Representations to Tonbridge & Malling Local Plan Examination on behalf of Kitewood Estates in relation to Matters 2 and 3 in the Inspector’s Agenda for discussion at the Examination on 3 to 5 November 2020

Date: October 2020

The Elms, Oakwood Park Business Centre, Bishop Thornton, Harrogate HG3 3BF Tel: +44 (0)1423 206620 Email: [email protected] Registered in England No.12096560

Representations

Contents

1.0 Introduction ...... 2

2.0 Response to Inspectors’ questions on Matter 2 – the Spatial Strategy, settlement hierarchy; distribution and site selection (Policies LP2; LP3; LP4 and LP5 ...... 5

3.0 Matter 3 – Metropolitan Green Belt Policy LP3 ...... 11

Appendices

Appendix 1: Extract from Reg 19 representations – site plan and overhead photographs

Appendix 2: Masterplan from Reg 19 representations

Appendix 3: Figure D from Reg 19 representations report

Appendix 4: Study of Green Belt purposes performed by Kitewood site from Reg 19 representations report

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1.0 Introduction

1.1 This statement has been prepared on behalf of Kitewood Estates relating to its objections to the Tonbridge & Malling submitted (Regulations 19) Local Plan. These were originally submitted by consultants, WYG, in a document dated 16 November 2018.

1.2 These representations have been made taking account of the Inspectors’ guidance (Doc ED50) on representations to Matters 2 and 3 (and indeed all other Matters). They do not, therefore, seek to repeat in detail the previous representations made by WYG as many of the points made in those representations apply to the discussion on Matters 2 and 3 – and particularly the questions that are asked by the Inspectors in doc ED56. In these terms, certain conclusions in the WYG report will be relied upon in the further discussions at the Examination in response to the Inspectors’ questions.

1.3 Since the closure of the deadline for submissions in relation to the Regulation 19 version of the Plan, the objectors have been aware of the ongoing correspondence between the Inspectorate and the Council in relation to a number of matters relating to the soundness of the Plan. This includes the Inspectors’ concerns relating to the justification and evidence base to support key elements of the Plan, including its Spatial Strategy; the approach to the Green Belt and also co-operation issues.

1.4 Kitewood shares those concerns and welcomes that the Inspectors have raised important questions (similar to the position set out in the WYG report) particularly relating to the issues of the Spatial Strategy in the Local Plan and justification for it in their correspondence. The Council has not yet, in Kitewood’s view, adequately responded to such queries and it is hoped the Examination sessions will allow further clarification on key points.

1.5 Kitewood controls land to the south of the Tesco depot which lies to the west of Hays Road in Snodland. A site location plan together with some overhead photographs of the site are set included in Appendix 1. The site is some 2.42 hectares in size and is located immediately to the east of Hays Road lying between the Tesco depot to the north and the Sandhole Veterinary Centre to the south. As the plans in Appendix 1 show, there is therefore built development to the north and south of the site. The western site boundary comprises a substantial hedge line beyond which lies the Oast Park Golf Centre and open land. The boundary of the AONB is located further to the west. The potential development capacity

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of the site shown on in Appendix 2 are that a mix of uses could be accommodated with approximately 1.2 hectares being for housing; 0.5 hectares for alternative uses, eg small scale employment, and then open space. Further discussion in relation to the characteristics of the site and its contribution to the Green Belt is set out under Matter 3 later in this statement.

1.6 Snodland is one of the defined five main urban areas in Tonbridge & Malling. Notwithstanding the status of Snodland as one of the principal urban areas within the Borough it is proposed to make no new allocations for housing in the settlement in the Local Plan up to 2031. The settlement framework of Snodland is such that it lies mainly to the east of the railway line with the main A228 road running north-south through the eastern part of the settlement. Much of the land to the east of the railway line is in either flood zones 2 and 3, so there is no realistic potential for expansion of the settlement in that direction. Residential and commercial development is contained on the southern side by the A228 (and mainly onto the east as well). The settlement extends west along a number of estate roads – including Paddlesworth Road and St Catherine’s Way. The built-up framework of the settlement extends considerably further west than the Kitewood site – including the Tesco distribution centre immediately to the north of it. It is proposed to allocate four new site allocations for employment purposes.

1.7 The focus of Kitewood’s concern about the Local Plan – set out in answer to the Inspectors’ questions in Doc ED56 – is that there is no reasoned justification for the lack of housing allocations in Snodland as one of the principal urban areas within the Borough. The Council has accepted (see Topic Paper ED10) in principle that there is a need to review Green Belt boundaries to accommodate development requirements and that development should be concentrated in the first instance within and adjacent to the main urban areas to promote sustainable patterns of development . So, on that basis, it will be logical to conclude that Snodland should be one of the principal locations for growth based upon the availability of services and accessibility to places of work and public transport.

1.8 If Kitewood’s representations are accepted, the Inspectors are recommended to advise the Council to review the potential for growth around Snodland; to accept the principle of further housing development in that settlement (together with employment growth) and to review the Green Belt boundary in a sensible way (as opposed to what has been done in

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relation to the Green Belt study the Council is relying on) to arrive at a relatively small but proportionate expansion of Snodland on the Kitewood site to help meet housing and employment needs to 2031 and beyond.

1.9 Whilst Kitewood made representations to the Regulation 19 Local Plan in relation to the calculation of objectively assessed need (Matter 4) – it is content to rely on the position adopted by the HBF on this issue. However, we do consider (as appears to have been confirmed in discussions under Matter 1 at the Examination) that the Council appear to have rushed the final stages of the Plan-making stages to ensure examination under the 2012 NPPF for the purpose of avoiding the Standard Method for calculating housing need which would have resulted in the requirement for around 3,000 additional dwellings in the Plan period. Furthermore, the likelihood of housing requirements changing – particularly significantly increasing – as part of the latest Government pronouncements on the scale and nature of national housing requirements should not be ignored as part of this Local Plan process. The ability for the Borough Council’s neighbouring Local Planning Authorities to meet their own needs is questionable and proximity to London is likely to exacerbate the issues. In consideration of the considerable amount of time it has taken the Council to reach the Examination stage, it is considered that an early review of the Plan will be too late to deal with these fundamental matters. There should be a debate about the likely need for housing both in this Plan period and beyond – hence requiring a re-definition of Green Belt boundaries and the identification of safeguarded land to ensure, in accordance with the NPPF, that Green Belt boundaries endure beyond the end of this Plan period in 2031.

1.10 Kitewood would also wish to reiterate the point it made at Regulation 19 stage that it – in common with a number of other parties – is concerned about the Plan period finishing in 2031. In the context of NPPF advice about the minimum period for Plans to cover, when this Plan is adopted in, say, 2021 it is likely to have less than ten years still to run. This is of concern in itself but also highlights the need to ensure (see Matter 3) the need for Green Belt boundaries to ensure beyond this Plan period – hence the need for a more comprehensive and focused approach to the issue of safeguarded land.

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2.0 Response to Inspectors’ questions on Matter 2 – the Spatial Strategy, settlement hierarchy; distribution and site selection (Policies LP2; LP3; LP4 and LP5

2.1 It is considered the questions raised by the Inspectors are in a logical order to enable a full discussion of Matter 2. For convenience, therefore, the Kitewood response to questions has been done in the order of the questions and where convenient we have grouped the responses to several questions together.

Questions 1, 2, 3 and 4

2.2 These questions relate to how the strategic policies for the area have been set out and justified (Topic Paper ED12); what evidential basis exists for them and whether Policy LP5 clearly defines the settlement tiers; that they are soundly based and supported by robust evidence.

2.3 Kitewood agree that in principle the focus for growth should be that part of Tonbridge & Malling Borough which falls within Maidstone HMA where the majority of growth within the first five years of the Plan period has been located. In principle Kitewood has no issues with the Local Plan setting out a settlement hierarchy comprising urban areas; rural service centres; other rural settlements and rural areas. Whilst there may be some debate about which settlements may be included in what category in the rural areas, Kitewood does not dispute that the five main urban areas in the borough are those defined in Policy LP5. Paragraph 2.27 of the Spatial Strategy Topic Paper gives the justification for which settlements are in which category and confirms those settlements that feature at the top of the hierarchy have the best sustainability credentials. Whilst there could be some debate about the evidence which has been put forward to support that hierarchy – the Council appears to rely on the adopted Core Strategy for a continuation of the settlement hierarchy rather than undertake a review of the sustainability credentials of the urban areas. However, Kitewood does not object to the results of that process. It is though relevant to Kitewood that Snodland continues to be defined as one of the five urban areas in the district which by definition have the best sustainability credentials to accommodate more development as per paragraph 2.2.17 of ED12.

Question 5

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2.4 From the November 2019 WYG statement, Kitewood’s principal concern is that the distribution of housing and employment in the Local Plan is not consistent with the Spatial Strategy and settlement hierarchy in Policy LP5 – with particular regard to the lack of housing allocation in Snodland. The apportionment of development to each settlement (or not as the case may be) is not soundly based and the reasoning behind the apportionment is not made clear.

2.5 The first observation is that despite Snodland being one of the five principal urban areas with the “best sustainability credentials in terms of availability and accessibility to a range of services and public transport nodes including schools; health care shops; bus services and train stations” no new housing is proposed to be allocated in the settlement up to the end of the Plan period in 2031. Although 2.2.17 of ED12 confirms that some 52% of new dwellings required are within or adjacent (our emphasis) to urban areas, there is no reason given in the justification for this distribution as to why there are no new housing sites proposed in Snodland. Table ED19b confirms that Snodland had the third highest number of housing completions from April 2011 to March 2018 with a further 248 dwellings committed with extant permissions at 31 March 2018 (the fifth highest amongst the various settlements). No evidence has been put forward as part of ED12 to say why Snodland is not being seen appropriate not to allocate further housing land in Snodland. There is no evidence put forward to suggest there is any over-riding reason in relation to the availability and accessibility of services in Snodland that have resulted in no allocation for housing being made. On the contrary, the ability of services to deal with additional housing (whether funded through s.106 or not) is given as a reason why Snodland is identified within a main urban area. The restrictions on the expansion of the settlement in the Green Belt are matters dealt with below.

2.6 The lack of provision for new housing in Snodland is made even more unjustifiable by the proposed allocation of additional land for employment within the settlement in Policy LP34. Four sites are allocated in Snodland in that policy. This is consistent with its status as a main urban area. The lack of balance between no additional housing being allocated compared to the additional employment allocations is unsound and inconsistent with the conclusions of document ED12.

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2.7 As set out in the WYG statement of November 2019, the Council is seeking to bring forward for development the strategic site (Policy LP27) at Bushey Wood. For the reasons set out in paragraphs 2.28 to 2.33 of the WYG statement, the allocation of the Bushey Wood site is clearly inconsistent with a settlement hierarchy. The village of Eccles where Bushey Wood is located is within the third category referred to as ‘other rural settlements’. Its expansion to accommodate 900 homes fails to accord with the strategy and requirements of Policy LP5. The Plan is therefore proposing an unsustainable pattern of development.

2.8 It is recognised the land at Bushey Wood was originally identified in the 2007 Core Strategy as an area of opportunity and was safeguarded for future development. This seems to be the main reason why the allocation has been made – ie it was identified as having housing potential in the Core Strategy. In Kitewood’s view the review of this Local Plan should re- consider, notwithstanding the intentions of the Core strategy, whether the potential area identified for development (it was not a specific allocation) remains sustainable in the context of the position of Eccles within the hierarchy of settlements. The ability of the five main urban areas and settlements above Eccles in the hierarchy should be reviewed to see whether they can accommodate the 900 or so dwellings intended for that site in a more sustainable way.

2.9 Whilst Kitewood has a number of concerns about how the Eccles site is being delivered (again set out in the WYG document), the delivery of this site – given the somewhat vague nature of the Statement of Common Ground (document ED27) between the authorities and the developer – could also be doubted. The concerns which Kitewood expressed in its November 2019 document about the conclusions about the sustainability of Bushey Wood (Sustainability Appraisal September 2018) remain relevant.

2.10 Kitewood has no particular comment to make in relation to questions 6 and 7.

Question 8

2.11 Kitewood does not consider the Spatial Strategy hierarchy and distribution of development as justified and sustainable – so the Plan is unsound. Options for alternative development strategies have not sought, as a priority, to examine how many additional dwellings could (taking a realistic approach to opportunities for Green Belt review) be accommodated in the main settlements before then moving down to the lower tier settlements. The Bushey Wood

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site and indeed the other site at South Aylesford appear to have been taken as a given and the Local Plan review strategy has been worked around the intention to develop those sites. Whilst certain options for housing development (though not taken very far) were identified at Snodland, no sensible reasons were given to why the principle of further housing development in the main urban area was not pursued as part of the Local Plan review.

Question 9

2.12 Question 9 refers to what extent the spatial strategy seeks to focus on non-Green Belt sites and how the Green Belt has influenced Spatial Strategy settlement hierarchy and distribution development.

2.13 To a great extent Kitewood’s views on this issue will be set out in the questions on Matter 3 on the Green Belt. However, having accepted that the principle of Green Belt release was necessary to accommodate housing requirements (see Green Belt Exceptional Circumstances Topic Paper) and that land within and adjacent to main urban areas should be prioritised, that approach has not been applied consistently to the strategy for development for the main urban areas including Snodland.

2.14 As will be discussed under Matter 3, the assessment of the sensitivity of various areas of the Green Belt, including that to the west of Snodland, used areas that were unrealistically large so the conclusion about the impact of releasing such areas from the Green Belt was therefore over-estimated. The potential to release smaller areas from the Green Belt on the fringes of main urban areas such as Snodland (and the Kitewood site is relatively modest in size at 2.4 hectares) was not undertaken.

2.15 Thus, whilst it is right for the extent of Green Belt constraints around urban areas to be assessed and considered, in terms of whether exceptional circumstances exist to change Green Belt boundaries through Local Plan reviews, the extent to which it was done around main settlements was not at a level that allowed the true impact of releasing smaller areas for housing or employment to be quantified. Although the Council is correct in regarding the Green Belt as an appropriate constraint in considering the Spatial Strategy for housing allocations, they did not (particularly in the case of Snodland) assess the impact in Green Belt terms on a realistic basis. Thus, the conclusions arrived at are unsound.

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Question 11

2.16 The above discussion also relates to question 11 which asks why there are no housing allocations proposed in places including Snodland. There is no justification for the lack of allocation given:

1. The identification of Snodland as an urban area with a good range of supporting services (see paragraph 2.2.17 of ED12).

2. There are allocations proposed for employment that are not supported by new allocations for housing.

3. The assessment of Green Belt constraints around Snodland over-estimated the potential impact of development by looking at wider areas for release than would be required (see Matter 3).

4. The amount of housing land that could be allocated in Snodland either through this Plan or through safeguarded land (see Matter 3) would result in less housing being required in the lower tier settlements which are less sustainable.

2.17 It is also relevant to refer to the current settlement framework of Snodland. This basically shows that expansion of the settlement to the east (beyond the railway line) is effectively prevented by land being in areas of high risk of flooding (see Figure D produced in the WYG report in Appendix 3). The A228 provides a reasonable definition of the southern edge of the settlement and the AONB is located to the west – without including certain land including the Kitewood site between the AONB and the settlement boundary. Expansion to the north is potentially possible although that may result in a merger with the smaller settlement of Holborough. Therefore, expansion to a limited degree on the western side of Snodland appears to be the most logical location for housing growth.

2.18 The fact that the Spatial Strategy does not allocate new housing at Snodland either within or adjacent to the settlement is a clear failing of the Plan which has knock-on effects elsewhere in the settlement hierarchy.

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Question 12/Question 13

2.19 Of the five strategic sites identified in Policy LP3, Kitewood has expressed reservations about the land at Bushey Wood (Policy LP27) and the South Aylesford site (LP28). The reasons for that concern are set out in the WYG report which are therefore not repeated in the context of the answers to the questions in this submission. The concerns which are particularly expressed about Bushey Wood relate, inter alia, to the deliverability of that site and whether a large site in that location contributes to providing sufficient mix of large, small and medium sites to achieve a flexible land supply.

Questions 14 and 15

2.20 The Inspectors’ questions relate to the Council’s site assessment and selection methodology and the timing of that exercise which required sites to be submitted up to September 2015. Kitewood’s concern about the call-in procedure; the duty to co-operate and the Plan period remain as set out in section 2.5 of its 2019 representations.

2.21 It is noted that in document ED13 – the Local Plan Sustainability Appraisal Addendum – none of the options assessed show the possibility of any sites being considered within or adjacent to Snodland (see page 24 of ED13). That assessment highlights that option 2 is the best option to progress but that the chosen option (option 5) does not present significant concerns. However, the allocations in both options do not in principle include the potential to allocate land within or adjacent to one of the main urban areas. To that extent the site assessment methodology is somewhat irrelevant as far as Kitewood is concerned because the principle of further allocation of Snodland was excluded at a strategic level.

2.22 Therefore, as a result of the answers to the Inspectors’ questions, it is requested that the Inspectors advise the Council that the settlement strategy and allocations based upon it (ED12 etc) are not soundly based; the Council should review the allocation of housing based on the greater priority of allocations in the main urban areas with a particular regard to the potential for allocation of land for housing to support new employment development at Snodland.

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3.0 Matter 3 – Metropolitan Green Belt Policy LP3

3.1 In relation to the Inspectors’ questions on Matter 3, those questions 1, 2 and 8 relate to the NPPF requirements for the circumstances in which a review of Green Belt would be appropriate. The Council’s approach to this matter is to refer to the exceptional circumstances test identified within the NPPF and other relevant documents and then to see whether such circumstances apply to justify the principle of land being released from the Green Belt for development purposes. Along with that the Council then have prepared a Green Belt review as an evidence base which informs the Plan.

3.2 It is Kitewood’s position that the methodology that has been used to review the Green Belt – accepting these conclusions have informed the Local Plan – has not been sound for the reasons set out below. Whilst Kitewood accepts the position about the essential characteristics of the Green Belt being openness and permanence; and that the five purposes they serve need to be considered on a site by site basis, the example of how the Council addressed the matter of Green Belt review around Snodland is not a sound way of reviewing the Green Belt.

Questions 5, 6, 7 and 9

3.3 The Council, in Green Belt Exceptional Circumstances Topic Paper, accepts that the circumstances identified in section 1 lead to the conclusion that “intrusions into the Green Belt defined in the adopted Development Plan are required” to accommodate further sustainable patterns of development (which is agreed by Kitewood). However, the Green Belt review they have carried out unfortunately has a number of errors in approach which make the process and the conclusions arising from it unsound.

3.4 These procedural errors were explained in the WYG document in November 2019 to the Regulation 19 submitted Plan. Kitewood still has the concerns about that process which relates to the fact that Part 1 of the Green Belt review (page 63, paragraph 3.1.2) confirms that in order to undertake the review the borough was divided into Parish/study areas and then further parcels where required. The Green Belt to the west of Snodland was appraised as one single parcel despite the study identifying that the smaller parcel of the Green Belt including the Kitewood site – bordered by the Tesco depot to the north, the Kent Hills AONB to the west (which does not include the Kitewood site) and the urban area of Snodland to

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the south and east is “removed somewhat from the wider expanse of the Green Belt” (see page 10 of Part 2 to the study in Appendix D).

3.5 The Plan showing the existing urban area defined by in the study and the Kent AONB confirms that there is existing built development within the Green Belt between the AONB boundary and the existing urban area. It remains unclear to Kitewood why this smaller area of land was not considered on its own merits in Green Belt terms and inevitably by considering the impact of releasing larger areas of Green Belt, the conclusion was bound to exaggerate the impact of releasing a smaller area.

3.6 The conclusions of stage 2 of the Green Belt assessment sets out the Council’s exceptional circumstances case for removing and extending Green Belt but does not explicitly consider the possibility of looking at smaller areas where development might be realistically considered in Green Belt terms – particularly on the edge of main urban areas where the settlement strategy is seeking to concentrate most of that re-development.

3.7 The assessment of the contribution of the wider Green Belt west of Snodland compared to the contribution of the area including the Kitewood site which is accepted as being removed from this wider Green Belt was set out by WYG in its November 2019 report. The tables carrying out that assessment remain relevant to the Examination and are therefore set out in Appendix 4. The conclusions show, not surprisingly, that the Green Belt value of the smaller area is considerably less than the area identified for assessment in the Council’s study. This particularly relates to two of the four purposes of the Green Belt where no contribution (preventing towns from merging and preserving and setting the special character of historic towns) is performed by the smaller area. Whilst it is accepted the sub- parcel does partially serve purposes 1 and 3 of the Green Belt, in the context of the need for additional housing resulting in the release of Green Belt, the implications of removing a small parcel of land from the Green Belt on the edge of a defined urban area to accommodate housing would be acceptable. This particularly assists the situation where no new housing is allocated in a main urban area. This could all potentially constitute the exceptional circumstances required for the boundary to be moved as part of the Local Plan review.

3.8 The Council therefore missed the opportunity because of the procedures adopted in the Green Belt review to assess the realistic impact of a relatively small release of land for housing and employment would make. These failings have also been applied in other parts

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of the Green Belt review although Kitewood is clearly most interested in how it has affected the Council’s decision not to allocate its site at Snodland. The Green Belt review process would appear to be a principal reason why no further housing land has been allocated at Snodland. On the basis that the procedure is unsound the opportunity to allocate land adjacent to a main urban area has therefore been missed on spurious grounds.

3.9 Therefore, in the context of the Inspectors’ questions 7 and 8 the decisions made about alterations to the Green Belt and the proposed Spatial Strategy distribution of housing are, in the case of Snodland, simply not connected. The decision about whether there are sites that can realistically be put forward for release from the Green Belt has not been properly carried out and the knock-on effect of this appears to be that there are no housing sites proposed within Snodland contrary to the objectives of the Spatial Strategy.

3.10 Kitewood has no particular comment to make in relation to questions 10 to 14 of the Local Plan. However, in relation to questions 15 and 16 – safeguarded land – it is not considered the Local Plan (based on the Green Belt review) does a comprehensive exercise to assess whether across the borough as a whole – including the main settlements – there is a coherent strategy for safeguarding of land for future development beyond 2031 that is currently Green Belt. Since the submission of the Local Plan the Government’s emerging proposals for a change in the planning system (including Local Plans) has now been put forward for consultation purposes. The advice in NPPF (2012), which was continued to the 2019 version, is that the Local Plan review process should, inter alia, establish Green Belt boundaries which should endure beyond the Plan period.

3.11 A number of local authorities are guilty, in Kitewood’s view, of not adhering to this guidance by not carrying out a realistic or comprehensive review of whether the existing Green Belt boundaries will endure in the long term, particularly around major settlements where housing growth beyond the Plan period is inevitable.

3.12 The opportunity should not be missed in Kitewood’s view for this Local Plan review to carry out a suitably comprehensive exercise and to look more widely at the potential for safeguarded land. That exercise could, in the first instance, simply be restricted to land in the Green Belt on the fringes of urban areas – given those urban areas are likely to remain the most significant locations for future growth beyond the Plan period. The allocation of housing land ‘adjacent’ to urban areas is a main objective of Local Plan policy. In

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circumstances where much of the land adjacent to certain urban areas is Green Belt, that in itself means that the Local Plan review – even relating to beyond 2031 needs to be more proactive about the scale and location of safeguarded land in reviewing the Green Belt boundary.

3.13 Thus as a result of Kitewood’s representations on Matters 2 and 3, it is requested the Inspectors advise the Council to re-assess the contribution which land on the edge of the urban area of Snodland to housing delivery which will ultimately result in the site being an allocation in Policy LP25. The re-assessment of the impact of such development (which is relatively small in scale) in Green Belt terms should be carried out to justify the allocation of the site for housing. If such an allocation is not seen as necessary in the Plan period, then the issue of the safeguarding of land from the Green Belt for development beyond the Plan period should be comprehensively assessed in the circumstances of preparation of the Local Plan. If that exercise is done, then the Kitewood site to the south of the Tesco Depot at Snodland should be included as safeguarded land in Policy LP32.

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Appendix 1

Extract from Reg 19 representations – site plan and overhead photographs

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Urban & Landscape Design

Land South of Tesco Depot, Snodland

Prepared on Behalf of Kitewood Estates

November 2018 Wider Context Plan

A228

Paddlesworth Rd

The town centre Sondland train station

Snodland Church Constitution Hill of England Primary School Snodland Train Station

Malling Rd

Birling Rd

St Benedict Rd

Christ Church The Holmesdale School St Katheri ne ’s

L St.Katherine’s n Saltings Rd School and Nursery

Hollow Ln The Holmesdale School Neville Park

Hays Rd Tesco Distribution Centre

Malling Rd Oastpark Golf Course Leybourne Leybourne Lake watersports Oastpark Lakes Country Golf Course The Site Park A228

Key

The Site

Town Centre

Green Belt Areas of Outstanding Natural Beauty Kent Downs (Areas of Outstanding Natural Beauty) Urban Region A228 Industrial Areas New Hythe Sites of Special Scientific Train Station Interest PROW Bus Route 1 St Katherine’s Ln

Snodland Rd Local Context Plan St Benedict Rd St.Katherine’s School and Nursery

Hollow Ln

Snodland Rd The Holmesdale School

Hollow Ln Tarmac

Quarry Sandy Ln Sandy

Tesco distribution Centre Existing public rights of way Holmesdale Technoloy College

Hays Rd Simpson Rd Tesco Distribution Centre

Hollow Ln

Malling Rd

Apple Cl

Freemasons Arms Tarmac Quarry Sandhole Hays Rd Barn Brook Ln The Site

MallingShell Rd Garage Sandhole Lakeside Veterinary Centre A228 Oastpark Golf Course

Sandhole Barn Existing residential development near the site

Leybourne Lakes Country A228 Park

RSPCA Leybourne Leybourne Animal Centre Lake Watersports

Key

The Site

Green Belt Areas of Outstanding Natural Beauty Sandhole Veterinary Centre Roundabout Urban Region

Industrial Areas

Quarry

PROW Laybourne Way Bus Route and Stop 2 Constraints Plan

View overlooking the Tesco Distribution Centre roof Large area for embankment with a height drop from the site around 3m at the highest point

Hays Rd

Slope up

Existing electricity overhead cable with 10m buffer up Slope Existing trees along the eastern edge screening the

on each side site from Hays road

Slope up Slope Slope up Slope

Slope up

Existing vegetation screening the site from wider The site raising up towards north-western edge landscape

Key

The Site

Noise

Flood Zone 2

Electricity Overhead Cable Existing agricultural building and fence on the site Area within Flood Zone 2 Electricity Overhead Buffer

Existing Trees

Embankment 3 A228 Development Areas

Approximate area in ha. 8 m

Residential 1.17 Ha Development Area

Area for Alternative 0.45 Ha Uses

Open Space 0.80 Ha 8 m 20 m 1.09 Total Area 2.42 Ha Ha

Hays Rd

5 m

0.08 Ha

8 m 0.45 Ha

Key

The Site Electricity Overhead 20 m Buffer Residential Development Area

Potential Development Area for Alternative Uses

Proposed Access 4 A228

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Appendix 2

Masterplan from Reg 19 representations

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Appendix 3

Figure D from Reg 19 representations report

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Figure D: Proposed amendment to the Green Belt to create an extension to Snodland

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Appendix 4

Study of Green Belt purposes performed by Kitewood site from Reg 19 representations report

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GB Purpose Council Assessment of WYG Assessment of sub-parcel Snodland GB to the south of Tesco Depot 1: Check Performing Well Limited or no contribution Unrestricted The Green Belt does provide a Sprawl clear boundary to the western Whilst the Green Belt does provide side of the town that may a boundary to the town, in terms otherwise perhaps be vulnerable. of the settlement boundary defined in the Plan, we consider the sub- 3: Assisting in Performing Well parcel should be removed to allow safeguarding There has only been sporadic and for planned sustainable growth of countryside mostly historic and/or farm based the town. from building in the Green Belt in this location such that the land encroachment generally retains a sense of We question whether the current openness. boundary does provide a ‘clear’ distinction as there are many existing developments within the sub-area, as shown on Figure C, above. The presence of the Vet Centre, its grounds and intensive residential uses, including development at and surrounding Sandhole Barn, blur the clarity of the existing Green Belt boundary. These are not simply rural farms, as the Council’s assessment contends. We disagree that the Green Belt can be considered to be performing well in relation to wither purpose 1 or 3, in this regard.

It would be a much clearer and defensible Green Belt boundary to align with the AONB boundary in this location.

www.wyg.com creative minds safe hands 12 We also note that the site has historically been used for extraction and does not comprise typical countryside.

In any case, releasing Green Belt land adjoining a settlement for the purposes of sustainable development will often be assessed as performing well in relation to purposes 1 and 3 of the Green Belt. Good performance against these criteria should not be a reason for failure to consider releasing sites for sustainable growth of settlements as part of an appropriate spatial strategy. 2: Preventing Performing Moderately Limited or no contribution Towns from The Green Belt has generally We agree that Leybourne Lanes merging provided a clear edge to the Country Park, situated between settlement to the west. To the Snodland and New Hythe, prevents south and east (the latter of these settlements from merging. which is away from the Green Belt), other features including the We agree that the Green Belt to the A228 road network and north of Snodland/Holborough Leybourne Lakes help prevent prevent Snodland/Holborough and merging. The area is somewhat Halling and Upper Hallingfrom mixed therefore and thus has merging. We consider that the been categorised as performing AONB prevents Snodland and the moderately. settlement of Birling from merging. However, removal of the sub-parcel from the Green Belt has no baring on any of these relationships. As such, the sub-parcel serves no function in relation to this Green Belt purpose. 4: Preserving Limited or no contribution Limited or no contribution the setting The historic core of Snodland and There are no views from the site or and special its Conservation Area is removed the public footpath which runs character of from the Green Belt designation through it to any of the and buffered by existing historic towns Conservation Areas. The sub-area buildings. Views of the town’s Conservation Area from within the therefore makes no contribution to Green Belt are restricted by other this purpose. built form and the topography. Within the Green Belt smaller Conservation Areas can be found (Paddlesworth and Holborough Mill) where the setting is assisted by other designations including AONB and a Local Wildlife Site.