000079
Borough of Dartford Local Plan Public Local Inquiry INSPECTOR'S REPORT
March 1993 Tollgate House Our ref. PINS/T2215/429/l Houlton Street Bristol BS2 9SZ .,.. 2' February 1993 To the Chief Executive Dartford Borough Council
Sir
1. I have the honour to report that between 23 June and 18 September 1992 I held a public inquiry into objections to the deposit version of the Borough of Dartford Local Plan.
2. This report of the proceedings commences with lists of contents and abbreviations used in the text, following which it takes the form of an introduction giving the history of the plan, and the background to the inquiry. It is then divided into chapters, the numbers of which correspond to the chapters in the plan. Each chapter has an introduction which sets out the background against which the various objections have been considered. Only brief summaries of the cases for the objectors and the council are given; proofs of evidence, written representations and documents are available, and they are listed together with the names of those appearing at the inquiry, at the end of the report.
3. The inquiry sat for 21 days, and I carried out site visits on 7 days in addition to some sites which I viewed after the inquiry had adjourned.
4. I would like to thank the council for their hospitality and the quality of thto arrangements made not only for me but also for objectors and interested Pl'~JJODS. You provided a programme officer for the inquiry, and I wish in pa..C:icular to express my appreciation of Miss Teresa Young's support and o·rganisation which made such a valuable contribution to the smooth running of the inquiry. Miss Young holds a full set of the inquiry documents.
I am Sir Your obedient servant
Ernest WSmith BSc,MSc,MICE Inspector · CONTENTS
Sections Objections and Representations page
CHAPTER 1 - INTRODUCTION 1
CHAPTER 2 - STRATEGY background 2.1 3 policies 2.2 - Representations Rl-R9;
CHAPTER 3 - EMPLOYMENT Background 3.1 5 Policies 3.2 - 3.11 - Objections l,3-5,6(part), 7-17,228 - Representations Rl0-Rl2,Rl5 Absence of policy 3.12 - 3 .13 - Objection 19
CHAPTER 4 - HOUSING Background 4.1 16 Policies and 4.2 - 4.23 Objections 2,20-25,42-72,127-169, land allocations 172-182,304,341-343 Representations Rl6-R34,R51,Rl22 Sites in the green 4.24 - 4.35 - Objections 26-34,37-41,194,211, belt not allocated 217,222 for housing Representations R56,Rl22 Other sites not 4.36 - 4.37 Objections 35,36 allocated for housing Commended changes 4.38 - Objections Cl-C3,C5
CHAPTER 5 - RETAILING Background 5.1 59 Policies 5.2 - 5.7 - Objections 170,183-189(part) Representations R35-R37,R40-R42 Absence of Policy 5. 8 - Objections 189(part),l90
CHAPTER 6 - THE GREEN BELT Background 6.1 Representations R43,R52,R53 69 General extent of the 6.2 - Objection 191 Green Belt Representations Rl0,Rl3,Rl4,R43-R50 Specific sites deleted 6.3 - Objections 73-126,192 from the Green Belt Sites designated as 6.4 - 6.15 - Objections 18,171,193,195-216, Green Belt 218,219,221,300,344
CHAPTER 7 - TRANSPORT Background 7.1 93 Policies 7.2-7.17 Objections 223-227,229-262,264-267 340 Representations R57-R69 Commended changes 7.18 - Objections C7,C8
CHAPTER 8 - DERELICT & DESPOILED LAND, MINERALS & WASTE DISPOSAL Background 8.1 113 Policies 8.2-8.6 - Objections 268-278,280,281,345 Representations R70-R74 Absence of Policy 8.7 - Objection 279
i CONTENTS (CONTINUED)
Sections Objections and Representations page CHAPTER 9 - RECREATION & TOURISM Background 9. 1 122 Policies 9.2-9.14 -Objections 282-296 Representations R75-R86 Absence of Policies 9.15-9.16 -Objection 291 Commended chaQges 9.17-9.19 - Objections C4,C6,C9 CHAPTER 10 - COUNTRYSIDE Background 10.l - Representations R87-Rl05,Rl07,Rl09, 139 Rlll,Rll3-Rll4,Rll6,Rll7, 4 Policies 10.2-10.12 - Objections 297-299,301-303,305-309, 346 Representations R54,R55,Rl06,Rl08, Rl10,R112,R115 Absence of Policy 10.13 - Objection 310 CHAPTER 11 - VILLAGES Background 11.1 150 Policies 11.2-11.4 Objections 311-313 Representation Rll8 CHAPTER 12 - BUILT ENVIRONMENT Background 12.l 155 Policies 12.2-12.4 - Objections 314-316
CHAPTER 13 - COMMUNITY FACILITIES AND PUBLIC UTILITIES Background 13.1 159 Policies 13.2-13.10 Objections 220,317-326 Representations R33,R34,R38,R39, Rl19-Rl21,Rl23 Absence of Policies 13.11-13.12 Objections 327,328 Commended changes 13.13-13.14 - Objections ClO,Cll
CHAPTER 14 - TOWN CENTRE Background 14.1 174 Policies 14.1-14.7 - Objections 263,329-339
Addendum
ii LIST OF ABBREVIATIONS
CPRE - Council for the Protecion of Rural England DTp - Department of Transport DGHA - Dartford and Gravesham Health Authority HBF - House Builders Federation KCC - Kent County Council KTNC - Kent Trust for Nature Conservation LNR Local Nature Reserve PPG Planning Policy Guidance RSPB Royal Society for the Protection of Birds SERPLAN Standing Conference on London and South East Regional Planning SETRHA The South East Thames Regional Health Authority SNCI Site of Nature Conservation Interest SPG Supplementary Planning Guidance STDR South Thames-side Development Route TPO - Tree Preservation Order
iii CHAPTER 1 - INTRODUCTION
1.1 The local plan was placed on deposit on 4 November 1991, ie before the new development plan procedures came into force on 10 February 1992, and has proceeded under the transitional arrangements for a "saved" local plan. The objection period ended on 13 December 1991 but the Council accepted further objections up to 7 April 1992. Having considered the objections, the council produced a schedule of changes to be commended to me, which were approved by the Council's Planning and Transportation Committee on 14 April 1992: The commended changes were advertised on 23 April 1992 with a 6 week period for any further objections. Following the receipt of comments on the commended changes, the council produced a supplementary list of commended changes which were advertised on 18 June 1992 with a 3 week period for objection ending on 9 July 1992. Three further lists of commended changes were produced, which arose from agreements reached with various objectors during the couse of the inquiry, under powers i delegated to the officers by the council. In order for the plan to become I compliant within the meaning of the transitional arrangements, the changes I deleted policies on minerals and waste disposal matters. 1.2 The current statutory development plan for Dartford is the North West Kent Town Map approved in 1978. There is also the Kent Countryside Local Plan which was adopted in 1983. The Council published a draft borough wide local plan in January 1988 but further progress was deferred pending approval of the Second Alteration to the Kent Structure Plan which was approved and became operative on I 1 June 1990. A new draft plan for public consultation was published in January 1991, and a schedule of amendments prepared following analysis of the representa tions received on the draft document. The published consultation plan and I amendments formed the basis of the deposit version of the plan. Under the terms of Planning Policy Guidance (PPG)l2, policies carried forward from the current local plans are not open to objection.
1.3 A full programme of public consultation was carried out in early 1991, and the placing of the plan on deposit was advertised in appropriate publications and displayed in prominent locations. Kent County Council issued a Certificate of Conformity with the structure plan on 26 August 1991. I .~as informed that all statutory procedures had been complied with. A pre-inquiry meeting was held on 7 April 1992.
1.4 A total of 346 objections were accepted of which 290 were made within the statutory objection period. There were 123 representations in support of the plan, of which 116 were received within the statutory period. At the opening of the inquiry eight objections had been withdrawn or were not relevant, and 9 objectors confirmed that their objections would be met by the commended changes. A further 11 objections to the commended changes were received.
1.5 At the inquiry I heard 18 cases containing evidence on 46 objections and included two objections to the commended changes. I also heard two representa tions of support. 108 objections were not pursued as a consequence of the council's schedules of commended changes, and I received the council's responses to 186 written objections. I visited all the objection sites, and I was accompanied on some of the site visits. The relatively small number of residual objections to the plan is a testimony to the effectiveness of your Council's consultation procedures, which one objector described as exemplary. It is to be hoped that this will lead to a rapid adoption of the plan.
1 1.6 lssues raised at the inquiry and in the written objections covered the following broad topics:
Green Belt and housing, housing in villages, transport, town centre proposals, recreation and tourism, nature conservation, retailing, derelict and despoiled land, community facilities and public utili ties.
1.7 Some of the objections covered similar matters, and 3 topic papers were produced covering the general issues raised by objections to policies on Green Belt, housing and traffic.
1.8 Where an objection relates to more than one policy, it has generally been given two, or more if appropriate, objection numbers. They are considered as separate objections wherever possible, but in some cases, e.g where the objector considers that land should be removed from the green belt and allocated for housing, the objection is dealt with in the earlier chapter except where otherwise stated.
1.9 The chapter numbers are the same as the local plan, and all policy or paragraph numbers follow those of the deposit version of the plan.
1.10 Written representations in support of a policy (prefixed R) are either stated where no objection has been received, or contained within the council's response where an objection is being considered.
1.11 Where modifications to the plan are recommended, they refer to the deposit version. The council themselves put forward some commended changes which were approved by the council, and some of which were themselves the subject of objections (prefixed C). During the course of the inquiry, further changes were commended to me by the council's officers under powers delegated to them by the council (prefixed S). Where appropriate, my recommendation refers simply to the commended change number; the details of the changes are contained in Documents 6 6d. In other cases, where I have recommended a modification to a policy, I have maintained the council's style; i.e deletions are contained within square brackets [thus], and additions, where set out in detail, are within quotation 11 11 marks and underlined ,thw. • ·
1.12 Although the report was virtually complete, I have modified my conclusions on the Gun Club site to take account of the forthcoming boundary changes.
2 CHAPTER 2 - STRATEGY
BACKGROUND
2.1.1 Dartford's location near the M20, M25 and the River Thames crossing, together with the opening of the channel tunnel, present opportunuties for the borough to be a leading growth centre. It is identified in the approved structure plan and various strategic planning guidelines, as an area for growth of economic activity and employment.
2.1.2 SERPLAN has identified the East Thames Corridor extending from Docklands in the west to Sheerness in the east, as a corridor which presents considerable development opportunities. There is however, recognition that much of the potential is constrained by poor access. The Channel Tunnel "Kent Impact Study" has recognised the logic of designating Dartford and Gravesham as a leading growth centre. Strategic planning guidance also seeks to encourage a better balance of development and investment between East and West London.
2.1.3 The local plan makes explicit the council's commitment to maintain and foster the momentum for economic growth which is alrady established in the borough, and there is also a commitment to enhance the quality of life in the borough.
2.1.4 Apart from stating the strategic background to the local plan, the strategy also sets out the plan's assumptions, aims and objectives which have been translated into a set of strategic policy objectives.
2.1.5 Dartford was identified as a growth area in the approved structure plan, reflecting regional planning guidance. Notwithstanding general recessionary trends, a momentum for change was now established in the area, and high profile infrastructure projects such as the Queen Elizabeth II Bridge, the Dartford Northern By-pass and the South Thames-side Development Route (STDR) would build on this momemtum.
2.1.6 Regional guidance for the South East (PPG9) stressed the need to redress the balance between the western and eastern parts of the region, and SERPLAN had promoted the development of opportunities in the East Thames Corridor which could help to meet regional planning objectives. The Channel Tunnel "Kent Impact Study" (1987) had also recognised a powerful strategic logic in a policy of designating the Dartford and Gravesham area as a leading growth centre.
2.1.7 The 1990 Structure Plan approach had evolved against the background of a combination of factors at Dartford leading to a growth strategy fo' the area. These included: the Borough's strategic location between London and Europe within the East Thames Corridor, accessibility and development potential adjoining the only M25 junction not in open countryside, and a potential for growth as the borough was less constrained in environmental and landscape terms than other, more sensitive areas to the south and east. Policy Sl of the Structure Plan had advocated that there should be substantial new development and redevelopment at Dartford, including the release of land to the north-east of the town from the Green Belt, which was not essential to its function.
3 POLICIES
2.2.l There were no objections to the general strategy, and nine written representations in support of the council's commitments and policies were received.
PARAGRAPH 2.3.8
Representations Ngs Rl-R4
2.3.2 Allied London Properties PLC, and Blue Circle Properties Ltd supported the aims of maintaining the momentum for economic growth, and the provision of a range of new employment, retail and housing opportunities.
POLICY S3
Representation No.RS
2.3.3 The Council for the Protection of Rural England (CPRE) supported the recycling of redundant sites.
POLICY S4
Representations Nqs R6 and RZ
2.3.4 The CPRE and the Countryside Commission supported the continued protection to the Green Belt.
POLICY SS
Representations Nos RB and R9
2.3.5 The CPRE and English Nature supported the protection and enhancement of the nature conservation resources.
Conclusions
2.4.l The basic strategy of the Plan has widespread support. Due to the lack of any objections to it, I am not required to make any recominendations. CHAPTER 3 - EMPLOYMENT
BACKGROUND
3.1.l Dartford's strategic location and development prospects have been recognised by the Secretary of State's acknowledgement of the scope for major economic development at North-east Dartford.
3.1.2 Traditional employment in Dartford has mirrored that in North Kent generally, with concentrations of jobs in paper making, cement manufacture and heavy engineering. As has been the case with the national economy, there has been a trend away from manufacturing towards growth in the service indus tries. The borough's largest employer however, is the Wellcome Foundation Ltd who manufacture pharmaceuticals, and are in one of the manufacturing growth sectors.
3.1.3 About half the borough's residents work outside the borough, and while to an extent this represents its location near London, it also reflects a relative lack of major office employment within the borough. The potential growth of Dartford includes scope for office development in the town centre where some planning consents have been granted, as well as in other employment areas.
3.1.4 A number of industrial estates and business parks have been developed, which cater for the medium and larger units. The development of smaller units would ensure a diverse range of opportunities, and cater for the support needs of the larger businesses. The Structure Plan recognises that employee densities will be less than previously.
3.1.S The recent closure of Swanscombe Cement Works presents a major opportunity to redevelop and improve that part of the borough over a longer term than the plan period.
3.1.6 The structure plan sets out the guidelines for the amount of economic development to be made in each planning area, but it is based on data which preceded the Town and Country Planning (Use Classes) Order 1987. There are therefore some difficulties in interpreting the guidelines, and the intention is to monitor the situation pending a review of the structure plan.
3.1.7 There were no significant objections to the general employment policies. The objections in this chapter relate mainly to the effects of the proposed employment developments on traffic and nature conservation interests.
3.1.8 No specific objection was made to the allocation of land at Bean Triangle for a mixed use development under Policy E6; there were two representa tions in support. The proposal involves removal of the site from the Green Belt however, and is considered in Chapter 6.
5 PARAGRAPH 3.1.7
Written Obiection No. 1
3.2.1 The objection was made on behalf of Blue Circle Properties Ltd, and concerned the former Swanscombe Cement Works,
Summary of Objection
3.2.2 The plan failed to provide adequate guidance for the former Swanscombe Cement Works site.
3.2.3 A site specific policy covering the whole of the cement work site should be included in the plan to provide guidance for the future use and development of this area for a mixed use development scheme including business, industrial, retail, leisure and residential uses. Paragraph 3.1.7 should be deleted.
The Council's Response
3.2.4 The plan recognised thst the closure of the Swanscombe Cement Works presented a major opportunity to redevelop and improve this part of the borough. It was agreed that it would now be appropriate for clearer guidance to be incorporated as a policy in the plan to provide a basis for development. A change was recommended, which proposed a new paragraph 3.3.6 and new Policy E4 relating to the former Swanscombe Cement Works.
3.2.5 The objector acknowledged by letter that they were pleased to support the commended change.
Conclusions
3.2.6 In my opinion the recommended addition to the chapter would give a clearer indication of the Council's policy for this site.
R@cormggJMiatiQDI
3.2.7 I recommend that: 1. paragraph 3.1.7 be deleted; 2. that a new paragraph 3.3.6 and new Policy E4 be inserted in accordance with commended change No.4, and subsequent paragraphs and policies be renumbered.
POLICY El
Objection No. 3 Written Objections Nos 4 and 5 Representations Nos RlO apd Rll
3.3.1 Objection No.3 was made by the Kent Trust for Nature Conservation (KTNC); objection No.4 was made by the Royal Society for the Protection of Birds (RSPB), and Objection No.S was made on behalf of Mr & Mrs Thomsett. They concerned Littlebrook Lakes.
6 Summary of Objections
3.3.2 Objection No.3 stated that the site warranted designation as a Site of Nature Conservation Interest (SNCI), and should not be identified for business development. The site was previously managed as a nature park with a full-time paid warden, and in the original consultation draft was allocated as a potential local nature reserve. The provisions of Policy Cl4 should apply to the site, and the business park designation should be deleted.
3.3.3 Objection No. 4 stated that the Littlebrook Lakes area consisted of a range of habitats supporting both breeding and wintering bird populations. The lakes were of value for their wintering wildfowl, and the Business Park proposals for the lake should be deleted or substantially amended to take account of the significant wildlife interest.
3.3.5 Objection No. 5 stated that the "Littlebrook Lakes Nature Reserve" was a valuable and established local resource which would be irretrievably damaged by the land uses proposed in the policy.
The Council's Response
3.3.6 Structure plan Policies MGB3 and ED6 had established the principle of the removal of the site from the Green Belt, and its identification for economic development. The particular nature conservation interest of part of the El policy area was recognised but it would not be appropriate to show Policy Cl4 on the proposals map in areas of acknowledged development potential.
3.3.7 Nevertheless, it was agreed that the policy's reference to nature conservation interest should be strengthened, particularly by the inclusion of a reference to its management, in the particular site specific policy. The recommended change would take this into account and provide a clear and firm policy base for dealing with nature conservation considerations in the area. The site would be considered comprehensively to allow the nature conservation and economic development aspects to complement each other.
3.3.8 The South East Thames Regional Health Authority (SETRHA), ·and the Dartford and Gravesham Health Authority (DGHA) supported the policy's proposals.
Conclusions
3.3,9 During the consultation and deposit periods the council had strengthened the local plan's approach to nature conservation and its management, and KTNC acknowledged the council's approach to dealing with nature conservation. The council also acknowledged however, that the site was a key element in the economic development of the borough and of North Kent generally, and was a strategically important site. There was a large measure of agreement on the ecological significance of the site, and that it was worthy of a degree of protection.
3.3.10 I do not consider that the protection afforded to a site designated as an SNCI and protected under Policy Cl4 would enable the site to be developed in accordance with the policies of the approved Structure Plan. The modified policy would explicitly take account of the nature conservation interest of the site, and require provision to be made for its future management, having regard to its primary role as a business park. Some illustrative drawings were produced which indicated how the site could be developed and retain the lakes. In my opinion, the policy as modified would give proper regard to the interests of both the economic development of the site and to the interests of nature conservation.
7 3.3.11 Changes in the wording of the policy were co1D1Dended to me, which I consider would strengthen the nature conservation interest of the policy. I agree with the co1D1Dended change.
Written Obiection No. 7
3.3.12 The objection was made by the Kent County Council, and concerned land near the A282 Littlebrook junction.
SUJD1Dary of Objection
3.3.13 In view of the site's proximity to the Dartford Tunnel approach, the south-east corner of the site allocated for El purposes, would be an appropri ate location for a service station and roadside services use.
The Council's Response
3.3.14 Provision had been made for a motorway service station on the north side of the River Thames, adjacent to the tunnel approach road; the site had been chosen by the DTp after consideration of possible locations north and south of the Thames. One location considered and subsequently rejected on highway grounds, had been on the eastern side of the tunnel approach road by the tunnel toll booths, on what was now the Crossways Business Park.
3.3.15 Concern had been expressed by the DTp about the adequacy of the A282 Littlebrook Junction. They had also objected to the development of land on the eastern and western sides of the Littlebrook Junction unless it could be demonstrated that there was a feasible highway arrangement for the junction that could cope with the anticipated volume of traffic. A service station would be likely to generate additional traffic movements at the junction with additional weaving close to the toll booths.
Conclusions
3.3.16 A service station in this location would undoubtedly attract additional traffic turning on and off the A282 at a junction where the limited capacity is already a cause for some concern. In my opinion, it would also be visually prominent in the foreground of a development which is intended to have an open area of water and general landscape. I consider that the proposal for a service area on the north side of the River Thames removes any overriding need for a similar facility at this location, and I therefore conclude that there is no reason for the plan to propose a service station on this site.
R@cpl!'!f?nd•tion
3.3.17 I recolDJDend that Policy El be modified in accordance with colDJDended change No.l, as amended by recommended modifications to Policies T2 and T21 in Chapter 7.
POLICIES El, E2, AND E3
Written Obiection No, 6 (part)
3.4.1 The objection was made by the Department of Transport and concerned the adequacy of the A282 Littlebrook junction.
8 Summary of Objection
3.4.2 The DTp objected to the development proposals unless and until it could be demonstrated that there was a feasible highway arrangement for the A282 Littlebrook Junction which would be able to cope with the anticipated volume of traffic.
The Council's Response
3.4.3 The Council recognised the Department's concern, and changes were proposed to Policies El which included policy area RTB, E2 and E3, as well as to Policies T2 and T21, and paragraph 7.2.l(e).
3.4.4 By letter dated 14 May 1992, the Department recommended that the commended changes be accepted.
Conclusion I 3.4.5 I consider that the commended changes to Policies El, E2 and E3 which 1 relate to major redevelopment proposals, and could have significant traffic im plications, properly reflect this possibility. They are therefore worthy of support. The other commended changes relate to transport policies and are discussed in Chapter 7 below. l Rec9'QMndatign I 3.4.6 I recommend that Policies El, E2 and E3 be modified in accordance with I commended changes Nos 1, 2 and 3 respectively, as amended by commended change to ! Policy T2 and T21 in Chapter 7. 'i.
POLICY E2
Objection No, 8 Written Obiection No 9
3.5.l Objection No.8 was made by the Kent Trust for Nature Conservation, and objection No.9 was made by the Royal Society for the Protection of Birds. They c'oncerned the Dartford Marshes.
Summary of Objections
3.5.2 The site which formed part of the Dartford Marshes SNCI, would be affected by Policy Area E2. It consisted of grazing marsh which was important for breeding and wintering birds, in addition to the invertebrate and botanical interests. This kind of habitat had declined substantially in the Greater Thames area since the 1930's.
3.5.3 The site should be accorded SNCI status and protected under the provisions of Policy Cl4. It formed a southerly extension of the larger northern marshes area which had a more saline influence. The marshes narrowly failed to qualify under the criteria for SSSI selection, and the matter was again being considered by NCC's successor body, English Nature, in the light of additional survey and of habitat loss elsewhere.
9 i i'
The Council's Response
3.5.4 There was no dispute over the nature conservation value of the objection site, and if the site were not needed for development it would be likely to be allocated as a SNCI. The site was however, the only area where Wellcome who were the main employers in the area, could expand.
3.5.5 The principle of the removal of this land from the Green Belt and its identification for economic development, had been established through the structure plan process. In such circumstances the council did not believe it appropriate to identify land as a SNCI but considered the better approach was to deal with nature conservation issues in the site specific policy.
3.5.6 Commended changes to the wording of the policy would clarify the policy's intentions if expressed in the form of criteria, and the nature conservation interest could be strengthened by including reference to the site's nature conservation interest, and to its management. These changes in the policy were recommended, and would take all the relevant interests into account.
Conclusions
3.5.7 There was a large measure of agreement between the parties in weighing the interests of nature conservation which were not disputed, against the need for economic development. It appears to me that the most difficult psrt of the site on which to carry out development may well be the wettest part which is also the most sensitive part. There may therefore be an element of self regulation in developing the site. I understand that some 50% of the site will be likely to be required for development.
3.5.8 The policy as reworded, requires the nature conservation interest of the area and its future management, to form part of any proposal. In my opinion this would ensure that a balance between the needs of the economic development are balanced against the conservation interest of the area. The objection site adjoins the premises of the Wellcome Foundation which is an international pharmaceutical company, and it represents the only potential area for any extension of the existing premises. I am satisfied that there is a need in this case to balance the potential development needs of the Wellcome Foundation who make a significant contribution to the economy of the area, against the acknowledged nature conservation interest of the site, and that the modified policy would assist in this.
Written Objections Nos 10 and 11
3.5.9 Objection No.10 was made on behalf of Mr &Mrs Thomsett, and objection No.11 was made on behalf of the Wellcome Foundation Ltd.
Summary of Objections
3.5.10 Policy E2 should be extended to include Bl use, especially to the north-east of the site, which was suitable for a business/science park. It was inappropriate for the policy to restrict the site to a named user.
3.5.11 The wording of the policy did not reflect the existing range of uses on the adjoining site. The policy should also recognise that other areas may not be developed specifically for Wellcome's operations.
10 The Council's Response
3.5.12 The major use of the site should be for uses in Use Classes B2, B3 and BB, though it was accepted that there may be scope for some Bl development in the policy area generally, rather than solely and specifically in the south-west of the site as referred to in the policy, as Wellcome's activities included research and development functions as well as manufacturing and distribution. It was recognised therefore, that it would be unreasonable for the policy to preclude these functions from the objection site. Commended change No. 2 would provide for some limited Bl development within the site.
3.5.13 It was also acknowledged that it was inappropriate to include a named user in the policy, and the commended change would amend it accordingly.
3.5.14 The objection site was in multi ownership. Whilst accepting that the policy should not make reference to a named user, the policy should still make clear that the major part of any development on the site would be as an extension to the existing adjoining pharmaceutical complex. The commended change would provide for this.
3.5.15 Objector No.11 had confirmed in writing, that they supported the proposed change to Policy E2.
Conclusions
3.5.16 I agree with the view that the policy should allow for the possibili ty of other business development, including associated Bl uses, as Wellcome are involved in research and development activities.
3.5.17 I consider that reference to the existing adjoining major pharmaceutical complex is necessary, as the need for any possible future expansion of that complex is the primary justification for removal of the objection site from the Green Belt. I agree however, that it would be inappropriate for the policy to include a named user, and I support the commended change to relate the policy area to the adjoining user rather than to the named company.
Recqmendation
3.5.18 See recommended modification to Policies El, E2 and E3 above.
PROPOSALS MAP (POLICY E2)
Written Objection No, 12
3.6.1 The objection was made on behalf of the Wellcome Foundation Ltd.
Swnmary of Objection
3.6.2 The policy area identified on the Proposals Map included land that was either developed or committed for development. The site boundary should be redefined to exclude those areas.
The Council's Response
3.6.3 The local plan's base date in terms of housing and economic development provision was mid-1986, and the boundary of the policy area on the Proposals Map reflected the position as it had been at that date. The
11 provision figures in Appendices 3 and 4 related to the period 1986-2001. Part of the site had since been developed but that was not seen as a reason for altering the boundary in view of the position as at 1986.
3.6.4 Discussions had been held with the objector and whilst originally objecting to Policy E2 of the deposit plan, the company now fully supported the changes commended to the Inspector.
Conclusion
3.6.5 The site boundary as shown on the Proposals Map is consistent with the data base on which the plan is based, and I can therefore see no reason to alter the boundary shown on the map.
Recpmrgepdetion
3.6.6 I recommended that no change be made to the Proposals Map arising from this objection.
APPENDIX 4 (POLICY E2)
Written Objection No, 13
3.7.l The objection was made on behalf of the Wellcome Foundation Ltd.
Summary of Objection
3.7.2 The site area figures for the E2 policy area quoted in Appendix 4 were incorrect.
The Council's Response
3.7.3 The objector had provided revised details of the gross area and net area available for the development of the policy area. A commended change amended the figures in Appendix 4 accordingly. The commended change also provided for the identification of the site as "Dartford Fresh Marshes".
Conclusion
3.7.4 The figures in the commended change are agreed between the parties, and should thus be substituted for those in the deposit version of the plan. The renaming of the site would also make the appendix consistent with the removal of the named user in the change referred to above.
RIQ9Vl'ndatign
3.7.5 I recommend that Appendix 4 (as amended by commended change S2) be modified in accordance with commenced change No.7, and that consequential changes should be made to Appendix 3 (as modified by change S2), and to paragraph 3.1.9.
12 POLICY E3
Written Obiections Nos. 14 apd 228
3.8.l The objections were made by Thames Water Utilities concerning Stone Pumping Station.
Summary of Objection
3.8.2 The pumping station was situated within the Policy Area E3 and adjacent to the safeguarded alignment of the STD~. Land needed to be safeguarded to meet the requirements of future developments in the area. The Council's Response
3.8.3 It was accepted that proper provision should be made for the operational requirements of Stone Pumping Station. The commended change to Policy E3 would require them to be taken into account.
Conclusion
3.8.4 I consider that the commended change would overcome the objection, and is a necessary amendment to the policy in order not to prejudice the future requirements of the water utility.
Rtc;omm•rulntion
3.8.5 See recommended modification to Policies El, E2 and E3 above.
POLICY E4
Written Objection No. 16 3.9.l The objection was made on behalf of Property Holdings, London SEl. Summary of Objection
3.9.2 The site was not a suitable location for office development. The policy was too rigid, and it should be amended to permit not only offices but also resi dential, hotel and showrooms.
The Council's Response
3.9.3 The Council agreed that the site was suitable for commercial uses including restaurant and showrooms, and residential. A change to the policy and to the preamble would widen the choice of potential redevelopment uses. Conclusion
3.9.4 The policy and the preamble properly reflect the importance of the site's prominent location, and in my opinion the site would be suitable for a range of commercial or residential purposes. I therefore support the commended change. leg9DP'D11etion 3.9.5 I recommend that paragraph 3.3.6 and Policy E4 be amended in with commenced change No.SI. 13 POLICIES E4 AND ES
Written Objections Nos 15 and 17 Representation No.R12
3.10.1 The objections were made by Thames Water Utilities.
Summary of Objections
3.10.2 The development Policy Areas E4 and ES lay within the vicinity of the Wilmington Pumping Station, and could pose a risk to the underground water supplies. The utility should therefore be consulted upon the developments, and development proposals should pay regard to the NRA ground water protection policy (November 1991).
The Council's Response
3.10.3 The Council accepted the thrust of the objection, and commended a change accordingly. However as the issue could also arise on sites not identified in the local plan, it would be more appropriate to deal with this through a development control policy of general application rather than amending the site specific policies referred to in the objection.
3.10.4 The Council therefore proposed to include an additional criterion to Policy Bl.
3.10.5 Allied London properties PLC supported the policy's proposals.
Conclusion
3.10.6 The validity of the objections is recognised, and in my opinion the commended change to Policy Bl which would apply to all development proposals, would be appropriate. Resomendation
3.10.7 See recommendation modification to Policy Bl in Chapter 12.
:L POLICY E7
Representation No R15
3.11.1 British Rail supported the provisions of the policy, to which there were no objections.
14 ABSENCE OF POLICY
LACK OF EMPLOYMENT POLICY ON LAND AT THE GUN CLUB SITE
Written Obiection No. 18
3.12.1 The objection was to the absence of a policy for employment use on land at the Gun Club site, East Rochester Way. It appears to me however, that the key issue in this objection is whether the site should be deleted from the Green Belt. I have therefore considered the objection, together with Objection No.171, in chapter 6. y LACK OF ANY POLICY RELATING TO LAND AT EBBSFLEET
Written Objection Ho.19
3.13.1 The objection was made on behalf of Blue Circle Properties Ltd.
Summary of Objection
3.13.2 The Ebbsfleet area had development potential beyond the plan period which should be safeguarded pending further studies.
The Council's Response
3.13.3 The council accepted that the objection site, together with others at the former Swanscombe Cement Works and Craylands Lane, may have a potential for development in the longer term when the strategic implications had been fully considered. Because of the lead times necessary for any major infrastructure provision, it was acknowledged that this potential should be recognised in the plan, and a commended change containing a new policy and preamble in chapter 4 was recommended.
3.13.4 By letter of 19 June 1992, the objector stated that there was now no difference between their position and that of the council.
Conclusion
3.13.5 In my opinion, the commended change is a satisfactory means of recognising the long term development potential of the objection sites, and satisfies the points made by the objector.
3.13.6 See recommended new policy after Policy H5, and other modifications, in Chapter 4.
15 CHAPTER 4 - HOUSING
I BACKGROUND 4.1.1 Despite a declining population during the 1970's and 1980's, the number of households in Dartford increased. The trend to smaller average household size is expected to continue. Structure plan indications of new dwellings for I Dartford are higher than past trends would indicate, and they reflect the changed strategic perspective of the borough, especially in relation to economic development and its related employment growth.
4.1.2 The base date for housing land supply in the local plan is 30 June 1990. In order to bring the data into line with the census, a revised assessment was made of the supply at 1 April 1991. This assessment showed that current commitments including local plan allocations, amounted to 3,691 units against a structure plan requirement for the period 1991-2001 of 3,000 units. The structure plan (5.11) states that proposed policy levels of new housing are set well above local housing requirements to reflect the borough's jobs potential.
4.1.3 Completion rates in the late 1980's increased to a level greater than had been anticipated in the structure plan, but most of the potential for housing development arises from some 2,020 existing planning permissions. A further 610 units would be provided by the redevelopments of Bexley and Darenth Park hospitals in accordance with Circular 12/91.
4.1.4 Following the advice in PPG3, the local plan has sought to identify all potential larger housing sites. The scope for new windfall sites emerging in the future is cons$dered to be small, and no general allowance has been made for such sites.
4.1.5 The plan adheres to the "snapshot" principle, and whilst recognising that some sites may become unavailable, other previously unidentified sites may become unavailable. It is anticipated that the two categories broadly cancel each other out.
4.1.6 A joint study prepared by the county council and the House Builders' Federation (HBF) showed that the five year supply of land for housing in Kent in mid-1990 was 2~ times larger than the policy requirement. It is considered therefore, that there is ample housing land available to meet the five year requirement.
4.1.7 The vast majority of existing planning permissions and local plan allocations involve development on urban land. The.housing policies of the local plan are substantially opportunity led, and comply with the structure plan policy HD2 which aims to promote the best use of urban land in order to minimise the need to take fresh land for development.
4.1.8 It is a strategic policy of the structure plan to provide the best possible choice of housing, and it recognises that the rural settlements have a role to play in this. In recent years, there has been an emphasis in the borough on smaller and flatted developments in the urban area. Some 62% of the existing commitments are to be flatted developments whereas only 4% are to be in the rural area south of the A2. Whilst welcoming the provision of the lower cost units, the local plan seeks to redress the imbalance by providing high quality units at the redundant hospital sites, and by identifying some small sites on the edges of rural settlements where high quality residential development could occur, some at specifically low density. A general lowering of housing densities is being sought, and this is regarded as being of sufficient importance to warrant a specific policy.. 16 4.1.9 PPG3 provides for limited exceptions to be made to normal planning constraints where there is an identified need for low cost housing. The guidance does not however, alter the presumption against inappropriate development in the green belt. The council regard the best hope of providing low cost housing as being from cross-subsidy in general housing schemes.
4.1.10 Supplementary Planning Guidance (SPG) is contained within the plan, and others may be produced. The council will consult fully with interested parties before introducing any new SPG's.
Comments
4.1.11 This is the background against which I have considered the objections and the council's responses. Generally, it follows the advice of PPG3, and develops the policies of the structure plan. I am uncertain about the balancing effects of new sites coming forward to replace any which may not be developed for housing, in view of the council's conclusion that the scope for windfall sites is small. Nevertheless, there is clearly no shortage of land for residential development, and I do not consider that the possible loss of one or more individual sites since the assessment was made, gives any significant weight to the argument that other sites should be found.
4.1.12 I note the council's aim to provide for high quality housing on the edges of villages, and several of these sites are currently within the Green Belt. The plan contains several sites where planning briefs are required, or where high quality housing is specified, and while generally supporting the aims of providing for choice, and balancing the recent emphasis on smaller units, I do not consider that the need for this type of housing is such as to constitute exceptional circumstances for release of a site which is performing a Green Belt function.
4.1.13 No sites are specifically identified for low cost housing, and PPG3 makes it clear that low cost housing would be additional to the general provision of housing, and sites would be released as exceptions to normal policies. It is not appropriate for the local plan to identify such sites.
17 POLICIES AND LAND ALLQCATIQNS
PARAGRAPH 4.1.4
Written Objection No. 20
4.2.1 The objection was made by the Council for the Protection of Rural England (Kent Branch).
Summary of Objection
4.2.2 Housing provision in the local plan was inflated and in excess of structure plan requirements; it would put undue pressure on the countryside. Allowance should also be made for windfall sites which could constitute up to 20% of the total requirements.
The Council's Response
4.2.3 While acknowledging that the proposed supply would exceed the minimum policy requirement in the approved structure plan, the local plan also had regard to other factors in particular:
i. the need to realise economic development potential by providing accommodation for the additional workforce;
ii. regional guidance with particular reference to the East Thames Corridor;
ii. development opportunities in the borough.
4.2.4 Comprehensive appraisal of development potential within the borough had been carried out, which would reduce considerably the scope for currently unidentified sites emerging in the future. Nevertheless, an estimate of small sites had been made based on past completion rates, and this supply was included in the local plan provision figure. PPG3 stated that no allowance should be made for large unidentified sites in housing land supply assessments, and structure plan Policy HD2 made it clear that windfall developments may be regarded as additional to that which met the housing provisions in Policy HDl.
Conclusion
4.2.5 There is no dispute that the local plan provides for more housing than would be required merely to satisfy the housing requirements of the structure plan. Nevertheless, I do not consider that any of the major housing sites impinges to any extent on the countryside, and in view of the significant industrial and commercial development proposed in the plan, it would seem appropriate to allow for a small excess over minimum requirements in order to provide a range of housing types.
4.2.6 I do not recommend any change to the housing land provision as a result of this objection.
18 OBJECTIVES; PARAGRAPH 4.2.l
Written Objections Nos 21 and 22
4.3.1 The objections were made by the Council for the Protection of Rural England, and on behalf of the Hawkins Trust.
Summary of Objections
4.3.2 The plan omitted any objective aimed specifically at providing affordable housing for low income families.
4.3.3 There was an acknowledged shortfall of low cost housing available within the borough, particularly rented accommodation, and the shortfall could not readily be met by the private sector on land allocated for residential use in the local plan.
4.3.4 Failure to address this issue would place the borough at a disadvantage, and result in outward migration to distant areas where lower cost housing was available.
The Council's Response
4.3.5 The local plan objective contained within paragraph 4.2.l(d) was expressed in general terms which would encompass affordable housing. PPG3 made it clear that such provision was discretionary rather than a general requirement, and would be triggered by demonstrable lack of affordable housing to meet local needs. A substantial supply of lower cost housing already existed, and council initiated partnership schemes were further supplementing the supply.
4.3.6 The Green Belt status of much of rural Dartford precluded exceptions being made to policy for rural local needs housing.
Conclusions
4.3.7 One of the stated objectives of the plan is to provide a range of housing types to meet housing demands and needs. This would include low cost housing wherever such a need arises, and I have recommended modifications to the housing spatial standards (Policy HlO) in order to allow greater flexibility in providing low cost homes. In addition however, I consider that the plan should include a statement indicating those factors that will lead them to seek ~o negotiate affordable housing provision as part of a housing development on an unallocated site, as indicated in the Housing Topic Paper (Doc DBC2).
RecW1!ftrulotigp i: 4.3.8 I recommend that paragraph 4.3.7 and/or Policy H6 be modified by the ' addition of a list of factors which the council will take into account in securing the provision of affordable housing as part of a new housing proposal.
SECTION 4. 3
Written Objections Nos 23 arui 24
4.4.1 The objections were made by the Council for the Protection of Rural England (Kent Branch), and Thames Water Utilities. They concerned the infrastructure implications of housing development.
19 Summary of Objections
4.4.2 There was a need to arrange housing so that traffic movement would be minimised to avoid congestion and pollution.
4.4.3 There was a need to limit housing by water resources, the provision of which should not lead to any negative impact on the environment. Paragraph 4.3.1 should include a reference to Policy CFl to ensure that adequate service I infrastructure was available before development proceeded. The Council's Response
4.4.4 It was acknowledged that traffic movement should be minimised, and a 1 commended change to the plan was put to me.
4.4.5 The need to take account of water resources applied to all types of development, and not merely to housing. A commended change to Policy Bl was therefore proposed which would ensure that all development proposals complied with Policy CFl. Commended changes to the plan were suggested, which included requirements to take account of water resource issues, and for new infrastructure to be environmentally acceptable.
Conclusion
4.4.6 The commended changes would meet the points raised by the objectors, and in my view are necessary to ensure that proper consideration is given to these infrastructure implications of any proposed development. The commended changes however, are of a more general nature than simply allocated housing sites, and are therefore discussed in Chapters 7, 12 and 13 below.
B•snl!!"tJd•tign
4.4.7 I recommend no modifications to this section as a consequence of these objections, but see recommended modifications in Chapters 7, 12 and 13.
POLICY Hl
Written Obiections Nos 25 arui 42
4.5.1 The objections were made by Mr Simpkin on behalf of several clients.
Summary of Objections
4.5.2 The importance of Dartford in meeting the excess requirements of neighbouring local authority areas for new house building was increasingly being recognised. The land identified in the local plan, and the number of new housing units envisaged, was an over estimate having regard to:
1. the reduced densities implied in the residential layout criteria in the ~· plan; 2. it was unrealistic to expect all the sites to be developed during the plan period; 3. there was uncertainty over some of the larger sites identified; 4. some allocated sites had been developed for other purposes since the plan was originally conceived; 5. some of the sites identified, eg Al and A4, were not ideally suited for residential development, and more appropriate sites should be identified in their place. 20 4.5.3 Housing land identified in the local plan should be reassessed.
The Council's Response
4.5.4 There was ample housing land to meet structure plan and other strategic needs. There was also an ample five year supply as required by PPG3. The housing land supply assessment had been updated to 1991, which indicated that the adequate supply situation remained largely unchanged. The updated assessment reflected the local plan housing density policies and other relevant factors.
4.5.5 The assessment also took a realistic view of the rate at which sites would come forward, and did not include units likely to be developed after 2001.
4.5.6 It was acknowledged that a few sites in the assessment had since been developed for other purposes but it was important to adhere to the "snap-shot" principle. Whilst some identified sites may not come forward, new sites could compensate for them.
Conclusions
4.5.7 Under commended changes, sites AS and AS would be deleted from the allocations in Policy Hl, and site 82 is being developed for other purposes. They have therefore not been included in the council's revised land availability calculations in the Housing Topic Paper (Doc D8C2). I have also recommended the deletion of sites Al4 and Al5, which in my view have will no significant effect on the overall housing provision in the borough.
4.5.8 The likelihood of all the allocated sites and those with planning permission being developed within the plan period is, in my view, questionable; much will depend on the market conditions. In my opinion, there may be some doubt aver sites A6 and AlO in the short term, and a reduced number from site 83 appears likely. The extent of developments proposed at some sites indicates that completions would be phased over a considerable period of time. I consider that the remainder of the sites will be subject to market conditions, and to the speed with which Darenth Park Hospital redevelopment proceeds.
4.5.9 The council's estimates have been prepared jointly with the Housebuilders Federation, and are net of any dwellings lost due to rede velopment. They imply a significant increase in the rate of completions over recent years, and that will be influenced by other investments such as the commercial and industrial development contained in the plan. In my opinion, it is as likely that supply could outstrip demand as the reverse.
4.5.10 The overall housing provision in the local plan is more than adequate to achieve the structure plan targets, and I can see no need for additional sites to be identified at this time. Lack of sites coming forward for development due to adverse market conditions is not in my opinion, a valid reason for allocating more sites. Neither do I consider that any totally new assessment should be made; this would merely delay the adoption of the plan, and will in any event be carried out as part of the future review.of the plan.
Rec9"""ndation
4.5.11 I recommend no change to Policy Hl as a consequence of this objection.
21 POLICY Hl(Al)
Representations Nos R16 and RlZ
4.6.1 The South East Thames Regional Health Authority (SETRHA) and Dartford and Gravesham Health Authority (DGHA) support the allocation of land at North Dartford for housing. There were no objections to this allocation.
POLICY Hl(A3)
Written Objections Nos 43-66. 159. 164-167 and 222
4.7.1 These objections relate to the redevelopment of Bexley Hospital, and are considered below under Policy H3.
POLICY Hl(A4)
Objection no. 68 Written Objections Nos 67. 69-71 Representation No Rl8
4.8.l The oral objection was made by Mr P James. The written objections were made by Ms A Burke, Wilmington Parish Council, Mrs L Mason, and by Mr Simpkin on behalf of various clients. They concerned land at Edwin Road, Wilmington.
Summary of Objections
4.8.2 The land allocated for housing should be retained in the Green Belt for the following reasons:
1. it was a greenfield site, and it formed a buffer between Wilmington and the A2 trunk road; 2. Wilmington was becoming overdeveloped and was losing its village atmosphere. The capacity of the infrastructure to take further development was doubted. In particular, the primary school was full; 3. The local roads were inadequate to serve any additional develop ment; 4. Significant local opposition to the housing had been ignored by the council.
The Council's Response
4.8.3 The structure plan provided a basis for reviewing Green Belt boundaries in the local plan, and the land between Edwin Road and Oakfield Lane performed no Green Belt function in terms of either PPG2 or the structure plan.
4.8.4 The provision of open space to the north and east of the objection site would provide a valuable local amenity and meet the Local Plan's recreational objectives. The land containing the objection site was overgrown and separated from other agricultural land. Development with housing and recreational facilities would improve the appearance of the land, and safeguard the open swathe between Wilmington and Oakfield Lane.
4.8.5 Improvements to the local road system could be carried out within highway limits, which could then accommodate the likely traffic from the 30 40 dwellings envisaged on the site. Such a level of housing would not unduly 22 burden the local infrastructure or services. The amenities of nearby residents would not be unduly affected, and any loss of amenity would be more than offset by the creation of a new local open space.
4.8.6 Majorhive Ltd appeared at the inquiry in support of the allocation.
. I Conclusions
4.8.7 The first issue to be determined is whether the objection site contributes to a Green Belt function. The land is currently shown on the Development Plan as Green Belt but the structure plan permits changes in the Green Belt boundaries, which are not of structural significance. I consider that this is such a case and that the land containing the objection site does not perform any of the Green Belt functions identified in either PPG2 or in the approved structure plan. It is separated from the open countryside by a school along one boundary, and is enclosed by housing on two sides and the A2 trunk road on the fourth.
4.8.8 There was no objection to the principle of recreational or open space uses on the adjoining land, and its availability to the general public; currently access to the land is unauthorised. The objection site is opposite residential development along its southern boundary, and adjoins a school on its western boundary. A development of housing in. conjunction with provision of local open space would comply with the overall aims of providing a wider choice in housing and also providing an attractive local amenity.
4.8.9 The roads and junctions serving the objection site have limited capacity to accommodate further significant development, but they are capable of being improved within highway limits. I do not consider that the current road system need be a major constraint on development of the scale suggested.
4.8.10 There is a typographical error on the Proposals Map relating to the adjoining RT18 land.
Recopwendation
4.8.11 I recommend no change be made to the allocation of housing land (A4) and open space (RT18) at Edwin Road, Wilmington.
POLICY Hl(AS)
Written Objection No, 72
4.9.1 The objection was made by the Stone Parish Council, and concerned the proposed housing site at Kirby Road, Stone.
Summary of Objection
4.9.2 The proposed housing site was utilised as allotments, and should be deleted for housing purposes.
The Council's Response
4.9.3 The Council concurred with the parish council's view, and proposed the deletion of the allocation. A change was recommended.
23 I
I Conclusion 4.9.4 I can see no reason to disagree with the views of the council and the I parish council. The future of the objection site will now be subject to Policy I CF12. ! Recommendation
4.9.5 I recommend that:
1. Site AS be deleted from Policy Hl in accordance with commended t change No.8, and 2. the Proposals Map modified in accordance with commended change No. 69.
:i POLICY Hl(A8)
Qbjectious Nos 80. 81. 88. 94. 107 AND 120 ' Written Obiections Nos 73-79.82-87.89-93.95-lo&,108-119.an
Conclusion
4.10.2 The objection site is a valued local amenity, though it is not open to the public. It provides a visual break in a long road with development along both sides, and forms a habitat for small wildlife such as butterflies. While most of the arguments put to the inquiry would be more appropriate for considera tion as part of the development control process, I support the site's deletion from Policy Hl. Any application for development could then be considered on its merits, with no presumption either way, and having regard to the site's inclusion within an Area of Special Residential Character.
4.10.3 I recommend that:
1. site A8 be deleted from Policy Hl in accordance with commended change No.9; and 2. the Proposals Map modified in accordance with commended change No.70.
POLICY Hl(Al2)
Written Objection No 127 Representation No Rl9
4.11.1 The objection was made on behalf of the White family, and concerned land at Shellbank Lane, Bean.
24 Summary of the Objection
4.11.2 Whilst it would appear from a plan that Shellbank Lane may be suitable for development, its physical characteristics and steep slope made it a prominent site which was not really suited to development as it was highly visual and did not relate well to the village.
The Council's Response
4.11.3 The site lay at the village edge and within its confines. Structure plan Policy RS3(a) provided for the identification of villages having potential, within or adjoining the built confines, for new residential development. Housing on the objection site would contribute to structure plan, PPG3 and local plan objectives regarding housing choice, given that the vast majority of local plan housing sites were in the urban area.
4.11.4 A written representation in support of the allocation was made on the grounds that the allocation would round-off the village and that the site could be effectively landscaped.
Conclusion
4.11.5 The objection site is of an irregular shape which forms an indent into the built-up area of the village. Development on the site would round-off the village outline, though in my opinion, the site relates well to the countryside, «l and to an extent, performs the Green Belt function of preventing the spread of development into the countryside. The site is on rising ground, and new housing development can be seen on the high ground above the objection site.
4.11.6 Any development on the site would have to recognise the constraints of the topography and of the access, which would be likely to result in low-density development. Such development would however provide an alternative to the rather uniform, suburban type housing on the east side of High Street. As one of the aims of the plan is to provide a range of housing types in a village such as Bean, development of this site would accord with that aim, and justify the site's removal from the Green Belt. In my opinion the site would be suitable for development of a relatively small number of dwellings in a landscaped setting.
Rognmendatign
4.11.7 I recommend no change to Policy Hl as a consequence of this objection.
POLICY Hl(Al3)
Reoresentation No.R20
4.12.l Mr F G Meakin supported the allocation of land north of Page Close for housing. POLICY Hl(Al4) AND Hl(Al5)
Objections Nos 128-130.134-136.139,140.142.144-146,150,151.154.155 and 157 Written Objections Nos 131-133. 137. 138. 141. 143. 147-149. 152, 153. 156 !!II!! ill Representations Nos R21-R28
4.13.1 The oral objections were made by Mrs Salway on her own behalf, and on behalf of Mr S H Alabaster, Mr & Mrs KV Barden, Mr K Boddy, Mr & Mrs J Hoadley, Mr & Mrs K J Harrison, Mr A A Lidsey, Southfleet Parish Council and Mr P 25 Wanless. The written objections were made by Mr R Calver, Mr A J Forknall, Mr and Mrs J Grady, Mrs R Millns, Mrs C A Prankard, Mr B E A Tolmie, and Mr and Mrs e R Williams. The objections concerned the allocation of housing sites in Betsham. ent i Summary of Objections 4.13.2 The sites identified as Al4 and Al5 should not be allocated for housing, and should be retained in the Green Belt for the following reasons:
1. There was no need for additional housing development in the village. Recent planning permissions had been granted for 25 new dwellings which represented an increase of 25% in the size of the village. 2. Each proposal amounted to more than infilling and would extend the village into the countryside. 3. Development of either site would result in adverse traffic effects on the local rosd system and on the amenities of residents. 4. There was ample land available elsewhere in the borough for housing development .
The Council's Response
4.13.3 Both objection sites lay within the confines of the village and were properly so shown on the local plan. The identification of these two sites for housing purposes accorded with the structure plan's policy approach for rural settlements concerning sites within or adjoining village confines, and would contribute to housing choice. No undue impacts would arise from the development of either site.
4.13.4 Representations from Mr J Declerk, Mrs J DeClerk, Mr L Declerk and Miss V P Mower supported both allocations, on the basis that the village envelope should be redrawn to recognise the redevelopment of the Betsham Service Station, and that the village envelope should be expanded.
Conclusions
4.13.5 Betsham is a settlement with no previously defined village limits, and was "washed over" as Green Belt. It is a relatively small hamlet with a public house but no church; the nearest post office and surgery are at Southfleet. It is identified on the Proposals Map as an Area of Special Residential Character and subject to Policy H9.
Site Al4
4.13.6 There is residential development opposite the objection site but it is well above road level and behind retaining walls. The frontage of the objection site is open and there is no footway or verge. In my opinion the dwelling Elmstone is an individual dwelling separated from the main built-up area, and the objection site is well-related to the countryside. Up to eleven dwellings could be erected on the site under Policy H9, and any such development which would require the formation of a new access, would be a significant extension of the built-up area into the countryside. I consider that the objection site performs a valuable Green Belt function in safeguarding the countryside from further encroachment.
4.13.7 The site lies in a sensitive area south of the A2 trunk road. I note that planning permission was refused in 1982, and a subsequent appeal dismissed, on the grounds that the site performed a Green Belt function and that the
26 I . proposed development would have a detrimental effect on the amenities of the area and on its rural character. In my view, that situation still pertains, and site Al4 should remain in the Green Belt.
Site Al5
4.13.8 Up to 5 dwellings could be erected on this site which lies between the existing built-up area and a small cottage to the south. Although there is a row of bungalows opposite the site, and a kerbed footway along its frontage, it is my opinion that this site is well-related to the adjoining countryside. I consider that it performs a similar function to Site Al4 in safeguarding the countryside from further encroachment. For similar reasons to the above, it is therefore my view that Al5 should be retained within the Green Belt.
4.13.9 I have had regard to the aims of Policy V2 to provide a gradual transi.tion from open countryside to the built·up area, but I do not consider that any such benefit would be gained from development on Site Al4, and that there would be insufficient benefit to such development on Al5 to outweigh what I regard as an extension of development into the countryside. Furthermore, there also appears to be a resonable range of housing within the village, and I find no special circumstances to justify removing either site from the Green Belt
R@connnendation
4.13.10 I recommend that:
1. Policy Hl be modified by the deletion of sites Al4 and Al5;
2. The Proposals Map be modified so as to retain sites Al4 and A15 in the Green Belt.
A consequential modification to Policy V2 will also be required.
POLICY Hl(Al6)
Representations Nos R29 and R30
4.14.1 The South East Thames Regional Health Authority (SETRHA) and Dartford and Gravesham Health Authority (DGHA) supported the allocation of land at west Hill Hospital for housing. There were no objections to the allocation.
POLICY Hl(B3)
Representation No.R31
4.15.1 Mr J C Thompson supported the allocation of land at Dartford Football CLub for housing, planning permission for which had been granted.
27 POLICY H2 (ALSO POLICY CF4) :ea :e Written Objection No 160 Representations Nos R32-R34
4.16.l The objection was made on behalf of the White family.
Summary of Objection >W 1y 4.16.2 The Darenth Park Hospital site should not be allocated for housing in addition to a new general hospital; this view had been supported on a recent planning appeal decision. The allocation of the site for residential use in addition to hospital use, did not accord with Government advice for the use of redundant hospital sites, as the hospital was clearly no longer redundant.
The Council's Response
4.16.3 Planning permission for redevelopment for housing had been originally refused on the basis of Circular 12/87, solely because the site could not be regarded as wholly redundant since a new district general hospital had been proposed on part of the site. However, Circular 12/91 now accommodated this situation, by allowing for mixed residential and hospital development on hospital sites when existing buildings had become redundant. Policy H2 specifically referred to Circular 12/91, and there was thus no basis to the objection.
4.16.4 Colyer Greenhithe Estate, The South East Thames Regional Health Authority (SETRHA) and Dartford and Gravesham Health Authority (DGHA) supported the proposed redevelopment of the hospital site.
Conclusion
4.16.4 Circular 12/91 supersedes Circular 12/87, and I regard the provisions of Policy H2 as being in accordance with the latest advice contained in the current circular. In my view, no change to Policy H2 is required as a consequence of this objection.
Written Objections Nos 161-163
4 .16. 5 The objections were made by Kent County Council, Dartford and Graves ham Health Authority and South East Thames Regional Health Authority.
Summary of Objections
4.16.6 A general policy should be included in the plan to the effect that developers of substantial sites for residential use such as at Darenth Park Hospital, should make adequate provision of land for new educational facilities.
4.16.7 The policy should deal with the whole site to permit greater flexibility in the development brief. In particular, the specified timings were unreason able, and not as previously agreed.
4.16.8 Additionally, the boundary between the two allocated areas was incorrect.
28 The Council's Response
4.16.9 The council concurred with the principle that major housing developments should include an appropriate contribution towards service provision, and proposed to modify Policy H2 accordingly by requiring a scheme which would make appropriate educational provision.
4.16.10 It was agreed that in the light of Circular 12/91 it would be appropri ate to provide greater flexibility in planning the layout of the site as a whole, and that the relevant policies and the Proposals Map be changed to identify a single area for both housing and hospital purposes.
4.16.11 It was recognised that, as long as a firm and binding commitment to construct the hospital were obtained prior to redevelopment, there was no necessity to use the relative timing provision for its construction as a safeguard.
Conclusions
4.16.12 The provision of educational facilities insofar as they are related to the development, would accord with the advice in Circular 16/91, in that only an appropriate provision would be required under the policy. A major housing development is envisaged as part of the redevelopment, and I consider that the developer should be required to make an appropriate provision for educational facilities as suggested in the commended change.
4.16.13 Circular 12/91 stresses the importance of considering redundant hospital sites as a whole, and in my opinion the commended change to the Proposals Map would bring the policy into line with that advice.
4.16.14 I consider that the requirement for the hospital to be built before or at the same time as, the housing is unreasonable. I therefore agree with the commended amendment to the proposed change, which would correct this.
Recqmn"1ktion1
4.16.15 I recommend that:
1. paragraph 4.3.2 be modified in accordance with commmended change No.10
2. Policy H2 be modified in accordance with commended change No.11 as amended by commended change No.S3.
3. The Proposals Map be modified in accordance with commmended change No.71.
POLICY H3 (ALSO POLICIES Hl(A3) AND GB4(d))
Written Objections NoS 43-66.159.164-168.222 and 324 Representations Nos R56 arui Rl22
4.17.1 The objections were made by Mr A Baxter, Mr D S Coleman, Mr R J Downer, Mrs S Downer, Mr T Futter, Mr B Harris, Mr R J Harris, Mr W F Howsar, Mr R Symes, Mr D A Styles, Mr G Sharvell, Mr D Ling, Mr PE Willshear, Ms LS Willshear, Mr C D Stennett, Mrs S Woolstonhulme, Mrs KM Wood, Mr F W Fordham, the London Borough of Bexley Chief Planning Officer, the London Green Belt Council, Mrs E McFarlane,
29 Mrs D Broad, Mrs D V Coomber, Wilmington Parish Council, Ms A Cockerill, Mr K F Howard, Mrs L Mason, Mr J Nash, South East Thames Regional Health Authority, Mr D :s Stanton, and Drs Sen and Patel. Summary of Objections
4.17.2 1. The proposal would result in the loss of recreational facilities. 2. Valuable open space would be replaced by dense development. 3. There were no exceptional circumstances to justify deletion of land from the Green Belt, and Structure Plan Policy MGB3 did not provide a basis for it. 4. The Green Belt was valuable in preventing the coalescence of Coldblow/Bexley with Joydens Wood; the site formed an effective barrier between the settlements. 5. The site contributed to the Green Belt functions of checking the unrestricted sprawl' of large built-up areas, and of safeguarding the surrounding countryside from further encroachment. 6. The site allocated for housing was not part of Bexley Hospital. 7. There was a~ over-provision of housing, so the housing site was not needed. 8. Any housing :development should be deducted from the hospital "footprint". 9. The allocation of housing on site A3 prejudiced the preparation of a Development Brief. 10. The surrounding road network was already overloaded and no development should be allowed until it had been demonstrated that the road network could absorb the additional traffic generated. 11. Joydens Wood already generated considerable volumes of traffic and Summerhouse Drive would become congested as a result of this proposal. 12. The Dartford Road/Old Bexley Lane junction was dangerous and overloaded. Tilekiln Lane should be opened up and Summerhouse Drive continued in order to relieve the Old Bexley Lane. 13. The proposed school was not needed and would generate additional traffic. 11. There would be a need for additional flood protection. 12. There was no reference in the policy documents to the preservation of listed buildings. 13. The word "services" was insufficiently explicit and should specifically incorporate wording to the effect of "flood protection" or "land drainage". 14. Flooding problems in the area would be increased by any development and a substantial sum of money would be required to alleviate the difficulty. No reference to drainage was included in Policy H3. 15. There was a need for a surgery to serve the area of Joydens Wood (Objection to Policy CF6).
The Council's Response
4.17.3 The Council concurred with the view that sports facilities at the hospital site should be retained as they formed a valuable amenity. A commended change to Policy H3 was therefore proposed which took this into account. The Sports and Social Club had written expressing satisfaction with the commended change.
4.17.4 The site allocated for housing under Policy Hl(A3) did not perform any of the Green Belt functions listed in PPG2, in that it did not serve to check the unrestricted sprawl of large built-up areas. Once the hospital site and the school site were developed, the objection site would effectively be landlocked and could not therefore perform a buffer to outward expansion.
30 4.17.5 The site did not safeguard the surrounding countryside from further encroachment as it was suburban in character and could not be said to be open countryside. Neither did it prevent neighbouring towns from merging into one another as it was not a strategic gap between Coldblow and Joydens Wood since these two built-up areas were already contiguous.
4.17.6 The A3 site did not perform any of the other Green Belt functions and should therefore be excluded from the Green Belt.
4.17.7 The hospital site designated as H3, was to be redeveloped in accordance with Circular 12/91 concerning redundant hospitals in the Green Belt. The housing site to be developed under Policy Hl(A3) was also in the ownership of the Health Authority and would be developed as part of a comprehensively planned scheme for the whole complex. The owners intended that the total footprint of the whole scheme including the A3 site, should not exceed that existing on the hospital site.
4.17.8 Kent County Council had confirmed that the site was required for a new school which would serve residents of the housing proposed on the hospital site.
4.17.9 Policy H3 sought to incorporate appropriate vehicular access arrange ments which would safeguard the environment of housing areas to the west and south. If redevelopment were accessed as at present from the north, most traffic would discharge directly onto the nearby junction on the A2, leaving adjoining housing areas relatively undisturbed.
4.17.10 It was recognised that development should include uses ancillary to residential development, and the commended change would take account of this. Such ancillary uses could include a surgery, and that would be taken into account at the detailed planning stage. r 4.17.11 The Council would ensure that at the planning application stage for each site, any consent would contain a condition requiring detailed plans with supported documentation and calculations, to be submitted to the council, thereby enabling them to exercise their duties pursuant to the Land Drainage Act 1976 to ensure that the proposals did not put land or property at additional risk from flooding.
4.17.12 The commended change to H3 included a requirement for development to incorporate adequate drainage. Consultants acting for the owners of the land had stated that "new infrastructure to serve the development will be installed and funded by the developers .... " Appropriate services would all be provided including surface water drainage. The scheme included features which could be designed to provide balancing' to ensure that no additional flooding occurred downstream as a result of the development.
4.17.13 The South East Thames Regional Health Authority (SETRHA) appeared at the inquiry, and generally supported the Council's approach to the redevelopment of the Bexley Hospital. They suggested minor changes to the wording of Policy H3 so as to include the provision of community facilities in association with the proposed housing.
Conclusions
4.17.14 The commended change had not only the support of the objector but also several local residents who were concerned at the possible loss of recreational facilities. The change would introduce uses which I consider would be appropri ate to its sensitive Green Belt location.
31 4.17.15 I do not agree that site A3 does not perform a Green Belt function, or that the exceptional circumstances referred to in the Structure Plan and discussed in chapter 6, justify removal of housing site A3 from the Green Belt. The site forms part of the open area north of Dykewood Close, which although containing the hospital, forms part of the Green Belt enclosing Joydens Wood and separating it from Maypole and the built-up area north of the A2 trunk road.
4.17.16 The retention of the Green Belt notation on the A3 site need not inhibit the comprehensive redevelopment of the hospital site, as the intention is that the housing allocation on the A3 site should be set against the overall hospital footprint. Dykewood Close forms s natural boundary between Joydens Wood and the open area to the north, and in my opinion would be a more defensible Green Belt boundary than that shown on the Proposals Map or on Map 3 of the commended changes. I can see no reason why all the land in the Health Authority's ownership could not be developed comprehensively as a single site within the terms of Circular 12/91 which recommends that sites should be considered as a whole, and still remain within the Green Belt.
4.17.17 The illustrative proposals put to me indicate the main access from the north near the roundabout junction with A2. Any detailed appraisal of traffic flows would form part of the consideration of a planning application, and I see no reason on traffic grounds for any need to propose further modifications to H3, including the possible provision of a school. Other policies within the plan require consideration of such matters as part of the development control process.
4.17.18 The commended change to Policy H3 would draw attention to the drainage issue on the hospital site. The possibility of any redevelopment leading to flooding of the surrounding area would be considered by the council under its statutory powers, and the development brief would require appropriate measures to be taken.
4.17.19 In other locations, the council's statutory powers and other policies in the plan, in particular policies Bl and CFl, should ensure that land outside areas to be developed will not be put at risk from flooding by any development proposals.
4.17.20 The possible need for a new surgery is neither supported nor disputed, and any proposal for such a development would be considered on its merits within the terms of Policy H3 if modified as recommended.
R@c91N11opdations
4.17.21 I recommend that:
1. Policy H3 be modified in accordance with commended change 13 but deleting any reference to Policy Hl(A3);
2. the Proposals Map be modified by (i) deleting any reference to A3, and (ii) retaining site A3 in the green belt;
3. the proposals map be modified to show the H3 notation extending over all the land designated as A3, RT14 and CFS on map 3 of the schedule of commended changes.
32 POLICY H4 (ALSO POLICIES Tl3, Cll, BG AND APPENDICES 3,4 & 5)
Qbjections Nos 2 169,304 341 342 arui 343
4.18.l The objections were made on behalf of the Marine Society, and concerned land at Ingress Park, Greenhithe.
Summary of the Objections
4.18.2 Objection 2 stated that the local plan did not have proper regard to the provisions of the 1987 Use Classes Order and as a consequence it failed to comply with Kent Structure Plan Policies EDl, Sl and ED1-ED7.
4.18.3 Objection 169 stated that the policy did not identify the site for Bl uses, and that public access should not be required along the whole of the river front or at Ingress Park. It was unnecessary for a comprehensive scheme to be provided and it was unreasonable to expect the developer to provide for the ultimate construction of the STDR over land which was not in their ownership or control.
4.18.4 Objection 259 related to parking standards, and is considered in Chapter 7
4.18.5 Objection 304 referred to the inclusion of part of the site in the Woodlands Policy Area, and the blanket Tree Preservation Order (TPO) over the whole objection site would be sufficient to protect trees.
4.18.6 Objection 341 was against the provision of two access points to the site as shown on the Proposals Map.
4.18.7 Objection 342 related to the provisions of Policies BG and B7, and pointed out that Ingress Lodge and the stone walls and railings along the front of the site, were within the current line of the proposed STDR.
4.18.8 Objection 343 referred to Policies B8 and B9, and objected to the extension of the Greenhithe Village Conservation Area.
The Council's Response
4.18.9 Objection Nos 341 and 343 arose from mis-perceptions of the plan. It was i intended that there should be only one access point to Ingress Park. The highway limits shown took no account of the redevelopment proposals for Ingress Park, and assumed that the existing access at the western end of the site was to be maintained. There was no proposal to extend the Greenhithe Village Conservation Area.
4.18.10 It was acknowledged that some rewording would be necessary to clarify the mixture of development intended for the site, and the status of data in Appendices 3, 4 and 5. The tables in the appendices were to enable comparisons to be made between the provisions of the local plan and the structure plan guidelines, and no significance should be attached to the table entries; commended change No.G would reflect this. Commended change S2 would group the 3 appendices together and make their interpretation more clear. The removal of the word "subsidiary" from paragraph 3.3.1 as recommended in commended change Sl2, would enable applications to be judged on their merits without the mixture of development being prejudged. The assumption that one third of the site would be available for economic development was not intended to be a strategic requirement but was for structure plan monitoring purposes only; commended change Sl7 would clarify this. The rewording of paragraph 4.3.4 recommended in change Sl3 would bring the structure plan policy in line with the objective of structure plan 33 Policy HD2. It was accepted that Bl type uses would be an acceptable part of any redevelopment, and this would be made clear by the insertion of Bl uses as recommended in change 814.
4.18.11 The alignment of the STDR was that carried forward from the previous statutory development plan. The eventual alignment may be different, but for the time being it was considered advisable to safeguard the original route. Contributions from developers towards the cost of its construction may be required, but this would be in accordance with Government guidelines. Traffic studies already carried out indicated that substantial improvement to the highway network would be required to serve the new development in the area. The major aim of the STDR was to serve new development. A change to Policy H4 similar to that recommended in change SlS, would bring the policy into line with the principles of Circular 16/91.
4.18.12 One element of the Council's overall strategy was to improve public access to the river frontage. The objection site represented an important feature along the riverside, and it was compatible with their overall strategy that public access should be maximised in this area. It was however, recognised that Policy H4 as worded lacked flexibility, and the suggested rewording contained in change SlS was recommended.
4.18.13 The site and its woodland setting was of considerable importance, and its redevelopment and management should not be left to the development control process alone. Nevertheless, it was recognised that the TPO could be used to protect the trees, and it was recommended that woodland at Ingress Park be deleted from Policy Cll which is a countryside policy, in commended change Sl6.
4.18.14 It would not be appropriate for the plan to contain any specific reference to the demolition of listed buildings. The policy should seek to secure the refurbishment of the existing listed buildings, Ingress Abbey in particular, and rewording to recognise this was suggested in commended change SlS.
Conclusions
4.18.15 I do not consider that any actions with regard to Objections 341 and 343 are necessary. The road links shown on the Proposals Map indicate the envelope of roadworks necessary at the junctions each side of the objection site.
4.18.16 There was little difference of substance between the parties at the inquiry, and several changes to the deposit version of the plan were agreed in order to achieve the correct emphasis, and to clarify the parties' intentions. I generally support these changes. Commended change Sl2 would not prejudge the composition of any redevelopment, and change Sl3 would clarify the relationship of the policy to structure plan objectives; commended change Sl4 would indicate the nature of development envisaged on the site.
4.18.17 I generally agree with the changes commended in Sl5 to Policy H4, in that the policy now sets out aims for any redevelopment. I am however concerned at the inference which could be drawn from reference to the contributions to the funding of the STDR when no other site specific reference is made in the plan. In my opinion the matter is adequately covered in Policies Tl2 and T21. I consider that reference to the construction of the STDR is not necessary, and its deletion would not affect the council's ability to require contributions to road improvements if the requirements satisfy the tests of 16/91. I therefore consider that the clause relating to the provision of the STDR should be deleted from the supplementary commended change; a requirement for the development scheme to have regard to other policies of the plan would in my view be sufficient.
34 4.18.18 The objection site comprises a considerable amount of open area and woodland which provides a valuable amenity within the built-up area. Nevertheless I support its exclusion from Policy Cll which is a policy contained within other policies designed to preserve the countryside. It does not appear to me that the site's inclusion in Policy Cll would achieve any of the objectives set out in the countryside chapter. The current TPO should provide adequate protection for the trees on the site. I therefore support the deletion of the site from Policy Cll within commended changes Sl5 and Sl6. It appears that through no direct fault of the owners, the quality of the listed buildings on the site is not all that it should be. Depending on the ultimate alignment of the STDR, some of the buildings and boundaries may also be threatened. Whilst there is always a presumption in favour of retaining listed buildings, and that any redevelopment brief should seek to achieve their retention, it may not be practical to secure their refurbishment. Accordingly I support the rewording of the policy as recommended in change Sl5. Policies B6 and B7 set out the criteria against which demolition or alterations to listed buildings will be considered.
Recommendatign1
4.18.19 I recommend that:
1. paragraph 3.3.l be modified in accordance with commended change Sl2;
2. paragraph 4.3.4 be modified in accordance with commended change Sl3;
3. paragraph 4.3.5 be modified in accordance with commended change Sl4;
4. Policy H4 be modified in accordance with commended change SlS but (i) omitting the words [provides for the ultimate construction of the adjacent section of the South Thames-side development route], and (ii) omitting the words [see Policy Cll], and (iii) adding that proposals must pay regard to other policies of the plan.
5. paragraph 10.3.11 be modified in accordance with commended change Sl6;
6 . Appendix 4 (footnote) be modified in accordance with commended .I change Sl7; 9. I recommend that Appendices 3, 4 and 5 be modified in accordance '· with commended change S2.
POLICIES H7 AND H8
Written Objections Nos 172,173,174 arui 175
4.19.1 The objections were made on behalf of Waites Built Homes Ltd, and by the House Builders Federation.
Summary of Objections
4.19.2 The policy should not stipulate that new housing development should make adequate provision for family housing as not all sites would be suitable for such housing. The type of housing appropriate to any site should be determined by the market, and planning control should not seek to override such considerations. 35 SS 4.19.3 Supplementary planning guidance indicating acceptable densities for new r developments would be inappropriate. This was a matter which needed to be he considered on a site by site basis, taking account of the character of any 'le surrounding development and other site characteristics.
4.19.4 Policy H7 did not recognise the need to meet the demand for lower cost smaller unit accommodation within the borough. The policy also referred to the "general lowering of density" and making adequate provision for family housing. s Strict application of this policy arising from Section 54A of the Town and Country Planning Act 1990, would generally restrict opportunities for providing smaller dwellings in the borough for which there was a recognised demand.
4.19.5 There was no evidence to show that lowering of density necessarily enhanced the environment or character of the area.
4.19.6 Policy HS was not a policy but an explanation of how the Council would apply other policies in the plan. It should therefore be included as part of the text. It was unclear to what "these factors" referred.
4.19.7 Policy HS contained a reference to supplementary planning guidance which could be prepared without proper public consultation, yet would carry the weight given to a policy. Supplementary planning guidance on densities would be inappropriate as they should be considered on a site by site basis.
4.19.8 In reply to the council's response, Objector No.173 considered that any flexibility of interpretation should be reflected in the wording of the policy. Supplementary planning guidance could be used to indicate density levels over the plan area without any proper public consultation.
The Council's Response
4.19.9 There was no intention to apply the policy's reference to "make adequate provision for family housing" rigidly to all sites regardless of their suitabil ity. However, the provision of new housing in the borough over recent years had been dominated by smaller units, and in order to attain a full range of available house types, the policy sought to redress the imbalance. A more balanced provision would make it easier for small households to "trade up" when seeking larger accommodation without having to leave the borough. This would also fulfil local plan and strategic housing objectives.
4.19.10 There was no intention to use the policy to preclude low cost units. There was already a significant supply of units at the lower end of the housing market, and the council itself was actually involved in such provision.
4.19.11 A lowering of density was mentioned in the policy by way of an example of enhancement; it would not necessarily apply to all redevelopments. Neverthe less the council was generally keen to avoid town cramming.
4.19.12 It was acknowledged that Policy H8 was effectively an adjunct to H7 and a commended change would combine the two policies into one. This change would clarify the meaning of "these factors".
4.19.13 Supplementary planning guidance was a legitimate element of planning control, and was useful in amplifying local plan policies as advocated in PPG12. The weight accorded to such guidance would depend, inter alia, on whether public consultation had been carried out. Any supplementary planning guidance on densities would take account of varying site characteristics but would create a consistent basis for determining such densities.
36 Conclusions
4.19.14 As worded, policy H7 requires developers to "make adequate provision for family housing". While it may not be the council's intention to apply the policy rigidly to all sites, development proposals should accord with the local plan other than in exceptional circumstances. The preamble to the policy in paragraph 4.3.8 refers to a greater emphasis being placed on family housing, which in my view gives adequate guidance to future residential development proposals. I consider that the requirement for developments to make adequate provision for family housing should be deleted from the policy.
4.19.15 The development of low cost housing is not explicitly referred to in the policy but I do not consider that the policy precludes its provision. One of the objectives of the housing policies is to secure the provision of a range of housing types to meet housing demands, and where a need for low cost housing can be demonstrated, Policy H7 would not preclude its provision. It appears to me that the purpose of Policy H7 together with the preamble in paragraph 4.3.8, is to provide improved standards of design and density. Subject to the modification described above, I do not find any reason to recommend a further change to the wording of Policy H7. A reference to a lowering of density is given as an example of redevelopment of residential areas where densities are already high.
4.19.16 I agree with the combining of the two policies H7 and H8; their meaning would be clearer as a consequence.
4.19.17 In my opinion supplementary planning guidance can be a useful means of amplifying local plan policies; the status of such guidance is set out in PPG12. The weight to be accorded to them would depend on the manner of their production and publicity, but I can see no reason why the policy should not refer to the possibility of such guidance being prepared.
Recq=endatigp
4.19.18 I recommend that:
1. Policy H7 be modified by deletion of the words [make adequate provision for family housing,) and [pay regard].
,j 11 2. Policies H7 and H8 be combined in accordance with commended change No 15, subject to the modification to Policy H7 described above.
POLICY H9 AND APPENDIX 10
Hritten Objections Nos 173 (part).174 (part).175 (part) and 176
4.20.1 The objections were made on behalf of Waites Built Homes Ltd, and by the House Builders Federation.
Summary of Objections
4.20.2 1. There was a lack of flexibility in the policy and too much detail in Appendix 10. 2. No justification was given for the designation of Areas of Special Residential Character, yet the policy stated similar requirements to those of Conservation Areas. The designated areas were very extensive and the quality of the areas was not uniformly high.
37 3. The normal application of development control policies subject to Policy H7 would be adequate to protect the character of the areas. The policy therefore duplicated Policy H7, and should be deleted. for 4. Development proposals should not be assessed against an appendix in icy the plan. Indications of density may be helpful but they were only of secondary importance to site specific circumstances. •ph 5. Development proposals for flatted development should not be precluded.
4.20.3 In reply to the council's response, objector 176 stated that strict application of Policy H9 could prevent any development in the prescribed areas. Policy H7 if modified as commended, and Policy Bl would be adequate to determine he whether any development would be suitable having regard to the character of the he area. The restrictions in Appendix 10 concerning flatted developments and densities exceeded those referred to in the policy. n The Council's Response
l 4.20.4 Identified Areas of Special Residential Character were areas of lower density housing with an attractive established character, and which would be vulnerable to over intensive development. The criteria in Appendix 10 must necessarily be detailed to prevent the insidious effects of inappropriate development, and to clearly identify the factors which the policy sought to address.
4.20.5 Policy H9 did not duplicate the purpose of Policy H7 which related to new housing proposals generally and to the nature of new housing provision. Policy H9 sought to safeguard the character of certain existing defined areas of housing. The areas on the Proposals Map covered by Policy H9 had been identified for the character and quality of their residential environments in well established settings.
4.20.6 Appendices were a useful way of keeping the text clear of detail which was not essential to the main thrust of the policy. They should be regarded as elaborations of the policy.
Conclusions
4.10.7 Provided care is taken in their selection, I recognise the advantage of identifying areas where higher than normal standards of development would be appropriate. This would be consistent with the council's aim of improving the overall standard of hoasing in the borough. Dwellings in such areas may well have larger curtilages than normal, and sub-division into smaller plots could adversely affect the character of the area to a greater extent than might be acceptable elsewhere. I therefore support the principle of a policy such as H9.
4.20.8 I consider that the last sentence of Policy H9 gives excessive weight to the guidelines, and its inclusion within the policy is inconsistent with the advice in PPG12. Guidelines appear to have similar status to supplementary planning guidance, and reference to them should be made in the preamble in paragraph 4.3.9. This would have the effect of introducing some flexibility into the guidelines where circumstances require a slight variation from them.
4.20.9 I regard some of the criteria in Appendix 10 as unduly excessive. No reason is given either in Policy H9 or the preamble for rejecting flatted devel opments, and in my view it would be more appropriate to set out criteria against which proposals for flatted developments would be considered. There is also a blanket objection to backland development, which would prevent developments which may be perfectly satisfactory on the ground, for example the development at
38 Langworth Close. While it may be appropriate to reject tandem development, I consider that it would be more appropriate to define the criteria against which backland development may be considered.
Recg=rntiation
4.20.10 I recommend that:
l. Policy H9 be modified by deleting the last sentence;
2. Paragraph 4.3.9 be modified by adding the words "set out at Agpendix 10" after the words "associated guidelines"; I 3. Appendix 10 be modified by deleting criteria 2 and 5, and adding i factors against which proposals for new flatted developments, and for backland development would be considered.
POLICY HlO
Objection No, 179 Written Qbjections Nos 177. 178. ancl 180
4.21.l The oral objection was made on behalf of GA Land and New Homes, Crest Homes (Southern) Ltd of Westerham, Berkeley Homes (Kent) Ltd of Westerham, Ward Homes of Chatham, Persimmon Homes of Crawley and De Vinci Properties of Wrotham. The written objections were made by Blue Circle Properties Ltd, Waites Built Homes Ltd and the House Builders Federation.
Summary of Objections
4.21.2 Objection 179 was to the introduction of new spatial standards embodied I in the deposit version of the local plan, and were intended to apply to the I' layout and design of new housing developments in the borough. In particular the objection was directed at prescribed minimum garden lengths, and minimum rear garden sizes to be applied to differing sizes of dwelling.
4.21.3 The policy should allow for exceptions by insertion of the word normally. The policy was unreasonably detailed, and the spatial standards were unreasonable. These comments also applied to policy Bl. The over-generous space standards were unreasonable and would discourage development, particularly those for small properties.
4.21.4 The inclusion of standards within the policy made the policy onerous and inflexible. All the criteria should be deleted as such standards were more appropriate to a design brief or supplementary design guidance. The functional requirements such as garden areas within a development, were matters of marketing judgement.
4. 21.5 Government advice was that maximum effective use should be made of urban areas.
The Council's Response
4.21.6 Improving standards of residential amenity, and avoiding the dangers of town cramming were important objectives of the plan's housing policies. Definitive standards were necessary if a degree of consistency was to be maintained in development control. The standards in Policy HlO were appropriate and reasonable in this regard. 39 I 4.21.7 The spacial standards criteria associated with Policy HlO constituted a lch key factor in the council's aim to improve the quality of its residential areas. The augmentation of its spacial standards should lead to a general lowering of densities, and was an overdue requirement. It would ensure the protection and improvement of the residential environment and householder privacy, and make some allowance for the possible loss of garden land at some stage due to domestic extensions. It represented a positive and meaningful contribution towards the "greening" of development control.
4.21.8 The improved spacial standards should be incorporated within an approved local plan policy to be in tune with relevant PPG's and circulars, in particular with the expressed need for there to be clear policies in local Plans against which applications would be considered. The standards were more flexible than in some other local authority areas such as LB Havering. The objectors proposed :I amendment of Policy HlO lacked precision and reference to "a high standard" of layout and design was a recipe for confusion.
4.21.9 There would occasionally be instances when it would be appropriate to make an exception to these criteria, but an explicit statement to this effect was unnecessary and would undermine the general application of the policy. The standards set out in Policy HlO were of fundamental importance, and should carry the full weight accorded to statutory local plans.
Conclusion
4.21.10 Due to the council's objective of improving the quality of residential areas in the borough, Policy HlO sets out higher standards than might otherwise be the case. The council are particularly concerned to prevent "town cramming", and the spatial standards in Policy HlO allow for the possibility of an extension being erected as permitted development without reducing the back garden to an unacceptably small size. In principle therefore, I regard a policy to establish higher spatial standards as appropriate in the local plan.
4.21.11 The recent appeal decision in Dartford, as well as examples of recent developments in the locality, indicate that proposals which do not comply with the standards of Policy HlO can nevertheless result in acceptable standards of development. The council agreed that the standards in Policy HlO were a target for desirable standards, and that they should be applied flexibly not rigidly. As currently worded however, there is no flexibility indicated in Policy HlO.
4.21.12 In my opinion the inclusion of standards for new development within a local plan policy gives undue weight to the prescribed standards which are necessarily somewhat arbitrary. Failure to comply with any one of the criteria could result in development which may be otherwise acceptable, being prevented. To rely on the policy being interpreted flexibly is, in my opinion, likely to devalue both this and other policies in the plan. I therefore consider that the criteria which are of a higher standard than has hitherto been the case in the borough, should be contained in an appendix and have the status of supplementary planning guidance.
4.21.13 Recognising the aims of the Council to raise the standards of housing in the borough, I consider that it would be appropriate for Policy HlO to establish this aim. The preamble to the policy in 4.3.10 should state the background to this, indicating that the target for new housing development would be as set out in the appendix, and that proposals for development should aim to achieve these standards wherever possible.
40 , A
4.21.14 Another of the council's objectives is to provide a range of housing types, and where a need for lower cost housing can be identified, lower standards than those currently stated may be appropriate. The policy should recognise this as constituting circumstances justifying a relaxation of the higher spacial standards. I llecQUepdation
,! 4.21.15 I recommend that:
1. Policy HlO be deleted.
2. A new Policy HlO be inserted stating that the layout and design of new housing developments should be to a high standard, and pay regard to the Kent Design Guide and other policies of the plan. They should aim to be compatible with, or an improvement on, the surrounding area.
3. Paragraph 4.3.10 be modified by the deletion of the words [Policy HlO]
4. Paragraph 4.3.10 be modified by the addition after "set out in" of a statement referring to a new appendix setting out target standards which developments should aim to achieve whenever possible, unless the developer can demonstrate that special circumstances require different standards.
POLICY Hll
Written Objection No 181
4.22.1 The objection was made by Lloyds Bank PLC and concerned residential de velopment above A2 user outlets.
Summary of Objection
4.22.2 Flats over banks were a security risk, and the policy should acknowledge that either operational or security reasons would in certain circumstances, necessitate that flats could not be let for residential purposes. Unless change to an A2 use was permitted, they would remain vacant and deteriorate.
The Council's Response
4.22.3 It was accepted that bank security was a legitimate concern. The "upper floors" sub-section of Chapter 14 of the local plan referred to security as a relevant consideration. Policy Hll stated a presumption against the loss of sound residential accommodation, and the concern for security could be weighed against that presumption.
Conclusions
4.22.4 Policy Hll states a presumption against the loss of residential accommo dation whereas Policy TC4 states a presumption in favour of proposals for the re use or conversion of upper floors in the town centre's central business area. I consider that there is a possibility of confusion as to which is the stronger presumption in the town centre. Policy TC4 lists criteria against which
41 proposals for conversion of upper floors would be evaluated, and they include, g for residential use, the availability of private amenity space, The preamble to dards that policy also refers to considerations of access and security. this 4.22.5 In my view the matter of security is a valid consideration in this policy, and a rigid interpretation of Policy Hll could result in upper floor accommodati~n remaining vacant. While it may not be appropriate to list all the possible exceptions to the policy, I consider that it would be appropriate to indicate which policy took priority in the town centre. It is my opinion that Policy TC4 which is specific to the town centre, should have priority in the town centre over Policy Hll which is of more general application. I therefore conclude that Policy Hll should be modified so as to be subject to the provisions of Policy TC4. of Recg•endation
4.22.6 I recommend that Policy Hll be modified by the addition of the words "subject where relevant. to the proyisions of Policy TC4" before the words "there is a presumption".
f POLICY Hl3 AND APPENDIX 11
Written Objection No 182
4.23.1 The objection was made by the House Builders Federation, and concerned flats and flat conversions.
Summary of Objection
4.23.2 Appendix 11 was specifically mentioned within Policy Hl3 and therefore formed part of that policy. The appendix unnecessarily interfered with normal development and design procedures, and schemes for higher density housing would become uneconomical.
4.23.3 NHBC standards were now mandatory, and the council had not put forward any justification for prescribing higher standards.
4.23.4 In reply to the council's response, the objector stated that the Environmental Health Professional Practice standards only related to houses in multiple occupation, whereas Appendix 11 referred to flats and flat conversions. The practice standards did not refer to new-build developments.
The Council's Response
4.23.5 The local plan standards for flats and flat conversion were based on a paper containing national guidelines, and produced by the National Symposium of Environmental Health Officers. The council attached great importance to maintaining basic standards of amenity in dwellings, and regarded those as a major factor in promoting adequate and satisfactory housing within the borough. It was not accepted that such standards would make development schemes uneconomical . ·
4.23.6 The NHBC's standards were far more limited in scope. As far as space standards were concerned, they only related to bedroom sizes.
42 Conclusions
4.23.7 I consider that the guidelines set out at Appendix 11 constitute supple mentary guidance and should not be included within the policy. Reference to the guidelines in Appendix 11 is made in the preamble within paragraph 4.3.13; repeating the reference in the policy is unnecessary, and could lead to unduly rigid application of the guidelines.
4.23.8 I note that the space standards in the Environmental Health Professional Practice standards for houses in multiple occupation, set out minimum floorspace areas for both conversion of existing buildings, and for new-build self-contained flats. Having regard to the council's aim to imrove standards of residential accommodation, they do not appear to me to be excessively generous, and in my opinion form reasonable standards to be used as guidelines for development i proposals. t Recpqrendation1 I 4.23.9 I recommend that:
1. Policy Hl3 be modified by the deletion of the words [and comply with the guidelines set out at Appendix 11].
2. Paragraph 4.3.13 be modified by the addition of the words: 11 proposals should comply with these &uidelines whenever possible•i.
43 UNALLOCATED SITES WITHIN THE GREEN BELT
Written Objection No.26
4.24.l The objection was made on behalf of Swaisland Settled Estates, and concerned land at Burnham Road, Dartford.
Summary of Objection
4.24.2 The site comprised a small parcel of land on the north-western outskirts of the borough, and was situated immediately adjacent to recent housing development. It also adjoined the railway to the south, and to the north was Burnham Road with non-conforming commercial users to the north-west. The site made no useful contribution to the Green Belt, and the Green Belt boundary should be redrawn along the line of the Stanham River which also formed the borough boundary, along the western boundary of the objection site.
4.24.3 There was a need to identify additional sites in order for the council to achieve their housing objectives.
The Council's Response
4.24.4 The objection site formed part of an important "green wedge" separating Dartford from Crayford, and was a vital part of a very narrow neck of Green Belt land. Development of the site would therefore militate against the purpose of the Green Belt as identified in PPG2, namely, to prevent neighbouring towns from merging with one another.
4.24.5 Any development of the site would relate unsatisfactorily to existing buildings. Also it was important to keep the banks of Stanham River open in order to enhance its amenity value.
Conclusion
4.24.6 The objection site forms part of an exceptionally narrow area of Green Belt separating Dartford from Crayford. Any reduction in this width would be highly significant, and would effectively eliminate its value in separating the two settlements. Notwithstanding the activities to the north of Burnham Road, which include the construction of the new Dartford Northern Bypass, it is my opinion that the site performs a green belt function, and should therefore remain open land.
4.24.7 Whether development of the site would relate satisfactorily to the existing buildings is, in my view, a development control matter, but I consider that when the area recovers from the works associated with the new bypass, the open nature of the site will contribute to the amenities of the area, and that the site has s value in its own right as open space.
4.24.8 For reasons given above in the background to this chapter, I do not consider that there is any overriding need for additional land to be allocated for housing.
Recommendatjon
4.24.91 I recommend no change in the allocation of this site.
44 Objection No. 194 and Written Objection No. 27.
4.25.l Objection No.27 was made on behalf of the White family, and Objection No. 194 was made by Mr Rixson. Both objections related to sites east of School Lane, Bean; the objection sites overlap each other.
Summary of Objections
4.25.2 Bean was a suitable village for additional housing, and there was a need for housing land to be identified in the borough as some other allocated sites were not genuinely available for development. School Lane was an arbitrary boundary of the Green Belt, and there was no reason why development should not extend as far as Sandy Lane. The site of Objection 27 would round off the village, and had previously been identified as being suitable for development. It was bordered on 3 sides by housing and would be more appropriate for housing than other sites such as site Al2 at Shellbank Lane.
4.25.3 The site of Objection 194 should be deleted from the Green Belt as it was Grade 3 agricultural land, and comprised an overgrown orchard which had not been used for the past 25-30 years. It was unsuitable for agricultural purposes. Its development for housing would round-off the village and provide a transitional area between the urban development and the countryside. Occasional dwellings should be allowed within the Green Belt to provide a gradual transition between the urban area and the open countryside.
4.25.4 Development was being allowed elsewhere within the Green Belt, such as at Darenth Park Hospital, and release of the site of Objection No. 194 would enable it to be brought into some beneficial use.
The Council's Response
4.25,5 School Lane was the clear boundary of development on the east side of Bean, and both objection sites were beyond the village confines. The sites fulfilled the Green Belt function of safeguarding the surrounding countryside from further encroachment. The fact that land was not being actively cultivated as agricultural land was not a reason for releasing it from the Green Belt. I j' 4.25.6 The land to the south and east of School Lane formed part of an Area of I Special Significance for Agriculture, and an Area of Local Landscape Importance. I 4.25.7 There was no need to release further land for housing in order to achieve the Council's overall housing targets.
Conclusions
4.25.8 In my opinion School Lane defines the current boundary between the built-up area of Bean on its western side, and the open countryside to the east. Both objection sites lie within areas which are protected from development in order to protect the needs of agriculture or the quality of the landscape. I consider that the current boundary of the Green Belt along School Lane is a logical and defensible boundary, and I do not consider that either of the objection sites, if developed, would provide a satisfactory or defensible boundary for the Green Belt,
4.25.9 Unfortunately Mr Rickson appears to have received conflicting advice on possible uses of his land, which has resulted in its being left idle for many years, and becoming overgrown. Nevertheless, it forms part of an area of woodland along the east side of School Lane adjoining open countryside. I can however, see nothing in the local plan which would preclude its use for recreational purposes as he suggested, subject to due consideration of normal 45 planning criteria. The residential development in the Green Belt referred to at the inquiry, will be subject to the limitations imposed by Circular 12/91 concerning the use of redundant hospitals in the Green Belt.
Regommepdation
4.25.10 I recommend no change to the allocation of these sites as a consequence of these objections.
Written Objection No. 28
4.26.1 The objection was made on behalf of the Hawkins Trust, and concerned t land to the east of Lane End. l Summary of Objection
4.26.2 The objection site should be allocated for low cost housing. There was a shortage of such housing, and the landowner would be willing to provide low cost housing for rent on the objection site.
The Council's Response
4.26.3 The site was within the Green Belt and fulfilled the purpose of safeguarding the surrounding countryside from further encroachment. PPG3 stated that the need for low cost housing did not override the presumption against inappropriate development in the green belt.
4.26.4 Development of the objection site would create a visually intrusive extension of the built-up form of Lane End into an area of open countryside which was identified as an Area of Local Landscape Importance and an Area of Special Significance for Agriculture. Residential development on the site would conflict with Policies C6 and C9 designed to protect such areas.
Conclusions
4.26.5 The objection site is a grass field on rising ground with rolling countryside beyond. In my opinion it forms a part of the attractive open countryside to the east of the settlement, and any development on the site would intrude visually into this attractive area of countryside. I consider that the existing limits of the residential development and the village hall form a natural boundary between the built-up area and the Green Belt.
4.26.6 No evidence was produced to show a need for low cost housing in this particular location, and I can find no special circumstances to warrant the removal of the objection site from the Green Belt in order to allocate it for housing development. llasnwendation
4.26.7 I recommend no change to the allocation of this site as a consequence of this objection.
Written Objections Nos 29 and 2ll(partl
4.27.1 The objections were made on behalf of Nevill Moreton & Phillips, Solicitors, and Mr E Huxley. They concerned land at Appleacre, Westwood Road, Betsham.
46 Summary of Objections
4.27.2 The objection site should be included within the village confines of Betsham as it was the only property in Betsham which was excluded. The dwelling Appleacre was a post-war detached bungalow on a plot of some 0.8 acre, and it related more closely to the village than did Elmstone which had been allocated for residential development.
The Council's Response
4.27.3 Appleacre lay behind properties fronting the west side of Westwood Road. Development of the site would constitute unsatisfactory backland development which would not relate well to the village. It would also be difficult to provide satisfactory access to the site.
4.27.4 It was acknowledged that the definition of village confines was not a clear cut matter in all case~, but it was considered that the objection site lay outside the village confines. The site was within the Green Belt and performed the function of safeguarding the countryside from further encroachment.
4.27.5 Betsham was a hamlet unable to support the level of services found in larger villages. It was unlikely that development of the objection site would be sufficient to ensure a larger range of services than existed at present. Only a significant enlargement of the settlement would achieve this, and such enlarge ment would be wholly unacceptable in the green belt.
Conclusions
4.27.6 The objection site forms part of the open countryside surrounding the small settlement of Betsham. In my opinion residential development on the objection site would extend the village into the open countryside which is designated as Green Belt. I consider that the boundary of development along the rear of dwellings in Westwood Road is appropriately drawn in this case, notwith standing the presence of a single dwelling on the objection site. I can see no exceptional circumstances in this case for removal of the site from the green belt and by implication, its suitability for residential development.
4.27.7 Whether it would be possible to provide a satisfactory means of access to the site, or whether development of the site would constitute unacceptable backland development, are in my view matters of development control.
R@cogpgeJMlatigp
11 4.27.8 I recommend no change to the allocation of this site as a consequence of these objections.
Written Objections Hos 30-32, 211 (part) am! 217
4.28.1 The objections were made by Mr P C Cox, J J Barker (Southfleet) Ltd, Mr J D Tremlett, Mr E Huxley and Mr M Gedney. They concerned four possible sites for housing development at Southfleet.
Summary of Objections
4.28.2 More housing was needed in order to maintain the viability of the village services, and to maintain its social existence.
47 4.28.3 A site to the west of Brcrl:e£ield Road, and a site to the east of Red Street should be allocated for housing. Each site had good access, and development of them would make good use of poor quality agricultural land which was surplus to need.
4.28.4 The site at Rectory Meadow allocated for a school, should be re allocated for housing, as it had been allocated for educational purposes for the last 25 years and was now unlikely to be required for a school. The site would be suitable for executive housing as it was already alongside the existing new housing development and could use the existing access.
4.28.S The farmyard at Chapter Farm should be allocated for housing, as it was redundant following the amalgamation of two farms in the 1970s. The site would make an excellent small development without taking open land or extending the village confines.
The Council's Response
4.26.6 The sites to the west of Brql;efield Road and to the east of Red Street lay outside the village confines and were in open countryside. In neither case would the development comprise infilling of a narrow gap within a substantially built-up frontage. The surrounding countryside was designated Green Belt, and performed the function of safeguarding the surrounding countryside from further encroachment. The surrounding land was also designated as an Area of Special Significance for Agriculture, and development of either site would be contrary to Local Plan Policy C6.
4.26.7 Kent County Council as the education authority, had confirmed their view that the site at Rectory Meadow should continue to be safeguarded for educational purposes. Furthermore, while residential development would extend the built form of the settlement, thereby encroaching on the countryside in the Green Belt contrary to PPG2, a primary school would be acceptable as an institution standing in extensive grounds.
4.28.6 The farmyard at Chapter Farm was a complex of agricultural buildings which lay beyond the built-up frontage and confines of the village. Residential development of the site would create a visually intrusive extension of the built up area into the open countryside forming part of the Green Belt.
4.26.9 The development of any or all of the objection sites would make little difference to the level of services which the village could support.
Conclusions
4.28.10 In my opinion both the site on Brake £ield Road and that on Red Street would extend the existing built-up area into what is currently open countryside within the green belt. The land to the east of Red Street is in agricultural use and forms part of the rolling countryside to the east. BrOlke,field Road narrows at the limits of the existing housing and along the front of the objection site has the character of a country lane, with a hedge and bank along the site frontage. The site forms part of a large agricultural field with well estab lished trees and hedges. In my opinion development of either of these sites would be visually intrusive, and would extend the built up area into the countryside.
4.26.11 I can find no circumstances in this case to override the view of the education authority that ·the site should continue to be safeguarded for a possible future school, though I note that the project is not in any capital programme. Should the site not be required for school purposes, I would not regard it as suitable for residential development. The existing footpath along 48 the northern boundary of this site forms a natural boundary between the built-up area and the open countryside to the south which forms part of the Green Belt, and which permits extensive open views to the south.
4.28.12 The buildings at Chapter Farm lie to the rear of a detached dwelling on the edge of the village. They are of a rural character and I consider that their replacement by new housing would introduce a suburban character to the edge of the village. 1 4.28.13 I can therefore find no exceptional circumstances to warrant removal of any of these sites from the Green Belt.
R@co""'"'™'4tion
4.28.14 I recommend no change to the allocation of any of these sites as a consequence of these objections.
Written Obiection No 33
4.29.l The objection was made on behalf of the Hawkins Trust, and concerned land at Main Road, Sutton-at-Hone.
Summary of Objection
4.29.2 The objection site should be allocated for housing as there was an identified requirement in the plan for additional housing in the village. The site provided an opportunity for infill development, and would be suitable for low density housing for which a need was identified in the plan.
The Council's Response
4.29.3 The site was within the green belt and performed the functions of ,-_: safeguarding the surrounding countryside from further encroachment, and preventing neighbouring towns from merging into one another. Furthermore, any development of the site would be contrary to the expressed aim of the structure plan which was to curb the growth of, and preserve the separate identities of, settlements in the area between Dartford and Swanley, and in the Darent Valley north of Eynsford.
4.29.4 Residential development of the site would be unrelated to any settlement and would intrude into a rural area adjoining the Darent Valley Policy Area wherein under Policy ClO, priority was to be given to landscape, conservation and recreation factors.
4.29.5 The site also lay within an Area of Special Significance for Agricul ture, and residential development would be contrary to Local Plan Policy C6.
Conclusions
4.29.6 Whilst there is a small residential estate on the opposite side of Horley Road, development on the west side of the road either side of the objection site is of a sporadic nature. A short distance to the north is the A2 Trunk road, and the main settlement of Sutton-at-Hone lies some distance to the south. There is some development along the western side of the objection site, but I would not regard residential development on the site as infilling of a small gap within an otherwise continuously built-up frontage. In my opinion it would consolidate the development in the locality.
49 4.29.7 Hawley Road (A225) runs through generally open countryside which is designated as green belt between the edge of Dartford and the settlement of Sutton-at-Hone. It skirts the eastern edge of Hawley but its open character is interrupted by frequent groups of small developments. Development on the objection site would reduce still further the road's open nature. I can find no r special circumstances for removing this land from the Green Belt and allocating it for housing development.
Recrnmpendation
4.29.8 I recommend no change to the allocation of this site as a consequence of this objection.
Written Objection No 34
4.30.l The objection was made on behalf of T G Baynes and Sons, and concerned land at Barton Road, Sutton-at-Hone.
Summary of Objection
4.30.2 The site should be included in the village confines, having been formerly identified as suitable for housing in an earlier council study. Other sites in the plan were unlikely to become available in the plan period, and there was a shortage of identified village sites; no other land had been identified for development in Sutton-at-Hone. The site was well contained by the topography and by existing development, and was well serviced with a good vehicular access. The site was of limited extent, and of a shape which made its potential for farming very low.
The Council's Response
4.30.3 The objection site lay beyond the village confines and within the Green Belt where it performed the function of safeguarding the surrounding countryside from further encroachment. It was within an area identified in the approved structure plan as one where the aim was to curb the growth of, and preserve the separate identities of, settlements in the area between Dartford and Swanleigh, and in the Darent Valley north of Eynsford.
4.30.4 The site and its surroundings also lay in an Area of Special Signifi cance for Agriculture, and development would be contrary to Local Plan Policy C6. The objection site was contiguous with other open farmland.
Conclusions
4.30.5 The objection site comprises a large grass field with a few trees. It adjoins existing housing on its eastern and south-eastern boundaries, from which it is separated by a footpath. To the north and west however is open land and in my opinion development of the objection site would represent an extension of the village into open countryside. I can find no special circumstances in this case to warrant the removal of the site from the Green Belt in order to allocate it for residential development.
hcg=tJtmdetion
4.30.6 I recommend no change to the allocation of this site as a consequence of this objection.
50 Written Objection No. 37
4.31.l The objection was made on behalf of Mrs ME L Inniss, and concerned land at Stock Lane, Wilmington.
Summary of Objection
4.31.2 The site should be removed from the Green Belt and allocated for housing as it was of little agricultural value and subject to trespass. A suitable access could be made available, and improvements to the road system would produce a planning gain. The site was bounded on two sides by housing and a school, and was of little landscape value. Several sites identified in the local plan for housing were unlikely to come forward for development, and this would be a suitable replacement for them.
The Council's Response
4.31.3 The site comprised open land beyond the built-up area, and was situated in the Green Belt. It performed the functions of checking the unrestricted sprawl of large built-up areas, safeguarding the surrounding countryside from further encroachment, and preventing neighbouring towns from merging into one another.
4.31.4 Development of the site would be contrary to one of the aims of the approved structure plan which was to curb the growth of, and preserve the separate identities of settlements in the area between Dartford and Swanley.
4.31.5 The objection site also lay within an Area of Special Significance for J Agriculture, and was contiguous with other open farmland. At present part of the • site was used for grazing. Development of the objection site would be contrary to Local Plan Policy C6.
Conclusions
4.31.6 Part of the objection site is wooded and the remainder forms a paddock. There is some evidence of fly-tipping. On the Proposals Map the boundary of the Green Belt lies along the western and northern boundaries of the objection site which are defined by a bridleway and the school respectively. I regard these as logical and defensible boundaries for the Green Belt. In my opinion, the objection site relates well to the countryside to the south and east, and I can find no special circumstances for removing the site from the Green Belt and allocating it for residential development.
Recorreendation
4.31.7 I recommend no change to the allocation of this site as a consequence of this objection.
Qbiection no. 38 Representation No.51
4.32.l The objection was made on behalf of the Archdiocese of Southwark, and related to land east of Orchard Way, Wilmington.
Summary of Obiection
4.32.2 The land should be removed from the Green Belt and allocated for housing for the following reasons: 51 1. the site was a self-contained area of 1.35 ha; Id 2. the site contributed little to the Area of Special Significance for Agriculture, and its development would not harm this interest; 3. the land was bounded on two sides by development, and contributed very little to the countryside or the wider Green Belt; 4. the land had good access; g 5. the local plan ·recognised a need for additional land to be made available for new housing; 6. the site was more appropriate for the expansion of Wilmington than Site Hl(A4); 7. the site was more appropriate to meet the Council's objectives of providing low density housing than other allocated sites; 8. the minimum separation distance from Wilmington to Swanley and Hawley would not be affected.
The Council's Response
4.32.3 The objection site was part of the countryside, and satisfied the purposes of the Green Belt in PPG2 and Structure Plan Policy MGBl, in that it checked the sprawl of the built-up area, safeguarded the countryside from encroachment, and prevented neighbouring towns from merging with one another.
4.32.4 Wilmington Parish Council supported the inclusion of the objection site within the Green Belt.
Conclusions
4.32.5 At present the northern boundary of the Green Belt in this area extends to the rear of residential development along High Road and in Langworth Close; there is a row of 6 bungalows along the west side of Orchard Way, and a school off Stock Lane within the Green Belt. Most of the boundary is defined by a public footpath.
4.32.6 I consider that the objection site is seen as part of the countryside, though being well treed it has different characteristics from the adjoining paddock and agricultural land. Its use for housing would lead to the loss of trees, and I find it difficult to envisage that the presence of housing could be concealed, especially as tall dense trees along the southern boundary would shade any properties.
4.32.7 The objectors' proposal would extend the boundary of the built-up area to include the objection site and the bungalows along Orchard Way, leaving areas of open land on each side of the objection site. In my opinion these two areas would be vulnerable to development pressures being relatively small areas enclosed by development on three sides. They would make little, if any, contribution to the purposes of the Green Belt, and I do not consider that the suggested Green Belt boundary would be defensible. The result could be a significant extension of development into the countryside, consolidating that development to the south-west of the A2 trunk road in the area between Dartford and Swanley which is specifically identified for protection in Structure Plan Policy MGBl.
4.32.8 I can see no special circumstances to justify removal of the objection site from the green belt.
&egg=endation
4.32.9 I recommend no change to the allocation of this site as a consequence of this objection. 52 Written Objection No· 39
4.33.1 The objection was made on behalf of the owners of land at Hawley Road, Wilmington.
Summary of Objection
4.33.2 The site should be excluded from the Green Belt and allocated for housing as there was insufficient housing land available elsewhere; in particu lar, Darenth Park Hospital shouild not be allocated for housing. The site was isolated from other farmland by the A2 trunk road, and its boundaries were well defined, Access would be readily available and the land was within easy reach of the town centre. There was a need for low density housing which could be provided on the site, and social housing could also be provided.
The Council's Response
4.33.3 The site lay beyond the built-up area, and lay within the Green Belt where it performed the purposes of checking the unrestricted sprawl of large built-up areas, and safeguarding the surrounding countryside from further encroachment. It also served to prevent neighbouring towns from merging into one another.
4.33.3 The eastern edge of the site was not defined by any clear and defensible boundary, and if developed, there would be pressure to develop the remainder of the land to the east.
4.33.4 The site also lay in sn Area of Special Significance for Agriculture, and development would therefore be contrary to Local Plan Policy C6. The site was connected with other agricultural land to the south by way of a farm track and bridge over the A2.
Conclusions
4.33.5 The site forms part of a larger field which rises towards the south. and is in arable agricultural use. There is a public footpath behind houses along the western boundary of the site, and this forms the boundary of the Green Belt. In my opinion the path is a logical and defensible boundary for the Green Belt.
4.33.6 Although the site is opposite a trading estate, it forms the start of the open land along this side of Hawley Road. Despite the presence of two modern dwellings in the north-east corner of the objection site, which I regard as sporadic development, I consider that development on the site would extend the built-up area into the countryside. I can find no special circumstances in this case to remove the land from the Green Belt and allocate it for housing.
Rgsgmmepdetion
4.33.7 I recommend no change to the allocation of this site as a consequence of this objection.
Written Objections Nos 40, 41
4.34.l The objections were made by Mr T Wilson and Mrs AS Wood concerning land at Longfield Hill.
53 Summary of Objection
4.34.2 The proposed Green Belt boundary was illogical, and should be modified to follow the borough boundary. The land was derelict and if retained in the Green Belt would continue to be used as a rubbish dump. The objection site was the only parcel of developable land.within the village and a modest well planned scheme would be the most practical solution to a problem piece of land.
The Council's Response
4.34.3 The site performed the Green Belt functions of checking the unrestricted sprawl of large built-up areas, and of preventing neighbouring towns from merging into one another.
4.34.4 Development of the site for housing would not relate satisfactorily with the village and would create an attenµated layout. There were also highway objections to housing development on the site.
Conclusions
4.34.5 The merits of retaining this site within the Green Belt are discussed in Chapter 6.
4.34.6 Whether a satisfactory form of residential development, including a satisfactory means of access, could be provided on the objection site is in my view, a matter for development control and not for the local plan. Nevertheless, the site does not appear to me to be a natural housing site, and I do not consider that it should be allocated for housing within the local plan. Any proposals for housing or other forms of development, should be considered on their merits.
Reco•epdation
4.34.7 I recommend no change to the allocation of this site as a consequence of this objection.
Qbjection No.171
4.35.1 The objection concerned the former Dartford Gun Club site. It appears to me that the main issue in this objection relates to its location in the Green Belt. I have therefore considered it in Chapter 6, together with Objection No.18.
54 OBJECTION CONCERNING OTHER SITES NOT ALLOCATED FOR HOUSING
Written Objection No 35
4.36.l The objection was made on behalf of Blue Circle Properties Ltd, and concerned land at Craylands Lane, Swanscombe. The objection also relates to Policy RT16, and is referred to in the council's response to Objection No.19 in Chapter 3.
Summary of Objection
4.36.2 The southern part of the objection site should be allocated for housing to offset the cost of restoration, as the cost of restoring damaged land made open apace use unviable. Housing could also improve the raw edge of the settlement.
The Council's Response
4.36.3 The long-term development potential of this site was recognised, and changes were proposed to Policy H5, and a new Policy APl was commended.
4.36.4 The objector's solicitors had confirmed that on the basis of the commended change, there was no difference between them and the council.
Conclusions
4.36.5 The proposed new policy APl would overcome the objection, though the owners wish to consider the development of the site within the plan period. In my consideration of Objection No.C4 in Chapter 9, I have recommended an amendment to Policy APl affecting this objection site. I consider that my proposed amendment would also meet the main thrust of this objection.
4.36.6 Reasons for supporting the proposed new policy are given in my consideration of Objection No.19 in Chapter 3. I Recomm@Matign
4.36.6 I recommend that:
1. A new paragraph and policy be added following Policy H5 in accordance with commended change No.16, as modified by commended change S5 and by my recommendation on Objection No.C4 in Chapter 9;
2. The Proposals Map be modified in accordance with commended change No.73 as modified by my recommendation on Objection No.C4 in Chapter 9;
3. Policy Hl be modified by the inclusion of land east of Craylands Lane.
Written Objection No 36
4.37.1 The objection was made by Kent County Council and concerned Swanscombe Secondary School. The extent of the objection site had been reduced prior to the inquiry, and the area of land shown on the Local Plan as being within the Green Belt, no longer formed part of the objection.
55 Summary of Objection
4.37.2 The school was surplus to requirements and should be allocated for housing.
The Council's Response
4.37.3 The school buildings lay within the built-up area, and proposals for its redevelopment would be judged against the general policies within the plan.
4.37.4 The Council were not aware of any feasibility study having been carried out in the light of the school closure decision, as to the suitability of the site for any particular main use or uses. In those circumstances, it was preferable to consider proposals on their merits rather than make a specific land use allocation for the site.
Conclusion
4.37.5 The absence of any designation for the site does not appear to preclude its development for housing purposes, and I agree with the view that it is preferable to maintain a flexible approach to development of the site, which may permit uses other than housing but which would recognise its proximity to residential development.
R@snmmewJation
4.37.6 I recommend no change to the allocation of this site as a consequence of this objection.
56 COMMENDED CHANGES
COMMENDED CHANGES NOS 16 AND 73
4.38.1 The commended changes would introduce a new Policy APl.
Written Objection Np Cl
4.38.2 The objection was made by the Kent Trust for Nature Conservation.
Summary of Objection
4.38.3 The Swanscombe Marsh was originally grazing marsh and until agricultural and industrial activities took hold, was of high wildlife value. Nature conservation was an important element, and should be referred to in the policy or preamble. The policy area at Ebbsfleet also included land of high wildlife value. A similar caveat should be attached to this site also.
Written Objection No,C2
4.38.4 The objection was made by Swanscombe and Greenhithe Town Council. Objection No.C4 is considered in Chapter 9.
Summary of Objection
4.38.5 The proposed development would generate additional traffic. A number of dwellings in that area had been provided for elderly residents.
I Written Objections Nos C3 and CS !' 4.38.6 The objections were made by Councillor Mrs D Ash-Smith.
Summary of Objections
4.38.7 As a consequence of change no 16, RT16 was also modified by change No.48 to delete the land east of Craylands Lane.
4.38.8 The land east of Craylands Lane should not be developed, because Craylands Lane was a narrow lane, and not suited to the heavy traffic such a development would generate. It was not clear what type of development was going to be situated in what was a green area. Swanscombe and Greenhythe needed a green area to enjoy. Apart from the loss of one of the few remaining green areas, commended changes to the transport policies inserting the objective to seek or reduce increases in car borne traffic by careful attention to both the siting and detail of new development. Development east of Craylands Lane would be contrary to that policy.
The Council's Response
4.38.9 The Council had accepted that these sites identified in Policy APl may have a potential for development in the longer term, when the strategic implications had been fully considered. Because of the lead times necessary for any major infrastructure provision, this potential should be recognised in the plan, and a new policy and preamble had been put forward as part of Commende~
57 I I Change No 16. The policy made it clear that the development of these areas may need to be associated with major infrastructure improvements; this woUld include access.
4.38.10 The policy also referred to the council's willingness to be involved in studies to examine the development potential of these areas in more detail. Any development in these areas would be subject to the development control process, and proposals would be judged against the relevant national and county guidance, as well as local plan policies. The public would also be able to make their comments on any formal planning applications.
4.38.11 The possible development of part of the area east of Craylands Lane in association with the provision of public access and some public open space, would provide the means to deal with the current poor environmental and visual conditions on this site.
4.38.12 The policy as currently drafted, provided an appropriate level of guidance for the longer term consideration of these areas. In any event, the local plan review process would role forward the development strategy for the borough, at which stage the investigations of the areas' development potential should be available, and the policy could then be revised to provide a greater level of guidance for their development.
Conclusions
4.38.13 While the purpose of a local plan is to guide and encourage development for the period to 2001, in situations where an extensive area such as indicated in Policy APl, is proposed for major redevelopment, I consider that it is appropriate to indicate the possibility of such redevelopment in order to guide the long term planning of the various undertakers and service providers. I therefore support the principle of the policy, which recognises that additional traffic would be generated and that there may be a need for major infrastructure improvements.
4.38.14 Swanscombe Marshes is not identified as a site of nature conservation interest, though I note that some interest has survived the industrial activity on the land. I consider that there is inadequate information on the nature conservation interest at this stage, to make specific reference to it, though it will no doubt be considered alongside other amenity and environmental factors. The impact of the nature conservation interests at Ebbsfleet is discussed under Objection No.305 in Chapter 10.
4.38.15 The land east of Craylands Lane is considered under Objection No.C4 in Chapter 9.
Racn""'D'!etigp
4.38.16 For reasons given under Objection C4 in Chapter 9, I recommend the deletion of land east of Craylands Lane from policy area APl.
58 CHAPTER 5 - RETAILING
BACKGROUND
5.1.1 The Secretary of State has granted planning permission for the development of a Regional Shopping Centre at Western Quarry (Bluewater). It is anticipated that major economic and environmental benefits will arise from the proposal. Despite the inevitable effects of the scheme, it is expected that the prime function of the town centre as a district centre will remain, and should be enhanced.
5.1.2 The stated aim of structure plan Policy RDl is to strengthen the attraction of town centres by (i) improving consumer convenience and the environment, (ii) extending the range of quality and specialist shopping and
services 1 and (iii) generating more residential opportunities, particularly for small households.
5.1.3 Established town or district centres are the preferred locations for large food stores subject to environmental and traffic considerations. If local conditions indicate, other locations would be suitable, consistent with the maintenance of the viability of the town centres, and not being in conflict with other land use, countryside or Green Belt policies,
5.1.4 Structure plan Policy RD3 envisages non-central retail warehouses as complementary to the retailing base of established town centres. They should be operationally convenient, and in locations which have good accessibility.
59 POLICIES
POLICY Rl
Objection No. FO Representations Nos R35 and R36
5.2.1 The objection was made on behalf of J Sainsbury Plc.
Summary of Objection
5.2.2 The policy implied a lessening of the presumption in favour of retail development at locations other than those listed.
The Council's Response ! 5.2.3 The council agreed that the policy should be clarified and recommended a change in the wording. The commended change was accepted by the objectors as meeting their original concern.
Conclusion
5.2.4 I agree that the commended change to the wording of the policy would be an improvement.
5.2.5 For reasons given in my consideration of Objection No.294 in Chapter 9, Knockall Chase should be added to the list of centres.
Recommendation
5.2.6 I recommend that Policy Rl be modified in accordance with commended change No,S21, with the addition of "Knockall Chase" to the list of centres. This requires a consequential change to the Proposals Map.
POLICY R2
Representation No.R37
5.3.1 British Rail supported the policy to which there was no objection. I therefore make no recommendation regarding this policy.
POLICY R3
Written Objection No 183 Representation No 40
5.4.1 The objection was made on behalf of the Halifax Building Society, and concerned the change of use of shops in the existing shopping frontages, to other uses.
Summary of Objection
5.4.2 Whilst supporting the aim of Policy R3, the policy should be re-worded to make it absolutely clear that reference would be had to the criteria set out under (a) to (g) in considering applications. 60 The Council's Response
5.4.3 Sub-sections (a) to (g) of the policy related to matters of fact rather than the setting of standards, and the word "factors" was more appro.priate than "criteria". The suggested amended wording would neither improve the policy nor make it any clearer.
5.4.4 Support for the policy was received from Abbey National Plc.
Conclusions
5.4.5 In my opinion the policy as worded is quite clear, and as no numbers, dimensions or other standards are stated, I do not consider that the word "criteria" would be appropriate in this case.
Written Objections Nos 184 and 185
5.4.6 The objections were made by Lloyds Bank PLC and the Woolwich Building Society.
Summary of Objection No 184
5.4.7 A2 use class businesses provided valuable services which should be viewed as an essential and integral part of every retail centre. Sub-sections (a)-(c) of the policy indicated that the amount of A2 occupiers would be subject to limitations so as to reduce "breaks in retail frontage".
5.4.8 Banks were a retailer of financial services, and consequently preferred to trade from behind a shop front which incorporated as much glazing as possible. The policy should specifically recognise the expansion needs of A2 use class businesses. A2 users already present in a location, should be enabled and encouraged to occupy sufficient accommodation to enable satisfactory levels of customer services to be provided and maintained.
Summary of Objection No 185
5.4.9 An incorrect emphasis was placed on Policy R3 which set out criteria, while failing to explain precisely how any proposals would be judged. Sub paragraphs (d) to (g) should be deleted as they reflected normal development control considerations.
5.4.10 DCPNll acknowledged that A2 uses may often complement existing Al uses in primary retail areas. The Use Classes Order 1987 also noted that many A2 uses justified a shopping street location, where they provided a substantial element of direct service to visiting members of the public. They frequently maintained an attractive and lively window display. Sub-paragraph (a) should therefore be deleted. Sub-paragraphs (b) and (c) reflected in general terms criteria requiring consideration of matters contained within relevant national guidance.
5 ..4.11 Policy R3 should therefore be deleted and replaced by a new policy which would aim to create a balance of uses within Use Classes Al, A2 and A3 of the 1987 Use Classes Order, provided that the proposals whether individually or cumulatively, would not damage the area's vitality and attractiveness.
61 The Council's Response
5.4.12 It was a stated objective of the local plan to foster the vitality and viability of the town centre, and to widen its role and range of facilities. Because of the town centre's compact nature, the council had chosen not to identify primary and secondary areas as provided for in DCPNll.
5.4.13 The policy related specifically to the town centre and to the impact a change of use or redevelopment from retail use (Al) to A2 or A3 uses would have on the town centre. It was appropriate for the policy to set out the factors that would be taken into consideration in such circumstances, and the matters referred to at R3 (d) to (g) were pertinent considerations in dealing with such changes of use. The policy did not have any undue emphasis placed upon it. It was aimed at addressing a real issue and the genuine concern about the future functioning of the town centre, particularly its attraction as a shopping location.
5.4.14 DCPNll stated that it was a matter of judgement for the local planning authority whether or when the overall number of service outlets could reach or had reached a level at which further changes from retail shop use should be resisted. Factors to be considered included not only the number of outlets, floorspace or frontages but also the type of shopping centre, trends in usage and, where known, the views of traders and shoppers. Factors (a) to (c) thus accorded with the policy note. The policy did not make sole reference to numbers of outlets, floorspace or frontages.
5.4.15 Use Class A2 included not only batiks and building societies which helped to stimulate the service trade within shopping centres, but also accountants and solicitors. DCPNll recognised the detrimental impact "dead frontages" could have on shopping centres and suggested the impact of dead frontages could be avoided or reduced by the dispersal of non-retail uses within a shopping centre.
5.4.16 The suggested policy put forward by Objector 185 did not provide any guidance to enable any assessment of what constituted a balance, and whether it currently existed. Neither would it address the issue of the town centre's role as a district retail centre. The wording would also conflict with policy R2 to which there had been no objection and one representation of support.
5.4.17 A Use Class A2 business user had written in support of Policy R3 as worded.
Conclusions
5.4.18 It is the purpose of a local plan to set out detailed policies and specific proposals for the development of use of land, and the policies should guide most day to day planning decisions. The plan should not rely only on national and regional guidance. I therefore consider it correct for the policies in the plan to list those factors against which development proposals will be considered.
5.4.11 The economic importance of non-retail uses is recognised in the preamble to Policy R3, and nothing within the policy would preclude the reasonable expansion of a non-retail business in order to provide a better level of service. The disadvantages of extensive breaks in the retail frontage caused by some types of non-retail business activity are widely recognised. In my opinion, Policy R3 sets out the relevant considerations to be taken into account, without attempting to specify rigid nUlDbers or proportions, thus permitting a flexible approach to be msde to development proposals, and for each case to be considered on its merits.
62 ReGO'P'l'nd•tign
5.4.12 I recommend no change to Policy R3 as a consequence of these objections.
POLICY R4
Written Objection No 186 Representations Nos 41 and 42
5.5.l The objection was made by Blue Circle Properties Ltd.
Summary of Objection
5.5.2 While it was intended that the primary use of the site would be retail, the concept of a regional shopping centre embraced a broader range of complemen tary uses, of the type and nature normally found in a town centre. The inclusion of a range of uses, all complementary to the shopping centre, would assist in broadening the contribution that the scheme could make to the local and wider economy, thus introducing additional vitality to the scheme and local area beyond the attraction of the retail space itself. The preamble to the policy in paragraph 5.3.5 should be amended to reflect this.
The Council's Response
5.5.3 The Council concurred with the view of the objector, and a commended change would suitably amend the preamble. The objector had confirmed by letter that the commended change would meet their objection.
5.5.4 Blue Circle Properties Ltd and Colyer Greenhithe Estate supported the proposal for a regional shopping centre at Bluewater.
Conclusion
5.5.5 The commended change would amplify the nature of the proposed develop ment, by referring to other uses which could be regarded as ancillary to a major shopping centre such as is proposed at Bluewater. I therefore support the commended change.
R@cogqrepr!etion
5.5.6 I recommend that paragraph 5.3.5 be modified in accordance with commended change No 18.
POLICY R6
Written Objection No 187
5.6.l The objection was made by Lloyds Bank PLC, and concerned propos~ls for changes of use or redevelopments at local shopping centres.
Summary of Objection
5.6.2 The policy should specifically acknowledge the expansion needs of A2 businesses. Such users already present in a location should be enabled, and indeed encouraged, to occupy sufficient accommodation to enable satisfactory levels of customer service to be provided and maintained. 63 The Council's Response
5.6.3 It was an objective of the local plan to safeguard the role of local centres in providing convenient shopping and service facilities for local communities. The preamble to policy R6 in paragraph 5.3.7 recognised the importance of local shopping centres to their local communities, both for the retail and for other services they provided, and for the job opportunities they offered. These centres were also under pressure for changes of use and redevelopment proposals which would result in the loss of retail and service provision. A general commitment to accommodating the expansion needs of A2 uses was not seen as necessary or appropriate to the policy. Any particular proposal would be dealt with on its own merits, having regard to the substance and objectives of the policy.
Conclusion
5.6.4 The importance to local shopping centres of both retail and other appropriate services is recognised in paragraph 5.3.7 as a preamble to Policy R6. The policy does not preclude the expansion of service uses unless such a development would adversely affect the economic viability, physical attractiveness or efficient functioning of the centre. I can therefore see no necessity to alter the policy in order to enable improvement to customer service to be carried out where such improvements are in the interests of the local shopping centre and the community it serves.
Objection No.189 5.6.5 The objection was made by J Sainsbury Plc. Summary of Objection 5.6.6 The preamble to Policy R6 implied that planning applications would be considered against economic considerations. It also failed to differentiate shopping centres from other types of commercial centres. The Council's Response 5.6.7 The incorrect emphasis was recognised, and a change was recommended which would overcome the objection. This was agreed, though at the inquiry, the council accepted that "implication" would be a more appropriate term than "impact". of a proposal. Conclusion 5.6.8 I agree that the commended change, with the suggested amendment, would more correctly interpret national policy, and clarify the intention of the policy. 5.6.9 I recommend that Paragraph 5.3.7 be modified in accordance with commended change No.S26, amended by the deletion of the word [impact], and the substitution therefor of the word "implications". 64 POLICY R7 Qblection No. 189 (Rart) arui Written Objection No 188 5.7.1 Objection 188 was made by Town Planning Consultancy, and Objection 189 was made by J Sainsbury Plc, Summary of Objections 5.7.2 Policy R7 did not reflect current government advice as expressed in PPG6, and was overly restrictive. The policy would unreasonably restrict retail warehouse proposals which could otherwise properly proceed when considered against the Government's advice and other policies in the plan. l 5. 7, 3 The policy was inappropriately detailed and unduly restrictive. There was no reason why retail warehousing such as a superstore, should not be permitted in the town centre. The Council's Response 5.7.4 The restrictive nature of Policy R7 was recognised, and a commended change to Policy R7 was recommended which would go some way towards meeting the objection. Nevertheless the general approach to the restriction of further retail warehouse development in specific locations was justified. The approach was consistent with Structure Plan Policy RD3. The aim of Policy R7 was not to stifle competition but to protect the Bluewater site. Conclusions 5.7.5 The commended change to the preamble to Policy R7 contained in paragraph 5.3.8, would remove the potential conflict between the restrictive nature of Policy R7 and the presumption in favour of development contained in Structure Plan Policy RD3. It is therefore supported. 5.7.6 The commended change to Policy R7 would be less restrictive than the policy as worded in the deposit version of the plan, Nevertheless, it would still be opposed to further retail warehousing in the town centre. It is the council's view that there is already adequate provision of retail warehousing in the town centre, and that any increase would adversely affect the town centre strategy which is to encourage office and tourism related developments. They are also concerned that an increase would prejudice the Bluewater scheme. Kent County Council have not considered it necessary to identify any locations in the borough for additional retail warehousing except the Bluewater scheme which would lead to a doubling of retail warehouse floorspace within the borough during the plan period. 5.7.7 I recognise that some of the council's opposition to retail warehouse developments in the town centre related to the appearance of the buildings, and that this could be overcome by better design. Nevertheless, PPG6 refers to the benefits, in particular the traffic benefits, of taking retail warehouses out of the town centre. In the light of the existing provision, I consider it reasonable for the council to restrict further retail warehouses in the town centre, and for this restriction to be included within the local plan policy; this would accord with the intention of the structure plan, In my opinion however, the plan should either specify the "Central Business Area", or define the area to which town centre policies apply. 5.7.8 The objectors consider that it is unnecessary to specify criteria against which planning applications for retail warehousing development would be considered. In their opinion other policies in the plan could adequately be 65 used. Notwithstanding this possibility, it is my opinion that a clear statement of the council's requirements are of assistance to any prospective developer, though I do not consider that the word "justified" in the main text of the policy is appropriate. Developers should not have to justify a proposal, and in my opinion the word "permitted" is to be preferred. 5.7.9 In response to the objectors' reservations about use of the word "prejudice" in the criteria, the council agreed to a rewording of the commended change. I regard the revised wording as acceptable. Recg=m'tttians 5.7.10 I recommend that: 2. Paragraph 5.3.8 be modified in accordance with commended change 518; 3. Policy R7 be modified in accordance with commended change S27, amended by the deletion of the word [justified] and the substitu tion therefor of the word "permitted". 4. The term "Dartford Town Centre" be defined. /: ;' i:\ 66 ABSENCE OF POLICY FOOD SUPERSTORES Objection No.189 Summary of objections 5.8.1 The plan was deficient in that it did not provide policy guidance on the future of food superstores. The policy should be included in the plan, and deal specifically with food superstores. 5.B.2 In reply to the council's response, Objector 190, whilst welcoming the proposed new policy, had reservations concerning its wording. It should be made clear that the criteria were matters for consideration by the local planning authority in order that they may consider the benefits and disadvantages of the proposal as a whole, and that failure to satisfy a particular criterion should not of itself be a reason for refusal of a planning application. The criterion relating to over-provision contravened national planning guidance. The criterion relating to the environmental impact of a proposal was unclear, and went beyond the normal criterion. 5.B.3 Objector 1B9 regarded the commended new Policy RB as loosely defined. The Council's Response 5.B.4 It was accepted that the plan would be improved by the inclusion of a policy for food superstores, and a commended change would propose a new Policy RB. In response to further comments on the commended change, modifications to new Policy RB were commended as a supplementary change. 5.B.5 The aim of recommended new Policy RB was to protect the local shopping centres. Commended changes to the wording would clarify this aim. Conclusions 5.B.6 I agree with the view that a policy on food superstores would be appro priate, and the proposed Policy RB contains the general substance of matters to be considered as part of a development proposal. 5.B.7 Commended changes to the proposed new Policy RB would clarify the nature of the development to which the policy applied, and remove the limitation on floorspace provision. I regard these as necessary modifications to the suggested policy. 5.B.B The commended supplementary change would meet most of the objections raised to the new policy, though the objectors consider that it should apply only to town centres of size and substance. The aim of the policy however, is to safeguard the smaller local centres which the council regard as providing benefits to local communities; they ·and Objector 1B9 agreed that these centres were in need of protection. 5.8.9 In my view the words "shopping centres" adequately describes those centres to which the recommended policy would apply. It is my view that the recommended Policy RB suitably amended, would adequately state the matters against which proposals for large food stores would be considered. 67 ....I 5.8.10 The proposed policy as worded however, suggests that should a proposal fail one of the criteria, it would not be permitted. It does not appear to me that this is the aim of the policy, but that when proposals for large food stores are made, .they will be considered against these matters indicated.• and a decision taken on the balance of benefits and losses. In which case, I consider that a policy written more in the terms of Policy R3 would be appropriate. The policy would then list the factors to be taken into account, and enable a balance to be reached. I therefore propose a further modification to new Policy R8. "somrpdatiQDI 5.8.11 I recommend that: 1. a new section headed "G. Food Su,perstores" be inserted and a new paragraph 5.3.9 be added in accordance with commended change No 19; 2. a new Policy RB be inserted after new paragraph 5.3.9, similar to that described in commended change S20, but describing factors to be taken into account instead of the list of criteria. 68 CHAPTER 6 - THE GREEN BELT BAGKGROIJND 6.1.1 In addition to the general functions of the Green Belt described in PPG2, the structure plan states other specific functions for the Green Belt in Kent. In particular, this part of the Metropolitan Green Belt is to curb the growth of, and preserve the separate identities of, settlements in the area between Dartford and Swanley, and in the Parent Valley north of Eynsford. It also has the function of restricting the expansion of settlements south of the A2 including inter alia, Longfield and New Barn. 6.1.2 The local plan's policies and in particular Green Belt policy, arise in large part from the need to accommodate growth. The Green Belt boundaries in the Dartford area were first established in the Thames-side Town Map of 1958. The boundaries were tightly drawn around the urban area. The North-west Kent Town Map, published in 1972 and approved in 1978, re-drew the inner boundaries even tighter around and into, the urban areas of Dartford and Stone. These boundaries provided no reserves to meet long term development needs. There was limited land available to meet the levels of growth provided for by the Structure Plan Second Review, and to provide the necessary mix of social and cultural facilities. 6.1.3 Policy MGB3 of the structure plan states that the Green Belt boundaries should be reviewed in the local plan, and adjusted to new edges. Land has been spcifically identified at North-east Dartford for future development needs, and in North-west Kent for a Regional Shopping Centre. Elsewhere, minor adjustments may be made to the Green Belt boundaries but there will be no re-definition of structural significance. 6.1.4 Representations [Nos R43, R52 and R53] from the Council for the Protection of Rural England (CPRE) and the Countryside Commission, supported the general thrust of the Green Belt policies. 69 GENERAL EXTENT OF THE GREEN BELT POLICY GBl Written Objection No 191 Representations Nos Rl0.Rl3 Rl4.R44-R50 6.2.l The objection was made by the Department of the Environment, Summary of Objection 6.2.2 The roll-back of Green Belt boundaries appeared to be more than of just local significance, and appeared to go further than anticipated by the relevant strategic context. The Council's Response .(N..jl; the numbers in brackets are site reference numbers as identified in Document DBC No.191.2 Appendix D) 6.2.3 Structure plan Policy MGB3 had removed land at Joyce Green Hospital (3) from the Green Belt, and as a consequence of a decision by the Secretary of State who granted planning permission for a regional shopping centre, known as Bluewater, land at Stone (4) had also been removed from the Green Belt. Policy TS2 removed further land to the east of the Dartford Tunnel approach at Stone Marshes (2); this was removed in the 1980 structure plan. Representations [Noa RlO, R45 and R50] from The South East Thames Regional Health Authority (SETRHA), Blue Circle Properties Plc and Dartford and Gravesham Health Authority (DGHA) supported the removal of sites (3) and (4) from the Green Belt. 6.2.4 The report of the structure plan EIP had recognised the possibility of the release of land from the Green Belt in North Dartford south of the line of the North Dartford Bypass, in order to meet essentially local needs (2); the land was required for possible future expansion of a major local employer. The ensuing Green Belt boundaries left areas of land at Bow Arrow (5), St James Lane Pit (6) and Stone Castle (7) as land within the urban area rather than comprising part of the open countryside. These areas did not perform any of the Green Belt functions, and they had therefore been removed from the Green Belt. Their removal from the Green Belt was suported by Representations [Nos R46, R47 and R49] from Colyer Greenhithe Estate and SETRHA. 6.2.5 Areas which formed parcels of land in the urban area, or which comprised the built-up confines of villages within the predominantly rural area south of the A2 trunk road (8-32), had been excluded from the Green Belt as they did not contribute to the Green Belt functions. A further triangle of land at West Dartford, which was entirely contained by railway lines (33), and had development to the north and the south had also been excluded from the Green Belt as it performed none of the Green Belt functions. 6.2.6 An area of land at Bexley Hospital (34) had been deleted from the Green Belt and allocated for housing as it did not perform any of the Green Belt functions. For similar reasons, land on the north side of Edwin Road, Wilmington (35) had also been deleted from the Green Belt, and allocated for housing. 6.2.7 Central Park (36) lay immediately to the south of Dartford town centre and was a valued local amenity within Dartford's urban structure. Other policies in the plan provided for its protection, but it did not fulfil any of the Green Belt functions, being set within the urban area and divorced from the open countryside abutting the southern side of the town. It had therefore been deleted from the Green Belt. Brooklands Lakes and the surrounding land were 70 separated from Central Park by Princes Road, but together with Central Park they made up a tongue of open land stretching into the core of the town centre. Nevertheless, they lay within the urban area, and were effectively defined and contained by built development. The land was isolated from the open countryside to the south by the Dartford Trade Park, and the land did not fulfil any Green Belt function. 6.2.8 Land to the south of Princes Road (38) had also been removed from the Green Belt. It currently comprised the buildings and grounds of the Leigh City Technology College and a trade park, and an area used for sports and recreational purposes. There was an acknowledged lack of indoor sports provision in Dartford and it was proposed to erect such a facility on the area currently used for sports and recreation. There was also a need for a major hotel development in the locality, and the western portion of this site was allocated for such a use. It was considered that the nature of the indoor sports provision envisaged for the site would fall beyond that which could be accommodated within the terms of PPG2, and taken together with the existing use of the site, would provide exceptional circumstances justifying the removal of the site from the Green Belt. Taken together with land to the west which adjoined the Dartford Trade Park (39), and which was required for its expansion, the two sites marked the transition from the urban context of the land to the north to the open countryside to the south. The removal of these two areas from the Green Belt would thus form a defensible boundary of the Green Belt in the long term and accommodate the current needs of the Borough. Representations [Nos R44 and R48] from Allied London Properties and Forte UK Ltd supported the removal of these sites from the Green Belt. 6.2.9 The triangle of land to the north of Bean (37), known as the Bean Triangle, lay between the A2 trunk road and Watling Street, the former line of the A2. When determining an application for a motel on the western part of the land, the Secretary of State had agreed with the Inspector's conclusion that the site made no significant contribution to the Green Belt area as a whole whereas there was a need in the area for more tourist facilities of the type proposed. The land was isolated from its surroundings by the highways defining its boundaries. The local plan proposed that the eastern and western parts of the site be identified for mixed developments incorporating facilities and accommoda tion related to the A2, while the central section would be shown as a protected woodland. The proposed development of this site and its removal from the Green Belt, was supported by Representations [Nos Rl3 and Rl4] from A Winchester & Sons, and from Mount York Properties Ltd. 6.2.10 As part of the general redetermination of Green Belt boundaries, five small parcels of land at Heathside, Downs Farm, Swanscombe and Longfield were added to the Green Belt. Conclusions Sites 1-4 6.2.11 The land at Stone Marshes (1) was excluded from the Green Belt in the 1980 structure plan, and comprises the Crossways development. The site of Joyce Green Hospital together with land to the east as far as the Dartford Tunnel Approach Road (3) is explicitly referred to in the currently approved structure plan as land to be excluded from the Green Belt in order to permit redevelopment. With the possible exception of land at the western end of the Joyce Green Hospital site [see objection 192 below], I consider that these two sites are correctly excluded from the Green Belt. Similarly in view of the extant planning permission on the western quarry site (4) known as the Bluewater Regional Shopping Centre Development, this site should also be excluded from the Green Belt. 71 ... 6.2.12 The panel reporting on the Examination in Public of the Second Review and Alterations to the Structure Plan did not reach a unanimous view on the boundaries of the Green Belt in North Dartford. Those members of the panel proposing removal of land from the Green Belt in North Dartford, recognised however, thst it would be appropriate in the local plan for minor changes to be made to the Green Belt boundaries in order to meet essentially local needs. That part of Dartford Fresh Marshes south of the northern bypass (2) adjoins land owned and operated by the Wellcome Foundation who are the major employer in the area. In a constantly changing market, their future expansion needs are difficult to predict, but this land would be the only land available for them to expand their activities. The area proposed to be deleted from the Green Belt extends as far as the northern bypass which in my view would form a defensible boundary of the Green Belt. The land has acknowledged nature conservation interest, and the relevant policy for the site provides for the management of the nature conservation interest and for the provision of a landscaped buffer. I consider that the special circumstances of this site, and the construction of the new northern bypass, justify exclusion of this land from the Green Belt. Sites 5-7 6.2.13 The area of land to the west of Stone identified as Bow Arrow (5) is allocated on the Proposals Map for major recreational, leisure and associated development. It is currently mainly open land, comprising a restored former mineral workings site. It contains a rifle range and other minor recreational uses. The open site is. however, divorced from open countryside, being enclosed by Stone on the east and the edge of Dartford on the west. To the south is residential land and to the north is the new crossways development. I do not consider that the land fulfils any of the Green Belt functions, and should therefore be excluded from the Green Belt. 6.2.14 To the south, area 6 is an irregular L-shaped area comprising recreation ground laid out to playing fields, and a disused quarry with vertical sides some 35 m deep. The pit is subject to local plan Policy DL2 which states that it is regarded as a priority site for restoration using inert materials only. The site is statutorily derelict. Most of the site boundary abuts residential develop ment, and part of the site will be adjacent to the Bluewater Regional Shopping Development. In my opinion the site performs none of the stated purposes of the ,. ·1 Green Belt, and Watling Street along its southern boundary would in my view form ~ a defensible and logical boundary for the Green Belt. I thus support its deletion from the Green Belt. 6.2.15 Area 7 comprises reclaimed open land, and a research laboratory. The reclaimed land is subject to Policy DL3 which encourages additional treatment in order to complete the restoration to an acceptable standard. From near the centre of the site development can be seen to the south-west, the north and the east, and to the south is the site of the approved Bluewater Shopping Develop ment. I do not consider that retention of the site within the Green Belt would serve any of the Green Belt purposes. Along the eastern boundary of the site is a steep bank with trees, beyond beyond which is open land. In my opinion this feature forms a natural and defensible Green Belt boundary. Sites 8-32 6.2.16 The previous Development Plan, the North-west Kent Town Map, showed many of the hamlets and villages in the rural areas washed-over as Green Belt, and building development in the form of infilling within the confines of the present built-up areas, was permitted in specified villages. The current plan deletes the built-up area of villages and the periphery of the town, from the Green Belt. In my opinion this is to be preferred, as the limits within which 72 development can take place are therefore identified. In general the limits are tightly drawn around the built-up area. These areas are located at Bowmans Road (8), Chastilian Road (9), Maypole (10), Birchwood Road West (11), Layton Cross Road (13), Broad Lane (15), Orchard Way (17), Hawley Road (19), Hawley (20), Old Rectory Estate (21), Lane End (23), Green Street Green (25), Bean (26), Swanscombe School excluding the playing fields (27), and Fawkham Road, Longfield (30). I am satisfied that none of these built-up areas performs any of the Green Belt functions, and can be deleted from the Green Belt without harming its effectiveness, and that the ensuing boundaries will prevent the further erosion of the Green Belt by development spreading from the villages or built-up areas. A further built-up area at Longfield Hill (32) should also be removed from the Green Belt, but the establishment of the north-eastern boundary is considered under Objections 199-209 below. 6.2.17 Land within the highway at Barn End Lane (14) has also been removed from the Green Belt, as have the existing school complexes at Stock Lane, Wilmington (16) and Longfield Upper School (31). In my opinion removal of the highway land is a logical realignment of the Green Belt boundary. I therefore support its deletion from the Green Belt. School sites can be regarded as appropriate development in the Green Belt, and the council have taken the view that where they are attached to a built-up area it would be appropriate to delete them from the Green Belt. In the long term however, should the schools ever become redundant, subsequent redevelopment of the sites could well extend the built-up area into the Green Belt. At Swanscombe (27) the buildings have been severed from the school playing fields which are to be retained in the Green Belt, and the removal of the buildings from the Green Belt would in my view be appropriate. A logical and defensible boundary exists between the playing fields area and the built-up part of the school. At Stock Lane and Longfield Upper School however, I would regard any redevelopment of the school sites as extending the built-up areas into the countryside. In my opinion therefore, the school site at Stock Lane (16) and at Longfield Upper School (31) should be retained within the Green Belt, and the Proposals Map modified accordingly. 6.2.18 An area of land on Hedge Place Road, Stone (24) has also been deleted from the Green Belt and allocated for housing under Policy Hl (A7). This is an elongated area of land bordering the site of the Bluewater Retail Development on two sides, and faces residential development on the other two sides. Given the deletion of other land from the Green Belt, it is isolated from other open land, and performs no Green Belt function. The site is separated by a steep bank from the land allocated for the Bluewater Retail Development, and is related more to the residential development on Hedge Place Road. In my opinion this site does not perform any of the Green Belt functions, and its deletion is justified. 6.2.19 Other areas to be removed from the Green Belt at Birchwood Road East (12), Garden Place (18), Sutton at Home (22), Betsham (28) and Southfleet (29) are the subject of site specific objections, and are considered below under the relevant objection number. Further sites at Hawley, Lane End and Bean are allocated for residential development under Policy Hl (A9), (All), (Al2), (Al3). They generally round-off existing development, and assist in the provision of a range of housing types as provided for under housing objective 4.2.l(d). I do not consider that their development would materially affect any of the Green Belt functions described in PPG2 or the structure plan. Sites 33-39 6.2.20 In West Dartford a triangular area of land entirely contained by railway lines (33) has been removed from the Green Belt. To the west is the Cray Valley which forms part of a relatively small tongue of Green Belt separating Dartford from Crayford. The site has been used for allotment gardens, but much of it is currently overgrown. To some extent, the value of this land in performing its 73 .... Green Belt function bas been reduced by the recent residential development and a sctlool to the north, but in my opinion the limited extent of Green Belt in this area is such that the deletion of a relatively small area, albeit enclosed by railway lines, has the effect of reducing the separation between the two built-up areas. While I consider that the site makes only a small contribution to the overall aims of the Green Belt, it is open land being used for purposes appropriate in the Green Belt, and adds to the already small area of Green Belt in this locality. I can find no exceptional circumstances to warrant its deletion from the Green Belt. 6.2.21 Land south-west of Bexley Hospital (34) is also shown on the Proposals Map as being deleted from the Green Belt and allocated for housing under Policy Hl (A3). My conclusions on this are stated under Objection No 43 et al in Chapter 4, and I consider that the site should be retained as Green Belt. 6.2.22 The merits of deleting land (35) which is allocated for housing under Policy Hl (A4) is considered under Objection No 68 in Chapter 4. In my opinion the site can reasonably be deleted from the Green Belt as it performs none of the stated Green Belt functions. Such a consideration however, applied to a part of an area of land from which it is not physically separated, casts doubt on the suitability of the remainder of the land, designated for recreational use under Policy Rl8, as Green Belt. 6.2.23 The land containing Central Park and Brooklands Lakes (36) is in my view well within the urban area of Dartford. It comprises public and private open spaces within an urban area rather than open countryside. It is a valued recreational area, and the plan allows for its extension, but I do not consider that it performs any of the Green Belt purposes, and in my view its deletion from the Green Belt would be appropriate. 6.2.24 Much of the area of land containing the Leigh City Technology College and a trade park together with Council owned recreational grounds (38) is relatively open, and contributes to the open character of the land south of Princes Road. It has been removed from the Green Belt on the Proposals Map, and allocated for recreational and tourist purposes under Policies RT2 and RT8. Some of these uses may be regarded as appropriate in the Green Belt, but they will be associated with the town which extends to the north side of Princes Road. 6.2.25 The level of activity associated with the proposed indoor recreational facility may exceed that which would be appropriate within the Green Belt. The need for such a facility has been recognised by inter alia, the Sports Council, I and in my view such a facility would be necessary in the town given the extent of I house building proposed in the plan period. It is unlikely that such a development could take place elsewhere within the existing built-up area, and I consider that the circumstances of this case are such as to warrant removal of I this area of land from the Green Belt to meet a particular local need. The site ! is enclosed on the north and east sides by existing development, and part of the western boundary is opposite what is currently the main trading estate in the town; the rest of the western boundary faces an area for the proposed extension of the trading estate under Policy ES. The southern boundary of the site adjoins woodland protected under Policy Cll, which in my opinion forms a natural and defensible boundary of the Green Belt, there being open countryside to the south. 6.2.26 The land west of Darenth Road which adjoins the existing industrial estate on its northern and western boundaries (39) is proposed for Bl development within a well landscaped setting; a landscaped buffer zone is proposed under Policy B4. It is also proposed that the southern boundary of the site will be defined by a proposed new service road from an improved Darenth Road. The site currently comprises some commercial development in the northern part of the site, and an equestrian centre. While I consider that the site currently performs a 74 Green Belt function, its value would be significantly reduced by the removal of the land to the north and east from the Green Belt, The proposed link road along the southern boundary would form a logical and defensible boundary for the Green Belt, and as the site would no longer perform any Green Belt function, I consider that its removal from the Green Belt is justified. 6.2.27 The combined effect of the council's proposals is to delete a signifi-· cant area of land to the south of Princes Road from the Green Belt (Areas 38, 39 and part of 36). Collectively these sites perform a Green Belt function in restricting the spread of development into the countryside. Some of the proposed uses of the land would be open space uses, but there would undoubtedly be an extension of the built form of the town into land which is currently Green Belt; in particular the industrial estate would be expanded and the sports ground which is currently an open use, would contain an hotel and a substantial indoor sports facility. Nevertheless, the gaps between the main built-up area of Dartford and the settlements to the south would not be reduced by the proposals for this land; in my opinion, they can be regarded as rounding-off the built-up part of southern Dartford. The resulting Green Belt boundary if reinforced by landscaping in the ES policy area, would be a belt of protected trees separating the developments from the open countryside to the south. 6.2.28 The area of land to the east of Dartford known as the Bean triangle (37) was the subject of a planning appeal in 1976, when the Secretary of State determined that the site made no significant contribution to the Green Belt area as a whole. There was on the other hand, a recognised need for more tourist facilities having regard to the site's location alongside the A2 trunk road. Currently the site comprises a transport cafe and a derelict petrol station; the majority of the HGV parking takes place on Watling Street, this part of which forms an eastbound access onto the A2.trunk road. 6.2.29 The most prominent part of the site is proposed to remain as protected woodland, and mixed developments of business and hotel or other tourist facilities, are proposed on the remainder under Policies E6 and RT8. A car/coach interchange is also proposed under Policy T9(d). 6.2.30 In my opinion the site makes a significant contribution to the Green Belt, being surrounded on all three sides by open land designated as Green Belt. While this differs from the view taken by the Secretary of State, on the advice of the Inspector, in 1976, it is my opinion that current circumstances are somewhat different. At that time, Green Belt boundaries were tightly drawn, and the Inspector who was considering the site in isolation, took into account the appearance of much of the site, and recognised an overriding need for tourist related facilities. He also concluded that any such facility in this general area would almost certainly lie in the Green Belt. Some of those circumstances have not changed, but in reviewing Green Belt boundaries in a wider context, I consider that the exclusion of this island site, and its possible development, would reduce the effectiveness of the surrounding land in performing its Green Belt function. I therefore conclude that it should be retained within the Green Belt. 6.2.31 Under my consideration of Objections 18 and 171 below, I have recommend ed a modification to the local plan, which would take account of improving the contribution a site such as the Bean Triangle, could make to the Green Belt 6.2.32 No objection has been made to any of the areas added to the Green Belt on the Proposals Map. These areas are generally small areas of land and arise from redefinition of Green Belt boundaries. 75 Rac~tion 6.2.28 I recommend that the Proposals Map be modified to retain the following areas of land within the Green Belt: a. The existing school complex at Stock Lane, Wilmington; b. The existing school complex at Longfield Upper School; c. The allotment gardens east of Stanham Farm, West Dartford; d. Land south-west of Bexley Hospital designated A3 on the Proposals Map; e. The area known as the Bean Triangle, at the junction of A2 and Watling Street. 'I 76 SITES DELEIED FRQM THE GREEN BELT Objections Nos 80. 81. 88. 94. 107 AND 120 Written Objectipns Nos 73-79. 82-87. 89-93. 95-106 108-119 and 121-126 6.3.l The objections were made by Mr and Mrs Cobb, Mr Cobbet, Mr and Mrs Hurley, Mr Lawrence and Mr and Mrs Travella, concerning land at Birchwood Road, Joydens Wood. The written objections were made by AW Ager, Mr G Andrews, Mrs G Bethell, Mr and Mrs Blew, Mr G W Butler, Mr and Mrs J Capel, Mr J S Carter, Mr GA Dryden, Mr Emery, Mr H Fenton, Mr C L Hill, Mr J Hill, Mr A J Hunt, Wilmington Parish Council, Mrs Nightly, Mr and Mrs P Kilby, Ms G Lamb, Mr D Lane, Mrs P A Lawson, Mr R H F Lee, Mr M Miles, Mrs L J Mitchell, Mr C F Moon, Mr J Nagy, Mr and Mrs M Nicholson, Mr Ormay, Mr Peyto, Mr E Put, Mr and Mrs B V Reed, Mr and Mrs K Rickett, Mr E F Riddles, Mr J H Roberts, Mr J P Rooks, Mr and Mrs A L Sallis, Ms S K Saunders, Mrs A Simmonds, Mr J A Skinner, Mr and Mrs F Skopila, Mr and Mrs R S Small, Ms V M Sith, Mrs E Stevens, Mr R W Strutt, Mr P Sulway, Mr and Mrs P Travella, Mr C A Treble, Mrs E Tuffield, Mr L M Watkins, Miss M Watkins, Mr P Watkins and Mrs B Widley. Summary of Objections 6.3.2 The land designated AS should not be developed for housing, and should remain in the Green Belt because it contributed to the appearance of probably the most attractive road into Dartford, and development on the objection site would harm the character of the road. 6.3.3 The site complied with Green Belt criteria in that it contributed to the separation between built-up areas, and it curbed the growth of the settlement. It also preserved the separate identity of the settlement. The site provided a valuable habitat for wildlife. The Council's Response 6.3.4 A change to the Local Plan was commended, which would delete the housing allocation (AS) on the objection site. 6.3.5 The Green Belt boundaries had last been reviewed 20 years ago, and the structure plan permitted minor revisions to the boundary. The ribbon develop ment along the east side of Birchwood Road including the objection site, was deleted as not performing a Green Belt function. Conclusions 6.3.6 The objection site is not accessible to the public but is highly valued as a local amenity, both for its visual contribution to the appearance of the road, and because it provides a haven for wildlife, in particular to a variety of birds and butterflies. Nevertheless, there is residential development on the opposite side of the road, and to the north and south of the objection site. Behind the site are dwellings associated with adjacent agricultural and horticultural land. The site is therefore enclosed by housing. 6.3.7 While the dwellings behind the objection site can be regarded as acceptable in the Green Belt, taken together with the back gardens of other dwellings, they contribute to the severance of the objection site from the open land to the east. In my opinion, neither the objection site nor the back gardens of dwellings in either direction perform any of the Green Belt functions identified in PPG2 or the structure plan. 77 6.3,8 The objection site it within s residential area designated as an Area of Special Residential Character, and any proposal for development would be assessed against the criteria in Policy H9. These apply higher standards to the control of development than is generally applicable, and they seek to maintain the character of the area. In my opinion, the concerns of the objectors relate more to matters of development control than the strategic objectives of the Green Belt. R•c?P'!'no•tion 6.3.9 I recommend no change to the Green Belt boundary in the vicinity of Birchwood Road. Written Qbjection No 192 6.4.l The objection was made by the London Borough of Bexley, and concerned land west of Joyce Green Hospital. Summary of Objection .I 6.4.2 The whole of the ares annotated CF7 should be retained within the Green Belt. An educational campus would be an acceptable use in the Green Belt, and should the proposal not proceed, alternative inappropriate development could take place. 6.4.3 There was a need to maintain adequate separation between the built-up areas of Crayford/Slade Green and Dartford in accordance with Green Belt policy. The Council's Response 6.4.4 The line of Joyce Green Lane in the vicinity of Joyce Green Farm, marked a significant transition between the open marsh land to the west and the level of ground to the east which related more closely to the developed part of the Hospital than to the remote and open character of the marshes. This part of Joyce Green Lane would be a clear and defensible boundary for the Green Belt. 6.4.5 Further north however, Joyce Green Lane led away from the hospital environs, and to the north of the farm a line nearer to the hospital buildings would be more appropriate. A defensible line would be the access road running along the southern edge of the site of the former Orchard Hospital which lay to the north-west of Joyce Green Hospital. This line ran eastwards and joined the defined El policy area allocated in the Structure Plan to be deleted from the Green Belt. The Green Belt boundary thereafter followed alongside a strip of land excluded from the Green Belt to take account of a planning permission granted to Thames Water for the use of the land for operational purposes. Conclusions 6.4.6 The extent of the Green Belt in this locality was discussed at the structure plan EIP; it took place in the context of a planning application for development, which extended as far west as the River Darent, and included marshland forming part of the wide area of open land east and west of the River Darent separating Dartford from Crayford and Slade Green. The panel referred to the vital role which the Green Belt land to the west of the hospital had in separating Dartford from Crayford. 78 6.4.7 I am satisfied that the intention of the structure plan is that Policy Area El comprising the buildings of Joyce Green Hospital, should be excluded from the Green Belt and redeveloped in accordance with Policy El. I also consider that the planning permission for the westward extension of the sewage treatment works justifies the removal of that site from the Green Belt. The northern part of the proposed site of a polytechnic, designated CF7 on the Proposals Map, is shown as remaining within the Green Belt, and the site would be developed as an institution in its own grounds, which is an appropriate form of development within the Green Belt. In my view the issue concerns the white land allocated for CF7 purposes. 6.4.8 The southern part of the white area is largely overgrown scrubland. The boundary between the CF7 site and the El site is defined by a post and wire fence, whereas the boundary of the Green Belt on the deposit version of the Proposals Map consists of Joyce Green Lane and a track with a hedge along the western boundary. The strip along the northern boundary of the El site forms an easement for overhead high voltage electricity cables. In my view there are no natural features in this locality, which would form a permanent, defensible boundary for the Green Belt. In the future however, it is likely that there will be a clear distinction between the development on the El site and that on the.CF7 site, and the boundary between the developments could form a defensible Green Belt boundary. Furthermore, the currently proposed use of site CF7 would be an appropriate use in the Green Belt, and I do not therefore, consider that there are any exceptional circumstances warranting removal of any of the CF7 site from the Green Belt. 6.4,9 In the event that the development of a polytechnic did not proceed, there would appear to me to be the likelihood of the El policy area extending into the white CF7 area. This would reduce the separation between Dartford and Slade Green, and in my opinion, be contrary to the purpose of the Green Belt policy in this locality. · Raso rd•tipp 6.4.10 I recommend that the Proposals Map be mOdified so as to retain all the CF7 areas within the Green Belt, 79 SITES DESIGHATEP AS GREEN BELT I ! Objection Ng.171 Written Objection No. 18 6.5.l Objection No.18 was made on behalf of Bexley Metals Ltd and Easy-load Ltd, and Objection No.171 was made on behalf of DBT Holdings Ltd. The objections concerned land at East Rochester Way (the Gun Club site). 6.5.2 At the inquiry, it was confirmed that the site of Objection No.171 included both the quarry and the adjoining commercial development. Since the conclusion of the inquiry however, boundary changes have removed the quarry site from the Borough of Dartford. I hsve therefore considered only the developed part of the site, though it has been necessary to consider its relationship with the surrounding land. Summary of Objection No.18 6.5.3 The area over which Policy DL3 applied should coincide with the disused workings and exclude the area of established commercial uses. 6.5.4 The site should be identified for employment use, recognising its existing use, unique location and potential, together with the need to secure long term environmental improvements. It did not contribute functionally or visually to the Green Belt, and releasing it from the Green Belt would be the only means of securing environmental improvements. 6.5.5 The site was ideally situated in relation to the M25 and A2 to fulfil a valuable role for storage and distribution and, particularly, waste transfer. There should be a site specific employment policy for the site, similar to that applied to the Bean Triangle. 6.5.6 The objection site was not an open area and was clearly not part of the surrounding countryside. There was no recognition by the Council of the need for a positive planning approach to the area. The site did not fulfil any of the functions of the Green Belt as set out in PPG2. No provision was made in the local plan for the waste transfer, transport and storage uses of the type located within this site, elsewhere in the borough. Considerable additional plant and buildings could be needed in the future which would be contrary to the Green Belt policies. If the existing uses on the site were to continue to fulfil a useful role in the borough, future changes must be facilitated and hence there was a need for a specific policy for the site. Summary of Objection No.171 6.5.7 The plan should reinstate Policy H4 to be applied to the objection site as contained in the consultation draft of the plan. Policy H4 had stated: "Land is identified at the Gun Club for a mixed use scheme based on housing development, which takes due account of the site's environment and setting. Proposals should include the provision of open space as required by Policy RT17, and are to be formulated on the basis of a development brief for the site as a whole." 6.5.8 The policy should be reinstated as there had been no material change since the draft consultation plan had been prepared, and no justifiable reason for rescinding the draft policy had been produced. 80 6.5.9 The objection site had for several years been considered as exceptional by the council in negotiations with Dougal Brothers and their agents. This arose from the planning history and the environmental damage caused by the approved uses. The culmination of those negotiations had led to the exclusion of the site from the Green Belt and the inclusion of Policy H4 in the consultative draft version of the local plan. 6.5.10 The site and surrounding area had been regarded as exceptional in the way that the council had considered planning applications. This had permitted the consolidation of existing bad neighbour uses despite the inclusion of the site as Green Belt on the North West Kent Town Map. 6.5.11 The planning permissions granted on the Gun Club site for mineral extraction in the 1960s did not require the land to be restored. 6.5.12 Government policy stressed the positive role for local plans in improving the environment and resolving long-standing planning problems. The deposit version of the plan did not adopt a positive role in relation to the objection site. 6.5.13 Government policy and structure plan Policy MGB3 required Green Belt boundaries to be reviewed in a way which provided both for long-term development needs to be met and for changes to be made where exceptional circumstances applied. Exceptional circumstances had been accepted as existing with regard to the Gun Club site and surrounding land. 6.5.14 With regard to the requirements for long-term development, the future development needs in Dartford beyond 2001 were likely to be significant given firstly the inclusion of the area within the East Thames Corridor, and secondly the impact of the Channel Tunnel Link. 6.5.15 The most recent consultative draft of the Third Structure Plan Review published by the county council indicated that consideration should be given to excluding land north of the A2 at Dartford from the Green Belt to provide for long-term development needs. 6.5.16 Despite the advice in PPG2 and there being continuing needs for development in Dartford post-2001, the local plan did not set aside any "white land" sites from the Green Belt. This shortcoming should be rectified and the objection site excluded from the Green Belt given its characteristics and history. 6.5.17 The allocation of the Gun Club site and/or its removal from the Green Belt would provide the catalyst towards plan led environmental improvements in accordance with Government advice. 6.5.18 The redevelopment of the area including the Gun Club could take place despite there being multi-ownerships, and whilst the situation may take. time to resolve itself, nothing would happen to improve the environment unless the site were excluded from the Green Belt. 6.5.19 The Master Plan submitted with the objection indicated the types of scheme which could take place. These could be the subject of discussions prior to the formulation of a design brief as indicated in the consultative draft version of the local plan. 81 The Council's Response 6.5.20 It was acknowledged that the DL3 policy area should coincide with the disused workings, and exclude the area of commercial uses bordering East Rochester Wsy and Denton Road. A change to the Proposals Map, necessitiated by the boundary changes, would delete the quarry from the plan area. 6.5.21 The objection site performed the Green Belt functions of checking the unrestricted sprawl of large built-up areas, and safeguarding the surrounding countryside from further encroachment. It also contributed towards preventing neighbouring towns from merging into one another. The uses on the objection site were long established and had to be recognised. They were however, mainly open in character and their presence was not regarded as a valid reason for removing the site from the Green Belt. 6.5.22 Planning permissions granted on the site had related to the long established commercial uses situated there, and had provided an opportunity to secure some planning gains in terms of ameliorating the environmental impact of the existing uses. Elsewhere the main planning permissions granted had been for temporary consent for built development ancillary to the use such as office or toilet facilities. 6.5.23 Existing users would not be forced to move away, and there were no provisions in the plan to displace them. Policy ES in the plan encouraged development in existing employment areas but only subject to transport and environmental considerations. Conclusions 6.5.24 It is acknowledged that the sand extraction on the quarry site can be an appropriate use in the Green Belt but the non-conforming uses along the south and east strips of the site, and in separate ownership, are visually intrusive. They comprise activities such as plant hire, builders' materials and external storage, and waste paper transfer which adversely affect the character and appearance of the area. The preamble to the draft Policy H4 had recognised this, and stated that the issues could be resolved through a well-designed development in a landscaped setting, incorporating open space provision, on the basis of Policy ! RT17. However, in the light of responses to the consultation draft, and that from London Borough of Bexley in particular, the council reconsidered the matter l and retained the site in the Green Belt. 6.5.25 The non-conforming uses undoubtedly reduce the effectiveness of the open apace in its contribution to this part of the Green Belt, and in my opinion recent planning permissions which have enabled some intensification of the uses, have aggravated the situation somewhat. 6.5.26 Despite the non-conforming uses, I consider that the abjection site performs several of the purposes of the Green Belt in this area. It is a within a neck of open land linking substantial open areas to the north-west and south· east. This swathe separates Crayford and Dartford to the north from Maypole and Coldblow to the south, and any urbanisation of the site would significantly reduce the value of the whole swathe. At present, the non-conforming uses are out of character in that they are set in generally open land but any significant new development would appear as an extension of the built-up area, and reduce the gap to an insignificant amount. In my opinion, the value of this part of the Green Belt is more likely to be preserved if the abjection site is retained within the Green Belt. In view of the considerable amount of land being released from the Green Belt ta acommodate growth in the borough, I can see no reason to release further land as "white land" for possible further growth. 82 6.5.27 I consider that an appropriate response to the problems created by existing commercial and industrial sites in the Green Belt would be for the local plan to acknowledge their existence, and to indicate what factors the council would take into account in considering applications for inappropriate development on such sites. Such applications should improve the contribution of the site to the functions of the Green Belt. An application which, say, reduced the bulk of buildings, and/or resulted in a more open appearance or reduced traffic, could be considered on its merits as a departure from the policies of the plan. Recrnnmepdation 6.5.28 I recommend that: 1. no change should be made to the allocation of the former Dartford Gun Club site; 2. a new paragraph be inserted before Policy GB2, indicating those factors which the council would take into account when considering proposals for inappropriate development on sites currently in commercial or industrial use, as departures from the plan.· Written Qbjection No 193 6.6.1 The objection was made on behalf of Mr and Mrs Thomsett concerning land to the west of Joyce Green Lane. Summary of Objection 6.6.2 In view of the contemplated developments shown by the local plan in the vicinity of the objection site, there would appear to be no reason why the objection site should remain designated as Green Belt. It would be emminently suitable for Bl development including a business/science park, together with a service station adjacent to the roundabout in the south-east corner of the site. The Council's Response 6.6.3 The land to the west of Joyce Green Lane clearly fulfilled Green Belt functions, particularly in terms of preventing the coalescence of Dartford and Crayford. This vital role was acknowledged in the structure plan. 6.6.4 Land immediately to the east of the River Darent was identified as a site of nature conservation interest, and subject to the protection of Policy Cl4. 6.6.5 Development on the objection site would conflict both with Green Belt functions and with the objectives of nature conservation. Conclusion 6.6.6 The objection site forms part of the application site considered by the EIP Panel. The structure plan identifies the area west of the Joyce Green Hospital site as having a vital role in separating Dartford from Crayford, and it specifies that the land should remain in the Green Belt. There is no evidence of any overriding need for the type of development proposed by the objector, and I can see no special circumstances why this site should be excluded from the Green Belt. 83 6.6.7 The objection site also contains areas subject to nature conservation policies, and any proposals for development would be likely to conflict with the nature conservation interest. Raqg=eg4etipp 6.6.8 I recommend no change to the allocation of this site as a consequence of this objection. Written Qbjectipp No 195 6.7.1 The objection was made on behalf of Otas Holdings, and concerned land at Darenth Road, Darenth. Summary of Objection 6.7.2 The site was currently unused and contributed little to the surrounding area or to this part of the Darent Valley. It should be put to some form of beneficial use. The owners would provide an area for car parking to serve the parish church, and to provide a facility for visitors to the Darent Valley. In return, a limited amount of additional development should be permitted adjacent to the existing well-established business premises at Darenth Mill. 6.7.3 The character of the sensitive area would be preserved as the objectors had received awards for their contribution to the environment in respect of their existing site. The Council's Response 6.7.4 The site lay within the Green Belt which at this location particularly served to safeguard the countryside from further encroachment. Any built commercial development would conflict with this aim. 6.7.5 The landscape of this area was of a special quality which was recognised in Policy ClO relating to the Darent Valley, wherein landscape, nature conserva tion and recreational factors were given high priority. A commercial' development would conflict with this policy. 6.7.6 The objection site adjoined an area of special character subject to Policy BlO, and was important to its setting. Conclusions 6.7.7 The settlement of Darenth comprises sporadic development and is "washed over" as Green Belt with no defined village limits. The objection site lies between an arm of the River Darent and a minor road near its junction with Parsonage Lane. The commercial development at Darenth Mill is set back from the road and is relatively unobtrusive in this predominantly rural setting. In my opinion any extension or intensification of the use would be likely to make it more intrusive. 6.7.8 The site is within an acknowledged sensitive area, and I do not consider that either the provision of a car park or any additional development at Darenth Mill, would comply with the policies of the plan which are designed to protect the character of the area. 84 - lagpp=ndet;ism, 6.7.9 I recommend no change to the allocation of this site as a consequence of this objection. Written Qbjectign Ng 196 6.8.l The objection was made on behalf of the Hawkins Trust, and concerned land at Green Street Green. Summary of Objection 6.8.2 The confines of the village of Green Street Green on the Proposals Map did not adequately reflect the existing area of built-up land on the south and west sides of Green Street Green Road. The south-east boundary should be extended as far as Malt Bungalow which was the point at which the built-up part of the village gave way to more open land. The Council's Response 6.8.3 The land in.question formed part of the Green Belt which at this location served to safeguard the countryside from further encroachment. 6.8.4 The village boundary as drawn on the Proposals Map, reflected the substantially developed part of the village. Beyond the identified confines, existing development was diffuse and spasmodic rather than forming a mainly built-up frontage. Conclusions 6, 8. 5 Green Street Green is a linear settlement along the s.outh side of Green Street Green Road. It comprises a group of dwellings separated from a further small group of dwellings related to Malt House Farm, by an engineering plant yard which utilises a redundant barn and an area of open storage. There is a kerbed footway which extends as far as Malt House Cottage. 6.8.6 While I recognise that the south-eastern limit of the settlement as defined on the Proposals Map does not represent a firm boundary between housing and open countryside, the objection site comprising the plant yard and the few dwellings near Malt House Farm, are of a more rural character than the housing to the north-west. The plant yard makes use of a redundant barn and a redundant far.myard, and the continuous high hedge along the front of the site maintains a rural appearance. The use of redundant farm buildings is not regarded as inappropriate in the Green Belt. 6.8.7 Removal of the objection site from the Green Belt would be likely to lead to further development which would encroach into the countryside and be contrary to the normal Green Belt policies. I do not consider that the existing use of the site constitutes circumstances which justify its removal from the Green Belt. lopg !!det;ion 6.8.8 I recommend no change to the allocation of this site as a consequence of this objection. ,1 !i' j 85 Written Obiections Nos 197 anci 198 6.9.1 The objections were made by Mr B G Bartram and on behalf of Mr A Reilly. They concerned areas of land south of New Barn. 6.9.2 Objection Site No 197 is contained within Objection Site No 198. Summary of Objections 6.9.3 The Green Belt boundaries shown on the Proposals Map did not properly define the boundaries of the existing village settlement. A change as proposed would comply with the structure plan, and with other policies and statements in the deposit version of the local plan. 6.9.4 The confines of the village should be extended as far as the railway in order to release further land for small scale housing which would not bring about ,. the merging of settlements and would thus not undermine Green Belt policy. There were already existing dwellings in the area which formed part of Longfield Hill. 1. Adequate infrastructure existed, and a new defensible boundary could be created. 6.9.5 The natural boundary of the Green Belt did not lie along the line of the main road but south of the group of dwellings on that side of the road. Extension of the proposed boundary would not compromise the future definition of the Green Belt or lead to the coalescence of village settlements, as there were natural breaks between the settlements of New Barn and Longfield, and there was a further natural break of open countryside between New Barn and Longfield Hill. One of the aims of the Local Plan was a re-definition of Green Belt boundaries in order to add to the reasonable potential for housing development. The Council's Response 6.9.6 The objection sites lay within the Green Belt and performed the functions of checking the unrestricted sprawl of large built-up areas, and safeguarding the surrounding countryside from further encroachment. It also prevented neighbouring towns from merging into one another. Inclusion of the land within the confines of the village and possible subsequent development, would conflict with thsse functions. 6.9.7 Development of the sites w0uld also contribute towards the coalescence of New Barn and Hartley, conflicting with the specific Green Belt function identified in the Structure Plan namely to •to restrict the expansion of settlements south of the A2 including (inter alia) Hartley ... Longfield in order to prevent further suburbanisation snd preserve their identity•. 6.9.8 The land in question contained scattered dwellings but was essentially rural in character. Main Road clearly defined the southern edge of the developed area of New Barn. Conclusion 6.9.9 The objection site contains a school and some sporadic residential development. It lies between Main Road and the railway line which forms the boundary of the borough. The north side of Main Road is hedge lined and gives the appearance of a soft outer edge to the settlement of New Barn which is excluded from the Green Belt. The development to the south of Main Road is of a sporadic nature, and when descending New Barn Road, the land south of Main Road appeared to me to be open countryside, albeit containing some sporadic dwellings near Main Road. I consider it to be correctly designated as Green Belt. 86 6.9.10 The importance of the Green Belt containing New Barn is explicitly referred to in the structure plan. Rocg ndatlw 6.9.11 I recommend no change to the allocation of these sites as a consequence of these objections. Objections Nos 199-209 6.10.1 The objections were made by Messrs J M Adams, J C Evans, C Gray, F Miles, C Milner, S P Payton, J Paine, AG Town, HAG Wood, F S and E R Fitness, and Mr D Sharp. They concerned land to the rear of properties in 1:"ngfield Hill. Summary of Objections 6.10.2 The site should be removed from the Green Belt as the proposed boundary was illogical, followed no natural feature, and ignored the current use of the site. The site did not contribute to Green Belt objectives and was suitable for residential development. 6.10.3 Mr Sharp argued separately that the land had always been within the village confines when part of the Sevenoaks District, and the boundary across the middle of the garden imposed restrictions on his property, which did not apply to houses on the opposite side of Main Road. He did not argue for residential development of the objection site. The Council's Response 6.10.4 The objection site should remain within the Green Belt and outside the village confines, as it performed the recognised Green Belt functions set out in PPG2, the structure plan and the local plan. The Green Belt boundary should be drawn to prevent the sprawl of development and the coalescence of nearby settlements; it should therefore reflect the existing built form. Sevenoaks District Council's SPG was not a constraint on policy formulation in Dartford; !. 6.10.5 Longfield Hill was a small hamlet and the additional development • potential of the site would not be sufficient to sustain a normal range of village services. 6.10.6 Development of this "backland" site would create an unsatisfactory form of development which would relate poorly with existing buildings, and would spoil the character of Longfield Hill. 6.10.7 The Green Belt boundary across the gardens would prevent any significant new development but would not affect the occupants' permitted development rights. Conclusions 6.10.8 The western part of the objection site is mostly in the ownership of Mr Adams, and is largely overgrown and unused but contains a storage area for builders' materials. The eastern half comprises the rear part of back gardens to dwellings. 6.10.9 Much of the Council's concern regarding the objection site related to its unsuitability for residential development, and to the impact of any residential development on the curvilinear character of the settlement, part of 87 which is designated as an Area of Special Residential Character. These however, are matters of development control, and other policies could prevent any unsuitable development on the objection site. 6.10.10 Wherever possible, PPG2 recommends that Green Belt boundaries should follow natural features, and be defensible and permanent. The boundary shown on the Proposals Map cuts across the middle of some gardens, and is undefined on the ground. On the other hand, the northern boundary of the objection site is defined by a strong hedgetow beyond which is open countryside; it is also the borough boundary. In my opinion the northern boundary of the objection site would form a more natural and ultimately more defensible, long term boundary than that shown on the Proposals Map. Begg n4,et;iqn 6.10.11 I recommend that the boundary of the Green Belt and the village confines north of Main Road, Longfield Hill be modified to follow the hedgerow and borough boundary. Written Objections NQS 210 Cpart). 212-216 6.11.1 The objections were made by Mr and Mrs SR Butler, Mr J De Clerk, Mrs J De Clerk, Mr L De Clerk, Miss V P Mower and Mr and Mrs H L Edwards. The objections related to the village limits at the village of Betshsm. SUllllllAry of Objections 6.11.2 The village boundary had been too tightly drawn. Lanes Farm as far as the existing farmhouse and out to the edge with Warwick House, should be included within the village confines. 6.11.3 The village envelope in the north-west corner of the village wss ill defined and 111ade little sense particularly when it passed across the area of Betsham Service Station and Lanes Farm. It should he redrawn in the light of planning permissions already granted for the redevelopment of Betshsm Service Station. 6.11.4 The land at Oast View should be included within the village as it was within the village envelope prior to 1976. The current village confines did not take account of the substantially built-up frontage between Osst View and the centre of the village. The Council's Response 6.11.5 Betsham was a small hamlet unable to support a high level of services, and the housing sites advocated by objectors would not result in the provision of a range of village services. To create such a viability, substantial expansion of the settlement would be necessary, which would be unacceptable on Green Belt, environmental and other planning grounds. 6.11.6 Lanes Farm lay in an Ares of Local Landscape Importance, and subject to Policy C9. Inclusion of the site within the confines of the village and its possible subsequent development, would intrude into open countryside conflicting with this policy. Furthermore housing on this site would constitute backland development which would relate unsatisfactorily with the village. 6.11.7 Oest View lay beyond the perceived western extremity of the village. The· inclusion of the site within the village confines, and its possible subsequent 88 development, would result in built development extending into open countryside. The site also lay in an Area of Local Landscape Importance, and development on it would conflict with Policy C9. Conclusions 6.11.8 Betsham is an attractive village defined as an Area of Special Residential Character, and is surrounded by open countryside designated as Green Belt. It has few village facilities, and in the absence of any identified need for any specific housing provision, I do not consider that it would be appropri ate for any enlargement of the village beyond its existing limits. 6.11.9 In my opinion, development of the land at Lanes Farm would be an extension of the village into open countryside which is designated as being protected from proposals for development which would materially affect the quality of the landscape. 6.11.10 The dwelling Oast View is set well back from the road and on elevated ground. The dwellings between Oast View and the village centre are on elevated ground behind a retaining wall, and the road west of Broomhills has in my view, a rural character which is frequently found near the edge of a village. 6.11.11 I do not consider that there is any justification for the expansion of Betsham, and I can see no special circumstances to justify the deletion of the objection sites from the Green Belt. 6.11.12 Further consideration of these issues can be found under Policy Hl in Chapter 4. BogPT"'Y"tlpn 6.11.13 I recommend no change to the allocation of these sites as a consequence of these objections. Written Ob1ections Nos 218 and 300 6.12.l The objections were made by the Parochial Church Council of St John the Baptist, Sutton-at-Hone, and the Rochester Diocese. Summary of Objection 6.12.2 The area of Sutton Court was functionally and practically related to the community and village of Sutton-at-Hone. The furthest northern extent of the curtilage represented a much better boundary for the village. The Council's Response 6.12.3 The Council accepted that the objection site, together with properties immediately to the north, related to the built-up area of the village, and that the village confines and Green Belt boundary should be amended accordingly. The objection site would be suitable for social facilities, and commended changes would modify the Green Belt boundary and apply Policy CF3 to the objection site. 89 Conclusion 6.12.4 Sutton Court which comprises the Area Health Authority offices, forms part of a large curtilage which is enclosed by a high wall. It is within the 30 mph speed limit, and is situated on the junction of Main Road with a side road opposite the village hall and residential development. It is close to a primary school, and a short distance from the church. 6.12.5 In my opinion the site is more closely related to the village than to the open countryside, and has development to the north, south and east. I do not consider that it performs any significant Green Belt function, and should therefore be deleted from the Green Belt and included within the village confines. Repqp=gletign 6.12.6 I recommend that the Proposals Map be modified in accordance with commended changes Nos 74, 82 and 83. Written Qbjectipn No. 219 6.13.1 The objection was made on behalf of Mr D Wildish. Summary of Objection 6.13.2 Land at Days Farm, Wilmington should be excluded from the Green Belt, as the site was already substantially built up and used as a road haulage yard. It had been a constant source of nuisance to local residents living in Garden Place, and nearby in High Road. A proposal for residential development had been submitted to the Council in 1989, and the principle of the redevelopment of the site had been agreed in order to extinguish the existing use rights of the land. The Council's Response 6.13.3 The buildings at Days Farm lay beyond the general extent of built development in the area, and the Green Belt boundary on the Proposals Map was defensible and clear. The existing use of this site and possible alternative uses for it, were not relevant considerations which could justify overriding the Green Belt factors which predominated in this case. Conclusions 6.13.4 The site comprises a large brick building with a.high corrugated iron fence. It also contains sheds and corrugated iron buildings, together with parked trucks and vans. The site is situated beyond existing housing and in' otherwise open countryside adjacent to the A2 trunk road. This part of the built up area is closest to the settlement of Horley and any extension of it into the Green Belt would be contrary to one of the main purposes of the Green Belt. 6.13.5 I recognise that the removal of the haulage yard and its possible replacement by housing, may improve the amenities of those living nearby. This however, is not one of the functions of the Green Belt, and uses such as take place on the objection site, are not unusual where longstanding uses have taken place within open countryside. In my opinion the existing use of the site does not constitute exceptional circumstances justifying its removal from the Green Belt. My recommended new paragraph preceding Policy GB2 may be relevant to this site. 90 Bascnzagtettgp 6.13.6 I recommend no change to the allocation of this site as a consequence of this objection. Written Objection No.344 6.14.l The objection was made on behalf of Thames Polytechnic but was subsequently withdrawn. POLICY GB4{b) Written ObiectiQD No 221 6.15.l The objection was made on behalf of Colyer Greenhithe Estate, and concerned land at Darenth Park Hospital. Summary of Objection 6.15.2 The hospital site should be removed from the Green Belt, otherwise development would be restricted to PPG2 guidance. The development of the site for a major residential scheme and a District General Hospital, together with the development nearby of a regional shopping centre, would completely alter the character of the area. In such circumstances the site could not maintain its Green Belt function. The Council's Response 6.15.3 Darenth Park Hospital was a redundant hospital in the Green Belt to which Circular 12/91 applied. Policy H2 sought to apply the circular to the particular circumstances of the Darenth Park site, and referred specifically to Government guidance. It was clear from the circular that the aim in any redevelopment must be to avoid the erosion of any Green Belt function performed by sites to which it applied, and the criteria specified for redevelopment sought to achieve this, If redevelopment proposals would significantly alter the character of the site they would be unlikely to comply with the terms of the circular. Conclusion 6,15.4 The effect of the planning permission for the Bluewater retail development on the north side of Watling Street, has been to roll back the extent of the Green Belt on that side of Watling Street. On the south side of Watling Street however, the residential development is contained along the western boundary of the objection site, and the removal of the hospital site from the Green Belt would be to extend the built-up area further east and south. I consider that this would not only reduce the effectiveness of the Green Belt by the deletion of the objection site, but would also reduce the effectiveness of the land to the east. Effectively the limit of the Green Belt would extend to the A2 trunk road. I do not consider that removal of the Darenth Park Hospital site from the Green B~lt would produce a defensible and logical Green Belt boundary. 6,15.5 The redevelopment of hospital sites is a general exception to the restrictions on development in the Green Belt, and Circular 12/91 is intended to ensure that the effectiveness of the Green Belt is not harmed by any redevelopment of the hospital site. The circular, therefore, inevitably places constraints on any redevelopment proposals. 91 6.15.6 I can find no exceptional circumstances in this case to warrant removal of the site from the Green Belt. 6.15.7 I recommend no change to the allocation of this site as a consequence of this objection. 92 CHAPTER 7 - TRANSPORT 114C1 7.1.1 The structure plan highlights Dartford as an area of new opportunities for development, arising from its proximity to the M25. The borough is also within the East Thames Corridor which is identified in SERPLAN as being in need of regeneration and new investment. 7.1.2 Transport is seen as being a key factor in the realisation of the local plan's overall development strategy. The main feature of the proposed highway network is a new route along the south bank of the River Thames. The route shown on the Proposals Map is that shown on the North-West Kent Town Map pending further studies and detailed design. 7.1.3 The town centre is enclosed on three sides by a ring road but the south east sector uses a tortuous alignment along local roads which are heavily used by pedestrians. A new one-way route is proposed through an area allocated for redevelopment. 7.1.4 Following the improvements to the Thames Crossing, the Department of Transport (DTp) are investigating an improvement of the M25/A2 junction. This is likely to involve improving the access to Dartford, and the council support the option of a new link from the M25/A2 junction. Land is also being safegusrded for identified highway improvement schemes. 7.1.5 Concern has been expressed over the adequscy of Junction lA on A282. Studies have been carried out, which indicate that the junction will not operate satisfactorily in the year 2001 with the anticipated traffic flows. The roundabout can be enlarged within available land, and traffic signals would improve the situation. Studies are continuing, and it appears likely that further improvements are possible, and the effects of improved public transport could have an influence. As development proposals emerge, financial contribu tions towards highway improvements will be required. 7.1.6 Existing traffic flows are already high, and in view of the anticipated increase in flows, public transport and transport interchanges are expected play an increasing role. 7.1.7 In order to maintain the importance of the town centre as a retail centre, importance is given to the provision of a sufficient supply of short term parking which is well related to the highway network. 7.1.8 Representations from the Kent Trust for Nature Conservation and British Rail (R57, R58 and R60) supported the council's emphasis on an integrated transport system. 7.1.9 Local plan Policies Tl2 and Tl3 have been carried forward from the North-West Kent Town Map which is the current statutory plan for the area, and are therefore not open to objection. 93 POLICIES PARAGRAPH 7 .1. 5 Written Qbjection No· 223 7.2.1 The objection was made on behalf of Blue Circle Properties Ltd. Summary of Objection 7.2.2 Adequate infrastructure should be provided within the plan period and beyond, colDlllensurate with development proposals. Additionally, the cost of providing additional infrastructure should be shared equally between the main beneficiaries. The Council's Response 7.2.3 The plan's transport strategy ·recognised that adequate transport infrastructure was needed to facilitate the implementation of the development options identified in the plan. Where the cost of provision was to be borne by service providers as beneficiaries, the importance of bearing the costs equitably was recognised. An additional sentence at the end of paragraph 7.3.l was recoQllllended, which would meet the objection. Conclusions 7.2.4 Paragraph 7.3.l of the plan sets out the justification for Policy Tl which encourages the implementation of an integrated transport strategy for the borough. Paragraph 7.3.2 explains the need for transport infrastructure to be adequate to realise the development potential of the borough. As Policy T2 is the relevant policy for the funding and provision of transport infrastructure to serve major development, I consider that reference to mechanisms for enabling the cost of provision of infrastructure would be more appropriate in paragraph 7.3.2. 7.2.5 A modification to paragraph 7.3.2 on the lines of commended change No. 25 to paragraph 7.3.l, would in my view, be compatible with the advice in Circular 16/91, in that where contributions towards the cost of providing infrastructure are appropriate, it should be borne equitably between the infrastructure undertaker and the beneficiaries. lecmwnc'etiqn 7.2.6 I recommend that paragraph 7.3.2 be modified by the addition of the last sentence in colDlllended change No.25. PARAGRAPH 7.2.1 AND POLCY Tl Written Qbjection No. 224 Representations Ngs R57 and R58 7.3.1 The objection was made by the Kent Trust for Nature Conservation, and related to the objectives of transport policy. 94 Summary of Objection 7.3.2 Whilst supporting the objectives, and the provisions of Policy Tl as re iterated in Representation No.R57, the large development opportunities identified in the plan would in themselves generate significant increases in road traffic unless the issue were urgently addressed. Policies should reflect a presumption against development which increased traffic per se, rather than that which increased traffic but failed to improve the highway network. 7.3.3 In reply to the council's response, the objector opposed any new highway provision which would have an adverse environmental impact. There should be a move towards reducing mobility, particularly where high levels of new development were proposed. The Council's Response 7.3.4 The plan recognised that an adequate transport strategy for the borough could not rely solely on new road building, and that an integrated strategy was required. An additional objective reflecting this would improve the plan, and a change to recognise the importance of both the siting and detail of new development was recommended. 7.3.5 A further change would aim to secure additions as well as improvements to the highway network. There could be substantial improvements to the environment by new road construction, when the opportunity could be taken to transfer some existing traffic from roads where accident levels and traffic impact were high. 7.3.6 British Rail supported Policy Tl. Conclusions 7.3.7 I support the objective of seeking to reduce or minimise increasing car- borne traffic by careful attention to both the siting and detail of new development. 7.3.8 In my opinion, the extent of new development proposed in the borough, particularly that to the north of the town centre and along the riverside, is likely to generate more traffic than the existing road system could be expected to accommodate. I thus consider that additions to the highway network are inevitable. Such provision if sensitively designed and located, could have environmental benefits as well as disbenefits, and the balance should form part of the assessment of any new road proposal. lagg wfetign 7.3.9 I recommend that paragraph 7.2.1 be modified in accordance with commended changes Nos 23 and 24. POLICY T2 Written Objection No.6 7.4.1 The objection was made by the Department of Transport (DTp) 95 Summary of Objection 7.4.2 Any proposals for new development should be required to demonstrate that provision had been made to provide adequate capacity within the transport system, to cater for the effects of the development. This particularly applied to the A282 Littlebrook junction. The Council's Response 7.4.3 The Council recognised the Department's concern, and changes were proposed to Policies T2 and T21, and paragraph 7.2.l(e), as well as to Poli cies El, E2 and E3 in Chapter 3. 7.4.4 By letter dated 14 May 1992, the Department recommended that the commended changes be accepted. 7.4.5 British Rail supported Policy T2. Conclusion 7.4.6 I consider that the commended change to paragraph 7.2.1 is correct in that it recoyiises the possibility that additions to the highway network may be necessary as well as improvements. 7.4.7 The commended changes to Policies T2 and T21 are also in my view, right in principle but as worded there is an inconsistency between the policies and their preambles. It appears to me that the intentions of the policies are that where insufficient capacity exists in the transport or highway infrastructure to serve proposed developments which would be otherwise acceptabe, then the developer in conjunction with the transport provider, will be required to contribute towards any necessary improvements, subject to the criteria in Circular 16/91. As worded however, the commended changes require there to be adequate capacity available in existing and planned infrastructure. 7.4.8 I therefore support the commended change to paragraph 7.2.l(e), but I propose to amend the commended changes to Policies T2 and T21. Reps pd&tiQM 7.4.9 I recommend that: 1. paragraph 7.2.1 be modified in accordance with co1D1Dended change No.23 2. Policy T2 be modified by the addition of a new final sentence; "Development proposals must demonstrate that before the development com&a into use. adequate transport capaqity will be aya.ilab]e to serye the deyelopment. " 2. Policy T21 be modified by the addition of a new final sentence; 11 Develpmuent propgsala must demgn•trate that before the dewlqpment cwpeo into use, ad1g1mte hishuy canacity will be ayailable to seryo it. See also recommended modifications to Policies El, E2 and E3 in Chapter 3. 96 POLICIES T6, T7 AND T8 Qbjectign Ng, 225 Representations No.R61 7.5.1 The objection was made on behalf of Stone Parish Council, and concerned the provision of park and ride facilities and the development of other railway stations in the borough, in particular at Stone Marshes. Summary of Objections 7.5.1 The provision of park and ride facilities would have the effect of attracting additional and unnecessary traffic into Stone causing congestion on roads. Such facilities would provide improved access to Dartford town centre, thereby rendering the Crossways development and the Bluewater Park retail development less attractive to customers than developments in the town centre. Employees would also be attracted to commute, hence reducing the appeal and potential of the Crossways office development. 7.5.2 The relocation of passengers from Dartford to a new station at Stone could have an impact on the character of Stone by making it s suburb of the Dartford urban area, and blurring its current independent sense of identity. 7.5.3 A light rapid transit system would be expensive, and would create an impact on Stone's environment while construction work took place. The scheme was unnecessary since Dartford and Stone were adjacent stations, and the BR line between them would duplicate the proposed new road network. 7.5.4 The new parkway station at Stone Marshes would sterilise land under large areas of car parks, and would attract road traffic, thereby moving congestion from Dartford to Stone. Furthermore, the proposal· may encourage the provision of s station.onto the channel tunnel rail link which was likely to pass through the Stone area, with consequent massive attraction of traffic and development of huge parking areas. The Council's Response 7.5.5 The transportation policies in the local plan, particularly policies relating to public transport such as T6, T7 and T8, had been formulated with the express aim of removing unnecessary traffic from congested areas, and to move parking to areas more suitable than town centres. Any move from private transport to public transport would be beneficial both to the development of the area and the environment generally. Investigations into systems, routes and parking sites would take full account of the traffic implications of such proposals, and their development would necessarily encompass highway improvement schemes and schemes of traffic restraint to minimise their impact on the local environment. 7.5.6 Colyesr Greenhithe Estate supported the proposal for a parkway station contained in Policy TB. Conclusions 7.5.7 Policy T6 and the preamble in paragraph 7.3.5 contain a commitment to investigate the feasibility of providing park and ride services to and from the town centre; no specific reference in this connection is made to Stone. The policy is of general application throughout the borough, and seeks to alleviate congestion in the town centre during the morning and evening peak periods as described in paragraph 7.3.4. In my opinion these objectives are worthy of 97 pursuing, and any investigation can reasonably be expected to pursue the cost in both financial and environmental terms, as well as the benefits to traffic. I can therefore see no reason to modify Policy T6. 7.5.8 Policy T7 also is a commitment to investigate the promotion of other railway stations in the borough. It is a policy of general application, though reference is made to the possibility of a station in the Stone Marshes area to complement the existing Dartford Station. In my opinion, the possibility thst alternative railway stations in the borough may be better related to the main highway network than existing stations, and could also more readily provide suitable parking facilities, is realistic, and any investigation would show the disbenefits and costs as well as the benefits. I can thus find no reason to modify Policy T7. 7.5,9 A study commissioned by Rritish Rail and Slue Circle Industries Plc has been carried out concerning the possibility of a new parkway station at Stone Marshes. The study has shown that such a station would be beneficial both to the development at Crossways and to public transport generally in the North Kent area. Further investigations into this project will need to take full account of the impact of attracted traffic to the new station in its role as a parkway facility, in accordance with other policies in the plan, but it is anticipated that this might be balanced by a reduction in the movement of private road traffic, and a possible change of mode from car to train. Policy TB is a commitment to investigate these matters, and not necessarily to provide a new facility. I can see no reason to modify the policy. Refore any new station could be provided, the results of a further study showing both the costs and benefits in both financial and environmental terms, would be available. llegszmenMtigp 7.4.10 I recommend no change be made to Policies T6, T7 or TB as a consequence of this objection. POLICIES T9 AND T24 Written Objectigns Ngs 226 and 261 7.6.1 The objections were made by Thames Water Utilities. Summary of Objection ' 7.6.2 Improved bus routes, and a bus/rail interchange at Dartford Station and Dartford town centre would be in the vicinity of Dartford Pumping Station. They could therefore affect the quality of t.he underground water supplies. The water I authority would therefore need to be consulted upon the proposals at an early stage. 7.6.3 The Lowfield Street car park proposed in Policy T24 would also be in the vicinity of Dartford Pumping Station, and the policy for additional car parking could affect the quality of the underground water supplies. The water authority should therefore be consulted upon the proposals at an early stage. The Council's Response 7.6.4 The objector's concern was recognised, and a change to the general Policy Rl which applied to any new development, was recommended. An additional clause would require the relevant water undertaking to be consulted as appropri ate. 98 Conclusions 7.6.5 I consider that the additional clause which would be applicable to any proposed new development, would meet the legitimate concerns of the water undertaking. Begg J¥lotion 7.6.6 See recommended modification to Policy Bl in Chapter 12. POLICY T9 Written Qbjegtions Nos 227 and 340 R@pro11ntation1 Ngg R62 and R63 7.7.1 The objections were made by London Transport. Summary of Objections 7.7.2 A new clause should be inserted stating that suitable bus priority schemes would be implemented in order to improve the reliability and efficiency of bus services. 7.7.3 A new policy was required which would consider the reintroduction of buses into Spital Street and Hythe Street on an experimental basis, in order to improve bus access in Dartford town centre. The Council's Response 7.7.4 Public transport was seen to be a key element in the plan's integrated transport strategy. It was recognised that the plan could be improved by amending the policy to include a reference to bus priority schemes, and to amend the wording of the reference to bus routes serving the town centre. A suggested modification to Policy T9 was commended to me. 7.7.5 A Winchester and Sons, and Mount York Properties Ltd supported the proposal for a transport interchange at Bean Triangle. Conclusion 7.7.6 Key objectives of the Council's transport policy are to develop and implement an integrated transport strategy for the Borough, and to secure the provision of improved public transport and better transport interchange facilities. In the light of these objectives, I consider that Policy T9 would be improved by the recommended changes. 7.7.7 I recommend that Policy T9 be modified in accordance with commended change No, 27. 99 POLICY Tl2 ll.epreseptations Noa R64 7.8.l Colyer Greenhithe Estate supported the safeguarding of the South Thames- side Development Route and Dartford Northern By-pass, to which there were no objections. POLICY Tl3 Written Objection No. 229 Representation No.R65 7.9.l The objection was made on behalf of Blue Circle Properties Ltd. Summary of Objection 7.9.2 The safeguarded alignment of the South Thames-side Development Route (STDR) to the north of the former Swanscombe Works should be deleted in order to allow for alternative routes through the former Swanscombe Cement Works which are now closed, to be considered. 7.9.3 In reply to the council's response, the objector stated that the policy should embody the essence of the preceding paragraph 7.3.11 as amended, by acknowledging that consideration was to be given to alternative route proposals. The Council's Response 7.9.4 The alignment shown on the Proposals Map was that shown on the previous town map, and it was being safeguarded under that policy. Reference to the alignment being under review was contained in the preceding paragraph 7.3.11, and this was the appropriate way to refer to it. A change to the policy which would refer to the review, had been suggested, but any further reference in the policy would qualify its importance. 7.9.5 Colyer Greenhithe Estate supported the safeguarding of the South Thames- side Development Route. Written Objections Nos 230 a!ld 231 7.9.6 The objections were made by the Kent Trust for Nature Conservation and the Royal Society for the Protection of Birds, and related to the alignment of the eastern end of the STDR. Summary of Objections 7.9.7 The eastern end of the safeguarded route for the STDR would have damaging impact on nature conservation because it would encroach upon the Bakers Hole SSSI, and also on the proposed extension to the Ebbsfleet Site of Nature Conservation Interest (SNCI). The Council's Response 7.9.8 The only current· alignment of the STDR with any genuine status was that shown on the previous town map, and it was currently safeguarded under that policy. Alternative alignments of the eastern end of the STDR would be considered, and this review was referred to in the preamble to the policy in 100 -- paragraph 7.3.11. Any review would take full account of nature conservation and other environmental issues including those of the Ebbsfleet SNCI extension and the Bakers Hole SSS!. Conclusions 7.9.9 Policy Tl3 is a policy carried forward from the previous statutory Development Plan, and is therefore not open to objection. Neverthele.ss, the Council have recognised in paragraph 7.3.11 that the route of the STDR between Station Road, Greenhithe and Northfleet is under review by the highway authority, and that consideration will be given to alternative route proposals. The modification suggested by the council would safeguard the existing alignment until such time as any review proposals may be approved by the highway authority, and the policy would preclude any development which would prejudice the implementation of the scheme. 7.9.10 In my opinion the preceding paragraph 7.3.11 as amended, adequately explains how Policy Tl3 will be implemented, and is the appropriate place to refer to the alignment being reviewed. I consider however, that the safeguarding should continue until alternative proposals for the STDR have not only been approved by the highway authority but have also been published. Rescrn pdettw 7.9.11 I recommend that paragraph 7.3.11 be modified by the addition of the words: "until gµcb time as ADY reyiow propgsals baya b@an approyed and published bv the high!qy authgrity." after the words "will be safeguarded". POLICY Tl4 Written Qbjnstion No. 6 (part) 7.10.1 The objection was made by the Department of Transport, and related to the provision of s new link road from junction 2 of the M25 to Princes Road. Summary of Objection 7.10.2 The Department could not guarantee the provision of such a link road ss part of its own improvement scheme for the A2/A282 junction. Also the impact of such a new link on the operation of junction 2, existing or improved, could be unacceptable to the Department. The Council's Response 7.10.3 Subsequent to the publication of the local plan and receipt of the Department's objection, the Department had decided upon its preferred solution to the improvement of junction 2. Whilst not forming part of the proposed design solution, the Darenth Road link would not be impossible and was treated seriously by the Department who no longer objected to it in principle. In connection with the proposed link road, the Department's publicity material for the junction improvement stated, "however, the proposed new arrangements at junction 2 do not preclude its construction at some future date•. 7.10.4 Both the borough council and the county council had formally considered the Department's published scheme. Both authorities supported the proposals to improve junction 2, to widen the A2, and to seek the inclusion and implementation of the Darenth Road link. 101 Conclusion 7.10.5 It appears that the Department of Transport no longer object in principle to the provision of the link road between junction 2 and Princes Road. I therefore consider it reasonable that the policy should remain in the plan to provide s basis for the investigation and development of the concept. Objection No. 249 Hritten Objections Noe 232-248 and 250-253 Representation No, R66 7.10.6 The objections were made by Messrs G Bailey, K Biswell, D V Hacker, A J Langridge, R K Scott, P Scudder, K Spaul, K D Timms, J Waters, S D Webb, K J Williams, also by R & S Bonnett, M F and J Byhurst, Mr & Mrs R Hoadley, Mr & Mrs M J S Smith, Mr & Mrs J P Wynne, Ann Day, Mrs J Enright, Catherine McDonnell, Ann Scudder, Mrs MWilson, and the Wellcome Foundation. The objections concerned a proposed road link between the M25/A2 junction and the town centre. I Summary of Objections ! 7.10.7 The whole project was ill-conceived and would be detrimental to the south-east part of the town. Problems on Park Road would be transferred to t Darenth Road, including' those caused by lorries. Residents along Darenth Road would suffer from the extra traffic which would produce environmental disbenefits including noise, vibration with the risk of structural damage, fumes, health and I safety, limitations on residents' on-street parking, and loss of visual amenity. 7.10.8 The proposal would either negate the impact of the northern bypass or alternatively, the opening of the northern bypass would render improvements to Darenth Road redundant. Before proceeding, it would be better to wait till the Northern By-pass was open, and judge the results. 7.10.9 The scheme would introduce more traffic into Dartford town centre leading to greater congestion. It would also attract unnecessary traffic to Darenth Road, by using it as an alternative access to the Dartford river crossing. The cost was not justified as queues only built up at peak times and improvements to the local highway network could be carried out instead. 7.10.10 The proposal would affect the open sports ground, and reduce the quality of life for local people. 7.10.11 The scheme was ambiguous in that it did not show a proposed alignment for the new road. The Council's Response 7.10.12 The council sought to encourage the provision of the Darenth link road but this should not be interpreted as promoting a particular detailed option. The proposal would enhance access to the town centre whilst not becoming a through route. At all stages it would be subjected to environmental scrutiny, and comparisons between alternatives would be carried out. 7.10.13 At present access to Dartford from strategic routes to the south-east was dependent on junction lB on A282. All traffic from this junction to Dartford used a short section of Princes Road and then access to the town centre was by means of substandard roads. 102 7.10.14 Recent improvements to the Dartford river crossing approach roads had substantially reduced.the likelihood of significant delays in queuing there. The use of local roads as an alternative access to the river crossing was therefore considered unlikely. 7.10.15 The Dartford Northern By-pass would reduce traffic within the town centre. The purpose of the Darenth Road link was to provide a much improved access to the town centre from A2/M25. It would not encourage traffic to use town centre roads, and traffic management measures would be available to ensure that that would not happen. 7.10.16 No detailed studies had been carried out in order to prepare an alignment but any study would seek to ensure the mitigation of the impact new roads may have on the environment. 7.10.17 Representations from Forte UK Ltd supported the policy on the grounds that the proposal would improve access to Dartford town centre. Conclusions 7.10.18 The proposed link road comprises two elements. The length between the M25/A2 junction and Princes Road would lie in a predominantly rural area, and the other section connecting the town centre with Princes Road is identified as running to the west of the existing Darenth Road. The land to the west of Darenth Road is used as a private recreation ground. 7.10.19 The section south of Princes Road would provide access to the trunk road system for what is currently the largest employment zone in the borough, and which is to be enlarged as one of the local plan proposals. An extension into the town centre would be a logical highway provision. It is likely that the provision of a new link road from the motorway to Princes Road would in any event lead to additional traffic using Darenth Road whether it is improved or not. I therefore support the concept of a new/improved link road between the M25/A2 junction and the town centre. None of the existing or other proposed new road links would adequately serve the southern part of the town centre. 7.10.20 The timescale on this proposal is not clear. A lead time of eight years was mentioned, which could create blight and uncertainty for a considerable period of time. It does not appear to me that the proposal is sufficiently advanced for the council to apply a safeguarding policy, and I consider that reference in the local plan to the alignment of the road could be misleading and create uncertainty in the area. In my opinion, it is tantamount to a diagrammatic line (PPG12 para.5.35 refers). I also consider that there is some ambiguity between the reference to the route in Policy Tl4 and the statements in the last two sentences of paragraph 7.3.15. llsqwrpdetign 7.10.21 I recommend that paragraph 7.3.12 and Policy Tl4 be modified to delete reference to the alignment of the proposed road and its proximity to Darenth Road. A consequential modification to paragraph 14.3.9 is also recommended in Chapter 14. 103 POLICY Tl5 \lritten Objection Nos 254. 255 7.11.1 Objection No.255 was made by the Wellcome Foundation Ltd, and Objection No.254 by Rritannic Assurance, was withdrawn by letter dated 7/5/92. Summary of Objection 7.11.2 The proposed line of the town centre link roads would lead to the demolition of important buildings, and the proposed route should be reconsidered. While having no objection in principle, to improvements which would reduce pedestrian/vehicle conflict in Market Street and Lowfield Street, the plan should include justification for the route, in addition to merely showing the preferred line. 7.11.3 Environmental improvements could be obtained in High Street an~ Market Street by way of traffic calming and similar techniques without the need to construct the new road with the consequent loss of buildings. Pending full evaluation of alternatives, the specific improvement line should be deleted from the Proposals Map and the policy modified. The Council's Response 7.11.4 There was a need for improved highway arrangements within the south-east quadrant of the town centre. There was considerable pedestrian/vehicular conflict, and the frontage premises were served from the main carriageways. The roads were subject to delays at peak times, and increasingly during the day when capacity was lost through parked vehicles. 7.11.5 The alignment shown on the Proposals Map would meet the traffic requirements of the town centre for the plan period. It would also allow better access for public transport facilities, and permit their better distribution within the area bypassed by the new proposals. The proposal showed the best alignment involving the minimum disturbance to existing properties, and was adopted by the highway authority after extensive consideration of a number of alternatives. During the plan period, issues would be carefully studied and details submitted for public consideration. 7.11.6 It would not be reasonable or practical to safeguard land for a road without specifying its route on the Proposals Map, and the current proposal had reached a stage where it was considered to be the optimum route for this road and · worthy of safeguarding. Conclusions 7.11.7 I note from the report to the Committee of 11 September 1990, that there were a considerable number of reported accidents in the south-east quadrant of the town centre, which would indicate that an improved road system would be justified on safety grounds. The preferred route shown on the Proposals Map is one of several options considered by the council, and utilises Market Street and a linear car park for much of its length. It is a somewhat tortuous alignment involving two right angle bends, but any improvement on this would have an adverse impact on Central Park and possibly a greater impact on the objector's property. 7.11.8 The western part of the alignment as shown, passes through an area to be redeveloped, and few buildings of note either at the western end or fronting Market Street or High Street would be affected. An attractive building within 104 the grounds of the objectors would require to be demolished. The current use of the building is not clear, but I understand that it was formally used as a gymnasium but has now been replaced by a new one. 7.11.9 The choice of an alignment for any new road involves a balance between the needs of the traffic, a satisfactory alignment, and the impact on amenities and buildings. It appears to me that the route shown on the Proposals Map achieves the best balance of these various factors, and alternatives to it would either not satisfy the traffic needs, or have what I would regard as a greater environmental impact. This sector of the Town Centre Ring Road comprises two new links, the western one being of the higher priority. I understand that both links are candidates for construction during the plan period, and that the highway authority will accept blight notices on the published scheme. I can see no reason to modify either Policy Tl5 or the Proposals Map. Beggmegsl•tion 7.11.10 I recommend no change to Policy Tl5 as a consequence of this objection. POLICY Tl6 Written Qbiections Nos 256-258 Representatipn Np R67 7.12.l The objections were made on behalf of Blue Circle Properties Ltd. Objection 256 concerned the re-alignment of B255 between London Road and Watling Street, and objections 257 and 258 concerned references to funding of road improvements. Summary of Objections 7.12.2 Although the area of land shown for the road closely followed the layout ·which had been discussed at the Bluewater Public Inquiry, it may prove necessary during the detailed design stage, to adjust the precise layout. This possibility should be referred to in the supporting text to Policy Tl6. 7.12.3 Reference to the mode of funding should be deleted from the policy in order to bring the local plan in accordance with central Government advice which required that policies should relate directly to the use of the land. If considered necessary, the reference should be included in the supporting text. 7.12.4 For consistency reference to funding under Tl6(b) should be deleted. The Council's Response 7.12.5 New road proposals of this nature were almost invariably subjected to minor variations dependent upon precise design requirements. No amendment to the text of the plan was necessary. 7.12.6 It was accepted that as the policies related to safeguarding of land, it would be more appropriate to refer to funding in the preceeding explanatory text rather than in the policies themselves. A suggested change to the policy and preceeding paragraph was suggested. 7.12.7 Colyer Greenhithe Estate supported the improvement of Bean Road and associated junctions as proposed in Policy Tl6(c). 105 Conclusions 7.12.8 Policy Tl6 provides for the safeguarding of specified highway schemes identified on the Proposals Map. As is common with all such proposals, the details of the eventual road may be different from that shown on this plan. As the intention of the policy is to prevent or defer development which could prejudice the construction of the road, I see no reason to make any specific reference in either the policy or the preamble, to adjustments in the layout of the road as a result of detail design or ground conditions. 7.12.9 I agree with the view that reference to funding within a policy primarily aimed at safeguarding highway schemes, is not appropriate. It should therefore be deleted from the policy. 7.12.10 Contributions by developers to improved road infrastructure are described in Policy T2, and further reference to it in paragraph 7.3.15 would to an extent, be repetitive. Nevertheless, Policy Tl6 specifically identifies named schemes, and in my opinion it would be helpful to have the source of the funding identified in the preamble to the policy. Reco=wxktion 7.12.11 I recommend that paragraph 7.3.15 and Policy Tl6 be modified in accordance with commended change No 28. POLICY Tl8 Representation No.68 7.13.l The Council for the Protection of Rural England strongly supported Policy Tl8, to which there were no objections. POLICY T22 Qbjection No 259 Written Qbjection No, 260 7.14,1 Objection No.259 was made by the Marine Society, and Objection No.260 was made on behalf of the Woolwich Building Society. They concerned parking vehicle standards in Appendix 17. Summary of Objections 7.14.2 Objection 259 considered the parking standards in Appendix 17 to be un reasonable, as they did not take proper account of the provisions of the 1987 Use Classes Order. The word "normally" should be inserted in Policy T22, thereby recognising that there may be exceptions. The final sentence implied that the stated exceptions were the only circumstances where a relaxation of standards would be permissible, and the policy should make it clear that other exceptions were admissible. 7.14.3 The policy should not require commuted payments in order to provide off. site parking spaces for a change of use from Use Class Al to A2. 106 The Council's Response 7.14.4 Parking standards were set by the highway authority and were intended to apply throughout the county. They were currently under review by the county council, and it was likely that the new standards would be available in time to form a modification to the local plan prior to its formal adoption; they would therefore be available for public objection if necessary. In the meantime however, it would be wrong to adopt standards different from other districts within the county. There was no objection to the insertion of "normally", as the standards would be applied flexibly if circumstances so required. 7.14.5 The council was prepared to accept an allowance for the previous use of the premises even when such parking was not provided, which could be used to offset the car parking requirements for an alternative use. In the case of the change between Use Classes Al and A2, the difference would only be between the provision of one space per 18 sq.m for Use Class Al and one car parking space per 20 sq.m of floor area for Use Class A2. Unless the building were to be substantially increased in area, the provision of additional car parking space whether physically or in the form of a commuted sum, would not normally be required. Conclusions 7.14.6 The preamble to Appendix 17 recognises that the current vehicle parking standards have been prepared by the county council and adopted throughout the county; it also states that they are subject to review by the local planning authority in conjunction with the county council. I do not consider that Dartford Borough Council can act unilaterally in this matter. The insertion of "normally" in Policy 22 would accord with the wording of structure plan Policy Tll, and in my opinion would be appropriate as indicating that standards will be applied unless there are circumstances in any particular case which justify an exception. I also consider that separating the final sentence from the earlier part of Policy T22 would remove any doubt over whether exceptions are permitted in addition to the two stated special circumstances. 7.14.7 The current wording of the policy in the deposit version of the plan does not in my view, make it clear that the calculation of the parking require ment for a change of use would take account of the existing use; the policy only takes account of any existing parking facilities. It appears to me that as currently worded, a change of use from Class Al to A2 where no existing parking facility exists, would require parking to be provided for the proposed A2 use. In my view this would go beyond the advice in Circular 6/91. 7.14.8 I therefore consider thst the policy should be modified so that account should be taken of the existing use as well as any existing parking facilities. lappmepdetipN 7.14.9 I recommend that: 1. the word "normally" be included in Policy T22 after "should" and before "include"; 2. the last sentence in Policy 22 co1111Dencing "The adopted parking standards ..."should form a separate paragraph; 3. Policy T22 be modified by the deletion of the second sentence and the substitution therefor of a statement to the effect that for changes of use, calculation of the parking requirement will take 107 account of the existing use of the land and any existing parking facilities (whether on or off site, provided for the use of the land. POLICY T24 Written Objection No.262 7.15.1 The objection was made by Miss D M Goldsmith and concerned parking in the town centre. Summary of Objection 7.15.2 Whilst generally supporting the parking policy for the town, the plan should identify (a) an inner zone within which visitors' short term parking would be sllowed at controlled locations, and residents only car parking schemes established; (b) an outer zone within which long stay car parks with park and ride facilities would be provided at the point of entry into the inner zone; (c) special car parking and/or park and ride facilities should be made available for the disabled and wheelchair users. The Council's Response 7.15.3 Policy T25 which encouraged out of town locations for long stay car parking provision, and for it to be well related to public transport, together with the preamble in paragraph 7.3.24 met the main thrust of the objection. Conclusion 7.15.4 The pressure for long stay parking facilities in the town centre is recognised in paragraph 7.3.23, and the underlying strategy to discourage long stay parking in the town centre is stated in paragraph 7.3.24. Policy T24 identifies locations for additional public car parking, and in my opinion, Policy T25 meets the substance of the objection. Written Qbjection No, 264 7.15.5 The objection was made by the Wellcome Foundation Ltd, and concerned the provision of car parking within the town csntre. SWlllllary of Objection 7.15.6 The policy stated that additional public car parking would be provided at and adjoining, Darenth Road car park. The Council however currently occupied the site on a short term lease which would expire well before the end of the plan period, The plan should specifically indicate the location of the additional parking referred to in Policy T24(c), or else reference to it should be withdrawn. The Council's Response 7.15.7 The council were anxious to supplement parking provision in this sector of the town centre but specific proposals to achieve this had not yet been drawn up. In view of the imprecise nature of the proposal, it was agreed that it would be appropriate to amend reference to the site in the policy and the preamble. Changes to the policy and to the preceeding paragraph, were recommended to me. 108 Conclusions 7.15.8 The suggested modifications to Policy T24 and its preceeding paragraph, would have the effect of differentiating between specific proposals and longer term objectives. This would appear to correctly represent the situation and to meet the objection. Boson pdettgp 7.15.9 I recommend that: 1. Paragraph 7.3.24 and Policy T24 be modified in accordance with commended change No. 31; 2. The Town Centre Inset Map be modified in accordance with commended change 76. A consequential modification to paragraph 14.3.12 is recommended in Chapter 14. POLICY T26 Written objection No.265 7.16.1 The objection was made by Miss D M Goldsmith, and concerned parking in the town centre. Summary of Objection 7.16.2 The plan should tackle motorists' unwillingness to pay a parking fee irrespective of the availability of spaces. The Council's Response 7.16.3 Matters such as residents' parking schemes and parking charges are not matters for a local plan. Conclusion 7.16.4 I do not consider that whether motorists are willing or unwilling to pay a parking fee is in itself a matter for the local plan which is concerned with the use of land, though it can be affected by the relative provision of on-street and off-street parking facilities. Illegal avoidance of payment is the subject of other legislation. Bogg pdegign 7.16.5 I recommend no change to Policy T26 as a consequence of this objection. POLICY T29 Written Ob1ections Nos 266. 267 7.17.1 Objection No.26' was made by the Royal Mail, and Objection No.267 by London Transport. They concerned the proposed pedestrianisation of Lowfield Street. 109 Summary of Objection 7.17.2 No reference was made in either the policy or the supporting text, to provisions for access for the purposes of servicing the pedestrianised area. In the absence of rear servicing facilities in Lowfield Street, direct access via the highway was essential for the purposes of maintaining delivery of mail. 7.17.3 Following discussions between the council and London Transport, Objection No.267 was withdrawn by letter dated 19/5/92. The Council's Response 7.17.4 There was no intention to prevent deliveries of Royal Mail, and the existing pedestrianisation of High Street presented no problems of this kind. 7.17.5 The precise nature of vehicle exclusions from the proposed pedestrianisation scheme would be determined at the detailed planning stage, and this was a traffic management matter capable of being dealt with through traffic orders. Conclusions 7.17.6 The pedestrianisation of Lowfield Street, although contained within a policy of the local plan, would still be subject to the necessary statutory processes. The extent and nature of traffic prohibited within the street would form a part of that process, and I dol)ot consider that it is necessary for this to form part of the policy. Boer pdatigp 7.17.8 I recommend no change to Policy T29 as a consequence of this objection. POLICY T32 Representation No.69 7.18.l The Council for the Protection of Rural England strongly supported the encouragement to cycling in Policy T32, to which there were no objections. 110 OBJECTIONS TO CQMMENDED CHANGES COMMENDED CHANGES NOS 26 AND 29 Written Obiections Nos CZ and CB 7.19.1 The objections were made on behalf of Blue Circle Properties Ltd and concerned proposed modifications to Policies T2 and T21. Summary of Objections 7.19.2 The proposed additions to Policies T2 and T21 were unnecessary, bearing in mind the provisions of Policy Tl9. 7·.19.3 The preamble to Policy T2 dealt with the need to provide adequate infrastructure in order to realise the development potential of the area, and addressed the Council's expectations in relation to the investment programmes and priorities of the relevant agencies. It did not address the relationship between the development proposals and the transport infrastructure which were addressed elsewhere in Section E. The proposed amendment was therefore inappropriate in the context of the preamble, and unnecessary since the point was covered by Policy Tl9. 7.19.4 The preamble to Policy T21 dealt with situations where the development was acceptable in principle but where the network was demonstrably inadequate. In this context, the proposed modification was unnecessary and inappropriate. 7.19.5 In addition to Policy Tl9, several other policies also referred to a need for developers to demonstrate adequate highway or infrastructure capacity. The Council's Response 7.19.6 The Commended Changes to Policy T2 and T21 complemented changes to Policies El, E2 and E3, and were developed following lengthy discussion with the Department of Transport and the Highway Authority, concerning the Department's objection to Policies El, E2 and E3. The Department had subsequently indicated that the commended changes met their objection. 7.19.7 The logic of Policy Tl9 was entirely appropriate in order to protect the existing highway system and its users from excessive induced traffic and increased danger. However this was a negative policy, and there should be more specific positive policies to reflect the enabling thrust of the plan to achieve the development proposals for the borough. This positive attitude was expressed in Policies T2 and T21, but the commended changes were necessary for two basic reasons. 7.19.8 Firstly the local highway system had a major connection with the trunk road A282. Whereas the county council as highway authority could only judge the highway impact of new development at the year it was completed, the DTp as highway authority for trunk roads, had the responsibility to ensure that there would be adequate highway and transport capacity 15 years after the opening of development. 7.19.9 Secondly, the major new development proposals for the borough related to the South Thames-side Development Route (STDR) and the capacity of the route was a sensitive issue. This was compounded by the fact that the form of development proposals now coming forward was changing from those assumed at the time the road scheme was being developed. There had been a general shift away from the 111 industrial proposals it originally envisaged, to those based on Bl development and residential use. The differing traffic patterns of these developments needed careful study to ensure adequate transport provision was provided in the short and medium term. 7.19.10 The critical importance of the planned transport system and its sensitivity in both local and national terms, meant that the commended changes giving clear statements within Policies T2 and T21, were logical and necessary. Conclusions 7.19.11 Policy T2 is contained in the sub-section dealing with transport strategy and relates to transport infrastructure generally which could include public transport facilities, whereas Policy Tl9 deals explicitly with the capacity of the highway network. The policy has a positive tone which I regard as appropriate in a growth area, and I regard the proposed addition to the policy as appropriate within the transport strategy section. In my opinion however, the modification should not require adequate capacity to be demonstrated in both the existing and the planned transport infrastructure; this is inconsistent with other policies wherein improvements can be provided where the existing infrastructure is inadequate, 7.19.12 Notwithstanding reference elsewhere to the need for infrastructure to be adequate to serve proposed development, I regard the provisions of Policy 21 as proposed to be modified by commended change No.29, as appropriate at the conclusion of the section dealing with the relationship of development to the highway network. The section starts with the presumption against proposals for development in circumstances where the highway network could not properly serve the proposed development; this is contained in Policy Tl9 which it is stated in the preamble, should be read against other policies, one of which is Policy T21. Policy T21 sets out how inadequacies in the highway network could be overcome in order to serve development which is otherwise acceptable. As worded however, the policy requires development proposals to demonstrate the adequacy of the existing infrastructure where the preamble refers to the means by which inadequacies should be overcome. I have therefore re-worded the proposed modification. ltso=mktt,gn 7.19.13 See reco1111110nded modifications to Policies T2 and T21 above. 112 CHAPTER 8 - DERELICT AND DESPOILED LAND, MINERALS AND WASTE DISPOSAL BACKGRQUND 8. l.l The borough has a long history of mineral extraction. In particular, sand and gravel have been extracted from near the Darent Valley, and chalk extraction has taken place over a wide area to the east of Dartford. There are currently several areas of derelict and despoiled land, and others have been recently restored. The scale of dereliction has been sufficient to make the borough one of the worst affected areas in the region. 8.1.2 The quality and pace of restoration have improved over recent years but there remain several problem sites. Inert fill material is not in plentiful supply. 8.1.3 Under the terms of the Planning and Compensation Act 1991, a local plan is not compliant if it contains policies on Minerals or Waste Disposal. Such policies were contained within the deposit version of the plan, and in order for the plan to be compliant, changes were commended to me which would delete those policies. 113 ...... ------· POLICIES OBJECTIVES (PARAGRAPH 8.2.1) AND POLICY DLl Written Qbiectious Nos 268-271 Representation No.R70 8.2.l Objections Nos 268, 270 and 271 were made by Thames Water Utilities, and concerned ground water pollution. At the inquiry it was confirmed that Objection No.269 was not, in fact, an objection. Summary of Objections 8.2.2 The objectives of the council's policy to encourage suitable development of derelict and despoiled land was recognised but there existed the possibility of ground water pollution from site works and developments on contaminated land. Such developments should only be carried out after consultation with the relevant water authority. Reference should also be made to the National Rivers Authori ty's ground water protection policy. The Council's Response 8.2.3 The concerns were acknowledged, and an additional objective in relation to derelict and despoiled land, was proposed, together with an amendment to Policy Bl which was of general application. A new paragraph added to the preamble to Policy DLl was also recommended. 8.2.4 English Nature supported the reference to nature conservation interest contained in the restoration policy. Conclusions 8.2.5 I agree with the commended changes put to me which would meet the legitimate concerns of the water utility. "sOPP"'Y'Uion~ 8.2.6 I recommend that: 1. Paragraph 8.2.1 be modified in accordance with commended change No.32; 2. A new paragraph be inserted after 8.3.2 in accordance with commended change No.33, and subsequent paragraphs renumbered; 3. Policy DLl be modified in accordance with commended change No.34 (with "an.v nature gonservation interest" underlined). See also modification to Policy Bl in Chapter 12 below. POLICY DL2 Hritten Objection No, 272 Representation No.R71 8.3.1 The objection was made on behalf of Colyer Greenhithe Estate, and concerned the restoration of St. James' Lane Pit. 114 Summary of Objection 8.3.2 Although a large void, the pit could be filled to an appropriate level within the local plan period, The local plan should therefore provide an indication as to the site's potential use once the pit had been filled. The Council's Response 8.3.3 It was agreed that the plan should acknowledge the possibility of built development on the site when filled, and an addition to the paragraph preceeding Policy DL2 was recommended. 8.3.4 The objector had confirmed that the proposed change would overcome the objection, and had also written in support of the priority given to the pit's restoration, agreeing that it should be filled with inert material. Conclusions 8.3.5 In my opinion an indication as to the site's potential for future use could influence the nature of filled material to be used and how it is placed. I therefore agree with the commended change which takes this into account. Reso==vkt;lgn 8.3.6 I recommend that paragraph 8.3.3 be modified in accordance with commended change No 35. POLICY DL3 Written Objectipn Np. 273 8.4.l The objection was made on behalf of Bexley Metals Ltd/Easy-Load Ltd, and concerned land at the Gun Club. Summary of Objection 8.4.2 The DL3 policy area should coincide with the disused workings and exclude the area of established commercial uses. The Council's Response 8.4.3 The point of the objection was agreed, and a change to the Proposals Map was recommended, though since the conclusion of the inquiry, boundary changes have been inroduced which will remove the DL3 site from the plan area. Conclusions 8.4.4 The policy applies to the restoration of former mineral sites, and does not relate to the adjacent area of commercial uses. I thus agree with the recommended change, and although the changes to the borough boundaries will remove the quarry site from the plan area, the adjoining land in commercial use should not be subject to Policy DL3, 115 Written Objection No. 274 8.4.5 The objection was made by the Kent Trust for Nature Conservation and concerned the restoration of Craylands Lane Pits, Bean Clay Pit and Bowmans Pit. Summary of Objection 8.4.6 All these sites were designated either as nature conservation areas or Public Open Space in the Local Plan. Some limited restoration at the pits would be acceptable, but should be limited to the objectives of public safety and of improving their nature conservation value. The Council's Response 8.4.7 Environmental benefits would result from the appropriate restoration of the sites. The policy would be applied to the particular characteristics and circumstances of each site but it would be beneficial to encourage the restora tion of these areas. Any proposals would also be subject to Policy DLl which made specific reference to nature conservation interests. Conclusions 8.4.8 Policy DLl is a general policy relating to restoration of derelict, despoiled, and partially restored sites to appropriate and beneficial after uses. Read in conjunction with Policy DL3, I consider that any proposal for restoration and after use would be required to take due account of any nature conservation I interest. 8.4.9 Furthermore, I note that the Craylands Lane Pit is also subject to Policy RT16 which has a specific reference to nature conservation interest. Bowmans Pit is also subject to Policy RT13, and as such can only be used for appropriate open space purposes. Bean Clay Pit is subject to Policy RTll which proposes a tourist visitor centre. In my opinion, these site specific policies which are additional to Policies DLl and DL3, are sufficient to ensure that the site when restored, will take full account of their nature conservation value, 8.4.10 I do not consider that any change to Policy DL3 is required by this objection. Roggppeps!etlgp 8.4.11 l recommend that the Proposals Map be modified by the deletion of [DL3] from the area of commercial uses adjoining the quarry at the Gun Club site (commended change No. 77 refers). POLICIES Ml, M2 AND WDl Written Obiections Nos 275-278,280 and 345 Representations Noa RZ2-R74 8.5.1 The objections were made by Thames Water Utilities, and on behalf of Blue Circle Properties Ltd, The Wellcome Foundation and Thames Polytechnic. 116 Summary of Objections 8.5.2 Reference to underground water supplies should be included in Policy Ml, and the policy should include reference to other measures to mitigate environmental impact. Policy Ml should also maintain the objection to mineral extraction at Dartford Fresh Marshes. 8.5.3 Minerals snd Waste Disposal policies should not be included within the plan. The Council's Response 8.5.4 Policies Ml, M2 and WDl would be deleted by commended changes to the plan in order to make it compliant. The other matters referred to in the objections could not therefore be accommodated. 8.5.5 English Nature and the Council for the Protection of Rural England supported the references to conservation interests in the policies. Conclusions 8.5.6 The deletion of these policies is necessary in order for the plan to be compliant. I therefore agree with the commended changes. Bo;g~•tinnp • 8.5.7 I recommend that: 1. Policy Ml be deleted in accordance with commended change No.36; 2. Policy M2 be deleted in accordance with commended change No.37; 3. Policy WDl be deleted in accordance with commended change No.38. POLICY WD2 Written Ob1ection No. 281 8.6.1 The objection was made on behalf of Blue Circle Properties Ltd. Summary of Objection 8.6.2 The policy should be deleted as it related to minerals and waste disposal. 8.6.3 In reply to the council's response, the objector stated that as a consequence of the suggested change, the landfill site once restored would no longer be derelict or despoiled, and the categorisation would therefore be inappropriate. The policy should come under a separate heading such as "treatment and restoration". The Council's Response 8.6.4 The policy dealt with development on former landfill sites generating gas, rather than minerals or waste disposal matters. It was therefore proposed to re-categorise the policy as a derelict land policy. 117 8.6.5 Consequential changes to the text would be necessary as a result of the suggested change. These consequential changes would be a matter of editittg in the final version of the plan, and would not affect the principle or the policy. Conclusion 8.6.6 Although Policy WD2 is headed Waste Disposal, I consider it an appropriate policy for the local plan, and I support its redesignation as a derelict land policy. I am satisfied that this modification, together with appropriate editing of the preceding paragraph, would be a logical modification to the plan. Whether land contaminated by gas is literally derelict or despoiled is a matter of interpretation, but the current heading "Derelict and Despoiled Land" appears to have the intention of separating that section from other sections headed "Minerals" and "Waste Disposal". Rac?DP"Vktiop 8.6.7 I recommend that: l. Policy WD2 be modified in accordance with commended change 39; 2. Paragraph 8.3.ll be renumbered and appropriately edited. 118 ABSENCE OF POi.ICY LACK OF PROVISION FOR AN AGGREGATE WHARF 'i I Written Objection No. 279 8.7.1 The objection was made by Kent County Council. Summary of Objection 8.7.2 The policy should include the provision of an aggregate wharf at Stone Marshes or at a suitable alternative location which could be rail linked and was well related to the strategic highway network. Such a proposal was contained in both the Kent Structure Plan and the Deposit Draft of the Kent Minerals Local Plan. 8.7.3 The county relied significantly on imported aggregates, particularly of hard rock, and sought to encourage the import of construction aggregates by making provision for adequate depot and wharf facilities to receive minerals from sources which lay outside the county. Rail and/or water connections were essential if Kent's roads were not to have the burden of road vehicles being used for bulk imports from outside the county, although the distribution of material into the local market would normally be by road. 8.7.4 The Stone Marshes area was not yet fully developed, and was a key point in Kent where the primary road, river and railway networks came together. It would be an appropriate location for a major generator of heavy goods vehicles such as an aggregates importing facility, and there was no planning reason to oppose the proposal. Given up-to-date planning controls, a modern development could co-exist with more "upmarket" industrial or warehousing developments. 8.7.5 A key issue here was direct access to the primary road network at the Dartford crossing. The location at Stone Marshes was identified on the basis of the current extent of the South Thames-side Development Route (STDR) and its eastwards further extension, where suitable locations could be identified along the river in future reviews of the plan. The Council's Response 8.7.6 Policy MWD3 of the structure plan expressed a presumption in favour of proposals for marine terminals on appropriate sites, but did not specify any particular location. I.and at Crossways (Stone Marshes) was identified in the deposit version of the Kent Minerals Local Plan, as a possible wharf site. In paragraph 8.3.7 of the Dartford Local Plan, the council acknowledged that the need for aggregates meant that the supply may have to be supplemented by the import of supplies either through a rail head or through a wharf facility on the River Thames. 8.7.7 The council had strong reservations about the suggested site at Crossways. Given the quality and nature of the surrounding commercial develop ment, the siting of an aggregate wharf there would have a considerable impact upon that development. A wharf facility in the Crossways development would conflict with regional, structure plan and local plan objectives for the East Thames corridor. 8.7.8 The proposal would reinforce the predominance of traditional mineral extraction industry to the detriment of growth sector activity in the corridor, 119 and would detract from the environmental quality of the area, specifically that of the riverside. It could also prejudice investor and developer perceptions in relation to a key growth point to the north and east of Dartford. 8.7.9 Consideration should be given to the establishment of a new facility in the area to the east of the Empire Paper Mills in the vicinity of the disused Swanscombe Cement Works which would be a far more suitable location, and one where any environmental impact would be minimised. The identification of such a site would enable environmental safeguards and proper access arrangements to be incorporated as integral elements in the provision of a wharf facility. 8.7.10 The building of a wharf would not be a practical option since the river frontage land at Stone Marshes was fully committed. In any event, it was doubtful whether it would be appropriate to include such a policy in a local plan, given that district wide local plans which included minerals policies, were non-compliant. Conclusions 8.7.11 Considering first the matter of whether it would be appropriate to include a policy on an aggregate wharf in the local plan as distinct from a County-wide minerals local plan, I am of the opinion that such a policy would be more appropriate in the Dartford Local Plan. The minerals content of a development plan as stated in MPGl, is that it should express the strategy for mineral working and related development. Paragraph 21 of MPGl indicates those items to be included in development plans relating to minerals, and they all appear to me to relate to the working of land and the winning of minerals, and the subsequent reclamation and after-use. The location of such activities is pre-determined, whereas the location of a wharf is a land-use matter. A local plan may also indicate what the council's attitude would be towards any mineral application, or what considerations would shape their attitude when commenting on these applications to the Mineral Planning Authority. 8.7.12 The local plan expresses reservations about the proposal in the deposit version of the Kent Minerals Local Plan, and expresses a preference for the establishment of a new facility in the area to the east of the Empire Paper Mill site. The plan also states that the identification of such a site would enable environmental safeguards and proper access arrangements to be incorporated as integral elements in the provision of a wharf facility. In the absence of any identified site, an application for a wharf would be considered on its merits against the presumption in favour of such a proposal in the County Structure Plan Policy MWD3. 8.7.13 I do not have the county council's full statement of reasons for preferring the site at Stone Marshes, but it appears to me that a proposal for a wharf for the purposes of importing aggregate would not be compatible with the local plan Policies E3 and RT8 which provide for a major business park and tourist accommodation respectively. Furthermore, the river frontage land at Stone Marshes is already fully committed, and it therefore appears unlikely that such a proposal would come forward. On the other hand, there could be scope for such a facility in the proposed policy area APl where both development and highway proposals are at an early stage of consideration. Although further from the River Thames crossing, the STDR and other highway improvements would provide a satisfactory link to the trunk road system. 8.7.14 I make no recommendation on this objection as the current situation is that any planning application would be considered on its merits having regard to the presumption in favour of such a proposal in the structure plan, and the council's observations on the relative merits of Stone Marshes and the alterna tive sites to the east. Should the deposit version of the minerals local plan be 120 adopted in its current form, that plan would to an extent be in conflict with the Dartford Local Plan, in which case the provisions of the later plan would prevail. I consider that this would be an unfortunate situation, and it would clearly be in all parties' interests for the council and the mineral planning authority to have a consistent approach to this situation. Such negotiations may however, be lengthy and possibly controversial, and could delay the adoption of the local plan. For that reason, I do not propose to make any recommendation on this objection. 121 CHAPTER 9 - RECREATION AND TOURISM RACKGROIJND 9.1.1 The structure plan regards tourism as of major importance in Kent. The channel tunnel is likely to lead to more opportunities but they could alter the pattern of demand or increase pressure on the environment. Policy TR6 adopts a positive attitude to proposals for new attractions and facilities, subject to environmental safeguards. Another objective of the structure plan is to improve facilities for informal recreation, particularly sites which are accessible by public transport as well as by car. 9.1.2 The local plan identifies the importance of the River Thames as a recreation facility, which historically has been severed from its hinterland by commercial riverside development. Opportunity has been taken in the plan to improve accessibility to the river. 9.1.3 The council sees substantial scope for extending the provision of recreation and tourist facilities in addition to the River Thames. The borough has good accessibility, and a correspondingly large catchment area. Improved leisure facilities are seen as giving a positive impact to the image of the borough, thus improving investor perception of the area and thereby bringing benefits for the local economy. 9.1.4 The council commisioned a study by consultants on a leisure strategy, and they identified scope for a range of facilities. The Sport's Council's Regional Recreation Strategy specifically identified Dartford as a high priority area for the provision of an indoor sports centre. 122 ~------~-- POLICIES PARAGRAPH 9.2.1 OBJECTIVES Written Objection Ng. 282 9.2.l The objection was made on behalf of the Ramblers' Association - Kent Area. Summary of Objection 9.2.2 There should be provision of pedestrian routes linking the town centre to the countryside wherever possible. The Council's Response 9.2.3 The plan recognised the general importance of improving the public footpath network, and Policy RT9 sought to achieve this. 9.2.4 A particularly valuable achievement in this respect had been the establishment of the Darent Valley footpath which ran south from the town centre alongside the River Darent, and which already provided a link between the town centre and the countryside. The preamble to Policy RT9 referred generally to the need for additional paths and to the specific objective of continuing the Darent Valley footpath northwards from the town centre to the River Thames. 9.2.5 In the circumstances, the matter of links between the town centre and the countryside was already appropriately addressed through the Local Plan as far it was practical to do so. Conclusion 9.2.6 Policy RT9 seeks to improve the network of rights-of-way, and the preamble in paragraph 9.3.7 recognises that the rights-of-way network generally needs to be improved. In my opinion however, this policy would be strengthened if improved access to the countryside were a stated objective of the policy, as it is in the structure plan. I therefore consider that the policy could be improved by an additional objective in paragraph 9.2.1. Bos•g pdatigp 9.2.7 I recommend that paragraph 9.2.l be modified by the addition of: 11 Cel to seek to impxoye access to the countxyaide", and consequent modifications to (c) and (d). POLICY RTl Written Qbjectiqn No· 283 9.3.1 The objection was made on behalf of Colyer Greenhithe Estate, and concerned land at Stone Lodge. 123 I Summary of Objection 9.3.2 Whilst supporting generally Policy RTl which identified the site as being suitable for major recreational, leisure and associated development, the site could also be suitable for a range of employment uses within the local plan period. Consideration should therefore be given to allocating part of the site for employment use. The Council's Response 9.3.3 Ample land was allocated, committed or developed to meet structure plan economic development guidelines. There was no justification for identifying land at Stone Lodge on this basis. The site was already well established as a recreational area, and the opportunity existed to enlarge that provision and develop the area into a major recreational complex of regional significance, as provided for by Policy RTl. The council was actively seeking a partnership with developers to achieve thi~. 9.3.4 Recreational development would also bring more employment to the area and accord with the aim of the plan as set out at paragraph 2.3.8 which sought to widen the employment base through the encouragement of commercial, industrial, leisure and tourist related development. Conclusions 9.3.5 There is no dispute between the parties that the site has good accessibility and is well located for development. In view of the area of land already allocated for industrial or business uses, and the opportunity to expand the existing recreational facilities on the site, I can see no reason for changing the allocation of this site. Iese gtattgn 9.3.6 I recommend no change to Policy RTl as a consequence of this objection. POLICY RT3 Representation No RZS 9.4.1 Forte UK Ltd supported the proposal for a sports· complex, as it would complement their proposal for an hotel. There were no objections to this policy. POLICY RT3 Objection No. 284 9.5.l The objection was made by the Council for the Protection of Rural England, and concerned the provision of golf courses. Summary of Objection 9.5.2 In view of the recent proliferation of golf course applications, further provision for golf courses would risk changing the attractive countryside for a manicured landscape, and generally lowering the quality of the landscape over an unacceptably large area of the borough. 124 9.5.3 There would be an unacceptable increase in new buildings in the countryside, and public access to the countryside would be affected. Wildlifb habitats would be disrupted and destroyed. 9.5.4 More golf courses would cause additional traffic congestion on country lanes, and lead to an unacceptable demand for resources, in particular for water. 9.5.5 Golf clubs catered for non-residents rather than fulfilling the demand for golfing facilities of local residents. It would be impracticable to return the land to agricultural use should the need arise in future. The Council's Response 9.5.6 Many of the objector's points were recognised, and changes to the policy were recommended. These established guidelines against which planning applica tions would be considered. 9.5.7 The working party examining the provision of golf facilities on behalf of the Kent Planning Officers' Group, had identified a deficiency in provision of golf courses in the Borough of Dartford. Hence a positive approach to golf course provision was contained within the plan; the need to continue to encourage provision would be examined in the next review of the local plan. 9.5.8 The guidelines in the commended changes, together with other policies of the plan, would achieve the balance between recreational provision and protection of the countryside in accordance with PPG17. A further change was recommended which would take account of wildlife habitats. Conclusions 9.5.9 The objector broadly welcomed the changes to the policy, which included a new policy and appendix, but was disappointed that the council had not chosen to highlight some particular problems which golf courses can cause. Th~se are primarily matters of emphasis, and in my opinion the guidelines taken together with other policies in the plan, such as Green Belt policies, regarding buildings in the countryside, should be sufficient to enable planning applications to have proper regard to the need to protect the countryside. · 9.5.10 I accept the point that the proximity of the countryside within the borough to the highly populated areas of London, together with potential growth of incoming temporary and permanent residents in the East Thames corridor, as well as from the Channel Tunnel and M25, are likely to create increased demands on recreational use of the countryside in this area. The need for further provision of golf courses however, arises from a county-wide study which is based on resident population, and I do not foresee the likelihood of an over-provision of golf courses in the borough. The provision in the borough is currently less than that recommended by the Sports Council. BaprneewJetion 9.5.11 I recommend that paragraph 9.3.3 and Policy RT3 be modified in accordance with commended changes 40, 41, 42 and S7. 125 POLICY RT4 Written Qbiections Nos 285 and 286 9.6.1 The objections were made by the Kent Trust for Nature Conservation and the Royal Society for the Protection of Birds. They concerned accessibility to the River Thames. Summary of Objection 9.6.2 Whilst supporting the principle of use of and access to, the resource of the River Thames, the policy extended along the frontage of Dartford Marshes which was within a Site of Nature Conservation Interest (SNCI) and the proposal for a local nature reserve. This was an important area of inter-tidal habitat providing a rich feeding ground for wintering birds. While there was no obvious conflict with passive recreation, more active sport and leisure based facilities would be damaging. The Council's Response 9.6.3 The need for a policy safeguard against such conflict was accepted, and an amendment to Policy RT4 was proposed. Objector 285 had written expressing support for the proposed modification. Conclusion 9.6.4 I support the commended change which meets the legitimate concerns of the objectors. Resmwemr!etign 9.6.5 I recommend that Policy RT4 be modified in accordance with commended change No. 43. POLICY RT5 Qbjection No. 287 Written Qbjection No, 288 9.7.1 Objection No.287 was made by Crest Homes (Southern) Ltd, and Objection No.288 was made on behalf of F T Everard & Sons Ltd. They concerned the proposed marina at Greenhithe. Summary of Objection No.287 9.7.2 An area of 0.63 acre of land would be sufficient to allow for a marina development. There was no need to prevent alternative mixed development taking place on the remainder of the objection site. ·.·.~ Summary of Objection No 288 I' l 9.7.3 Although not objecting to the principle of a marina, the proposed marina f development would not be viable, and the allocation of the land for that purpose ' would frustrate the beneficial use of the site. A more suitable location should be found possibly as part of other river frontage developments. 126 9.7.4 The housing site 834 should be excluded from the RT5 policy area as it was in different ownership. Planning permission for housing had been granted, and no reference had been made in the permission to cross-subsidy of the marina. 9.7.5 In reply to the council's response and commended change, the objector welcomed the reference to mixed residential and marina development, but they would be negated by the requirement for the housing to subsidise the marina. Other conditions to be imposed would make the marina unviable. It was unrealis tic to burden ·a small housing development with such costs. No reference to cross-subsidy had been made when the adjoining site was developed. There was also an objection to the parking requirement for additional unspecified uses. The Council's Response 9.7.6 The provision of a marina at the Greenhithe RT5 site formed an important part of the local plan's economic regeneration strategy for the borough as a whole and for Greenhithe in particular. Experience had shown that regeneration projects based on a single use were unlikely to be successful, and that a broad mix of uses and facilities was required in order to provide for balanced and sustainable growth. 9.7.7 The council had gone to considerable expense to take expert advice on the engineering implications and the economic viability of the project. 9.7.8 Site B34 should remain within the policy area, in order to provide a pleasant outlook. 9.7.9 The commended change to the policy would clarify the criteria against which proposals for redevelopment of the site would be assessed. These were modified in response to points made at the inquiry. Conclusions 9.7.10 In determining an earlier appeal for development on the objection site, the Inspector had concluded that a marina could be provided on 0.63 acres of land. That however, was based on a specific proposal including deck parking. At that time, the deposit version of Policy RTS was taken into account, and it did not contain any reference to cross-subsidy of the marina. 9.7.11 The council considered that a marina would become viable within a period of four or five years if assistance were given with the development costs. In order to achieve this, I consider that some flexibility within a comprehensive approach to the development of the whole site, would be necessary to enable some cross-subsidy of development costs to take place. If the suggestion of safeguarding 0.63 acres for the marina, and developing the rest of the site independently were implemented, I do not consider that the necessary degree of flexibility would be available to ensure the development of a marina within the plan period. 9.7.12 It is an objective of the council's policy to maximise the facility of the river frontage, and in particular to provide a marina. The principal purpose for the use of the objection site is to promote a marina, and other development is intended to complement and facilitate its main use as a marina. In my. opinion this is only likely to be achieved by a comprehensive development of the site as a whole, in which the marina would be a key element. I therefore support the aims of the policy. 9.7.13 The Council acknowledged that the original policy lacked definition, and commended changes to the policy in order to better describe the criteria for 127 development of the site. They accepted that it may not be economical for any developer to develop the marina by itself, and the commended change reflects this. 9.7.14 In response to comments on the commended change, and other matters raised at the inquiry, further modifications were suggested. The revised commended change recognises that it may not be economical for a developer to develop the marina before receiving any revenue from the housing. The car parking requirements have also been clarified; they are in any event, below the normal requirement because of local conditions. I agree with the revised commended changes to the policy. Bocq ndatipp 9.7.15 I recommend that Policy RT5 be modified in accordance with commended change No S22. POLICY RT8 Written Qbiection No, 289 9.8.l The objection was made on behalf of Mr &Mrs Thomsett, and concerned the allocation of land for hotel use in North Dartford, east of Joyce Green Hospital. Summary of Objection 9.8.2 The proposal would harm the nature reserve to the east of Joyce Green Hospital. A more suitable site could be found on farmed land at Dartford Marshes, which would do less damage to local nature conservancy resources. The Council's Response 9.8.3 The North Dartford Economic Development Area (Policy Area El) was a suitable location for hotel accommodation which could service the proposed business park. Similar provision was already successfully operating on the Crossways Business Park. The hotel development could be provided in association with economic development, without damaging the nature conservation interests. 9.8.4 An hotel on Dartford Marshes would be divorced from the Business Park, and within the Green Belt. It would also intrude visually into an Area of Local Landscape Interest which was protected under Policy C9. The marshes were identified as a Site of Nature Conservation Interest, and as a proposed local nature reserve; they were thereby protected under Policies Cl4 and ClS respec tively. Conclusions 9.8.5 The effects of the development proposed in Policy El on the nature conservation interests are discussed under Objection No.3 in Chapter 3. The illustrative plans produced at the inquiry indicate a desire to maintain the conservation interest of the El policy area, and I can see no reason why an hotel development need harm those interests. 9.8.6 Any proposal for a new hotel to be built on Dartford Marshes would in my view conflict with the aims of the Green Belt, and also the identified nature conservation interest of the area which is a proposed local nature reserve. The designation of land as a nature reserve is intended to enhance the scientific and 128 ·------~~~~~- nature conservation value of Sites of Special Scientific Interest, and Sites of Mature Conservation Interest. Such interests are in my view, stronger here than in the El Policy area, and would be harmed by the allocation of land for an hotel with the provision of the necessary access to it. 9.8.7 I do not propose to recommend any change to the allocation of this site. Written Qbjection No. 290 9.8.8 The objection was made on behalf of the Hawkins Trust, and concerned land at Sandbanks Hill, Green Street Green. SU1111Dary of Objection 9.8.9 Land near The Ship Public House should be allocated as a touring caravan site, the need for which was recognised in the plan. The objection site was accessible to the primary road network, and'was near complementary facilities such as a restaurant and public house. It was reasonably flat and of a suitable size, and mains services were available. The Council's Response 9.8.10 The site lay in open countryside which was designated as Green Belt, and performed the function of safeguarding the countryside from encroachment of development. It adjoined an Area of Local Landscape Importance, and a caravan site would be particularly visually intrusive. The site also lay within an Area of Special Significance for Agriculture, and permanent non-reversible development associated with caravan sites, would prejudice the long term agricultural viability of the land. 9.8.11 A caravan site would impose an additional traffic burden on a road of unsatisfactory standard near an inadequate junction at Green Street Green (B260/B262). Conclusions 9.8.12 The objection site is an open field used for grazing within a generally open landscape rising towards the east. There are some trees along the frontage boundary with B260, but the countryside is generally open and there are extensive views in all directions. In my opinion a caravan site on this field would be visually intrusive in an attractive area of countryside lying within the Green Belt, and designated for protection from development which would affect the long term agricultural interests. I consider that the proposal would be an inappro priate form of development in the Green Belt. 9.8.13 Access from the site onto B260 could be obtained either directly or by means of B262. In either event, I would regard improvements to the sccess and to the junctions as necessary to serve the suggested use, and this would involve works on areas of land designated as Sites of Nature Conservation Interest. Represeptatiops Noa R76-R78 9.8.14 Forte UK Ltd supported the proposal for an hotel at Darenth Road. A Winchester & Sons and Mount York Properties Ltd supported the allocation of hotel and tourist accommodation at Besn Triangle. 129 BACQ ps\lrt.ion 9.8.15 I recommend no change to Policy RTB as a consequence of these objec tions. POLICY RT9 Written Objection No. 292 Representations Nos R79. R80 9.9.1 The objection was made by the Ramblers• Association, and concerned improvements to the rights-of-way network. Summary of Objection 9.9.2 Whilst generally supporting the intention to improve the rights-of-way network (R80), there was a need for the provision of pedestrian pathways for wheelchair users and prams. The Council's Response 9.9.3 It was agreed that this was an important consideration, and an addition to the preamble to Policy RT9 was recommended. 9.9.4 The Countryside Commission welcomed the provisions of this policy. Conclusion 9.9.5 I agree that the commended change would recognise the need to provide paths suitable for wheelchairs and prams, and thereby meet the legitimate concern of the objector. R1s91"'P"etign 9.9.6 I recommend that paragraph 9.3.7 be modified in accordance with commended change No.45. 1 POLICY RTlO Representations Nos R81 apd R82 9.10.1 The Ramblers' Association amd the Countryside Commission supported the aim of this policy. There were no objections to it. POLICY RTll Written Objection No.293 Representation No.R83 9.11.l The objection was made by Thames Water Utilities, and concerned the proposed visitor centre at Hawley Road, Hawley. 130 Summary of Objection 9.11.2 The proposal lay in the vicinity of the Darenth Pumping Station, and it could pose a risk to underground water supplies. A reference to the National Rivers Authority's ground water protection policy was requested. The Council's Response 9.11.3 The importance of this issue was recognised, and a change to the general development control Policy Bl was recommended to overcome this objection. 9.11.4 The Ramblers' Association supported the provisions of this policy. Conclusion 9.11.5 I agree that the commended change is necessary, and being of general application, should be contained within Policy Bl. RtpmrM1pdatign 9.11.6 See recommended modification to Policy Bl in Chapter 12. POLICIES RT12, RT13 AND RT14 Representatigns Nos R84~R86 9.12.1 The Ramblers' Association supported the provisions of these policies to which there were no objections. POLICIES RTlS AND RT18 Written Objections Nos 294 arui 296 9.13.1 The objections were made on behalf of F T Everard & Sons Ltd, and concerned the provision of open space at Knockhall Chase. Summary of Objections 9.13.2 The open space designation should not cover the whole of the Knockhall Chase pit, and should not prejudice the implementation of a planning permission for retail use on part of the site. 9.13.3 In reply to the council's response, it was considered that the recommended change to Policy RT18 was ambiguous. The planning permission should be specifically identified, and Policy RT15 should be amended to read "and part of Knockhall Chase, Greenhithe". Ideally the area concerned should be excluded from the RTlS and RT18 designations on the Proposals Map. The council's Response 9.13.4 It was agreed that the plan should make it clear that the open space designation would not prejudice the proposed approved retail development. A change to Policy RT18 to this effect was proposed. 131 / Conclusions 9.13.5 Policy RT18 identifies four areas of land, each of which "is to be laid out as local open space in conjunction with associated development proposals". On the Proposals Map, two of the areas are identified separately from the related residential development, and a third is identified as mixed residential and open space uses. The objection site however, is shown as wholly subject to the open space policy. Notwithstanding the council's suggested qualification to the policy, I regard it as inconsistent and to an extent, ambiguous. 9.13.6 The objector's preferred solution would be to separate the land for which planning permission has been granted for a supermarket and garden centre with associated car parking, from the area subject to Policies RT15 and RT18. The planning permission however, applies to a larger area of land than the objection site, and a condition relates the development of the supermarket to that of the associated housing which does not form part of the objection site; neither is it linked to the open space by any of the council's policies. 9.13.7 In my opinion, the objection site should be shown as allocated for a mixed development, and subject to Policies RT15, RT18 and Policy Rl. This would require a modification to Policy Rl, and to the Proposals Map. Rtst?""Phtigp 9.13.8 I recommend that the Proposals Map be modified to show the objection site subject to Policies Rl, RT15 and RT18. See also recommended change to Policy Rl in Chapter 5. POLICY RT16 Written Obiection No.295 9.14.1 The objection was made by the Kent Trust for Nature Conservation. Summary of Objection 9.14.2 The land to the west of Craylands Lane should be identified as a Site of Nature Conservation Interest (SNCI), and a nature conservation clause should be added to the policy. The site had only recently been identified as a Site of Nature Conservation Interest, and did not therefore feature in early drafts of the plan. 9.14.3 In reply to the council's response, the commended changes to the policy and to the Proposals Map were welcomed, but the SNCI designation should apply to the whole of the policy area RT16. The site should also be added to Policy Cl5 as a possible candidate for a local nature reserve. The Council's Response 9.14.4 The nature conservation interest of the site was acknowledged, and a commended change to the policy would require development proposals to pay due regard to the nature conservation interest of the site. On the Proposals Map, a strip along the north-western boundary of the site would be designated as SNCI under a commended change. 132 ..------~-- 9.14.5 The commended changes were the correct approach to the nature conserva tion issues, in that the area of cutting in the western part of the site would be identified as an SNCI, and the modified Policy RT16 would recognise the nature conservation interest of the area generally. The maximum protection would thus be offered to the least accessible part of the site which had the greatest nature conservation interest, and had the least potential for recreational uses or development. The reference to nature conservation in Policy RT16 should be retained in view of the nature conservation interest of the site generally. 9.14.6 It was not realistic to identify further nature reserves until progress had been made on what was seen as the priority areas, and until the resource question could be positively addressed. 9.14.7 The broad tract of open land between Swanscombe and Knockhall offered the potential to provide an open space of structural significance in this part of the borough, which was less well served by major open space than the west of the borough. The council had already developed an indoor sports facility to the west of Craylands Lane, and the recreational potential of the objection site was important. Conclusions 9.14.8 The whole objection site which adjoins a national nature reserve, comprises a largely restored chalk pit. It contains several areas of nature conservation interest, the most readily identifiable area being a cutting and tunnel along the north-western boundary of the site. The remainder of the 'site contains areas of interest among other areas of restored grassland. I agree with the designation of the cutting as an SNCI, but the remainder of the area whilst appearing to have some nature conservation interest, is in my view of·less value. The site overall however, has value as open space in an area where such space is scarce, and in my opinion the suggested changes properly reflect the priorities in this area. Bgc•• ppd@,tiona 9.14.9 I recommend that: 1. Paragraph 9.3.14 be modified in accordance with commended change No.47; 2. Policy RT16 be modified in accordance with commended change 48; 3. The Proposals Map be modified in accordance with commended change No.81. 133 ABSENCE OF POLICY LACK OF ANY POLICY COVERING PUBLIC HOUSES AND RESTAURANTS IN RURAL AREAS. Written Objection No. 291 9.15.1 The objection was made on behalf of Whitbread Plc. Summary of Objection 9.15.2 The plan took insufficient heed of A3 uses. Two additional policies should be added in order that public houses and restaurants may be encouraged to locate in the Dartford area but not necessarily within the built-up area. There was an increasing demand for more family pubs and restaurants in rural areas, which should be regarded as part of the leisure industry. 9.15.3 Policies should be introduced which would enable public houses and restaurants within the countryside to be extended in suitable circumstances, and to enable the conversion of appropriate listed buildings or other buildings of interest, to A3 or hotel use. · The Council's Response 9.15.4 Proposals for such extensions and conversions would be judged on their merits, and in relation to all the relevant policies in the local plan, including particularly the countryside, Green Belt and built environment policies. These policies formed an adequate basis for determining such proposals. 9,15.5 Whilst the recreation value of pubs and restaurants was acknowledged, there could be no special relaxation of environmental controls for their benefit. Conclusion 9.15.6 Tourism and recreation is generally encouraged in the plan. Policy RT7 encourages the provision of tourist facilities, and RT8 states a presumption in favour of proposals for the development of hotels and other tourist accommoda tion, suitable to compliance with other policies. Chapter 10 of the plan has as one of its objectives, to enhance the recreational value of the countryside. None of these policies would preclude extensions of existing buildings, or the conversion of suitable buildings in appropriate locations. 9.15.7 PPG2 explicitly states that local planning policies should make no reference to the possibility of allowing developments in the Green Belt other than those specified, and in my opinion, the suggested policies for extensions and changes of use within the Green Belt would go further than is permitted by national guidance. Whether a proposal for the conversion of a redundant building in the Green Belt to recreation purposes would meet the criteria for re-use of redundant buildings in the Green Belt, would depend on the particular circum stances of the case. R@gg nd&t;igp 9.15.8 I recommend no additional policy as a consequence of this objection. 134 CQMMENPED CHANGES COMMENDED CHANGE No.48 Written Objection No. C4 9.16.1 The objection was made by Swanscombe and Greenhithe Town Council, and concerned the deletion of land to the east of Craylands Lane from Policy RT16. Summary of Objection ' i 9. 16, 2 The original area as proposed in the deposit version of the plan, should , I be safeguarded for open space and leisure purposes. The Council's Response 9.16.3 The possible redevelopment of the large area including land to the east of Craylands Lane would be in association with the provision of public access and some public open space. It would provide the means to deal with the current poor environmental and visual conditions on the site. Conclusions 9.16.4 Part of the site has been filled and restored, but there is chalk dross on the northern part of the site, which is currently being removed by a contractor. There is an unofficial footpath across the site to the nearby recreation ground. I understand that there is no planning condition or other obligation placed on the owners to remove the chalk dross or carry out further restoration. 9.16.5 The objection site and two other areas of land, have been identified in proposed new policy APl, as having potential for long term comprehensive development. The commended change resulting in the re-allocation of the land, followed an objection to its designation as open space, in which the visual appearance of the current edge of residential development was referred to. The objector proposed housing development on the southern part of the site, with newly created areas of open amenity space on the northern part of the site. The damaged nature of the site meant that its progressive restoration for public open space and amenity purposes alone would not represent an economically viable proposition and, given constraints on public expenditure, was unlikely to be achieved in the foreseeable future. 9.16.6 In my opinion, this area of open space has value in forming part of the broad tract of open land between Swanscombe and the open countryside south of Alkerden Lane. The value of this is recognised in the plan, and the issue is whether the whole site should be retained as open space or whether open space should be provided in association with other development. In my opinion the most likely means by which the site will be satisfactorily restored is in association with other development. 9.16.7 The intention of preserving the open space in association with some housing, is acknowledged in the objection to the original designation as exclusively open space and leisure purposes, but this would not necessarily be ensured under the provisions of proposed Policy APl. Development within the plan period is also a possibility. I consider that the intended use of the site for housing and open space would be made more clear if it were designated under Policy RT18, in a similar way to that at Manor House, Swanscombe. 135 f 9.16.8 While there are no details of any proposal for the site, I would expect the provision of open space to occupy most of the site and that the open space would link with the recreation ground and with the land to the west of Craylands Lane, thereby maintaining the continuity of open space between the open countryside to the south, and Swanscombe. Begg g Metign 9.16.9 I recommend that: 1. Policy RT18 be modified by the addition of: "east of Crulanda Wne (related to housing development)"; 2. the Proposals Map be modified by showing the area of land east of Craylands Lane (currently designated RT16 and DL3) as subject to Policies DL3, RT18 and Hl. See also recommended change to Policy Hl in Chapter 4. COMMEHDED CH6NGE NO 42 l!ritten Objection No. C6 9.17.1 The objection was made by the Ministry of Agriculture, Fisheries and Food, and concerned the proposed new guidelines for golf course provision. Summary of Objection 9.17.2 The guidelines should be amended to require consultation with MAFF where any golf course proposal contained more than 20 Ha of high quality agricultural land. It should be stated that planning conditions would be applied to ensure that the land was capable of being brought to best quality agricultural use at some future date if required, and stating a presumption against proposals which irretrievably damage 20 Ha or more of best and most versatile land. The Council's Response 9.17.3 The Council was statutorily required to consult MAFF in the manner suggested by the objector, and it was not therefore necessary to reiterate this in the guidelines. The presumption against proposals irretrievably damaging large areas of best agricultural land, was contained within the proposed guidelines. Conclusion 9.17.4 The application of conditions to ensure the land could be brought back to best quality agricultural use if required, would be unenforceable and unreasonable, I do not consider that the application of a planning condition such as that suggested by the objector, would be the appropriate means of ensuring that land could be returned to agriculture if necessary. I consider that detailed consideration of the planning application in accordance with the guidelines, should ensure that the golf course is laid out in such a manner that, should its use cease or.there be a requirement for the land's return to agriculture, the development would not preclude such a reversion. 136 B•crr gpdatipp 9.17.5 ~I recommend no further change to the proposed new appendix "Guidelines for Golf Course provision" as a consequence of this objection. CQMMENPED CHANQE N0.48 Written Objection No C9 9.18.1 The objection was made on behalf of Blue Circle Properties Ltd, and concerned the proposed modification to Policy RT16. Summary of Objection 9.18.2 There should be more flexibility in the wording of Policy RT16 as amended, to allow for planning requirements to take account of detailed studies which have yet to be undertaken. The final sentence which the Council proposed to add to Policy RT16 in response to Objection No. 295, should be deleted,.and the word "safeguarded" should be replaced by the word "promoted primarily". 9.18.3 The objector was keen to reuse its surplus land assets to achieve a proper balance of land uses in the area. Whilst the alleged shortfall in open space within the eastern part of the borough was noted, the closure of Swanscombe Secondary School could yield a valuable contribution to formal play space. In its approach to future land management decisions, the objector expected to secure the improvement of open space facilities in the area, but a comprehensive, economically viable scheme of management for Craylands Lane West was essential. The various diverse considerations required integrated management within the framework of a well resourced plan if each element was to be retained and enhanced without conflict. 9.18.4 In the absence of a demonstrated need for recreation space and the importance of a viable scheme for management, more flexibility was required in Policy RT16. The final sentence added on by the commended change was unnecessary as the site would be protected under Policy Cl4. The Council's Response 9.18.5 The suggested wording was unacceptable as it could allow for uses or development not related to open space or recreation, and which would fundamentally conflict with the key recreational role which the Council saw the site as fulfilling. Safeguarding the recreational potential of the land west of Craylands Lane was particularly important in view of the deletion of Policy RT16 l from the area east of Craylands Lane. Conclusion 9,18.6 The objector's comments indicate a positive approach to the provision of open space facilities in the area, which include integrated management within the framework of a well resourced plan. In my opinion however, none of the consider ations listed by the objector would appear to contravene the principles in Policy RT16 or the preceding paragraph. All the considerations listed can be regarded as open space or leisure purposes, and I can see no reason for any further change in the policy to be applied to the objection site. 137 Roppmencletfpn 9.18.7 I recommend no further modification to Policy RT16 as a consequence of this objection. 138 CHAPll!R 10 - COUN'lRYSIDE BACJ(GROVND 10.1.l The countryside policies of the structure plan were not subject to the Second Review, and the policies approved in 1980 and in 1983 have been carried forward as approved policies. 10.1.2 The structure plan recognises that many countryside issues lie outside the scope of planning control, and local planning authorities are encouraged to work for the voluntary co-operation of those involved in the countryside and rural activities. 10.l.3 Kent has a disproportionally large share of the nation's best agricultural land. This land is regarded as a national resource to be protected from irreversible development. An objective of the structure plan is to safeguard agriculture as a major industry. Much of the agricultural land in the borough comprises one of the seven Areas of Special Significance for Agriculture in the county. These areas are protected under structure plan Policy CC3 which gives priority to the needs of agriculture over other planning considerations. 10.l.4 Another objective of the structure plan is to conserve and enhance the variety of important wildlife habitats. Nature Reserves, Sites of Special Scientific Interest, and other areas of high nature conservation value are specifically referred to. 10.1.5 Whilst much of the northern part of the borough has been developed, the southern part remains as substantially open countryside, and forms a downland landscape as a backdrop to the Thames-side urban area. Most of the countryside lies within the Metropolitan Green Belt, though some of it has been damaged by mineral extraction. 10.l.6 Local plan Policies C6 and CB have been carried forward from the Kent Countryside Plan which is a statutory plan. They are not therefore, open to objection. 10.1.7 The countryside policies heve been generally well received; there were 31 representations in support of them, compared with 14 objections. In particular, the Ministry of Agriculture, Fisheries and Food (MAFF) welcomed Policies Cl-C7, and the Ramblers' Association supported Policies Cl-C5 and C8-Cl7 as being of benefit to walkers and users of the countryside, and also to the flora and fauna. The Countryside Commission welcomed Policies C5, CS, C9 and ClO. 139 POLIQI!lS POLICY Cl Written Qbjectipn No 297 10.2.1 The objection was made by the Council for the Protection of Rural England (Kent Branch). SUIJllDB.ry of Objection 10.2.2 The policy had a permissive tone and should be re-worded. The Council's Response 10.2.3 It was accepted that the emphasis of the policy was inappropriate, and a change to the policy was recommended. Conclusions 10.2.4 I agree that the emphasis of the policy would be improved by the recommended change, though I note that the change as commended, would delete the word "normally". The corresponding Policy RS6 in the structure plan contains the word "normally", and in my opinion that word should be retained. 10.2.5 For reasons given in my consideration of Objection No.310 below, I also recommend a further modification concerning agricultural dwellings. 10.2.6 I recommend that Policy Cl be modified: 1. in accordance with commended change No 50, except for the retention of the word •norlDBlly". 2. by the addition after factor (e) of a statement to the effect that proposals for new agricultural dwellings will be considered against the guidelines in Planning Policy Guidance 7 Annex E. POLICY C3 Written Qbjectipn No 298 10.3.l The objection was made by the Senior Technical Adviser to the National Farmers' Union, South East Region, and concerned the use of redundant farm buildings. Summary of Objection 10.3.2 Policies C3(c) and (d) would be used as a mechanism for rejecting all applications relating to the change of use of farm buildings, which did not involve buildings of historic or architectural merit. Circular 16/87 made clear its support for the principle of farm diversification as a means of generating additional farm income. 140 POLICY CS Written Qbjection No 299 10.5.1 The objection was made by English Nature (SE). Summary of Objection 10.5.2 The policy should be amended to include the words "enhance the environment and nature conservation quality". The Council's Response 10.5.3 It was agreed that the policy would benefit from such a reference, and a change to the policy was recommended. Conclusions 10.5.4 I agree that the commended change would encourage proposals which enhance the nature conservation interest of the countryside, and be an improve ment to the policy. llosn ndatf on 10.5.5 I recommend that Policy CS be modified in accordance with commended change No 51. POLICY C7 Written Obiection No 301 10.6.1 The objection was made by the Senior Technical Adviser to the National Farmers' Union, South East Region. Summary of Objection 10.6.2 Local planning authorities had to recognise the needs of the agricul tural holding. Agricultural buildings were primarily utilitarian in function, and it was not always possible to construct and site them with the same degree of flexibility as other types of development. 10.6.3 The requirement that proposals should demonstrate a need for the development proposed, was contrary to the advice in PPG7. Criteria relating to scale, design and materials, minimising impact on the landscape, and grouping should contain the phrase "wherever possible". The Council's Response 10.6.4 The operational requirements of the agricultural use would clearly be taken into account when any proposals were considered, but the criteria set out in the policy were important objectives which agricultural development should seek to achieve. They would be applied in a practical, reasonable manner. 10.6.5 The reference to need was a safeguard to try and ensure that new buildings were justified by an agricultural need rather than being erected and subsequently put to another use. 142 Written Ob1ection No 302 10.6.6 The objection was made by Mr Graham Simpkin on behalf of various clients. Summary of Objection 10.6.7 While the objectives of this policy may be commendable in themselves, it was important that the policy was not misinterpreted to preclude or prohibit the erection of modern agricultural buildings to meet the requirements of farmers. There was a danger that in its present form it could be interpreted to require traditional style farm buildings more appropriate to an earlier form of farming use but not suited to the needs of the modern agricultural industry. The Council's Response 10.6.8 The policy did not tie agricultural buildings to traditional styles. The functional requirements of such buildings were accepted, but the policy was intended to minimise any adverse visual impact of such structures on the countryside. Conclusions 10.6.9 Policy C7 arises from Structure Plan Policy RS6 where development in the countryside has to be demonstrated as necessary to agriculture or other appropriate use. The policy therefore correctly requires a need for the development to be demonstrated. This however, would only apply where planning permission is required, as otherwise planning permission is granted under the terms of the General Development Order. The criteria relating to siting and design of agricultural buildings are necessary in my opinion, in order to protect the countryside as much as possible from inappropriate types of building. Nevertheless, I consider it is difficult to envisage that some materials used in silos and other large structures, could be expected to harmonise with the surrounding countryside. I note that Structure Plan Policy RSl refers to development being appropriate, and in my view proposals for agricultural buildings should be appropriate both to their use and to the surrounding countryside. 10.6.10 I recommend that Policy C7 be modified by the deletion of the second criterion, and its replacement by a statement to the effect that agricultural buildings should be of a scale and design, and use materials which are appropri ate to its use and to the surrounding countryside. POLICY Cll Jiritten Qb1egtign No 303 Representation Ng R106 10.7.1 The objection was made by English Nature (SE). Summary of Objection 10.7.2 Whilst welcoming Policy Cll (Rl06) relating to woodlands, the preamble in paragraph 10.3.11 should contain an additional phrase stressing the extent and importance of the borough's broadleaved woodlands. 143 ...... ______~~- The Council's Response 10.7.3 It was agreed that the preamble would benefit from the objector's suggestion, and recommended a change to the paragraph accordingly. Conclusions 10.7.4 I agree with the commended change which would give added emphasis to some of the woodlands in the borough. Rtc~tign 10.7.5 I recommend that paragraph 10.3.11 be modified in accordance with commended change No 52. POLICY Cl2 Representation No.R108 10.8.1 The policy was welcomed by English Nature. There was no objection to this policy. POLICY Cl3 Representation No,RllO 10.9.1 Mrs Mason wrote expressing pleasure that Sites of Nature Conservation Interest (SNCI) were identified in addition to Sites of Special Scientific Interest (SSSI). POLICY Cl4 Written Objection No 305 R@praaeptations Noe R54. RSS. Rll2 10.10.1 The objection was made by the Kent Trust for Nature Conservation. Summary of Objection 10.10.2 While supporting Policy Cl4 as providing strong protection for Sites of Nature Conservation Interest (SNCis), four additional areas should be subject to the policy of Cl4. The sites were: 1. extensions to Dartford Marshes SNCI; 2. Mabledon Hospital grounds; 3. Craylands Lane Pits; 4. extension to Ebbsfleet Valley. 144 The Council's Response 10.10.3 Some of these sites were dealt with in other site specific objections, namely Objections Nos 8, 295 and 323. 10.10.4 It would not be appropriate to apply Policy Cl4 within areas of acknowledged development potential, or where development was proposed. In such cases it was considered that the nature conservation interest should be dealt with in the particular site specific policy, and accordingly Policies E2 (Dartford Marshes), RT16 (Craylands Lane) and CF5 (Mabledon Hospital), required, or would require if modified in accordance with the commended changes, proposals to "take due account of the nature conservation interest of the area". Commended changes to Policies E2 and RT16 would include a similar requirement. The Dartford and Gravesham Health Authority (DGHA) and The South East Thames Regional Health Authority (SETRHA) supported the redevelopment of Mabledon Hospital under Policy GB4. 10.10.5 It was agreed that the dykes on Dartford Marshes lying to the south of the currently designated SNCI, should also be designated as SNCI. 10.10.6 Much of the valley to the south of the Ebbsfleet Valley, which included land in the adjoining borough, was already a designated SNCI and a proposed Local Nature Reserve. The proposed additional land however, lay within the proposed new Policy Area APl, and was also affected by the proposed South Thameside Development Route under Policy Tl3, It was not therefore appropriate for it to be a designated SNCI, but nature conservation would be one of a range of issues to be taken into account when a strategy for the area was formulated. 10.10.7 Mrs Mason wrote in support of the policy. Conclusions 10.10.8 In my opinion it would be inappropriate to designate sites allocated for development as also subject to Policy Cl4, in which proposals which would materially harm the nature conservation value would not be permitted; there.would be a conflict between the relevant policies. Policy CF.5 specifies a requirement that proposals for redevelopment of Mabledon Hospital should take due account of nature conservation interests of the area, and I have recommended modifications to those policies applying to areas containing Dartford Marshes and Craylands Lane pits, which would then contain the same requirement. For similar reasons, I do not consider that the SNCI designation would be appropriate within Policy Area APl. Policy APl however, makes no reference to the nature conservation interest of land at Ebbsfleet, and in my opinion, any proposals for development of that land should have regard to the nature conservation interests. I therefore consider that reference to the nature conservation interest should be incorporat ed in Policy APl and its preceding paragraph. 10.10.9 I agree with the proposed additions to Dartford Northern Marshes SNCI shown on the Council's plan DBC305.l. Rapp pdetiPDI 10.10.10 I recommend that the SNCI at Dartford Marshes be extended by the addition of land shown on the Council's plan reference DBC305.l. See also recommended change to Policy APl in Chapter 4, 145 -- Qb1ect!on No 306 10.10.11 The objection was made by Blue Circle Industries, and concerned Sites of Nature Conservation Interest (SNCI). Summary of Objection 10.10.12 The term "Site of Nature Conservation Interest" had no statutory basis, but it nevertheless enjoyed the same level of protection as SSSI's. The Council's Response 10.10.13 During the inquiry, modifications to Policy Cl4 and the preamble were agreed, which overcame the objection. Conclusions 10.10.14 As currently worded, Policy Cl4 taken with the other relevant conservation policies, does not accurately reflect the hierarchy of the various sites of conservation interest as described in the structure plan. In my view the policy modified in accordance with the commended changes, would accurately reflect the hierarchy in structure plan Policies CC8, CC9 and CClO. Ro9W!11!'7ldetim I recommend: 1. the insertion of a new paragraph 10.3.13 in accordance with commended change No.Sll; 2. the renumbering of subsequent paragraphs; 3. paragraph 10.3.14 (renumbered to 10.3.15) and Policy Gl4 be modified in accordance with commended change No.S25. POLICY Cl5 Written Qbjection No 307 Representation No.Rl15 10.11.1 The objection was made by Mr and Mrs Thomsett and concerned a possible local nature reserve at Dartford Northern Marshes. Summary of Objection 10.11.2 A Local Nature Reserve (LNR) was not appropriate on this farmed land in view of the character and location of the site. In any event, any local need for nature conservation was already met by the more appropriate and long established site to the east of Joyce Green Hospital, which was already owned by Dartford Borough Council. The Council's Response 10.11.3 Dartford Northern Marshes were of considerable nature conservation value as evidenced by their designation as a Site of Nature Conservation Interest (SNCI) which had been recognised in the context of the El Policy area. The Dartford and Grayf ord Marshes comprised the largest remaining area of marshland on the south side of the Thsmes within the Greater London area. 146 10.11.4 The area would benefit from the introduction of a management plan and a possibly interpretive facility as well. Designation as a LNR would be the best means of achieving this end. 10.11.5 The nature conservation value of the land east of Joyce Green Hospital was acknowledged, and Policy El provided for its management. However, the more remote location and character of the marshes and their relative isolation from built development suggested that their identification and management as a LNR was an appropriate policy approach which would be less relevant and applicable to the circUD1Stances of the area east of Joyce Green Hospital. 10.11.6 The regional health authority supported the encouragement in the policy for the establishment of a LNR. Conclusions 10.11.7 The site's characteristic of being the largest remaining area of marshland on the south side of the Thames in the London area, gives it a rarity value, and its remoteness from existing or proposed development presents an opportunity for designating the site for management and conservation; this can best be provided by its designation as a LNR. As stated in the preamble, such a designation would enhance the scientific and nature conservation value of the SNCI. I therefore support its designation shown on the Proposals Map. 10.11.8 Whatever the nature conservation interests of the land east of Joyce Green Hospital, the area is and will be, enclosed by existing development including the redevelopment of Joyce Green Hospital. 'llhilst Policy El requires development proposals to have due regard to the nature conservation interest, 1 do not consider that the land would be suitable as a LNR either in its own right or as an alternative to Dartford Marshes. I therefore do not propose to recommend any change to Policy Cl5 as a consequence of this objection. Written Qbjection No 308 10.11.9 The objection was made by the Kent Trust for Nature Conservation. Swmaary of Objection 10,11.10 'llhilst supporting the proposal to declare Dartford Marshes as a LNR, the dykes west of Joyce Green Lane should also be included within it. This would enable restoration and enhancement of its wildlife interest, and would also expand the area of the reserve, thereby facilitating management, visitor access and available wildlife habitat. 10.11.11 The whole of the Ebbsfleet SNCI within Dartford, and the quarries at Craylands Lane should also be designated as LNR's. The Council's Response 10.11.12 The dykes to the west of Joyce Green Lane had been recommended for designation as an SNCI as part of the proposed modifications to the plan (Objection 305). It may however, be appropriate to consider uses appropriate to the Green Belt rather than a LNR in this area, In all the circumstances, it would be more appropriate to reconsider the possibility of extending the LNR at the first review of the local plan in the light of progress on the principal LNR designations, and greater certainty as to surrounding land uses, particularly at the CF7 site. 147 ~------ 10.11.13 It would not be appropriate to identify a greater area of land at Ebbsfleet as an SNCI or LNR in view of the need to consider all relevant factors in future planning of the area within the context of proposed new Policy APl. Much of the valley to the south was proposed for LNR designation. 10.11.14 Land at Craylands Lane was considered under Objection No.295. Conclusions 10.11.15 The dykes west of Joyce Green Lane would become designated SNCis under recommended modifications to the plan. They are also protected by the restric tive policies applied to the Green Belt. While there does not appear to be any opposition to their designation as a possible LNR, Policy Cl5 does no more than seek to encourage the establishment of Local Nature Reserves. The likely value of the objection site as a nature reserve could well depend on the type of development on the adjacent CF7 site. In my opinion, while there are uncertain ties relating to both the CF7 site and the likelihood of establishing an LNR at Dartford Marshes, the council's approach in establishing priority areas first and then reviewing the situation, is reasonable. 10.11.16 Land at Ebbsfleet is considered under Objection No.305 above, and the pits at Craylands Lane are considered under Objection No.295 in Chapter 9. Boc;p=epdetign 10.11.17 I recommend no change 1;Q Policy ClS as a consequence of these objections. >.' POLICY Cl7 Written Objection Np 309 10.12.l The objection was made by English Nature (SE). Summary of Objection 10.12.2 Whilst welcoming the inclusion of Policy Cl7, the wording should be altered so as to prevent confusion with designated Sites of Nature Conservation Interest. The Council's Response 10.12.3 It was accepted that the policy would benefit from this re-wording and a change to the policy was recommended. Conclusions 10.12.4 I agree that the commended change would avoid confusion with designated Sites of Nature Conservation Interest. kggW'D'W;ign 10.12.5 I recommend that Policy Cl7 be modified in accordance with commended change No.54. 148 A8SENCE OF fOLICY LACK OF POLICY FOR AGRICULTURAL DWELLINGS Written Qbjactign No 310 10.13.l The objection was made by the Senior Technical Adviser to the National Farmers' Union, South East Region. Summary of Objection 10.13.2 There should be a specific policy which provided for agricultural dwellings as permitted under Policy RS6 of the Kent Structure Plan, in cases where the criteria in the Annex to Circular 24/73 could be met. The Council's Response 10.13,3 Structure plan Policy RS6 and Planning Policy Guidance (PPG)7 provided an adequate policy basis for determining proposals for agricultural dwellings. Furthermore local plan Policy Cl confirmed the policy acceptability of proposals complying with RS6. In the circumstances, no additional specific local plan policy was necessary. Conclusion 10.13.4 Whilst Policy Cl makes reference to structure plan Policy RS6 which states a requirement for the need for development in the countryside to be necessary for agriculture or other specified uses, neither policy nor the associated preambles to them, make reference to the criteria in Annex E of PPG7. That document sets out the criteria against which applications for agricultural and forestry dwellings are considered, and in my opinion the policies of the local plan should make reference to them. The annex contains guidelines and considerations to which neither the structure plan nor the local plan make any reference. 10.13.5 I therefore consider that an addition should be made to Policy Cl, which would draw attention to the tests and guidelines in PPG7. 19&CS ptetlgp 10.13.6 See recommended modification to Policy Cl above. 149 CHAPTER 11 · VILLAGES BACKGROllND 11.1.1 Although the main theme of the structure plan is economic growth, the quality of the urban and rural environment is regarded as of paramount importance in attracting new investment and boosting the tourist industry. 11.1.2 The structure plan identifies a need for the provision of a wide range of good quality housing. Most development will continue to be in towns but where a limited amount of new housing can be acommodated in an attractive environment at villages or small rural towns, this can help meet a locality's needs, and provide for choice. Some 20X of all new housing permitted annually in Kent, has been in rural settlements. 11.1.3 The many villages and small rural towns are particular features of the Kent countryside It is considered to be important to preserve this character, which means protecting some from growth; this will entail firm development control policies. In some villages infilling may harm the character, wheras others may have potential for new development. 11.l.4 In Dartford, villages are generally close to the main highway network, and they tend to act as dormitory settlements, having only limited ties with the agricultural economy. 11.1.5 Considerable housing development occurred in some villages during the 1950's and 1960's, but since then, Green Belt policies have constrained development. A key function of the local plan is to identify settlements to which the different structure plan policies should apply, and to define their confines. 150 POLICIES OBJECTIVES; PARARAPH 11.2.1 Representation No. R118 11.2.1 Mr E Huxley supported the introduction of village envelopes. There were no objections to the objectives of the policies for villages. POLICY Vl Written Objection No 311 11.3.1 The objection was made on behalf of Mrs J Masters, and concerned the settlement of Westwood. Summary of Objection 11.3.2 Westwood which was defined in the local plan as an Area of Special Character, should also be identified as a village for the purposes of structure plan policies. The Council's Response 11.3.3 Westwood was a small group of buildings lying in open countryside. It was designated an Area of Special Character under Policy BlO, but was to be regarded as a hamlet within the context of structure plan Policy RS6. It was not of a scale which would warrant its identification as a village for policy purposes. Its diffuse character would be adversely affected by built development which may occur in the event of village confines being established. Conclusion 11.3.4 Westwood is a small, loose-knit settlement situated in generally open countryside. It has no shop, post office or public house, and I would agree with the view that it has a diffuse character. In my opinion the gaps between buildings are an important part of the settlement's character, and to designate Westwood as a village for policy purposes would establish confines within which some development would be permitted. In my opinion, this would be likely to lead to these gaps being filled in by development, with a consequent loss of the settlement's character. Bose qlttigp 11.3.5 I recommend no change to Policy Vl as a consequence of this objection. POLICY V2 Written Qbjection No 312 11.4.1 The objection was made by Waites Built Homes Ltd, and concerned land at Shellbank Lane, Bean (Site Al2). 151 ~ ! Summary of Objection 11.4.2 The specification of a maximum density of six dwellings per acre for site Al2 at Shellbank Lane, Bean was inappropriate, having regard to the character and functions of the village, the design and density of adjoining development which was only recently completed, and the opportunity to provide a landscape buffer on land adjoining that part of the site which abutted open countryside. The determination of an appropriate density of development should be left to the processes of development control. The Council's Response 11.4.3 Site Al2 abutted an Area of Local Landscape Importance, and it was I particularly important that the development of this site did not detract from the ! visual quality of the surrounding countryside. Accordingly, a well landscaped low density scheme would create a softer edge to the village of Bean in this I I area. This point was recognised in PPG3, and the need for more low density high I quality housing schemes was recognised in the local plan. i 'ii i: 11.4.4 This site could accommodate about seven units at the prescribed density 'I of six dwellings per acre. Any larger development would be likely to give rise , I' to access problems either in Turner Road or Shellbank Lane. Conclusions 'I 11 11.4.5 The objection site is an irregular shape, and slopes down towards the south-west. It is on the fringe of the village, and is visually prominent from the south-west. Although the site forms an indent into the built up area of Bean, the topography is such that the site has a closer visual relationship to the countryside than to the main body of the settlement. Residential development on a site such as this however, would help to give effect to the housing objective stated in 4.2.l(d) but in my view it would have to be low density in well landscaped surroundings. The provisions of Policy V2 and its preceding paragraph, aim to secure that objective. 11.4.6 Furthermore, although primarily a development control matter, Shellbank Lane is a narrow, country lane, and I consider that it would be unsuitable to serve a high density development. 11.4.7 This site is also the subject of Objection No.127 in Chapter 4. Objection No 313 11.4.8 The objection was made on behalf of Mr F G Meakin, and concerned land at Paige Close, Bean (site Al3). Summary of Objection 11.4.9 The allocation of the objection site for housing in Policy Hl was supported, but the application of density standards in Policy V2 was inappropri-· ate. The site was not suitable for high quality, low density housing, and development at a higher density would improve the overall housing provision in the borough. 152 The Council's Response 11.4.10 Objection site Al3 presented an opportunity to provide additional housing stock, .possibly of a size and type to reflect its rural location, and to increase the choice for Bean. It would soften the hard urban edge presented by the existing development. The policy aimed to produce an appropriate and sensitive treatment of this transitional area. Conclusions 11.4.11 The objection site is bounded by dense woodland to the north and residential development to the south. Towards the east the land is open countryside containing the A2 trunk road. Access to any development on the site would be via Paige Close from School Lane; Sandy Lane along the eastern boundary, is a no-through road, and is regarded as unsuitable to serve additional traffic. 11.4.12 Much of the development in Bean comprises housing built during the 1960s and 1970s. It has taken place almost entirely east of High Street, and in my opinion the housing on Beacon Drive, Bramble Avenue, School Lane and Paige Close has produced a suburban type appearance. The result has been to give the village a hard edge along School Lane which forms the boundary between the built-up area and the open countryside. The aim of Policy V2 is to soften the village edge. 11.4.13 The objection site is screened from view by housing or woodland except for views from Sandy Lane and the open countryside to the east. I can understand the objector's view that low-density housing would not be an attractive proposition for potential buyers when approached through high-density development such as Paige Close. On the other hand, while I recognise the aims of Policy V2, I do not consider that development on the objection site at a higher density than 6 per acre need necessarily have any material impact on the character of the village as long as it was not hard up against Sandy Lane. 11.4.14 In my opinion, the specified maximum density of 6 dwellings per acre is unreasonable in the circumstances of Site Al3. 11.4.15 While density can only be a rough guide to the likely quality of development, I regard the requirement for low density at Site Al2 as appropri ate. As written however, the density is given the status of being contained within a policy, which in my view gives it excessive weight. I therefore consider that the density should be stated in the preceding paragraph, and the policy refer to the aim of providing low density housing in a well landscaping setting, in order to provide a transition between.the built-up area of the village and the open countryside; this aim was put to me at the inquiry. 11.4.16 For reasons given elsewhere, I have deleted sites Al4 and Al5 from the policy, and I consider the density requirement as inappropriate for site Al3. I therefore regard the list of sites as unnecessary, and propose instead a more general approach. In the case of site Al3, proposals for development would have regard to both the nature of the adjoining development, and to the proximity of the open countryside. 11.4.17 I recommend that: 1. paragraph 11.3.2 be modified by the addition of a sentence to the effect that sites identified in Policy Hl and situated on the edges of villages, should not normally be developed at a density in excess of 6 dwellings per acre. 153 2. Policy V2 be modified by (i) the deletion of the sentence starting [The following sites, identified in Policy Hl, •. ] including the list of sites; and (ii) the addition of a new sentence stating that sites on the edges of villages should be developed at densities which will provide a transition between the built-up area and the open countryside. r~ I ,i ii jl 154 I I I I CHAPTl!R 12 - &UILT BNVIRONllBllT I J!ACKGROl!ND !. 12.1.l The structure plan recognises the strategic importance of conserving the quality of the built environment, both for its intrinsic merits, and in recognition of the value of the environment in attracting new investment, thereby supporting the main thrust of the structure plan in promoting economic activity. Encouragement is given to development which will support the commercial and leisure role of town centres, while maintaining and enhancing its visual and functional quality. 12.1.2 In areas of run-down or deteriorating environment, particularly those associated with industrial decline, co-ordinated environmental improvement initiatives are seen as possible catalysts for revival, providing a key element in economic strategy. 12.1.3 There are over 200 listed buildings in the borough, and four conserva tion areas, in addition to sooie archaeological sites and ancient monuments. The local plan recognises the poor quality of much post-war development, especially in the industrial and retail sectors. Restructuring and redevelopment are seen as providing opportunities to improve the environment. 155 POLICIES POLICY Bl Written ObjectlQD No 314 12.2.l The objection was made on behalf of Blue Circle Properties Ltd, and concerned standards of layout and design in housing developments. Summary of Objection 12.2.2 While supporting the council's objective to achieve a higher standard in the layout and design of new housing developments, standards which could be useful in guiding development proposals must allow for alternative proposals to come forward which, although of a high standard and acceptable layout, did not comply with the specific standards set out. Policy HlO should be modified to introduce the word "normally", and a similar modification should be made to Policy Bl, particularly clauses (d) and (f) relating to amenity and parking standards respectively. The Council's Response 12.2.3 Policy Bl commenced by stating the factors which would be taken into account in considering development proposals. That did not convey a rigid application of all the listed factors, but built into the policy a degree of discretion and flexibility. The word normally was not therefore necessary, and could imply a generally weaker application of the criteria than was appropriate. 12.2.4 Changes to Policy Bl would take into account objections from other parties, but none was necessary in response to this objection. Policy HlO is discussed under Objection 179. Conclusions 12.2.5 Policy Bl lists factors to be taken into account when considering proposals for development. It does not state criteria which have to be met, and I do not therefore consider that there is any need for the inclusion of the word "normally". In my opinion, these are considerations which would be applied to every application. 12.2.6 My conclusions on Policy HlO are given under Objection No.179 in Chapter 4; I have recommended a modification which would introduce the flexibility sought by this objector. 12. 2. 7 For reasons given in consideration of Objections Nos 15,17, 226, .261, 268, 270, 271, and 293, the council have recommended changes to Policy Bl, which I support. Roen IMlotigna· 12.2.8 I recommend that Policy Bl be modified in accordance with commended changes Nos 56, 57 and 58. 156 POLICY B4 Written Ohlection No 315 12.3.l The objection was made on behalf of the Wellcome Foundation Ltd, and concerned land at Dartford Fresh Marshes. Summary of Objection 12.3.2 The requirement for a landscape buffer zone in Policy Area E2, along the creek side and the southern boundary of the Dartford Northern Bypass, should the site he developed, was unacceptable. The Council's Response 12.3.3 Informal discussions concerning the objection site, and consideration of the written response to the 1988 consultation draft local plan, had suggested that a landscape zone of the order of some 30 m in depth would be appropriate. However, this was one of many issues which would need to be considered in developing proposals for the E2 policy area, and it was not seen as appropriate that the policy should include any specific dimension. Policy B4 provided for a zone in areas to be agreed with the council. Policy B2 which required a development brief to be agreed with the council for development on major sites, would also be relevant here, and a brief would have to be agreed with the council. There would be adequate flexibility for this issue to be discussed and resolved as the master planning for this site progressed. Conclusions 12.3.4 The preamble to Policy B4 refers to the need for development proposals to make provision for a substantial landscaped buffer zone on identified sites which had s particularly sensitive visual relationship with their surroundings. In my view the E2 policy site is such a site, forming as it does, part of the Darent Valley. The extent of landscaping which would be appropriate on the site would depend on the nature of development proposed, in particular its bulk, location and external materiels. In my view such matters can only be considered when s development brief is being prepared, or when considering a planning application. In the circumstances of this site, I do not regard the requirements of Policy B4 as unduly onerous. Rosgmruytetign 12.3.5 I recommend no change to Policy B4 as a consequence of this objection. POLICY BlO Written Objection No 316 12.4.l The objection was made by Mr G Simpkin on behalf of various clients, and concerned Areas of Special Character. Summary of Objection 12.4.2 The character of the areas identified in Policy BlO derived in part from the existence of some key buildings possessing some architectural or historic merit. The loss of such key buildings through demolition could clearly affect 157 the special character of these areas, and the wording of the policy should be amended to encourage the retention where possible, of buildings which added to the special character of these areas. The Council's Response 12.4.3 Areas of Special Character related to groups of buildings which had some character and attractiveness but did not merit conservation area status. There were some listed buildings which lay within these areas of special character, and which were protected by legislation from uncontested demolition. There were however, non-listed buildings which also contributed to the character of the areas, and it was accepted that the wording of the policy should be amended to recognise this. 12.4.4 The objector had confirmed that the commended change met the objection. Conclusions 12.4.5 I agree that the commended change would be a desirable addition to the policy, and assist in retaining the more important buildings. 12.4.6 I recommend that Policy BlO be modified in accordance with commended change No 59. 158 CllAPTl!lil 13 - COMIMTlTY FACILITHS ARD PUBLIC UTILITIES BAGKGRQ!lNJ) 13.1.1 The current provision of community facilities and services in the borough is regarded as generally satisfactory except for primary health care which is considered to be of a poor standard in terms of convenience and quality of buildings. Proposals for the redevelopment of Joyce Green, Darenth Park, Bexley, Mabledon and West Hill Hospitals are contained within the local plan. 13.l.2 The considerable amount of development envisaged in the local plan will require an appropriate level of investment in services to match the anticipated housing and employment growth. 13.1.3 In addition to facilities which meet local needs, Littlebrook Power Station and Long Reach sewage treatment works are major utility sites in· the borough, which are of strategic importance. 13.1.4 The objectives of the local plan in relation to community facilities and public utilities are to ensure that the development strategy for the borough is not prejudiced by a lack of infrastructure facilities, and to foster the provision of facilities that meet the needs of the whole community. 159 POLICIES POLICY CFl Written Objection No 317 13.2.1 The objection was made on behalf of Blue Circle Properties Ltd. Summary of Objection 13.2.2 It was important that development opportunities were not constrained by a lack of necessary infrastructure. Additionally the cost of providing additional infrastructure should be shared equally between the main beneficiar ies. 13.2.3 Policy CFl should be amended by the addition of the word "normally". The Council's Response 13.2.4 The plan recognised that adequate service infrastructure was needed to facilitate the implementation of the development options identified in the plan. It was acknowledged that where the cost of service provision was to be borne by service providers and beneficiaries, it was important that these costs should be equitably borne. A change to the preamble to Policy CFl would emphasis this matter. 13.2.5 It would be inappropriate to permit development proposals where there was inadequate service infrastructure or an absence of agreement as to how any deficiency in provision might be overcome. Policies CFl and CF2 together sought to ensure adequate service facilities to meet the requirements of developments proposed by the plan. Providers of service infrastructure had been advised about, and consulted on, the plan to help enable them make adequate provision in their programming for any necessary works in the borough. 13.2.6 Policy CFl deliberately stated that development proposals would only be permitted where there was adequate service infrastructure or where there was agreement as to how any deficiencies could be overcome. The inclusion of the word "normally" in the policy would significantly undermine the thrust of the policy in that it would enable development to occur that could not be adequately serviced. This could also be detrimental to existing users. Service providers could also take such a policy amendment to indicate a reduced commitment by the council to the provision of adequate service facilities. It would therefore be inappropriate to include the word •normally" in the policy. Conclusions 13.2.7 The preamble to the policy currently makes no reference to the provision of additional or improved infrastructure. The commended change would add reference to the provision of new infrastructure, and indicate how the cost is to be met, which complies with Circular 16/91. 13.2.8 I consider that this is a case where the policy has to state in unambiguous terms that development will only be permitted where such development can be adequately serviced. The insertion of the word "normally" would indicate that exceptions may be permitted, which I would regard as unacceptable. 160 Written Obiegtion Ng 318 13.2.9 The objection was made by Southern Water Services Ltd and concierned the capacity of existing sewerage systems. Summary of Objection 13.2.10 Where a development would overload the sewerage system, new off-site sewers should be requisitioned so that all the flows from the site could be accommodated without overloading. The policy should be extended to include a statement to this effect. 13.2.11 Under the terms of the Water Industry Act 1991, there existed a mechanism for the provision of sewerage within a fixed timescale, but the only way that connections to public sewers which would cause flooding downstream could be resisted, was through the planning process. It would.therefore be satisfacto ry for the developer to requisition a sewer from the site to a point where sufficient capacity existed to accommodate the flows arising from the develop ment. The preamble to the policy should be modified to indicate this. The Council's Response 13.2.12 Policy CFl and its preamble were deliberately expressed in general terms so as to provide a clear policy base for all development related infrastructure. Sewerage was clearly a key element of infrastructure but was one of a number of such elements. The wording of the policy was appropriate to deal with the circumstances which concerned the objector, and no amendment or elaboration was necessary. f, Conclusions 13.2.13 I consider that the Policies CFl and CF2 as worded adequately set out the policy in general terms, and under the terms of Policy CFl, development would not be permitted unless it would be adequately served. The preamble to the policies however, should indicate to prospective developers the means by which any deficiency should be met. I am therefore recommending 8J1 addition to the preamble, which would set out the means by which any necessary improvement or additions to the infrastructure should be provided. Rtgg gp4etiPM : 13.2.14 I recommend that paragraph 13.3.1 be modified in accordance with commended change No 60; See also recommended modification to Policy Bl in Chapter 12. POLICY CF2 Obiection Ng 319 13.3.1 The objection was made on behalf of Blue Circle Properties Ltd. 161 Summary of Objection 13.3.2 The providers of service infrastructure should ensure that they make adequate provision to meet the needs of the borough, and in particular, that any additional provision which may be necessary to accommodate development proposals embodied in the local plan and beyond was appropriately programmed. The Council's Response 13.3.3 The purpose of the policy was to encourage providers of service infrastructure to make adequate provision available to meet the needs of the borough, and in particular, the development proposed in the plan. This development was quantifiable in broad terms, and could be taken account of by service providers in their capital programmes. However, development beyond the plan period additional to that proposed by the plan, was uncertain. It would therefore be unreasonable to expect service providers to programme for unknown levels of development. In any event, the review of the plan would roll forward the development strategy for the borough beyond the year 2001, and this revised strategy would provide the basis for future infrastructure provision. 13.3.4 The principal areas of longer term development potential were now identified in proposed new Policy APl, and the service providers would therefore be aware of such potential in relation to their investment programming. Conclusions 13.3.5 In my opinion it would be unreasonable to require, as part of a policy, any additional provision of service infrastructure to cater for possible needs beyond the period of the local plan, except where such longer terms needs are identified such as in Policy APl. The identification of Policy Area APl enables service providers to make informed decisions on their likely long term programme of capital works but I do not consider that provision of infrastructure so far in advance can be reasonably contained within a policy. I find no reason for extending the policy beyond the plan period, or for any other modification as a consequence of this objection. Written Objection No 320 13.3.6 The objection was made on behalf of London Electricity Plc. Summary of Objection 13.3.7 The plan should provide a policy framework to support the provision of public utility services, and Policy CF2 should be re-worded. The current wording indicated a lack of support from the council in terms of provision of public services infrastructure. The Council's Response 13.3.8 The first sentence of Policy 57 of the local plan already provided the level of encouragement and support sought by the objector. The amendments sought by the objector would not clarify or improve the policy approach. · Conclusions 13.3.9 I consider that Policies S7 and CF2, taken together, encourage the provision of appropriate service infrastructure, and set out the requirements for the service providers. I can see no reason to modify the policy in that regard. 162 los?'NW'MktiPP 13.3.10 I recommend no change to Policy CF2 as a consequence of this objection, but see recommended modification under Objection No.ClO below. ·I POLICY CF4 Representations Nos R33. R34 13.4.1 The Dartford and Gravesham Health Authority, and the South East Thames Regional Health Authority supported the proposals for residential development and a new District General Hospital at Darenth Park. There were no objections to the policy, but see Objection No.221 in Chapter 6. POLICY CFS Written Qbjections Nos 321 arui 322 13.S.l The objections were made by the Dartford and Gravesham Health Authority and on behalf of South East Thames Regional Health Authority. Summary of Objections 13.5.2 Policy CFS should make reference to the government guidelines in Circular 12/91, The Council's Response I~ 13.S.3 The objections were accepted, and a change to Policy CFS incorporating reference to government guidelines, was recolllllltlnded. The original commended change was amended, in which form it was supported by the objectors. Conclusions 13.5.4 I consider that the current wording of Policy CFS does not adequately set out the criteria for redevelopment of the site, which the commended change would correct by reference to government guidelines. Ob1ectiou No· 323 Representations Nos R54 RSS 13.5.S The objection was made by the Kent Trust for Nature Conservation, and concerned the proposed development at Mabledon Hospital. Summary of Objection 13.5.6 Although the site was a formerly built-up area, it now had a rich flora of chalk grassland species. It adjoined the Darenth Wood SSSI, and was also therefore an important woodland edge habitat. Part of the site should be designated an SNCI, and the CFS policy notation should be confined to the remainder of the site. 163 The Council's Response 13.5.7 There was inadequate information to determine the full extent of the nature conservation interest, and more evidence would be needed. From the evidence available, the site was well short of the quality of ecological interest to merit recognition as an SNCI in county terms. It was recognised that the site was worthy of some protection but not the full protection offered by Policy Cl4. 13.S.8 The nature conservation interest of the site and its proximity to the Darenth Wood SSSI were referred to in the preamble to Policy CFS. Nevertheless, changes to Policy CFS were recommended which, as amended at the inquiry, would refer to the need for development proposals to take "full account" of nature conservation matters. If sufficient nature conservation interests were revealed, those interests could be safeguarded by vigorous application of the policy. Previously, the nature conservation interest and development had co-existed for many years. 13.S.9 Dartford and Gravesham Health Authority (DGHA) and The South East Thames Regional Health Authority (SETRHA) supported Policy GB4(c) which proposed the redevlopment of Mabledon Hospital. Conclusions 13.S.10 On the basis of the evidence available to me, and in the absence of any studies carried out since 1989, I do not regard the objection site as having sufficient value to designate it as SNCI and thereby to be subject to the full protection of Policy Cl4. While chalk grassland is rare internationally, much of it occurs in Kent though it appears that there is little of significance in the Dartford Borough. The site has for many years been developed, during which time the activities on the site and the grassland have co-existed. It is not a par ticularly good example of chalk grassland, and occupies a relatively small area. None of the identified species of flora and fauna is specifically protected by law, and with the exception of the Man Orchid, they generally occur widely on the chalk lands of Kent and lowland England. I consider that the commended change to Policy CFS requiring development proposals to take full account of the nature conservation interest of the area, would adequately protect the site, The weight given to the nature conservation interest would depend on the information available at the time. 13.5.11 I recommend that Policy CFS be modified in accordance with commended changes Nos S8 and S9. POLICY CF6 Written Qbjection No 324 13.6.1 The objection was made by Doctors Sen and Patel, and concerned the provision of a surgery at Joyden's Wood. Summary of Objection 13.6.2 The need for a new doctors' surgery to meet the requirements of the community at Joyden's Wood had previously been brought to the attention of the council. A new surgery in the Joyden's Wood area should be provided before any major new housing development was permitted. i 164 The Council's Response 13.6.3 This matter was referred to in the response to Objection 43 et al in Chapter 4. Conclusion 13.6.4 The recommended modifications to Policy H3 would allow for the provision of a surgery to serve the Joyden's Wood area, and I do not consider that there is any need to make a further modification to this policy. RocremrwJetigp 13.6.5 I recommend no change to Policy CF6 as a consequence of this objecion. POLICY CF7 Written Qbjectign Ng 325 Represeutatigns Nos R38.R39,R119,Rl23 13.7.1 The objection was made by the Royal Society for the Protection of Birds (RSPB). Summary of Objection 13.7.2 The RSPB welcomed the inclusion of a provision for nature conservation within Policy CF7. However, there was a need for more information on the wildlife interest and extent of the development proposals affecting the site, before all the implications could be assessed. The Council's Response 13.7.3 The policy stated that development proposals should be formulated on the basis of a development brief to be agreed with the council. The policy's recognition of the nature conservation interests of the site had been welcomed by the relevant Health Authorities, Thames Polytechnic and the Kent Trust for Nature Conservation. 13.7.4 An outline planning application for an educational campus had been submitted. A detailed study of the nature conservation implications of the development had been submitted, and the principal nature conservation bodies, including the Kent Trust for Nature Conservation, had been consulted and had not objected to the proposal. The need for more information was noted, and nature conservation interest was an important issue to be addressed on this site. Policy CF7 required it to be taken into account, and no amendment to the policy was necessary. 13.7.5 The Dartford and Gravesham Health Authority, the South East Thames Regional Health Authority, the Kent Trust for Nature Conservation, and Thames Polytechnic supported the structured approach to developments in North Dartford, and in particular the proposals for a major educational campus. Conclusions 13.7.6 The exact nature of the objection is not very clear, but reference is made to the need for more information on the wildlife interest. While the policy requires the developers to take due account of the nature conservation interest of the area and be appropriately related to the redefined Green Belt boundary, no 165 reference to these aspects of the development is made in the preceding paragraph 13.3.7. In my opinion, the preamble should draw attention to the location of the site within the Green Belt, and to the proximity of the Site of Nature Conserva tion Interest which is proposed to be a Local Nature Reserve. 13.7.7 The nature conservation interests of the area are also referred to in the recommended modifications to Policy RT4 in Chapter 9. Roso n4a,tiqn 13.7.8 I recommend that: 1. paragraph 13.3.7 be modified by the deletion of the words [and be an envirot1111entally appropriate form of development in this area]; 2. a new paragraph be inserted after paragraph 13.3.7 stating that the identified area is located within the Green Belt and adjacent to a Site of Nature Conservation Interest designated as a proposed Local Nature Reserve. An environmentally appropriate form of development will be required in this area. POLICY CFS Repreaentation No R120 13.8.1 Kent County Council wrote in support of the safeguarding of the identified sites (but see Objection No.327 below). There were no objections to this policy. POLICY CF12 Written Objection No 326 13.9.1 The objection was made by Mr D E May. Summary of Objection 13.9.2 The previous policy in the town plan had stated that there would be no loss of allotment land, and required that new allotments should be in close proximity to those replaced. The deposit version of the local plan policy however,· allowed for allotment land to be lost if an absence of need could be established. This proviso was vague. If allotment holders were relocated there was no requirement in the policy for replacement sites to be in close proximity to the existing facility. The Council's Response 13.9.3 The criterion regarding the establishment of an absence of need for existing allotment land was reasonable in that where there was an absence of need then the facility would not be used. In these circumstances it would be appropriate to consider other economic uses for the site. 13.9.4 With regard to the second criterion, it was not the intention that the policy should be used to enable the provision of replacement or relocated allotments to be inappropriately located in relation to existing users. 166 Allotments were regarded as facilities at a very local level which needed to be closely related to the community they served, and this perception would properly influence the application of the policy. Conclusions 13.9.5 The preamble to the policy indicates that there is no quantitative need for additional provision of allotment sites. Where it can be established that there is no need for the existing facility then I consider it reasonable for alternative uses of the land to be considered. Development could involve a range of possible uses, including not only buildings but also public open space uses. 13.9.6 In order to meet the objection to the alternative criterion of replacement or relocation, the policy would have to be interpreted sensitively. The council state that it is not their intention that replacement or relocated allotments should be inappropriately located, but there is no requirement in the policy for any replacement or relocated plots to be appropriately situated, In my opinion the concern of the objector is a legitimate one, and I consider that the preamble to the policy should be expanded to clarify the intention of the policy. Res• IMlatton 13.9.7 I recommend that a new paragraph be inserted after paragraph 13.3.13 to the effect that the Council propose to retain allotment plots wherever they serve a local need. In situations where the need has declined, proposals for alterna tive uses will be considered provided that there is no longer any local need, or that alternative suitable sites can be provided in the locality. POLICY CF13 Hrittep Objectiop No 220 RepreAentation No.121 13.10.1 The objection was made by Kent County Council. Summary of Objection 13.10.2 Land at Longfield should be allocated for a link services centre. The Council's Response 13.10.3 Allocation of land for a link·services centre would not conflict with Green Belt policy. Policy CFlO and para 13.3.1 already referred to community needs at Longfield. Changes to these were recommended so as to include specific reference to identifying land for a link services centre at Longfield. 13.10.4 London Electricity Plc supported the policy. Conclusion 13.10.5 Although originally an objection to inclusion of the land within the Green Belt, the allocation of such a community facility would not contravene the Green Belt policy. A need for the link services centre has been identified, and I can find no reason for not supporting its inclusion within the provisions of the plan. 167 los•t!PMld.etign 13.10.6 I recommend that: 1. paragraph 13.3.11 be modified in accordance with commended change No. 65; 2. Policy CFlO be modified in accordance with commended change No.66; 3. the Proposals Map be modified in accordance with commended change No. 86. , 168 ABSENCE OF POLICIES LACK OF A FRAMEWORK POLICY FOR EDUCATION PROVISION Written Qb1ection No 327 13.11.l The objection was made by Kent County Council. Summary of Objection 13.11.2 A general framework policy should be included in the local plan, to the effect that developers of substantial sites for residential use should make adequate provision of land for new educational facilities in their development master plan, where the magnitude of the proposed development warranted such provision, The education authority should not be financially disadvantaged by such schemes, and would seek the land to be made available at no cost to the county council. Furthermore, there should be a contribution made towards the cost of the new school by the developer. 13.11.3 In reply to the commended change to Policy CF3, a further modification should be made requiring the provision for new school facilities necessitated by the development, to be made at nil cost. The Council's Response 13.11.4 It was accepted that major residential developments should make provision for educational requirements resulting from the scheme. There would however, be only a few developments which were on such a scale that they would generate the need for a new school, and be able to make the land available as part of the overall scheme. Nevertheless, there would be some schemes which generated a need for new educational facilities. In these instances a financial contribution towards new classroom facilities at nearby existing schools would be more appropriate than provision of land. 13.11.5 The recommended change to Policy CF3 had been worded in a manner which was flexible enough to enable the provision to be made in the form of land and/or a financial contribution, depending on which would be the most appropriate for each case. Conclusion 13.11.6 In my opinion the commended change to Policy CF3 would be adequate to meet the concerns of the objector. I do not consider that a new policy is necessary. The preamble to the policy however, indicates that the council expect the service providers, including the county council, to ensure that there will be an adequate provision of education facilities to meet both current and future needs in the borough. In view of the additional statement in the policy, I consider that there needs to be a corresponding reference in the preamble. I do not consider that there is a necessity for the policy to refer to the provision of new school facilities at nil cost. Any contribution would depend on the particular circumstances of the case. 169 Rocg77pgvletign 13.11.7 I recommend that: 1. paragraph 13.3.2 be modified by the addition of a sentence after the words "investment programmes• stating that developers of major housing schemes will be expected to make appropriate contributions by the dedication of land and/or the making of a financial contribution, towards the cost of additional or new facilities where such facilities are necessitated by the development. The remainder of paragraph 13.3.2 should form a new paragraph. 2. Policy CF3 be modified in accordance with commended change No.62. ABSENCE OF POLICY RELATING TO LONG REACH SEWAGE WORKS Written Objection No 328 13.12.1 The objection was made by Thames Water Utilities. Summary of Objection 13.12.2 Long Reach Sewage Treatment Works was recognised in the plan as being a major utility site of strategic importance. It adjoined Littlebrook Power Station to the east, and was enclosed to the west and south by land with designated proposed uses. The works' ability to expand or deal effectively with new methods of waste disposal should not be compromised by the developments or designations on surrounding land. 13.12.3 The plan should positively recognise that the objector expected to expand operational activity at Long Reach during the plan period. This would be necessary to meet the expected increased demand resulting from the new develop ment proposed in the North Dartford area, and perceived changes in populations within the catchment. There should be a policy designation applied to the treatment works, which would recognise the need for the expansion of the works, and ensure that development on adjoining land provided adequate protection to the treatment works. The Council's Response 13.12.4 Planning permission had been granted in 1990 for the use of land to the west of Long Reach Sewage Treatment Works for Thames Water operational purposes. This land was shown on the Proposals Map as removed from the Green Belt as part of the adjustments to boundaries in the area north-east of Dartford generally, consequent upon Structure Plan Policy MGB3. No other additional land-take requirements had been notified. 13.12.5 As a matter of course, in considering any development proposals on adjoining land, or at the Long Reach works themselves, the inter-relationship with adjoining sites and proposals would be properly taken into account, There was no need for an additional policy. Conclusions 13.12.6 The Proposals Map shows a strip of land along the western side of the treatment works as being available for expansion of the works. I am not aware thst any additional land over and above this is required for future expansion 170 needs. The impact on the works of any proposals on the Dartford Marshes or proposed polytechnic sites would be s legitimate matter to be taken into account as part of the development control process, but in my view there is no need for a specific policy to protect the sewage treatment works. 13.12.7 Reference to the possibility of a westerly expansion to the works could be included in any development brief for proposals on the adjoining land; this would avoid possible misunderstandings in future should problems of amenity arise. 13.12.8 I recommend that there be no new policy as a consequence of this objection. 171 OBJECTIONS TQ COMMENDED CHANGES COMMENDED CHANGE NO 60 Written obiection No Cll 13.13.1 The objection was made by Southern Water Services Ltd, and concerned the commended change to Policy CFl. Summary of Objection 13.13.2 The preamble to the policy referred.to all services but specifically mentioned drainage, water supply and sewerage. For these specifically mentioned services, the Water Industry Act 1991 provided a legal framework for the provision of, and funding of, water related infrastructure. The provisions of the Water Act did not preclude the equitable sharing of costs between developers and the landowners. The Council's Response 13.13.3 The most appropriate means of meeting the objector's points was through use of Section 106 Agreements. The council had followed this approach and had found it to be an appropriate mechanism. Conclusion 13.13.4 Although the council prefer the use of Section 106 Agreements, Circular 16/91 explicitly states that such agreements are not necessary because it is the developer's responsibility to requisition for water supply, sewerage or sewage disposal under the appropriate sections of the 1989 Water Act. 13.13.5 The policy and its preamble refer to the provision of infrastructure generally, and there may be cases where a Section 106 Agreement would be the most appropriate method for achieving such provision. In my opinion however the provision of roads to adoptable standards, drainage, sewerage and water supply should be provided by means of the relevant legislation. I therefore consider that reference to the legislation should be included in the preamble to the policy. Reon JMlatigp 13.13.6 I recommend that a new paragraph be inserted after paragraph 13.3.1 stating that where service infrastructure is not available or is inadequate, the council will consider mechanisms for providing new infrastructure which will enable the cost of provision to be borne equitably among service providers and beneficiaries, including developers and land owners. Sewerage and water supply should be requi sitioned within the terms of the Water Industry Act 1991, and highway improvements should be carried out by means of an agreement with the I Highway Authority. 172 COMMENPED CHANGE NQ 61 Written Ob1ection No ClO 13.14.1 The objection was made on behalf of London Electricity Plc, and concerned the commended change to Policy CF2. Summary of Objection 13.14.2 The commended additional wording was opposed on the grounds that the reasoning for its inclusion was vague, and its application would be impractical. Furthermore the preamble to Policy CF2 made .no reference to environmental impact. 13.14.3 The proposed additional wording established an unnecessary conflict between infrastructure provision and environmental protection. It removed the presumption in favour of infrastructure provision, which was contrary to one of the plan's main objectives. It also represented an unnecessary duplication of other policies in the plan. The Council's Response 13.14.4 There was some misunderstanding regarding the commended changes to Policy CF2. In response to the CPRE's objection, two changes to the plan were recommended, one dealing with the issue of water resources through the provision of an additional clause to Policy Bl, and the other a change to Policy CF2 dealing with the environmental impact of infrastructure provision. It would not be the council's intention to apply Policy CF2 in an unreasonable manner, and it was consistent with the policy approach of the local plan generally, in attaching due weight to environmental matters in the consideration of proposals. Conclusion 13.14.5 The preamble to Policy CF2 makes no reference to environmental considerations, and there are no criteria stated as to what would be environmentally acceptable. In that respect the commended change to the policy is imprecise. Nevertheless, I consider that the policy should require public utilities and others providing services, to have regard to environmental considerations, and to other relevant policies of the plan. I therefore propose to recommend a modification which would be similar to, but worded differently from, the commended change. Resz ndatiw 13.14.6 I recommend that Policy CF2 be modified by the addition of a sentence after the words "appropriately programmed", stating that the provision of any new infrastructure should have regard to environment.al considerations and other policies of the plan. 173 CHAl'Tlll 14 - DAll.TFOllD 'lOWll CBR'l'llB ' ,1 BACKGROUND 14.1.1 The structure plan identifies the county's town centres as a· focus for buildings and townscape of exceptional architectural and historic character, It regards the quality of the built environment in town centres as of growing importance to their retailing, leisure and tourism functions. Structure plan Policy BEl encourages development which will support the coDDDercial and leisure role of town centres, while maintaining and enhancing their visual and functional quality. 14.1.2 Development proposals are required to be acceptable in functional terms, and regard is to be had to:- the protection of townscape of character; vehicular and pedestrian movement, and car parking; the needs of housing, coDDDerce and industry; provision for public and community services and facilities, including public open space; and the availability and capacity of infrastructure. Structure plan Policy BEl places particular emphasis on the importance of visual and architectural design, and attention is drawn to the guidelines in the Kent Design Guide. 14.1.3 Dartford Town Centre is the principal centre in the borough. The local plan seeks to consolidate and strengthen its role, taking account of trends and developments in the borough as a whole, inclu.ding the Bluewater proposals. The council sees other developments in the borough as complementing rather than undermining, the role of the town centre. 14.1.4 The town of Dartford has a long history, having developed along the line of Watling Street. The original nucleus of the town has grown into the modern town ce')ire, much of which is designated as a conservation area. A distinctive feature~central Park which penetrates almost to the core of the town centre. 174 POLICIES PARAGRAPHS 14.3.9, 14.3.12 14.2.1 Although there were no objections to these paragraphs, I rec9!!!!1!§!!d that reference to Darenth Road in paragraph 14.3.9, and to Darenth Road car park in paragraph 14.3.12 should be deleted. These are consequences of my reconaended modifications to Policies Tl4 and T24(c) in Chapter 7. POLICIES TC5, TC7, TCS, TC9, TClO AND TC12 Written Objections NoS 330. 332-335 an 14.3.1 The objections were made by Thames Water Utilities, and concerned the impact of development on underground water supplies. Summary of Objections 14.3.2 Land for development was identified under each of the above policies, which could affect underground water supplies. The objector should therefore be consulted on proposals at the earliest opportunity, and all the policies should require development proposals to pay regard to the National Rivers Authority (NRA) groundwate~ protection policy. The Council's Response 14.3.3 It was accepted that development of the identified sites could affect the quality of the underground water supplies. The issue however, could also arise on sites not currently identified in the local plan as having development potential, and it would be more appropriate to deal with this issue through a development control policy of general application, rather than amending the site specific policies referred to in the objections. An additional criterion to Policy Bl was therefore recommended which would require development proposals to take into account the effect on underground water supply, and stating that they must consult the NRA and the relevant water undertaking as appropriate. Conclusion 14.3.4 As considered under earlier objections, I agree that the principle of the objection extends beyond identified sites. I thus support the commended change to Policy Bl. Begg ndetign 14.3.5 See recommended modification to Policy Bl in Chapter 12. POLICY TC6 Written Qbjectjon No 331 14.4.1 The objection was made by Thames Water Utilities. 175 8U1111Dary of Objection 14.4.2 The policy proposed major office, hotel or housing development at Overy Street which was directly adjacent to Dartford Pumping Station. The development could pose a serious threat to the quality of the water abstracted. The objectors should therefore be consulted on these developments at the earliest opportunity, and the policy should include a statement that proposals should have regard to the NRA groundwater protection policy. 14.4.3 The objector also had a requirement to maintain Dartford Pumping Station for operational purposes, and to add certain items of equipment in order to improve the water quality. Development proposals should have regard to these requirements. The Council's Response 14.4.4 It was accepted that proper provision should be made for the operational requirements of Dartford Pumping Station, and that the policy should be amended accordingly. The effect on underground water supply was covered by a change to Policy Bl discussed above. Conclusion 14.4.5 Policy Area TC6 encloses the pumping station on three sides, and I consider that it would be appropriate for the operational requirements of Dartford Pumping Station to be brought to the attention of a potential developer, within the policy. I therefore agree with the commended change to Policy TC6. 14.4.6 I note that the objector also included policy area TC7 within the objection. That site does not adjoin the pumping station, and I consider that the objectors' requirements are met by the proposed change to Policy Bl. In my view there is no further need for a site specific reference. Bestnzngt•gton 14.4.7 I recommend that Policy TC6 be modified in accordance with commended change No 67. POLICIES TC2 AND TClO (ALSO POLICY T24(a)) Written Objection No 263 14.5.1 The objection was made on behalf of the Ramblers Association; Kent Area. Summary of Objection 14.5.2 There should be provision in the plan for informal recreation within the urban area. The facilities listed in paragraph 9.1.3 would require payment from those using them, and there did not appear to be areas such as gardens allowed for in the plan. Areas where people could relax informally should be provided in the town centre, within sites listed for town centre purposes such as the proposed car park east of Lowfield Street (Policy T.24). The Council's Response 14.5.3 Central Park provided a major facility for the town centre, and Policy RT13 sought to safeguard its recreational and environmental value. Policy TCll proposed an increase in the area of the park. 176 Conc1usion 14,5,4 It appears to me that the objector is referring to relatively small, informal amenity areas, to which the plan makes no specific .reference. Reference is made in Chapters 7 and 14 to pedestrianisation of parts of the town centre, which may imply the provision of some sitting out or garden areas, but no provision of facilities for pedestrians to relax is mentioned. Paragraph 7.3.26 and Policy T27 refer to the requirement for safe and convenient facilities for pedestrians, and Policy Bl5 encourages environmental improvements. Policy TC3 aims to enhance the environment of the town centre. Provision of facilities for disabled and less mobile people is required under Policy Bl4. 14,5.5 In my opinion, the type of facility to which the objector refers would not be provided in its own right, but would be an ancillary part of a development scheme. As such, it would be included in the general amenity features associated with good design. Although there is no specific reference to such provision in the plan, I consider that there are several references to the need for good standards of design and environment; attractive features such as the provision of areas for a period of relaxation, should form part of the design. I can see no reason for a specific reference in a policy for facilities of that nature. B@s~p4otigp 14.5.6 I recommend no change to Policies TC2 or TClO as a consequence of this objection. POLICIES TClO, TCll AND PARAGRAPH 14.3.31 Objections Nos 329 and 336 14.6.l The objections were made on behalf of Vas (Kent) Ltd, and concerned premises at Vauxhall Place, Lowfield Street, Dartford. Summary of Objections 14.6.2 The local plan proposals would prejudice the business, in that improved pedestrian access to Central Park would bisect the objection site creating operational and security problems. 14.6.3 The policies would displace the operator from the site, and it would be difficult to find alternative accommodation. The business was well-known and well-situated for the specialist business associated with touring caravans. The Council's Response 14.6.4 The policies were permissive and not prescriptive. The objector's concerns about the identification of Vauxhall Place as a pedestrian access were accepted however, and specific references at paragraph 14.3.31 and Policy TCll should be deleted. 14.6.5 The council had no wish to displace any business by compulsion; the intention was to provide a positive basis for the consideration of development proposals should they arise at some future date during the plan period. Nevertheless, changes to the wording of Policies TClO and TCll were recommended in order to remove any ambiguities in the policies. 177 Conclusions 14.6.6 Both Policies TClO and TCll include provision for improved pedestrian access to Central Park, and the two policies are linked; the objection site is common to both policies. Paragraph 14.3.31 also refers to Vauxhall Place as a possible route for improved pedestrian access to Central Park. 14.6.7 There are currently no proposals for redevelopment of this area, as the intention of the policies is that they should provide an opportunity rather than an imposition, ·but I regard any reference to Vauxhall Place as placing an unnecessary blight on the objection site. 14.6.8 In my view the commended changes to TClO and TCll avoid any pre judgement of Vauxhall Place as a new pedestrian route to Central Park, which would require access across the objection site. 14.6.9 The area around the objection site appears to have potential for redevelopment, and Policies TClO and TCll indicate the type of development considered appropriate when suitable opportunities arise. I cannot envisage circumstances when Compulsory Purchase Orders would be appropriate, and nothing in the plan suggests that the objectors would be forced to cease trading on the objection site against their will. leggm=pdeti9Q1 14.6.10 I recommend that: 1. Policy TClO be modified in accordance with commended change No.S23; 2. Paragraph 14.3.31 be modified in accordance with commended change No.SlO. POLICY TCll Written Qbjection No. 337 14.7.l The objection was made by Mrs L Mason. Summary of Objection 14.7.2 The site should not be used for housing but should be retained and enhanced for recreational purposes. The proposal was contrary to Policy RT13. The Council's Response 14.7.3 The policy area currently contained a mix of land uses, including private housing, retail and commercial properties, a club, privately used open space and a former nursery. The area was in need of improvement, and parts of it were either unused or underused. The local plan proposals provided a basis for securing such improvements and a better use of land, including an extension to Central Park. These benefits would outweigh the curtailment of the existing recreational uses. 14.7.4 Policy RT13 applied to the existing area of Central Park together with the extension area referred to above. The proposals for policy area TCll did not conflict with it, and would result in an increase in the area to which the public had access, 178 ' Conclusions 14.7.5 The policy area is adjacent to a public swimming baths, and an athletics track. Central Park contains a bowling green, and to the east of Central Park are the playing fields belonging to the Wellcome Foundation, which include a sports hall. and tennis courts. In these circumstances, I do not regard the area as deficient in recreational facilities. Policy Area TCll includes an area for the extension of the park, and the policy requires proposals to provide for a new pedestrian access to Central Park. I can therefore see no necessity for Policy TCll to make additional provision for recreational facilities. 14.7.6 The objection appears to refer to the need to make provision for organised recreation including a training area, with the possibility of an income being derived from such a provision. I consider that any such proposal would have to be considered on its merits, having regard to all material considerations including the traffic attraction of such a facility. I have no evidence that there is a need for such a facility, or that the objection site would be the most appropriate location for it. Written Qb1ection No 338 14.7.7 The objection was made by Mr A J Champion. Summary of Objection 14.7.8 Dartford Harriers Pavilion was not shown on the proposals map. The Council's Response 14.7.9 The objector wished to provide a new pavilion within the confines of the Athletics Track in Dartford Central Park. There was however no specific proposal which it would be appropriate to show as such on the local plan proposals map. The development of such a facility would not conflict in principle, with the policies and proposals of the local plan, and Policy RT13 allowed for appropriate recreational development. Such a proposal could be appropriately handled through the development control process. It was therefore not considered necessary to amend the proposals map to show a site for the sports pavilion at the athletics track in Central Park. Conclusion 14.7.10 The provisions of Policy RT13 would not preclude the building of a new pavilion within the confines of the athletics track in Central Park. Such a facility could be regarded as directly associated with the recreational function of the open space, and I do not consider that there is any need for any specific reference to a pavilion in the plan. Regmp ndation 14.7.11 I recommend no change to Policy TCll or the Proposals Map as a consequence of these objections, but for reasons given above, I recommend that Policy TCll be modified in accordance with commended change No.S24. ;;. l 179 I I ADDENDUM I ' !i :I ' . ! L ' The Planning Inspectorate An Executive Agency In the Department ofthe Environment and the Welsh Office ...... '-'... Room 13/0J .;utt-·co t Line 0272-218902 Tollgate House ..,.J 11"' · ard 0272-218811 Houlton Street ,, ·· 1./'.,) 0272-218769 Bristol BS2 9DJ /·,,_~ " \~~ 1374-8902 '':.[ '" i;\f>.'\ I Development Planning Dartford Borough coun l Civic Centre Home Gardens Dartford Date: 13 May 1993 Kent DAl lDR Dear Sir INSPECTOR'S REPORT INTO OBJECTIONS TO THB DARTFORD LOCAL PLAN REQUEST FOR CLARIFICATION 1. I refer to your letter of 29 April 1993 requesting clarification of certain points contained within the Inspector's report. 2. The matters have been raised with the Inspector, and his response has been submitted in the form of an addendum report. 3. A copy of your letter and the addendum are attached. These should form part of the Local Plan report and be published accordingly. Yours sincerely CfYl~ c M Pritchard Development Plans , I BOROUGH OF DARTFORD LOCAL PLAN ADDENDUM TO INSPECTOR'S REPORT para. 4.16.15 (p.29) amend Recommendation 1. to read: 1. paragraph 4.3.2 be modified in accordance with commended change No.10 as amended by commended change No.83. para.4.28.14 (p.49) add new sentence at the end of the recommendation: See recommended change in Chapter 6, para.6.2.28. para. 6.2.28 (p.76) add new sub-heading: f. The allocated school site at Rectory Meadow, Southfleet. para.11.3.4 (p.151) amend the second sentence to read: It has no ShQp or post office, and I would agree with the view that it )l.il' ~ diffuse cparacter. ' ' Iii:nest W Smi!=l) Jnsp~!ltor · ' Directorate ofDevelopment and Leisure Michael Wilson Dirrctor pllllilfletcher Head ofProperty Services DARTFORD Ch..Dl•hop Head ofArts and Lei.mre Barougb Council Adrian Penfold Head ofPlanning and Design Civic Centre, Homo Gardens, Darlford, Kent, DAl lDR Tel: (0322) 343434 Mr C M Pritchard Ploue"*for: Mr J Underhill The Planning Inspectorate DINc& Line: (11322) 343 2 0 7 Room 13/01 Direct Pax 0322-343047 'i Tollgate Bouse YoarlW: PINS/T2215/429/1 Boulton Street 0urn.r: JCU/E. 6097 Bristol BS2 9DJ L _J Dole: 29th April 1993 Dear Mr Pritchard :.11 I 11 BOROUGH OP DARTFORD LOCAL P:LIUI ;I, IHSPBCTOR'S RBPORT IHTO OBJBCTIOllS ',') I Further to the Chief Executive's letter to you of 19th March in response to yours of 3rd March, I am writing to you now ~o draw your attention to three matters in the Inspector's report :ui the context of possible ambiguities referred to in your letter. They are as followsa- Objection Hoa. 161-163 ~t paragraph 4.16.15 of his report, the Inspector reconunends that paragraph 4.3.2 of the Plan be modified on the basis of the Council's conunended change no. 10. Be also recOlllmends that Policy H2 be modified, in accordance with conunended change no. 11 as amended by commended change no. S3. However commended change S3 also proposes the amendment of paragraph 4.3.2, but this is not referred to in the Inspector's recommendation. The Council would wish to progress the proposed change at S3 to paragraph 4.3.2· through a modification and it would be helpful to know . whether this approach has the Inspector's endorsement. Objection Hos. 30-32, 211 (part) (pp 47-49) '11 I ' ' These objections sought the identification of four sites for I , housing development at Southfleet, but I draw your attention in : i this· letter particularly to the Rectory Meadow school site (paragraphs 4.28.4, 4.28.7, and 4.28.11 of the Inspector's report). · The Inspector recommends no change to the allocation of these· sites as a consequence of the objections. It is clear that the Inspector sees the school site (and indeed the others) as fulfilling Green Belt functions and his conclusions and recommendation are made on this basis. The Council's written representation is also predicated on a similar basis. However '., I i' ij'.'i ~ cont'd/•••••••••• f,':; I!1 ,,I '• Fu. No: (0322) 343422 DX 31908 :~}II:~ - - 2 whilst the Local Plan Proposals Map shows the sites (including the school site) lying outside the defined village confines of Southfleet, the Proposals Map Green Belt tone does not overlay the school site. This situation - in which land beyond the confines is not shown as Green Belt - arises nowhere else in the Local Plan and does not conform with the Plan's otherwise consistent approach of village confines and the Green Belt boundary being co terminous. It appears to be a draughting error not previously identified. Neither was this distinction in Green Belt terms between the school site and the other three apparent from the objections themselves, the documentation for which included a black-and-white copy extract from the Proposals Map showing the village confines but not the Green Belt tone. In the light of the Inspector's conclusion at paragraph 4.28.13 as to the absence of exceptional ·circumstances to warrant removal of any of these sites from the Green Belt and in order to address the inconsistency referred to above, it seems appropriate to the Council that a modification be brought forward showing the school site as lying within the Green Belt. This would also be consistent with the Inspector's approach elsewhere of showing school si~es at the edges of settlements as lying within the Green Belt (see page 76 of his report). Objection No. 311 (pl51) This objection sought the identification of the settlement of Westwood as a village for the purpose of Structure Plan policies. The Inspector recommends no change to Policy Vl as a consequence of this objection, but at paragraph 11.3.4 he comments that Westwood has no public house. In fact it does (the 'Wheatsheaf')• The Council's Planning and Transportation Committee will' be meeting on Bth June to consider the Inspector's report, and the re~ort for t_hat meeting will clearly need to be finalised a little while beforehand. If the Inspectorate wishes to respond to any of these matters perhaps you could let me know as soon as possible. Yours sincerely <;f~,J;f DEVELOPMENT PLANNING MANAGER lo/plan/jupritch. APPBAR.\BCSS FOR DARTFORD BOROUGH COURClL Mr Robert Griffiths of Coun•el instructed by Mr M N Wilson Director of Development and Leisure Civic Centre Rome Gardens Dartford Kent DAl lDR Be called: Mr A P Penfold, BA (Bona) Dp TP, MRTPI Chief Planning and Design Officer Dartford Borough Council Mr J c Underhill Dip TP, MRTPI Chief Planning Assistant (Forward Planning) Dartford Borough Council Mr J C Smith C Eng. MICE Policy Manager Dartford Borough Council Mr P J Buckley BA Bona, DIP TP, MRTPI Senior Planning Assistant (Forward Planning) Dartford Borough Council Mr A M Legg BA Bona, BTP, MRTPI Principal Planning Assistant (Development Control) Dartford Borough Council Mr A J Hoare Dip TP, MRTPI Chief Planning Assistant (Development Control) Dartford Borough Council Mr J Payne C Eng, MICE Team Leader (Traffic Planning), North Kent Kent County Council Mr J Arnold Dip TP, MRTPI Senior Planning Assistant (Forward Planning) Dartford Borough Council Mr C A Perkin MCIM, MIPR, M.Inat D, Principal MBIM, MIED Colin Perkin Associates 1 •• -- Mr A Hitchcott BSC HONS, MSC, Dip Ecology Group LA, C Biol, MI Biol, MI Env Sci Leader and Landscape Architect Kelsey Associates Mr M P Roberts BSC Hons, Dip TP, Head of Town Planning MSC, ARICS, MRTPI Fuller Pieser Ms D Thornton BSC, MSC Head of Ecology (Midlands Area) Environmental Advisory Unit Ltd OBJBCTIORS AND RBPRB8BRTATIORS Objection Ro.38 (Southwark Roman Catholic Diocese) Mr C Burton, Solicitor of Rawlinson and Butler Solicitors Griffin House 135 High Street Crawley West Sussex RBlO lDQ Be called: Mr G K Simpkin Dip TP, MRTPI, Planning and Development Consultant of Graham Simpkin Chartered Town Planners and Development Consultants 2 The Parade Ash Road Hartley Dartford Kent DA3 8BG Objection Ro.168 Repre•entation Ko•.R122, R56 (South East Thames Regional Health Authority) Mr D Woods, Solicitor Benan Ashford 35 Tolston Avenue Bristol BSl 4TT 2 Objection Mo.171 (DBT Bolding•) Ltd Mr G Warren MA, FRICS, MRTPI Senior Partner Chapman Warren 3 Grosvenor Street London WlX 9FA Be called1 Mr s W Chadwick Bae (Bona) ARICS Partner of Chapman Warren 3 Grosvenor Street London WlX 9FA Objection Mo.68 Mr P James Lugano Stock Lane Wilmington Kent DA2 7BY Repre•entation Ro. R18 (Majorhive Ltd) Mr D Jarman BA (Bona) MA, MRTPI Partner BSF Planning Consultants 67a Castle Street Canterbury Kent CTl 2PY Objection Ro.9& Mr G J Lawrence 58 Birchwood Road Wilmington Dartford Kent DA2 7HE Objection Ro.107 Mr E F Riddles 55 Birchwood Road Wilmington Dartford Kent DA2 7HF Objection Ro.81 Mr R F Cobbett 15 Birchwood Drive Wilmington Dartford Kent DA2 7NE 3 Objectioll llo.95 (Mr• P A Laweoll) Mr Lawson 79 Birchwood Road Wilmington Dartford Kent DA2 7HQ ObjectiOll Ro.BO Mr B C Cobb 17 Birchwood Road Wilmington Dartford Kent DA2 7HF Objectioll Ro.120 65 Birchwood Road Mrs L M Travella Wilmington (also representing Dartford Mrs O Hurley - Objection No.88) Kent DA2 7HF Objection Hoe. 139 and 156 1 Yew Tree Cottages Mrs M N Salway Station Road (Also representing Southfleet Betsham Parish Council, Objection Nos Nr Gravesend 140 and 155) Kent DA13 9PJ Mr S Alabaster, Objection Noa. 128 and 1441 Mr and Mrs K V Barden, Objection Noa. 129 and 1451 Mr K Boddy Objection Noa. 130 and 1461 Mr and Mrs K J Harrison Objection Noe. 135 and 1511 Mr and Mrs R Hoadley Objection No.239 Mr A Lidsey) Objection No.136; Mr B E A Tolmie, Objection Noa. 141 and 156, Mr P Wanless Objection Noe. 142 and 157). Objection Ho.313 and Repreeentatioll R20 (Mr F G Meakin) Mr J B Pike FSVA Head of Land and New Homes Division General Accident Property Services 3 Spital Street Dartford Kent DAl lEH 4 L , ObjectiOD 179 (Creat Rome• (Soutlle;na) J;e:t, lfard •-•, Perai-D 8099a, Da ViDoi Propertiea, , I Berkely •-•> Objaotioa Roa.2, 169, 3D•, 3•3, 259, 3•1 (Maria• sooi-4:y) Mr Matthew Borton Queen's Counsel instructed by Mr P W Match"8 Maples Teesdale Solicitors 21 Lincoln's Inn Fields London WClA 3DU Objaotioa Bo.19• Mr J W E IU.xaon 26 Weald Close Istead Rise Northfla•t Kent DA13 9JX Objeotioa Bo.2•9 Mr S D Webb "Silverlea• 109 Darenth Road Dartford Kent DAl lNJ Objactioa No.255 (Stone Pariah Council) Clerk to Stone Parish Mrs K Chidley Council Council Offices Hayes Road Greenhithe Kent DA Object .OD lloa.199-206 208-2!)9 (Mr J M Adama, <*jeotioo lf0.1991 Mr J C Evaoa, ObjeotiOD &o.2001 Mr aad ~· rito•••· Qbj~tioa 80.2011 Mr c Gray, ObjaotiC>D ~o.202J 11r r Milaa, Obj•ctioa ¥0.2031 Mr c Millaar, ObjeCi14:i011t·~.2CNJ 11r s P Plitoa, Ob:J•9':.t.• -..2os1 Mr J Payna, Gb:Jactioa ~o·.:ao61 Mr A a Towia, Ob:Jectio• ll0.2011 Mr B A a lfood, ObjtlC!tips ...205) \ Mr M c Copsey FRIC,, Il'IRV Mundars Ltd 165 K nga Road Brentwood Essex CM14 4EG 5 Objection •o.207 Mr C D Sharp Orchard Cottage Main Road Longfield Kent DA3 7AS Objection Nos.329 an4 336 (VAS (Kent) Lt4) Mr R D Dewar LLB 6 Fairlight Cross Longfield Kent DA3 7JD Be called: Mr D J White VAS (Kent) Ltd Vauxhall Place Lowfield Street Dartford Kent DAl lBU Objection No.287 Crest Rom•• (Southern) Lt4 Mr Rhodri Price-Lewis of Counsel instructed by Mr I D Bull, MRTPI, Strategic Land Co-ordinator Crest Homes (Southern) Ltd Crest Bouse 30 High Street Westerham Kent TN16 lRG He called: Mr I D Bull B.Tf, DMS, MBIM, MRTPI Strategic Land Co-ordinator Crest Homes (Southern) Ltd Objection Ros.3, 8 an4 323 (Kent Trust for Nature Conservation) Mr P Buckley BSc, Mac Conservation Officer Kent Trust for Nature Conservation lAS Bower Mount Road Maidatone Kent ME16 BAX Objection Ro.28& (Council for the Protection of Rural Bnglan4) (Kent Branch) Dr R Baxter, BSC (Agriculture), Coldharbour Farm MSC, Ph.D Wye Ashford Kent TN25 SDE 6 - Objection Koa.170 and 189 (J. Sainabury plc) Mr S Ashworth J Sainabury plc Stamford House Stamford Street London SE9 9LL Mr N M Hollanda Bae, Dip TP, MRTPI Town Planning Consultancy Ila e 7 ad/ProgrammeO/TYoung/Appearance I BOROUGH or DAR'WOBD LOCAL PI.Alf PUBLIC LOCAL IRQUIRY 1992 DOClDIBR'rS LIST - DARTPORD BOROUGH COtJRCIL (Beyi•ad •• at 28th July 1992\ DBCl Green Belt Topic Paper, DBC 1992 DBC2 Hou•inq Topic Paper, DBC 1992 DBC3 Transport Topic Paper, KCC/DBC 1992 DBC3(a) Topic Paper: Junction lA (A282) Traffic Issues, KCC/DBC 1992 DBC4 Kent Structure Plan, KCC 1990 DBCS Kent Structure Plan• Third Review Draft Consultation Document, KCC 1992 DBC6 Schedule of Changes to be Commended to the Inspector, DBC 1992 DBC6(a) Supplementary List of Changes to be Commended to the Inspector, DBC 1992 DBC6(b) Second Supplementary List of Changes to be Commended to the Inspector,DBC 1992 DBC7 Summary of Objections and Representations, DBC 1992 DBC7(a) Report to Planning and 'rransportation Committee 14 April 1992. DBC DBCB Listings of Objections Representations, Objectors and Supporters, DBC 1992 DBC9(a) 1991 Consultation Draft Local Plan Written Statement, DBC 1991 DBC9(b) 1991 Consultation Draft Local Plan Proposals Map, DBC 1991 DBClO Report on Public Consultation on 1991 Draft Local Plan, DBC 1991 ' i DBCll Schedule of Amendments to 1991 Consultation Draft Local I Plan, DBC 1991 DBCl2(a) 1988 Consultation Draft LOcal Plan, Written Statement, DBC 1988 DBC12(b) 1988 Consultation Draft Local Plan, Proposals Map, DBC 1988 DBC13 Report on Public Consultation on 1988 Draft Local Plan, DBC 1988 DBC14(a) North West Kent Town Map Written Statement, KCC 1978 DBC14(b) North West Kent Town Map, KCC 1978 DBClS Introduction to the Local Plan DBC16 Vehicle Parking Standards, KCC 1986 DBC17 Greenhithe Conservation Area, DBC 1976 DBC18 Greenhithe• Possibilities for the Future, DBC 1986 DBC19 Kent Countryside Local Plan, KCC 1983 DBC19(a) Note on Kent Countryside Local Plan, DBC 1992 DBC20 Planning for Golf in Kent, Kent Planning Officers Group 1991 BOROUGH 01!' DARTFORD LOCAL PLAIT PUBLIC LOCAL INQUIRY 1992 BQBOQGH CQQNCJ:L PRQQPS or BVJDBlfCB .MD BJT.t\'l'BD nnmnnnlT' Objection (Ho) Document Ro Document Orchard Way DBC38.1P Proof of Evidence1 (38) J.C. Underhill DBC 38.2 Appeal decision1DA/81/0195 DBC 38.3 Petition from local residents, 18th June 1992 Gun Club DBC 171. lP Proof of Evidence: (171) J.C. Underhill DBC 171.2 Plan showing objector's land holding and Green Belt in adjoining area of Bexley. DBC 171.3 Plans attached to application TH/1/70/200 DBC 171.4 Bexley Committee report and resolution on 1991 Consultation Draft Dartford Local Plan Edwin Road DBC 68.lP Proof of Evide~ce: (68) A.P. Penfold DBC 68.2P Proof of Evider c:e: J.C. Smith DBC 68.3 Plan showing boundary of Wilmington Parish Birchwood Road DBC 120.lP Proof of Evidence& (120 ate) P.J. Buckley Elmstone (139 ate) DBC 139.lP Proof of Evidence: East of Westwood J.C. Underhill Road (154 ate) Betsham Page Close, Bean DBC 313.lP Proof of Evidence: (313) A.M. Legg Objection (Ro) Do~t Ro Document Housings External DBC 179.lP Proof of Evidence1 Space Standards A.J. Hoare (179) School Lane, Bean DBC 194.lP Proof of Evidence: (194) A.M. Legg Ingress Park DBC 2.lP Proof of Evidence: (2,169,304,342) A.P. Penfold (witness not called) (304) DBC 2.2P Proof of Evidences E.A. Davis (witness not called) (169) DBC 2.3P Proof of Evidences J. Payne (169) DBC 2.4P Supplementary Proof of Evidences A.P. Penfold South Thames-side DBC 259.lP Proof of Evidences Development Route J. Payne (341) Parking (witness not called in Standards (259) relation to Parking Standards) Darenth Road Link DBC 249.lP Proof of Evidence: (249) J. Payne Park-and-Ride, DBC 225.lP Proof of Evidence: Parkway Station J.C.Smith (225) Longfield Hill DBC 199.lP Proof of Evidences (199-209) J. Arnold / DBC 199.2 Supplement to Proof of Evidences J. Arnold DBC 199.3 Plan showing Green Belt in adjoining parts of Gravesham and Sevenoaks Land at Lowfield St DBC 329.lP Proof of Evidences (329,336) J. Arnold Objection (Ho) Docum.nt Marina Site, DBC 287.lP Proof of Evidence: Greenhithe A.P. Penfold (287) DBC 287.2P Proof of Evidence: c. J. Perkin DBC 287.3 Letters from G.R. Thompson DBC 287.4 Plan from G.R. Thompson DBC 287.5 Department of the Environment consultation paper: Urban Regeneration Agency Land at North DBC 3.lP Proof of Evidence: Dartford: El A.P. Penfold Policy Area (3) DBC 3.2P Proof of Evidence: A. Hitchcott DBC 3.3 Draft Planning Policy Guidance: Nature Conservation Land at North DBC 8. lP Proof of Evidence: Dartford: E2 J,C. Underhill Policy Area ( 8) DBC 8.2P Proof of Evidence: M.P. Roberts DBC 8.3P Proof of Evidence: D. Thornton Mabledon Hospital DBC 323.lP Proof of Evidence: (323) J.C. Underhill DBC 323.2P Proof of Evidence: A. Hitchcott Golf Courses DBC 20.lP Proof of Evidence: (284) A. J, Hoare Retail Policies DBC 170.lP Proof of Evidence: (189) P. J. Buckley Objection (llo) Document 110 DoaWHnt Sites of Nature DBC l.lP Proof of Evidence: Conservation A.P. Penfold Interest (Witness not called) (306) DBC l.2P Proof of Evidence: A. Hitchcott (witness not called) ! DOCUMBRTS SUBHI!r!rBD BY OBJBCTORS Mr G Simpkin on behalf of 38:1P - Proof of Evidence R C Diocese of Southwark in respect of Policies Hl (Objection No.38) and GBl Land to the East Side of Orchard Way, Wilmington, 38:2P - Appendix to Proof, Mr N Shute of Llewelyn-Davies RlO:lP ) proof of Planning on behalf of South East Rl0:2P ) evidence Thames Regional Health Authority Rl0:3P ) (Objection/Representation Noa. Rl0:4P - Appendix 168, RS6, Rl22) Mr S Chadwick of Chapman Warren 171:1P - Proof of Evidence on behalf of DBT Holdings Limited 17lt2P - Appendix (Objection No.171) 171:3P - Summary of Objections Mr P James 68:1P - Proof of Evidence (Objection No.68) 68:2P - Petition I Majorhive Ltd Rl8:1P - Proof of Evidence ' (Representation No,18) ,I ' Mr G Lawrence 94:1P - Proof of Evidence (Objection No,94) Mr R Cobbett 81:1P - Proof of Evidence (Objection No.81) Mr R Cobbett 81:1P - Proof of E~idence (Objection No.81) Mr Lawson 120:2P - Paper on birds at Birchwood Road Site. Mr B C Cobb 80:1P - Proof of Evidence (Objection No,80) Mrs L Travella 120:1P - Proof of Evidence (Objection No.120) Mrs 0 Burley 88:1P - Proof of Evidence (Objection No.88) Mrs M N Salway 1391lP - Proof of Evidence (Objection Nos.139 and 154) i I f' 1 lI I r/, I' 11 ,I L Also submitted by persona she was representing (as written reps) Southfleet Pariah Council 140:1P - Proof of Evidence (Objection Noa.140 and 155) Mr and Mrs Barden Written Representation (Objection No.129 and 145) 129:1P Mr and Mrs Boddy Written Representation (Objection Noa.130 and 146) 130:1P Mr and Mrs Hoadley Written Representation (Objection No.134 and 150) 134:1P Mr B E A Tolmie Written Representation (Objection Noa.141 and 156) 141:1P Mr J B Pike on behalf of Proof of Evidence Mr F G Meakin 313:1P (Objection No.313) Mr J B Pike on behalf of 179:1P - Proof of Evidence Crest Homes (Southern) Ltd, Report on Public Ward Homes, Persimmon Homes, Consultation on 1991 Da Vinci Properties and Consultation Draft Berkely Homes LocalPlan. (Objection No.179) 179:2P - Appeal Letter (Ref T/APP/T2215/A/91/ 194430/P8 (application no. DA/91/0404) dated 19 March 1992. 17913P - Brochure on Plots 1-6 Wilmot Road, Dartford. 179:4P - GA Land and New Homes plans in respect of Greenhithe Quay (Plot 4). 179:5P - Brochure on Fiddlers Quay, Greenhithe. 179:6P Brochure of Tufnail Road, Dartford. 179:7P - Brochure on Plots 14-39 Priory Place, Anne of Clevea Road, Dartford. 17918P - Brochure of Plots 80-82 Worcester Park, Greenhithe. 179:9P GA Development at Fawkham Road 179:10P - Willow Fields Development 2 Maples Teesdale on behalf 2:1P - Proof of Evidence of Marine Society by Mr Owen Luder CBE (Objection Nos.2, 304, 342) PPRIBA, FRSA Mr J W E Rixson 1941lP - Proof of Evidence (Objection No.154) 194.2P - Letter from DBC dated 18.12.85 194.3P - Plan of Bean Villaqe 194.4P - Letter re response to Consultation Draft 194.5P - Development at Greenwood 194,6P - Letter from local residents re. bus turninq bay Maples Teesdale on behalf of 2:2P - Proof of Evidence Marine Society by Mr G B Parker MA (Objection No.169, 259 and 341) (Cantab), MSE (CE), Dip TP, Dip TE, C Enq, MICE, MRTPI, MCIT, MIHT 2:3P - Supplementary Proof of Evidence by Mr GB Parker MA (Contab), MSE (CE), Dip TP, Dip TE, C Enq, MICE, MRTPI, MCIT, MIHT Mr S Webb 249:1P - Proof of Evidence (Objection No.249) 249:2P - DoT's Consultation Document on A282 Road _A49:3P - Letters from residents of Darenth Road Mrs K Chidley on behalf of 225:1P - Proof of Evidence Stone Parish Council (Objection No,225) 3 Mr M C Copsey on behalf of the 1991lP - Proof of Evidence following objectors1 Mr JM Adams (Objection No.199), 199:2P - Plan showing Mr JC Evans (Objection No.250), Mr Adams ownership of the Mr and Mrs Fitness (Objection No.201), objection site. Mr C Gray (Objection No.202), Mr F Miles (Objection No.203), Mr C Millner (Objection No.204), Mr IP Paton (Objection No.205), Mr J Payne (Objection No.206), Mr AG Tom (Objection No.208), Mr HAG Wood (Objection No.209). Objection Nos.329 and 336 (VAS (Kent) Ltd)) Mr D J White 329:1P - Proof of Evidence (Objection No.329) Mr I D Bull, Crest Homes (Southern) Ltd 287:1P - Proof of Evidence (Objection No.285) 28712P - Appendix to proof 287:3P - sheet identifying 4 viable schemes for the Marina as presented to the Appeal Inquiry. 287:4P - Joint proof of evidence by Mr Gilbert and Mr Perkin as presented to the Appeal Inquiry. 287:5P - (A) Letter (B) Letter (C) Letter 287:6P - Plan drawn by Mr Bull showing possible layout for the Marina. Mr P J Buckley 3:1P - Proof of Evidence Kent Trust for Nature in respect of Objection Conservation No.3 (Objection Nos.3,8,323) 3:2P - Proof of Evidence in respect of Objection No.8 \ 3:4P - Proof of Evidence in respect of Objection No.323 Dr R Baxter 20:1P - Proof of Evidence Council for Protection of 20:2P Rural England (Kent Branch) (Objection No.284) 4 Mr N M Hollands 1701lP - Proof of Evidence Town Planning Consultancy on 170:2P - Appendix to Proof behalf of J Sainsbury plc (Objection Noa 170 and 189) Blue Circle Properties Ltd 11lP - Proof of Evidence (Objection No. 306) by Dr c Downs 112P - Draft PPG on Nature Conservation 5 sd/ProgrammeO/TYoung/Objectors BOROUGH or DARTFORD LOCAL PLll.ll IRQUIRY ATTll:llDARCB LIST !!!!!!! Repreaentinq 23rd June 1992 Mr R Griffiths Counsel Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr J Arnold Dartford Borough Council Mr P Buckley Dartford Borough Council Mr J C Smith Dartford Borough Council Mr J Payne Kent County Council Mr P Gilbert Kent County Council Mr N Shute Llewelyn-Davies Planning representing South East Thames Regional Health Authority Mr K Hookey South East Thames Regional Health Authority Mr D Woods Solicitor Mra K Chidley Clerk to Stone Parish Council Dr R Baxter Council for Protection of Rural England (Kent Branch) Mr J W E Rixaon Objection (No.194) Sally Turner Residents of Langworth Close, Orchard Way, Gorden Place and High Road, Wilmington Lorraine Moaa " . Mr K Boys Blue Circle Properties Mr C G Downs f Blue Circle Properties Mr D Rixson Vincent and Gorbing (on behalf of Blue Circle Properties). 2Sth June 1992 Mr G Warren Chapman Warren Mr S W Chadwick Chapman Warren, representing DBT Holdings L Dougal DBT Holdings Mr R Griff itha Counsel, Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr Buckley Dartford Borough Council Mr R Lewis Vincent and Gorbing (on behalf of Blue Circle Properties). Mr J W E Rixson Objection (No.194) 1 30th June 1992 Mrs B D Lawrence Mr G J Lawrence Objection (No.94) Mr P James Objection (No.68) Ms S James Mr R F Cobbett Objection (No.81) Mr P Travella Objection } (No.120) Mrs L Travella Objection } Mrs K Chidley Clerk to Stone Parish Council Mr B Cobb Objection (No.BO) Mr E F Riddles Objection (No.107) Mr J Burley Objection (No.88) Mr J W E Rixson Objection (No.194) Mr E Huxley Objection (Nos.211, RllB, 37) Mrs M N Salway Chairman Southfleet Parish Council and representing other Objectors. Mr R Griffiths Counsel, Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J c Underhill Dartford Borough Council Mr J Arnold Dartford Borough Council Mr P Buckley Dartford Borough Council Mr JC Smith Dartford Borough Council Mr D Jarman BSF Planning Consultants (on behalf of Majorhive Ltd) Mr S Slater BSF Planning Consultants (on behalf of Majorhive Ltd) lst July 1992 Mr R Griffiths of Counsel Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr A J Hoare Dartford Borough Council Mr A M Legg Dartford Borough Council Mr J B Pike General Accident Property Services (on behalf of Mr Meakin (Objection No,313)7 and Crest Homes, Ward Homes, Persimmon Homes and Da Vinci Properties (Obj No.179) Mr P M Newnes General Accident Property Services as above Mr I Bull Crest Homes (Southern) Ltd Mr R D Lewis Vincent and Gorbing (on behalf of Blue Circle) Mr J W E Rixson Objection (No.194) 2nd July 1992 Mr R Griffiths of Counsel Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr E A Davis Dartford Borough Council 2 Mr T J Payne Kent County Council, assisting DBC Mr J P Gilbert Kent County Council, assisting DBC Mr M Borton Q C Marine Society Mr R Frampton Marine Society Mr P W Matcham Maples Teesdale Solicitors on behalf of the Marine Society Mr O Luder On Behalf of the Marine Society 3rd July 1992 Mr R Griffiths of Counsel Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J c Underhill Dartford Borough Council Mr A M Legg Dartford Borough Council Mr B A Davis Dartford Borough Council Mr J W B Rixson Objection (No.194) Mr R Lewis Vincent and Gorbing (on behalf of Blue Circle Properties Ltd) 7th July 1992 Mr R Griffiths of Counsel Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J c Underhill Dartford Borough Council Mr P J Buckley Dartford Borough Council Mr T J Payne Kent County Council, assisting DBC Mr P Gilbert Kent County Council, assisting DBC Mr J M Turner Kent County Council, assisting DBC Mr A L Norton Department of Transport Mr R M Frampton Marine Society Mr M Horton Q C Marine Society Mr P Matcham Maples Teesdale Solicitors on behalf of the Marine Society Mr O Luder On behalf of the Marine Society Mr G B Parker On behalf of the Marine Society Mr R Lewis Vincent and Gorbing on behalf of Blue Circle Properties Ltd 8 July 1992 Mr R Griffiths of Counsel Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr P J Buckley Dartford Borough Council Mr T J Payne Kent County Council, assisting DBC Mr P Gilbert Kent County Council, assisting DBC Mr S Webb Objection (No.249) Mrs M B Webb Mr M F Byhurst Objection (No.235) Mr A Winchester A Winchester & Sons Ltd. Objection (Noa. Rl3, R62, R77) Mr J W B Rixson Objection (No.194) Mr K Winchester A Winchester & Sons Ltd Mr A Winchester A Winchester & Sona Ltd 3 ,...... 9 July 1992 Mr R Griffiths, Counsel Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr J C Smith Dartford Borough Council Mr J Arnold Dartford Borough Council Mr P Buckley Dartford Borough Council Mrs K Chidley Clerk to Stone Parish Council Mr J M Adams Objection (No.199) Mr M C Copsey Mundays Ltd on behalf of objectors of Longfield Bill (Nos.199-206, 208 to 209) Mr C D Sharp Objection (No.207) Mr R D Dewar Representing VAS (Kent) Ltd Mr D J White VAS (Kent) Ltd Mrs M Dewar Mr J W E Rixson Objection (No.194) 10 July 1992 Mr R Griffiths, Counsel Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr J Arnold Dartford borough Council Mr J W E Rixson Objection (No.194) 21 July 1992 Mr R Griffiths Counsel, Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr C Perkin Colin Perkin Associates on behalf of Dartford Borough Council Mr Rhodri Price-Lewis Counsel, Crest Homes (Southern) Ltd Mr I D Bull Crest Homes (Southern) Ltd Mr 0 Luder OWen Luder Practice on behalf of Marine Society Mr J W E Rixson Objection (No.194). 22 July 1992 Mr R Griffiths of Counsel, Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr I D Bull Crest Homes (Southern) Ltd Mr R Price-Lewis of Counsel, Crest Homes (Southern) Ltd Mr 0 Luder on behalf of Marine Society Mr J Rixson Objection (No.194) 4 - ---·--- 23 July 1992 Mr R Griffiths of Counsel, Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr P Buckley Dartford Borough Council Mr E A Davia Dartford Borough Council Ma D Thornton Environment Advisory Unit Ltd (on behalf of the Wellcome Foundation Ltd, assisting Dartford Borough Council) Mr P Roberta Fuller Pieaer (representing Wellcome Foundation Ltd) Ma E Francia Fuller Pieaer (representing Wellcome Foundation Ltd) Mr A Hitchcott Kelsey Associates, assisting Dartford Borough Council Mr A E Bridgman The Wellcome Foundation Ltd Dr C G Down Blue Circle Industries plc Mr A Stevens Hepper Robinson (representing South East Thames Regional Health Authority Ma D Rider South East Thames Regional Health Authority Mr J W E Rixaon Objection (No.194) 24 July 1992 Mr R Griffiths of Counsel, Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr J Arnold Dartford Borough Council 28 July 1992 Mr R Griffitha of Counsel, Dartford Borough Council Mr A P Penfold DaLtford Borough Council Mr J C Underhill Dartford Borough Council Mr A J Hoare Dartford Borough Council Mr P J Buckley Dartford Borough Council Dr R Baxter Council for the Protection of Rural England (Kent Branch) Mr I P Biddington Vincent and Garbing (on behalf of Blue Circle Properties Ltd) Mr N M Hollands Town Planning Consultancy (on behalf of J Sainsbury plc) Mr A Ashworth J Sainsbury plc Mr J W B Rixaon Objection No.194 s ' II 29 July 1992 Mr G Griffitha of Counael, Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr J Arnold Dartford Borough Council Mr P Buckley Dartford Borough Council Mr J W E Rixaon Objection No.194 30 July 1992 Mr R Griffiths of Counsal, Dartford Borough Council Mr J C Underhill Dartford Borough Council Mr J Arnold Dartford Borough Council Mr P Buckley Dartford Borough Council Mr J W E Rixson Objection No.194 31 July 1992 Mr R Griffiths of Counael, Dartford Borough Council Mr A P Penfold Dartford borough Council Mr J C Underhill Dartford Borough Council Mr J Arnold Dartford Borough Council Mr P J Buckley Dartford Borough Council Mr J Smith Dartford Borough Council Mr A Hitchcott Kelsey Asaociatea, aaaisting Dartford Borough Council Mr P Buckley Kent Truat for Nature Conservation aaaiating Dartford Borough Council Mr R Fookes of Co1"1ael, Blue Circle Properties Ltd Mr I Trehearne Derwin Leighton on behalf of Blue Circle Properties Ltd Mr K Boys Blue Circle Propertiea Ltd Dr C G Dawna Blue Circle ~roperties Ltd Mr J W E Rixson Objection No.194 18 September 1992 Mr R Griffiths of Counael, Dartford Borough Council Mr A P Penfold Dartford Borough Council Mr J C underhill Dartford Borough Council Mr P J Buckley Dartford Borough Council Mr J Arnold Dartford Borough Council Mr J W E Rixaon Objection No.194 6