Diocese of Rochester August 2020

Examination Statement

West Malling Abbey

Diocese of Rochester

Tonbridge and Malling Borough Council

Examination in Public

Matter 3 – The Metropolitan Green Belt

savills.co.uk

West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

Contents

1. Introduction 1 2. Response to Inspectors Questions 2 3. Conclusions 11

Appendix A: Regulation 18 Representation Appendix B: Regulation 19 Representation

Appendix C: Fabrik Landscape Evidence

Appendix D: Local Plan Post-Submission Representation Appendix E: Excerpt from Green Belt Study Part One

Appendix F: Excerpt from Green Belt Study Part Two

Appendix G: Excerpt from the Green Belt Exceptional Circumstances Topic Paper

Diocese of Rochester August 2020

West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

1. Introduction

1.1. This Examination Statement is submitted by Savills on behalf of the Diocese of Rochester (“the Diocese”).

1.2. The Diocese covers North and West Kent, including the London Boroughs of Bromley and Bexley. It

comprises 216 parishes, including approximately 239 churches and serves a population of 1.3 million.

1.3. This Statement relates specifically to the West Malling Abbey. Situated to the East of West Malling, the

Abbey was established in the area by Gundulf Bishop of Rochester as the Abbey of the Virgin Mary for

Benedictine nuns in circa. 1090 and has a historic association with the Town. As such, the Diocese has a

long-standing interest in the area.

1.4. As custodian of this historic Abbey site, the Diocese’s priority is to ensure the long term viability and

sustainability of the Abbey estate. The Abbey is already heavily-constrained in terms of its various planning

designations, including: Historic Park and Garden; Scheduled Ancient Monument; and, a number of listed

buildings. The imposition of a Green Belt designation across the Abbey site would introduce an

unnecessary and restrictive planning burden for any future alterations required.

1.5. Previous representations have been made to Tonbridge and Malling Borough Council (TMBC) for the

Regulation 18 (Appendix A), Regulation 19 Local Plan Consultation (Appendix B) and the Local Plan Post

Submission Consultation (Appendix D). It is our opinion that, as it stands, the Local Plan should not be

found sound as it is not justified and there is insufficient evidence to support it.

1.6. This hearing statement outlines how the proposed Local Plan is not compliant with the National Planning

Policy Framework (NPPF), specifically where is relates to Green Belt Policy within the Borough.

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

2. Response to Inspectors Questions

2.1. Savills, on behalf of the Diocese, has informed the Programme Officer, of their intentions to participate at

the hearing sessions relating to Matter 3.

Matter 3 – The Metropolitan Green Belt (Policy LP3)

Issue: Whether the Local Plan has been positively prepared and whether it is justified, effective and

consistent with national planning policy in relation to the overall approach to the Green Belt.

Q1. What is the basis of the Green Belt Review and how have the conclusions informed the Local Plan?

What methodology has been applied and is it soundly based?

2.2. The Green Belt Review has not been founded on a sound basis and there are distinct flaws in the

methodology used. As such, it is considered that the conclusions used to inform the Local Plan are not

appropriate, reasonable or justified.

2.3. The Green Belt Review (Part One) sought to consider how the Urban Areas, Rural Service Areas and other

settlements within or adjacent to the Green Belt achieve the purposes of the Green Belt (Appendix E). This

methodology is justified when assessing the extent to which existing Green Belt land fulfils the five

purposes of the Green Belt as set out in the NPPF. However, it is not appropriate when considering

additional land to allocate within the Green Belt as it assesses the performance of each parcel against the

Green Belt purposes.

2.4. As such, scoring well against the purposes of the Green Belt cannot be used to justify the inclusion of new

land as part of the Green Belt. As such, Part One of the Green Belt Review cannot be used to establish

whether non-Green Belt land warrants inclusion within the Green Belt.

2.5. Significantly, the Green Belt Review (Stage Two) does not provide further rational on the inclusion of

additional Green Belt, or demonstrate exceptional circumstances for the extension of the Green Belt

Designation. This review is therefore inadequate as it merely reiterates the findings of the Green Belt

Review (Part One), where the area was assessed against the five purposes (Appendix F).

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

2.6. TMBC published the Green Belt Topic Paper in June 2019 to outlines the exceptional circumstances

present that warrant the allocation of additional land within the Metropolitan Green Belt. This paper is

divided into three chapters, of which Chapter 3 is pertinent to the West Malling Abbey site. As with the

above, TMBC has been unable to provide a justification for the inclusion of the Abbey site.

2.7. Notably, Paragraph 83 of the NPPF 2012 pertains to the creation of new Green Belt land. Within this, it

states that (emphasis added):

2.8. “Once established, Green Belt boundaries should only be altered in exceptional circumstances, through

the preparation or review of the Local Plan. At that time, authorities should consider the Belt boundaries

having regard to their intended permanence in the long term, so that they should be capable of enduring

beyond the plan period.’

2.9. TMBC has not demonstrated the exceptional circumstances required by Paragraph 82 of the NPPF. In

relation to the Abbey site, the following should be noted:

 There have been no major changes that warrant the adoption of this exceptional measure. As

outlined in the Green Belt Topic Paper, TMBC have decided to extend the Green Belt in this area

to ‘create a legible boundary.’ This justification is insufficient and does not warrant the additional

administrative burden it places on the Diocese and adjoining landowners;

 TMBC has not demonstrated the necessity for the Green Belt extension in West Malling. The

Abbey is already heavily-constrained in terms of its various planning designations, including:

Historic Park and Garden; Scheduled Ancient Monument; and, a number of listed buildings. As

such, it is evident that normal planning and development management policies are sufficient to

manage development on the Abbey site;

2.10. For the Plan to be found sound, TMBC should reconsider Green Belt allocations on a site by site basis,

clearly demonstrating the exceptional circumstances that justify the Green Belt extension and omitting

those areas that do not warrant a Green Belt designation.

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

Q2. Does it reflect the fundamental aim of Green Belts, being to prevent urban sprawl by keeping land

permanently open?

2.11. No.

2.12. Paragraph 79 of the NPPF clearly states that the fundamental aim of the Green Belt is to prevent urban

sprawl by keeping land permanently open. The TMBC Green Belt review does not reflect the fundamental

aim of Green Belt, as the expansion of the Green Belt in West Malling is not required to prevent urban

sprawl by keeping land permanently open.

2.13. In the previous representations to the Regulation 19 version of the Local Plan we set out why the Abbey

site does not uphold the fundamental aims and essential characteristics of the Green Belt. Notably:

 The land is not open in nature and it is not necessary for it to be kept as such. The Abbey site has

a much closer relationship with the urban settlement of West Malling, because of its historic

association with the settlement and its more urban character (e.g. buildings, allotments, structures,

boundary walls, etc.).

 The Abbey site has clearly defined boundaries that relate to nearby roads (Lavenders Road, Water

Lane and Swan Street). The northern, southern and western boundaries abut the urban area of

West Malling, giving the Abbey site a more urban context and character.

 There are a number of development management policies in place across this area to restrict and

control development, including countryside policies, conservation area policies, designated

heritage assets and open space designations. As such, there is no need for the Green Belt

allocation to prevent urban sprawl in this location.

2.14. In accordance within the above, we consider that the inclusion of the Abbey site within the Green Belt

extension will ultimately undermine the great importance attached to this designation. On these grounds,

the Green Belt Review does not reflect the fundamental aims of the Green Belt and cannot be found sound.

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

Q3. Does it reflect the essential characteristics of Green Belts, being their openness and their

permanence?

2.15. No.

2.16. As outlined above, the land is not open in nature and the inclusion of the Abbey site within the Green Belt

will challenge the essential characteristics of it.

2.17. It is notable that, to the best of the knowledge of the Diocese, planning policy officers have not visited the

Abbey site as part of their Local Plan preparation work to analyse it (e.g. assess the extent to which the

site is open, etc.).

2.18. This demonstrates that the Green Belt study does not reflect the essential characteristics of the Green Belt

and the designation of the Abbey site would fundamentally undermine the essential characteristics of it.

Q4. Does it reflect the five purposes that Green Belts serve, set out in paragraph 80 of the NPPF?

2.19. The Green Belt Study Part One does not reflect the five purposes of the Green Belt as it simply provides

an audit of the Green Belt assets, including the generalised parcel of West Malling. The study does not

provide any qualitative judgments as to how the proposed extension meets the criteria set out in paragraph

80 of the NPPF.

2.20. It is therefore difficult to understand the rationale for including this land. The Diocese instructed Fabrik

(Landscape Architects) to undertake a review of the proposed extension to assess whether it meets the

requirements of the NPPF (Appendix C). Fabrik’s report, which was submitted alongside the Regulation

19 representation, explains why the land does not meet the relevant Green Belt criteria under paragraph

80.

2.21. Fabrik’s assessment concludes that:

“In landscape and visual terms, the [Abbey] Site fails these tests on all counts. There is therefore no

justification for the inclusion of the Site within the emerging proposed Green Belt designation.”

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

2.22. The inclusion of the Abbey site within the Green Belt therefore demonstrates that the Green Belt Review

does not reflect the five purposes of the Green Belt. For the Plan to be found sound, TMBC should

undertake a robust review of the proposed Green Belt boundary changes and remove the Abbey site from

the Green Belt extension at West Malling.

Q5. Paragraph 83 of the NPPF is clear that Green Belt boundaries should only be altered in exceptional

circumstances. Is the Council’s approach to the Green Belt set out in its Green Belt Exceptional

Circumstances Topic Paper (ED10) robust and in line with national guidance?

2.23. Published in June 2019, TMBC released the Green Belt Topic Paper (Part Two) to explain the Exceptional

Circumstances for the alterations to the Metropolitan Green Belt in the Borough. The paper is divided into

three chapters, of which Chapter 3 relates to the proposed Green Belt extension.

2.24. Chapter 3 outlines the purposes of the Green Belt (p. 3.1.3.); purposes of Green Belt Boundaries (3.1.4.);

and the ‘factors that have justified the exceptional circumstances for the removal of land from the Green

Belt’ (3.1.5.). This report then goes on to explain the alternative options for the Green Belt Boundaries,

concluding that the Exceptional Circumstances include the fact that extending the boundary to Ashton Way

would be a more logical boundary to the Green Belt.

2.25. There is very little clarity on the exceptional circumstances that exist to alter the Green Belt boundary in

this area. As such, the approach to Green Belt is not considered robust, nor is it consistent with Paragraph

83 of the NPPF.

2.26. With regards to the Abbey site, the Council had not presented any exceptional circumstances that warrant

the inclusion of this land within the Metropolitan Green Belt.

2.27. It is considered that the inclusion of the Abbey site is not justified as the area does not serve the five

purposes of the Green Belt. As such, TMBC should remove the Abbey site from the Green Belt extension

for the Plan to be found sound.

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

Q6. Do the exceptional circumstances necessary exist to warrant the proposed alterations to Green Belt

boundaries, in terms of both removing land from and adding land to the Green Belt?

2.28. TMBC has dismissed paragraph 82 of the NPPF in the Green Belt Topic Paper. However, it is considered

that in lieu of an alternative, paragraph 82 is the most appropriate policy in the framework to inform the

extension of the Green Belt in the District.

2.29. Significantly, paragraph 82 of the NPPF outlines the exceptional circumstances required to establish new

Green Belt. Within this it states that:

“If proposing a new Green Belt, local planning authorities should:

 demonstrate why normal planning and development management policies would not be adequate;

 set out whether any major changes in circumstances have made the adoption of this exceptional

measure necessary;

 show what the consequences of the proposal would be for sustainable development;

 demonstrate the necessity for the Green Belt and its consistency with Local Plans for adjoining

areas; and

 show how the Green Belt would meet the other objectives of the Framework.”

2.30. There is a lack of detail in the Green Belt Topic Papers on the Exceptional Circumstances that warrant the

extension of the Green Belt in West Malling. Whilst it is noted that the Council is not proposing to construct

a new Green Belt, TMBC should have considered the policies set out in paragraph 82 to evidence the

exceptional circumstances to extend the Green Belt in West Malling.

2.31. Q7. What relationship, if any, is there between the exceptional circumstances leading to the alterations

proposed to the Green Belt and the proposed spatial strategy/distribution of new housing?

2.32. It would appear that the rationale for the proposed extension has been established on a quantitative basis

(i.e. TMBC is seeking to mitigate the loss of other Green Belt land that is being displaced elsewhere in the

Borough by housing sites).

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

2.33. Maintaining or exceeding the net-coverage of Green Belt does not act as a sufficient justification for

including the Abbey site within the proposed Green Belt extension. Nor is it a requirement of the NPPF to

maintain the same net quantity of Green Belt land.

2.34. As such, TMBC’s apparent strategy to replace lost Green Belt by extending its coverage in West Malling

is not justified.

Q8. Do the decisions taken on Green Belt releases reflect the need to promote sustainable patterns of

development, and prioritise sites which are previously developed and/or well served by public transport?

Where is this evident?

2.35. No Comment.

Q9. Has a comprehensive assessment of capacity within built up areas been undertaken? Where is this

evident?

2.36. No Comment.

Q10. Have all potential options on non-Green Belt land in the countryside been thoroughly assessed,

including some of the land being proposed to be included in the Green Belt? Where is this evident?

2.37. No Comment.

Q11. Have opportunities to maximise capacity on non-Green Belt sites been taken (including increasing

densities)? Where is the evidence of this?

2.38. No Comment.

Q12. Have discussions taken place with neighbouring authorities about whether they could accommodate

some of the identified housing need? If so, where is the evidence of this?

2.39. No Comment.

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

Q13. Are all the sites and their boundaries clearly and accurately shown on the proposals map?

2.40. No Comment.

Q14. Is the approach to new infrastructure in the Green Belt justified?

2.41. No Comment.

Q15. What land is safeguarded through this Local Plan and what land was safeguarded through the

previous adopted Local Plan? Does the Local Plan make clear that safeguarded land is not allocated for

development at the present time? Is all land previously safeguarded allocated for development in this Plan?

2.42. No Comment.

Q16. Is it necessary to identify safeguarded land more widely in order to meet longer term development

needs stretching well beyond the plan period? Without the identification of further safeguarded land, what

reassurance is there that longer-term development needs can be met without further review of the Green

Belt?

2.43. No Comment.

Q17. Have the altered Green belt boundaries been considered having regard to their intended permanence

in the long term? Are they capable of enduring beyond the plan period?

2.44. No comment.

Q18. In terms of the land being included in the Green Belt through proposed boundary changes, what other

options were considered and rejected, as a way of preventing harmful development in this area? Where is

this evident?

2.45. In the Green Belt Exceptional Circumstances Topic Paper, TMBC states that the Council has assessed

the alternative boundary changes towards Kiln Barn Road or Wateringbury Road. Whilst the report

provides some justification of why TMBC discounted these options to extend the boundary, it does not

provide a comprehensive overview of the mechanisms available to prevent harmful development in this

area.

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

2.46. There are a number of policy mechanisms available to TMBC to control or restrict development in the area.

The Council has not reviewed the effectiveness of development management policies to restrict harmful

development to the east of West Malling.

2.47. As previously noted in this representation, the normal planning and development management policies

have been sufficient in controlling and restricting development in this area. The Council has not evidenced

why they now consider it necessary to extend the Green Belt in this location to prevent harmful

development, in lieu of the previous planning policies.

2.48. Significantly, since the expansion of the Metropolitan Green Belt to West Malling in 1983, there has been

more development towards the west of the town, within designated Green Belt, than the east of it. This

demonstrates that the development management policies within the proposed extension have effectively

prevented harmful development in this location for nearly 40 years. This has not been given due

consideration by the Council and has not been evidenced within the emerging Local Plan.

Q19. Has consideration been given to leaving this land outside of the Green Belt boundary in order to allow

for some future development without the need to review the Green Belt boundaries again?

2.49. No Comment.

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West Malling Abbey Tonbridge and Malling Borough Council EIP – Matter 3

3. Conclusions

3.1. This hearing statement is made in respect of the Inspector’s Main Issues and Questions. The Diocese

considers that the Green Belt Assessment is unjustified, ineffective and inconsistent with National Planning

Policy.

3.2. The West Malling Abbey site does not meet the purposes of the Green Belt and should not be included

within a Green Belt allocation. Significantly, there are no exceptional circumstances to warrant the

extension of the Green Belt in this location, nor has the Council provided evidence why development

management policies are not sufficient to restrict harmful development in this location.

3.3. For the Local Plan to be found sound, TMBC should be required to reconsider their evidence base to

ensure that it is independently and objectively assessed. This will ensure that their Local Plan is founded

on appropriate, relevant and up-to-date evidence, in accordance with the NPPF.

3.4. In light of the above the Local Plan should be found unsound.

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West Malling Abbey

Tonbridge and Malling Borough Council EIP – Matter 3

Appendix A

Regulation 18 Representation

Client Month YYYY 2

West Malling Abbey

Tonbridge and Malling Borough Council EIP – Matter 3

Appendix B

Regulation 19 Representation

Client Month YYYY 2

15th November 2018

Planning Policy Manager Andrew Watson Tonbridge & Malling Borough Council E: [email protected] Gibson Building DL: 01798 879050 F: 01732 01732 879051 Gibson Drive 23 Kings Hill Avenue Kings Hill West Malling West Malling ME19 4UA Kent ME19 4LZ www.savills.com

Dear Sir/Madam,

Re: Letter of Representation on Draft Tonbridge and Malling Local Plan

Introduction

Thank you for the opportunity to comment on the draft Tonbridge and Malling Borough Council (TMBC) Local Plan. This representation is made by Savills on behalf of the Diocese of Rochester (‘the Diocese’).

About the Diocese of Rochester

The Diocese of Rochester is one of 41 dioceses of the Church of England and was established by St Augustine in 604AD. Geographically the Diocese of Rochester covers North and West Kent and the London Boroughs of Bromley and Bexley; comprising 216 parishes with 239 churches and serving a population of 1.3 million.

Brief History of West Malling Abbey

The abbey was founded by Gundulf Bishop of Rochester as the abbey of the Virgin Mary for Benedictine nuns in about 1090. It was one of the earliest nunneries to be established after the Norman conquest. The Diocese currently leases the West Malling abbey site (‘the abbey site’) to the Benedictine Community (‘the Community’). The abbey and the town of West Malling were both established during the Medieval period, which means they have a historic association with one another in terms of the evolution and morphology of their urban development.

Existing Development and Future Plans

The abbey site has a varied planning history associated with it, but most notably in recent times has secured planning permission for:

‘Proposed demolition and replacement of the Pax House for theological training offices and library and the conversion of the Guest House into related non-residential centre, alteration of walls at vehicle access at Swan Street and associated works including parking area and demolition of garage’ (ref: 16/00340/FL)

The application sets out a case that the Community is aging and their ability to access, maintain and use all areas of the site effectively is becoming more difficult and that there is a surplus of accommodation within the precinct.

Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East.

Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD

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The Diocese, in conjunction with the South East Institute for Theological Education, required additional space for offices, day-time study, conferences and retreats, as well as a specialist library. The existing Pax House was in a serviceable condition but fell short on disability access, flexibility and thermal performance. The existing Guest House also fell below standards for fire compartmentalisation, fire detection, means of escape in the event of a fire and energy performance. The application, which has now been consented, provided a significant opportunity to ensure the continued use of the abbey site by the Diocese and the Community.

Future Use of the Abbey

As custodian of this historic site, the Diocese’s priority is to ensure the long term viability and sustainability of the Abbey estate. The Abbey site is already heavily-constrained in terms of its various planning designations (e.g. Historic Park and Garden, Scheduled Ancient Monument) and the imposition of a further Green Belt allocation would introduce an unnecessary and restrictive planning burden.

Planning Policy Framework

The most relevant sections of the 2012 National Planning Policy Framework (NPPF) in relation to Green Belt are set out below. Paragraph 80 of the NPPF explains that Green Belts have five purposes: 1. ‘to check the unrestricted sprawl of large built-up areas; 2. to prevent neighbouring towns merging into one another; 3. to assist in safeguarding the countryside from encroachment; 4. to preserve the setting and special character of historic towns; and 5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.’

Paragraph 83 explains that (emphasis added): Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.

In relation to the setting of boundaries, paragraph 85 goes on to state that: ‘When defining boundaries, local planning authorities should:  ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development;  not include land which is unnecessary to keep permanently open;  where necessary, identify in their plans areas of ‘safeguarded land’ between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period;  make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following a Local Plan review which proposes the development;  satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and  define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.’

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Proposed Green Belt Allocation around West Malling

The September 2016 Issues and Options draft Local Plan set out the extension to the Green Belt (pages 38 – 39) where paragraph 6.3.7 explained that: ‘Figure 11 (overleaf) suggests a proposed strategic extension to the Green 6.3.7.Belt in the vicinity of West Malling and Kings Hill. It is considered that this potential addition of 134 Ha would be a more reliable and defendable boundary that would contribute positively to purposes of the Green Belt.’ Some further evidence was provided in the Green Belt study (dated September 2016) on pages 35 - 36 and Appendix I. However, no rationale is provided anywhere as to how the extension complies with the relevant paragraphs of the NPPF. Paragraph 6.3.6 of the draft Local Plan (2016) states that: ‘…the preparation of the new Local Plan presents an opportunity to consider whether certain boundaries need to be re-aligned so that the Green Belt performs a more effective function (as measured against the five purposes outlined in the Government’s NPPF – see above). This could have the consequence of increasing the amount of land within the Green Belt in certain locations which, overall, could ensure the quantum of land within the Green Belt across the borough is not significantly eroded.’ It would appear that the rationale for the proposed extension has been established on a quantitative basis (i.e. TMBC is seeking to mitigate the loss of other Green Belt land that is being displaced elsewhere in the Borough by housing sites). This does not act as a sufficient justification for including the abbey site within the proposed Green Belt extension. It is also not a requirement of the NPPF to maintain the same net quantity of Green Belt land. Nor does it amount to exceptional circumstances under paragraph 83 of the NPPF. Green Belt Assessment Part 2 Since the Green Belt Study (Part 1), a Green Belt Assessment (Part 2) has been produced dated August 2018. The report explains (pages 12-13) how the extension meets the exceptional circumstances to justify an extension. However, only cursory detail is provided on this. The Diocese has a number of concerns with which are set out below. Notwithstanding these concerns, the criteria set out in paragraphs 4.7 - 4.10 could still be achieved without the Diocesan land being included. Assessment Against Paragraph 80 Criteria

The proposed Green Belt extension does not appear to have been informed by any credible evidence. The Green Belt study (part 1) simply provides an audit of the Green Belt assets, including around West Malling. It does not provide any qualitative judgments as to how the proposed extension meets the criteria set out in paragraph 80 of the NPPF.

Furthermore, it does not set out any ‘exceptional circumstances’ as to why the abbey site should be designated as Green Belt. It is therefore difficult to understand the rationale for including this land. The Diocese has instructed Farbrik (landscape architects) to undertake a review of the proposed extension to assess whether it meets the requirements of the NPPF.

Fabrik’s report, which forms part of this representation, explains why the land does not meet the relevant Green Belt criteria under paragraph 80. Below, I have gone on to explain below the other shortcomings of the proposed allocation against other relevant paragraphs of the NPPF.

Assessment Against Paragraph 85 Criteria

When assessed against the relevant criteria in paragraph 85, the proposed allocation does not comply with the NPPF. I have provided specific reasons for this below.

“…not include land which it is unnecessary to keep permanently open.” [BP2, paragraph 85]

The land is not open in nature and it is not necessary for it to be kept as such. The abbey site has a much closer relationship with the urban settlement of West Malling, because of its historic association with the settlement and its more urban character (e.g. buildings, allotments, structures, boundary walls, etc.).

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It is also notable, to the best of the knowledge of the Diocese, that planning policy officers have not visited the abbey site as part of their Local Plan preparation work to analyse it (e.g. assess the extent to which the site is open, etc.). Without officers having seen the abbey site, it is difficult to understand what the Council’s logic might be for proposing the site as a Green Belt designation. define boundaries clearly, using physical features that are readily recognisable and likely to be permanent [BP6, paragraph 85]

The abbey site has clearly defined boundaries that relate to nearby roads (Lavenders Road, Water Lane and Swan Street). The northern, southern and western boundaries abut the urban area of West Malling, giving the abbey site a more urban context and character. The land to the east of the site is much more open in nature and would therefore be more appropriate as Green Belt land.

Assuming that TMBC can provide a rationale for allocating the other land as Green Belt land, a far more logical boundary would be the adjoining roads that run around the perimeter of the abbey site, thus excluding it from the proposed Green Belt allocation.

Land at Hildenbourough

The Diocese own land at Hildenborough which is designated under policy S1 (g) of the adopted Local Plan as: safeguarded land for school playing fields. It is understood that the School has no need for the land to be used as playing fields. The land is now proposed to be designated as an open space in the new Local Plan (LP13.OS.299 – Hildenboorugh Church Grounds). The Diocese object to this designation on the following grounds: 1. Evidence for open space designation – the Open Space Assessment (March 2018) does not provide any justification for why the site has been designated as an open space. 2. Accessibility – the land is included in Appendix P Open Spaces (Publicly Accessible). However, the land is private and there are no rights of access over it aside from the public footpath that runs to the west of the site. It is therefore incorrect to identify it as being publicly accessible. 3. Recreation land to the north – there is a large area of recreation land to the north which is publicly accessible. This provides suitable and accessible space for the local community. Therefore, there is sufficient public open space in the local area, and the Diocesan land does not need to be safeguarded as open space. 4. The land is close to a settlement boundary, and sustainably located. It will therefore serve as a suitable future development site.

Conclusion

The Diocese would be happy to discuss these comments with you at your convenience if that would be helpful, and I look forward to hearing from you if this would be of interest.

Yours Sincerely,

Andrew Watson • MRTPI Associate Director e [email protected] • t 01732 879050 encs – Fabrik Landscape and Visual Assessment

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West Malling Abbey

Tonbridge and Malling Borough Council EIP – Matter 3

Appendix C

Fabric Landscape Evidence

Client Month YYYY 2

West Malling Green Belt: Landscape Representations to the Tonbridge and Malling Local Plan: The Way Forward

Land at Malling Abbey, West Malling, Kent

Job No.D2462 14 November 2016 – Rev B Landscape Representation Land at Malling Abbey, West Malling, Kent

Project Title: West Malling Green Belt Review, Kent

Client: Diocese of Rochester

Revision Date Revision Details Prepared By Checked By Approved By

Draft 14 November 2016 Draft for Savills review LS LS -

A 18 November 2016 Draft for client review LS LS AS

B 21 November 2016 Final for submission LS LS -

2 Landscape Representation Land at Malling Abbey, West Malling, Kent

Contents

1. Executive Summary....... 4 5.12 Landscape Characteristics of the Existing Green Belt...... 35 5.13 Landscape Characteristics of the Proposed Green Belt.....35 2. Introduction....... 5 2.1 Introduction...... 5 6. Application of Green Belt Purposes to Malling Abbey ...... 2.2 Desktop Research...... 5 Grounds...... 37 2.3 Field Work...... 5 6.1 Introduction...... 37 6.2 Green Belt Purposes...... 37 3. Landscape Planning Background....... 6 3.1 Introduction...... 6 7. Conclusions....... 40 3.2 Current Landscape and Heritage Designations and Policy...6 3.3 Emerging Designations and Planning Policy...... 6

4. Landscape and Visual Analysis of the Malling Abbey ...... Grounds...... 13 4.1 Introduction...... 13 4.2 Topography...... 13 4.3 Vegetation...... 13 4.4 Land Uses...... 13 4.5 Access and Rights of Way ...... 13 4.6 Settlement Pattern ...... 13 4.7 Features...... 13 4.8 Visual Analysis...... 13 4.9 Skyline / Panorama / Landmark...... 13 4.10 Strengths and Sensitivities...... 14 4.11 Landscape and Visual Analysis Conclusion...... 14

5. Landscape and Visual Analysis of the Eastern Edge of West Malling and Proposed Green Belt Extension...... 34 5.1 Introduction...... 34 5.2 Topography...... 34 5.3 Vegetation...... 34 5.4 Land Use...... 34 5.5 Access and Rights of Way ...... 34 5.6 Settlement Pattern...... 34 5.7 Features...... 34 5.8 Boundaries...... 34 5.9 Recreation and Culture ...... 34 5.10 Visual Analysis...... 35 5.11 Strengths and Sensitivities...... 35

3 Landscape Representation Land at Malling Abbey, West Malling, Kent

1. Executive Summary

fabrik Chartered Landscape Architects have been appointed by the through by the railway line, and to the south there are some farm to the Church and its grounds. Diocese of Rochester to prepare this landscape representation to the buildings and larger residential buildings (including Douces Manor).” Local Plan: The Way Forward consultation, to set out the landscape An assessment of the Site against the five purposes of the Green Belt and visual reasons to exclude Malling Abbey (the Site) from the new In terms of openness and visibility, the study goes on to state that: has been carried out. In landscape terms, the Site fails these tests on Green Belt area proposed to the east of West Malling. “Boundary hedging, planting and existing built form tend to block all counts. There is no justification for the inclusion of the Site within views from within the built-up area from a pedestrian viewpoint, the emerging proposed Green Belt designation. The desktop survey carried out as part of this study has included however, some views of the landscape can be obtained at various a review of Ordnance Survey maps, interactive maps, aerial points including from Public Rights of way and the road network. The removal of the Site from the proposed Green Belt area would not photography, together with current and emerging planning policy, not the land is undulating with a slight slope to the north. The land is alter the wider purposes of the Green Belt designation. only for the Site, but also the extent of the proposed eastern Green considered to be generally open as buildings are sporadic within the Belt area. designation in this location.” In landscape and visual terms, it is therefore our conclusion that the Site should not be included in the wider proposed Green Belt The field work was carried out on 7 November 2016 and recorded fabrik concur with this overview for the existing Green Belt area. designation, as the wider designation beyond the Site adequately the existing landscape and built elements of the Site, together Views to the wider landscape from within the Site are contained by fulfils paragraph 80 of the National Planning Policy Framework. with the contextual landscape characteristics informing the setting the combination of the boundary wall, trees, vegetation and in places, to the eastern edge of West Malling. A photographic record was the built form. prepared as an aide memoir. Relevant key viewpoints included in this document. In terms of the proposed Green Belt, the landscape beyond the eastern edges of Malling Abbey exhibit the same characteristics of The majority of West Malling Abbey and its grounds are designated the existing Green Belt designation to the west of the town. This is as a Scheduled Ancient Monument; contains a range of Grade because it comprises fields, some of which are farmed, others are I, II and II* Listed Buildings; form the northern part of the locally in use as paddocks (and therefore are typically settlement fringe designated Historic Park and Garden; and lies within a Conservation landscapes). The landscape to the north is also cut through by the Area. The Abbey and its grounds are therefore subject to three railway line and includes the station and associated car parking planning designations. area, a typically urban use, but in a location where there is little intervisibility between the station and the developed edges of West In terms of an appraisal of the Site, Malling Abbey contains a number Malling. of buildings that together are read as part of the eastern townscape fringes both physically and visually. The Site’s boundaries are In contrast, Malling Abbey does not exhibit the same characteristics marked by a range of walls which follow the alignment of the local as the landscape which lies beyond Lavenders Road or Water Lane. road network. As such, the combination of walls (with the range The enclosure provided by the wall that wraps itself around the Abbey of built form of West Malling townscape evident beyond) and the together with the range and cluster of buildings results in a character road network, provides a well defined, robust, defensible, clearly area that is distinctly different the wider landscape setting to the town distinguished and settled edge boundary between town and the wider to the east and south. countryside. Other ecclesiastical grounds, such as St Mary the Virgin Church and As set out in the Tonbridge and Malling Green Belt Study, September its associated churchyard, on the south-western edge of the town, 2016 (at Appendix I) the Overview states that: “It comprises open lie within the defined built up area and outside of the existing and fields, some of which are farmed. To the north the landscape is cut proposed Green Belt areas. Malling Abbey has similar characteristics

4 Landscape Representation Land at Malling Abbey, West Malling, Kent

2. Introduction

2.1 Introduction Legend fabrik Chartered Landscape Architects have been appointed by the Site Boundary Diocese of Rochester to prepare this landscape representation to the Tonbridge and Malling Local Plan: The Way Forward consultation. It sets out the landscape and visual reasons as to why Malling Abbey (the Site) should be excluded from the new Green Belt area proposed to the east side of West Malling. The Abbey lies on the eastern edge of West Malling, as shown on Figure 1.1 opposite.

This document sets out the landscape related policy background to the Site, including the emerging policy proposals (relative to the proposed new Green Belt designation); appraises the internal Site arrangements, together with the immediate contextual landscape to the eastern side of West Malling, to explain the Site’s physical and visual relationship with the town; appraises the eastern landscape setting to the town; describes the broad landscape characteristics of the current and proposed Green Belt areas; and tests the proposed Green Belt designation relative to the Site against the five purposes of the Green Belt (as set out at paragraph 80 of the NPPF).

This report froms an appendix to a letter of representation prepared by Savills.

2.2 Desktop Research

The desktop survey carried out as part of this study has included a review of Ordnance Survey maps, interactive maps, aerial photography, current and emerging planning policy, not only for the Site, but also the extent of the proposed eastern Green Belt area.

2.3 Field Work

A site visit was carried out on 7 November 2016 to record the existing landscape and built elements of the Site, together with the contextual landscape characteristics informing the setting to the eastern edge of West Malling. A photographic record was prepared as an aide memoir. Figure 1.1 – Extract from Ordnance Survey Plan showing the location of the Site (fabrik, November 2016)

5 Landscape Representation Land at Malling Abbey, West Malling, Kent

3. Landscape Planning Background

3.1 Introduction progress. The objective is to ensure that, at the end of this exercise, extension has not been tested in the Green Belt Study evidence base the boundaries are robust and can ensure at least for the duration of for the local plan and which makes it highly questionable. This section sets out the current and emerging landscape and the plan period (up to 2031).” heritage designations (and associated policy where relevant) within Paragraph 6.3.8 goes on to state that: “It is considered that this would the administrative area of Tonbridge and Malling District Council Section 6.3 raises the question of ‘What should the Green Belt be a more reliable and defendable boundary that would contribute relative to West Malling and, in particular, Malling Abbey and the land boundaries be in the Local Plan?’. Paragraph 6.3.1 states that: “As positively to the purposes of the Green Belt.” to the east of West Malling. part of the evidence gathering for the new Local Plan, the robustness of the existing Green belt boundaries was assessed. The boundaries Paragraph 6.3.9 then concludes that: “This would result in 3.2 Current Landscape and Heritage Designations and Policy were assessed against the five purposes of the Green Belt as approximately 134 ha being put into the Green Belt.” identified in the Government’s NPPF: As shown on Figure 3.1a, the majority of West Malling Abbey and its grounds is designated as a Scheduled Ancient Monument; lies • to check the unrestricted sprawl of large built-up areas; within the West Malling Conservation Area and forms the northern part of a locally listed Historic Park and Garden (the latter designation • to prevent neighbouring towns merging into one another; being subject to SQ3 within the Managing Development and the Environment document). • to assist in safeguarding the countryside from encroachment;

The Site also contains Grade I, II and II* Listed Buildings, including • to preserve the setting and special character of historic towns; the Gatehouse and Chapel; the Refectory; the Convent Building; and the Guest House; the Church of the Resurrection of our Lord Jesus Christ and of the Blessed Virgin Mary; the Charterhouse and Library; • to assist in urban regeneration, by encouraging the recycling of the north wall of the Cloister; the Ewell Monastery Guest House; St derelict and other urban land.” Mary’s Tower to the original abbey; the Abbey Tithe Barn; and the cascade. Paragraph 6.3.6 goes on to state that: “... the preparation of the new Local Plan presents an opportunity to consider whether certain The current Green Belt designation lies to the west of West Malling boundaries need to be re-aligned so that the Green Belt performs and is subject to Policy Core Strategy policy CP3, refer to Figure 3.1. a more effective function (as measures against the five purposes outlined in the Government’s NPPF - see above). This could have the 3.3 Emerging Designations and Planning Policy consequence of increasing the amount of land within the Green Belt in certain locations which, overall, could ensure the quantum of land The Tonbridge and Malling Local Plan: The Way Forward, within the Green Belt across the borough is not significantly eroded.” Regulation 18 Issues and Options, Draft (September 2016) This paragraph is in conflict with the five purposes of the Green Belt This document proposes land to the east of West Malling, up to the which does not seek to ‘secure a quantum of land’ but the emphasis A228, as an extension to the Green Belt (refer to Figure 3.2). is on the five purposes.

Paragraph 4.2.14 states that: “An assessment of the robustness of Figure 5 of The Way Forward document, as described in para 6.3.7: the existing boundaries of the Green Belt, as measured against the “... suggests a proposed strategic extension to the Green Belt in purposes identified in the Governments NPPF, is currently work-in- the vicinity of West Malling and Kings Hill.” However, this proposed

6 Landscape Representation Land at Malling Abbey, West Malling, Kent

3. Landscape Planning Background Legend Site Boundary

Green Belt (Core Strategy Policy CP3)

Historic Park and Garden (Managing Development and the Environment Policy SQ3)

Scheduled Ancient Monument

Conservation Area

Listed Buildings (source: Historic England)

Ancient Woodland

Figure 3.1 – Plan showing current landscape and heritage designations (fabrik, November 2016) Figure 3.1a – Zoomed plan showing current landscape and heritage designations (fabrik, November 2016)

7 Landscape Representation Land at Malling Abbey, West Malling, Kent

3. Landscape Planning Background

Legend

Site Boundary

Existing Green Belt

Proposed Green Belt

Existing defined built up Area

Figure 3.2 – Extract of Figure 5 from Tonbridge and Malling Local Plan: The Way Forward, Regulation 18 Issues and Options, Draft (Tonbridge and Malling DC, September 2016) with red line of Malling Abbey added by fabrik (November 2016)

8 Landscape Representation Land at Malling Abbey, West Malling, Kent

3. Landscape Planning Background

Evidence Base: Green Belt Study (September 2016) landscape setting to these suite of designations consistent with the existing designation. The above document has been prepared to review the current Green Belt boundary. Para 1.1.11 states that the study: “...provides a Furthermore, under the ‘Other Factors’ and under the ‘Surrounding functional assessment only of the Green Belt land designation within Constraints / Other Designations subsection, it is acknowledged that: TMBC. As part of the preparation of the Local Plan and the collection “The majority of the town is designated as a Conservation Area. To of evidence, the study takes stock of the existing situation and tests the north of the town and to the east is an area of high risk of flooding current Green Belt land coverage against the criteria set out within (Flood Zone 3). Large TPO area to the south.” However, there is no the NPPF...” (emphasis added). It therefore does not objectively recognition of the locally designated Historic Park and Garden being consider any of the proposed Green Belt extensions and how present to the south overlaid with the TPO area. these proposed extensions measure against the five para 80 NPPF purposes of the Green Belt. It should be noted that other ecclesiastical grounds, such as St Mary the Virgin Church and its associated churchyard, on the south- The assessment of the existing Green Belt at West Malling is western edge of the town, lie within the defined built up area and considered at Appendix I of the Study and a summary of the findings outside of the existing and proposed Green Belt areas. Malling Abbey of the assessment are set out at the table on pages 35-36 of the main has similar characteristics to the Church and its grounds. report. The consistency of approach relative to existing designations is There is no document set out under the suite of evidence base therefore questionable. information to the Local Plan, or The Way Forward document, that sets out the reasons and necessary NPPF tests to justify the extent of The plan on the following page shows the designation constraints the proposed Green Belt area on the eastern side of West Malling. associated with the existing Green Belt area of West Malling. Malling Abbey grounds are defined as an Historic Park and Garden and are At p36 of the summary table, in terms of the overview of the five covered in part by Flood Zone 3. purposes of the Green Belt, relative to ‘Preserving setting and special character of historic towns’ it states that: “West Malling is a historic town, much of which is designated as a Conservation Area, with the High Street accommodating a significant number of Listed Buildings. The historic eastern side of the town, where the majority of the Conservation Area can be found, does not contain Green Belt. To the western side, the Green Belt plays a role in providing a setting for the Conservation Area (and Historic Parks and Garden Areas). The area is somewhat mixed therefore and thus has been categorised as performing moderately.” (Emphasis added). As such, there has not been a consistent approach to the consideration of the new Green Belt area which also proposes to wash over the existing Conservation Area, Scheduled Ancient Monument and Registered Park and Garden, whereas it could provide a better function in providing the

9 Landscape Representation Land at Malling Abbey, West Malling, Kent

3. Landscape Planning Background

Legend

Site Boundary

Figure 3.3 – Extract of Appendix I from Tonbridge and Malling Green Belt Review (Tonbridge and Malling DC, September 2016) with red line of Malling Abbey added by fabrik (November 2016)

10 Landscape Representation Land at Malling Abbey, West Malling, Kent

3. Landscape Planning Background

Evidence Base: Development Capacity Study (December 2013)

The conclusions section at page 16 of the above document sets out a plan illustrating ‘All Constraints’ (see Figure 3.4 on the following page) which includes all archaeological and heritage, ecological and biodiversity, flood risk, landscape and minerals and waste constraints’ but which excludes Green Belt and the Kent Strategic Gap. A zoomed in version of this plan reveals that the Site lies within the constrained zone in terms of development capacity. These constrained areas are covered by footnote 2 which states that:

“This is not an absolute assessment of constraints to determine what parts of the Borough or specific sites should or should not be appropriate for development. Individual sites and areas should be considered taking into account relevant guidance and assessments of their impact and mitigation in line with the NPPF.”

11 Tonbridge and Malling : Development Capacity Study

5.0 Conclusions

5.1 Taking account of all the information on environmental, transport and minerals and waste factors in the previous section of the report it is possible to synthesis all of the outputs together and show areas of the Borough where in principle constraints to development might apply.2

5.2 These are shown in Figure 5.1 (red shading).

Figure 5.1 Synthesis of Constraints

Tonbridge and Malling : Development Capacity Study

5.0 Conclusions

5.1 Taking account of all the information on environmental, transport and minerals and waste factors in the previous section of the report it is possible to synthesis all of the outputs together and show areas of the Borough where in principle constraints to development might apply.2

5.2 These are shown in Figure 5.1 (red shading).

Figure 5.1 LandscapeSynthesis of Constraints Representation Land at Malling Abbey, West Malling, Kent

3. Landscape Planning Background

Legend

Approximate site location

Figure 3.4 – Extract of Figure 5.1 from the Tonbridge and Malling : Development Capacity Study (December 2013) Figure 3.4a – Zoomed extract of Figure 5.1 Source: withTMBC/ the location NLP Ana of Mallinglysis Abbey added by fabrik (November 2016) © Crown copyright and database rights 2013 Ordnance Survey 100023300

12

2 This is not an absolute assessment of constraints to determine what parts of the Borough or specific sites should or should not be appropriate for development. Individual sites and areas should be considered taking into account relevant guidance and assessments of their impact and mitigation in line with the NPPF.

P16 5655400v3

Source: TMBC/ NLP Analysis © Crown copyright and database rights 2013 Ordnance Survey 100023300

2 This is not an absolute assessment of constraints to determine what parts of the Borough or specific sites should or should not be appropriate for development. Individual sites and areas should be considered taking into account relevant guidance and assessments of their impact and mitigation in line with the NPPF.

P16 5655400v3 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

4.1 Introduction as a key landmark feature of the Site in views towards West Malling. 4.8 Visual Analysis The tree planting within the Manor Park Country Park beyond the In order to understand the relationship of Malling Abbey to the Site to the south, extends into the south-eastern quadrant of the Site, Views Inwards: Open views of the Site are limited to those in close townscape of West Malling, an analysis of the Abbey grounds has masking views of the buildings within the Site from this direction. proximity. In particular, from the north, south and west views of the been carried out. This work has informed the assessment of the Site Hedgerows predominantly define the boundaries of the cemetery and walled boundaries and buildings within the Site occur in the context of relative to the five purposes of the Green Belt which is considered in private gardens within the Site. the developed streetscene (or where the presence of the townscape Section 6 of this representation. is evident behind the viewer). Views from the east along Lavender 4.4 Land Uses Road (refer to key viewpoints 7-11) are informed principally by either Section 5 of this representation then describes the wider contextual the walled boundary with buildings beyond; the walled boundary with landscape and how the Site sits within that landscape. The Abbey grounds include St Mary’s Abbey and associated range trees beyond; or the walled boundary with trees beyond in the context of buildings and structures (including the Tower; the Western Range, of the adjacent Lavenders Residential Home. The enclosure to the Beyond the predominantly walled edges of the Site, it is bound the Gatehouse; and Guest House). A number of private dwellings lie road corridor to the east comprises wholly vegetation which gives the by Swan Street (a predominantly single track road, with on street on the edges of the Site, a number of buildings associated with The sense of countryside beyond. The walled boundary gives the sense parking) and a range of commercial and private buildings, including Pilsdon at Malling Community associated are located on the southern of an estate containing buildings and marking, together with the road dwellings and a chapel to the north; by Lavenders Road to the edge of the Site. Beyond these collection of buildings, the grounds corridor, a clear and definitive hard developed edge to the wider east, with occasional dwellings and Lavenders Residential Home, comprise a range of formal and informal gardens, including areas landscape beyond. There is little sense that the Site has an open separated by a single paddock; to the south by Water Lane with either for food production (both vegetables and livestock) and associated character due to the combination of built form and walled boundaries. dwellings or the Manor Park Country Park beyond; and to the west structures such as glass houses and sheds. by a ‘pay and display’ car park and the rear elevations of the range of Views Outwards: Generally, wider views out of the Site are curtailed commercial properties on the High Street. 4.5 Access and Rights of Way by either built form or vegetation. Views of the buildings which bound the Site to the north, wesT, south-west and south-east are evident The plan on the following page illustrates the existing Site landscape. Access to the Abbey is principally via the Gatehouse on Swan Street; from a number of places within the Site (refer to site photographs A photographic record of the Site is set out on page 16. with access to The Pilsdon via Water Lane. There are no Public 1, 2, 4, 16, 20, 22 and 23). The Site is therefore influenced by the Rights of Way passing through the Site. surrounding range of buildings. 4.2 Topography 4.6 Settlement Pattern There are limited locations in the immediate environs of the Site Consistent with the immediate townscape, the Site lies on the east where views are entirely free from built form (including walled facing valley sides and valley floor associated with a local stream. The pattern of built form within the Site is clustered predominantly boundaries). This stream runs through the Abbey Grounds from the south and to the north-eastern and south-western quadrants, with private exits the grounds through a cascade on the boundary with Swan residential buildings located to the north-western and south-western 4.9 Skyline / Panorama / Landmark Street (refer to internal site photo S11; and key viewpoint 5). Site edges. The location of buildings within the Site is well-related to the built form present beyond the Site. Depending on the location of the view, the skyline of the view towards 4.3 Vegetation the Site comprises either built form or trees, or a combination of both. 4.7 Features The grounds includes significant areas of trees both to the The gatehouse on Swan Street; the historic Abbey building of the boundaries and within the Site, comprising a range of native and The range of buildings within the Site, set behind the walled Tower; together with the barn on Water Lane are the principal non-native evergreen and deciduous trees together with a number of boundaries and within a well treed and robust framework of trees landmark features of the Site in views from the immediate environs to orchard trees. There is no single tree within the Site that stands out together create the principal site elements. the Site.

13 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

4.10 Strengths and Sensitivities

The walled boundary, predominantly enclosing the Abbey grounds, is a key element of the local townscape and provides a definitive boundary to the eastern edge of West Malling.

4.11 Landscape and Visual Analysis Conclusion

The Site boundaries are marked by a range of walls which follow the alignment of the local road network. As such, the combination of walls, with built form evident beyond and the road network, provides a well defined, robust, defensible and clear edge between town and the wider countryside.

The Site therefore contains a number of buildings that form part of the townscape fringes both physically and visually rather than forming part of the wider landscape and landscape setting to the town.

14 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Legend

1 Walled Site boundary 1

1 Local valley and stream line 7 8

3 Direction of slope

Landmark building and principal entrance 9

1 3 The Pilsdon the Malling Community building 4 6 2 1 Significant tree groups

5 Local road corridors bounding the Site

1. Privately rented dwellings in the estate

10 2. Cemetery 3. Areas containing orchard trees 4. Kitchen garden 5. Glass houses 6. Formal lawn 7. Cascade (water feature) 8. New permeable car park area (currently under construction) 9. Vehicular entrance on Lavender Road 10. Entrance to The Pilsdon at Malling Community Figure 4.1 – Plan illustrating landscape analysis of the Site (fabrik, November 2016)

15 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Legend

Site Boundary S24

S1 Viewpoint location S23 S3 S1 S2 S6 S7 S4 S5 S22

S8 S20 S21

S19 S18 S9

S17 S16 S12 S11 S13

S14 S10

S15

Figure 4.2 – Plan illustrating photographic viewpoints (fabrik, November 2016)

16 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Contextual Photograph Survey

Photograph – Viewpoint S1 View looking north-west towards Swan Street from the Gatehouse. Two to three storey buildings form part of the developed context to the Site.

Photograph – Viewpoint S2 Photograph – Viewpoint S3 View looking north-west across the northern part of the Site View looking south-east towards the Tower, Western Range and Guest House from the eastern side of the towards the Gatehouse and pedestrian entrance. Again, the built Gatehouse. form along Swan Street is evident as the backdrop to the view.

17 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Contextual Photograph Survey

Photograph – Viewpoint S4 View looking north towards Swan Street adjacent to the Tower. Again, dwellings fronting Swan Street form the developed setting to this part of the Site.

Photograph – Viewpoint S5 Photograph – Viewpoint S6 View looking south towards the Tower and the Western Range adjacent to the Guest View looking south-west adjacent to the Tower towards the Guest House. House.

18 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Contextual Photograph Survey

Photograph – Viewpoint S7 View looking south-east towards the Chapel forming part of the cluster of buildings in the north-eastern section of the Site.

Photograph – Viewpoint S8 View looking north-west towards the Chapel across the north-eastern corner of the Site.

19 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Contextual Photograph Survey

Photograph – Viewpoint S9 View looking north-west towards the cluster of buildings in the north-eastern section of the Site. The walled boundaries to the Site are clearly evident and extend into the formal garden space. Views out of the Site are curtailed principally by the boundary wall, but also the layers of vegetation beyond the Site.

Photograph – Viewpoint S10 Photograph – Viewpoint S11 Photograph – Viewpoint S12 View looking north towards the facade of the principal Abbey building View looking north along the stream within the Site. View looking north across the formal garden area east of the walled across the formal garden area. kitchen garden.

20 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Contextual Photograph Survey

Photograph – Viewpoint S13 Photograph – Viewpoint S14 Photograph – Viewpoint S15 View of the glasshouses and chalets associated with The View of the Barn on the southern edge of the Site and within the area View looking south-east towards Lavender Road, across the south-eastern Pilsdon. associated with The Pilsdon. quadrant of the Site. The care home on Lavender Road is evident between the intervening trees.

Photograph – Viewpoint S16 Photograph – Viewpoint S17 Photograph – Viewpoint 18 View looking west towards Water Lane across the south-western View looking north across the walled kitchen garden. View looking west towards the dwelling on the western edge of the quadrant of the Site. The spire of St Mary the Virgin Church is visible Site on Water Lane. as part of the developed setting to this part of the Site.

21 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Contextual Photograph Survey

Photograph – Viewpoint S19 Photograph – Viewpoint S20 Photograph – Viewpoint S21 View looking north across the orchard on the western edge of the View looking north-west towards the dwelling on the western View looking south-east across the northern edge of the kitchen Site. boundary. The rear elevation of buildings on the High Street provide garden to a bungalow dwelling. the developed context to this view.

Photograph – Viewpoint S22 Photograph – Viewpoint S23 Photograph – Viewpoint S24 View looking north-east across the new car park area towards the View looking north along the driveway entrance to the dwellings and View looking south-east along the driveway entrance to the dwellings dwelling within the northern part of the Site, south of Swan Street. new car park area off Swan Street. The dwellings within the Site are and new car park area off Swan Street. Building on the north side of Swan Street are evident between the evident in the context of the built form of Swan Street beyond. trees.

22 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Legend 1 2 3 Site Boundary

4

5 Location of Photographic viewpoint – Open View (An open view of 6 17 1 the whole of the site or open view of part of the site). 16 Location of Photographic viewpoint – Partial View (A view of the site 15 7 2 which forms a small part of the wider panorama, or where views are 14 filtered between intervening built form or vegetation). 8 18 9 Location of Photographic viewpoint – Truncated View (Views of the 13 10 3 site are obscured by the intervening built form and / or vegetation, or is 12 22 difficult to perceive).

27 19 11

21

20

26

23

25 24

Figure 4.3 – Extract from Ordnance Survey Plan showing key viewpoint locations (fabrik, November 2016)

23 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Site Photograph Survey

Approximate Site location and extent

Photograph – Viewpoint 1 Photograph – Viewpoint 2 View looking south-east towards the Site from the western end of View looking south across the northern edge of the Site from further along Swan Street. Open views of the dwellings; their walled boundaries; and the trees Swan Street. Partial views of the northern edges of the Site occur beyond forming part of the northern edge of the Site, occur from this location. The Site forms part of the wider developed streetscene of Swan Street visible from this location, filtered between the built form and vegetation. beyond and forming the setting behind the viewer. Views of the Gatehouse are partial, framed by vegetation. Approximate Site location and extent

Photograph – Viewpoint 3 Note: Viewpoints 1-3 are taken from within the View looking south-east from Swan Street, adjacent to the junction of Police Station Road. Open views of the northern developed edge of the Site occur from Conservation Area. this location, including views of the dwellings together with a clear view of the Gatehouse. The upper sections of the Tower within the Site is visible above the Gatehouse, giving an indication of what lies beyond the Gatehouse. The Site forms part of the developed streetscene, albeit interspersed with vegetation.

24 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Site Photograph Survey

Photograph – Viewpoint 4 View looking south towards the Site from further along Swan Street, opposite the Gatehouse and Pilgrim Chapel. Open views of both the built form and vegetation occur from this location, set beyond the walled boundary. These views occur in the context of the wider developed streetscene (and considering the developed setting behind the viewer). Boundaries along Swan Street at this location are defined either by buildings, walls or railings.

Photograph – Viewpoint 5 Note: Again, both photographs are taken from View looking south-west towards the Site from Swan Street, adjacent to Frog Lane. Open views of a range of buildings and trees occur from this location, set within the Conservation Area. beyond a walled and hedged boundary, giving an impression of what lies beyond. The cascade is a key feature of this elevation. Again, these views occur in the context of the developed streetscene of Swan Street (and considering the developed context set behind the viewer). Boundaries either side of Swan Street are defined by walls.

25 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Site Photograph Survey

Note: Photograph 6 is taken from within the Conservation Area.

Photograph – Viewpoint 6 View looking west towards the Site from the junction of Swan Street and Lavenders Road. Open views of the walled boundary with vegetation beyond occur from this location. Glimpses of buildings within the Site are evident, filtered between the intervening trees. Buildings fronting the northern side of Swan Street are visible in the distance, forming part of the setting to this view.

Photograph – Viewpoint 7 View looking west towards the private vehicular entrance off Lavenders Road. Open views of the cluster of buildings within the Site occur from this location, visible beyond the walled site boundary. Lavenders Road is set down lower in the landscape than the fields beyond to the east.

26 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Site Photograph Survey

Photograph – Viewpoint 8 Photograph – Viewpoint 9 Photograph – Viewpoint 10 View looking south-west along Lavenders Road. View looking south-west along Lavenders Road adjacent to an View looking north-east along Lavenders Road adjacent to an unused entrance. unused entrance.

Commentary on Viewpoints 8-10. The character and amenity of the view along Lavenders Road is informed by the tall walled boundary of the Site, with the vegetation beyond. Glimpsed views of the built form within the Site occurs intermittently filtered between the intervening vegetation. The setting to the east of these views is informed by the dense vegetation, marking a change in character between built edges and countryside.

Photograph – Viewpoint 11 View looking north towards the Site from the junction of Lavenders Road and Water Lane. Again, open views of the walled boundary with trees beyond occur in the context of the built form of the adjacent Lavenders Residential Home.

27 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Site Photograph Survey

Photograph – Viewpoint 12 View looking north-east towards the Site from Water Lane, adjacent to the entrance of The Pilsdon at the Malling Community. Open views of the Barn and buildings within the Site occur over and between the intervening walled boundary, and in the context of the developed streetscene beyond. Walled boundaries line both sides of Water Lane at this location.

Approximate Site location and extent

Photograph – Viewpoint 13 View looking north-east towards the Site adjacent to Old Parsonage Court. Open views of the walled boundary and the trees beyond occur from this location. Partial views of buildings within the Site occur beyond the walled and vegetated boundaries in the context of the walled developed set behind the viewer.

28 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Site Photograph Survey

Photograph – Viewpoint 14 Photograph – Viewpoint 15 View looking south-east towards the Site from the western end of Water Lane. View looking south-east towards the Site from the western end of Water Lane. Open views of the walled boundary, vegetation and built form within the southern Partial views of the walled boundary and vegetation in the southern part of the part of the Site occur in the context of the neighbouring buildings. Site occur from this location in the context of the developed streetscene.

Photograph – Viewpoint 16 View looking south-east towards the Site from the pay and display car park to the east of the High Street. Open views of the northern part of the Site occur (the boundary walls and the trees within the Site) with partial views of the dwellings and built form within the Site evident between the intervening vegetation. Views of the Site occur in the context of the urban scene of the car park and the High Street built form behind the viewer.

29 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Site Photograph Survey

Photograph – Viewpoint 17 Photograph – Viewpoint 18 View looking west along Swan Street adjacent. Partial views of the walled View looking west towards the Site from the pavement on station approach. Views of the Site (and the settlement of boundary to the Site occur from this location. Walled boundaries are typically West Malling) are wholly truncated by the intervening layers of vegetation. enclosing built form, a characteristic feature of this street.

Photograph – Viewpoint 19 Note: The countryside to the LHS of the road View looking north-west towards West Malling and the Site. Views of both West Malling and the Site are wholly obscured by corridors in photos 17 and 18 is proposed to be the intervening layers of vegetation. The Station Car Park allows open views to the surrounding landscape Green Belt. The Station Car Park is also included in the proposed Green Belt area.

30 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Site Photograph Survey

Photograph – Viewpoint 20 View looking north-west towards West Malling and the Site from the footpath off the A228 Ashton Way. Again, views of the town and the Site are wholly obscured by the intervening layers of vegetation. The character and amenity of the view is informed by the openness of the countryside which contains individual dwellings.

Photograph – Viewpoint 21 Note: The land within these photos is included in View looking north-west towards West Malling and the Site from the footpath to the east of Lavender Road. Views of the townscape of West the proposed Green Belt area. Malling and the Site are obscured by the intervening layers of vegetation. Individual dwellings to the east of Lavender Road and on the fringes of the town are evident set below the treed visual horizon. The overall character and amenity of the view is informed by the combination of openness provided by the fields, framed by vegetation.

31 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

Site Photograph Survey

Photograph – Viewpoint 22 View looking north-west towards the Site from the footpath adjacent to Lavender Road. Again, views of the built form of the Site and West Malling are wholly obscured by the intervening layers of vegetation. The character and amenity of the view is informed by the open fields and the trees.

Photograph – Viewpoint 23 Note: The land within these photos is included in View looking north-west towards the Site from a footpath to the south-east of the Site. Again, views of the Site and West Malling are wholly the proposed Green Belt area. obscured by the intervening layers of vegetation. The character and amenity of the view is informed by the openness of the fields, framed by vegetation, together with the individual, isolated dwellings.

32 Landscape Representation Land at Malling Abbey, West Malling, Kent

4. Landscape and Visual Analysis of the Malling Abbey Grounds

St Mary the Virgin Church Spire Site Photograph Survey

Photograph – Viewpoint 24 Photograph – Viewpoint 25 View looking north towards the Site and West Malling from the footpath to the west of Lavender Road and within the Manor Park Country Park. View looking north from further along the footpath in the Country Views of the Site and West Malling are wholly obscured by the intervening layers of vegetation. Park. Whilst views of the Site are obscured, the location of the Site is understood due to the church spire being visible.

St Mary the Virgin Church Spire

Photograph – Viewpoint 26 Photograph – Viewpoint 27 Note: The land within these photos View looking north-east towards the Site and West Malling. Again, the extent and location of both the Site View looking north towards the Site from the northern edge of the is included in the proposed Green and West Malling are obscured by the intervening layers of vegetation. Country Park. Open views of the walled boundary and the trees Belt area. beyond are visible in views from this direction, clearly marking the edge of an estate.

33 Landscape Representation Land at Malling Abbey, West Malling, Kent

5. Landscape and Visual Analysis of the Eastern Edge of West Malling and Proposed Green Belt Extension

5.1 Introduction 5.3 Vegetation slopes. The settlement has extended from the network of historic road corridors. Whilst it is acknowledged that the Green Belt Study advises that Significant treebelts are principally associated with the local valley the Green Belt is not a landscape designation, there is a synergy and the designed landscape associated with Manor Park Country 5.7 Features between the physical and visual characteristics and relationships Park to the south of West Malling. This tree cover extends into the between the existing and proposed Green Belt areas which are well Malling Abbey grounds, continuing the tree cover into the edges of The principal features of the townscape relate to the range of related to both landscape and townscape elements and landscape West Malling. buildings found within the Conservation Area and historic core; and planning policy. This is reinforced by the High Court Case of Turner the significant treebelts which provide a good level of visual enclosure v Secretary of State for Communities and Local Government (ref 5.4 Land Use to views. 2016 EWCA CIV 466) and in particular paragraph 15 which states: “... There is an important visual dimension to checking “the unrestricted West Malling comprises a small town, with its current centre The spire of St Mary the Virgin Church is a key feature both in the sprawl of large built-up areas” and the merging of neighbouring concentrated along the High Street, which lies broadly on a north to local townscape and landscape. towns, as indeed the name “Green Belt” itself implies. Greenness south alignment. Malling Abbey and its grounds lies on the eastern is a visual quality: part of the idea of Green belt is that the eye side of West Malling. Beyond the settled areas, the landscape 5.8 Boundaries and the spirit should be relieved from the prospect of unrelenting comprises paddocks and orchards set aside and arable farmland. urban sprawl. Openness of aspect is a characteristic quality of the Individual properties (including private dwellings, a care home and a On the eastern edge of West Malling, property boundaries include countryside, and “safeguarding the countryside from encroachment” series of schools) all set as isolated buildings, or clusters of buildings the walls associated with Malling Abbey grounds and which follow includes preservation of that quality of openness. The preservation in the principally farmed landscape. the local road corridors (of Swan Street to the north; Lavenders Road of “the setting... of historic towns” obviously refers in a material way to the east; and Water Lane to the south). Boundaries beyond this to their visual setting, for instance when seen from a distance across West Malling train station and its associated car parking areas lie to more formal edge are more organic and are formed principally by open fields. Again, the reference in para. 81 to planning positively “to the east of the settlement. vegetation. retain and enhance landscapes, visual amenity and biodiversity” in 5.9 Recreation and Culture the Green Belt makes it clear that the visual dimension of the Green 5.5 Access and Rights of Way Belt is an important part of the point of designating land as Green Manor Park Country Park, together with the network of Public Rights Belt.” A series of transport corridors bisect the townscape and landscape, of Way, form the principal area for recreation locally. principally including the railway line on a north-west to south-east The plan on page 36 is to be read in conjunction with the text below. alignment; the A228 on a south-west to north alignment; and the A20 West Malling itself it rich in time depth which is evident both through on a broadly west to east alignment. the extent of its Conservation Area, which includes Malling Abbey. 5.2 Topography The local landscape is crossed predominantly by designated Cultural and artistic connections are evident through the number of A minor S shaped ridgeline runs through West Malling from high footpaths extending out from the eastern edge of West Malling to blue plaques to the buildings present throughout West Malling. ground to the south-west of the town towards the north-east. The the wider landscape. A concentration of paths is associated with the High Street lies on part of this ridgeline. The east facing slopes falls to Manor Park Country Park to the south, providing a range of circular a minor tributary valley, before rising again to another local ridgeline non-designated paths around the lake and wider Park. to the south-east of the town. 5.6 Settlement Pattern Malling Abbey lies both on the east facing slopes and the minor valley floor, consistent with the townscape of Swan Street to the north. The centre of West Malling lies broadly on the ridgeline and extends down predominantly the north, but also, historically, the east facing

34 Landscape Representation Land at Malling Abbey, West Malling, Kent

5. Landscape and Visual Analysis of the Eastern Edge of West Malling and Proposed Green Belt Extension

5.10 Visual Analysis 5.12 Landscape Characteristics of the Existing Green Belt different and separate from the wider proposed Green Belt area.

The visual analysis is determined from a visual inspection of the As set out in the Green Belt study (at Appendix I) the Overview proposed Green Belt area and its townscape context from principally states that: “It comprises open fields, some of which are farmed. To roads, public rights of way and properties. the north the landscape is cut through by the railway line, and to the south there are some farm buildings and larger residential buildings Seasonal change in existing evergreen and deciduous plant material (including Douces Manor).” will affect the available views. Typically views will be different through the seasons with a greater sense of enclosure in the summer months In terms of openness and visibility, the study goes on to state that: when deciduous trees are in leaf. “Boundary hedging, planting and existing built form tend to block The photographs 1-27 describe each of these views. views from within the built-up area from a pedestrian viewpoint, however, some views of the landscape can be obtained at various Views Inwards: Views in towards the eastern edge of West Malling points including from Public Rights of way and the road network. are restricted through the combination of topography and dense the land is undulating with a slight slope to the north. the land is layers of vegetation (comprising principally of tall hedgerows and considered to be generally open as buildings are sporadic within the treebelts). There is little sense of West Malling in views back from the designation in this location.” east (refer to key viewpoints 17-26). fabrik concur with this overview for the existing Green Belt area. Views Outwards: Similarly, views outwards from either the town centre or the eastern limits of the settlement boundary are limited due 5.13 Landscape Characteristics of the Proposed Green Belt to the combination of topography, built form and vegetation. There is little sense of the wider landscape from the edges of the town (refer to In terms of the proposed Green Belt, the landscape beyond the key viewpoints 6-11 and 27). eastern edges of Malling Abbey exhibit the same characteristics of the existing Green Belt designation to the west of the town in terms of Skyline / Panorama / Landmarks: The skyline in may of the views comprising of fields, some of which are farmed, others are in use as is formed by the treed horizon. As set out earlier, the spire of St Mary paddocks (and therefore are typically settlement fringe landscapes) the Virgin Church is evident above and between the trees in some of and some set aside. The landscape to the north is also cut through by the views towards the eastern edge of West Malling. the railway line and includes the station and associated car parking area, an urban use and in a location where there is little intervisibility 5.11 Strengths and Sensitivities between the station and the developed edges of West Malling. The landscape also includes isolated buildings in the landscape. The landscape strengths associated with the eastern edge of West Malling relate to the combination of tree cover and built boundaries In contrast, Malling Abbey does not exhibit the same characteristics following local road corridors. as the landscape which lies beyond Lavenders Road to the east. Whilst the enclosure provided by the wall that wraps itself around the The sensitivities relate principally to the open landscape beyond the Abbey estate, the range and cluster of buildings within the Abbey are Malling Abbey grounds to the east and south. clearly evident from the north, east and south resulting in a character area that whilst is distinctly different from the West Malling townscape to the west, north, and to a degree,the south, is also distinctly

35 Landscape Representation Land at Malling Abbey, West Malling, Kent

5. Landscape and Visual Analysis of the Eastern Edge of West Malling and Proposed Green Belt Extension

Legend

Site Boundary

Minor ridgelines

Minor valley

Direction of slope

Defined settlement area

Main road corridors

Minor local road corridors

Railway line and station

Station car park area

Landmark building

Schools

Parkland Figure 5.1 – Plan illustrating landscape analysis of eastern edge of West Malling (fabrik, November 2016)

36 Landscape Representation Land at Malling Abbey, West Malling, Kent

6. Application of Green Belt Purposes to Malling Abbey Grounds

6.1 Introduction requirements of purpose 1. Again, the combination of existing Site boundaries and the local road network, provide permanent and clearly recognisable physical This section of the representation considers how the Site performs 2. To prevent neighbouring towns merging into one another: boundaries to the town. in landscape and visual terms in relation to the five purposes of the The Site forms part of the eastern fringes to West Malling. The Green Belt, drawing on the landscape analysis work set out in earlier nearest town to the east of West Malling is East Malling. There is As such, the inclusion of the Site fails to meet the requirements of sections and the Councils own Green Belt Study (September 2016). currently no intervisibility between these two settlements due to the purpose 3. extensive level of tree cover. The settlements are also separately The photographs on the following pages illustrate the key by the A228 road corridor which bisects the landscape north to 4. To preserve the setting and special character of historic characteristics of the proposed and existing Green Belt areas and south. The eastern edge of West Malling, including the Site, is well towns: As set out in the Green Belt Study of West Malling at page shows how the Site is disinctly different to these landscapes. contained visually and physically from the wider landscape. There is 36, “West Malling is an historic town, much of which is designated little sense of the presence of West Malling within the landscape to as Conservation Area... The historic eastern side of the town, 6.2 Green Belt Purposes the east of the town. The Site therefore does not fulfil this purpose. where the majority of the Conservation Area can be found, does not contain Green Belt...” Malling Abbey lies within the Conservation 1. To check the unrestricted sprawl of large built up areas: The Applying the questions and assessment criteria used in the Green Area and is designated as a Scheduled Ancient Monument. These Site does not form part of the towns identified in the Core Strategy Belt Study (Table 2 at section 3.1.11) in addition to the aspects two designations preserve the setting to the historic town without the as an ‘Urban Area’ but lies on the edge of a ‘Rural Service Centre’. considered under purpose 1, the following should be noted: need for another tier of policy. The range of Abbey buildings and its Appendix I of the study (at page 35) sets out that the existing “... grounds form part of this historic framework to the town and not part Green Belt to the west does help contain the area to the west, as it The landscape beyond the Site plays a key role strategically, not the of its setting. The setting to the town therefore lies beyond the Site. runs along the built form edge and presents visual containment and Site itself. clear definition in this area.”The Site is contiguous or enclosed by The Site fails, in landscape and visual terms, to meet the two or more distinct areas of built form and is well connected with Any increase in development within the Site will not result in a merger requirements of purpose 4. the existing large built up area. Furthermore, the landscape and of built-up areas, due to the level of physical and visual containment visual analysis has demonstrated that the Site, consistent with other the Site has from the wider landscape. 5. To assist in urban regeneration by encouraging the ecclesiastical buildings, forms part of the existing eastern Fringes of recycling of derelict and other urban land: The Site does not fulfil West Malling and that the series of road corridors can provide a clear, The existing boundaries to the Site, together with the local road either of these requirements. robust and defensible edge to the eastern edge of the settlement. network, together provide permanent and clearly recognisable physical boundaries to the town. Overall, the Site fails in landscape and visual terms to meet all five Applying the questions and assessment criteria used in the Green purposes of the Green Belt designation and should be excluded from Belt Study (Table 2 at section 3.1.11) the following should be noted: The Site, in landscape and visual terms, therefore fails to meet the the proposed new Green Belt designation. requirements of purpose 2. • The landscape beyond the Site plays a key role in containing the development of West Malling (both in terms of topography and 3. To assist in safeguarding the countryside from vegetation cover, not the Site itself. encroachment: The Site does not share the same characteristics as the countryside beyond Lavenders Road to the east or Water • The boundaries of the Site are clearly and permanently defined by Lane to the south (refer to the comparative images on the following the combination of walls and road corridors providing a defensible pages). Due to the existing range of land uses, the Site is not open physical boundary to the eastern edge of West Malling. countryside, but exhibits a number of similar characteristics to its immediate townscape. As such, the Site is considered to be part of The Site therefore, in landscape and visual terms, fails to meet the the townscape fringes rather than countryside.

37 Landscape Representation Land at Malling Abbey, West Malling, Kent

6. Application of Green Belt Purposes to Malling Abbey Grounds

Photograph Survey

Photograph illustrating typical farmed landscape character of the Photograph illustrating typical farmed landscape character of the Photograph Illustrating typical farmed landscape character of the landscape to the east of Lavenders Road which is proposed to be landscape to the north-east of West Malling which is proposed to be landscape of the southern section of the proposed Green Belt. Green Belt). Green Belt.

Photograph – Viewpoint 5 Illustrating the typical walled boundaries of the Site (with built form evident beyond) on the existing developed edge of West Malling on Swan Street. The Site in this view is also proposed to be Green Belt.

38 Landscape Representation Land at Malling Abbey, West Malling, Kent

6. Application of Green Belt Purposes to Malling Abbey Grounds

Photograph Survey: Photographs Illustrating the Character of the Existing Green Belt to the south of West Malling

39 Landscape Representation Land at Malling Abbey, West Malling, Kent

7. Conclusions

The majority of West Malling Abbey and its grounds is a Scheduled Ancient Monument; contains Grade I, II and II* Listed Buildings; forms the northern part of the locally designated Historic Park and Garden; and lies within a Conservation Area. The Abbey and its grounds are therefore subject to three planning designations.

A landscape and visual analysis of the Site reveals that the Site is well related to the urban fabric of West Malling, as it is enclosed to the north; west and in part the south by built form. Furthermore, the Site boundaries are defined predominantly by a wall, that follows the alignment of the historic road networks associated with Swan Street to the north; Lavender Road to the east; and Water Lane to the south. This combination of features provides a robust and clearly defined eastern edge to West Malling.

The characteristics of the landscape to the east of Lavender Road and to the south-east of Water Lane, are distinctly different to the Site and comprise a range of fields (in varying uses) and a number of individual buildings dotted within this agricultural landscape.

An assessment of the Site against the five purposes of the Green Belt has been carried out. In landscape and visual terms, the Site fails these tests on all counts. There is therefore no justification for the inclusion of the Site within the emerging proposed Green Belt designation.

The removal of the Site from the proposed Green Belt area would not alter the wider purposes of the Green Belt designation.

In landscape and visual terms, it is therefore our conclusion that the Site should not be included in the wider proposed Green Belt designation, as the wider designation beyond the Site adequately fulfils paragraph 80 of the National Planning Policy Framework.

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West Malling Abbey

Tonbridge and Malling Borough Council EIP – Matter 3

Appendix D

Local Plan Post-Submission Representation

Client Month YYYY 2

9th December 2019

Planning Policy Manager Andrew Watson Tonbridge & Malling Borough Council E: [email protected] Gibson Building DL: 01798 879050 F: 01732 01732 879051 Gibson Drive 23 Kings Hill Avenue Kings Hill West Malling West Malling ME19 4UA Kent ME19 4LZ www.savills.com

Dear Sir/Madam,

Re: Letter of Representation on Draft Tonbridge and Malling Local Plan

Introduction

Thank you for the opportunity to comment on the draft Tonbridge and Malling Borough Council (TMBC) Local Plan. This representation is made by Savills on behalf of the Diocese of Rochester (‘the Diocese’). This letter follows previous submissions made on the Local Plan in 2016 and 2018.

About the Diocese of Rochester

The Diocese of Rochester is one of 41 dioceses of the Church of England and was established by St Augustine in 604AD. Geographically the Diocese of Rochester covers North and West Kent and the London Boroughs of Bromley and Bexley; comprising 216 parishes with 239 churches and serving a population of 1.3 million.

Brief History of West Malling Abbey

The abbey was founded by Gundulf Bishop of Rochester as the abbey of the Virgin Mary for Benedictine nuns in about 1090. It was one of the earliest nunneries to be established after the Norman conquest. The Diocese currently leases the West Malling abbey site (‘the abbey site’) to the Benedictine Community (‘the Community’). The abbey and the town of West Malling were both established during the Medieval period, which means they have a historic association with one another in terms of the evolution and morphology of their urban development.

Existing Development and Future Plans

The abbey site has a varied planning history associated with it, but most notably in recent times has secured planning permission for:

‘Proposed demolition and replacement of the Pax House for theological training offices and library and the conversion of the Guest House into related non-residential centre, alteration of walls at vehicle access at Swan Street and associated works including parking area and demolition of garage’ (ref: 16/00340/FL)

The application sets out a case that the Community is aging and their ability to access, maintain and use all areas of the site effectively is becoming more difficult and that there is a surplus of accommodation within the precinct.

Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East.

Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD

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The Diocese, in conjunction with the South East Institute for Theological Education, required additional space for offices, day-time study, conferences and retreats, as well as a specialist library. The existing Pax House was in a serviceable condition but fell short on disability access, flexibility and thermal performance. The existing Guest House also fell below standards for fire compartmentalisation, fire detection, means of escape in the event of a fire and energy performance. The application, which has now been consented, provided a significant opportunity to ensure the continued use of the abbey site by the Diocese and the Community.

Future Use of the Abbey

As custodian of this historic site, the Diocese’s priority is to ensure the long term viability and sustainability of the Abbey estate. The Abbey site is already heavily-constrained in terms of its various planning designations (e.g. Historic Park and Garden, Scheduled Ancient Monument) and the imposition of a further Green Belt allocation would introduce an unnecessary and restrictive planning burden.

Planning Policy Framework

The most relevant sections of the 2012 National Planning Policy Framework (NPPF) in relation to Green Belt are set out below. Paragraph 80 of the NPPF explains that Green Belts have five purposes: 1. ‘to check the unrestricted sprawl of large built-up areas; 2. to prevent neighbouring towns merging into one another; 3. to assist in safeguarding the countryside from encroachment; 4. to preserve the setting and special character of historic towns; and 5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.’

Paragraph 83 explains that (emphasis added): Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.

In relation to the setting of boundaries, paragraph 85 goes on to state that: ‘When defining boundaries, local planning authorities should:  ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development;  not include land which is unnecessary to keep permanently open;  where necessary, identify in their plans areas of ‘safeguarded land’ between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period;  make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following a Local Plan review which proposes the development;  satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and  define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.’

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Proposed Green Belt Allocation around West Malling

The September 2016 Issues and Options draft Local Plan set out the extension to the Green Belt (pages 38 – 39) where paragraph 6.3.7 explained that: ‘Figure 11 (overleaf) suggests a proposed strategic extension to the Green 6.3.7.Belt in the vicinity of West Malling and Kings Hill. It is considered that this potential addition of 134 Ha would be a more reliable and defendable boundary that would contribute positively to purposes of the Green Belt.’ Some further evidence was provided in the Green Belt study (dated September 2016) on pages 35 - 36 and Appendix I. However, no rationale is provided anywhere as to how the extension complies with the relevant paragraphs of the NPPF. Paragraph 6.3.6 of the draft Local Plan (2016) states that: ‘…the preparation of the new Local Plan presents an opportunity to consider whether certain boundaries need to be re-aligned so that the Green Belt performs a more effective function (as measured against the five purposes outlined in the Government’s NPPF – see above). This could have the consequence of increasing the amount of land within the Green Belt in certain locations which, overall, could ensure the quantum of land within the Green Belt across the borough is not significantly eroded.’ It would appear that the rationale for the proposed extension has been established on a quantitative basis (i.e. TMBC is seeking to mitigate the loss of other Green Belt land that is being displaced elsewhere in the Borough by housing sites). This does not act as a sufficient justification for including the abbey site within the proposed Green Belt extension. It is also not a requirement of the NPPF to maintain the same net quantity of Green Belt land. Nor does it amount to exceptional circumstances under paragraph 83 of the NPPF. Green Belt Assessment Part 2 Since the Green Belt Study (Part 1), a Green Belt Assessment (Part 2) has been produced dated August 2018. The report explains (pages 12-13) how the extension meets the exceptional circumstances to justify an extension. However, only cursory detail is provided on this. The Diocese has a number of concerns with which are set out below. Notwithstanding these concerns, the criteria set out in paragraphs 4.7 - 4.10 could still be achieved without the Diocesan land being included. Assessment Against Paragraph 80 Criteria

The proposed Green Belt extension does not appear to have been informed by any credible evidence. The Green Belt study (part 1) simply provides an audit of the Green Belt assets, including around West Malling. It does not provide any qualitative judgments as to how the proposed extension meets the criteria set out in paragraph 80 of the NPPF.

Furthermore, it does not set out any ‘exceptional circumstances’ as to why the abbey site should be designated as Green Belt. It is therefore difficult to understand the rationale for including this land. The Diocese has instructed Farbrik (landscape architects) to undertake a review of the proposed extension to assess whether it meets the requirements of the NPPF.

Fabrik’s report, which forms part of this representation, explains why the land does not meet the relevant Green Belt criteria under paragraph 80. Below, I have gone on to explain below the other shortcomings of the proposed allocation against other relevant paragraphs of the NPPF.

Assessment Against Paragraph 85 Criteria

When assessed against the relevant criteria in paragraph 85, the proposed allocation does not comply with the NPPF. I have provided specific reasons for this below.

“…not include land which it is unnecessary to keep permanently open.” [BP2, paragraph 85]

The land is not open in nature and it is not necessary for it to be kept as such. The abbey site has a much closer relationship with the urban settlement of West Malling, because of its historic association with the settlement and its more urban character (e.g. buildings, allotments, structures, boundary walls, etc.).

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It is also notable, to the best of the knowledge of the Diocese, that planning policy officers have not visited the abbey site as part of their Local Plan preparation work to analyse it (e.g. assess the extent to which the site is open, etc.). Without officers having seen the abbey site, it is difficult to understand what the Council’s logic might be for proposing the site as a Green Belt designation. define boundaries clearly, using physical features that are readily recognisable and likely to be permanent [BP6, paragraph 85]

The abbey site has clearly defined boundaries that relate to nearby roads (Lavenders Road, Water Lane and Swan Street). The northern, southern and western boundaries abut the urban area of West Malling, giving the abbey site a more urban context and character. The land to the east of the site is much more open in nature and would therefore be more appropriate as Green Belt land.

Assuming that TMBC can provide a rationale for allocating the other land as Green Belt land, a far more logical boundary would be the adjoining roads that run around the perimeter of the abbey site, thus excluding it from the proposed Green Belt allocation.

Additional Evidence Submitted by TMBC as part of Local Plan Examination

The Spatial Strategy Topic Paper (2019) identifies that:

‘In addition the strategy alters the outer boundary of the MGB to extend the coverage eastwards justified by exceptional circumstances because it strengthens the purposes of the Green Belt in this part of the borough without compromising the ability of the Plan to meet the development needs. The outcome is a net increase of Green Belt land of approximately 200 hectares.’ (para 1.2.3)

Nowhere is the reason for the Green Belt expansion provided. The point seems to be more that TMBC has secured a net increase of 200 hectares. This is a quantitative increase but is not justified by a rationale for why this land meets the purposes of the Green Belt. It is therefore flawed.

Furthermore, it is noted that TMBC has included, within the Sustainability Appraisal report addendum, a rationale for extending the Green Belt. However, this is post-rationalisation to fit a pre-determined approach to delivering a net gain in Green Belt land.

In their letter dated 23rd Mary 2019, the Inspectors ask:

‘… can the Council explain whether any alternative policy approaches to designating this new land as Green Belt have been considered, and how the sustainability appraisal process has influenced the option pursued.’

TMBC’s letter (dated 28th June) and the newly presented information that forms part of the Local Plan consultation responds to this point. However, the question has not be satisfactorily addressed.

Land at Hildenbourough

The Diocese own land at Hildenborough which is designated under policy S1 (g) of the adopted Local Plan as: safeguarded land for school playing fields. It is understood that the School has no need for the land to be used as playing fields. The land is now proposed to be designated as an open space in the new Local Plan (LP13.OS.299 – Hildenboorugh Church Grounds). For clarity, the land in question does not form part of the grounds of the Church of St John the Evangelist, Hildenborough so the designation LP13.OS.299 is misleading. We would like to request that the description is amended. The Diocese object to this designation on the following grounds: 1. Evidence for open space designation – the Open Space Assessment (March 2018) does not provide any justification for why the site has been designated as an open space.

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2. Accessibility – the land is included in Appendix P Open Spaces (Publicly Accessible). However, the land is private and there are no rights of access over it aside from the public footpath that runs to the west of the site. It is therefore incorrect to identify it as being publicly accessible. 3. Recreation land to the north – there is a large area of recreation land to the north which is publicly accessible. This provides suitable and accessible space for the local community. Therefore, there is sufficient public open space in the local area, and the Diocesan land does not need to be safeguarded as open space. 4. The land is close to a settlement boundary, and sustainably located. It will therefore serve as a suitable future development site.

Conclusion

The Diocese would be happy to discuss these comments with you at your convenience if that would be helpful, and I look forward to hearing from you if this would be of interest.

Yours Sincerely,

Andrew Watson • MRTPI Associate Director e [email protected] • t 01732 879050

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West Malling Abbey

Tonbridge and Malling Borough Council EIP – Matter 3

Appendix E

Excerpt from Green Belt Study Part One

Client Month YYYY 2

West Malling Abbey

Tonbridge and Malling Borough Council EIP – Matter 3

Appendix F

Excerpt from Green Belt Study Part Two

Client Month YYYY 2

Green Belt Stage Two Report August 2018

4. Exceptional Circumstances for the extension of the Green Belt Designation

4.1. There is one proposal in the Local Plan to extend the Green Belt designation to the east of West Malling to cover an area between the settlements of West Malling, Leybourne (part of the Medway Gap urban area), East Malling and Kings Hill (excluding the proposed strategic housing allocation at Broadwater Farm, north of Kings Hill).

4.2. The Local Plan – The Way Forward document (September 2016) proposed a more modest extension to the Green Belt around West Malling. This involved re-aligning the outer Green Belt boundary to the A228 Ashton Way By-Pass, a piece of infrastructure that was constructed after the detailed boundaries were established.

4.3. The proposed extension was supported by consultation responses but many felt the extension should go further east to prevent the coalescence of settlements. With this in mind, the location of the outer boundary of the Green Belt at this location was re- examined and consideration was given to extending it east to Wateringbury Road.

4.4. When examining the coverage of the Green Belt it is important to have regard to the purposes it serves in the borough and whether or not these purposes can be strengthened through the redefining of the boundary in a way that does not put at risk the delivery of the proposed Local Plan strategy for meeting identified development needs. These are considered to be exceptional circumstances for extending the Green Belt boundary through the Tonbridge & Malling Borough Local Plan-making process.

4.5. The five purposes of the Green Belt are set out in para.80 of the NPPF (March 2012) and formed the basis of the Stage One Study (2016). In respect of the Green Belt covering Tonbridge and Malling borough the relevant purposes are:

• To check the unrestricted sprawl of large built-up areas; • To prevent neighbouring towns merging into one another; • To assist in safeguarding the countryside from encroachment; • To preserve the setting and special character of historic towns.

4.6. In order for there to be exceptional circumstances, each of these purposes needs to be strengthened by extending the Green Belt boundary whilst not frustrating the delivery of the proposed development strategy in the new Local Plan.

4.7. To check the unrestricted sprawl of large built-up areas - Extending the outer boundary to Wateringbury Road would help prevent the coalescence of Kings Hill with the conurbation of the Medway Gap area, two significant built-up areas in the borough. This extension is consistent with the proposed Local Plan strategy because it would allow for additional housing development at Broadwater Farm whilst restricting sprawl of these two urban areas.

12 Green Belt Stage Two Report August 2018

4.8. To prevent neighbouring towns merging into one another - The proposed extension would help strengthen this purpose by preventing West Malling, East Malling, Kings Hill and the Medway Gap from merging, thereby protecting their individual integrity.

4.9. To assist in safeguarding the countryside from encroachment - The proposed extension of the outer boundary would strengthen this purpose without frustrating the ability of the new Local Plan to address assessed development needs in a sustainable way. It would allow for the delivery of housing at Broadwater Farm north of Kings Hill whilst safeguarding the countryside north of this site from encroachment.

4.10. To preserve the setting and special character of historic towns - West Malling and East Malling are historic settlements including several Listed Buildings and being covered by Conservation Areas. The proposed extension of the outer boundary to Wateringbury Road would strengthen this particular purpose of the Green Belt by protecting the setting of these settlements which would help preserve their special characters.

4.11. It is clear from this analysis that exceptional circumstances exist for extending the outer boundary east to Wateringbury Road because such a change would strengthen the four purposes the Green Belt serves in Tonbridge & Malling in a way that is consistent with the Local Plan strategy for meeting identified requirements for sustainable development. The Local Plan proposals in this part of the borough therefore constitute an integrated and complementary strategy that can serve the area well in the long-term. From a strategic perspective, this extension would ensure a closer alignment with the outer boundary defined in the boroughs of Maidstone and Gravesham.

5. Summary and Conclusions

5.1. This report sets out the exceptional circumstances for the proposed amendments to the Green Belt boundaries that are necessary to deliver a sustainable pattern of development that will meet assessed needs and achieve wider planning objectives set out in the Local Plan.

5.2. If implemented the amendments would lead to a net increase of Green Belt land of approximately 200 hectares.

5.3. Appendix 1 illustrates the proposed amendments to the Green Belt designation that are supported by the exceptional circumstances set out in this report.

13 Green Belt Stage Two Report August 2018

Site where exceptional circumstances are made for extending the Green Belt Designation Map 8 Land east of West Malling to Wateringbury Road

© Crown copyright and database rights 2018 Ordnance Survey 100023300

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West Malling Abbey

Tonbridge and Malling Borough Council EIP – Matter 3

Appendix G

Excerpt from Green Belt Exceptional Circumstances Topic Paper

Client Month YYYY 2

Andrew Watson Hannah Haddad Associate Director Graduate Planner

+44 (0) 1732 789 785 +44 (0) 1732 789 776 [email protected] [email protected]

savills.co.uk Diocese of Rochester August 2020 1