Planning Services

PLANNING APPLICATION FORUM

Held at the Town Hall, Tunbridge Wells On Wednesday, 19th December 2012

APPLICATION REF: TW/12/3078 SITE ADDRESS: AXA PPP Healthcare Limited, International House, Forest Road, Royal Tunbridge Wells PROPOSAL: Demolition of link-detached single storey building. Erection of a 3 storey linked extension to side (north) elevation of the main building to create additional office floor space and the erection of a single storey building to the rear to create decked car parking spaces, with the addition of car parking spaces and landscaping PRESENT: Jane Lynch (Development Manager, TWBC) – in the chair; Nancy Redgrove (Planning Officer, TWBC); Denise Haylett (Support Manager, TWBC); Priscilla Blanchard (Secretary, TWBC). Vic Hester; Laurence Gomersall (Douglas Moat Practice); Helen Ewart-Bainbridge (Property Services Manager, AXA); Michael Doyle and Graeme Gibson (Hawkenbury Village Association); Tim Harper (Camden Park Residents’ Association); Peter Waller (Independent Consultant on behalf of CPRA); Francis McGee (Camden Park, The Shaw and The Meads). Councillors McDermott, Backhouse, Mrs Mayhew, Mrs Soyke and Webb; Councillor Bulman arrived late. 41 members of the public were also present. APOLOGIES None were received. DECLARATIONS OF INTEREST None declared.

INTRODUCTION The Chairman opened the meeting and the attendees were introduced. The purpose and structure of the meeting were explained. PRESENTATION BY THE CASE OFFICER The Case Officer summarised key points from the following written presentation:

Site Description International House is located on Forest Road in Hawkenbury, on the edge of Tunbridge Wells. To the north and west is Camden Park, which is designated Conservation Area and Arcadian Area. To the south is Teise Close, which is a small residential estate. The site contains a three storey building set around a central courtyard. The building provides 4,900 square metres of office space. There is an existing single storey pavilion to the north west corner, linked to the main building, as well as several single storey outbuildings. Car parking is located to the front, south and west side of the building, providing 241 spaces. The building and car park are set within landscaped grounds. Proposal An application has been submitted by AXA PPP Healthcare to demolish the pavilion and erect an extension, connected to the north side of the main building by two glazed links. The extension would be essentially three storeys, with a flat roof, and a plant room on the western end of the flat roof. The rest of the flat roof would be covered with solar panels and a grass roof. The extension would create an additional 2403 square metres of gross office floor space connected to the main building with glass links. In order to increase parking provision on site, a raised deck is proposed over part of the car park creating 65 spaces, and this, along with some additional parking spaces being created in the existing car park, would result in 83 additional spaces being provided in total. Summary of Representations TWBC Sustainability Team - Do not have concerns about air quality. The developer should provide works to upgrade existing pedestrian and cycling routes and a Green Travel Plan. TWBC - Environment and Street Scene - Recommends conditions dealing with hours of working and screening during demolition and construction, wheel cleaning, noise and vibration of plant, submission of lighting details. Royal Tunbridge Wells Civic Society - Do not object to the form of the extension but in view of the existing demand for parking they are concerned that the proposed car parking is inadequate. Require more parking on or off site and/or a more effective Travel Plan.

TWBC Tree Officer - Some trees would be lost for the new extension and also for the car park area. New planting is proposed on the north boundary to screen the extension from Camden Park and in the south west corner to screen the development from Camden Park and Teise Close. The trees that would be lost are not particularly important, and they could be replaced in the areas described. However the planting size of the trees is too small. Further comments made in relation to the impact of the height of the car park deck on protected trees to the west outside of the site boundaries. Given the proximity of the structure to the trees it is likely that trees would have to be cut back to construct the car park deck and for future maintenance. This could be overcome through a reconfiguration of the car park deck. Planning Policy Team - Strongly support the proposal in principle to build additional office space in Tunbridge Wells, particularly for a large volume of new purpose built floorspace for an existing large employer within the Borough. AXA PPP is the second largest employer within the Borough and the largest private sector employer. The consideration of town centre sites as part of the sequential test has not referred to Vale Avenue and Calverley House, where there are high levels of vacant floorspace. 24 hour working in three shift patterns could cause disturbance for residents in the area, and the decked parking area may cause some landscape, design and parking concerns. Southern Water - Flood Risk Assessment and Drainage Strategy are satisfactory. Need confirmation that soakaways are adequate to dispose of surface water and suggest condition requiring details. TWBC Building Control – Soakaways are acceptable in principle but infiltration drainage via soakaways is not always possible. Soakaways should be designed in accordance with BS EN752-4 or BRE Digest 365 considering the area to be drained and the permeability of the ground conditions. Kent Highways – Existing site has a large car park but there is evidence of existing overspill parking in the vicinity. However, both the existing building and the proposed extension comply with maximum parking standards used by KCC. Due to the existing overspill parking problems the applicant has worked from first principles to assess likely future demand for parking. A survey of existing staff shows that 72% of staff currently drive to work and on that basis 144 extra vehicles could be generated. This has been factored by a figure of 65% to reflect typical attendance to give an estimated 94 vehicles which is anticipated to be further reduced through the introduction of travel plan measures. This approach is generally in keeping with Government guidance, but it is essential that these calculations are robust and supported by a robust Travel Plan to address parking demand and trip generation in a congested highway network. The Travel Plan should include improvements to bus services and to examine and address the implications of allocation of parking spaces within the existing and proposed car parks.

TWBC Senior Traffic and Parking Engineer – Has considered the application only in relation to parking management within Hawkenbury and neighbouring roads, and whether the proposal gives rise to the need for a time limited or resident priority parking restrictions. There is already significant pressure on on-street parking space and this has resulted in complaints and conflict, and based on current trends it is likely that the proposal would give rise to additional vehicles looking for on-street parking spaces. A legal agreement should therefore be secured if permission is granted, which would make funds available for the introduction of new or amended parking restrictions, possibly a residents’ parking zone, in Hawkenbury and neighbouring areas. The need for such restrictions would be solely at the discretion of TWBC, but based on survey work and consultation with local residents. TWBC Principal Design and Heritage Officer – Has some concerns from the design point of view. In particular he is concerned at the location of the ramp to the car park so close to residential properties, and we need more detail of the lighting. The design of the new extension is acceptable, but the details of the parapet and the handrail require further submissions. Landscape planting on the northern edge requires further ‘gapping up’, and more detail. Comments from Local Residents Town and Country Housing Group - Owns Nos. 19, 20, 21 and 22 Teise Close which immediately join the east boundary of the AXA site. They consider that provided there is adequate screening the single storey car park deck will not be visible from street level. Lighting on the upper level needs careful consideration. They are concerned about the position of the ramped access to the upper decks as it appears to be very close to their properties and could create noise nuisance. The ramp should be relocated well away from any residential property, i.e. closer to the centre of the site. Representations have been received from about 55 households, some of whom have written more than once, as well 3 separate petitions requesting the planning forum. The main issues raised by the representations are as follows: • Impact on residential amenity of neighbouring properties because of the proximity

and scale of the extension which will cause overshadowing and overlooking • Car park ramp is too close to neighbouring properties • Concern at 24 hour operation of the business which will cause more noise and

disturbance to residents • Light pollution from the office windows and the lights in the car park • Harm to the Conservation Area from the extension due to its scale and bulk, which

does not respect the spacing and relationship with properties on Camden Park • Increase in traffic on local roads • Increase in on street parking by employees cars on local roads

• Harm to vitality and viability of the town centre by having 750 staff on this site which

is too far from the town centre. If other town centre AXA sites close and relocate to International House this would be harmful to the town centre.

• Development is too large for Hawkenbury village, inappropriate to have a large

commercial development in a residential area • Main foul sewer from several properties in Camden Park (west of site) runs under the

parking deck, and it is not clear whether this has been taken into account. • Harm to trees and wildlife

• Some say they need to introduce parking permits for local roads, some say that AXA

should pay ongoing costs of permits to residents. Others say other options should be explored with regard to parking

Main Issues At this stage I consider that the main issues are: 1. The principle of the development, sequential test and the sustainability of the

location. 2. The impact on the character and appearance of the Conservation Area and the

Arcadian Area and views to and from it. 3. The adequacy of parking provision. 4. The impact on local highway network from traffic and parking. 5. The scope for other transport and parking measures and improvements 6. The impact on the residential amenity of neighbouring properties including from

the parking deck, ramp, lighting as well as from the building itself. 7. The impact on trees and scope for landscape planting 8. Any issues arising from 24 hour working at the property. PRESENTATION BY THE APPLICANT My name is Vic Hester and I am joined by Laurence Gomersall from Douglas Moat Practice and Helen Ewart-Bainbridge who is the Property Services Manager at AXA, based in Tunbridge Wells. I am making the opening presentation and the three of us hope to be able to respond to questions that are likely to come through this forum. Michael Mason who is AXA’s transportation consultant is not able to be here as he is on holiday. We hope to be able to provide clarification on transport matters but we may have to defer from replying if a question requires a more detailed and technical answer.

Background AXA PPP Healthcare Ltd is the largest private sector employer in the Borough, and a significant national and international employer throughout the world. Within Tunbridge Wells, AXA currently occupies 6 buildings at:

International House, Forest Road

Union House, The Pantiles

Eynsham House, Crescent Road

Phillips House, Crescent Road

Priplan House, Crescent Road

PPP House, Vale Road. International House was acquired in 2011 to help achieve a number of AXA’s objectives: first, to provide contingency against ageing and inappropriate property holdings; second, to enable accommodation to provide growth and flexibility to all aspects of the healthcare and Group operations; third, to maintain and support the core business and role of the Tunbridge Wells Head Office base; fourth, to develop the global brand of AXA. As part of AXA’s business plan and planned growth for the next 4-5 years, an extension to International House of some 2,000 sq m net office floor space has been identified. This would help achieve the objectives I have set out and more specifically would help create some 200 additional jobs within Tunbridge Wells. It would consolidate the ‘international’ function of the business in one key location, and it would enable 24 hour working to keep pace with the global marketplace. International House is one of the few Grade A office buildings within the Borough. It is freehold, it enhances AXA’s corporate branding, it achieves high energy efficiency as it is naturally ventilated and without air conditioning or other mechanical ventilation, it provides the flexibility of work space and helps establish the core business role of the Tunbridge Wells area. Process In November 2012, we submitted a planning application to be able to meet AXA’s need, accommodation and employment requirements. The submission of the application followed a 11 month process of considering and re-considering design and location options, involving the Borough Council, the County Council and local people. This included a public consultation event in August. Following this event, the proposed extension was reduced in size and height, and located a further 1 metre from the flank boundary (the pinch point being 11m). Significantly, as a direct result of a suggestion made at the consultation event, and at some considerable cost, a decked parking area to the rear is now proposed which will enable up to 83 additional parking spaces to be provided on site. As such, there have been 6 design options considered for the proposed extension and 3 design options considered for the proposed decked parking area included in the application. Planning History International House was built in 1998/99 and followed a Crown application by the Land Registry. Prior to this application, the former Land Registry site was substantially covered in buildings and extensive activities including a 7-storey building, outbuildings and an underground bunker which is still there. It was an intensive, commercial activity in the Hawkenbury area.

In 1999 the Land Registry occupied the office space. Teise Close was built on land left over from the redevelopment of the larger site. At the time, the ratio of the number of parking spaces to office floor space complied with parking standards. It is our understanding that the floor space was not fully occupied by the Land Registry. AXA bought and first occupied the second floor of the site in the summer of 2011. The building was occupied fully by February 2012, but this led to an immediate impact on the surrounding area from staff parking off-site. Instead of an incremental increase in parking on nearby streets, it went from nil to many in a short space of time. The planning permission for the office building granted under the Crown Approval does not limit the number of people on site, the hours of use, or imposes a travel plan to require a modal shift in car use to encourage staff not to drive their own cars to the site. Proposal The proposal provides additional gross internal office floor space of 1,896 sq m. The proposal provides an additional 200 jobs – new to the area – over the next 4-5 years. The International Customer Service opening hours are currently 8am to 8pm (Mondays to Fridays) and 9am to 5pm on Saturdays. Some 120 staff work in this section on a shift pattern basis. In wanting to be as open with the Council as possible, AXA included the possibility of 24-hour working at International House in the proposal. This is not their current intention but they do not want to rule this out as part of their global presence in the market. It would come about as part of a package of measures/approaches in a wider strategy and would have to be something they would put to existing staff. It is also something that is not necessarily predicated on the extension being built out and occupied by new staff. The 24 hour working may take place from one of AXA’s other sites. This is why the transport assessment made mention of 24 hour working but does not place heavy reliance on it. Should 24 hour working begin at the current offices; firstly, this would not be controllable under the current planning permission; secondly it would not involve significant numbers of staff – say, some 25 people. AXA is aware of the current wider impact from staff parking in nearby streets – along with cars related to local businesses and commuters parking and walking to the town centre. This is why AXA is prepared to make a number of commitments through this planning application which are controllable by a planning condition and/or Section 106 Agreement. These include:

A Travel Plan to create an ongoing modal shift away from the use of the private car

Funding the setting up of a Traffic Regulation Order and/or residents parking scheme, which following a proper consultation exercise, will enable local people to set out what restrictions would be applied to non-resident parking in local streets

Improved signage for cycle routes, cycle use, car sharing, priority parking, shower facilities etc.

Whereas there is no control at the moment, the proposals include the ability to control or restrict parking in the immediate area. There are no longer parking standards applicable. The AXA scheme provides a reasonable level of parking for the new development and provides additional parking spaces to seek to accommodate the current issues. NPPF advises that this approach is not necessary to deal with existing parking issues. However, a balance is needed and the scheme provides this balance as well as encouraging staff to shift away from driving their car to work by considering alternative solutions. Matters raised through this application I have tried to answer some key points that have come through the consultation of the application. In addition, and in brief, I set out a few other answers:

New lighting could be on a timer to go off at a certain time

The roof terrace will only be used for maintenance

The decked parking area could be closed before the evening. This would avoid evening use by cars with headlights on etc. Additional screening to the decking could be imposed.

After the initial comments from planning officers, AXA instructed landscape and tree consultants to advise on what part of the site would best accommodate the additional floor space, whether the conservation area and other landscape designations might be affected, and whether the location of the extension would enable further tree and landscaping to be provided. This exercise was carried out for both the extension and then for the decked area. The impact from the proposed extension and decked are would be contained within the site and would be further enhanced through additional planting.

Conclusion AXA is committed to growth. A significant amount of work has been undertaken by AXA’s team of consultants in order to arrive at a best solution while delivering the floor space requirements at International House. We note the number of comments that have been submitted in response to the application. We will provide a further written response to the main points set out in the letters received. PRESENTATION BY THE PETITIONERS Michael Doyle, Hawkenbury Residents’ Association First thank you for setting up this meeting to allow full and frank discussion of all the implications of AXA’s proposed extension. I am Michael Doyle and together with Graeme Gibson, I wish to outline the opinions of the membership of the Hawkenbury Village Association. We are both Committee members of the HVA and I was asked to petition for this Forum to enable their views to be considered at a non-confrontational meeting. The HVA’s membership area lies mainly to the east of Forest Road. It extends as far as Benhall Mill Road and the Cemetery and includes Maryland Road and Hawkenbury Farm. Much of this residential area is affected by AXA employees parking their cars in front of members’ properties which often means that they are not able to get in or out of their driveways – of which there are not many anyway, especially in those roads closest to International House.

AXA’s Operations Director has quoted in the Courier of 16th November as stating that the HVA was opposed to the Council introducing residents’ parking permits; I note that a provision of £10,000 is included in the draft Section 106 Agreement in the application to cover the Council’s costs for setting up and monitoring a parking scheme and meeting residents’ costs of parking close enough to their houses to permit passengers (often school children and elderly relatives) perhaps with household shopping – to unload with safety – as they did previously before AXA staff parking prevented it. Patrolled Residents’ Parking would not solve that problem – it would merely move it somewhere else. This problem is of AXA’s making and it is for AXA to resolve it. This is the present situation. It might be argued that this application should only be concerned with new matters, but this is not true. “Let’s do the math” as our American friends might say:- The present office capacity can take 540 staff – 72% of whom are said to be one car drivers: there are only 241 parking spaces and not every employee is entitled to on-site parking – hence the increase of on-street parking in those roads closest to International House, to take up the shortfall of 300 odd places. If the proposed extension is approved as planned, some 200 additional staff (perhaps working shift patterns over 24 hours) could be accommodated with a new proposed parking spaces total of 324, a mere 83 extra spaces. The new notional shortfall now becomes 416, if the 65 spaces planned for the upper parking deck in the south west corner of the site close by Camden Park and Teise Close, are achieved. So much for the parking; as for the design and siting of the new building it must be remembered that its footprint puts at least an extra 25% or so on the side closest to Camden Park (including Birken Lodge Nursing Home) to the north of the site; this three-storey addition might well be considered to be overbearing to these houses in Camden Park. No doubt the Camden Park Ltd speakers will enlarge on the affect that the new buildings could have on their members. However – all is not gloom and doom. AXA is a good and valued neighbour to us in Hawkenbury in particular, and to Tunbridge Wells in general and their continuing prosperity is of concern to us all. The Transportation Summary sheet distributed at the on-site meeting in August (and included in the application documents) has some very welcome proposals in the Comprehensive Travel Plan section, though somewhat more aspirational than achievable. Also I think the Travel Assessment provided by OPEN PROJECT needs to be updated in terms of accuracy and assumptions. AXA’s Property Services Manager is at all times helpful and constructive. She finds herself frustrated at the limits to her ability to satisfy the differing needs of the Hawkenbury residents, AXA’s operational requirements, and the staff who work at International House. However requests for specific help and assistance made are handled courteously and promptly and when possible with a satisfactory resolution despite the challenges inherent in trying to “fit a quart into a pint pot”. I fear that the problems associated with the expanded parking requirements may prove to be our “third runway at Heathrow” – too much too far. Finally, suggestions have been made to me for AXA’s consideration: (1) AXA should dig deeper both structurally and financially to provide parking below the new wing of the north of the site or below the existing parking at the south.

(2) Much as we would all like to see the “daffodil lawn” preserved in the north-east corner of the site, both it and all the garden frontage to Forest Road may need to go to permit more surface parking especially if the upper-deck parking terrace is deemed unacceptable. (3) Further study of Pre-Application Feasibility Drawing SP 02 should be made. This

scheme has the benefit of moving the three-storey extension building away from the Camden Park area of the site, to the front (Forest Road side) of the existing building, freeing up space for more above-ground surface parking.

(4) Off-site parking in the town for use with your wonderful electric shuttle transport might

become available. I believe that the Borough Council could well welcome guaranteed regular contract income from Meadow Road car park which is rarely fully occupied by shoppers.

Graeme Gibson, Hawkenbury Residents’ Association My name is Graeme Gibson, I am a retired architect and committee member of the HVA. The Association have asked me to speak about the scheme proposals and put what we hope will be seen as some constructive suggestions to the meeting. As has been mentioned the primary concern of the Association is the effect on local residents of the off-site parking by AXA employees. This arises because of the inadequate on-site parking provision, a situation which will only be made worse by the new development, even though it may meet county standards. The way the designers have sought to provide sufficient parking to meet the required county standards involves the construction of a large open parking deck on the South Western corner of the site. It is our view that, as designed, this deck produces an intolerable environmental intrusion onto the lives of the residents to the South and West of the deck, both by noise and light pollution and by loss of privacy. This could possibly be ameliorated by fully enclosing the ramp and the South and West elevations of the deck, though this would need to be sensitively designed to avoid it becoming an unsightly mass of building to those living directly adjacent, and on balance we consider it would be better to provide an alternative solution. The other issue we consider should be addressed is the impact of a new three storey office block on the Camden Park conservation area if it is built on the site to the North of the existing building. Paragraph 9.4 of the Landscape and Visual Appraisal by the applicant claims that the new block will have a negligible effect on the conservation area but the existing building can be clearly seen from the conservation area and a similar new three storey building some twenty five metres closer to the boundary will be so much more overbearing and intrusive. In order to address both these issues we feel that further consideration should be given to the pre-application feasibility option shown on drawing SP02. This drawing shows the new block located adjacent to the Eastern elevation of the existing building in what we would suggest is a more appropriate urban setting. Re-siting the office to the Eastern Elevation would then open up the land to the North of the building for parking.

By excavating half a level over the area of the parking, a split level 2 storey parking deck could be provided which, after allowing for the loss of the parking adjacent to the east elevation at present, would give a net increase of 160 cars on site rather than the 83 currently proposed. Being only half a level above natural ground the upper parking deck would be relatively easy to screen from Camden Park both visually and acoustically. Paragraph 9.3 in the Landscape and Visual Appraisal suggests that some parkland trees could be lost with the new block adjacent to east elevation but overlaying the feasibility plan over the existing layout indicates that the building footprint is almost entirely within the existing parking area and in fact shows areas which are currently car park and which could be returned to landscape to provide additional reinforcing to the screen planting between the new office at the east elevation and Forest Road. Tim Harper, Camden Park Residents’ Association My name is Tim Harper Chairman of Camden Park Residents’ Association.

Firstly, we appreciate the opportunity to present an objective argument relating to a proposal

that would have a major, permanent and detrimental affect on Camden Park, which is, as we all know, an important conservation and Arcadian area.

Can we also say straightaway that we are glad, like most citizens of our town, that AXA/PP have made their home here; we are glad they took over the old Land Registry building. We are also glad they are continuing to invest in Royal Tunbridge Wells. They have clout, but with power comes responsibility, like being good neighbours and engaging with their local community.

Their consultation was a farce held at short notice in the middle of the summer holidays and we were given two choices of the same building, one with and one without a rooftop restaurant. In fact looking at all AXA’s drawings & plans we concluded that the conservation area didn’t exist, it doesn’t seriously figure in their analysis.

What about trying to produce a solution to their office needs by working with the community and not causing traffic & parking mayhem and more importantly putting a vast building and two storey car park up against their neighbour’s boundary.

These buildings defy planning requirements and common sense. We ask that AXA go back to their drawing board and come up with something much less dominating, a lot further away from the boundary, enjoys underground parking and has integrity with the adjacent conservation area.

I’d like to ask Peter Waller who is far more eloquent to present our case supported by what we believe are some powerful images. Thank you. Peter Waller, Independent Planning Consultant acting on behalf of Camden Park Residents’ Association

I am Peter Waller, an independent Planning Consultant with experience of planning policy and practice in Tunbridge Wells over many years, firstly as the Council’s Development Control Manager during most of the 1990s and latterly as a private Planning Consultant.

I represent the residents of Camden Park, a large private residential estate located immediately to the north and west of the application site. The estate is acknowledged in the Local Plan as being an exceptionally special and environmentally sensitive location by its designation as part of Tunbridge Wells Conservation Area, an Arcadian Area and as an Area of Landscape Importance. The estate also contains many listed buildings. Camden Park residents have very real concerns about the implications and consequences of this proposal. They wish to stress they are very supportive of AXA’s presence in the town and welcome the principle of consolidation of that presence provided it involves more carefully considered and conceived proposals than those currently before the Council.

Their concerns relate to three issues. (We share HVA’s concerns about car parking and traffic, but leave that aspect to them.)

1. The likely implications of the proposal for the future of the town centre.

2. The likely impact of the proposal upon the character and setting of the designated Conservation Area and the Arcadian Area.

3. The likely impact of the proposal upon the residential amenities.

I will address each in turn. 1. The likely implications of the proposal for the future of the town centre Tunbridge Wells is very special town because of its strategic location, its vibrant and successful economy, its history and its superb environment, based upon many attractive historic buildings, spaces, vistas, lush mature landscapes and attractive topography. Key to this is the town centre, which exhibits all of these characteristics and, as a result, has successfully attracted many successful businesses and important drivers of the national economy and cultural life to locate here.

The town centre provides a successful mixture of locations for many activities including retail, leisure, residential and business use. Together, this mixture creates an almost unique sense of place that is both very attractive, vibrant and economically successful. There is little wonder therefore that AXA have located their headquarters here because Tunbridge Wells and its town centre are very prestigious and impressive places to bring important and influential clients to do business and relax afterwards. AXA, as the largest private employer in the town with six office sites (five in the town centre) and 1800 employees, has the ability to have a significant impact on the town’s future not just in economic terms but in terms of the vitality, vibrancy and special environment of the town centre. Indeed it has a duty of care to the town and its residents.

In seeking through this application to expand its operations at International House the company has provided few clues as to its future plans for its property holdings in the town centre. These buildings house many hundreds of employees who play a significant and vital role in maintaining, through their presence as shoppers and consumers of food and other town centre services, the vitality and viability of this special town centre. Their removal, either in part or whole, out of the town centre would have a very serious impact on the town centre as we know it today. Further, the Council in its Policy Officers’ comments on the application have failed so far to ask for greater detail as to why, in operational terms, this extension is needed specifically at Forest Road and most importantly, what AXA’s future plans are for the four remaining office buildings once this large extension is built.

Do AXA propose to retain all or any of the four buildings?

Do they plan to seek to revamp or redevelop any or all of the four office sites?

Or do they wish to eventually contract back to International House alone?

If so do they plan to seek to further expand office space on the International House site with all its implications for the environment, parking and traffic?

The answers to these questions we feel would provide the Council with a clearer picture as to whether or not AXA’s application does truly meet planning policy in terms of being necessary at the Forest Road site, whether it protects the vitality and viability of the town centre and whether it would leave existing important employment sites redundant. One does not have to look far across the road from the Town Hall to the Cinema site to see the disastrous results of an earlier planning decision (by a Planning Inspector rather than the Council) to allow the removal of a vital town centre use to the peripheral location at Knights Park. 2. The likely impact of the proposal upon the character and setting of the designated Conservation Area and the Arcadian Area

While the application site is outside the Conservation Area, the applicant has a duty to ensure that the proposal does not materially harm the setting and character of the Conservation Area as required by paragraphs 128 and 129 of the National Planning Policy Framework and Policy EN5 of the Local Plan. Is it perhaps significant that the plans of the proposal show little of the context of the site in relation to land to the west and almost none to the north? Similarly, little assessment has been undertaken of the impact of such a large, prominent and uncompromising building upon the acknowledged special and sensitive character of the land west and north of the site. One wonders are they trying to pretend there is no impact? Also, it is interesting to note that the Council’s Design Expert has yet to comment on the proposal. Well, to assist the Council Officers, its Members and the applicants, we have, with the assistance of a professional Architect and a Surveyor, produced a three dimensional model of the proposal and assimilated it into numerous viewpoints around the edge of the Conservation Area. The model is accurate and was constructed using the applicant’s scale drawings and site survey together with additional topographical survey material obtained by a professional Land Surveyor, all related back to the Ordnance Datum and the applicant’s survey.

View 4. This is the view looking east along Camden Park from outside Moorlands, the last house on the south side of Camden Park before reaching the site. This shows that the top two floors of the building plus the roof housing would be very starkly noticeable from Camden Park despite the landscaping. The building will be only 19m from Camden Park.

View 2. This is the view looking south from the rear garden of Camster Cottage, which is a bungalow on the north side of Camden Park almost level with the rear corner of the proposed office building, which would be approximately 17m from the site boundary at this point.

View 3. This is the view looking south from the front door of Carnanton, which is a two storey house on the north side of Camden Park roughly level with the front corner of the proposed office building, which would be 11m from the site boundary at this point.

These two views show the massive scale, height and monolithic character of the proposal which dwarfs and dominates the small domestic scale of the close by dwellings in this part of the Conservation Area. The building would bear more of a passing resemblance to an ocean liner tied upon alongside Camden Park in terms of its character, scale and appearance. In short, such a building would emphatically fail the requirement to respect the character and setting of the Conservation Area because it would not respect the scale of existing development in the Conservation Area and the spacious character whereby buildings do not dominate their setting and should be refused in terms of Local Plan policy EN5 and Core Policy CP9. 3. The likely impact upon adjacent residential amenities

When the proposal for the replacement of Curtis House with what is now International House was considered in 1998, careful note was made of the need to provide an appropriate setting for such a large building in relation to its location amidst a residential area of varying character and design. As a result, the scheme approved and built was seen as a success and respected the residential amenities of surrounding occupiers.

The current proposal appears to have been designed without any regard for the reasonable amenities of neighbouring residential occupiers as witnessed by views 2 and 3. Similar looming views of the building and the glazed walkways would be seen from the rear garden of Moorlands. (View 1).

However, of perhaps greatest concern in terms of unneighbourly impact is the relationship between the car park deck and The Firs, a bungalow sited immediately to the west of the deck and only 10 to 12m from the site boundary. (View 5) The car park deck is elevated 4m above the garden of The Firs and would have a parapet of only 1.1m high, low enough for an average height person (as illustrated in view 5) to have a grandstand view into the garden and some windows of The Firs so destroying the privacy and amenity currently enjoyed by the occupants. Further, the car ramp to the deck would be sited within 1m of the boundary with The Firs and would have a parapet only 0.8m high, thus allowing the noise, exhaust fumes and lighting of vehicles driving up and down the incline to permeate and severely pollute the garden of The Firs and other properties to the south. While this ramp would not be readily descried from The Firs it would be nevertheless very evident in terms of noise and fumes. The proposal clearly is ill planned and should be refused if it is to continue to include this element of the scheme.

Conclusion - The Way Forward

Camden Park residents appreciate the value of having an organisation such as AXA established in the town. They wish to see that presence continue and grow for the good of the town and the company.

However, they consider that AXA as an important and responsible organisation should be more open about its long term plans and should work with the Council to produce a strategy that avoids seriously damaging the long term viability and vitality of the town centre and despoiling the character of an important Conservation Area as well as many people’s amenities. There is a need for AXA to maintain a continuing presence in the town centre by a process of revamping or redeveloping outmoded buildings and seeking a more proportionate expansion of the International House site that avoids all of the problems and issues described here. Perhaps the approach to development suggested by the Hawkenbury Residents, Option2 on the east side of the building could be a basis for such a rethink?

We thank the Council and AXA and their representatives for providing this opportunity to set out our concerns about what we would prefer to describe as a “work in progress scheme” rather than the finished article. Thank you.

Tim Harper concluded that he was sure Councillors could see why we have strenuously opposed this application. We want to look forward and ask AXA to talk to us and our colleagues in Hawkenbury. Among other things we would like to discuss their suggestion for a building on the east side of the site & ways of avoiding a multi storey car park. We sincerely hope they respond to that invitation. Francis McGee, speaking for the residents of 72-110 Camden Park, The Shaw, and The Meads I speak for the residents of 72-110 Camden Park, The Shaw, and The Meads which is approximately 45-50 addresses and roughly 120 individuals in all. Occupants are chiefly families with children, and more elderly householders. Since the meeting was called I have been contacted by residents in neighbouring roads who faced similar concerns. The cul-de-sac area exemplifies residential “village” nature of local area. Basic concern and impact of proposals Our unifying characteristic is that the only vehicle access to our properties is the stretch of Camden Park between Nos 110 and 102. This access has been seriously compromised by on-road parking since AXA took occupancy of the International House site. On most days parking extends into The Shaw and as far as 100 Camden Park. This parking has stretched our streets’ capacity – and residents’ ability to conduct normal life – up to and beyond the limits of tolerance. Our streets are not adequately covered in AXA’s Transport Assessment and Travel Plan. There is one general reference to “inconvenience” to the residents of Camden Park, and one specific reference to the footway from our streets to town centre via Camden Park and Grove Hill Road is incorrect in claiming it is well lit and in good order. The group of streets will be adversely affected by additional parking by AXA staff. By not properly considering our situation, we believe AXA have not fulfilled para 4.6 of Environment Chapter of TWBC’s Local Plan. We also believe the proposals would cause significant damage to amenities in our streets, and therefore do not satisfy criteria 1 and 2 of Local Plan policy EN1. We believe the application is detrimental to highway safety in our roads, and our access on to the highway network, and therefore does not meet aim 4 of Ch 11 of the Local Plan, on transport and parking. The parking provision built into the proposals does not reflect the local transport infrastructure, and therefore breaches aim 5 of Ch 11. Lack of suitable bus service, cycling facilities and footways is evident in the 72% of AXA staff who choose to drive. We believe that because there are inadequate local transport links, traffic conditions in our streets are unacceptable, and would become more so, in contravention of aim 5 of the Local Plan’s economic development policies. We consider these last 2 points trigger Local Plan Policy TP2, which calls for remedial measures, including park and ride and public transport options. These have not been explored with the rigour or public involvement required to underpin a decision on the proposals. We believe the development impedes the free and safe flow of traffic on our little network of roads and therefore breaches criterion 5 of Local Plan policy TP4. I should point out that some members of our community – especially in The Meads – are also directly affected by the proposed building scheme itself – specifically the car park access ramp, which comes within feet of their properties. Objections filed online include arguments on town centre development as alternative to expansion of site, and concerns that the NPPF and TWBC policy CR2 is not satisfied by the proposal.

More Detail on Impact Before AXA moved to International House, it was not uncommon for 1-2 vehicles to park along Camden Park during the working week. We assume that people park and walk to TW station. AXA have in one document claimed more prior parking, but they provide no evidence, and any resident will tell you they are wrong. Now there are typically 10-17 cars on the same stretch of Camden Park, plus 3 in The Shaw. Impact 1 – access Parking has rendered Camden Park a single carriageway. Delivery vans/commercial vehicles are parking on pavements because driveways are inaccessible. This causes further obstruction. It is difficult or impossible for larger vehicles successfully to make the turn into The Shaw and neighbours along Camden Park cannot get into and out of their driveways. One elderly couple has required ambulance attendance on several separate occasions in the last 3-4 months, in and out of office hours. Access has been problematic and they struggled to get out. In early November, one neighbour suffered damage to the front brickwork of her house, caused by a van or lorry with equipment on the roof using her drive to turn or let another vehicle pass. Impact 2 – Road safety The relevant section of Camden Park is a blind summit. You cannot see traffic coming the other way. As a single carriageway, with 2-way traffic on one side of the road, there is a clear and present risk of collision. Parking means more traffic, more reversing and turning manoeuvres, more speed and more evasive action. It also means more noise/nuisance. This matters because Camden Park and The Shaw are primary pedestrian routes to Claremont School and parking restricts visibility at key crossing points. The junction of Camden Park and Forest Road is often obstructed by vehicles parked too close to the corner, in contravention of the Highway Code. Turning vehicles are at increased risk and outgoing vehicles have to turn on to Forest Road from the wrong side of the road. Impact 3 – Public Services (consuming amenities is taken for granted) The mouth of Camden Park at Forest Road is in urgent need of repair. Repair is impossible with parking as it is. On 6 November KCC carried out routine repairs to the road surface in The Shaw. Thoughtless on-street parking partially blocked the road for several hours, and would have closed it completely had one neighbour not persuaded a third car to park elsewhere. We have had 3 or 4 episodes of Water Company excavation outside 100 Camden Park this Autumn. Each event blocked half the road. If this had happened in the parked areas, the road would have been blocked completely, and/or repair access impossible. Conclusions and considerations for the development The present levels of on-street parking in our neighbourhood are a direct result of AXA’s current occupancy at International House. Our streets only absorb the current level of parking because much of it is inconsiderate or illegal. The proposals would increase demand for parking - therefore AXA and TWBC need to consider that The Shaw, Camden Park and the Meads are as much directly affected by these plans as more adjacent roads like Teise Close and the Camden Park private road.

AXA could take a long lease on parking in the town centre and should provide more information on actual effectiveness of staff incentives not to drive to work. There is a wide dispersal of home post codes for AXA staff. Clarification relating to 24-hour shift work would be appreciated; it should be the subject of a separate assessment. A decision should also be made on whether parking regulation of streets should be ruled in or out but this would not address the route cause of the problem as the impact of parking spreads further than realised and any restrictions would simply displace the problem elsewhere. It would also have major implications for the safety of children. AXA should meet the full and ongoing costs of any additional parking restrictions. Finally, I would like to raise a procedural point about whether such a large-scale application should be reviewed in the light of implications of any changes made to the Tunbridge Wells Plan documents and changes to policies and procedures following implementation of the NFPP. QUESTIONS AND ANSWERS Q Cllr Webb asked whether changes under the Localism Act and the pending framework

should in fact delay any Committee decision. A Jane Lynch confirmed that the Council had an adopted Core Strategy and an adopted

local plan with saved policies and all applications should be considered against that existing framework. As time moves forward, if potential changes emerged planning considerations might need to be amended but there were currently no grounds to delay making planning decisions. Reference to the NPPF would be made in the Case Officer’s presentation to Planning Committee.

Q Cllr Mrs Mayhew referred to the new hospital at Pembury; she believed that a travel

plan had been agreed at the time of granting planning permission but subsequently they had sought to have it rescinded.

A Jane Lynch explained that a Travel Plan was agreed with Pembury hospital, that it still stands and had not been lifted. If a request was received it would be considered seriously. In response to a further question from Cllr Mrs Mayhew, Jane Lynch confirmed that bus services were outside the Travel Plan. A commitment had been made for a 5-year period but further work had proved that some bus services were not viable and the money available was being put into services which had the best chance of becoming viable and running longer term.

Q Cllr Mrs Mayhew asked if there was any agreement with AXA to provide a contribution

towards residents’ parking costs. A Jane Lynch stated that if traffic regulation requirements formed part of any planning

permission, the developer would need to fund the cost of the making of the Order but would not be responsible to pay any resultant charges that residents may incur. If an agreement to make an Order were to form part of any permission and the applicant later sought to alter this, the Council would need to see substantive evidence.

Q Cllr McDermott queried Mr McGee’s reference to point 4.6 of the Local Plan. A Francis McGee confirmed that he was referring to the fact that “applicants should

provide a written statement setting out the design principles adopted including reference to the wider context of the site beyond the immediately adjacent buildings and spaces”.

Q Cllr McDermott sought clarification about the Case Officer’s references to letters

received concerning the application. A Nancy Redgrove confirmed that no correspondence had been received in favour of the

application and representations from 55 households, some more than once, had raised concerns and objections.

Q Cllr Mrs Soyke queried references in the application to parking below ground level. A Laurence Gomersall explained that during the design process, the feasibility of all

types of parking methods had been considered. They believed there would be more impact from siting the building at the front of the site. Specifically in relation to underground parking, problems of access would potentially wipe out parking at the rear of the site and would only provide an additional 30 spaces. He also noted that the existence of the bunker raised issues by way of limiting underground options. Underground construction would have to go beyond the anticipated extension to gain adequate parking and the bunker limited the way forward into the suggested area. Any basement car parking would gain only 30 spaces with the loss of parking at the rear.

Q Cllr Mrs Soyke sought the designer’s view of the suggestion to have the extension at

the front of the existing building. A Laurence Gomersall explained that AXA had felt the visual impact on the site would be

far more from the way people looked at the area if the extension was at the front; the original plan had provided for the open park land and AXA sought to retain the very nice aspect which currently existed.

Q Cllr Mrs Soyke asked if the concrete from the bunker could be removed. A Laurence Gomersall stated that any demolition would involve months of considerable

noise and chaos for residents. Q Cllr Backhouse felt that the main issue was that only 83 new parking spaces would be

created in the current plans, but it seemed that existing off-site parking was the crux of the problem for local residents. He noted that everyone welcomed AXA as a large employer.

A Laurence Gomersall stated that during the consultation process and discussions with the Council’s planning officers, designers had considered parking issues carefully. The proposed deck parking had been suggested to address concerns. The designers had tried to keep the scale as small as possible. The ramp resulted in 30 parking spaces. The proposal provided the maximum design with the least impact.

Q Cllr Webb sought clarification of AXA’s employee numbers. A Helen Ewart-Bainbridge confirmed that AXA employed 1800 staff in Tunbridge Wells,

plus supporting and contract staff. 540 were currently employed at International House and the proposed extension would accommodate 200 additional staff.

Q Cllr Webb noted a reference by the Case Officer to a survey of AXA staff which showed

72% currently drove to work. Using 75% as an approximate figure, that meant 405 people drive to work at the moment and if 200 more staff were employed the proposed 83 additional spaces would be inadequate. He asked how AXA proposed to reduce the numbers of cars.

A Laurence Gomersall stated that the Travel Plan was based on established assessment criteria and percentage analysis. AXA actively supported arrangements to try to limit traffic across the sites. Car share plans were in place, and while these could not be enforced, AXA were doing as much as possible to encourage adherence.

Q Cllr Webb asked why only 83 spaces had been planned. A Laurence Gomersall explained that the design had been drawn up in consultation with

KCC Highways Department and TWBC Planning; more parking could be put on the site but the current plans adhered to normal planning constraints.

Q Cllr Webb asked whether a ‘park and ride’ scheme had been considered. A Laurence Gomersall stated that AXA had looked at all possibilities but such schemes

were difficult for AXA to implement so they were not advancing them at this stage. Q Cllr Mrs Mayhew noted that Officers at TWBC had considered the impact of the

streetscene but she asked for a view of the suggested expansion on the east side of the site which would result in less intrusion on residents. She wondered whether current planning policies were causing an impediment. Having a parking ramp and 2 storey car park 1.5m from a residential property would have a significant impact; was there any other instance of this in the town? She also wondered if a sequential test had been conducted, could office space in the town centre be reused for the advantage of AXA.

A Nancy Redgrove confirmed that building the extension on the east side of the site had been discussed with AXA but it had been felt this would have a worse affect on the streetscene. She commented that planning decisions were always a balance, weighing against impact on neighbouring residents. In relation to parking standards, she confirmed they were not being used as a constraint but noted that the current allowance was based on the maximum requirements laid down. AXA had based their parking provision on an assessment of their needs. The impact on residential amenity was an issue and Nancy Redgrove confirmed that the applicant had undertaken a sequential test and Planning had suggested other ideas, however AXA had their own specific needs as a business.

Q Cllr McDermott noted that the petitioners had suggested the consultation by AXA had

been “a farce” and asked if there had been any specific conversations with AXA. A Tim Harper stated that the Camden Park Residents’ Association had wanted to talk to

AXA but had not been able to do so; they were still keen for engagement. A Michael Doyle confirmed that current advice to residents was to email AXA about any

existing parking problems. He noted that a site meeting had been offered in August but the plans had not been developed. The front garden area was lovely but Forest Road was a busy route and the HVA felt having the extension at the front would have far less impact on surrounding narrow roads than what was currently proposed.

A Francis McGee stated that a number of neighbours had attended the presentation in August and that residents of The Meads had received the formal planning application notices as they were the nearest properties, but other properties which were not adjacent had been overlooked. He commented that the area he was speaking for did not have a formal residents’ association but they would welcome discussions at any time.

Q Cllr Mrs Soyke asked if the petitioners felt that the suggestion to have the extension on

the east side would help solve their problems. A Tim Harper commented that the extension on the east side did not have to look like the

suggested image; it needed much more consideration but the HVA felt there was a lot of land on the eastern part of the site. They accepted that they did not know AXA’s requirements.

A Peter Waller agreed with the comments made by the HVA and questioned whether the extension needed to be one large building; he suggested that 2 or 3 smaller units could avoid maximum disruption to AXA’s operations.

The Chairman asked that questioning be restricted to the current application. Q Cllr Webb suggested that the current design did not address concerns about the

building appearing like an ‘ocean liner’. A Laurence Gomersall responded that his team had spent months looking at the design

and they believed the current proposal had the least impact on the site as a whole.

A Helen Ewart-Bainbridge confirmed the properties which AXA owned freehold and that they would remain occupied.

Q Cllr Mrs Mayhew drew attention to the comment that Camden Park had standard street

lighting and she wondered if having a brightly-lit car park nearby would have an adverse impact on the vicinity.

A Tim Harper stated that the residents’ association had looked at Arcadian lighting; at present there was a low level of lighting but it was a safe area.

SUMMING UP BY THE APPLICANT None was made. SUMMING UP BY THE PETITIONERS Hawkenbury Residents’ Association Michael Doyle noted Mr Gomersall had stated that travel planning was not his area of expertise, but in view of the concerns raised by petitioners about parking, he felt it had been a major error not to have an expert present. Using percentages already quoted, at least 416 parking spaces were currently required on the site, before considering the addition 83 proposed by the current application. Mr Doyle confirmed that an on-site meeting had been held in April at which time AXA had suggested some extension to the building might be required within the next 3-5 years, but he noted the current proposal seemed more imminent. In April AXA had confirmed it was not their intention to include extra working hours and additional staff. He noted that no local consultation had taken place and that the current application appeared to be very different from what had been presented in August. With regard to suggestions of parking permits, Mr Doyle felt it was not the function of the local authority to implement such a scheme and he did not wish to pay £60 a year to park outside his own home, noting that most roads in the area did not have driveways or garages. He commented that every day someone with an AXA parking permit parked outside his house. Camden Park Residents Association Tim Harper felt that if AXA had engaged with local residents, the Forum would not have been needed. Many people supported the suggestion for the extension to be built on the east side of the site and he felt it would go a long way to alleviating the problems in the neighbourhood. He asked that AXA enter into a period of proper consultation. Residents of 72-110 Camden Park, The Shaw, and The Meads Francis McGee reflected that the current occupancy of International House caused parking problems, so an increase by 1500% would inevitably result in more demand for on-street parking. He felt there was a lack of connectivity with other local transport. His neighbours had grave concerns about access to highways and road safety, as well as having concerns about privacy and being over-looked. The traffic assessment and transport plan needed more work to assess the wider local impact and he suggested comparing it with other successful transport plans. Mr McGee referred back to the wider than typical workforce distribution with only one third of AXA staff living in the TN1-TN4 postcodes; he felt this would be a good starting point to develop any travel plans. He also reflected on AXA’s assertion that they did not have any “current plans” for 24-hour working, but in the competitive marketplace in which he had previously worked, Mr McGee was well aware that this was not necessarily the case.

CHAIRMAN’S COMMENTS Minutes of this Forum would be provided to the applicant and petitioners and published on the website. They would also be attached as an appendix to any future Committee report on the application. If the applicant wished to make any changes to the application in light of comments made at this Forum, this should be done within 14 days of receipt of the minutes. A further period of consultation could take place before the application be presented to a future Planning Committee. The Chairman thanked all the participants for their contributions and closed the meeting at 3.55pm.