure in Hawkhurst is a major factor which seems to have been ignored in this draft Local Plan, i.e. the so-called 'relief road' proposed as part of the Golf Club redevelopment is quite clearly not a 'relief road' - other than the top of Cranbrook Road, no traffic will be 'relieved' by this proposed road. All that will happen is that the traffic will move from one road to another road, and it is disingenuous to state that improvements can be made at the Flimwell Crossroads so that more lorries can be diverted along the A268 towards the A21 - Flimwell is in East Sussex, therefore TWBC has no influence on the crossroads or Rother DC.

No weight seems to have been given to the problems with the sewage system in Hawkhurst which is clearly not capable of dealing with the current capacity, let alone any additional houses.

There is little point in building more houses in an area where the proposed new residents will be unable to find local jobs - thus they will have to travel, either by car or by car to the nearest station since it is also disingenuous to suggest that anyone who needs to be at work at a specific time will catch a bus. And which secondary school will the proposed new residents' children be attending? And how will they get there?

Have the demographic changes in the UK been taken sufficiently into account? We have an ageing population who live in a third of all homes and those homes are often large family homes which no longer meet the requirements of their elderly residents. Hawkhurst's housing stock consists of a large number of larger homes, as indeed probably does the TWBC area as a whole. 'The number of people aged over 65 is forecast to rise over the next decade, from the current 11.7 million people to 14.3 million by 2025, a 22 per cent rise' https://www.local.gov.uk/sites/default/files/documents/5.17%20-%20Housing%20our%20ageing%20population_07_0.pdf (p.6) Has the need for suitable retirement housing or affordable housing been sufficiently taken into account in the TWBC Draft Local Plan. Will we actually need all these 3 or 4 bedroom houses in the future?

DLP_5752

Mr Alec Travers

I have to say that I find the Comments Page on the Draft Local Plan website intricate and confusing to follow, so, following my recent conversation with Chris of your staff, I am enclosing my comments in an email, suitably entitled to enable you to slot it into the relevant pages in your comments section.

I refer to the Draft Local Plan recently issued by the Tunbridge Wells Borough Council relating to Hawkhurst and wish to comment on both the Relief Road and the impact that this and other proposals will have on the traffic situation and the community as a whole, as follows:

The Relief Road is intended to divert traffic away from the centre of Hawkhurst and to act in effect as a mini-bypass. Any possibility of this being achieved is negated by the 400 plus households that are planned as part of this scheme, the bulk of whose traffic will be exiting/entering on to this road.
The Relief Road is approximately 7 metres wide which will be sufficient for two large lorries to pass each other on the two carriageways, but no more than that so that any breakdown or other vehicle stoppage will cause an immediate tail-back. Examples of this can be seen already on the Rye Road outside the Colonnade and at the two bus-stops on the High Street.
I presume there will be bus routes in both directions diverted on to this Relief Road with relevant bus-stops, but I see no evidence of any lay-bys for the bus-stops. If it is the intention that these buses are to collect and drop passengers directly on the Relief Road, there will be further delays and congestion resulting.
There is no indication of any pedestrian crossings, bearing in mind that those wishing to use the buses may well need to cross the Relief Road to access the stops. I note that the pedestrian crossing close to the junction with the Cranbrook Road is marked as “uncontrolled”. I consider this to be highly dangerous, the crossing on the Rye Road is controlled as are those at the traffic-lights, anything else on the Relief Road is threatening serious harm to pedestrians. It should be borne in mind that there are new recreation areas planned and controlled pedestrian crossings will be needed to access these. See also later Point 14.
I note that access to the Relief Road from the Cranbrook Road junction is by means of a “T” junction which I consider to be hazardous given the volume of traffic likely to be using the Relief Road.
The intention is to close off the Cranbrook Road junction at the traffic-lights: I presume the plan will be to have each of the three remaining arms separately controlled by traffic-lights which means that the delay times will be exactly the same as at present. I do not see any proposal as to how the Highgate Hill junction at the traffic-lights is to be rebuilt. Any sizeable vehicle turning this corner from Highgate Hill towards the High Street will need to have sufficient space to turn without obstructing or being obstructed by traffic waiting at the High Street lights.
The existing bus-stops on the High Street close to the traffic-lights already cause considerable tail-backs as the buses will often wait there (to adjust their route running times?), the potential delays and congestion on the High Street due to this will create major delays on all three arms of the traffic.
The Colonnade parking is not adjusted so that the delays caused by the conflict between parked vehicles and moving traffic will remain unamended.
Much is made of a large car-park in the Golf Club scheme, the idea being apparently that residents from the new housing estates (and others) will park their cars there and walk into the village. I consider this to be naive, any elderly resident or parent with young children is going to drive to the supermarkets rather than walk, particularly in the circumstances of inclement weather.
Nothing can be done regarding the implementation of the Relief Road until the Flimwell junction is rebuilt, and I have serious doubts about the practicality of the design as shown, I do not think any proper estimate has been made of the volume and type of traffic in the proposed junction design.
At present during the rush-hour the tail-back from the Flimwell junction towards Hawkhurst frequently extends back several hundred yards, and there is the potential for extensive delays due to the considerable amount of extra traffic generated by the Relief Road scheme.
The junction between the Relief Road and the High Street is apparently to be by means of a mini roundabout (aka a “Drive over” roundabout). I think that the volume of traffic that will be passing through this junction makes this a highly dangerous and impractical proposal and I do not believe this has been thought through in any depth.
The effect of the above on the existing traffic-light junction at Highgate will be such as to impact severely traffic wishing to pass through Hawkhurst towards the main-line stations at Etchingham and Staplehurst and towards Maidstone and the A21. The result will be to divert through traffic via the back-lanes of Stream Lane, Conghurst Lane, Foxhole Lane, White’s Lane, Water Lane and Delmonden Lane. There has already been a significant uplift in traffic volumes in recent months due to the existing traffic problems and this situation will only be worsened by the proposed Relief Road and the other above amendments. These lanes are struggling to meet the current increased traffic volume and are totally inadequate to handle the extra numbers of vehicles that will pass through them in order to avoid the additional congestion resulting from the proposed scheme.
Ref item 4 above, I have noted that the original scheme proposed by Messrs Cedardrive’s planners for the Golf Course Relief Road showed four pedestrian crossings across the Relief Road. As each of these must be controlled, see my earlier comments, then the potential for further traffic delays is much increased.
I would also point out that the current tendency towards lower speed restrictions such as 20 m.p.h. on residential roads may well be called for here, as I cannot imagine that house-holders in a residential area of 300 plus houses would be happy with a 30 m.p.h. major vehicle route passing through the centre of the estate areas. In this case the potential for delays will be even more thus reducing further the claimed effectiveness of the Relief Road in easing traffic congestion.

I therefore wish to object to this proposed Relief Road and other proposed traffic measures for the above reasons.

DLP_5759

Jenny Bigio

A cursory reading of the draft Local Plan indicates that TWBC are riding rough-shod over the (valid) wishes of local communities.

It is incomprehensible that TWBC would select Hawkhurst as the Wealden village that could absorb almost as many new houses as the much larger town of Tunbridge Wells. Why?

1) The entire village lies within an Area of Outstanding Natural Beauty

2) The impact of unchecked development – particularly the Hawkhurst Golf Club - will have an adverse effect on the natural environment.

3) The infrastructure is straining to breaking point; this includes sewage that could potentially be a health hazard

4) There is inadequate public transport, so new builds will mean more cars in a village already blighted by congestion. (Note that the dangled carrot of a 'relief' road being offered by the developers will provide no relief to the congestion).

5) Developers are building new homes at price points that puts them out of reach of the very people who seek new homes, a fact illustrated by stagnant sales of existing developments.

Why is TWBC ignoring the views of Hawkhurst Parish Council? Why is TWBC ignoring the intelligent Neighbourhood Plan, which was created with local insight and significant investment in time?

In summary, I am troubled by and strongly object to TWBC's Draft Local Plan.

DLP_5860

Mr Alec Travers

Further to my earlier email on this topic dated 13^th November, I wish to make further points with regard to items 10 & 11 therein relating to the Flimwell cross-road alterations [TWBC: See comment DLP_5752].

This work is all predicated on the assumption that these cross-roads will be altered in accordance with your design, yet I see nowhere in your document any confirmation that these alterations would be approved or even considered. As these works would be handled by another county and another road agency, I consider that this presumption is to say the least premature. What would happen if East Sussex County Council, the Highways Agency or other authorities involved refuse to meet either your anticipated programme or your design?

As this is fundamental to your “Relief Road” this would mean that this could not go ahead as the Flimwell cross-roads will not handle large vehicles in their present design.

DLP_5903

Ms Pamela Fletcher

I am a resident of Hawkhurst and wish to make theses comments.

The proposals that have been made in the draft document bear little resemblance to the manner in which the decision makers have behaved so far with regards to housing developments in the village. Those of us who have read the draft plan do not recognise that this newspeak is emanating from the same bureaucrats who have orchestrated uncontrolled housing development in Hawkhurst without due action on infrastructure development and who now appear to have morphed into environmentally sustainable stewards of the AONB and lofty master planners who are going to work with communities to solve the so called housing crisis and increase employment (low

paid hospitality and retail jobs that won’t cover mortgages or rents on the houses that developers are willing to build) for new residents. In actual fact these same bureaucrats are planning to continue their plans to annihilate forever the living environment of the very people whom they represent and who pay their salaries through taxation. Apparently infrastructure development will be in the hands of developers whom we all know drive a hard bargain about what they are willing to fund. So ultimately infrastructure plans get watered down to much less than what the community actually requires.

So frankly, based on your record of conduct in our village and nearby villages, we in Hawkhurst can refute all your proposals for lofty master planning based on your previous and ongoing record in our village. In particular I strongly object to the Hawkhurst Golf course development. It is too big and like all the recent new developments it contravenes the Hawkhurst NDP and will destroy the AONB - trees (the ‘lungs that reduce air pollution around us) and our precious and threatened wildlife numbers. TWBC continues to ignore our wishes as stated in our NDP. We actively chose to live here and raise our families because of the AONB. The council has continuously contravened our democratic right to determine the type of environment we wish to live in.

Throughout the explosion of housing growth in Hawkhurst in the last 4- 5 years TWBC have made no attempt to improve our infrastructure. We have an infrastructure that is only fit for a small village and not a rural town which it appears to be heading to if the draft plan is accepted. Hawkhurst roads are clogged up during the rush hour and holidays. There is insufficient parking in proximity to the shops and small supermarkets. The doctors’ surgeries are oversubscribed. Very few people are willing to walk and no one cycles. The footways are narrow and the air quality near them is poor due to queuing cars with idling engines. The gradients and lack of cycle lanes on the A268 and A229 the intersect our village negate any attempt at cycling. The village needs a bypass - through traffic increases year on year and coupled with more and more residents with two cars or more per household we are headed for gridlock and even poorer air quality. There is enough evidence now showing that poor air quality affects the health of everyone from the unborn to the elderly. Poor childhood brain development and heart and lung disease to name but a few.
‘Bribing’ the populace with a so called ‘relief’ road that will tear up a beautiful area full of mature trees and home to a wide variety of flora and fauna (the golf course) does not stand up to scrutiny. The proposed relief road will only serve to create another bottle neck where it joins the A268 on the High Street. That’s two bottlenecks in the village and possibly another one at Flimwell traffic lights. Based on the record of a lack of action on our infrastructure so far I can’t see the proposed alterations to Flimwell being carried out anytime soon. This means more misery for Hawkhurst residents and anyone using the A268. Creating additional traffic bottlenecks cannot be balanced out by promises of a new doctors’ surgery and community hall on the golf course site. There are plans for both elsewhere in the village.
Another failing in terms of infrastructure development in tandem with has been the sewage treatment facility. It has shown that it’s unable to cope with the increased households as a result of uncontrolled housing growth in Hawkhurst - there have been overflows into a water course and a lane. More misery for the residents of the village.

There is little employment potential in Hawkhurst other than retail. New residents in the proposed housing development will have to travel elsewhere to earn a living. To do so they have to drive or commute by train. There is no railway station in this village. People have to travel to Staplehurst or Etchingham. Virtually all will opt to get there by car. More people in cars on already congested roads. More misery for residents.
As a resident of Hawkhurst I support all the objections made by our elected local representatives (ie the chairman Claire Escombe and members of our parish council) to the TWBC draft local plan. We are grateful to them forprioritising our quality of life and the health and well-being of the people of this village.

I give my consent to TWBC to store my personal contact details under GDPR rules.

DLP_5949

Mr Andrew Constable

We have looked at the draft local plan and attended the presentation at the Royal British legion in Hawkhurst. As residents of Hawkhurst for over 20 years we feel extremely concerned that the extent of proposed development in the village is completely disproportionate to the size of the village and its facilities and infrastructure.

The plan appears to show that a similar number of dwellings are proposed around Tunbridge Wells as there are in Hawkhurst – that fact alone speaks volumes for the inappropriateness of the development now proposed in the small village of Hawkhurst.

Hawkhurst Neighbourhood Plan

When considering development in Hawkhurst, it is important to remember that the residents of Hawkhurst have given their views on appropriate levels and types of development for our village. As a result, the Hawkhurst Neighbourhood Plan was formally adopted by TWBC in 2018. The Neighbourhood Plan acknowledges that development is necessary, but it must be of appropriate scale. This is confirmed in the Neighbourhood Plan Vision Statement as follows:

“ Hawkhurst has developed slowly over centuries, with gradual change blending its environment with the needs of the population. This plan aims to encourage change within manageable limits to retain and strengthen Hawkhurst's distinct history and character”

In February 2018 TWBC posed the following question to the people of Hawkhurst:

“Do you want Tunbridge Wells Borough Council to use the Neighbourhood Plan for Hawkhurst to help it decide planning applications in the neighbourhood area?”

The result of the referendum was that over 90% of voters confirmed that they did wish TWBC to use the Neighbourhood Plan to help it decide planning applications. This led to the plan being adopted by TWBC.

The Neighbourhood Plan requires that change must be “within manageable limits” and must “retain and strengthen Hawkhurst’s distinct history and character”. The development proposed in the draft local plan, particularly the development at the golf course, utterly fails on both counts.

When deciding on this Local Plan, please remember the Hawkhurst Neighbourhood Plan and the commitment to honour it, made by TWBC to the people of Hawkhurst.

Area of Outstanding Natural Beauty (AONB)

The whole of the Hawkhurst village is within the High Weald AONB and as such there is an over-riding presumption against development. The primary purpose of an AONB is to protect the land and conserve and enhance its natural beauty. The draft local plan seems to utterly disregard this. In particular, it seems to us that the proposal to turn this beautiful golf course into a housing estate is precisely the type of development that the AONB is intended to protect against.

Capacity of the crossroads

At the centre of the village is a small crossroads where two A roads cross, the A268 and A229. Some time ago KCC Highways department acknowledged that the crossroads at the centre of the village was completely over capacity and that no more development could be justified unless it could be improved (it can’t!). Since then many more planning consents have been granted so the situation has steadily got even worse. The centre of the village is commonly at gridlock, with the attendant pollution that comes from queuing traffic. This alone should rule out any further development in Hawkhurst.

Quota of Development

There is no evidence of a local need for development in Hawkhurst of the scale envisaged in the draft plan. The village has completely exceeded its housing quota set out in previous local plans. The draft plan seems to overlook the fact that Hawkhurst is a village and not an urban area.

Village Infrastructure

Hawkhurst is a small village and simply cannot support a development of the scale envisaged in the plan. Please consider:

Primary School – the school is close to full capacity. There is no secondary school.

Surgery – the doctors’ surgery cannot accommodate any more people living in the village. There is no NHS dentist.

Infrastructure – the drainage systems are not fit for purpose. Flooding occurs in various locations after heavy rain. The sewage treatment system cannot cope such that waste has to be taken away by lorry on a regular basis.

Amenities – there are few amenities in the village. If one of the proposals goes ahead it will mean the loss of the golf club and the squash club. A great many people use and enjoy these facilities.

Employment – there is very little local employment. The village has no bank.

Public Transport

Public transport services in Hawkhurst are very limited and the absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development the scale proposed in the draft plan.

There is no railway station and buses run infrequently and, in many cases, during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution

The A21

Similarly, development in Hawkhurst of the scale proposed would undoubtedly lead to more traffic on the A21, adding to the congestion problem that already exist. Users of this road will be familiar with the problem, which is particularly acute at the Flimwell crossroads traffic lights.

[TWBC: See related comments DLP_5946_5949-5952]

DLP_5958

Mr Chris Austen

One of the main issues against the DLP for Hawkhurst is that TWBC has forgotten that we are totally in the AONB and that we are a rural village not an urban town and this needs a very different approach.

We fully agree with the responses made by Hawkhurst Parish Council to the Local Plan (Reg. 18)

Consultation and would like to make the further following points.

Should the lynchpin of the Hawkhurst Plan which is Policy AL/HA 1 go ahead it will be totally against the majority of the residents. We hope that residents’ comments will be seriously considered after this consultation as previously these exercises have been seen to be pointless as no notice has been taken which adds to the feeling that our views are of no importance at all.

Looking at the many, many comments rejecting this site at the Planning stage where there was virtually no one in favour of the relief road including many organisations why is it still being considered? This is not democracy at work – no wonder that so many residents are mistrustful and disillusioned with the planning process. This site also goes firmly against our NDP which has not had any recognition when TWBC put together this Draft Local Plan despite it being a legal document.

The relief road, suggested as a benefit to the village will not result in there being any ‘relief’ at all and seems to now be accepted as such. We note that KCC Highways see no need for this road which we gather would be a substandard A road anyway (why?) It might possibly move SOME of the HGV traffic away from the village centre, but not the local traffic, and the extra traffic generated by the additional 700+ houses is likely to outweigh any benefits of the ‘relief road’. There would be serious noise and air pollution from the extra traffic and the resulting poor flow increasing not decreasing congestion. The AONB would be lost forever along with many beautiful trees, some of which are ancient.

We strongly feel that this Policy should be removed from the Local Plan and that there needs to be a total rethink. The Golf (and Squash)Club is an important part of village life and could be redeveloped to provide much needed leisure and health facilities as well as being a possible wedding venue and providing some conference rooms – it just needs some imagination to make it a thriving asset to the village instead of a money spinner for the landowner. This would then be a much more sustainable asset to the village and would be used by residents who would then have less need to travel to other leisure facilities.

We understand that the terrible problems with the sewage system on the north side of the village will have to be sorted out PROPERLY before any more development is allowed on this side of Hawkhurst so are grateful that after many years of highlighting this by a number of residents someone is finally listening! As this is likely to take some time to resolve considering putting another 700+ houses in the village would be disastrous therefore the non relief road and its’ attached development should be removed from the plan and TWBC should be supporting development of more sports facilities on this site to enhance the village rather than destroying it.

We do accept that there is a need for some more housing in Hawkhurst – however, this should not be in the form of expensive developments – there are still a number of houses for sale on current developments presumably because they are too expensive. We need the right sort of housing to help residents which is not what is on offer. An example of inappropriate housing is the new development (Aspect Wood )by the Flimwell Traffic lights which is very largely unsold due to the huge price tag on the houses. As per our NDP new developments should be small in scale so that the village can absorb them so that the character of the village is not destroyed.

We sincerely hope that TWBC looks again at Hawkhurst and makes changes to this unacceptable Local Plan.

DLP_6053

Laura Rowland

Policy Number: STR/HA 1 Hawkhurst

DLP_6186

Mr Andrew Hill

The Draft Local plan is a very detailed document which requires a lot of time to assimilate. Accordingly I shall restrict my comments and objections to the Hawkhurst Parish but many of the points raised are applicable in a general way to the whole plan.

The strategy for Hawkhurst Parish STR/HA1 states approximately 681-731 houses will be delivered on 7 sites. The statement WILL BE is hardly a phrase which sounds consultative – more like a statement of fact! I fully understand that TWBC has to allow more houses to be built but to inflict 700 houses on Hawkhurst is unrealistic. Para 3.11 of the DLP states clearly that the Hawkhurst crossroads suffer severe congestion at peak times. All proposals will aggravate the congestion short of a rerouting of heavy traffic. This severe congestion is recognised in the DLP but it seems TWBC thinks the proposed relief road will alleviate the congestion. It will not - it can only complicate the situation (see objections to hybrid planning application 19/02025).

The two main allocations, viz. Fowlers Park and the Golf Course, are deeply flawed proposals. Both these allocations are within the AONB. In the case of the land at Fowlers Park (Policy AL/HA4) there was a previous application for some of this area (Site 64) which went to appeal. The Inspector dismissed the appeal on the grounds of the development having a harmful visual effect on the AONB. On this basis it is therefore not clear how TWBC can argue that exceptional circumstances apply to override the Inspectors decision. TWBC should not need reminding that AONB has the highest status of protection for conserving and enhancing landscape and scenic beauty. 100 houses certainly won’t do that. Furthermore 100 houses will generate at least 150 vehicles to congest the crossroads and leave a heavy carbon footprint. Most of the residents will be seeking employment which, in the immediate area, can only be provided by Gills Green and the retail section of Hawkhurst, both of which (I suspect) are already fully staffed. Those seeking employment will have to drive further thus increasing the carbon footprint. There are no gains for trees, woodland and hedges as in Policy EN15, only losses, and the same applies to Policy EN11, no gains for nature diversity.

DLP_6325

Persimmon Homes South East

Hawkhurst

It is considered that too much growth has been directed towards Hawkhurst which is demonstrably less sustainable, and should have substantively less growth.

Hawkhurst is allocated approximately 668 additional dwellings over the plan period. This is significantly higher than the level of growth directed towards Cranbrook which is around 500 dwelling once existing commitment are discounted.

However as highlighted in the table above, the Council’s Settlement Role and Function Study demonstrates that Cranbrook has significantly more services and facilities, scoring 32% higher in the assessment.

It is demonstrably unsound to direct substantially more growth to a significantly less sustainable settlement, when both a located within the AONB and both as subject to the same level of landscape and environmental constraints.

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

DLP_6372

Hawkhurst Parish Council

Response to Policy STR/HA1: The Strategy for Hawkhurst Parish

> Response: The introduction to this overarching policy for the village makes no mention of the TWBC NDP for Hawkhurst, that is the statutory planning document for this area. The NDP was endorsed by the local community at referendum and runs until 2033 yet is not used as the starting point for such an important policy within the draft TWBC Local Plan. This is a major oversight and needs amending in subsequent drafts. We would argue that the essence of STR/HA1 should be drawn directly from the content of the TWBC NDP for Hawkhurst as this is a “live” planning document that has the support of the local community.

1. Approximately 681-731 new dwellings will be delivered on seven sites (*) allocated in this Local Plan in the plan period (Policies AL/HA 1-4, 6 and 9). (*) Of these sites, the following already has planning permission: AL/HA 5 for 25 dwellings.

> Response: We disagree with the scale (increase of 32%+), pace and location of the housing numbers, for the reasons given in this response.

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

> Response: There are a number of concerns regarding TWBC’s approach to windfall site as compared to other Planning Authorities, such as South Downs National Park.

Firstly, in line with other Planning Authorities such as South Downs National Park, windfall should be included in the housing allocation for the parish rather than additional housing.

Windfall developments, by their nature, are unpredictable and unplanned – the community wants planned predictability from the system and is not getting it. This could be achieved by setting a maximum amount of windfall development for each Parish.

3. For those developments expected to be delivered before the relief road (reference criterion 4 of Policy STR 1) is fully operational, the applicant will be required to demonstrate with clear evidence that there is sufficient capacity at the Hawkhurst crossroads (junction of A229 and A268) to serve the proposed development, as at this point in time the Highway Authority does not consider that there is sufficient additional capacity at this crossroads. If it is not possible for the proposal to demonstrate sufficient capacity, then the proposed development will not be implemented until after the relief road is fully operational. In these circumstances, contributions will be required towards the provision of the relief road.

> Response: The “relief road” (as described in section 3) of this policy raises serious concerns, as follows

the proposed “relief road” is a substandard additional road to facilitate housing development within the AONB. It will not relieve anything. It will add to traffic, add to congestion and add to air quality problems;
we understand from the developer the proposed substandard additional road is not to A road specifications;
where did the idea originate from? No statutory agency responsible for major road infrastructure has endorsed this concept as a sensible response to the need to create sustainable travel patterns;
no statutory agency has asked for such a large and expensive piece of infrastructure to be built in the heart of the village, that is covered by heritage, conservation designations within the AONB;
the proposed relief road is this not part of a regional infrastructure programme, supported by Kent CC, Highways England, Sustrans and other agencies;
how will the road and its alignment provide any relief from traffic congestion? From what is understood about the alignment (as seen in the current planning application) it makes no sense in terms of diverting through traffic to any significant degree. It is impossible to see how any relief from the effects of through-traffic can ever be delivered by this project;
the proposed alignment will add to problems experienced in the village as the north-eastern section of the village will be cut off from existing retail and community services;
the “relief road” is not identified by KCC, the Highways Authority for Kent, in their infrastructure and growth programme; and,
the TWBC draft Local Plan has not considered the wider impact on Hawkhurst of development in neighbouring areas such as Hartley (an additional 300 houses), Cranbrook (600 houses) and Rother District (6,180 houses).

4. The Gill's Green Key Employment Area will be safeguarded for future employment (B1, B2, B8) use in accordance with Policy ED 1, in order to maintain employment opportunities in the locality. Further expansion opportunity of employment floorspace is allocated in Policies AL/HA 8, AL/HA 9 and AL/HA 10). All future development proposals will be designed and located so as to retain the existing landscape character of Gill's Green and its surrounding area and will include landscape management schemes to deliver this requirement.

> Response: The Parish Council fully support this aspect of the policy.

5. A small amount of housing will also be provided at Gill's Green (included in total above).

> Response: The Parish Council support this aspect of the policy.

6. All development proposals will be required to establish the impact of the proposed development upon the Flimwell crossroads (junction of A21 and A268), and if necessary, provide contributions towards works to this junction to mitigate that impact.

> Response: The Parish Council cannot support this aspect of the policy without including the “impact of the proposed development upon Highgate Crossroads.” In addition, the Parish Council has concerns that the funds taken from developments in Hawkhurst will be funding strategic highway projects, in another county. In essence, the Flimwell junction is a poor junction now and should be a regional priority for Highways England.

The proposed policy will reduce funding in Hawkhurst for local mitigation that will benefit Hawkhurst or leave other community projects at a parish level with reduced funding.

7. All development proposals will ensure that landscape gaps between individual areas of the parish are retained to prevent coalescence of development, preserve the setting of heritage assets and help protect the wider historic environment.

> Response: The Parish Council support this aspect of the policy but is concerned that recent track record of development creep (Birchfield) and the scale of development proposed by the draft TWBC Local Plan will make this very difficult to deliver. Why not introduce a “green gap policy” and support for local trusts / Parish Councils / Councils taking ownership to prevent development creep?

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

> Response: The entirety of the parish is within the AONB. This means that all sites in Hawkhurst are within the AONB. This is a worrying mistake from the TWBC Local Plan team and reveals a deeper problem with the way TWBC consider the parish as suitable for large scale development. Nevertheless, we fully support this commitment, but think it should go further - there should be an expectation that all development in the AONB will fully meet the objectives of the High Weald AONB Management Plan.

9. The following public car parks within Hawkhurst, and as defined on the draft Policies Map, will also be retained in accordance with Policy TP 4 Public Car Parks: North Grove and Fowlers Park.

>Response: The Parish Council support this aspect of the policy. However, there needs to be recognition that the current level of parking in Hawkhurst is inadequate for current demand. Therefore, significant additional parking will be needed to accommodate the proposed level of development.

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

> Response: The Parish Council support this aspect of the policy, but these are long-distance routes, primarily for recreational purposes and needs to link to safe short distance utility trips – e.g. between where people live, where they go to school, where they shop and so on.

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

> Response: The Parish Council support this aspect of the policy and it links to our Tree and Hedgerow policy. However, it highlights a lack of green open space in the Highgate part of the parish as identified within the TWBC NDP for Hawkhurst. The proposal to build on Hawkhurst Golf Course only makes this lack of green space, recreation and sporting facilities even more of a concern and completely undermines this policy.

12. Retention of an appropriate mix of uses within the defined Primary Shopping Area, as defined on the draft Policies Map in accordance with Policy ED 11 in order to retain and enhance its role as a local service centre.

> Response: The Parish Council fully support this aspect of the policy.

13. The loss of local shops, community facilities, and green spaces, will be resisted (particularly in The Moor) in accordance with Policy ED 12, and the provision of any new retail development, community services, and open space, recreation facilities, etc. will be supported to meet local needs in accordance with other policies within the Plan.

> Response: The Parish Council support this aspect of the policy although it should be noted there have been no local shops at The Moor for several years.

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

a. Primary and secondary education.

> Response: We could support this policy if it focused on Hawkhurst Primary education. We are concerned that the proposed layout for site HA4 has not been fully thought through, with areas safeguarded for school expansion not adjacent to the current school. Why is this? Furthermore, due to lack of pupil numbers, will KCC be able to request s.106 funding for secondary schools near Hawkhurst?

b. Health and medical facilities - it is anticipated that the two existing medical practices at Hawkhurst will combine. An allocation for a new GP practice to replace and re-provide the existing services provided by the Wish Valley Surgery and the North Ridge Medical Practice is set out in Policy AL/HA 5 (Fowlers Park).

> Response: There is a very specific requirement on medical provision when compared with the vagueness on education. This needs to be addressed in subsequent versions of the local plan. What is the fall-back option if AL/HA 5 Fowler’s Park is not deliverable?

c. The provision of buildings and spaces to provide cultural infrastructure.

> Response: There is a very specific requirement on medical provision when compared with the vagueness on cultural infrastructure. This needs to be addressed in subsequent versions of the local plan and focus on the cultural provision within the Hawkhurst Community Centre.

d. Improvements to highway and transportation infrastructure will be made in accordance with individual site criteria set out in Policies AL/HA 1 to AL/HA 10.

> Response: We emphatically disagree. Any improvement to highways and transport infrastructure should be linked to the overall aims, values and objectives of the TWBC NDP for Hawkhurst and not site-by-site policies. Where in the TWBC Local Plan is there an overall access and movement plan for Hawkhurst parish?

There is further concern that TWBC has not considered access and movement infrastructure on a wider basis. For example, any development in Sandhurst will impact on Hawkhurst; developments in Hawkhurst, Cranbrook, Sissinghurst and Goudhurst will all impact on each other. People travelling by car south from Cranbrook will go through Hawkhurst and anyone in Hawkhurst travelling towards Maidstone will go through Cranbrook. Where is the evidence that the impact on the Hawkhurst crossroads has been considered in the other strategic policies?

This is completely the wrong policy. A joined-up Highway and transport infrastructure plan is required as part of the sustainability plan for the borough as a whole.

It should be noted that KCC Highways see no strategic need for the proposed “relief road” as part of the Hawkhurst Golf Club proposal. How can new infrastructure be made in accordance with individual site criteria, if those site criteria are not supported by the relevant agencies responsible for such infrastructure?

e. Improvements to, and increase in provision of, public parking to serve Hawkhurst (Highgate). This public car parking could be provided on sites near the settlement centre.

> Response: The Parish Council support this aspect of the policy and many parishioners feel there is not enough public car parking in the parish.

f. Provision of information panels and installation of public art along the Hop Pickers Line. Other locally significant historical features, events, and personalities could be recognised as part of this approach.

> Response: This is fine but a complete waste of time and energy. The land within Hawkhurst, as referred to in this section of policy, is privately-owned. How does TWBC propose to access the land and deliver this policy? It is a distraction from the real issues facing the parish.

g. The proposed Bedgebury to Sissinghurst cycle path route.

> Response: The Parish Council supports this aspect of the policy. However, the section between Hawkhurst and Cranbrook is the section called “the bends” and it is impractical to deliver a cycle path. Therefore, the land within Hawkhurst, as referred to in this section of policy, is privately-owned. How does TWBC propose to access the land and deliver this policy?

h. Provision of a new community facility. Opportunities for this facility to be of a design capable of providing sports use will be explored.

Response: The Parish Council fully support this aspect of the policy.

i. A feasibility study to consider alternative modes of public transport provision to serve Hawkhurst; for example, a Demand Responsive Bus service for the parish and beyond or community buses with subsequent contributions towards a project that delivers the preferred outcome of the feasibility study.

Response: This is fine, but this is only for a feasibility study, not the delivery of the actions resulting from the feasibility study – if any are required. What if the study says it cannot happen?

j. A study to reconsider road classification within Hawkhurst.

Response: The Parish Council support this aspect of the policy. This is fine, but HGVs on roads through Hawkhurst are the problem. The parish wants to divert HGVs from Hawkhurst (and the surrounding villages) to improve the quality of life, increase safety and reduce pollution, especially air pollution. Who will deliver the redirection of HGVs?

k. Provision of allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space to include potential for expansion and improvement of sports pitch provision at King George V field.

HPC Response: The Parish Council fully support this aspect of the policy, but this further lends evidence to the need to retain the Hawkhurst Golf Club, if not in its current form, then still as open space.

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

Response: The Parish Council support this aspect of the policy.

DLP_6439

Peter & Shirley Andrews

Just commenting on behalf of my wife and I who have lived in Hawkhurst for 43 years,it was then a small quiet village,unlike now!

We now have heavy traffic causing serious problems daily at the traffic lights, due to heavy lorries passing through to avoid Goudhurst.

We now have sewage spills because treatment plants cant cope.

We now have many water leaks in the village,due to having to increase supply pressure to already newly built houses.Here in Copthall Ave we have had leaks for six month now,there are three but only one has been repaired recently.

Ontop of these problems you wish to plan a further 400 new builds at golf course,48 at copthall ave and 30 at Westfield,this is just not practical due to the above existing problems.

With golf course development comes a Cranbrook relief road,this will only divert the traffic problems along with 400 homes = min 600 new cars to village.We badly need a total village bypass.

With Copthall development,access to main road, narrow width of avenue and danger to pedestrians due to very narrow pavements would all be problems.

SO PLANNERS PLEASE GIVE US IN HAWKHURST A BREAK,untill all of the above issues are sorted,

DLP_6464

DHA Planning for Cedardrive Ltd

Comments on Policy STR/HA1

3.3.7 We support the strategy for Hawkhurst as set out in Policy STR/HA1 in general, with particular support for the following requirements:

* The proposal for 681-731 new dwellings to be delivered in the village as set out in requirement 1. The proposals at Hawkhurst Golf Club are therefore a key part of the housing strategy;

* Requirement 3, in particular insofar as it requires contributions towards the relief road where this is appropriately justified; and

* The inclusion of some additional housing at Gills Green, as set out in requirement 5. The proposed development of Hawkhurst Golf Club includes some housing on the southern side of Gills Green.

3.3.8 Our client’s proposed development at Hawkhurst Golf Club will make a significant contribution towards delivering this strategy.

3.3.9 However, we raise concerns in relation penultimate paragraph of the policy, which requires employment floorspace to be provided on all greenfield windfall sites of 100 or more dwellings. It is assumed that the use of the word “windfall” means that this policy does not apply to Local Plan allocations but would be grateful for clarification on this. It should be noted in any event that any community facilities developed at Hawkhurst Golf Club would create some employment.

3.3.10 We object to the proposed Limits to Built Development for Hawkhurst insofar as the proposed allocation site at Hawkhurst Golf Club is shown as being excluded from the LBD. This makes no logical sense.

3.3.11 The draft proposals map already differentiates between areas of the Golf Club site which are suitable for housing, or which are required to be kept open. Whilst we make additional comments on this below, the principle of denoting these areas in this way is acceptable. There is no logical reason why the LBD should then exclude the whole site when it will clearly become part of the main built up area once developed. Instead the LBD could be drawn to exclude the non-developed area in exactly the same way as has been shown on allocations HA4 and HA6. The inconsistent approach to HA1 is unacceptable.

[TWBC: see full representation attached].

[TWBC: see also Comment Numbers DLP_6461-6472].

DLP_6484

Woolf Bond Planning for Millwood Designer Homes Ltd

Site 2: Chittenden Fields, adjacent to High Street and Slip Mill Road, Hawkhurst

Policy STR/HA 1: The Strategy for Hawkhurst

Representation

Hawkhurst has been identified as a key settlement in which to direct a significant proportion of new development during the Plan period.

The draft Local Plan allocates 681-731 new dwellings at Hawkhurst across seven sites.

Whilst we support the overall strategy of seeking to provide for additional growth at Hawkhurst, we consider there is an opportunity to provide for a further allocation at Chittenden Fields (SHELAA Site Ref: 2) to provide for approximately 70 dwellings in a sustainable location.

The allocation of the golf course site (AL/HA 1) identifies the broad location to the west of Hawkhurst as being suitable for residential development.

Omission Site: Land at Chittenden Fields, Hawkhurst

General

Our client’s site comprising land at Chittenden Fields, High Street, Hawkhurst (Site Ref: 2) is submitted as an additional housing allocation. It extends to approximately 3ha.

We have undertaken a thorough assessment of the character of the site and surrounding area and consider that it affords a sustainable development opportunity for up to approximately 70 dwellings.

The site is located within the confines of existing built development. It is not with a ‘gap’ and forms part of the built-up area.

Overall, the site has no physical constraints, and is well-related to the existing residential development. It is in close enough proximity to Hawkhurst to be able to walk to the centre, such that it affords a sustainable location in helping to meet identified housing needs whilst providing for sustainable patterns of growth.

Landscape

The Council’s SHELAA assessed the site as being unsuitable in landscape terms, which assessment draws upon the landscape analysis set out in the Landscape Sensitivity Assessment undertaken by LUC on behalf of the Council (July 2018).

The Landscape Sensitivity Assessment included the site within sub-area Ha1, which assessment area included the golf course which is now proposed to be allocated for housing.

Whilst it is acknowledged that the site has some landscape sensitivities (as is the case with the majority (if not all) greenfield allocations on the edge of settlements), with the development of the golf course as a backdrop, this will inherently alter the character and approach of the western edge of the settlement. Furthermore, the site is much smaller in scale than the golf course site, and could be developed sensitively, with a focus on a high quality landscaping strategy which would mitigate the landscape harm.

Our client instructed consultants Lloyd Bore Ltd to undertake an assessment of the suitability of the scheme to accommodate housing development. Their findings are set out in the accompanying Landscape and Visual Statement (Nov 2019) which concludes that the site has a high landscape capacity to accommodate development. Paragraph 7.5 states as follows:

“…the site is already very well contained and screened visually from the wider landscape, and offers good opportunities for mitigation, enhancement and successful integration with the existing development pattern of the village.”

Paragraph 7.6 further adds that the site is not prominent in the wider AONB landscape.

Paragraph 7.8 concludes in relation to the acceptability of developing the site for housing in landscape terms as follows:

“…. the impact on the AONB of an appropriately designed development on Chittenden Field would in fact be very limited. It also concludes that if the golf course site (within the same landscape character sub-area) is considered suitable for development of 400-450 dwellings, a relief road, community centre and public car park, then it follows that the Chittenden Field site, which is far smaller, contained and much closer to the village centre than most of the golf course site, should also be considered a suitable candidate for residential development.”

This analysis addresses the landscape comments in the Council’s SHELAA and sets out the landscape capacity of the site to accommodate housing development.

Highways, Accessibility and Sustainability

A Transport Assessment has been undertaken in order to assess the highway and sustainability merits of the site for housing development

In locational terms, the merits of the site include its proximity to the main retail facilities and bus stops are located in the centre of Hawkhurst which is 790m east of Chittenden Fields and therefore within walking distance.

There is a private school near to the site and a community hospital is located about 625m west of the site.

Other facilities such as golf club, public house and a church are also located within an easy walking distance, between the site and central Hawkhurst.

The nearest bus stops to Chittenden Fields are located on the A268 High Street approximately 150m east of the site (both east and westbound).

There are also bus stops (both east and westbound) located approximately 740m to the east of the site in Hawkhurst.

Overall, there are at least three buses per hour passing the site. Two of these run in two directions, therefore the overall frequency of buses passing the site is five per hour (two-way) on a weekday. However, they do not all stop at the nearest bus stops to the site.

There is a wide highways verge on the A268 adjacent to the site and therefore, there is the ability to introduce more formal bus stops with shelters on the A268 adjacent to the site to serve the bus routes that already pass the site.

The proposed means of vehicular access to serve development of the site for housing could be provided from the A268 via a new simple priority junction.

The visibility splays achievable from the site access to the nearside of the carriageway at present are 2.4m x 120m to the left (to the east) and 2.4m x 120m to the right (to the west). This fully complies with the DMRB standard for a road subject to a 40mph speed limit.

The access road would be extended into the site from the southern boundary to provide a surfaced road of 5.5m wide with 2m footways on both sides to the potential development site. The access road would have an average gradient of 1 in 12 between the back of footway level and development site, which would be adequate for use by large vehicles.

An impact assessment has been undertaken on the assumption of developing the site for up to approximately 100 dwellings. This has been undertaken as a sensitivity test in order to ensure trip rates are assessed at a maximum level.

This amount of development would generate an extra circa 550 vehicle trips (two- way) per weekday (two-way).

On the basis of the foregoing, the site is demonstrated to be in a sustainable location.

Suggested Change

Allocate land at High Street, Hawkhurst (SHELAA Site Ref: 2) as a housing allocation for approximately 70 dwellings.

[TWBC: for full representation, site plan and Landscape and Visual Statement , see attached documents].

[TWBC: see also Comment Numbers DLP_6479-6484]

DLP_6616

AAH Planning for Future Habitat Ltd

SECTION 5 – PLACE SHAPING POLICIES

Section 5 of the Draft Local Plan sets out the spatial priorities and policies for the Borough. The section is arranged by non-parish and parish areas, with reference to the various settlements within these areas, having regard to their characteristics and local issues, as well as reflecting the contribution that each can make to the overall development of the Borough.

Policy STR/HA 1 – The Strategy for Hawkhurst Parish

Policy STR/HA 1 sets out specific requirements for development within Hawkhurst. It specifically identifies that approximately 681-731 new dwellings will be delivered on seven sites allocated in the Local Plan in the plan period (Policies AL/HA 1-4, 6 and 9). It goes on to state that additional housing may be delivered through the redevelopment of appropriate sites and other windfall development in accordance with Policy STR 1.

Our Client welcomes the acknowledgement that additional housing may be delivered through the redevelopment of appropriate sites and other windfall development. However, in order to ensure that the overall aims and objections of the Local Plan can be met, it is considered that the wording of the policy in relation to the number of new homes should specify “at least” or “a minimum of”, rather than an approximate range, in order to boost significantly the supply of housing in accordance with the NPPF and ensure that the identified housing need can be delivered should some allocations not come forward.

Furthermore, it is considered that the identified development limits of Hawkhurst are overly restrictive and have been partially defined by existing planning applications, rather than being justified, rational and based on appropriate site assessment and evidence. It is therefore considered that these should be amended to allow for future development in and around the existing and proposed urban area. Our Client’s site at Heartenoak Road (Site Reference: 167) should be included within the proposed boundary to ensure that available, suitable and appropriate sites are not dismissed unnecessarily.

[TWBC: see full representation and site plan attached].

[TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627].

DLP_7334

Campaign to Protect Hawkhurst Village

Object

Hawkhurst is not a sustainable location for the entirely disproportionate level of growth proposed. An additional 730 dwellings will have a permanent detrimental impact on the character of the village and on the High Weald Area of Outstanding Natural Beauty.

There are three fundamental reasons why this level of growth does not represent sustainable development.

Hawkhurst is not a sustainable location, when properly considered against national policy and other strategic policies within the DLP;
Hawkhurst is all within the High Weald AONB and the proposed strategy will result in the loss of huge swathes of greenfield land, representing landscape which has been identified by the Council’s own consultants as high sensitivity and which should be afforded the highest degree of protection in accordance with the NPPF;

Hawkhurst village crossroads suffers from severe congestion and there is no capacity to accommodate further trips. The reliance on the relief round is unfounded as it will make matters worse in many respects. Likewise, no consideration has been given to the impact on the strategic highway network at Flimwell.

In 2017 there were 2139 households on the Hawkhurst Parish electoral role. If the maximum proposed allocations of 731 additional dwellings are all delivered it will increase the size of the village by 35%.

It is important to recognise that this further growth is in additional to the considerable recent development within the Village. In contrast to many other settlements within the Borough Hawkhurst has already over delivered on the 2010 Core Strategy allocation (which was approved to 2026) by almost 20%.

This level of growth is strongly opposed by the local community, as illustrated by the number of objections received to the Golf Course Planning Application.

In addition to public opposition, the Golf Course Planning Application has been received strong objections from Natural England, the High Weald AONB, CPRE and Highways England regarding the impact at Flimwell.

Hawkhurst has no train station, no secondary school, no NHS dentist, its primary school will be over capacity even after the contemplated additional form entry, and its two GP surgeries are at practical capacity.

The Council’s evidence base demonstrates that Hawkhurst already operates effectively as a dormitory settlement with the overwhelming majority of residents commuting by private car to their places of work. The proposed additional employment provision at Gills Green is not of a scale or type to provide employment for the future residents (in any event it is not walking distance to large parts of the village

The DLP will introduce in the region of an additional 1500 new residents to Hawkhurst. These future residents who will be entirely reliant on the use of private car to access every day employment, education, medical and retail services.

The Council’s suggestion that an increase in bus services can in someway mitigate this impact is entirely illusory.

The infrastructure contemplated to be provided within the village by the DLP will be wholly inadequate to meet the needs of this quantum of additional residents. The Infrastructure Development Plan (“IDP”) does not properly assess and address this increased demand. One additional form entry at the Primary school will not provide sufficient places, likewise the proposed combined medical centre is proposed to amalgamate the existing provision rather than new capacity. Both the primary school and the new medical centre are a considerable distance from a large part of the village.

This is directly contrary to the objectives of sustainable development (as set out in the NPPF) and other strategic policies within the DLP (most notably STR6 and STR8).

The whole of Hawkhurst is within the AONB. As set out above the Council has a statutory duty to conserve and enhance the AONB.

The NPPF is clear that the AONB should be given the “highest degree of protection” and great weight should be given to conserving and enhancing the landscape and scenic beauty. It provides that the scale and extent of development should be limited. Major Development should be refused other than in exceptional circumstances.

At present the DLP pays only lip-service to these legal and policy requirements.

In respect of the Golf Course site the Council’s own Landscape Sensitivity Study advises that the sensitivity of the site is ‘High’, and that any development would need to be of a very small scale.

The SA concludes that collectively the allocations in the parish represent a significant amount of development in a highly sensitive landscape and a large loss of greenfield land.

This impact is a direct consequence of the Council proposing to pursue a combination of Growth Strategy 5 with Growth Strategy 3. This is contrary of the recommendations of the interim SA which advises exploring Options 5 and 4 – focusing residual development outside the new settlement along the growth corridor.

Hawkhurst suffers from endemic congestion at the village crossroads. Kent County Council has acknowledged that the crossroads are over capacity and the existing situation is “severe”. This situation will be made worse when other consented but not built developments are fully occupied.

As set out above nowhere in the evidence base supporting the DLP has the Council undertaken any analysis on the impact of the level of growth on Hawkhurst crossroads.

This applies not just to the allocations within Hawkhurst but also the remainder of the Borough and all relevant adjoining boroughs which must be factored into the Council’s assessment.

The Transport Assessment accompanying the Golf Course planning application anticipates that by 2033 there will be an increase in AADT through the crossroads from the existing 16,193 to the predicted 19,193. This is even before the Golf Course and other proposed allocations are developed.

It acknowledges that the junction is already over capacity and that the situation will be considerably worse by 2033 - again without consideration of the impact of the proposed allocations.

The existing capacity of the crossroads is reflected in the draft policy. Paragraph 3 records the highways authority’s position that there is not sufficient capacity at the junction at this point in time to accommodate further growth.

The Council’s strategy for Hawkhurst is entirely predicated on the relief road providing actual relief. Paragraph 3 makes clear that if any of the other sites are unable to demonstrate that there is sufficient capacity they may not be implemented until the relief road is fully operational.

In practice given the Highways Authority position that there is no capacity this means that on the Council’s analysis none of the other allocations within Hawkhurst may be developed until the relief road is operational.

This analysis is flawed in two respects.

First, the whole point of a plan-led system is to ensure the combined impact of a series of allocations is considered at a strategic level prior to the adoption of the relevant policies. In this way both the plan will provide certainty for the Council, developers and the local community.

In this case it is incumbent on the Council to assess now as part of the Local Plan process, whether in the absence of the relief road there is sufficient capacity at the crossroads to accommodate the additional development. If it does not consider there would be sufficient capacity the policy should make that position clear.

It is wholly inappropriate for the Council to fudge the issue in the way proposed.

Secondly, and more importantly, the Council’s approach assumes that the relief road will make a significant improvement to the village crossroads.

However, there is not a shred of evidence in the supporting papers and assessments to substantiate this assumption. The issue has not even been considered in the specific Transport Assessment commissioned by the Council as part of the evidence base for the DLP – notwithstanding that several other documents acknowledge the severity of the current congestion.

In the absence of specific evidence demonstrating that the relief road will make a “significant improvement” (the test set by the Council in its strategic policies) the current policy STR/HA1 and the associated individual allocations are demonstrably unsound.

Given the contribution Hawkhurst makes to the Council’s overall growth strategy this has implications of the DLP as a whole.

We would refer you to our representations made in respect of the Golf Course Application (attached to these representations). These demonstrate that rather than result in “significant improvements’ the relief road will actually make the current position worse in several respects – most notably on the High Street where the traffic is predicted to increase by 98% and queue lengths are predicted to quadruple with the relief road in place.

The lack of assessment also casts doubt on the overall conclusions of the SA regarding the Hawkhurst allocations. In particular the SA assesses the proposals as having an overall positive impact on noise and air quality, but this is based on the assumption that the relief road will actually remove traffic from the crossroads – the Golf Course TA demonstrates that this simply won’t happen.

In respect of the specific Golf Course allocation, the SA assesses a positive impact in respect of travel – again this is based on the false assumption that traffic will be removed from the village crossroads.

It is instructive however that even with the relief road in place the SA considers there will be an overall negative impact on travel as a result of the cumulative impact of the Hawkhurst allocations.

Paragraph 6 of the draft policy provides that all development proposals will be required to establish the impact of the proposed development upon Flimwell crossroads and if necessary, provide contributions to the junction to mitigate the impact.

Again, this paragraph has been added on a flawed and unsubstantiated basis. Nowhere in the Transport Assessment submitted with the DLP (or anywhere else in the evidence base) is there any analysis or assessment of the impact of the Hawkhurst allocations (and other allocations) on the Flimwell crossroads.

It is the whole purpose of strategic planning to assess whether there will be an unacceptable impact arising from the combined impact of all the allocations. It should not be deferred to the development control stage.

The Council needs to assess the combined impact on the Flimwell crossroads and consider whether it is acceptable at this stage. If the impact is unacceptable it then needs to consider whether it is possible to adequately mitigate the impact based on a properly considered (and publicly available) scheme.

In this regard it is instructive that the Golf Course Transport Assessment again predicts dramatic impacts at Flimwell crossroads arising purely from that application. Queue times are predicted to quadruple with a practical reserve capacity in the AM peak proposed on minus 46.7% and degrees of saturation in excess of 130%.

In that application the applicant has proposed a scheme of mitigation – but even with which it is still predicted that overall average queue times will again quadruple. In any event Highways England have objected to the proposals on the basis that the scheme is inadequate and will make matters worse on the A21.

The impact on Flimwell has not been considered in the Council’s Transport Assessment and therefore not been properly taken into account in the overall SA.

Paragraphs i and j propose contributions be provided towards studies into alternative modes of public transport and to reconsider road classifications in the village. However, such contributions would only be lawful if they are considered to be necessary to make the developments acceptable in planning terms.

In turn, such contributions would only be necessary if there was a residual impact that would need to be mitigated – this suggests that even with the relief road in place there may still be a need for additional mitigation which undermines the entire basis on which the Policy is conceived.

Unless and until the traffic impacts of the Hawkhurst allocations and the relief road are properly assessed, the conclusions of the Sustainability Appraisal and therefore the DLP itself remain manifestly “unsound”.

DLP_7744

Mrs Susan May

The so-called “relief road” at Hawkhurst is a nonsense and will not relieve the traffic congestion at the traffic lights. It appears the Highways department had not realised that traffic will still be turning right from the Rye Road down Highgate Hill and therefore still requiring three phases as now, plus the pedestrian phase when activated.

Moreover, it includes a roundabout to the west of the traffic lights, and this is anathema to the High Weald AONB since roundabouts are not in keeping with this as explicitly mentioned in their HWAONB-Building-Design-Guidance-2019: “Roundabouts are uncharacteristic of street patterns within High Weald settlements and should not be used in new housing schemes in the area.”

Para 3: This relies on the relief road being effective, which it won’t be, and also that the development on the golf course will go ahead, ignoring the people who live here.

The proposed developments at the White House, and Copthall Avenue ignore the two historic settlements of Hawkhurst and the Moor by filling in the gap between them. Again ignoring the advice in the HWAONB-Building-Design-Guidance-2019: SITING DEVELOPMENT IN THE LANDSCAPE.

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Fiona Dagger

DLP_8009

Hobbs Parker Property Consultants Ltd for The Hedges Family Accumulation and Maintenance Trust

4 HAWKHURST – DEVELOPMENT STRATEGY

4.1 The local plan identifies existing deficiencies in infrastructure that requires improvement or new provision and will be secured via funding from development at Hawkhurst. Securing these additional facilities and infrastructure will improve the function of Hawkhurst in its role as key service centre during plan period. These include;

- a new relief road to relieve the crossroads at the centre of Hawkhurst
- new medical centre
- new community centre
- expansion of primary school

4.2 Further it is also noted that land forming part of the Hawkhurst Golf Course to the north of the High Street, Hawkhurst, identified in Policy AL/HA 1, are expected to be guided by an approved Master Plan that will form part of the evidence base to the Local Plan.

4.3 Related Policy STR 6 Transport also identifies the Hawkhurst Relief road as priority.

4.4 Consistent with the policy approach advocated above, all the land necessary to meet the full OAN in Hawkhurst should be identified by way of allocation to ensure that the viability of the schemes is fully tested to ensure that ‘Infrastructure Delivery Plan’ is capable of being delivery or, where funding shortfalls are identified, remedial measures are deployed to avoid under delivery.

5 HOUSING

5.1 It is noted that the plan states that total capacity of all identified sites (completed houses since 2016, outstanding planning permissions, retained Site Allocations Local Plan allocations, development through windfall sites, together with new allocations proposed in this Draft Local Plan) provides for some 14,776 net additional dwellings. This compares to a minimum requirement of some 13,560 dwellings. The council’s approach provides for a

modest oversupply equivalent to some 9% in order to ensure delivery of the full OAN. Where a range of housing numbers is provided in a policy for the outstanding site allocations and proposed allocations, the figure used in the above calculations the council state that this is the mid-point of this range.

5.2 However, table 1 Housing, sums to 13,560. It is therefore unclear as to where the additional 1,216 dwellings (14,776) are identified in the components of supply. This matter requires clarification.

5.3 The planned housing target for Hawkhurst is shown as a range. This approach is not supported. The target should be the specific figure of 731 dwellings as minimum. The plan allowance of windfall (equivalent to 5.16%) should be in excess the planned target for the

reason set above.

5.4 Notably the implementation of allocations has often yielded less dwellings than originally planned for. By way of an up to date example, the recently submitted planning application presented to the council on site HA 1 (Land forming part of the Hawkhurst Golf Course to the north of the High Street) is proposed for 400 dwellings as opposed to the 400-450 dwelling as envisaged in the draft allocation. This demonstrates the potential fragility of

the supply when relying on density assumptions on allocations in this area with identified national level environmental and policy constraints. There is need to allocate more sites in Hawkhurst to ensure delivery of the full OAN. A sensible approach would be to identify land for 10% above the 731 housing target to ensure delivery of the full OAN. Further, reserve sites should be identified to cover the eventuality, later on in the plan period, of allocations under delivering.

6 THE STRATEGY FOR HAWKHURST PARISH – PLACE SHAPING

6.1 Policy STR/HA 1 states that; “Approximately 681-731 new dwellings will be delivered on seven sites (*) allocated in this Local Plan in the plan period (Policies AL/HA 1-4, 6 and 9). (*) Of these sites, the following already has planning permission: AL/HA 5 for 25 dwellings”.

6.2 As set out above this approach lacks justification when having regard to the evidence of delivery of new homes within Hawkhurst in previous monitoring years and recent planning applications that are proposing to delivery demonstrably less than the draft allocation anticipates. In total the allocations sum to a range of 685 to 735. However, evidence form the planning application submitted on site HA 1 now demonstrates that the actual delivery figure from the allocations will only yield a maximum of 685 dwellings. There is need for the allocation of an additional site for 50 dwellings to be allocated at Hawkhurst.

6.3 The proposed allocation HA 6 acknowledges the need for a landscape buffer to be deployed on the southern boundary to ensure the development assimilates satisfactorily into the local landscape AONB setting.

6.4 SHLAA site 107 (see Plan extract below) at is located on Rye Road and has excellent connectivity to all of the main facilities and services within the settlement, all of which are accessible on foot.

6.5 The conclusions of the SHLAA states; “There is concern regarding impact on the AONB landscape and on the settlement pattern”.

6.6 These factors are common to all proposed allocations within Hawkhurst and therefore the acknowledgement that the landscape impact of the open southern boundary could be addressed in common with the approach advocated for site HA 6. Based on this policy approach the site is demonstrably suitable to accommodate development. The site is, in all other regards, suitable for development.

6.7 It is also evident that SHLAA site 107 performs better in terms of locational sustainability criteria than other prospective allocations.

6.8 For the plethora of reasons set out within this representation, support the inclusion of SHLAA site 107 for allocation in the emerging Local Plan.

DLP_8177

Highways England

Location:

No/Type:

Distance to SRN:

Impact:

Current traffic flows:

Recommendations

Hawkhurst

681-731 residential dwellings (7 sites)

New GP surgery, community and recreational facilities

Relief road to reduce congestion around A268 Rye Road/Cranbrook Road/Highgate Hill crossroads, as well as any impact on the Flimwell junction A21 and A268.

19/02025/HYBRID Hawkhurst Golf Club -Largest site proposes 400-450 dwellings, care home, relief road, community centre, closure of northern arm of crossroads. Currently being considered.

+3km west

A21

A268 runs through Hawkhurst, borders the largest proposed development at Hawkhurst Golf Club.

Primary concern is impact to A21 Flimwell crossroads. Development at Hawkhurst will generate significant trips. Hawkhurst Golf Club development estimated +200 trips during AM and PM peak.

Current traffic information shows there is congestion at Flimwell crossroads during AM and PM peaks. Google traffic shows heavier traffic during PM peak, particularly slow on the A21 southbound carriageway.

Highway capacity improvements proposed to mitigate impact.

TA submitted with 19/02025/HYBRID planning app mentions HE are currently working with A-one+ to development standalone scheme of enhancements to Flimwell Crossroads and that PRA will be identified Autumn 2019. Applicant welcomes opportunity to work with HE to deliver improvements.

S106/S278 Agreement.

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

DLP_8296

Programme Director - Local Care

NHS West Clinical Commissioning Group

General Observation

The CCG notes that the policy details that it is expected contributions will be required towards health and medical facilities, to mitigate the impact of the development. Policy AL/HA 5 (Fowlers Park) details an allocation for a new GP practice building to replace existing medical facilities.

There are currently two general practices located in Hawkhurst. The current premises are not suitable for the longer term and do not have the capacity to accommodate the level of growth proposed in the area (c 1700 new patient registrations in Hawkhurst and c2000 in total within existing boundaries of the practices. This is an identified priority area in the CCG Estates Strategy and the two practices submitted a joint proposal to the CCG in April 2019 to explore and develop plans for a new general practice premises in Hawkhurst; the practices have also signalled their intention to merge into a single general practice. The practices undertook an options appraisal and confirmed Fowlers Park as their preferred site. See CCG response to Fowlers Park.

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

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

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DLP_7477

Mr Peter Jefferies
Diana Robson
Kevin Conway
Lorraine Soares
Simon Whitelaw
Angela Thirkell
Madelaine Conway
Clive Rivers
Deborah Dalloway
Gillian Robinson
Paula Robinson
Andrew Roffey
Mrs Sarah Vernede
Charles Vernede
Linda Beverley
May Corfield
Vivien Halley
Simon Parrish
Catherine Baker
Patrick Thomson
Sally Thomson

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

There are very limited local employment opportunities and no secondary schools within walking distance.

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

The “relief road” will not work

DLP_1462

Mrs Wendy Coxeter

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

TWBC cannot misunderstand the local opposition to this development and the destruction of the character of our village which this would cause. We have experience of TWBC pushing for approval of a large scale near us of 49 houses. We are aware of how undemocratic and oppressive TWBC and KCC Highways can be when they ‘decide’ on a plan. There is an opportunity with this consultation to listen to our community.

I have already stated that this and many other large scale developments are not compliant with our Neighbourhood Development Plan. We have no need for this quantity of housing or this type.

Lack of adequate infrastructure

Southern Water suggests that it would take 2 years for them to improve our sewerage system adequately. This has been discussed in Parliament.

The proposed development would impact unacceptably on an AONB

The proposed development would not constitute sustainable development.

There are few viable transport alternatives to the car which means Hawkhurst would not be an appropriate location for a development of this size. Public transport services are limited and expensive. They do not match with demand for rail services at commute times and certainly do not adequately provide for young people to travel socially or for those on a limited income to access cheaper sources of food or better employment. Travelling East to West by bicycle would perhaps be fine (if you didn’t die in the process) but the topography is a deterrent for the developers idealistic view of us all popping to the shops on bicycles. Maybe in 20 years time electric bicycles will be so cheap that we can all afford them but for the moment this is not realistic.

As a community we feel that KCC Highways have provided incorrect data for traffic modelling and have relied heavily upon the traffic surveys of the developers. The traffic data for the Golf Course development included March readings during the ‘Beast from the East’ and ignores the seasonal variations of coast bound Camber traffic.

Traffic at a standstill does not add economically to our space paired as it is with inadequate central parking facilities. The relief road merely moves the issue down the road (quite literally) and shoppers will not use a car park so far from the centre. This road is being relied upon in the Sustainability Assessment but it is just a road that would have to be provided to service the properties and is substandard in terms of width and construction. It is a residential road and not fit to take the volume of heavy goods vehicles that will use it. It will crumble. Upon the closure of the top end of Cranbrook Road there is no allocation for a turning space further along if a vehicle should take a wrong turn. Only recently there was a well documented incident of a lorry trying to turn around at the top of Cranbrook Road at the junction with Peter Buswell’s office. There appears to be no plans for buses returning to the village centre via the relief road and Cranbrook Road residents will be marooned from the centre of the village by the closure of the Cranbrook Road at the top of the hill.

Kent Fire and Rescue have also commented upon the impact that this road closure would have on them.

The ‘relief road’ will not work.

Unless Highways England have substantial plans for reclassification of the major haulage routes taking HGV’s down from Maidstone to the A21 and not via Cranbrook and Hawkhurst south the road does not provide relief. Major alterations are required to the junction with the A21 at Flimwell to enable HGV’s to turn left to travel south. There are fears otherwise that HGV’s would turn left out of the relief road and turn right at the crossroads in the centre of the village to travel south down Highgate Hill and join the A21 at Coopers Corner/Hurst Green. This is likely to make the crossroads in the centre of the village more congested and less safe for the pedestrians.

DLP_3049

Mr Adrian Cory

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village.

The proposed development on the Hawkhurst Golf Club site would destroy the character of an important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development have simply not been properly considered in the Draft Local Plan.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan which provides that:

Larger developments of 10 or more houses will only be supported if it can be demonstrated that there are exceptional circumstances as prescribed by the NPPF and if it can be demonstrated that their impact on the sensitive landscape setting and the considerable environmental constraints of Hawkhurst can be effectively mitigated.

There are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

There are very limited local employment opportunities and no secondary schools within walking distance.

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

The “relief road” will not work

The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

DLP_2985

Mr Keith Lagden

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The proposed development on the Hawkhurst Golf Club site would destroy the character of an important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Placards saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

Non-compliance with Hawkhurst Neighbourhood Development Plan

As mentioned above the proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. I would repeat Hawkhurst is a village and not an urban area.

Lack of adequate infrastructure

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues, and that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

There are very limited local employment opportunities and no secondary schools within walking distance.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

The “relief road” will not work

DLP_3772

Mary Jefferies

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

Non-compliance with Hawkhurst Neighbourhood Development Plan

Lack of adequate infrastructure

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

There are very limited local employment opportunities and no secondary schools within walking distance.

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has objected to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

DLP_3981
DLP_3938
DLP_3906
DLP_3887
DLP_3955
DLP_3864
DLP_4066

B Draper
Rob Crouch
N T Harrington
E Leggett
Storm Harrington
Geraldine Harrington
Nicki Poland

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

Non-compliance with Hawkhurst Neighbourhood Development Plan

Lack of adequate infrastructure

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

There are very limited local employment opportunities and no secondary schools within walking distance.

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has objected to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

If the ‘relief road’ is planned as a standard 7.3m single carriageway then any parking or other temporary obstruction will result in no improvement whatsoever. The suggestion that HGVs etc will turn right at the roundabout at the southern end and then proceed westwards towards Flimwell cross roads will be exposed as totally flawed unless significant property appropriation is made. It should not be forgotten that this section of road lies within a different county boundary who may hold higher priorities for road improvement provision.

The expectation that large vehicles would be able to make a left turn under the current geometric circumstances would be revealed as over optimistic. In addition congestive build up of traffic at this cross roads will lead to further delay and disruption resulting in traffic resorting to the use of the cross roads in the centre of the village. Under these circumstances the term ‘relief road’ is something of a misnomer.

DLP_4728

Mike & Felicity Robinson

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village.

The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

There are very limited local employment opportunities and no secondary schools within walking distance.

The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

DLP_6427

Gary Birch

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

Lack of adequate infrastructure

The proposed development would not constitute sustainable development

There are very limited local employment opportunities and no secondary schools within walking distance.

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

The “relief road” is not a proven means of mitigating traffic

The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply my not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

DLP_6875

Rosemary Cory

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

There are very limited local employment opportunities and no secondary schools within walking distance.

The village is already a congestion black spot and subject to unacceptable levels of pollution – results of formal pollution monitoring in the village will be available shortly. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

The “relief road” will not work

The so-called “relief road” (which has been conceived by the putative developers of the Golf Course site) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

DLP_7198

Mr Michael Armitage

Sewage services are under scrutiny, as they are already unable to cope with demand. New development is therefore out of the question.

Hawkhurst golf club with the service road would make the village unsustainable, with no appreciation of the impact on schools, services, surgeries and infrastructure.

The AONB is being deliberately ignored. Terms of an AONB cannot assume that as the village will be the size of a ‘town’, the restrictions do not apply. Hawkhurst’s village status obviates this.

There are grave concerns that the proposed service road will make anything but a negative impact on traffic flow in the village.

DLP_3833

Liane & Alan Chambers

We do not agree with the proposals for Hawkhurst. The village cannot cope with the housing allocation put forward in the plan. The proposals for a relief road would add to traffic congestion, air pollution and adversely affect the quality of life of the residents.

Both the proposed housing and road would significantly affect the Area of Outstanding Natural Beauty (AoNB) and is contrary to provisions set out in the national guidance. Paragraph 172 of the National Planning Policy Framework (NPPF) states that major development in an AoNB should be refused “other than in exceptional circumstances”.

Please note that unlike Paddock Wood and Cranbrook, Hawkhurst is a village not a town.

DLP_2965

Michael Alder

The Draft Local Plan emphasises that TWBC prefers to meet its assessed housing needs by approving large-scale developments. It is clear that no consideration had been given to the consequences of this when related to the preservation of the ANOB where Hawkhurst is 100% covered by the ANOB criteria.

The claim by TWBC ( para 4.36 ) that there is a level of agreement with Parish Councils on development sites is incorrect, certainly in the case of Hawkhurst. The NDP for Hawkhurst submitted in March 2019 has been ignored by TWBC -- if read at all -- although it has be "made" and must be taken into account when preparing the Local Plan.

There has been much speculative housing development recently in Hawkhurst despite the fact that numbers of properties identified in earlier Neighbourhood Development Plans have already been exceeded. The calculations for the TWBC Draft Local Plan assume a zero base which is a basic error. Hawkhurst has already been seriously impacted by this.

Paragraph 4.40 claims that the growth strategy is based on infrastructure-led development. The experience in Hawkhurst is that statutory think otherwise. Sewage and transport provision for the existing demand of Hawkhurst is failing dismally. Southern Water themselves have admitted that their infrastructure is inadequate for further development. Transport, education and health services are facing the same situation.

Policy AL/HA 1: Land forming part of the Hawkhurst Golf Course to the north of the High Street

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_64	Patricia Cronin		Re: Proposed development of Hawkhurst golf course My husband and I attended the exhibition at The Royal British Legion this afternoon. We read all the information, scrutinised all the maps but there was no sign of the proposed “relief “ road on any of the maps. My husband and I have lived in Hawkhurst for 15 years. We bought our property because it had everything we wanted and was in a quiet road. We didn't have shops or anything within walking distance but we had a car and it only took about 7 minutes to get to a shop for essentials. The same distance to our doctors surgery also took about 7 minutes. That was 15 years ago. Now – it can take anything from 15 to 25 minutes depending on how much traffic is at the crossroads. BUT. If a “relief” road is constructed it will TAKE US LONGER! It will not be a RELIEF BUT A NIGHTMARE! IF we can still use Slip Mill Road, turn left into Lightfoot Green, then left again into ?? A roundabout almost opposite Marlborough House School with all the cars turning in and out of there. Then, eventually......up to the Hawkhurst traffic lights/crossroads...........then...will we be able to turn right into Highgate Hill? BUT – our doctors surgery seems to be moving to the land adjacent Fowlers School – so we will be driving straight ahead with all the traffic that's been re-routed from Cranbrook Road, across the golf course, into the roundabout and ahead towards Sandhurst!! We also noticed, at the exhibition, that there was a place called Hawkhurst Station. Where is this station? We didn't think Hawkhurst had a station. This development is unsustainable.
DLP_1749	Peter Hay	Object	I object to this policy
DLP_2092	Terry Everest	Object	Object Too large a site, too much development - not sustainable.
DLP_2419	Rosanna Taylor-Smith	Object	Policy ALH1 I totally disagree with this proposal for development and the so-called relief road on the Golf Club. This would result in the loss of important green space, a sporting and social venue, old life habitat and woodlands. The proposed Narrow estate road would not relieve anything - it would simply move traffic from one part of Cranbrook road, via a roundabout on A268 to the Highgate Traffic lights on the one hand, and then via those traffic lights to Sandhurst and Rye or to Hurst Green, A21 and onwards to Hastings or to Flimwell and the A21. I do not believe that Air Quality would be better for the Highgate Traffic Light area, apart from the area at the top of Cranbrook road. Unless and uuntil HGVs are banned from the centre of Hawkhurst , air quality will continue to worsen. Why does TWBC not demand that all engines are turned off when traffic is queuing? The anti-idling policy should be enforced.
DLP_2522	Mr Guy Dagger	Object	Major development is not appropriate in the AONB. TWBC have accepted that Hawkhurst Gold Course is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. The proposal (115, AL/HA1) to build a ’relief’ road through Hawkhurst Golf Course, together with 450 dwellings, constitutes major development in an AONB and should be considered under the sequential test set out in the NPPF, Para 172, the first part of which requires a justification of need, and the third part an assessment of harm. The Sustainability Appraisal score for landscape impact resulting from this allocation is ‘Very Negative’ and confirms the evident harm likely to be done to the AONB as a result of this development. TWBC have not adequately justified the need for this road and associated development as required under NPPF, Para 172, for the following reasons: - The Government’s Science and Technology Committee reporting 22nd August 2019 on policies needed to meet the Government’s commitment to net-zero emissions by 2050 stated that ‘widespread personal vehicle ownership does not appear to be compatible with significant decarbonisation’. The increase in car use which the local plan is seeking to accommodate is not compatible with the Government’s climate commitment, nor is it compatible with TWBC’ climate emergency declaration and aim to make the borough carbon neutral by 2030. Infrastructure improvements in the Plan appear to be dominated by consideration for the private car. Lip service is paid to walking and cycling with no comprehensive borough-wide plan to improve active travel put forward. - The building of the ’relief’ road is justified in the Site Assessment by anticipated noise and air quality benefits to Hawkhurst but this is not evidenced. - The Sustainability Assessment (p. 76), concludes that the air and noise benefits claimed to justify the road would themselves be ‘negated’ by additional traffic generated by this site and other allocations in the village. No analysis of the impact of the 1500+ additional vehicles generated by allocations of 731 new dwellings in Hawkhurst have been shared. There is no secondary school in Hawkhurst, very limited employment opportunities, and the primary school, supermarkets and a GP surgery lie on the opposite side (East) of Highgate Hill crossroads which are already notoriously congested. ‘Active travel’ (walking and cycling) will not be an option for accessing secondary schools or employment. Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?
DLP_2597	Jane Pyne	Object	I am not going into great detail but just to say that numbers are clouding sensibility. This should not go ahead and to say it is a relief road and therefore good for Hawkhurst is I have to say rubbish as looking at it you can see it is never going to work and is going to cause even more problems at the High Street between the roundabout and traffic lights. Nothing about easing traffic comes to mind. The amount of cars generated will make Hawkhurst awash with cars and fumes which are already a health hazard. I know how bad it is. This would be going against the NDP and AONB and iis far too many houses in one hit and would change the village forever. Once concrete is down the damage is done and an area on AONB is lost all because of not looking at the wider picture. IT IS NOT A RELIEF ROAD IN ANY SENSE AT ALL AND SHOULD BE STOPPED. The contributions do not go far enough and the only yhing of note is the Community Centre. Buses are raely used an no amout of study will change that as we are at the furthest end of so many services. Car park I have already stated it is not worth putting on the golf course because it is too far and too steep you would need a car to get from the golf course to Hakwhurst. They thought it was too far for a medical centre.
DLP_2665	C Chambers	Object	Other comments: In the light of the Neighbourhood plan and AONB, I also wish to object to the proposal for unsustainable development in Hawkhurst - especially the Golf Course - it is too large a development for the village and the relief road will cause further damage and negative impacts on landscape, air quality, noise quality and climate change.
DLP_3314	Kent County Council (Growth, Environment and Transport)	Object	Highways and Transportation The Local Highway Authority objects to this policy. The current application on this site does not support the claim that the road will relieve congestion at the junction, and the proposed development may make congestion worse. Therefore, this allocation cannot be supported by the County Council. Public Rights of Way and Access Service Paragraphs 1 and 9 are supported. Further, it is requested that opportunities for the provision of a new link with Public Bridleway WC219 are explored and, if feasible, provided. This is because the right of way provides access to a valuable network of walking, cycling and equestrian routes to the west, which would provide significant outdoor recreation opportunities for Hawkhurst residents. It is also requested that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development. Heritage Conservation Scale 2 - Pre-determination assessment should be carried out to clarify whether development of any part of the site is possible. This is a large proposed development which could have an impact on the rural historic setting of Hawkhurst and the surrounding small holdings and farm holdings, some of which are historic complexes. There is also some potential for prehistoric and later remains. An Archaeological DBA including an Archaeological Landscape Assessment would be advisable to inform this allocation
DLP_3450	High Weald AONB Unit	Object	Major development is not appropriate in the AONB. Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of: s) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; t) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and u) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”. TWBC have accepted that Hawkhurst Golf Course is major development but have not explained how the sequential tests required by para. 172 have been met. This policy is therefore, not justifiable. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’. The proposal (115, AL/HA1) to build a ’relief’ road through Hawkhurst Golf Course, together with 450 dwellings, constitutes major development in an AONB and should only be considered in exceptional circumstances and in the public interest and subject to the tests in the NPPF, Para 172, the first part of which requires a justification of need, the second a consideration of alternative ways of meeting that need and the third part an assessment of harm. The Sustainability Appraisal score for landscape impact resulting from this allocation is ‘Very Negative’ and confirms the evident harm likely to be done to the AONB as a result of this development. It is our view that TWBC have not adequately justified the need for this road and associated development as required under NPPF, Para 172, for the following reasons: - The Government’s Science and Technology Committee reporting 22nd August 2019 on policies needed to meet the Government’s commitment to net-zero emissions by 2050 stated that ‘widespread personal vehicle ownership does not appear to be compatible with significant decarbonisation’. The increase in car use which the local plan is seeking to accommodate is not compatible with the Government’s climate commitment, nor is it compatible with TWBC’ climate emergency declaration and aim to make the borough carbon neutral by 2030. Infrastructure improvements in the Plan appear to be dominated by consideration for the private car. Lip service is paid to walking and cycling with no comprehensive borough-wide plan to improve active travel put forward. - The building of the ’relief’ road is justified in the Site Assessment by anticipated noise and air quality benefits to Hawkhurst but this is not evidenced. - The Sustainability Assessment (p. 76), concludes that the air and noise benefits claimed to justify the road would themselves be ‘negated’ by additional traffic generated by this site and other allocations in the village. No analysis of the impact of the 1500+ additional vehicles generated by allocations of 731 new dwellings in Hawkhurst have been shared. There is no secondary school in Hawkhurst, very limited employment opportunities, and the primary school, supermarkets and a GP surgery lie on the opposite side (East) of Highgate Hill crossroads which are already notoriously congested. ‘Active travel’ (walking and cycling) will not be an option for accessing secondary schools or employment.
DLP_3452	Sally Marsh	Object	Policy Number: AL/HA 1 Hawkhurst Golf Course Major development is not appropriate in the AONB. TWBC have accepted that Hawkhurst Gold Course is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. The proposal (115, AL/HA1) to build a ’relief’ road through Hawkhurst Golf Course, together with 450 dwellings, constitutes major development in an AONB and should be considered under the sequential test set out in the NPPF, Para 172, the first part of which requires a justification of need, and the third part an assessment of harm. The Sustainability Appraisal score for landscape impact resulting from this allocation is ‘Very Negative’ and confirms the evident harm likely to be done to the AONB as a result of this development. TWBC have not adequately justified the need for this road and associated development as required under NPPF, Para 172, for the following reasons: - The Government’s Science and Technology Committee reporting 22nd August 2019 on policies needed to meet the Government’s commitment to net-zero emissions by 2050 stated that ‘widespread personal vehicle ownership does not appear to be compatible with significant decarbonisation’. The increase in car use which the local plan is seeking to accommodate is not compatible with the Government’s climate commitment, nor is it compatible with TWBC’ climate emergency declaration and aim to make the borough carbon neutral by 2030. Infrastructure improvements in the Plan appear to be dominated by consideration for the private car. Lip service is paid to walking and cycling with no comprehensive borough-wide plan to improve active travel put forward. - The building of the ’relief’ road is justified in the Site Assessment by anticipated noise and air quality benefits to Hawkhurst but this is not evidenced. - The Sustainability Assessment (p. 76), concludes that the air and noise benefits claimed to justify the road would themselves be ‘negated’ by additional traffic generated by this site and other allocations in the village. No analysis of the impact of the 1500+ additional vehicles generated by allocations of 731 new dwellings in Hawkhurst have been shared. There is no secondary school in Hawkhurst, very limited employment opportunities, and the primary school, supermarkets and a GP surgery lie on the opposite side (East) of Highgate Hill crossroads which are already notoriously congested. ‘Active travel’ (walking and cycling) will not be an option for accessing secondary schools or employment. Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?
DLP_3575	Robert and Alyson Taylor	Object	We write to object tot the revised planning application submitted for Streatley/52 and the proposal to build on the Golf Club. How can you continue to build more houses in Hawkhurst without any investment in local infrastructure? The local School is struggling to find places for all the children moving into the Village. The same applies to our doctors, one of whom I met recently at a social event when he told me that he was looking to retire soon due to his excessive workload and the effect it was having on his health and family life. Our sewerage system is not fit for purpose with raw sewerage leaking into our local streams. A water board employee, who was pumping our the stream know as the Wish, told me that if only half the residents of Hawkhurst flushed their toilets at the same time, Hawkhurst would disappear under a tidal wave of effluence! It would appear, therefore, to pose a serious threat to people's health. On the 28 October, Greg Clark raised the issue in Parliament and gained an admission from Southern Water that the infrastructure is totally inadequate and no further development should be approved until new infrastructure is in place. The roads have become more and more congested with every new development. The facilities for team sports within the village for children to take part in have no Council funding and a re completely undervalued. The social interaction and benefits, both for the parents and children, cannot be over emphasised, as they are part of the building blocks of a happy and well balanced society. Your defence is, we are only following Government guidelines. History is filled with people who were only following orders! We can see no coherent town planning in any of this. Your first priority should be to put the needs of your community first and to fulfill your duty as custodian of AONB, which makes up 80% of our area. The price od most houses that are being built are far beyond the reach of young local families and are being bought, for the most part, by people selling their London homes and buying what they consider (compared to London prices) to be cheap homes. You cannot house the whole of London. This plan, as anyone can see, is totally incomprehensible and can only end in disaster!
DLP_3615	Southern Water Services Plc	Support with conditions	Southern Water is the statutory wastewater undertaker for Hawkhurst. 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 450 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/HA 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 Hawkhurst. 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/HA 1 Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes
DLP_3843	Government Team Natural England	Object	Your authority will be aware that Natural England provided an objection response following a planning application for the development of this site. Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. Subject to assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.
DLP_3848	Liane & Alan Chambers	Object	Policy Number: AL/HA1 We object to this specific site allocation and also the proposed relief road as set out in this and other policies. These are for the following reasons: 1. The proposal is for 417 houses, a new road and ancillary development. It is overdevelopment for the location and will significantly alter the character of the area in a negative way. The proposal is too large for the village. It would lead to an additional 20% of residents in the village (based on 2011 census 4911 residents and average household figures of 2.4 per dwelling). 2. The development is outside the existing Limit of Built Development and would significantly alter the character of the village. 3. This development is proposed for a greenfield site within the High Weald Area of Outstanding Natural Beauty (AoNB). Paragraph 172 of the National Planning Policy Framework states that major development in an AoNB should be refused “for major development other than in exceptional circumstances”. The Golf Course links contribute to the rural character of the village outskirts by acting as an area of greenspace. This development will negatively affect the landscape character of the AoNB. The site is visible from public footpaths and roads and the houses would be a visual intrusion, reducing the feeling of being in the countryside. The increased noise pollution will also reduce the tranquillity of the area. 4. The community have agreed a neighbourhood plan which clearly states policies promoting small infill, brownfield development (Policy HD1a). Policy HD1b states that larger developments (defined as 10 or more) should only proceed if they effectively mitigate their impacts on the environment. Given the very large nature of this development, it cannot be concluded that the negative effects on the village and its AONB setting are fully or effectively mitigated. 5. The proposal includes reference to a new relief road for the village. The proposal would increase traffic congestion in the High Street area, as all traffic wishing to travel north of the crossroads (down Cranbrook Road) would be re-routed down the High Street. The High Street is already very congested at peak times, with long tailbacks and this would get worse. An additional 417 houses could add another 1000 cars to the locality, causing these adverse cumulative impacts. 6. The proposed road and additional traffic from the new houses and from re-routing other traffic will also increase local air pollution. 7. The proposed new road and roundabout near the Golf Club entrance and will add to the difficulty of pulling out on to the High Street for local residents. It is already a busy, dangerous road and this will make it harder to access and egress local properties. This development and resultant increased vehicle use will also add to the risk of accidents on this stretch of the High Street, where cars regularly travel faster than the speed limit.
DLP_4127	Tunbridge Wells District Committee Campaign to Protect Rural England	Object	Please see our comments on STR HA/1 concerning this proposed major development in the AONB which does not appear to be justified under NPPF Paragraph 172. However, if the number of houses allocated to Hawkhurst under that Strategy is eventually approved at examination, then we accept that the proposed development on this site may be less damaging than the loss of further greenfield sites elsewhere in the parish.
DLP_4237	Rother District Council	General Observation	General comment It is noted that contributions for ‘any other highway related works’ are referred to within each of the policies. However, in order for any necessary improvements to the Flimwell crossroads to be secured, it is specifically requested that explicit reference is made to requirement 6 of Policy STR/HA 1 or that its general requirements repeated in some form in each of the site allocation policies to ensure the traffic impacts are robustly considered.
DLP_5911	Miss Helen Mary Fletcher	Object	Ref: Relief/Link Road across Golf Club Development of 417 dwellings in Hawkhurst This Development can not stand up to all it offers. It would be a disaster for Hawkhurst and should not be included! The Relief/Link Road through this Golf Course will move traffic from the A229 towards the A268. with the addition of 2 bottlenecks plus the traffic from the new built 419 houses with as many or double the number of cars adding to our already congested transport system. Diverted traffic from the north closure of the A229 along this link road towards the A268 will create more traffic issues towards Flimwell and then back into Hawkhurst for vehicles requiring to go towards Rye etc. How does this improve the congested A roads with traffic in this village idling at the signal box in the centre? The aim of this Local Plan states that House and Economic Development will retain key environmental and historic attributes of the borough and overall quality as a great place to live and work. Certainly NOT in Hawkhurst! It’s unique character and history will disappear even more with the planned overload of houses on a strained infrastructure!! a). There are few opportunities for employment. There are mainly low paid jobs in super markets, shops, cafes or restaurants unless someone is self employed or running a business. Low income would equate to the difficulty of young and first time buyers obtaining mortgages to purchase the so called low cost houses already built. Not! Some houses that are already built not selling - so no rush from homeless buyers!! The result - new residents will have to travel out to seek employment. This demands use of cars as buses are not always convenient or reliable and 2 train stations are 20 minutes away at Staplehurst or Etchingham. Ticket prices are expensive for commuters. b). The air quality from the petrol and diesel fumes idling in traffic queues together with the noise generated will not improve the quality of life for walkers and cyclists - increasing respiratory conditions. c). Cycling in Hawkhurst does not exist as there are no dedicated spaces on the roads for cyclists! Never seen a cyclist using the village roads. Care for their Health & Safety would prevent this! d). Why do we require a new country park between Hawkhurst and Gills Green? What a waste of resources - when we live in an AONB with green spaces which the present population value but is gradually being eroded only to be invaded and destroyed by house building. e). Building a car park so far away from the shops means negotiating hilly terrain with shopping - certainly not an attractive prospect for many especially the disabled and elderly. Remember them? I am one of them! The Plans for 685 houses in Hawkhurst contravenes our NDP and TWBC is not proactively engaging with it or recognising the updated version for Hawkhurst completed in March 2019. Previously to put this in place a lot of time and expense was spent in the village and with the Hawkhurst Parish Council. It was accepted as part of TWBC Statutory Development Plan in March 2018. Have we wasted our time and money to meet false promises? Time and money should be spent improving the infrastructure In Hawkhurst Surely the time has arrived when it is obvious that the villages in Kent certainly in this Borough and Hawkhurst cannot support these large developments being thrust on all of us with little regard for the existing inadequate infrastructure to support them. Added to this scenario is the subsequent diminishing of the quality of life of existing rate paying residents. During Planning Consultations throughout the years for various housing estates faced by Hawkhurst we have constantly informed the Planners of all these issues which appear to have fallen on deaf ears as we seem to have to repeat them time after time! Housing Developments should be planned where there is land close to wide existing roads or motorways and where new efficient infrastructure can be put in place. The Sewage system in Hawkhurst has been identified as requiring upgrading in this village even with the current population and developments. Surface water run off from so many dwellings will be impeded when massive green areas and flood plains are concreted for house construction. Leading to more flooding. All the ditches in the neighbourhood are not efficiently cleared anymore many are choked with litter and weeds! The New Refuse Collection System started in September this year contracted for nine years is a hit and ‘missed’ bin one at present. How will it cope with all these additional houses? More Health & Safety issues? Loss of Green spaces & Agricultural Land With the current threat of climate change and shortage of food in the future we should not be squandering Agricultural land. Once built upon the land is lost forever! The Chairman of the Hawkhurst Parish Council Claire Escombe has succinctly stated and pointed out on our behalves all the failures of this Draft TWBC Local Plan. We support her and the Hawkhurst Parish Council whom we have elected and who democratically listen, hear and act on our opinions. I hope you as Planners will also listen, hear and act positively for all of us.
DLP_5950	Mr Andrew Constable	Object	Comments on specific sites in the plan. We acknowledge that Hawkhurst has to accommodate some development, but it has to be sustainable and in locations that do not have an overwhelmingly adverse impact on the AONB. There are three sites in the draft plan whose scale and location means that they are simply not appropriate: Policy AL/HA1 – Land forming part of Hawkhurst Golf Course – the people of Hawkhurst have commented in huge numbers against this proposal. There are even protest signs put up across the village. It contradicts almost every planning guideline, particularly the AONB. There is a new road proposed which the developers cynically describe as a “Relief” road, yet their own traffic forecasts show that it worsens the congestion in the centre of the village. Alternatives We believe that there is an alternative location that would be more suitable for this scale of development. On the A21 just south of Tunbridge Wells is a roundabout known as Kippings Cross (postcode TN12 7HB). There are numerous reasons why the land adjacent to this roundabout would make an ideal location for further development, including: It adjoins the newly improved A21 allowing traffic to move easily towards London, Tonbridge, Sevenoaks and into Tunbridge Wells. It is close to all the facilities and amenities of Tunbridge Wells, including schools and hospitals. Train stations at Paddock Wood, Tunbridge Wells and Tonbridge are in easy reach. There is limited existing development in the immediate vicinity, so fewer people will be directly affected by the development. [TWBC: See related comments DLP_5946_5949-5952]
DLP_6022	Tim Stephens	Object	I do not support the closure of the northern arm of Cranbrook Road (at the Rye Road crossroads) a head of the completion of a full transport assessment. I would support Cranbrook road being calmed for local traffic use.
DLP_6055	Laura Rowland	Object	Policy Number: AL/HA 1 Hawkhurst Golf Course Major development is not appropriate in the AONB. TWBC have accepted that Hawkhurst Gold Course is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. The proposal (115, AL/HA1) to build a ’relief’ road through Hawkhurst Golf Course, together with 450 dwellings, constitutes major development in an AONB and should be considered under the sequential test set out in the NPPF, Para 172, the first part of which requires a justification of need, and the third part an assessment of harm. The Sustainability Appraisal score for landscape impact resulting from this allocation is ‘Very Negative’ and confirms the evident harm likely to be done to the AONB as a result of this development. TWBC have not adequately justified the need for this road and associated development as required under NPPF, Para 172, for the following reasons: - The Government’s Science and Technology Committee reporting 22nd August 2019 on policies needed to meet the Government’s commitment to net-zero emissions by 2050 stated that ‘widespread personal vehicle ownership does not appear to be compatible with significant decarbonisation’. The increase in car use which the local plan is seeking to accommodate is not compatible with the Government’s climate commitment, nor is it compatible with TWBC’ climate emergency declaration and aim to make the borough carbon neutral by 2030. Infrastructure improvements in the Plan appear to be dominated by consideration for the private car. Lip service is paid to walking and cycling with no comprehensive borough-wide plan to improve active travel put forward. - The building of the ’relief’ road is justified in the Site Assessment by anticipated noise and air quality benefits to Hawkhurst but this is not evidenced. - The Sustainability Assessment (p. 76), concludes that the air and noise benefits claimed to justify the road would themselves be ‘negated’ by additional traffic generated by this site and other allocations in the village. No analysis of the impact of the 1500+ additional vehicles generated by allocations of 731 new dwellings in Hawkhurst have been shared. There is no secondary school in Hawkhurst, very limited employment opportunities, and the primary school, supermarkets and a GP surgery lie on the opposite side (East) of Highgate Hill crossroads which are already notoriously congested. ‘Active travel’ (walking and cycling) will not be an option for accessing secondary schools or employment. Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?
DLP_6188	Mr Andrew Hill	Object	Land forming part of the Hawkhurst Golf Course (Policy AL/HA1). This is by far the most contentious proposal being some 400+ houses. Para 3 of this Policy states a new relief road is to be provided. This is a totally flawed concept for many reasons which, I reiterate, have been pointed out by the very many objections to the hybrid planning application (19/02025). Briefly it can only hugely complicate the traffic situation and cause long delays at the crossroads. 400+ houses will generate around 800 cars with their carbon footprint, there is not enough employment locally, not to mention the destruction of woodland and natural habitat in the AONB. This being a consultative process one would hope the Borough Council will pay heed to residents and not dismiss their concerns and policies as laid out in the well constructed Neighbourhood Plan.
DLP_6389	Hawkhurst Parish Council	Object	Policy AL/HA1 - Land forming part of the Hawkhurst Golf Course to the north of the High Street Hawkhurst Parish Council (HPC) cannot support this policy. HPC has objected to the recent planning application for this site. HPC’s comments on the application are relevant to this allocation, as are those of other consultees. The application is opposed by Natural England (who are of the opinion that the size and scale of the proposal and the harm it would cause to the High Weald AONB are a matter of national importance), CPRE, WKPS and the AONB Management Unit amongst others. These objections relate to the size and scale of the application, which aligns with the policy in the draft Local Plan, rather than specific details which could be addressed through a different planning application. This is one of the largest developments proposed for an AONB anywhere in the country. Point 3 requires the provision of a new “relief” road through the site. At present, there is no evidence that this additional road would improve traffic conditions in Hawkhurst. In fact, the available data indicates that this would not be the case. Highways England and KCC Highways have both raised concerns over this aspect of the current planning application. If TWBC retains this policy in future versions of the Local Plan, there must be a requirement for an independent assessment of the impact on traffic throughout Hawkhurst and how this will impact on air quality. We have particular reservations about the increased traffic on the High Street, which the developer’s own traffic figures show will be 96% higher in 2033 if the Golf Course development goes ahead than if it doesn’t (Table 4-9 of Environmental Statement). If TWBC decides to allocate this site, then it is imperative that there is further discussion between TWBC, HPC and the developer to protect the open space land.
DLP_6461	DHA Planning for Cedardrive Ltd		1 Introduction 1.1 Purpose of this report 1.1.1 This representation has been prepared on behalf of Cedardrive Ltd in response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until 15th November 2019. 1.1.2 These representations relate to land at Hawkhurst Golf Club, which our client is promoting for a new relief road and residential development as part of the wider development plan review. 1.1.3 Based on the current national and local planning context, we consider this site to be suitable for development. Furthermore, the site is of a size and scale to play a role in accommodating the wider overspill of housing need from London and elsewhere within the South East of England. 1.1.4 This representation therefore responds to the content of the draft plan (and relevant supporting documents), reinforces why the site represents a suitable location to accommodate growth and outlines how development could be delivered on site. 2 Site and context 2.1 Site Overview 2.1.1 Our client is promoting land at Hawkhurst Golf Club for residential development and a relief road. The site was promoted via the original Call for Sites process in 2016 (site 115). The site boundary is shown within Figure 2.1. [TWBC: for Figure 2.1 see full representation attached]. 2.1.2 The 20.69-hectare site comprises a nine-hole golf course, formed in 1968 on land on the north western side of Hawkhurst in the High Weald Area of Outstanding Natural Beauty (AONB). 2.1.3 It should be noted that the AONB washes over the whole village, and therefore any development in the area will inevitably be located in the AONB. The need for housing within the AONB has been recognised in recent decisions, including the residential development at Herschel Place. In any event, there are already high levels of screening of the Golf Club site from existing, mature vegetation and views of the site are limited by the topography. Views are typically limited to the adjoining properties, roads and footpaths, and even from there are largely filtered. 2.1.4 The site also incorporates the 2.25ha Springfield Nurseries site, which has been allocated for residential development as part of the AL/HA1 allocation for 40 dwellings in the 2016 Site Allocations Local Plan, prior to which it had also been allocated in the 2006 Local Plan. Planning permission has now been granted on appeal for the residential development of the other part of the AL/HA1 allocation (at Brook House). Planning permission was recently refused on the Springfield Nurseries site (17/02192/OUT), contrary to the Planning Officer’s recommendation to committee. The current draft allocation incorporates the Springfield element of the 2016 allocation within the Hawkhurst Golf Club allocation. 2.1.5 The site is subject to a current planning application (19/02025/HYBRID) for the following description of development: “Hybrid planning application for the demolition of existing clubhouse, squash courts and ancillary structures, and redevelopment of existing golf course. Full planning permission sought for new relief road and associated earthworks and junctions with A268 and A229. Outline planning permission (all matters reserved for future determination) sought for residential development of up to 417 dwellings, a C2/C3 care home, class D1 facilities such as a doctor’s surgery and/or community hall, public car park, public park, and associated parking, servicing, utilities, footpath and cycle links, formal and informal open space and recreation facilities, drainage, ground and infrastructure works”. 2.1.6 Detailed planning permission is being sought for the new relief road, associated earthworks and junctions. 2.1.7 Outline planning permission is being sought for the remainder of the development, with all matters reserved for future determination. Proposed relief road 2.1.8 A relief road was first proposed more than 20 years ago but has never been delivered. This proposal seeks detailed planning permission for a new, public road through the centre of the site which would link the A268 High Street and A229 Cranbrook Road. Combined with the proposals to amend the Highgate crossroads this would effectively result in the A229 being diverted through the site. This new relief road will remove the need for some traffic movements to have to pass through the already congested Highgate crossroads, and will improve the performance of that junction, reducing queuing times. 2.1.9 This significant infrastructure improvement is key to the delivery of additional housing at Hawkhurst to meet the area’s share of the Borough’s overall housing need. 2.1.10 Hawkhurst Crossroads currently operates above its design capacity during both the morning and evening peak periods, with maximum queue lengths of 42 vehicles in the morning peak hour on the Highgate Hill arm of the junction and average delay per vehicle of three-and-a-half minutes. 2.1.11 The operation of the junction will continue to deteriorate in the coming years if nothing is done and background traffic growth and permitted developments in the village and surrounding area (including Cranbrook and Hartley) come forward. Indeed, Kent County Council has recently acknowledged that there are no other viable improvements that can be made to the crossroads in isolation. 2.1.12 By 2033, if nothing is done, peak period queue lengths on both the Highgate Hill and Cranbrook Road arms of the junction will increase to in the region of 100 vehicles, with average delay reaching almost nine minutes per vehicle. This would likely lead to increased ‘rat-running’ on unsuitable rural routes in the area. 2.1.13 With the Golf Club scheme and relief road, the Cranbrook Road closure and other committed developments in and around Hawkhurst in place (assumed to be in 2023 for the purposes of the current planning application), peak period queue lengths would reduce to a maximum of 32 vehicles in the morning peak hour on the Highgate Hill arm of the junction. Average delay per vehicle would reduce to less than two minutes in the morning peak and around two-and-a-half minutes in the evening peak, even with the expected growth in traffic from other developments. 2.1.14 By 2033, average delay at the junction would remain lower than currently. As such, it is clear that the Golf Club scheme and relief road are critical to the delivery of meaningful and much-needed improvements to the crossroads, as well as ensuring that wider housing growth in the area can be satisfactorily accommodated. Other benefits 2.1.15 The proposals also allow for new community facilities to be provided, including an 80-space car park to help to free up space in the existing village centre car parks. 2.1.16 A new public park will also be created in the centre of the development, which will be available to all existing and new residents, but will be particularly easily accessible to residents of Highgate and Gills Green. This will open up the site to public access for the first time. 2.1.17 The largest land use on the site will be residential development accommodating a mix of residential types and sizes and to include 35% affordable housing in accordance with the policy requirements of TWBC. Up to 417 dwellings would be provided. 2.1.18 The proposals would also allow the development of specialist accommodation for elderly residents, either in the form of a class C2 care home or class C3 dwellings designed for older residents (or indeed a combination of the two). 2.1.19 The proposals are for new homes of a wide mix of sizes, including social and sheltered housing. Of these, 383 will be on the golf course land, plus 34 homes on the Springfield site which, as discussed above, forms part of the same current draft allocation (HA1), but which has already been allocated in the adopted Local Plan for housing, giving a total of 417 homes. [TWBC: see also Comment Numbers DLP_6461-6472].
DLP_6465	DHA Planning for Cedardrive Ltd	Support with conditions	Comments on Policy AL/HA1 3.4.1 We strongly support the proposed allocation of Hawkhurst Golf Club for development as proposed in Policy AL/HA1, both in terms of the retention of the existing allocation for housing at Springfield and the new proposals for development on the golf course itself. However, we qualify that support with the following comments. Comment on paragraph 5.93 3.4.2 The fourth bullet point refers to the site including land within the EA’s Flood Zone 3. Whilst this is correct, the area in question is a very narrow strip of land well within the proposed open space buffer zone. The text should be amended to clarify this. Quantum and type of development 3.4.3 We fully support the quantum and type of development set out in the introductory paragraph to Policy AL/HA1. Bullet point 2: Open Space buffer 3.4.4 Whilst the principle of a development-free area is acceptable, we have concerns about the proposed buffer as set out further at paragraph 3.4.8 below. 3.4.5 Amongst other things, the proposed development-free buffer should contain no greater than a 15m buffer adjacent to the ancient woodland in order to avoid placing unnecessary constraints on development. As demonstrated in the current planning application proposals, a greater buffer is likely to be created in various places along these boundaries; however it important that appropriate flexibility be allowed, whilst respecting the need to maintain an acceptable buffer to ancient woodland. Comments on Map 61 3.4.6 It is noted that the key to Map 61 includes references to Safeguarded Land and Community Uses, yet there are no such designations on the plan (as indeed there is no reason for these to be shown on this map). These references should be removed to avoid confusion. Comments on Proposals Map in relation to Policy AL/HA1 3.4.7 For the reasons stated at paragraph 3.3.10 above, we object to the exclusion of site AL/HA1 from the proposed Limits to Built Development. 3.4.8 Part of the site is shown as an Open Space and Landscape Buffer. We have no objection to the general principle of both a minimum 15m buffer to adjacent ancient woodland, and to the creation of an appropriate area of open space to ensure the continued separation of Highgate and Gills Green. However, whilst the principles are generally consistent, the precise boundaries of the buffer area shown are slightly inconsistent with those shown on the current planning application masterplan and could prevent a small amount of development which we consider to be acceptable. We object to this and request that the boundaries are amended so that they are consistent. [TWBC: see full representationattached]. [TWBC: see also Comment Numbers DLP_6461-6472].
DLP_7030	Sally Hookham	Object	Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village. The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “NO” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Non-compliance with Hawkhurst Neighbourhood Development Plan The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. Lack of adequate infrastructure Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is near capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling across fields, footpaths and into the streams, resulting in a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water has recognised that there is insufficient capacity in the public sewer network for this development and the local MP has very recently raised the issue in Parliament. The proposed development would impact unacceptably on an AONB The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development would not constitute sustainable development The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population and employment centres and additional development would therefore simply add to the volume of traffic on local roads, putting more traffic onto unsuitable lanes and adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The proposed development on the golf course would result in the destruction of ancient woodland and large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has objected to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny. Indeed, I believe Kent Highways had serious concerns about the traffic congestion through the village, even before the Golf Course proposal came about. These concerns too do not seem to have been taken into consideration. As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along unsuitable local rural lanes.
DLP_7335	Campaign to Protect Hawkhurst Village	Object	As the Council will be aware there is currently an undetermined planning application before it for the Golf Course site. We attach our representations made in respect of the planning application which apply equally to the proposed allocation. [TWBC: see supporting document attached]. In turn the planning application has received approximately 500 objections. All of these responses should be taken into account and considered by the Council in the context of the DLP consultation. We note, in particular, the strong objection from Natural England. In respect of paragraph 3 of the draft policy it assumes that the relief road will reduce traffic congestion – again there is no evidence before the Council on which this assumption can properly be made. The policy also needs to require the assessment of the impact on the A21 at Flimwell – see our comments regarding the strategic policy. [TWBC: see Comment No. DLP_7334 Policy STR/HA 1]. In respect of the other allocations, the strategic policy is clear that the acceptability of these sites is entirely dependent upon a) the relief road being provided and b) the relief road actually freeing up sufficient capacity at the village crossroads to accommodate the additional traffic generated by these schemes. Given the position of the Highways Authority as articulated in the strategic policy, none of these allocations can be considered to be justified (and therefore sound) unless the Council can be satisfied that either the relief road will be delivered and crucially will actually be effective. If it is not effective all of these schemes will have an unacceptable impact based on the logic underlying the draft policy and therefore be unimplementable. All of the sites will result in the loss of high sensitivity greenfield sites in the AONB. All will provide considerable increased pressure on services in a village wholly unsuited to the level of growth proposed. The additional infrastructure contemplated in the IDP will fail to adequately meet required demand for employment, medical and education services. By way of one example, the combined impact of all the schemes will increase the demand for primary places far beyond the one additional form entry proposed in the IDP. In turn the proposed medical centre is to accommodate the existing under provision rather than meet the totality of future demand. There is also no certainty that sufficient funding will be provided at this stage. This under provision of accessible services will only further increase reliance on the use of private cars given the limited public transport provision – contrary to the objectives of sustainable development in the NPPF and other strategic policies within the DLP.
DLP_7912	Fiona Dagger	Object	Major development is not appropriate in the AONB. TWBC have accepted that Hawkhurst Gold Course is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. The proposal (115, AL/HA1) to build a ’relief’ road through Hawkhurst Golf Course, together with 450 dwellings, constitutes major development in an AONB and should be considered under the sequential test set out in the NPPF, Para 172, the first part of which requires a justification of need, and the third part an assessment of harm. The Sustainability Appraisal score for landscape impact resulting from this allocation is ‘Very Negative’ and confirms the evident harm likely to be done to the AONB as a result of this development. TWBC have not adequately justified the need for this road and associated development as required under NPPF, Para 172, for the following reasons: - The Government’s Science and Technology Committee reporting 22nd August 2019 on policies needed to meet the Government’s commitment to net-zero emissions by 2050 stated that ‘widespread personal vehicle ownership does not appear to be compatible with significant decarbonisation’. The increase in car use which the local plan is seeking to accommodate is not compatible with the Government’s climate commitment, nor is it compatible with TWBC’ climate emergency declaration and aim to make the borough carbon neutral by 2030. Infrastructure improvements in the Plan appear to be dominated by consideration for the private car. Lip service is paid to walking and cycling with no comprehensive borough-wide plan to improve active travel put forward. - The building of the ’relief’ road is justified in the Site Assessment by anticipated noise and air quality benefits to Hawkhurst but this is not evidenced. - The Sustainability Assessment (p. 76), concludes that the air and noise benefits claimed to justify the road would themselves be ‘negated’ by additional traffic generated by this site and other allocations in the village. No analysis of the impact of the 1500+ additional vehicles generated by allocations of 731 new dwellings in Hawkhurst have been shared. There is no secondary school in Hawkhurst, very limited employment opportunities, and the primary school, supermarkets and a GP surgery lie on the opposite side (East) of Highgate Hill crossroads which are already notoriously congested. ‘Active travel’ (walking and cycling) will not be an option for accessing secondary schools or employment. Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?
DLP_8018	Penny Ansell	Object	Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The proposed development on the Hawkhurst Golf Club site would destroy the character of an important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development have simply not been properly considered in the Draft Local Plan. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Placards saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Non-compliance with Hawkhurst Neighbourhood Development Plan As mentioned above the proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. I would repeat Hawkhurst is a village and not an urban area. Lack of adequate infrastructure Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament. The proposed development would impact unacceptably on an AONB The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues, and that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development would not constitute sustainable development The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. It would involve the removal of many mature trees and damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work The so-called “relief road” would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. I would further add that on 24/1019 Mr James Finch Assistant Director - Corporate Services Kent Fire & Rescue Service wrote on the TWBC planning portal regarding his serious concerns for his organisations ability to provide fire and rescue services to the area around Hawkhurst should the Golf Course proposal be granted. When are TWBC planners going to realise what is glaringly obvious to all but themselves that Hawkhurst cannot entertain the numbers of houses being put forward in this ill thought out Draft Local Plan.
DLP_8377	Ms Nicola Gooch	Support	AL/HA1 Hawkhurst Golf Course is a very sensible location for strategic growth; properly designed a residential development here would fit very naturally with the wider settlement and would offer opportunities to secure enhancements to the wooded areas and habitats, which are currently of fairly low ecological value considering the location. Concentrating housing growth on sites such as this, where it can be properly and holistically planned, will reduce the need for in-fill or 'garden grabbing' developments which when viewed cumulatively can pose a greater threat to the character of the area.
DLP_7499	Mr and Mrs A J Herbert	Object	The Draft Local Plan fails to preserve the character of the AONB (which accounts for about 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from development. The Draft Local Plan also fails to reference and draw on the recent recommendations from the DoE’s review of the management of AONB’s. (Glover Review) Specifically in relation to Hawkhurst. The proposed development on the Hawkhurst Golf Club site would severely damage the character of an important Wealden village. It would be one of the largest developments imposed on an AONB and would increase the population of the village by about 20%. The resulting burden would overwhelm local services, which are already under pressure from unplanned development. There is considerable local opposition to the golf club development as evidenced by the number of objections submitted in response to the recent application for outline planning approval. Posters saying “No” to such a development are in evidence throughout the area. The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of this size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. Hawkhurst has already seen a considerable amount of development and the infrastructure and services will not cope. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament. The proposed golf club development would impact unacceptably on the AONB. The CPRE and the High Weald AONB Unit have stated that the proposed golf course development would be inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues - and that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development on the golf course would result in the destruction of large numbers of mature trees. The Woodland Trust has objected to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland. The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore add to the volume of traffic on local and regional roads. When commuting on the A21 there are already serious delays and traffic jams in the morning and evening rush hours. The proposed “relief road” would not provide the benefits which have been claimed for it and is really just an access road to enable the development. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course would severely impact on traffic flows through the village and the surrounding area.

Policy AL/HA 2: Land at The White House, Highgate Hill

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_2422	Rosanna Taylor-Smith	Support with conditions	I fully support the proposal for The White House to be retained as an important Heritage Asset and for some sympathetic residential development adjacent to it, but it seems that planning permissions has already been granted (expected to be by 1/12/2019) for its demolition, and for an enormous 2.5-3 storey building to accommodate 43 retirement apartments in its place. Access is planned directly onto Highgate Hill, further adding to the already over-utilised road network. There seems to have been a complete lack of cumulative assessment by TWBC Planners and KCC Highways when determining the recently determined applications and those currently awaiting determination either by Appeal or Planning Committee. Even when KCC Highways offer no highways objection to particular applications, they should ALL be looked at in the round as the knock on and cumulative effects can be substantial and can result in seriously worse traffic conditions for local residents to endure. Simply requesting Section 106 contributions to bus travel and encouraging cycling does not deliver for Hawkhurst as the roads are too busy and dangerous for cyclists to use on a regular basis, with no cycle lanes or cycle paths within the village, or to link with neighbouring communities such as Cranbrook or Sandhurst, for example. I do however disagree with the proposed road access via Herschel Place -it is a private road and access cannot be provided without serious disruption to the recently established community.
DLP_2611	Jane Pyne	Object	I am not too sure how you can make this statement on the Local Plan and then pass it. This is very worrying that you cannot commit to what you stand upm and say in one breath and then go completely against what you say. This should not have been passed as the residents will need cars. The infrastructure is not here in Hawkhurst.
DLP_3316	Kent County Council (Growth, Environment and Transport)	Object	Highways and Transportation The Local Highway Authority objects to this policy. The cumulative impact of 681-731 new dwellings as a result of site allocations AL/HA 1 to AL/HA 6 and AL/HA 9 will cause a severe impact on the local road network - specifically at the A268/A229 Hawkhurst crossroads, with or without the addition of a new road and the stopping up of the northern arm of the junction as proposed in AL/HA 1. Heritage Conservation Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval. Potential for prehistoric or later remains
DLP_4238	Rother District Council	General Observation	General comment It is noted that contributions for ‘any other highway related works’ are referred to within each of the policies. However, in order for any necessary improvements to the Flimwell crossroads to be secured, it is specifically requested that explicit reference is made to requirement 6 of Policy STR/HA 1 or that its general requirements repeated in some form in each of the site allocation policies to ensure the traffic impacts are robustly considered.
DLP_6023	Tim Stephens	Support with conditions	I support the retention of this old building, it is distinctive and enhances the immediate area. Old buildings hold memories for residents, if they are lost residents lose their connection to an area. Everywhere becomes the same. I do not support the use of the building for apartments for older persons. Where is the evidence of need? There must be sufficient accommodation for older residents with Bowles Lodge and the Babes castle care home. We need a sensitive conversion for young, working locals that is offered as shared ownership. I realise this type of offer may cause issues in this type of building. If not convert to smallish units to provide some affordable units for locals young and not-so-young. But offer as market housing rather than executive style for commuters. We need refurbished accommodation the cost of which matches local earnings. If residents could afford the units that are coming forward they would be more positive and more engaged in the process.
DLP_6390	Hawkhurst Parish Council		Policy AL/HA2 - Land at The White House, Highgate Hill HPC could have supported this policy, which retained the non-designated heritage asset of The White House and provided approximately 15 residential units. However, it would appear that planning permission is likely to be granted for a much bigger application that includes the demolition of The White House.

Policy AL/HA 3: Land to the east of Heartenoak

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_2093	Terry Everest	Object	Object Site is greenfield and requires protection not development, not enough to have a buffer - the whole site is the buffer and should remain so.
DLP_3317	Kent County Council (Growth, Environment and Transport)	Object	Highways and Transportation The Local Highway Authority objects to this policy. The cumulative impact of 681-731 new dwellings as a result of site allocations AL/HA 1 to AL/HA 6 and AL/HA 9 will cause a severe impact on the local road network - specifically at the A268/A229 Hawkhurst crossroads, with or without the addition of a new road and the stopping up of the northern arm of the junction as proposed in AL/HA 1. Heritage Conservation Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval. Potential for prehistoric or later remains
DLP_4239	Rother District Council	General Observation	General comment It is noted that contributions for ‘any other highway related works’ are referred to within each of the policies. However, in order for any necessary improvements to the Flimwell crossroads to be secured, it is specifically requested that explicit reference is made to requirement 6 of Policy STR/HA 1 or that its general requirements repeated in some form in each of the site allocation policies to ensure the traffic impacts are robustly considered.
DLP_6391	Hawkhurst Parish Council		Policy AL/HA3 - Land to the East of Heartenoak Planning permission has already been granted for this site.

Policy AL/HA 4: Land at Fowlers Park

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_852	Thomson Snell & Passmore for Mr Norman, Mrs Ruth McChesney and others	Object	Representations to TWBC re Fowler's Park, Hawkhurst (Policy AL/HA 4) TWBC has included a site in Hawkhurst (Fowler's Park) ("the Site") in its Regulation 18 Consultation draft new Local Plan ("the Draft Plan"), which is being consulted upon in a first round of publication between 20 September and 1 November 2019. The detailed proposals for the Site is set out in Policy AL/HA 4 of the Draft Plan. Briefly, the Site is allocated for residential use (C3) of approximately 100 dwellings, a medical centre or community facility (together with sufficient parking space), and safeguarded land for future school expansion. We are instructed by Mr & Mrs McChesney of Birchfield Grove, Hawkhurst, the road from which any new development at the Site is to gain access. The representations contained in this letter are wholly supported and also represent the views and concerns of the following residents of Birchfield Grove (confirmed in writing, each line representing a separate household): Jean Kinsey Lyn and Don Beverley Raymond Page Hazel and Robbie Fulker Malcolm Snowball Janet Deakin Andrew Macfarlane Irene Poole Eddie Coombs, Janet Clark & Andrew Clark Jennifer Finnimore Lawrence & Sandra Faulkner Judy & Dennis Marshall Gavin Steele and David Veale Sarah & Aaron Greenslade Margaret & Derek Gregory Samantha & Ian Lovett Our clients and their fellow residents have several serious concerns regarding the suitability of the Site for the development which is being proposed in the Draft Plan. As set out in the draft policy, the Site in undeveloped "greenfield" land, it is within the Area of Outstanding Natural Beauty, is rural, comprises an area of Ancient Woodland and contains several Tree Preservation Orders and Veteran Trees. There is some development abutting the Site to the south and west, generally consisting of residential gardens and playing fields. The issues which will be addressed in this representation are: Transport / highways issues Consistency of decision-making with plan-making The earlier decision by the Secretary of State (13/00014) of 14 April 2014 AONB Protection ClientEarth letter, September 2019 Sustainability / future-proofing Housing Supply The Relief Road Transport / highways issues The Site will be accessed through the new development at Birchfield Grove. Birchfield Grove was only constructed very recently, between November 2018 and April 2019, our clients and the other represented persons indicated herein taking occupation of their property between November 2018 and September 2019. The properties in Birchfield Grove were still being sold up to September this year. At no point during the transfer of their property (or, we understand, any of the others on the development) was the possibility of development on the Site mentioned. Whilst it is fully appreciated that this is not a material planning consideration, it goes to the consistency and transparency of cumulative local government decisions and how the failure to hold those principles affects not only the sustainability of the area but also individuals' lives and futures. The Site will cater for, the Draft Plan indicates, about 100 new dwellings. With the average car ownership for a 3-bedroomed house being 2, that number increasing exponentially with the size of the home, this equates to an average (qualified guestimate) of 200 additional cars going through what was expected to be a quiet cul-de-sac by many of the purchasers. Birchfield Grove will be the only point of access for the Site as the consideration of any access from Whites Lane has been restricted by paragraph 2 of the draft policy. Hawkhurst suffers terribly from congestion, rippling back from the busy crossroads in the centre of the village. It is noted that a relief road is proposed in the Draft Plan in the Development Strategy ST1 for the whole borough (paragraph 4) but the details of this are in no way sufficiently advanced (or if they are, they are not yet publicised) to enable any adequate consultation on development which it may 'relieve', taking place. As far as the logistics of the Site itself, on leaving Birchfield Grove, the sightlines both to left and right are poor. The width of the mouth of the road joining Rye Road is too narrow to allow a vehicle to exit safely onto Rye Road if another vehicle is turning in at the same time. Whilst this is manageable in the context of 26 dwellings (that permitted and constructed at Birchfield Grove), the situation would likely become highly dangerous with the number of vehicles associated with the 100 extra houses proposed for the Site, public parking for 15 vehicles and a medical centre with its own parking. It should be noted that in relation to the application reference 19/01299 to build six bungalows opposite Birchfield Grove, KCC Highways and Transportation commented (26 July 2019) that: "Rye Road is a busy distribution route where the last recorded speeds in connection with the development opposite [that is, Birchfield Grove], were in excess of 40 mph." In this context it should be noted that despite the 30mph zone being extended beyond the Birchfield Grove development several months ago, almost all vehicles exiting the village eastward accelerate to or beyond 40mph even before arriving at the Birchfield Grove junction. It is noted that the draft policy AL/HA4, paragraph 11 states that "Confirmation from the highway authorities that there is no objection to the impact of the development at the crossroads at Highgate" is a requirement for any development of the Site. The added volume of westbound traffic from Birchfield Grove would add significantly to pressure on the crossroads already under considerable strain. Although Birchfield Grove is quite short at approximately 130 metres long, it has been constructed with appropriate minimal width and with four curves along its length to give the development a rural character. If Birchfield Grove had been planned as part of a larger development of 126 dwellings, public parking for 15 vehicles and a medical centre with its own (somewhat transient) parking facilities for staff and visitors, which is what it will become if the proposal for the Site goes ahead, such a curved road of minimal width would never have been contemplated. Birchfield Grove is of a width appropriate only to its current size and visitors' parking is limited to space for only two vehicles. While it is appreciated that adjustments could be made to Birchfield Grove by KCC who now control it, these adjustments would amount only to tweaks as they would be constrained by established garden boundaries on one side and common parts on the other. If the proposals for the Site as outlined in the Draft Plan go ahead, Birchfield Grove will become highly congested with through traffic to and from the proposed development. Consistency of decision-making with plan-making In the decision made by TWBC with regard to the development of Birchfield Grove, the applicant's agent agreed to remove any reference to access being maintained to the Site in response to representations made by Hawkhurst Parish Council that there was no future development proposed on the Site. An email from the applicant's agent to the local authority dated 30 March 2017 containing its agreement was published on TWBC's planning portal against application no.16/07797 on 29 September 2017 [enclosed]. It can therefore be presumed by the reasonable observer that it was considered by the applicant and the local authority that there was no element of access to the Site which should properly fall to be considered in the decision-making process for the development of Birchfield Grove. Our clients feel that, if the local authority (as a body) were aware of access being required for any potential future development (either in principle or properly formulated) at the Site at the time that it made the decision in the Birchfield Grove site, that information should have been a material planning consideration and should have been referred to in the material submitted for, and the subsequent decision of, Birchfield Grove. The local planning authority is put to proof regarding the timing of its knowledge of the Site coming forward for development either by way of application or as part of the Call for Sites for the Draft Plan and the decision taken in the Birchfield Grove application (decision notice issued: 29 September 2017). The earlier decision by the Secretary of State (13/00014) of 14 April 2014 Furthermore, a Planning Inspector, in the appeal against the decision of the Council to refuse application no.13/00014 (an application for the development of a larger site at the same location) dismissed an appeal against the refusal of 120 dwellings at the Site for the following reasons: The development would have a materially harmful visual effect on the AONB It would fail to represent the high standard of urban/rural design required by policy The AONB reason over-rode all of the other issues raised by the appellant in terms of housing numbers (the Council could not satisfy its 5yr HLS at that time), its generally sustainable location, the lack of material harm to the biodiverse ecology of the Site, identified and quantified economic, environmental and social benefits to the development, highways issues, drainage problems and the provision of affordable housing, all of which the Inspector felt could be addressed through the planning agreement but none of which would overcome the inherent and long-standing damage that would be caused to the AONB by the development of 120 houses on the Site. AONB Protection Paragraph 11 of the National Planning Policy Framework (the NPPF) states that: "Plans and decisions should apply a presumption in favour of sustainable development. For *plan-making* this means that: plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change; strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, *unless: (0 the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or (ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole."* One of the policies specifically mentioned in the NPPF that "protect areas or assets of particular importance" described in paragraph 11(b)(i) is that regarding Areas of Outstanding Natural Beauty. Paragraph 170 of the NPPF, in particular, states that, "planning policies and decisions should contribute to and enhance the natural and local environment by: protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan); recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland; maintaining the character of the undeveloped coast, while improving public access to it where appropriate; minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures; preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans; and remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate." More specifically, paragraph 172 states that, "Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks. Where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality and the Broads. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major developments other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of: the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated." Where there are sufficiently robust policies in place to counter-balance the presumption in favour of sustainable development, reasons for refusal may be sustained. In the Inspector's consideration of all of the policy factors, nothing outweighed the importance of the AONB, not even a lack of housing supply for the local authority. The importance of the AONB cannot be under-estimated. Once it is gone, it is gone forever; there is no return. The Inspector described the Site as being "part of a network of peaceful, managed, farmed landscape of pasture and open arable fields on the gentle open slopes rolling down from the plateau. The undulating topography of the site plays an important role on the landscape character" and "the undeveloped quality of the site makes a significant contribution to the landscape character". In plan-making (i.e. the allocation of sites for development), a similar approach should be taken, as outlined by the NPPF. The Draft Plan considers the AONB at Policy EN 21, which clearly states, at the first paragraph that: "All development within, or affecting the setting of, the High Weald AONB shall seek to serve and enhance its landscape and scenic beauty, having particular regard to the impacts on its character components, as set out in the High Weald AONB Management Plan." The preceding explanatory paragraphs to the draft policy are also set out below: "6.224 The High Weald AONB covers approximately 70% of the borough and has the highest status of protection nationally in relation to landscape and scenic beauty, equal to that of National Parks. The Local Planning Authority has a statutory duty to conserve and enhance the natural beauty of the High Weald AONB. The High Weald AONB Management Plan 2019-2024 provides the following statement of significance: `Time depth and objective analysis has defined the High Weald AONB as characterised by dispersed settlement, particularly historic farmsteads, ancient tracks and routeways, an abundance of ancient woodland, wooded heaths and shaws with a heritage of woodland industries and iron working and small, irregularly shaped and productive fields. These are all draped over a deeply incised and ridged landform of clays and sandstones with numerous gill streams, and are closely related to socio-economic characteristics that have roots extending deep into history. The essential character of the High Weald was established by the 14th century and has survived major historical events and social and technological changes. It is considered to be one of the best surviving coherent medieval landscapes in northern Europe. This fundamental and largely immutable character is the essence of the natural beauty of the AONB". 6.225 The High Weald AONB Management Plan is structured around the five key components of this character: geology, landform, water systems, and climate; settlements; routeways; woodland; and field and heath. 6.226 The Local Planning Authority will have particular regard to these components in determining development proposals affecting the High Weald AONB and, where relevant, areas of the High Weald National Landscape Character Area that adjoin the designated area." The draft policy, in paragraph 2, then attempts to preclude from itself those sites which are allocated in the draft NLP but which are within the boundaries of the AONB: "Development in the AONB on sites not allocated in the Local Plan will need to be of a limited scale appropriate in terms of its nature and location, and demonstrate a positive contribution to the objectives of the AONB Management Plan..." This statement goes entirely against the rationale behind national policy (the NPPF), the statutory duty imposed upon the LPA contained in section 85 of the Countryside and Rights of Way Act 2000 ("the CROW Act 2000") and also the Draft Plan's own preceding explanatory paragraphs. Whilst it is appreciated that the LPA has discretion when drafting Plans to determine the weight to apply to matters which are given materiality by the NPPF and the PPG, protection for the Area of Outstanding Natural Beauty is required in law by the application of section 85 of the CROW Act 2000. This states at sub-paragraph (1) that: "In exercising or performing any functions in relation to, or so as to affect, land in an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty." It is submitted that by attempting to remove the statutory protection from those sites which are allocated in the Draft Plan, the LPA is acting contrary to section 85 of the CROW Act 2000. ClientEarth letter, September 2019 In response to the letter written by ClientEarth to the LPA putting it on notice of the potential it faces to violate its legal environmental obligations, the Draft Plan must ensure the introduction of "proper" climate change plans, including evidence-based carbon reduction targets which are central to those new plans. ClientEarth describes the need to include carbon targets in local planning policies as a "core objective against which all other policies and decisions will be tested". It must therefore be questioned whether the use of the Site for 100 new houses satisfies the LPA's legal obligation to achieve a net zero carbon footprint for the UK. The LPA must be absolutely sure it can comply, via the imposition of appropriate planning conditions and, more importantly, the strong and targeted enforcement of any breaches of those conditions, with its statutory duty to uphold the law as set out in section 19(1)(A) of the Planning and Compulsory Purchase Act 2004, in that: "development plan documents must (taken as a whole) include policies designed to secure that the development and use of land in the local planning authority's area contribute to the mitigation of, and adaptation to, climate change" Sustainability / future-proofing The government has recently announced the target requirement for the country to achieve zero net carbon emissions by the year 2050. Should these site-specific objections not be successful and the Site be allocated as proposed by the LPA in the Draft Plan, any developer must be strictly required to ensure that the development of the Site achieves this high degree of sustainability and that neither the village, the county nor the region suffers any detriment to its air quality or available amenity land to provide services for future generations of its inhabitants. Housing Supply As mentioned above, the Inspector's decision from 2014 highlighted the importance of the AONB, even over a lack of housing supply. Our clients are fully aware of the need for the LPA to meet the figures set out annually by central government in the Housing Delivery Test, or undertake the consequential actions required where there has been a failure to do so. If the LPA can identify its housing supply, either including this Site or not, at the time of considering the Draft Plan, or at a later date prior to the Examination of the draft policies contained in the Draft Plan then there will be less pressure to allocate sites which are considered unsustainable or have additional designated national protection. It can be seen that much relies on the timing of the coming forward of sites for inclusion in the Draft Plan and also the number of houses being built in the years leading up to a Plan's examination and adoption. Our clients are strongly of the view that in order to satisfy its housing targets, the LPA (a) does not need to include this Site in its allocation; or (b) should consider alternative sites outside Hawkhurst before it over-runs the village with development that it cannot sustain either in the medium- or long-term. The Relief Road The provision of a relief road in Hawkhurst from Cranbook Road to Rye Road/High Street (as mentioned above, referred to in the Development Strategy policy STR1) is only required as a result of the enormous scale of development now proposed in the village and does not appear in the Transport section of the Draft Plan (paragraphs 6.506-6.540; policies TP1-6). Our clients are extremely concerned that it will not relieve the traffic concerns in relation to this particular Site as it is at the opposite end of the village. Its effect will be negligible. Furthermore, it would appear that a proper assessment of the relief road and its effects has not been conducted, or at least not officially reported upon and analysed in order for it to be published as part of the Draft Plan. Until such analysis is available on the real prospects of the relief road benefitting the village, or its surrounding area, and complying with all sustainability principles, the allocation of development sites which it is suggested would be better served by the existence of the relief road, is open to challenge. Conclusion The obvious remedy to facilitate the ability of the LPA to achieve its given target of net zero carbon emissions, to comply with all of its statutory obligations to conserve and enhance the AONB, and to protect any future detriment to the amenity of the residents of Hawkhurst, is to remove this Site from the Draft Plan.
DLP_1549	Mr Derek Gregory	Object	1. The whole of Hawkhurst is within the AONB, and as such the natural beauty of the area must be preserved. Once gone, it will never return. 2. Hawkhurst is a rural area, and not an urban one. The emphasis on additional housing must be in the urban parts of the Borough 3. However, residents of Hawkhurst must listen to the clamour for additional housing from would-be residents rather than speculative developers. To this end small developments up to (say) six dwellings could be welcomed. Any increase above that number would be disproportionate to the local environment. 4. Hawkhurst Neighbourhood Development Plan was accepted by Borough/County and should be complied with. To ignore it is either accidental or deliberate - which? 5. The volume of traffic within Hawkhurst village is legendary, and the X-roads in the centre cannot cope. 6. Largely as a consequence of 5 above, the air quality around that area is almost certainly illegal by current health standards. Village residents should not be exposed to increased pollution (air and noise) by yet more vehicles belching out exhaust fumes in traffic jams. People with chronic lung conditions, my wife included, deserve better than this. 7. Land at Fowlers Park has been earmarked for a possible medical centre and up to 100 houses, accessed via Birchfield Grove. This is a narrow road surrounded by an eco-strip and totally unsuitable for such adjacent development. The houses in Birchfield Grove were marketed as having "stunning views over the countryside" - not looking out over a medical centre, car park and 100 houses. 8. The T-junction from Birchfield Grove into Rye Road is an accident waiting to happen. Line of vision from Birchfield Grove is poor, and traffic in Rye Road rarely adheres to speed limit, partly because of the psychological release from the jam at the traffic lights in the village. Vehicles coming into Hawkhurst are not yet forced to slow down because of the imminent slow traffic they have yet to meet. 9. The "gift" of free land for the medical centre is clearly a bribe in order to gain planning approval on the rest of the land held by the same non-resident owner. 10. Whilst a new medical centre could well be advantageous for the village, this is not the site for it. The Cottage Hospital, the Golf Course or other sites must be reconsidered and a better alternative found.
DLP_2094	Terry Everest	Object	Object Too large, too many developments on green field, should not go ahead.
DLP_2524	Mr Guy Dagger	Object	Major development is not appropriate in the AONB. TWBC have accepted that Fowlers Part is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. Fowler’s Park is coherent historic parkland visibly delineated by Whites Lane which curves to the north of the estate and bounded by a historic routeway (Rye Road) to the South. The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving, i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that benefits would accrue to the AONB by creating a new edge of settlement which bisects the historic parkland. These benefits are not explained. Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?
DLP_2610	Mr Nicholas Justice	Object	Policy AL/HA 4 As an immediate local resident adjacent to this site - apart from the ever increasing gobbling up of AONB that continues, my main objection is the unbelievable access road infrastructure to the proposed new development - in particular the constant access to the proposed new Medical Centre will have a disastrous knock on effect to traffic on the Rye road and road safety in general. For such a large proposed development, surely more than one access point is absolutely essential?
DLP_2613	Jane Pyne	Object	I am very worried about this proposal for a number of reasons. The plan itself is somewhat flawed by putting the proposed school away from the school that there is there at the moment. There should be no reason to not use the existing building as it is fairly new. Therefore the land allocated should be right next door. This can always be used until a school is built otherwise another waste of money. The Medical Centre for this I wonder if they have another proposed site? There is nothing to say that this will go through? They were offered a site down Heartenoak I believe another gifted site. Too far out they cried. I do not think so. There is something not quite right because the entrance to this and the school and the proposed 100 dwellings is through Birchfield and this is beyond all reasoning that the houses were sold with the item about the possibility of being used as the main entrance in a section where no solicitor would normally look. I think this whole practice has a very unsavoury smell to it. On many grounds I will object to this proposition.
DLP_3318	Kent County Council (Growth, Environment and Transport)	Object	Highways and Transportation The Local Highway Authority objects to this policy. The cumulative impact of 681-731 new dwellings as a result of site allocations AL/HA 1 to AL/HA 6 and AL/HA 9 will cause a severe impact on the local road network - specifically at the A268/A229 Hawkhurst crossroads, with or without the addition of a new road and the stopping up of the northern arm of the junction as proposed in AL/HA 1. Public Rights of Way and Access Service Paragraph 3 and 10 are seeking the provision of pedestrian links between the site and PRoW WC187, are supported. Contributions should also be made towards off-site improvements along Footpath WC187 to mitigate the impact of future development. Heritage Conservation Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval There are multi period metal artefacts known from the fields to the north and there may be associated archaeology in the allocation site. There is potential for prehistoric or later remains. In view of the size of this development there may be an impact on the historic character of Hawkhurst as a medieval market town. Consideration of historic landscape issues would be essential In view of the size of this proposed allocation KCC recommends the need for an Archaeological DBA to inform the allocation.
DLP_3453	High Weald AONB Unit	Object	Major development is not appropriate in the AONB. Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of: v) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; w) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and x) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”. TWBC have accepted that development at Fowlers Park is major development but have not explained how the sequential tests required by para. 172 have been met. This policy is therefore, not justifiable. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’. Fowler’s Park is coherent historic parkland visibly delineated by Whites Lane which curves to the north of the estate and bounded by a historic routeway (Rye Road) to the South. The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that “great weight should be given to conserving and enhancing the landscape and scenic beauty” in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The ‘how’, i.e. the conserving and enhancing, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that benefits would accrue to the AONB by creating a new edge of settlement which bisects the historic parkland. We do not share this view.
DLP_3454	Sally Marsh	Object	Policy Number: AL/HA4 Fowlers Park Major development is not appropriate in the AONB. TWBC have accepted that Fowlers Part is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. Fowler’s Park is coherent historic parkland visibly delineated by Whites Lane which curves to the north of the estate and bounded by a historic routeway (Rye Road) to the South. The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving, i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that benefits would accrue to the AONB by creating a new edge of settlement which bisects the historic parkland. These benefits are not explained. Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?
DLP_3797	Mr Peter Jefferies	Object	Policy Number: AL/HA4 Land at Fowlers Park There has been an enlargement of the Limits to Built development in this location, without public consultation it seems. Not only does the plan to provide 100 dwellings on the area allocated look optimistic, unless significant high rise building is permitted, the suggestion that access to Whites Lane by emergency vehicles is seriously flawed. Whites Lane is a very narrow rural byway where opposing direction of travel would prevent urgent passage of vehicles of any type. The proposed closure of Cranbrook Road in the area of the fire station would only exacerbate any problems likely to occur. Additionally any such access would inevitably be subject to abuse given the inexorable rise in the local population were this plan to succeed in its aims; thus reducing further the hoped for benefits of any intended use by emergency vehicles of this particularly narrow byway.
DLP_3845	Government Team Natural England	Object	Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.
DLP_4128	Tunbridge Wells District Committee Campaign to Protect Rural England	Object	CPRE object to this major development in the AONB, which does not appear to be justified under paragraph 172 of the NPPF. Please see our comments already made regarding the AONB concerning other sites in the AONB. Fowlers Park is historic parkland bounded by a historic routeway and there appears to have been insufficient consideration of these aspects.
DLP_4240	Rother District Council	General Observation	General comment It is noted that contributions for ‘any other highway related works’ are referred to within each of the policies. However, in order for any necessary improvements to the Flimwell crossroads to be secured, it is specifically requested that explicit reference is made to requirement 6 of Policy STR/HA 1 or that its general requirements repeated in some form in each of the site allocation policies to ensure the traffic impacts are robustly considered.
DLP_5750	Fiona Clark	Object	I would like to make some comments on the proposals for Hawkhurst within the draft Local Plan published by TWBC and which is now undergoing consultation. Policy AL/HA 4. This is about the land at Fowlers Park which has been earmarked for development for many different uses: 100 houses, a large medical centre / community facility and also protecting land for future school development. I strongly object to this proposal. This land should be left undeveloped. In 2014 a plan for similar development at this same site was dismissed (Planning Inspectorate: Appeal Ref: APP/M2270/A/13/2198919 - Land at Fowler’s Park, Hawkhurst, Kent. Decision dated 14 April 2014.) In his Decision, the Inspector wrote: "53. In this location, the development would be seen as an unacceptable visual protuberance on landscape. This is because of the extent and scale of the development combined with the location of the access road. I find that the development would have a materially detrimental visual effect upon the natural scenic and beauty of this part of the AONB, and it would undermine the open and mainly undeveloped appearance of the site thereby harming features which are integral to the character of Hawkhurst. 54. Taking all of the points in the preceding paragraphs together, I find that the development would have a significant and demonstrable visual effect upon the landscape character of the AONB..." The latest proposal seems to be basically very similar to the previous proposal and so would, just as the previous plan would, "have a materially detrimental visual effect upon the natural scenic and beauty of this part of the AONB", and would destroy the environmental and amenity benefits which I, and many others, currently derive from the land in its undeveloped condition. The extra significantly increased number of vehicles needing to cross the traffic lights and use Rye Road would cause significant increase in pollution, noise and length of time sitting in queues which are already considerable. The natural asset which is the AONB is one which should be guarded and not abused. Once land has been developed it cannot be undone. I therefore urge TWBC to take their responsibilities as guardians of our countryside seriously and to look to other areas as sites more suitable for development.
DLP_5951	Mr Andrew Constable	Object	Comments on specific sites in the plan. We acknowledge that Hawkhurst has to accommodate some development, but it has to be sustainable and in locations that do not have an overwhelmingly adverse impact on the AONB. There are three sites in the draft plan whose scale and location means that they are simply not appropriate: Policy AL/HA4 – Land at Fowlers Park - this site is proposed to be allocated for 100 dwellings. The village cannot cope with this level of development. Alternatives We believe that there is an alternative location that would be more suitable for this scale of development. On the A21 just south of Tunbridge Wells is a roundabout known as Kippings Cross (postcode TN12 7HB). There are numerous reasons why the land adjacent to this roundabout would make an ideal location for further development, including: It adjoins the newly improved A21 allowing traffic to move easily towards London, Tonbridge, Sevenoaks and into Tunbridge Wells. It is close to all the facilities and amenities of Tunbridge Wells, including schools and hospitals. Train stations at Paddock Wood, Tunbridge Wells and Tonbridge are in easy reach. There is limited existing development in the immediate vicinity, so fewer people will be directly affected by the development. [TWBC: See related comments DLP_5946_5949-5952]
DLP_6347	Mr Paul Bristow	Object	I wish to comment on one of the proposals for Hawkhurst, contained in the draft Local Plan published by TWBC, and now subject to consultation. Policy AL/HA 4 allocates land at Fowlers Park for development for several uses: 100 dwellings, a medical centre or community facility, and safeguarding land for future school expansion. I wish to object to this proposed allocation. I propose instead that the land concerned be left undeveloped, and that other sites be found for the proposed uses. (Here is one suggestion: land is already in use at The Moor in Hawkhurst as playing-fields, and there is a building on that site. It must be possible to locate the medical centre or community facility here.) I know that in 2014 the Planning Inspectorate dismissed an appeal against a failure to give planning permission for similar development proposed for this site, and that TWBC confirmed that it opposed the proposed development. (Planning Inspectorate: Appeal Ref: APP/M2270/A/13/2198919 - Land at Fowler’s Park, Hawkhurst, Kent. Decision dated 14 April 2014.) In his Decision, the Inspector wrote: "53. In this location, the development would be seen as an unacceptable visual protuberance on landscape. This is because of the extent and scale of the development combined with the location of the access road. I find that the development would have a materially detrimental visual effect upon the natural scenic and beauty of this part of the AONB, and it would undermine the open and mainly undeveloped appearance of the site thereby harming features which are integral to the character of Hawkhurst. 54. Taking all of the points in the preceding paragraphs together, I find that the development would have a significant and demonstrable visual effect upon the landscape character of the AONB..." While there may be limited differences between the proposal dismissed in 2014 and the latest proposal in the draft Local Plan, it is evident that the latest proposal would also "have a materially detrimental visual effect upon the natural scenic and beauty of this part of the AONB", and would destroy the environmental and amenity benefits which I, and many others, currently derive from the land in its undeveloped condition. Moreover, the pollution and congestion that would result from the greatly increased use of cars in the village by the residents of the proposed additional 100 dwellings would do further damage to the quality of life in Hawkhurst. It seems to me unacceptable for such a valuable natural asset as this land to be wasted for the purposes proposed in the draft Local Plan. I urge TWBC to act as responsible stewards of the countryside, and to look elsewhere for sites for development. Please acknowledge receipt of these comments.
DLP_6392	Hawkhurst Parish Council		Policy AL/HA4 - Land at Fowlers Park HPC has significant concerns about the allocation of this site, which Hawkhurst residents have previously fought hard to protect from development. This includes a very large housing allocation, which does not reflect residents’ wishes for future development in Hawkhurst as outlined in the NDP. HPC recognises that the primary school is already at capacity and understands the need for land to be safeguarded for future school expansion. However, we have concerns over the location of the safeguarded land and feel this would be better placed next to the school. HPC recognises that in order to safeguard the land for the school some development may be necessary. However, if TWBC is still minded to allocate this site following the consultation, then the housing allocation should be much lower given that this is a greenfield site in the AONB. HPC is aware that this is the GP’s preferred site for their new medical practice. As outlined in CM3 of the NDP, HPC supports the provision of a new combined medical practice. The Parish Council’s position has always been that this would best meet the needs of the village if it was located at the Cottage Hospital. However, we appreciate that the GP’s practices are private businesses and they have made their decision based on business grounds. We have been informed that the land for the medical centre has been gifted to the GPs regardless of whether any houses are built. Therefore, we cannot support an allocation of 100 dwellings on this site. We have significant reservations regarding the access to this site through Birchfield Grove. It is not easy to exit Birchfield Grove onto the Rye Road. Using this one road for additional housing, the medical centre and school site would significantly increase the risk of accidents in this location. An independent traffic assessment is required. HPC has recently been made aware of an agreement that ensured access to this site through Birchfield Grove remained hidden from the prospective purchasers of homes in Birchfield Grove until after the development had been sold out. This is extremely worrying. It is interesting to note that in his comments on the Birchfield Grove planning application, the Landscape and Biodiversity Officer raised the concern that the “short section of road to the north between units 19/20 is over engineered.” Allocating this site with this vehicular access would mean that the ecological mitigation area at the boundary of Birchfield Grove will be lost. This policy allocates a sizeable amount of land as “Open Space and Landscape Buffer”. In the circumstances how can TWBC, HPC and the residents of Hawkhurst have any confidence that this will be retained as open space? If TWBC decides to allocate this site, then it is imperative that there is further discussion between TWBC, HPC and the developer to protect this land.
DLP_7053	Sigma Planning Services for Rydon Homes Ltd	Support with conditions	20. This site allocation for housing is supported and Rydon Homes Ltd are bringing a scheme forward to deliver the proposed housing, medical centre and safeguarded land for school expansion. The disposition of uses across the site as shown on Map 64 is deliverable and will be followed in preparing a detailed scheme. The site can come forward in the early part of the plan period and is unconstrained , with all the land necessary to deliver the development being within the control of Rydon Homes Ltd. 21. Highway consultants have been appointed and confirm that the development can proceed without any unacceptable impact on highway safety or severe residential cumulative impacts on the road network. The requirements of Paragraph 109 of the NPPF 2019 are therefore met. In particular there will be no unacceptable impact on highway safety or severe residual cumulative impact upon the crossroads at Highgate and confirmation from the highway authority on this point is being sought. 22. Discussions with the local medical practices with regard to the new medical centre are well advanced. This scheme will provide sufficient public parking for the needs of the medical centre. 23. Matters that need to be clarified/amended/removed from the policy are:- the requirement for 15 additional parking spaces for general public use. Rydon do not currently fully understand how the need for these spaces arises and where they should best be located to meet the need - possibly in conjunction with meeting the needs of the medical centre. the extent of greenspace provision on-site and whether this includes allotments and other forms of formal recreation set out in the list of Criterion 12 and referenced back to Policy OSSR 2. Also whether financial contributions in lieu or compensating areas of informal open space are desirable as alternatives. the route of any footpath link to the centre of Hawkhurst and how this can be best secured. Rydon seek an opportunity to discuss these details with members of the planning policy team to achieve better clarity in the policy when it moves forward into the submission Plan. The development is deliverable during the early part of the plan period, being generally unconstrained and able to make use of capacity in existing infrastructure. [TWBC: See attachment for full response]
DLP_7790	Dr Clive Dewing	Support	I am writing as a career Medical General Practitioner of 34 years standing at Wish Valley Surgery Hawkhurst and a local resident of Hawkhurst (since 1982). My family and I value rural life and would not wish Hawkhurst to be over developed. However, the local plan appears to ask us to accept a large burden of responsibility for housing over the coming years. Supporting infrastructure is vital, even if a proportion of the houses proposed are to be built. This infrastructure would include providing suitable and up to date premises for doctors and support staff to practice in, preferably sooner rather than later. The present surgeries in Hawkhurst (of which there are two) are planning to merge in July 2021 in order to protect general practice provision for Hawkhurst and the surrounding villages served. In doing so we wish to provide better access and increase the local provision of services. A new build would bring young doctors and nurses in training into the village and encourage a new generation of doctors to wish to work in this area over their professional lifetime. This would be in contrast to the present trend for medical staff to be leaving the service in the UK to go abroad. The current buildings where we practice are old and tired and lack the provision required for running a modern medical practice fit for the 21^st century. They cannot be developed further. We have been looking for a suitable site in Hawkhurst over 3 years to build a new facility. An acre of land at Fowlers Park has been offered to us at the end of Birchfield Grove in Hawkhurst. This site is unique and is being offered as a gift by a family who had lived in the village for many years and understand what is at risk. We feel that the area in Fowlers Park is the best available site for our much needed surgery. Access for local people is excellent – the majority of those patients living nearby could be encouraged to walk or cycle to the surgery thereby reducing traffic flow and congestion. We would aim to have ample of off street parking for those that need to drive to the site as well as an appointment system which would stagger patient flow. I am therefore urging the planners as well as the residents of Hawkhurst to support the development of this site which will also include a proportion of the new housing requirement expected of the village over the coming years.
DLP_7913	Fiona Dagger	Object	Major development is not appropriate in the AONB. TWBC have accepted that Fowlers Part is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. Fowler’s Park is coherent historic parkland visibly delineated by Whites Lane which curves to the north of the estate and bounded by a historic routeway (Rye Road) to the South. The impact on the AONB of allocating this site has not been properly assessed. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The conserving, i.e. the ‘how’, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the Distribution of Development Topic Paper, Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for this site set out in Appendix 3. These conclusions suggest that benefits would accrue to the AONB by creating a new edge of settlement which bisects the historic parkland. These benefits are not explained. Permanent grassland, which is the predominant land use on this site, plays a significant role in storing soil carbon and maintaining the resilience of the locality to grow food in the future under a warming climate. On 17th July 2019 TWBC passed a motion which declared a climate emergency and a commitment to ‘Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030’. What scrutiny have TWBC applied to its local plan policies to ensure this commitment is met?
DLP_8297	Programme Director - Local Care NHS West Clinical Commissioning Group	General Observation	The CCG notes that this site is allocated for residential development and a medical centre or community facility, including sufficient public parking to provide for the use of the medical centre/community facilities, as well as 15 additional spaces for general public use. Please see general comments regarding the Hawkhurst Strategy submitted in line with Policy STR/HA 1. The practices undertook an options appraisal and confirmed Fowlers Park as their preferred site. This has been acknowledged and supported by the CCG for the practices to further develop their proposals for this site in line with the CCG Premises Development Policy and Process. The practices have undertaken an engagement exercise to share their proposal and preferred site with patients and the public during August 2019 and September 2019; this included two evening engagement events, attendance at the draft local plan exhibition in Hawkhurst and a patient survey. As plans are developed they will be considered in line with the CCG’s premises development policy and process; this is a three stage process with final approval provided at Stage 3.

Policy AL/HA 5: Brook House, Cranbrook Road

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_2095	Terry Everest	General Observation	Monitor to ensure environmental concerns are fully met onsite and offsite.
DLP_3319	Kent County Council (Growth, Environment and Transport)	Object	Highways and Transportation The Local Highway Authority objects to this policy. The cumulative impact of 681-731 new dwellings as a result of site allocations AL/HA 1 to AL/HA 6 and AL/HA 9 will cause a severe impact on the local road network - specifically at the A268/A229 Hawkhurst crossroads, with or without the addition of a new road and the stopping up of the northern arm of the junction as proposed in AL/HA 1. Heritage Conservation Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval Some potential for prehistoric or later remains.
DLP_3616	Southern Water Services Plc	Support with conditions	Southern Water is the statutory wastewater undertaker for Hawkhurst. 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/HA 5 Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes
DLP_4241	Rother District Council	General Observation	General comment It is noted that contributions for ‘any other highway related works’ are referred to within each of the policies. However, in order for any necessary improvements to the Flimwell crossroads to be secured, it is specifically requested that explicit reference is made to requirement 6 of Policy STR/HA 1 or that its general requirements repeated in some form in each of the site allocation policies to ensure the traffic impacts are robustly considered.
DLP_6024	Tim Stephens	Object	Policy Number: AL/HA 5 Brook House, Cranbrook Road (SHELAA reference: Part of SALP AL/HA 1 and Site 457) Not as another allocation for residential development (C3) providing approximately 25 apartments. Retain as employment to get a better balance between new residential and local employment opportunities to reduce the amount of traffic leaving Hawkhurst for employment purposes.
DLP_6395	Hawkhurst Parish Council		Policy AL/HA5 - Brook House, Cranbrook Road Planning permission has already been granted for this site.

Policy AL/HA 6: Land off Copthall Avenue and Highgate Hill

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_1743	Peter Hay	Object	This is in pacticular reference to 18/01063/FULL (Now subject to an appeal) I am a retired West Kent Police Officer of 32yrs and during my service I submitted many traffic management reports concerning, in the main public safety on the roads. I have grave concerns regarding the junction of Copthall Avenue and Highgate Hill should this proceed. The vision splay is poor and as a result the increase in traffic to an already dangerous situation will, in my professional opinion result in serious injury or even a fatality. There have been a number of accidents at this junction already and the stats obtained by KCC Highways are in inaccurate. They are basing their figures on injury accidents only. Damage only accidents or those not recordable by Kent Police remain unrecorded. Recently a local resident felt the need to jump out of their car in fear of getting squashed by two vehicles at this very junction. Recent Freedom Of Information requests indicates that a large proportion of vehicles are exceeding the speed limit and Highgate Hill is reportedly too dangerous to carry out speedwatch or Police mobile enforcement. Herschel Place which is on the opposite side of Highgate Hill has a large vision splay with two way in and out for 62 houses whereas Copthall Avenue is a single carriageway and would have to cope with over 80 houses with a far smaller splay. In comparison to Herschel Place it is my view the junction would breach the Kent Design Guide and thus making the access totally unsuitable. It appears no vision splay assessment has been carried out for the junction of Copthall Avenue and Highgate Hill. This is paramount to road safety. The emergency access route is a shared track and I do not believe it is reliable enough to be a backup emergency access to the whole site. 1 week before the last proposed planning meeting a further proposal has been accepted to have virtually the entire length of Copthall Avenue (both sides) marked out with double yellow lines. This is so unacceptable and totally unfair for residents who have no driveways to be expected to now find another street to park their cars in. This is itself suggests the road is not suitable for the extra traffic. It is my belief this also breaches the Kent Design Guide PPS3 Section 51 Supplementary Guidance – Residential Parking and has not been factored in to this application. A separate petition has been submitted in relation to these yellow lines with over 600 signatures. Freedom of Information requests requested by me to TWBC Parking Wardens and Kent Police indicates that enforcement would be virtually non-existent. This development does nothing to help the local residents of Hawkhurst and makes a mockery of the NDP. The design will only generate further urban sprawl. The whole difficulty in Hawkhurst recently is that KCC have ducked the issue of assessing the cumulative impact of all these “small” schemes together. Their consultation responses literally say this is too “difficult” so they don’t even try (or require the Developers to carry out the assessment). This enables each developer to simply say their scheme in isolation won’t make that much difference… this is all in despite of an e-mail in which came from KCC Highways 4/9/17 vowed to oppose all future development in Hawkhurst because the effect would be severe on the notorious traffic light junction of the A268 and the A229 in the middle of the village. Since this date this has been ignored and now subject of a formal complaint to the Ombudsman. They therefore box themselves into a situation where they can’t object because they are petrified of defending their position on appeal! Furthermore, the impression given is that KCC’s main concern is an adverse costs award on appeal. This risk is being overstated. Costs in planning appeals are awarded very rarely and there are plenty of examples of appeals being dismissed on traffic congestion grounds even when there is a housing supply shortfall. KCC have previously been clear that they would not support any additional dwellings in Hawkhurst over the Core Strategy figure of 240 units. They made this clear at the time of the last Core Strategy Review and Site Allocations DPD examination in public. They then issued their position statement (I think almost two years ago) making the same point which was quickly withdrawn. That figure has now been considerably exceeded and no alternative solutions have come forward. It is not that difficult – all it would take is for them to require each individual developer to assess the cumulative impact assuming all the schemes come forward in their Transport Assessment. They would then have the information before them to consider! By failing to do this they are enabling each developer to salami slice the impact down to what they consider to be acceptable chunks. KCC have failed at all stages on all of these applications to consider the cumulative impact of all the schemes on the crossroads. Their standard consultation response simply says “No mitigation scheme has been identified” so we’ll just request investment instead to try and make things better. Why not look at the real picture – people just will not use bikes or buses! Furthermore, the Secretary of State quoted in appeal ref APP/U2235/A/2227839 BDW Trading Ltd section 16 stated the he shared the views of the Inspector that “little reliance can be placed on the proposed highways contribution as a means of mitigation (IR237) and he too concluded that the proposed developments severe traffic impact would not be effectively mitigated (IR239) “ Referring also to the site allocations development consultation draft report 18 March – 24 May 2013 I quote “The Borough Council has not received any objection to proposed development in Hawkhurst from Kent County Council Highway Authority, which is responsible for advising the local planning authority on highway capacity and safety. The Site Allocations DPD meets the development growth set out in the adopted Core Strategy and it has been accepted that the highway capacity can accommodate this growth” KCC should stand up and tell all developers for Hawkhurst that until there is a workable BYPASS (not relief road) around Hawkhurst there should be no more building of major developments. Should this develpoment pass the appeal stage a further appeal will be submitted in respect of the TRO (Double Yelow Lines) that could be destined for Copthall Avenue. I wish to strongly object to this planning application for the reasons detailed below. When I purchased my house in 2001 I did so partly based upon the quiet and secluded nature of Copthall Avenue and as such paid a premium price for this. However over the years this has slowly disappeared to such an extent that the traffic in particular has increased 10 fold. I have photographic evidence to show the lack of traffic even in 2009 compared to 2018 My point is that this proposed development is too intensive and would increase current traffic flow to such a level that Copthall Avenue is not suitable and therefore unable to sustain. As it is there is somewhere in the region of 60+ cars shared between 28 properties in the Avenue which works out to at least 2 per household. By building a development of 50 additional homes will surely generate somewhere in the region of an additional 100+ vehicles and as such a huge increase in traffic flow in a narrow road. Road Design: Copthall Avenue is only 4.9m wide along the entire length and along this road are numerous cars (in general) parked by residents some of whom have no off road parking and as such park strategically in places to facilitate the ingress and egress of vehicles to and from driveways safely. However visitors to Copt Hall and other dwellings are not so careful about parking which does cause at times difficulties in manoeuvring in the Avenue and can cause congestion and sometimes complete road blockage. In fact the road is often blocked be it for short periods by delivery vehicles, (photographic evidence available), which brings me on to the point of emergency access. Site Access and Public Safety: Copthall Avenue at its junction with Highgate Hill is my biggest concern. Quite simply the junction is barely able to cope with current traffic flow. It is more common than not for two cars or more to meet at this junction as a result of which is causing a danger to road users. In fact it is not possible due to the junction design for 2 vehicles to enter or exit Copthall Avenue at the same time. Again, I have photographic evidence to support this. Because of the tight right angled turn, vehicles either have to drive over the footpath or queue back up Highgate Hill until one or the other has either come out of the Avenue, or the other reverses back along the Avenue to allow the other in which can be some considerable distance at times. Where there is more than 1 vehicle involved in a queue on Highgate Hill this then causes a further dangerous situation especially for vehicles who want to turn right up Highgate Hill. One can then be faced with yet another danger of drivers overtaking waiting vehicles in Highgate Hill. There have already been a number of accidents at this junction in recent years and it will only be a matter time before the accident rate will increase and someone gets seriously injured. Highgate Hill itself has now become a busy road and once the development at Herschel Place is completed it will increase yet further. In addition, as it stands currently, it is my view that Copthall Avenue at its junction with Highgate Hill does not comply with the current Design Manual for Roads & Bridges as published by the Department Of Transport so any significant increase in traffic would breach this further. Quote: Junction Design Junctions are generally required at intersection points where roads meet each other. Most junction arrangements take the form of some kind of priority junction, either ‘T’ types, staggered types or crossroads which are normally appropriate where traffic flows, particularly to and from minor roads, are relatively light. Where traffic flows are heavier or road layouts are complex, other types of layout or control measures are generally required to reduce the accident risk and to balance or improve capacity. Where a residential road joins a distributor road, a road width of 5.5m should be maintained for at least 20m from the junction, with footways provided on both sides of the non-priority road. No other access or road junction should be provided within this 20m distance It has been noted that a recent decision by KCC to place double yellow lines on the Western side of Highgate Hill south of and opposite Copthall Avenue is in itself an admission of the dangers surrounding the entry and exit of Copthall Avenue. It is also my belief that additional traffic use will at some time cause a significant delay for emergency vehicle and with vehicular parking along the Avenue with additional cars moving up and down the road could cause a serious delay in emergency vehicle access. This in particular would be hindered by the main entry / exit in and out of Copthall Avenue into Highgate Hill. Copthall Avenue is also used extensively by parents and young children walking to school daily on what is already a narrow footpath and as such will be an increase in danger to these pedestrians. Parking: Movement of traffic: It is clear that Dandara acknowledge an access issue by trying to appease the planning department by way of suggesting “rationalised parking” i.e. line marked parking spaces to help traffic flow. Dandara state it would mean the painting of lines over the road and marking out specific parking spaces. This is an outrageous situation for residents to be told where to park their cars and should not be entertained. No residents have ever been approached for input on what “works” and “does not work” In any event, unless there are specific parking orders created by statute then this is not enforceable, will never be adhered to and over time the lines would disappear , no-one would take responsibility and situation normal would return. I am not aware of any other roads in Hawkhurst or in fact anywhere that have to be marked out to help traffic flow as a result of a building development. This in itself is an admission that there is no room. It is also Dandara’s plan to try and get double yellow lines at the junction with Copthall Avenue and Highgate Hill. This will not make any difference to the already bad situation although it may help the current situation. The road/junction is simply not wide/big enough. In any event, again the parking controls would not be enforced. Data obtained under the Freedom of Information Act shows that for the whole of Hawkhurst, only 76 tickets were issued in 2017 and none were outside of the centre of the village. No tickets issued by Kent Police in 2015, 2016 or 2017 with regard to obstruction offences in the past 12 months despite there being many offences of this type witnessed around the village in similar situations so if any incidents of this nature occur which they will, it is clear they will not be dealt with. In addition I do not believe the visibility splay is sufficient for the increase in traffic both in Copthall Avenue and Highgate Hill. To get any reasonable vision on traffic you have to approach the junction in the middle of the road to get a sufficient view in both directions. This then reduces the vision for drivers emerging from Copthall Avenue to see traffic travelling down Highgate Hill in a southerly direction. Any significant increase in the use of this junction will become a danger. As it is traffic speed in Highgate Hill is increasing. In fact, the fastest recorded speeding offence recorded by the Community Speed Watch was in Hawkhurst – 77mph in a 30mph limit! I also understand that no speed checks can be carried out close to the junction of Copthall Avenue and Highgate Hill as it is reportedly “too dangerous”! (I am also awaiting further data relating to speed of vehicles under the FOI Act recorded in Highgate Hill/Moor Hill areas where conducted.) I would also like to quote the below sections of information which I think is relevant to this application and must be considered. Residential Parking – Kent Design Guide Nov 2008 It is no longer acceptable for those involved in the development control process to cite residential parking ‘standards’; rather, it is important that a range of factors should be considered before determining the appropriate levels of parking. Care needs to be taken in these situations to ensure that the reasonable needs of visitors are catered for, even if only in nearby public car parks If on-street controls are needed to support the chosen approach to parking provision, these must be considered in relation to any potential for parking in neighbouring streets. Environmental Impact: Furthermore, a development of this size will generate a huge amount of heavy vehicles, including HGV’s all of which will have to negotiate access for many months and it is my view will cause huge problems and danger for road users and residents and will probably destroy the road surface and probably damage parked cars in the process. It is also clear that there will be a huge destruction of grassland that is home to a considerable amount of wildlife including Buzzards, Owls and Bats and as the plans appear to show the houses being sited very close to a public footpath, there could also be an environmental impact on adjoining land too. As it is I understand that another nearby housing development at the old Woodham Hall site has already caused a family of Buzzards to move out and seek a new home following the destruction of trees. In addition, I see no evidence in the planning application that any effort has been made to survey the area for wildlife and/or protected species. My garden backs onto the locality and regularly I hear and see Bats and Owls and I have no doubt they use this area for feeding. There are also signs of routes used by Badgers. In accordance with Schedule 3 Town & Country Planning Regulations 2017 it is my belief that this project falls within a “sensitive area” and thus should require and Environmental Impact Assessment. Conclusion: It is obvious to me that yet again the main outcome is GREED by the developers. Hawkhurst is already at its capacity for traffic and already reached its allotted homes up to 2026 and apart from this there are a number of large home developments already close to completion. Diagonally opposite the entrance of Copthall Avenue is a further 63 houses being built so another 50 in such close proximity will no doubt have a massive impact on the local residents, increase traffic chaos and destroy wildlife and Hawkhurst in general. I have also had considerable experience with Kent Police with regard to traffic management and I seriously feel that the increase in traffic with a junction that cannot support it will result in a high risk chance of serious injury or even death. There are even plans for yet a further development off Copthall Avenue which will exacerbate the situation! It is quite clear that the developers have not demonstrated a safe and suitable access. The planning department should be less reactive but more proactive in looking for sensible land for additional “affordable” housing, not destroying the countryside and allowing developers to squeeze as much as possible in the a small area just because it “may comply with planning law”. What about the environmental impact and that of local residents. Otherwise why don’t we just ditch planning laws and fill in all the green land with as many houses as possible. Extract from Hawkhurst Neighbourhood Development Plan Over the last ten years, Hawkhurst has shown a willingness to accommodate new development. Only 35 additional units were required to be built between 2015 and 2026 in order for the parish to accommodate the target of 240 housing units set for it by Tunbridge Wells Borough Council. The successful planning appeal in September 2015 to build 62 properties adjacent to Highgate Hill means that the parish will now “over-deliver” by 11%, or 27 houses up to 2026 (as at November 2015). Once they are built, there is no turning back! NOTE: I also have a mains sewer that runs deep underground between my property and that of my neighbour and as such need to know if this is in any way going to be connected with this development (should it progress against objections) as it has been subject of blockage in the past and any increase in additional waste further down the line may cause an issue further up the line! Now that TWBC have agreed a s106 agreement for double yellow lines it is my belief this also breaches the Kent Design Guide PPS3 Section 51 Supplementary Guidance Residential Parking. This has not been factored in to this application. As previously reported by the head of planning in the 1st March 2019 in a smaller development nearby (also entering the A229), this proposal does not demonstrate that safe and suitable access to the site can be achieved for all users. It has also failed to demonstrate that significant impacts from the development on the transport network (in terms of capacity and congestion) can be mitigated to an acceptable degree through public transport enhancements. It is thereby in conflict with Part 9 of the National Planning Policy Framework 2018, and saved policy TP4 of the Tunbridge Wells Local Plan 2006. The proposed development also fails to demonstrate safe, suitable and sustainable access for all and would be likely to increase hazards on the highway. The proposed development therefore fails to comply with the National Planning Policy Framework 2018, paragraphs 108, 109 and 110 inclusive. As previously reported on another nearby development by KCC Highways, the visibility splays Copthall Avenue/Highgate Hill are insufficient for 80 dwellings where 85th percentile speeds are in excess of 37mph and as already stated previously breach Highways Regulations Design and likely to be higher at this point. In response to KCC Highways report dated 26th February 2019. The junction of A229 and A268 will never be improved unless a ring road is built and that will never happen. The nearby development at the Golf Course will not benefit either as it is NOT a relief road but a layout change and traffic congestion will be as severe as it is now. In fact it will probably be worse. The comment about sweep paths at the junction of Copthall Avenue and Highgate Hill is still inaccurate. The manoeuvre can ONLY be carried out if the HGV/Refuse lorry crosses the centre line and uses the whole road to reverse into Copthall Avenue. Clearly KCC have not shown any consultation has been made with the local refuse collectors. If they had they would have been told of the issues. Other planning applications have indicated this is NOT acceptable on a busy A road to have to cross the centre line in similar circumstances. Whilst I appreciate TRO's are now require before any construction commences, it will not help the problems faced at this time or in the future. It is the narrowness of the junction whether cars are parked there or not that makes access in and out a danger. Sufficient warnings are now in place. As explained in my comments to TWBC to date, in line with NPPF (2018) paragraph 109 the impact of this development cannot be deemed 'severe': Paragraph 109 states: Within this context, applications for development should: a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second - so far as possible - to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use; b) address the needs of people with disabilities and reduced mobility in relation to all modes of transport; c) create places that are safe, secure and attractive - which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards; d) allow for the efficient delivery of goods, and access by service and emergency vehicles; and e) be designed to enable charging of plug-in and other ultra-low emission vehicles in safe, accessible and convenient locations. My response to this is as detailed below: Reference to paragraph 109 of NPPF is meaningless and you have not shown it to have been means tested - it is merely a "comment" which is open to interpretation and you have just not grasped the severity that many of us are putting forward with regards to the junction of Copthall Avenue and Highgate Hill. However Paragraph 110 is and does apply in particular section c) + d) below and probably a) and b) too a) There is no evidence that any improvements will be made to the current public transport service and it is a fantasy to expect any facilities that will encourage the use of. b) The footpath of Copthall Avenue is not wide enough on either side for people with disabilities especially when using walking aids and or scooters. c) The entrance/access via Copthall Avenue j/w Highgate Hill WILL breach Kent Design Standards. d) The same junction does not allow for efficient access to emergency vehicles in the scale of development - (no efficient backup/2nd access) I find it quite incredible that KCC have no grounds to object to the access via Copthall Avenue/Highgate HIll junction. They report developments should be refused on two grounds, one of which is the impact on Highway Safety. It is quite obvious they have not visited this site and experienced the dangers like I and many others have commented on. They claim there is no back up crash report data and yet the Transport Assessment attached to this application shows there is dated 23/7 so they have clearly either not looked or ignored this entry! Also, crash report data relies solely on Police reports so if there are accidents that are non injury and or non recordable by Police then this will not show up in crash report data making it totally unreliable. (I know this for a fact being a retired Police Officer) Therefore crash report data can't be the sole option to make an assessment on road safety. I also find it equally amazing that KCC are happy to allow HGV's to destroy the footpath and kerbs at the entrance to Copthall Avenue (BECAUSE IT IS TOO NARROW!) - what about pedestrians?? are they going to have to accept a risk of injury as a result. For residents and other motorists to have to put up with this ridiculous situation is quite unacceptable. It will be total chaos and KCC would have washed their hands by this stage. I am also "concerned" about KCC allowing the developers to take a piece of KCC Highway Land outside Russett Cottage to facilitate access. KCC needs to be transparent in this "agreement" Finally, the Kent Design Guide is quite clear in regard to junction design and it appears that KCC Highways are condoning a breach of this guide if they choose to accept there are no problems with the Highgate Hill/Copthall Avenue junction. Further to my previous comments I would like to add if not already clarified that in my view the proposal is not considered to be a sustainable development, and the adverse impacts of the development would significantly and demonstrably outweigh the benefits. Due to the location of the site and the nature of the routes to facilities, future residents are likely to use private cars for the majority of trips, which does not support the move to a low carbon future as required by para 95 of the National Planning Policy Framework. TWBC: see images attached
DLP_2096	Terry Everest	Object	Object Site is green field and development would constitute suburban sprawl and encroach on woodland and green space. No go.
DLP_2423	Rosanna Taylor-Smith	Object	I object to the further development behind Copthall Avenue for access reasons - Copthall Avenue is a narrow residential road which can barely accommodate refuse vehicles or fire engines, large HGVs, etc. The junction onto Highgate Hill is narrow and the visibility is poor without exiting onto the road to get a good view. The area is subject to numerous underground waterways and is a vital green gap or green wedge with important areas of woodland.
DLP_2526	Mr Guy Dagger	Object	Major development is not appropriate in the AONB. TWBC have accepted that Copthall Avenue is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. This area is a sensitive area of grassland buffering an important area of species rich grassland to the East. The fields are associated with the historic farmstead of Cockshott and form its setting. This combination of features provides a characteristic green gap between Highgate Hill and the Moor which would be compromised by this development.
DLP_3320	Kent County Council (Growth, Environment and Transport)	Object	Highways and Transportation The Local Highway Authority objects to this policy. The cumulative impact of 681-731 new dwellings as a result of site allocations AL/HA 1 to AL/HA 6 and AL/HA 9 will cause a severe impact on the local road network - specifically at the A268/A229 Hawkhurst crossroads, with or without the addition of a new road and the stopping up of the northern arm of the junction as proposed in AL/HA 1. Public Rights of Way and Access Service Contributions should also be made towards off-site improvements along Footpath WC189 to mitigate the impact of future development. Heritage Conservation Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval Site contains some post medieval brickworks and substantial industrial structures may survive on site. Archaeological DBA would be appropriate
DLP_3455	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_3459	Sally Marsh	Object	Policy Number: AL/HA 6 Copthall Avenue and Highgate Hill Major development is not appropriate in the AONB. TWBC have accepted that Copthall Avenue is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. This area is a sensitive area of grassland buffering an important area of species rich grassland to the East. The fields are associated with the historic farmstead of Cockshott and form its setting. This combination of features provides a characteristic green gap between Highgate Hill and the Moor which would be compromised by this development.
DLP_3541	John Charles Ball	Object	We have had an exhausting time objecting tot he Copthall Avenue access route and we can only repeat all of those objection again. The junction of Copthall Avenue and Highgate Hill has poor vision splay. The speed date is unrecordable due to the danger for Community Speedwatch. Herschel Place, by contrast, has a large vision splay for 62 houses that is denied to Copthall Avenue for 80. There are concerns that the single track access to the development for emergency vehicles is contestable and there is insufficient width in Copthall Avenue for emergency vehicles to proceed safely. Residents were served a last-minute amendment to the application for double yellow lines both sides of the road. This loss of amenity for properties in the Avenue who have little or no parking is unacceptable. The parking provision on the Dandara development being limited and residents on Highgate Hill already using spaces in Copthall Avenue for overspill parking would create undue pressure on parking spaces in the road for all. As the relocation of the community amenity Copthall is a long way off the lack of parking users of the hall would also be a significant problem. Hall users in the main are elderly and families who are all reliant upon car use. There are no traffic wardens to monitor the double yellow lines in any case. The cumulative impact of Herchel's Place, Copthall Avenue and Highgate Hill should be properly assessed so that the impact at the junction of the A268 and A229 is full calculated. If the two sites combine and vent onto Highgate Hill the traffic situation will be just as bad but Copthall Avenue residents the safety of pedestrians preserved. I am concerned that in order to facilitate the Westfield Site KCC Highways have offered to chop into the verges of a historic street scene to provide parking and turning space. Will KKC Highways stop at nothing. They have already included within the Fieldways application a piece of highways land that any other commercial enterprise would consider a ransom strip. This is not maximising our community assets. We will repeat again that road width restrictions do not allow for manoevres in and out of driveways in modern cars without sweeping the front bumpers across the footpath opposite. Residents are careful about parking so as to not inconvenience neighbours. It is not reasonable to reduce the parking provision for residents to facilitate this development. If 2 vehicles meet at the entrance to Copthall Avenue one has to give way to the other causing disruption to the flow of traffic on Highgate Hill. Impatient drivers will attempt to overtake conflicting directly with traffic coming up the hill. Traffic aiming to turn right into Copthall Avenue cause congestion as they are waiting alongside residents parking on Highgate Hill. Turning left into Copthall Avenue requires a driver to take a wide line to the road centre on Highgate Hill. Turning left into Copthall Avenue requires a driver to take a wide line to the road centre on Highgate Hill to avoid kerbing the entrance. There are 2 bus stops in the same vicinity with groups of school children at peak times. I can't imagine how approximately 2 years of heavy vehicles serving the development will safely enter and exit the site without damaging the road surface and vehicles and road users of all types. The footpaths on either side of Copthall Avenue are in places as little as 60cm wide and are cluttered with telegraph poles Without an environmental study on the site, only residents can explain to you the amount of wildlife that is routine witnessed in the green space that Dandara and Leander intend to build upon. Displaced wildlife from Woodham Hall has taken up residency. I am concerned that filling in the green space between the 2 distinct areas of the village will erode the character of the village. When we bought our property in 2001 because our boundary on the southern side was the LBD. There are no mitigating circumstances to excuse the destruction of this countryside. These properties are not for local people, they will not be 'low cost'. Seweerage problems deep in the valley have already been commented upon. There are also grave concerns for displaced water into the valley and their impact on historic properties. Copthall Avenue has springs and watercourses popping up along its breadth since there was development above and residents of Fieldways are dealing with water issues from the Woodham Hall site. It seems as if no one can predict the course of water and planners have been slow to use their powers to get developers to make amendments. Everyone seems very proud of creating 'green spaces' within these communities but handing the maintenance of these spaces over to the residents via a management company is flawed and we do not have a police force capable;e of controlling the behaviour of the present population so it is unlikely that we will have the support that we need going in to the future.
DLP_3617	Southern Water Services Plc	Support with conditions	Southern Water is the statutory wastewater undertaker for Hawkhurst. 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 79 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/HA 6 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 Hawkhurst. 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/HA 6 Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes
DLP_3847	Natural England	Object	Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.
DLP_4129	Tunbridge Wells District Committee Campaign to Protect Rural England	Object	This proposal for major development in the AONB does not appear to be justified under paragraph 172 of the NPPF
DLP_4242	Rother District Council	General Observation	General comment It is noted that contributions for ‘any other highway related works’ are referred to within each of the policies. However, in order for any necessary improvements to the Flimwell crossroads to be secured, it is specifically requested that explicit reference is made to requirement 6 of Policy STR/HA 1 or that its general requirements repeated in some form in each of the site allocation policies to ensure the traffic impacts are robustly considered.
DLP_4687	CBRE Ltd for Dandara Ltd		Land off Copthall Avenue and Highgate Hill, Hawkhurst 4.118 The site is comprised of fields and wooded areas, located to the south of Highgate. The site is adjoined to the north and west by residential properties, and to the east and south by fields and paddocks. In terms of access, the site includes a dwelling on Copthall Avenue, and a secondary access to Highgate Hill. A Site Location Plan is included in Figure 7 below. [TWBC: for Figure 7 see page 32 of full representation attached to Comment Number DLP_4614]. 4.119 The site (site ref. HA6) is allocated for residential development, for approximately 70-79 dwellings, as well as areas of publicly accessible open space. The implementation of this development will require assessments in relation to highways impact. 4.120 Land to the west off Copthall Avenue and Highgate Hill, Hawkhurst was assessed as part of the Strategic Housing and Economic Land Availability Assessment in July 2019. The assessment concluded that the site is a sustainable location for development, given it is located within/mostly adjacent to the Limits to Built Development and there is a pedestrian access to the centre of Hawkhurst. In addition, the assessment noted the availability of the site and that it is deliverable within the Plan period. Dandara supports the findings of this assessment and the proposed site allocation. 4.121 The site comprises primarily flat agricultural land, located in Flood Zone 1 and within the High Weald AONB. The site is well situated close to Hawkhurst and is an ideal location for a sustainable extension. The site itself is suitable for residential development (as concluded by TWBC in their SHELAA (July 2019), factoring in its flat topography, sustainable location and good access off Highgate Hill. 4.122 Hawkhurst is identified as a rural service centre as part of the proposed settlement hierarchy in the Draft Local Plan (Policy ED8). New development is directed to primary regional town centres (Royal Tunbridge Wells) first, then town centres before rural service centres. Hawkhurst as a key service centre is identified in the Draft Local Plan (paragraph 6.480) as being suitable for the main focus of town and rural centre uses (existing and future), the existing character and form of development, the visual, physical, and functional relationship between areas, and the potential for appropriate development opportunities. 4.123 It is further noted that in TWBC’s growth options, Options 1 and 2 place significant onus on Hawkhurst for new growth. Hawkhurst is considered to be spatially appropriate in respect to the settlement hierarchy identified above, and a suitable, accessible and sustainable location for growth. 4.124 The site is available now and can be delivered early as there are no barriers to delivery. 4.125 Dandara is promoting the site for residential development and is currently undertaking further site capacity and feasibility analysis at this stage. Dandara made an application in March 2018 (LPA ref. 18/01063/FULL) affecting part of the allocation for: “Demolition of a 1no. dwelling house and agricultural storage barn to the rear and erection of 49no. dwellings including car parking, cycle parking, sustainable drainage, internal road network and the creation of a new access with associated landscaping”. 4.126 A site location extract is shown below in Figure 9 and confirms that the application comprises the majority of land within site allocation AL/HA 6. [TWBC: for Figure 9 see page 34 of full representation attached to Comment Number DLP_4614]. 4.127 This application was refused in April 2019 despite an Officer recommendation for approval. The scheme was refused by Members at committee for one sole reason based on highway grounds despite KCC Highways Authority agreement that the proposed access was acceptable: “1. The access arrangements and highway mitigation for the proposed development would amount to poor design that would equate to harm to the area and the way it functions contrary to paragraph 130 of the National Planning Policy Framework 2019”. 4.128 An appeal has subsequently been submitted; Dandara’s appeal case demonstrates that the proposed access arrangements and highways mitigation are appropriate, and highlights that there was no objection from KCC Highways Authority. It should be noted that the proposed access to the site allocation is different to the proposed access arrangements subject of the above appeal. 4.129 In terms of the impact on the AONB, this too has been considered through the planning application. In accordance with paragraph 172 of the NPPF, significant weight should be placed on conserving and enhancing protected landscapes including the AONB and requires applications to meet the below tests: a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated. 4.130 In relation to the site’s location within the High Weald AONB, it is noted in respect to planning application LPA ref. 18/1063/FULL that the proposed layout and design was deemed acceptable as set out at paragraph 10.53 of the Committee Report: “the design and layout of the scheme is considered to be well thought through and evidenced by assessments of the locality and the characteristics of the site. It is considered that this would achieve a high quality appearance and character to the scheme which is fundamental within this AONB location and raising the bar in terms of new development delivered within the sensitive landscape of the AONB.” 4.131 It was further confirmed at paragraph of 10.81 of the Committee Report that “the Council’s Landscape and Biodiversity Officer considers this scheme to be an exemplary one that may provide a benchmark for others who wish to develop in the High Weald AONB”. 4.132 More recently, an application for the remaining part of allocation AL/HA6 (remaining area to the north) was made by Leander Homes in May 2019 (LPA ref. 19/01253/FULL) which is currently pending consideration and comprises: “Erection of 31No. residential dwellings and the retention of existing Westfield property. Provision of altered access on to Highgate Hill, associated hard and soft landscaping, retained woodland area and sustainable urban drainage systems (SUDS)”. 4.133 In order to ensure that the site allocation is in accordance with the NPPF (paragraph 35) tests of soundness; positively prepared, justified, effective and consistent with national policy Dandara have provide the following comments in relation to this site: Policy STR/HA1: ‘The Strategy for Hawkhurst Parish’ - Dandara notes the following: 4.134 Dandara supports growth at Hawkhurst as a sustainable location in the settlement hierarchy and allocation AL/HA6. This section specifically addresses Dandara’s comments in relation to Policy STR/HA1. 4.135 Paragraph 3 of Policy STR/HA1 states that for developments expected to be delivered before the Hawkhurst relief road is fully operational, the applicant will be required to demonstrate with clear evidence that there is sufficient capacity at the Hawkhurst crossroads (junction of A229 and A268) to serve the proposed development. 4.136 In reference to planning application LPA ref. 18/1063/FULL, it is noted that the application was refused for access reasons despite KCC Highways Authority confirming that the impact on the highway was acceptable. Dandara suggests further clarity is required in assessing the highway impact of development. 4.137 The timescales for the implementation of the relief road need to be clarified in order to ensure that the strategy for the Parish and relevant allocations are positively prepared, justified and effective under NPPF paragraph 35. 4.138 Dandara emphasises the importance of supporting transport infrastructure as a catalyst for new development. New transport infrastructure should be delivered to strict and realistic timescales in order to facilitate, not prevent, development. [TWBC: comment on Policy STR/HA 1 is duplicated at Comment Number 4688]. [TWBC: full representation is attached to Comment Number DLP_4614].
DLP_4689	CBRE Ltd for Dandara Ltd		Policy AL/HA6: ‘Land off Copthall Avenue and Highgate Hill’ - Dandara notes the following: 4.139 Dandara supports growth at Hawkhurst and the wider development strategy. This section specifically addresses Dandara’s comments in relation to the policy allocation – AL/HA6. 4.140 Paragraph 5.98 of Draft Policy AL/HA6 states that part of the site was subject to a planning application LPA ref. 18/01063 for residential development (which was refused due to design concerns related to the vehicular access onto Copthall Avenue, see above). The more northerly part of the site is subject to planning application LPA ref. 19/01253. This application will be determined on its own merits, and the proposed allocation of this site as part of a larger/wider sites does not indicate any conclusions on the current application. 4.141 Considering the importance of this site, adjacent to the Limits to Built Development of the settlement, its suitability and its role in contributing to the housing targets of the borough we consider that there should be more flexibility built into this policy to allow separate parcels to come forward independently, provided it can be demonstrated that it does not prevent or delay the other land parcels coming forward. Dandara, like TWBC, is concerned by potential piecemeal development and will seek to engage and work collaboratively with all landowners, but the policy should allow flexibility for delivery. Housing Trajectory 4.142 In TWBC’s Draft Local Plan housing trajectory, the first phase of parcel HA6 for the delivery of 44 homes is due to commence in the final year (2023/24) of the first five years of the Plan period. 31 homes will be delivered in the second (final phase) in 2024/2025. It is, however, likely that the site could be delivered sooner than this as there are no barriers preventing it coming forward sooner. 4.143 The site is suitable for housing, available and deliverable within the short term i.e. within the first 5 years of the Plan period. Dandara therefore supports TWBC’s housing trajectory for the delivery of homes on this site. [TWBC: full representation is attached to Comment Number DLP_4614].
DLP_5952	Mr Andrew Constable	Object	Comments on specific sites in the plan. We acknowledge that Hawkhurst has to accommodate some development, but it has to be sustainable and in locations that do not have an overwhelmingly adverse impact on the AONB. There are three sites in the draft plan whose scale and location means that they are simply not appropriate: AL/HA6 – Land off Copthall Avenue and Highgate Hill - this site is proposed to be allocated for 70-79 dwellings with vehicular access from Highgate Hill. This site is completely unsuitable for this scale of development, not least the position of the proposed access onto Highgate Hill. Alternatives We believe that there is an alternative location that would be more suitable for this scale of development. On the A21 just south of Tunbridge Wells is a roundabout known as Kippings Cross (postcode TN12 7HB). There are numerous reasons why the land adjacent to this roundabout would make an ideal location for further development, including: It adjoins the newly improved A21 allowing traffic to move easily towards London, Tonbridge, Sevenoaks and into Tunbridge Wells. It is close to all the facilities and amenities of Tunbridge Wells, including schools and hospitals. Train stations at Paddock Wood, Tunbridge Wells and Tonbridge are in easy reach. There is limited existing development in the immediate vicinity, so fewer people will be directly affected by the development. [TWBC: See related comments DLP_5946_5949-5952]
DLP_6025	Tim Stephens	Object	Policy Number: Policy AL/HA 6 Land off Copthall Avenue and Highgate Hill (SHELAA Reference: Sites 78 and 419) Leave this site as is. Don’t develop it, it is in an inappropriate position. Poor access, poor location on highway, dangerous bit of road due to topography, surface water issues, fast vehicles. Utilise local knowledge.
DLP_6187	Mr Andrew Hill	Object	Land off Copthall Avenue (Policy AL/HA6). Many of the previous remarks on Fowlers Park apply – this application was called in to TWBC and refused so why is it being allocated for development again?
DLP_6397	Hawkhurst Parish Council	Object	Policy AL/HA6 - Land off Copthall Avenue and Highgate Hill HPC has always made it clear that it objects to the inclusion of this allocation. This is a greenfield site in the AONB and there are no exceptional circumstances to justify its inclusion in the Local Plan. It has an unacceptable impact on the AONB and will impact on the designated green space of Little Switzerland. HPC’s objections to the planning applications for sites 78 and 419 are a matter of record.
DLP_7914	Fiona Dagger	Object	Major development is not appropriate in the AONB. TWBC have accepted that Copthall Avenue is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’. This area is a sensitive area of grassland buffering an important area of species rich grassland to the East. The fields are associated with the historic farmstead of Cockshott and form its setting. This combination of features provides a characteristic green gap between Highgate Hill and the Moor which would be compromised by this development.

Policy AL/HA 7: Sports Pavilion, King George V Playing Fields, The Moor

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_1748	Peter Hay	Support	I support this policy
DLP_2428	Rosanna Taylor-Smith	Support	I fully support the provision of a new community facility at King George V playing fields at the Moor. There is a widely used playground here as well as a sports pavilion and extensive sports fields and tennis courts. There is parking although more would be needed to accommodate the proposed new facility. The proposed new community building will be an important Village asset which can be utilised by a variety of local groups and ages for recreational, sporting and social use. I look forward to residents meeting together in a purpose built venue, fully accessible and providing a sustainable and eco friendly future.
DLP_3321	Kent County Council (Growth, Environment and Transport)	Support with conditions	Highways and Transportation The Local Highway Authority conditionally supports this policy. This site raises less concern than the residential sites in the village, owing to the spread of trips throughout the day (without a concentration during the AM and PM peaks) but any development proposal needs to be supported by a Transport Assessment including an impact assessment on the Hawkhurst junction. The following change is requested: Additional paragraph - Proposals for the development of this site shall be supported by a Transport Assessment including an impact assessment on the Hawkhurst junction. Heritage Conservation Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval Some potential for prehistoric and later remains.
DLP_6399	Hawkhurst Parish Council	Support	Policy AL/HA7 - Sports Pavilion, King George V Playing Fields, The Moor HPC supports this policy.

Policy AL/HA 8: Hawkhurst Station Business Park

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_1511	Broadlands Planning Ltd for Kent Woodware Company Ltd	Support	Policy Number: 1. Policy AL/HA8; Hawkhurst Station Business Park. Allocation for employment B1, B2 and B8 uses. Support. 2. Policy AC/HA9(i); Land at Santers Yard, Gills Green Farm. Allocation of northern part for employment B1, B2, B8 uses. Support. 3. Policy AL/HA10; Site at Limes Grove (March’s Field). Safeguarding for employment uses B1, B2, B8. Supports the proposed safeguarding of land at March’s Field north of Limes Grove, for employment B1, B2, B8 uses, under the terms of Policy AL/HA 10, but with the following suggested amendments; That the safeguarding review period of five years be removed from the Policy, and replaced with a policy that allows the land to be brought forward if monitoring indicates that the proposed 2 allocations of land above have either been taken up, or are not able to be brought forward to meet identified and justified employment/business needs which cannot be met on these sites, and which must be met in the eastern part of the Borough. Please see Broadlands Planning letter of 5th November 2019.
DLP_1747	Peter Hay	Object	I object to this Policy
DLP_2097	Terry Everest	General Observation	Query Is this an appropriate location for this deveopment? is it the best site, can this be achieved with minimal environmental damage. ?
DLP_3322	Kent County Council (Growth, Environment and Transport)	Support with conditions	Highways and Transportation The Local Highway Authority conditionally supports this policy. This site raises less concern than the residential sites in the village, owing to the spread of trips throughout the day (without a concentration during the AM and PM peaks) but any development proposal needs to be supported by a Transport Assessment including an impact assessment on the Hawkhurst junction. The following changes are requested: Additional paragraph - Proposals for the development of this site shall be supported by a Transport Assessment including an impact assessment on the Hawkhurst junction. The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate Heritage Conservation Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval Some potential for prehistoric and later remains
DLP_3456	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_3538	John Charles Ball	Object	HA8, HA9 and H10 referring to the expansion of Hawkhurst Station Business Park. The Business Park does not provide mass employment for local people as is suggested by your document. This size of expansion would attract yet more heavy haulage to the site which is already at an accident blackspot and have wider consequences for all the major routes into the village (with or without the 'relief' road).
DLP_3846	Government Team Natural England	Object	Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.
DLP_4130	Tunbridge Wells District Committee Campaign to Protect Rural England	Object	CPRE remain to be convinced that these major developments in the AONB are justified under paragraph 172 of the NPPF. Please see also our comments on Policy ED1.
DLP_4243	Rother District Council	General Observation	General comment It is noted that contributions for ‘any other highway related works’ are referred to within each of the policies. However, in order for any necessary improvements to the Flimwell crossroads to be secured, it is specifically requested that explicit reference is made to requirement 6 of Policy STR/HA 1 or that its general requirements repeated in some form in each of the site allocation policies to ensure the traffic impacts are robustly considered.
DLP_6400	Hawkhurst Parish Council	Support	Policy AL/HA8 - Hawkhurst Station Business Park HPC supports this policy.

Policy AL/HA 9: Land at Santers Yard, Gill's Green Farm

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_218	SJD Projects for Mr Shrubb and Ms Burnett	Support	I am writing on behalf of our clients Mr Shrubb and Ms Burnett, to acknowledge the inclusion of their land in the proposed site allocations within the draft local plan. Our client is keen to see this come to fruition so we hope that the site will be formally adopted in due course.
DLP_1515	Broadlands Planning Ltd for Kent Woodware Company Ltd	Support	Policy Number: 1. Policy AL/HA8; Hawkhurst Station Business Park. Allocation for employment B1, B2 and B8 uses. Support. 2. Policy AC/HA9(i); Land at Santers Yard, Gills Green Farm. Allocation of northern part for employment B1, B2, B8 uses. Support. 3. Policy AL/HA10; Site at Limes Grove (March’s Field). Safeguarding for employment uses B1, B2, B8. Supports the proposed safeguarding of land at March’s Field north of Limes Grove, for employment B1, B2, B8 uses, under the terms of Policy AL/HA 10, but with the following suggested amendments; That the safeguarding review period of five years be removed from the Policy, and replaced with a policy that allows the land to be brought forward if monitoring indicates that the proposed 2 allocations of land above have either been taken up, or are not able to be brought forward to meet identified and justified employment/business needs which cannot be met on these sites, and which must be met in the eastern part of the Borough. Please see Broadlands Planning letter of 5th November 2019.
DLP_1745	Peter Hay	Object	I refer to the parts HA8, HA9 and HA10 – The proposed expansion of Hawkhurst Station Business Park. There is an irony there already, as in the 20 years the business park has done nothing but expand, bringing noise, light and odour pollution with it. It also brings very large trucks through Hawkhurst crossroads, that often get lost and perform some amazingly dangerous manoeuvres to get back on track, very close to one of the worst accident black spots on the A229. Now I am sure that it seems like a good idea as this will provide employment for the people that relocate to the area, I’ve no doubt that is a powerful argument. However, the park is mostly a mixture of storage facilities, it doesn’t provide massive employment and I would question how many of the workers are local – but someone has done their homework here havn't they? Ive done some unverified and very rough sums, the current footprint of the Park is around 40,000m2 – HA9 and HA10 will increase this by 25,000m2 – an increase of 60 something percent – big increase. The increase is happenning on green fields, very beautiful fields too and of course there are many AONB arguments against ruining these, there are also a lot of residents in this area that will be effected by all of the issues a working estate brings – I of course object to turning green field into a grey storage plants with air conditioning and cold stores running 24/7 as they do now, and once I have worked out how to object to I will be ! The inclusion of HA10 is interesting. Why would a field on the other side of the road to the Business Park be included in the Park expansion? Even more curious that its size is only around 2,500m2 so it adds a mere 5% onto the area of the Park. Yet more curious that this field has had permission denied many times in the past to expand the Park, always on the same grounds – it is on the residential side of the road, it has no safe access and there is no need for business to exist there. The issue is of course, if you have sold the safety and environmental concerns that denied the planning permission in the past to the highest bidder for one small field – then what about the other 400 odd pages of the plan? In summary my points are:- I believe that the communication of the plan has been inadequate, and people are not sufficiently aware of the plan. Objecting to the plan either as a whole or in part requires a lot of time and skill, its unreasonable to expect ordinary people to have either. I believe the plan is written as a “sales document”. Attached is my dissection of HA10 which mentions all of the good points and none of the bad. I seriously question the motives for the plan as whole or in parts, the inclusion of HA10 makes me highly suspicious I am very concerned about infrastructure load the extra building will bring I am very concerned about the environmental impact of the building, that cannot be made better or reversed. [TWBC: there were no documents attached to this comment].
DLP_2098	Terry Everest	Object	Object Reduce by 50% and keep that within the southern part of the site. This would allow growth that is more sustainable.
DLP_3323	Kent County Council (Growth, Environment and Transport)	Support with conditions	Highways and Transportation The Local Highway Authority conditionally supports this policy. The cumulative impact of 681-731 new dwellings as a result of site allocations AL/HA 1 to AL/HA 6 and AL/HA 9 will cause a severe impact on the local road network - specifically at the A268/A229 Hawkhurst crossroads, with or without the addition of a new road and the stopping up of the northern arm of the junction as proposed in AL/HA 1. Heritage Conservation Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval. Some potential for prehistoric or later remains
DLP_3457	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_3539	John Charles Ball	Object	HA8, HA9 and H10 referring to the expansion of Hawkhurst Station Business Park. The Business Park does not provide mass employment for local people as is suggested by your document. This size of expansion would attract yet more heavy haulage to the site which is already at an accident blackspot and have wider consequences for all the major routes into the village (with or without the 'relief' road).
DLP_3849	Government Team Natural England	Object	Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.
DLP_4244	Rother District Council	General Observation	General comment It is noted that contributions for ‘any other highway related works’ are referred to within each of the policies. However, in order for any necessary improvements to the Flimwell crossroads to be secured, it is specifically requested that explicit reference is made to requirement 6 of Policy STR/HA 1 or that its general requirements repeated in some form in each of the site allocation policies to ensure the traffic impacts are robustly considered.
DLP_6401	Hawkhurst Parish Council	Support with conditions	Policy AL/HA9 - Land at Santers Yard, Gill’s Green Farm HPC broadly supports this policy, as it recognises the need for employment opportunities and the NDP supports the development of an employment hub at Gills Green. The provision of 38 dwellings is greater than supported by the NDP although the opportunity to provide additional land for employment could be considered to mitigate this (i.e. be an exceptional circumstance). HPC would like to discuss with TWBC whether the housing development could be phased or clustered so that it was more in line with the aims of the NDP to ensure that future development takes the form of small-scale clusters and is phased over time to ensure a steadier sense of change over time, rather than a sense of rapid change (paragraph 7.13). HPC recognises the value of housing near employment to minimise reliance on cars etc. However, future occupants will be some distance from the facilities and services at Highgate and a policy that supported the introduction of local facilities to meet the day-to-day needs of residents at Gills Green would be beneficial.
DLP_7054	Sigma Planning Services for Rydon Homes Ltd	Support	24. This policy is supported and the site is deliverable in general accordance with the criteria specified in the policy. [TWBC: See attachment for full response]

Policy AL/HA 10: Site at Limes Grove (March's Field)

Comment No.	Name/Organisation	Object/support/support with conditions/general observation	Response
DLP_1516	Broadlands Planning Ltd for Kent Woodware Company Ltd	Support with conditions	Policy Number: 1. Policy AL/HA8; Hawkhurst Station Business Park. Allocation for employment B1, B2 and B8 uses. Support. 2. Policy AC/HA9(i); Land at Santers Yard, Gills Green Farm. Allocation of northern part for employment B1, B2, B8 uses. Support. 3. Policy AL/HA10; Site at Limes Grove (March’s Field). Safeguarding for employment uses B1, B2, B8. Supports the proposed safeguarding of land at March’s Field north of Limes Grove, for employment B1, B2, B8 uses, under the terms of Policy AL/HA 10, but with the following suggested amendments; That the safeguarding review period of five years be removed from the Policy, and replaced with a policy that allows the land to be brought forward if monitoring indicates that the proposed 2 allocations of land above have either been taken up, or are not able to be brought forward to meet identified and justified employment/business needs which cannot be met on these sites, and which must be met in the eastern part of the Borough. Please see Broadlands Planning letter of 5th November 2019.
DLP_1750	Peter Hay	Object	I object to this policy
DLP_3324	Kent County Council (Growth, Environment and Transport)	Support with conditions	Highways and Transportation The Local Highway Authority conditionally supports this policy. This site raises less concern than the residential sites in the village, owing to the spread of trips throughout the day (without a concentration during the AM and PM peaks) but any development proposal needs to be supported by a Transport Assessment including an impact assessment on the Hawkhurst junction. The following changes are requested: Additional paragraph - Proposals for the development of this site shall be supported by a Transport Assessment including an impact assessment on the Hawkhurst junction. The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate Heritage Conservation Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval. Some potential for prehistoric or later remains
DLP_3540	John Charles Ball	Object	HA8, HA9 and H10 referring to the expansion of Hawkhurst Station Business Park. The Business Park does not provide mass employment for local people as is suggested by your document. This size of expansion would attract yet more heavy haulage to the site which is already at an accident blackspot and have wider consequences for all the major routes into the village (with or without the 'relief' road).
DLP_4245	Rother District Council	General Observation	General comment It is noted that contributions for ‘any other highway related works’ are referred to within each of the policies. However, in order for any necessary improvements to the Flimwell crossroads to be secured, it is specifically requested that explicit reference is made to requirement 6 of Policy STR/HA 1 or that its general requirements repeated in some form in each of the site allocation policies to ensure the traffic impacts are robustly considered.
DLP_6402	Hawkhurst Parish Council	Support	Policy AL/HA10 - Site at Limes Grove (March’s Field) HPC supports this policy.
DLP_7058	Judith Norris Ltd for Mr and Mrs Attwood	Object	Objection to Site and Policy AL/H10 in the Tunbridge Wells Draft Local Plan Regulation 18 Version Consultation Draft - 20 September to 1 November 2019. Site and Policy AL/H10 This site (a field) is proposed for Employment use (B1, B2, B8 - i.e. Business, general industrial and also storage and distribution). The site lies north of Limes Grove in the small hamlet of Gills Green. This hamlet is located 1.5 km north of the village of Hawkhurst in the High Weald of Kent. The site is also known as March’s Field and by the Call for sites ref ‘Site 55’. The objectors live adjacent to the proposed side on its Eastern boundary. The Attwoods have lived at The Manor House Limes Grove, Gills Green for 30 years and the Bridles at Limes Grove Oast for 20 years. The home, Limes Grove Oast is just 40 metres from the site. The garden runs up to the boundary. History Historically Hawkhurst Station Business Park (HSBP) was a station and sidings on the Tunbridge Wells Branch Line. The Hawkhurst Branch Line came to Gills Green in 1893 and ceased to operate with the Beeching cuts in 1961. The station yard became used by the Dunlop family trading as Kent Woodware as a brush handle turnery. Some of the railway buildings were re-used to support the business, and the signal box was removed comparatively recently. The site was well placed to accommodate brush manufacture. The locally sourced birch coppice was stored close to where it would be converted, some of it on this site (site 55); the legacy of this is some remaining hardstanding and a high Lawson Cypress hedge, but it has not been used for such a purpose for over twenty years when the main yard ceased production. The brushes were much in demand until the use of plastic backs came to the fore so the business closed. Regulation 18 Local Plan allocation The site which is the subject of this objection has now been allocated in the Regulation 18 consultation version of the new Tunbridge Wells Borough Local Plan. The neighbours object to this proposed allocation of employment land on the following grounds; 1 The site does not relate to the separate, and separately accessed, Hawkesbury Station Business Park. The site’s proximity to the Hawkhurst Station Business Park should not be accepted as a reason for its allocation - it would have little if no relationship with the business park. Across Limes Grove Road, and entirely separate from it is the existing Key Employment Area - Hawkhurst Station Business Park. This 1.02 ha employment area is accessed from the East directly from the A229. The proposed site is entirely separate. It would be accessed via Limes Grove which is a small rural sunken lane. There is a small entrance from the business park to the north onto Limes Grove that does not appear to be used. The small road that runs to the entrance within the site is lined with parked cars which would prevent use by wider vehicles. It should not be assumed that this exit would be cleared to allow the two sites to operate as one. Clearly parking would be an issue if this parking area was lost. Given there is not likely to be any link with the existing park building industrial uses on this site which has so many contraindications seems unnecessary. 2 The existing business park provides plentiful employment area for the surrounding local area. It would be better to locate additional employment where it is lacking not in this hamlet where there is plentiful employment provision. This site would only provide a small element of employment land if HA8 and HA9 were also progressed. The benefit of provision does not outweigh the detrimental impact on residential amenity for the neighbours. 3 The site is unsuitable for employment use given its rural feel, poor rural lane access and rural location. It would generate traffic as employees would need to be attracted from elsewhere. This area is rural with isolated homes and farm. To the north there are grazing fields. The area is not suitable for industrial uses which are overly dominant. Limes Grove has views into the surrounding countryside and relates to it. It would instead become a lane running through an industrial complex. As the Sevenoaks and Tunbridge Wells Economic Needs Study Final Report for Tunbridge Wells Borough August 2016 states of the HSBP; ‘the area is around 18 miles from the M25 therefore connections to the strategic motorway network are somewhat limited’. Likewise, the site is relatively inaccessible from local towns except using vehicular traffic. The A229 is a relatively small and twisting rural road. This means that employees need to travel to work. Other sites would be more sustainable. 4 The impact on the landscape of the High Weald AONB would be unacceptable. It is acknowledged that the existing business park is highly visible in The Sevenoaks and Tunbridge Wells Economic Needs Study Final Report for Tunbridge Wells Borough. Allocating additional employment land here would only exacerbate this. The site faces across the valley to the south and is clearly visible in long views. This site is higher than the others proposed in the vicinity and would be likely to be more visible. This site should be excluded from the Local Plan because of this significant impact on the High Weald Area of Outstanding Natural Beauty. The Tunbridge Wells Borough Landscape Character Assessment mentions the existing industrial estate (which is located at the eastern limit of this character area known as ‘Bedgebury Forested Plateau’ (Character Area 15)) . It describes the absence of visible settlement and building as creating a sense of relative remoteness in this area and notes that; ‘Settlement and built infrastructure are characteristically absent or hidden on the forested plateau except Windy Ridge radio transmission tower, Bedgebury Park and the industrial estate at Gills Green.’ ‘It adds that: ‘The few domestic buildings that are present are ... dispersed and isolated farm buildings that occur on the slopes or valley floors of the tributaries.’ It is clear that the existing industrial estate is very visible and significant in its density. It differs from the mosaic nature of the area by being a relatively dense coloured attention bringing development. It would be better to locate the new development away from the existing development park to ensure the typical dispersed nature of homes and farms in the area is not negatively impacted. Given the lack of relationship with the existing business park there seems little merit in using a site near it when this worsens the visual impact of this landscape. From the entrance to the site sweeping views up the fields to the oast beyond give the area an open rustic feel. Losing this sense of open countryside would be a loss to the appearance of the High Weald AONB. 5 The designation could run contrary to the landscape protection afforded by the recently made Hawkhurst Neighbourhood Plan which protects this view from the East. On Page 52 of the made Hawkhurst Neighbourhood Plan (http://www.tunbridgewells.gov.uk/__data/assets/pdf_file/0011/181757/Hawkhur st_Neighbourhood_Plan_March_2018.pdf) protected vistas are given. One these vistas looks westwards towards the site from the East. This view was considered worthy of protection and it would seem inappropriate to designate an employment area within it. Has the Council considered if these protected vistas are impacted? 6 The significant boundary that currently follows the northern side of Limes Grove and forms a hard and tangible border for the business park would be lost. Limes Grove with its dense hedging to its northern side has been a hard line demarcating the edge of the HSBP. It serves to soften views of the industrial park to the south. Developing north of this line where there is no barrier to the north will make the industrial area more dominant. Looking through the site from the site entrance northwards through the site the oast house beyond is clearly visible up the hill. It is obvious that views into the site are currently open. Development here will be very visually intrusive. 7 The access is unsuitable. The existing access onto Limes Grove is a little used farm gate at the south east corner. This would need to be greatly ‘improved’ to allow commercial vehicles to access the site. This would adversely impact the neighbours. Limes Grove is a rural lane. It is too narrow for commercial vehicles. A large part of the existing hedge to the south of the site would need to be removed to allow large vehicles to access the site. This would mean this softening feature would be lost. The access point from the A229 to Limes Grove is also unsuitable and would become more dangerous. It is barely wide enough for two cars to pass at the junction. A lorry turning in here would cross the central line of the slip road. Meeting oncoming cars could be an issue. One of the objectors has explained that he has seen and videoed lorries reversing out onto the A229 when they realise the lane is too narrow. This results in them reversing into a blind bend on the A road. An access onto Limes Grove for the Barn in the Oast House garden was apparently not supported by the Tunbridge Wells Borough Council. It therefore seems illogical to allow a bigger access for more and larger vehicles. This seems particularly pertinent now the north end of Slip Mill Road is closed to south flowing traffic which has increased the use of the road by those seeking to avoid the Hawkhurst Crossroads. The visibility of the junction of Limes Grove with Slip Mill Lane that will also be used by the B1 B2 and B8 businesses potentially located at this site is substandard. The promised right-hand turn lane into the business park did not materialise. 8 Employment development in the hamlet would exacerbate existing traffic problems on the A229. Development would impact the A229 connection between Maidstone and Hastings. The A229 is not a safe road with its heavy traffic and windy bends. It would particularly impact the Hawkhurst Crossroads to the south. Traffic generated is likely to be large commercial vehicles/HGVs and have a significant detrimental impact. 9 The site should not be accepted to be brownfield. The objection site was used for brush storage over 20 years ago and has been agricultural land with some small hardstanding since this time. In 2012 enforcement action was taken by Tunbridge Wells District Council against a temporary storage use. This use should therefore not be considered an accepted use which can be used as evidence of prior use and thus being brownfield. In the same year an application for car parking at the site was refused. 10 Residential Amenity - Noise. The existing business park is surprisingly noisy at its northern edge. The beeps of vehicles reversing and the constant whirr of machinery and air conditioning units is noteworthy. One of the objectors has explained that the promised muffling and planting has never been significantly implemented. The neighbours are concerned the new employment area would present similar issues. Air conditioning units being on the back of industrial units tend to face the neighbours and this is of particular concern given the possible proximity of the new employment units to the residential properties to the East. The site proposed could also generate other noise which would be unacceptable in amenity terms. Noise may also be an issue during construction. Traffic using the access road is likely to be heavy and noisy. It would pass both the objectors’ properties having a significant detrimental impact in terms of noise and disturbance. To experience noise on two sides would be particularly difficult for the residents living on the site’s Eastern edge. Spending time in the garden would not be pleasant if there was noise from industrial uses on two sides. The impact is too detrimental to be acceptable. One of the objectors suffers from MS and has found the noise from the existing industrial units and the grasscrete that was in place on the objection site particularly disruptive. The neighbours moved here expecting a quiet countryside life but having industrial uses so closes has not allowed for the quietness they sought. 11 Residential Amenity - Smell The existing industrial units create significant smells which disturb the objectors. As a planner this would be one of the most odorous industrial units ever visited in a long planning career. The smell was so intense that it felt like you were in a kitchen smelling cooking. The neighbours are obviously concerned the new units will have a similar impact. They are located downwind of any westerly winds. 12 Impact on cycle, equestrian and pedestrian use of Limes Grove Limes Grove is part of Cycle Route 18 and is well used by cyclists, horse riders and walkers as a route to Bedgebury Forest that is located less than a kilometre from this site, and to access houses along Slip Mill Lane from the bus stop on the A229. There is no footway. Increasing traffic and development located on Limes Grove further depletes the amenity of this now very developed rural site for leisure users and for those who use the bus service and who live on Slip Mill Lane. This runs contrary to the Hawkhurst Neighbourhood Plan in particular. 13 Previous local plan policies have been ignored when permissions have been granted. The designation of the HSBP as an economic development site (B1 B2 B8) in the Local Plan was made in 2006 by policy ED4 that required any future buildings to be single storey, sensitive to the setting in the Area of Outstanding Natural Beauty with provision of a right turn lane off the A229, and improved pedestrian access to the site with a bus shelter. Planning application reference 09/0363 granted permission for new buildings but ignored the Local Plan policy with no right hand turning lane, tall buildings, no improved pedestrian access or a bus shelter. The main access was improved but is very visually intrusive, and is directly off the heavily over used A229 that goes from Maidstone to Hastings via the cross roads in Hawkhurst, a notorious bottle neck; further economic development in Gills Green can only exacerbate this problem. The Tunbridge Wells Core Strategy 2010, Core Policy 7 also allocated the HSBP as an economic development site. A later application (14/504138) for another substantial building was granted planning permission with no reference to the policy ED4 of the Local Plan 2006 that still prevailed. The Site allocations document produced in 2016 also identifies HSBP for employment. 14 Impact on the setting of the listed building and on the historic asset. The Manor House was listed Grade II in 1987, while the Oast House is a heritage asset. The setting of the Manor House and the Oast has already been badly compromised by the industrial development at Hawkhurst Station Business Park with buildings 8.9 metres high, and aggressive two metre high security fencing next to Limes Grove. The landscape planting undertaken as a condition of the planning permissions has been remarkably ineffective. The setting has been further compromised by the decision about six years ago to close the north end of Slip Mill Road to traffic going south, meaning that all cars travelling south along Slip Mill Lane (unofficially the Hawkhurst by-pass) must use Limes Grove. This has considerably increased the traffic using Limes Grove passing both the Manor House and the Oast. 15 Biodiversity opportunity area The area is within a Biodiversity Opportunity Area where options for improving biodiversity should be taken not prevented by insensitive development. It is unlikely that any change of use to an employment area could increase biodiversity. 16 Better sites are available The Sevenoaks and Tunbridge Wells Economic Needs Study Final Report for Tunbridge Wells Borough August 2016 states of the HSBP that there is potential land for expansion to the south west which sounds more promising. ‘There is an area of land to the south west of the site (the HSBP) which would be suitable for an expansion zone. Access would be through the existing estate’. The proposed site is also relatively small in terms of industrial provision and it is questionable whether the small increase in industrial floorspace provision would outweigh the significant detriment to the local residents living along Slip Mill Lane/Limes Grove and those who use this rural lane. Conclusion This site should be removed from the emerging Local Plan for any sort of development.
DLP_7060	Judith Norris Ltd for Mr and Mrs Bridle	Object	Objection to Site and Policy AL/H10 in the Tunbridge Wells Draft Local Plan Regulation 18 Version Consultation Draft - 20 September to 1 November 2019. Site and Policy AL/H10 This site (a field) is proposed for Employment use (B1, B2, B8 - i.e. Business, general industrial and also storage and distribution). The site lies north of Limes Grove in the small hamlet of Gills Green. This hamlet is located 1.5 km north of the village of Hawkhurst in the High Weald of Kent. The site is also known as March’s Field and by the Call for sites ref ‘Site 55’. The objectors live adjacent to the proposed side on its Eastern boundary. The Attwoods have lived at The Manor House Limes Grove, Gills Green for 30 years and the Bridles at Limes Grove Oast for 20 years. The home, Limes Grove Oast is just 40 metres from the site. The garden runs up to the boundary. History Historically Hawkhurst Station Business Park (HSBP) was a station and sidings on the Tunbridge Wells Branch Line. The Hawkhurst Branch Line came to Gills Green in 1893 and ceased to operate with the Beeching cuts in 1961. The station yard became used by the Dunlop family trading as Kent Woodware as a brush handle turnery. Some of the railway buildings were re-used to support the business, and the signal box was removed comparatively recently. The site was well placed to accommodate brush manufacture. The locally sourced birch coppice was stored close to where it would be converted, some of it on this site (site 55); the legacy of this is some remaining hardstanding and a high Lawson Cypress hedge, but it has not been used for such a purpose for over twenty years when the main yard ceased production. The brushes were much in demand until the use of plastic backs came to the fore so the business closed. Regulation 18 Local Plan allocation The site which is the subject of this objection has now been allocated in the Regulation 18 consultation version of the new Tunbridge Wells Borough Local Plan. The neighbours object to this proposed allocation of employment land on the following grounds; 1 The site does not relate to the separate, and separately accessed, Hawkesbury Station Business Park. The site’s proximity to the Hawkhurst Station Business Park should not be accepted as a reason for its allocation - it would have little if no relationship with the business park. Across Limes Grove Road, and entirely separate from it is the existing Key Employment Area - Hawkhurst Station Business Park. This 1.02 ha employment area is accessed from the East directly from the A229. The proposed site is entirely separate. It would be accessed via Limes Grove which is a small rural sunken lane. There is a small entrance from the business park to the north onto Limes Grove that does not appear to be used. The small road that runs to the entrance within the site is lined with parked cars which would prevent use by wider vehicles. It should not be assumed that this exit would be cleared to allow the two sites to operate as one. Clearly parking would be an issue if this parking area was lost. Given there is not likely to be any link with the existing park building industrial uses on this site which has so many contraindications seems unnecessary. 2 The existing business park provides plentiful employment area for the surrounding local area. It would be better to locate additional employment where it is lacking not in this hamlet where there is plentiful employment provision. This site would only provide a small element of employment land if HA8 and HA9 were also progressed. The benefit of provision does not outweigh the detrimental impact on residential amenity for the neighbours. 3 The site is unsuitable for employment use given its rural feel, poor rural lane access and rural location. It would generate traffic as employees would need to be attracted from elsewhere. This area is rural with isolated homes and farm. To the north there are grazing fields. The area is not suitable for industrial uses which are overly dominant. Limes Grove has views into the surrounding countryside and relates to it. It would instead become a lane running through an industrial complex. As the Sevenoaks and Tunbridge Wells Economic Needs Study Final Report for Tunbridge Wells Borough August 2016 states of the HSBP; ‘the area is around 18 miles from the M25 therefore connections to the strategic motorway network are somewhat limited’. Likewise, the site is relatively inaccessible from local towns except using vehicular traffic. The A229 is a relatively small and twisting rural road. This means that employees need to travel to work. Other sites would be more sustainable. 4 The impact on the landscape of the High Weald AONB would be unacceptable. It is acknowledged that the existing business park is highly visible in The Sevenoaks and Tunbridge Wells Economic Needs Study Final Report for Tunbridge Wells Borough. Allocating additional employment land here would only exacerbate this. The site faces across the valley to the south and is clearly visible in long views. This site is higher than the others proposed in the vicinity and would be likely to be more visible. This site should be excluded from the Local Plan because of this significant impact on the High Weald Area of Outstanding Natural Beauty. The Tunbridge Wells Borough Landscape Character Assessment mentions the existing industrial estate (which is located at the eastern limit of this character area known as ‘Bedgebury Forested Plateau’ (Character Area 15)) . It describes the absence of visible settlement and building as creating a sense of relative remoteness in this area and notes that; ‘Settlement and built infrastructure are characteristically absent or hidden on the forested plateau except Windy Ridge radio transmission tower, Bedgebury Park and the industrial estate at Gills Green.’ ‘It adds that: ‘The few domestic buildings that are present are ... dispersed and isolated farm buildings that occur on the slopes or valley floors of the tributaries.’ It is clear that the existing industrial estate is very visible and significant in its density. It differs from the mosaic nature of the area by being a relatively dense coloured attention bringing development. It would be better to locate the new development away from the existing development park to ensure the typical dispersed nature of homes and farms in the area is not negatively impacted. Given the lack of relationship with the existing business park there seems little merit in using a site near it when this worsens the visual impact of this landscape. From the entrance to the site sweeping views up the fields to the oast beyond give the area an open rustic feel. Losing this sense of open countryside would be a loss to the appearance of the High Weald AONB. 5 The designation could run contrary to the landscape protection afforded by the recently made Hawkhurst Neighbourhood Plan which protects this view from the East. On Page 52 of the made Hawkhurst Neighbourhood Plan (http://www.tunbridgewells.gov.uk/__data/assets/pdf_file/0011/181757/Hawkhur st_Neighbourhood_Plan_March_2018.pdf) protected vistas are given. One these vistas looks westwards towards the site from the East. This view was considered worthy of protection and it would seem inappropriate to designate an employment area within it. Has the Council considered if these protected vistas are impacted? 6 The significant boundary that currently follows the northern side of Limes Grove and forms a hard and tangible border for the business park would be lost. Limes Grove with its dense hedging to its northern side has been a hard line demarcating the edge of the HSBP. It serves to soften views of the industrial park to the south. Developing north of this line where there is no barrier to the north will make the industrial area more dominant. Looking through the site from the site entrance northwards through the site the oast house beyond is clearly visible up the hill. It is obvious that views into the site are currently open. Development here will be very visually intrusive. 7 The access is unsuitable. The existing access onto Limes Grove is a little used farm gate at the south east corner. This would need to be greatly ‘improved’ to allow commercial vehicles to access the site. This would adversely impact the neighbours. Limes Grove is a rural lane. It is too narrow for commercial vehicles. A large part of the existing hedge to the south of the site would need to be removed to allow large vehicles to access the site. This would mean this softening feature would be lost. The access point from the A229 to Limes Grove is also unsuitable and would become more dangerous. It is barely wide enough for two cars to pass at the junction. A lorry turning in here would cross the central line of the slip road. Meeting oncoming cars could be an issue. One of the objectors has explained that he has seen and videoed lorries reversing out onto the A229 when they realise the lane is too narrow. This results in them reversing into a blind bend on the A road. An access onto Limes Grove for the Barn in the Oast House garden was apparently not supported by the Tunbridge Wells Borough Council. It therefore seems illogical to allow a bigger access for more and larger vehicles. This seems particularly pertinent now the north end of Slip Mill Road is closed to south flowing traffic which has increased the use of the road by those seeking to avoid the Hawkhurst Crossroads. The visibility of the junction of Limes Grove with Slip Mill Lane that will also be used by the B1 B2 and B8 businesses potentially located at this site is substandard. The promised right-hand turn lane into the business park did not materialise. 8 Employment development in the hamlet would exacerbate existing traffic problems on the A229. Development would impact the A229 connection between Maidstone and Hastings. The A229 is not a safe road with its heavy traffic and windy bends. It would particularly impact the Hawkhurst Crossroads to the south. Traffic generated is likely to be large commercial vehicles/HGVs and have a significant detrimental impact. 9 The site should not be accepted to be brownfield. The objection site was used for brush storage over 20 years ago and has been agricultural land with some small hardstanding since this time. In 2012 enforcement action was taken by Tunbridge Wells District Council against a temporary storage use. This use should therefore not be considered an accepted use which can be used as evidence of prior use and thus being brownfield. In the same year an application for car parking at the site was refused. 10 Residential Amenity - Noise. The existing business park is surprisingly noisy at its northern edge. The beeps of vehicles reversing and the constant whirr of machinery and air conditioning units is noteworthy. One of the objectors has explained that the promised muffling and planting has never been significantly implemented. The neighbours are concerned the new employment area would present similar issues. Air conditioning units being on the back of industrial units tend to face the neighbours and this is of particular concern given the possible proximity of the new employment units to the residential properties to the East. The site proposed could also generate other noise which would be unacceptable in amenity terms. Noise may also be an issue during construction. Traffic using the access road is likely to be heavy and noisy. It would pass both the objectors’ properties having a significant detrimental impact in terms of noise and disturbance. To experience noise on two sides would be particularly difficult for the residents living on the site’s Eastern edge. Spending time in the garden would not be pleasant if there was noise from industrial uses on two sides. The impact is too detrimental to be acceptable. One of the objectors suffers from MS and has found the noise from the existing industrial units and the grasscrete that was in place on the objection site particularly disruptive. The neighbours moved here expecting a quiet countryside life but having industrial uses so closes has not allowed for the quietness they sought. 11 Residential Amenity - Smell The existing industrial units create significant smells which disturb the objectors. As a planner this would be one of the most odorous industrial units ever visited in a long planning career. The smell was so intense that it felt like you were in a kitchen smelling cooking. The neighbours are obviously concerned the new units will have a similar impact. They are located downwind of any westerly winds. 12 Impact on cycle, equestrian and pedestrian use of Limes Grove Limes Grove is part of Cycle Route 18 and is well used by cyclists, horse riders and walkers as a route to Bedgebury Forest that is located less than a kilometre from this site, and to access houses along Slip Mill Lane from the bus stop on the A229. There is no footway. Increasing traffic and development located on Limes Grove further depletes the amenity of this now very developed rural site for leisure users and for those who use the bus service and who live on Slip Mill Lane. This runs contrary to the Hawkhurst Neighbourhood Plan in particular. 13 Previous local plan policies have been ignored when permissions have been granted. The designation of the HSBP as an economic development site (B1 B2 B8) in the Local Plan was made in 2006 by policy ED4 that required any future buildings to be single storey, sensitive to the setting in the Area of Outstanding Natural Beauty with provision of a right turn lane off the A229, and improved pedestrian access to the site with a bus shelter. Planning application reference 09/0363 granted permission for new buildings but ignored the Local Plan policy with no right hand turning lane, tall buildings, no improved pedestrian access or a bus shelter. The main access was improved but is very visually intrusive, and is directly off the heavily over used A229 that goes from Maidstone to Hastings via the cross roads in Hawkhurst, a notorious bottle neck; further economic development in Gills Green can only exacerbate this problem. The Tunbridge Wells Core Strategy 2010, Core Policy 7 also allocated the HSBP as an economic development site. A later application (14/504138) for another substantial building was granted planning permission with no reference to the policy ED4 of the Local Plan 2006 that still prevailed. The Site allocations document produced in 2016 also identifies HSBP for employment. 14 Impact on the setting of the listed building and on the historic asset. The Manor House was listed Grade II in 1987, while the Oast House is a heritage asset. The setting of the Manor House and the Oast has already been badly compromised by the industrial development at Hawkhurst Station Business Park with buildings 8.9 metres high, and aggressive two metre high security fencing next to Limes Grove. The landscape planting undertaken as a condition of the planning permissions has been remarkably ineffective. The setting has been further compromised by the decision about six years ago to close the north end of Slip Mill Road to traffic going south, meaning that all cars travelling south along Slip Mill Lane (unofficially the Hawkhurst by-pass) must use Limes Grove. This has considerably increased the traffic using Limes Grove passing both the Manor House and the Oast. 15 Biodiversity opportunity area The area is within a Biodiversity Opportunity Area where options for improving biodiversity should be taken not prevented by insensitive development. It is unlikely that any change of use to an employment area could increase biodiversity. 16 Better sites are available The Sevenoaks and Tunbridge Wells Economic Needs Study Final Report for Tunbridge Wells Borough August 2016 states of the HSBP that there is potential land for expansion to the south west which sounds more promising. ‘There is an area of land to the south west of the site (the HSBP) which would be suitable for an expansion zone. Access would be through the existing estate’. The proposed site is also relatively small in terms of industrial provision and it is questionable whether the small increase in industrial floorspace provision would outweigh the significant detriment to the local residents living along Slip Mill Lane/Limes Grove and those who use this rural lane. Conclusion This site should be removed from the emerging Local Plan for any sort of development.