Planning application to develop land between Sutton Street and Cross Keys
April 2, 2014
Long trailed, this planning application (MA 13/1708) has now been submitted to Maidstone Borough Council. It comes from Country House Developments which choose to call the proposed development “Roundwell Park”.
The deadline for objections is 27 November.
The application will be considered by the Bearsted Parish Council Planning Committee on Thursday 28 November. Do keep an eye on the parish notice boards for the agenda. This will be a public meeting so take the opportunity to make your views known. The Planning Committee will be seeking an extension for submitting their comments.
What is proposed?
The application comprises 39 two storey properties: 9 “affordable homes for local need” and 30 “open market”. It is described by Country House as “a local vernacular development using high quality traditional materials”.
The principal access to the site will come from the Cross Keys estate, roughly opposite the second house on the estate. The access road leads to three other roads: Lilk View (plots 1-6) – nearest The Street, The Meadows (plots 7-11) in the middle of the site and Roundwell Lane (plots 16-39) at the southerly end of the site. A fourth road, Sutton Close, (off Sutton Street) gives access to a cul-de-sac of three houses (plots 12, 13 and 14).
A playing field is identified between the tributary of the Lilk Stream and Roundwell Lane. In addition there will be a green. On the remaining (roughly 50%) of the site will be what is described as a”2.3Ha Public Ecology Park” with new footpaths running through the site connecting with the existing public footpath network to the south where it adjoins the Bearsted Woodland Trust footpath. Other footpaths will connect with The Street and Sutton Street.
Viewed from The Street, only plot 1 will face onto the existing highway. Looking due south from The Street the proposed development will extend in a broad crescent shape backing onto the existing properties in Sutton Street.
The proposal will, according to the developers, occupy less than half the site to a density of 16 houses to the acre – significantly lower than the recommended level. They originally wanted to build 70, but this has been reduced to 39 following discussions with Maidstone Borough Council planning officers.
The application is accompanied by numerous plans and supporting documentation.
The site and planning policy
The site is often referred to locally as Lilk Meadow. This is not strictly correct. The real Lilk Meadow lies to the south of the A20 and east of Otham Lane.
As the developers acknowledge, “the site is designated as being outside the built environs of Bearsted and is therefore classified as open countryside”.
However the developers have responded to MBC’s call for sites for development in both 2009 and again in January 2013. Since submitting the site the developers have been “actively promoting the site through the MBC’s Strategic Planning Office, with MBC members and over the last two years. Promotion and Pre-Planning meetings have taken place with MBC Planning Officer, Steve Clarke.” The planning officer has given considerable guidance on the size, layout and nature of development being sought. Meetings have also taken place with MBC members.
The developers draw attention to the fact that MBC has no Local Plan and lay considerable emphasis on the National Planning Policy Framework which is capable of overriding outdated development plan policies.
They also draw attention to the NPPF supporting the principles of sustainable development, maintain that MBC has only a 1.8 to 2.3 years supply of housing instead of the 5 year supply of housing it requires and that since the proposed development has “no adverse impacts” the site should be released for development as provided for under the NPPF.
The Society’s view
The Society is opposed to the development for the reasons set out below. The developers quote from the NPPF that “Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives.”
We agree, but draw different conclusions to the developers.
For them the proposed development is “effectively an infill between two established residential locations”. In the Society’s view the land is a green space that forms an integral part of the village landscape and which helps to make Bearsted such a pleasant village in which to live. Rather than being seen as infill it should be regarded as a natural extension of the Bearsted Woodland Trust land which it adjoins at its southern boundary ~ land once earmarked for development but which is now an essential element of retaining the semi-rural feel of this part of the village.
No one would now consider developing the BWT land.The land at Roundwell should be considered in the same light.
The NPPF makes it clear that local communities should be able to identify for special protection green areas of particular importance to them. By designating land as Local Green Space local communities are able to rule out new development other than in very special circumstances.
The NPPF criteria for such designations include:
Where the green space in reasonably close to the community it serves.
Where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty and tranquillity.
Where the green area concerned is local in character and is not an extensive tract of land.
This land meets these criteria.
The development would also damage the setting of the hamlet of Sutton Street ~ Bearsted’s oldest street – with a history dating back over 600 years.
Local consultation and the Local Plan
Immediately following the quote used by the developers the NPPF makes it clear that planning should be a “collective enterprise” which should “include people and communities”.
Because of the dilatoriness of the MBC in preparing a Local Plan local people have yet to be fully consulted and to have their say on where development should take place. While the MBC can be rightly criticised for the time it has taken this is no reason why local people’s views should be ignored, overridden or pre-empted. It is important that this land (which, as the developers acknowledge, lies outside the development boundary of Bearsted) should not be sacrificed before the Local Plan is published and local people have had a chance to make their views known. Such discussions might well result in this land not being designated for development.
There are already proposals in the pipeline for major developments at Barming/Allington and Langley – to say nothing of Golding Homes proposals for land at Otham. If the first two of these were to go ahead it would add hugely to housing supply in Maidstone and obviate the need to develop patently unsuitable sites such as this..
Impact of development
The developers state that “The spatial arrangements of the site demonstrates the high quality style of development where all housing has large distance to boundaries, generous car parking areas, garaging to conceal motor vehicles and sizeable gardens to ensure a comfortable level of private amenity.”
No doubt much depends on how one interprets words, but as the plan shows garden spaces are often smaller than those of surrounding properties while the modern practice of using garages as storage space and parking cars on driveways means that cars are unlikely to be hidden from view.
The development’s impact on this land will be substantial and if allowed would alter a valued local green space beyond recognition.
Effect on infrastructure
Impact must also be considered of the impact of such development on local infrastructure. The developers state that “all required infrastructure is available in the locality”. This cannot but generate a hollow ring amongst existing residents who have just gone through traumas trying to get their children into local schools.
The access road to the proposed Sutton Close appears to be too narrow to allow access to emergency vehicles, placing properties at risk and there is no doubt that such development would have an impact on traffic flows. Furthermore, access to the rest of the site is dependent on a bridge over the Lilk Stream. If anything were to happen to that bridge this ‘island site’ would be cut off to all vehicular access.
Flood risk assessment
The land at Roundwell is an area of wetland (at one time referred to as “The Bogs”) prone to flooding and, in the Society’s opinion, unsuitable for development.
The developers have had a flood risk analysis report prepared on the land and the two water courses that cross it. (Three public sewers also cross the site.)
That report makes it clear that “The full catchment area draining to these watercourses has not been established as part of this assessment. It is understood that part of the M20 drains to these networks.”
The Environment Agency flood map shows that the proposed site lies within Flood Zone 3a “High Probability” – i.e. land assessed as having a 1 in 100 or greater annual probability of river flooding. The developers argue that these figures are generated from a “coarse modelling approach” and that caution must be exercised when interpreting them.
As the developers acknowledge “A Flood Risk Assessment must demonstrate that the development will be safe, without increasing flood risk elsewhere and, where possible, will reduce flood risk overall.”
However it is clear from the developer’s submissions that more work needs to be done to establish the level of risk: “A more detailed hydrological and hydraulic model analysis will need to be developed, sufficiently robust to support a detailed flood risk assessment for the proposed development.”
To plan against the threat of flood all finished floor levels will be set to a minimum of 300mm above the predicted 100 year flood level. Action will also be taken to design the bridge over the Lilk Stream in such a way that it does not impede water flow.
Despite this, the developers also say that: “Home owners will be encouraged to sign up to the Environment Agency’s Floodline Warnings Direct service to ensure all residents are aware of the procedures to be followed in the event of a flood evacuation.”
In addition to protect the development against extreme events the use of flood resilient materials in the ground floor construction will be used where reasonably practicable. The developers also say that road surfaces will be made of permeable materials that will limit the effect of run-off. But they do not say whether this form of construction will satisfy the highway authority who they will, no doubt, expect to adopt the roads if the development were to be allowed.
The Society has real concerns about potential flooding. Members will recall that only a few years ago a period of very heavy rain created a large pond at the bottom of Water Lane. Fed by waters descending Water Lane the water flowed across The Street and straight into the Lilk Stream causing flooding across much of the site.
The growing intensity of rainfall deriving from climate change can only increase the likelihood of such events in future years. The various references quoted above indicate concern on the part of the developers to the possible impact of flooding. We are not convinced by the figures given that seek to demonstrate that post development run-off will not be significantly higher than is the case now. We are also concerned that Southern Water has said there is insufficient capacity in the local network to accommodate sewage generated by the development. The proposed solution of storing then releasing sewage from the development during periods of residual capacity seems to us to put too much faith in systems and to pose a risk of unacceptable problems arising should there be a systemic failure in the capacity of the public sewerage network. And all this before the necessary studies have been carried out.
In our view there should be no question of even considering the application until the studies the developer says will have to be carried out have been conducted and the findings properly evaluated.