REPORT SUMMARY REFERENCE NO -...

Planning Committee Report 7 March 2018

REPORT SUMMARY

REFERENCE NO - 17/01151/FULL

APPLICATION PROPOSAL

Demolition of existing buildings and erection of a 68 suite integrated community health centre

(C2 use class) and associated parking

ADDRESS Cornford Court Cornford Lane Royal Tunbridge Wells Kent TN2 4QX

RECOMMENDATION – Grant subject to conditions and the completion of a Legal Agreement

(see Section 11 for the full recommendation).

SUMMARY OF REASONS FOR RECOMMENDATION

The applicant has demonstrated a need for the development, and, where the plan is

silent or out of date, in accordance with Paragraph 14 of the NPPF, permission should

be granted, subject to all other material considerations being satisfied.

For the purposes of the NPPF, the development is, on balance, considered to be

sustainable development. The proposal would make use of the site of an existing

building on the site, would be in close proximity to the LBD and would provide for an

identified need, incorporating sustainable measures where possible and retaining and

enhancing landscaping to an acceptable degree.

Whilst the proposal is considered to be inappropriate development in the Metropolitan

Green Belt there are Very Special Circumstances that outweigh this harm.

The proposal would not harm the AONB as to warrant refusal of the application. On

balance, the scale and massing of the building is considered to be acceptable

The proposal would not be harmful to the amenities of the occupiers of the dwellings to

the north to a level that would warrant refusal.

It is considered that the proposal would be served by a suitable access, shared with the

existing care home on the site. Parking can be accommodated on the site in a

satisfactory manner and level of parking.

The proposed development would not result in significant harm to the level of amenity

enjoyed by nearby occupiers such that would warrant refusal.

Other issues raised have been assessed and there are not any which would warrant

refusal of the application or which cannot be satisfactorily controlled by condition.

INFORMATION ABOUT FINANCIAL BENEFITS OF PROPOSAL

The following are considered to be material to the application:

Contributions (to be secured through Section 106 legal agreement/unilateral

undertaking):

Pembury Road Corridor study – with a view to relieving congestion on the Pembury Road;


£32,188.

Net increase in numbers of jobs: 40 extra full time staff equivalent plus 20 part time shared

with existing facility.

Estimated average annual workplace salary spend in Borough through net increase in

numbers of jobs: £269, 300

The following are not considered to be material to the application:

Estimated annual council tax benefit for Borough: £337.18 pa

Estimated annual council tax benefit total:£3260 pa

Annual New Homes Bonus (for first 4 years):N/A

Estimated annual business rates benefits for Borough: There are not normally business

rates associated with care homes.

REASON FOR REFERRAL TO COMMITTEE

By virtue of the scale of development proposed, that exceeds the 2,000 sqm as set out in the

constitution.

Additionally, the application has been called in by Councillor Nuttall on the following grounds;

1) Impact on existing housing caused by the proximity and scale of such an imposing

property including loss of privacy and loss of light

2) Impact on green belt

3) Impact on infrastructure

4) Concerns that the impact on local doctors will mean they are not able to cope

5) Impact of proposal on highway safety at the junction of Cornford Lane and the High

Street

6) Accessibility for emergency vehicles, having regard to flooding issues on Cornford Lane.

WARD Pembury PARISH/TOWN COUNCIL

Pembury Parish Council

APPLICANT Graham Land

And Development

AGENT Carless & Adams

Partnership

DECISION DUE DATE

19/01/18

PUBLICITY EXPIRY DATE

30/06/17 & 02/10/17

OFFICER SITE VISIT DATE

21/06/17

RELEVANT PLANNING HISTORY (including appeals and relevant history on adjoining

sites): There are numerous applications for submission of details on the full application to

implement the current care home on the site (planning reference 05/00719). The relevant

history in relation to the existing buildings on the site is set out below.

App No Proposal Decision Date

Current single storey building on the site.

86/00513/REM Reserved matters – New building to provide

sheltered accommodation for the elderly

(Amended proposals) (land adjoining Cornford

House)

Granted 01.06.86

85/00592/REM Reserved Matters – New building to provide

sheltered accommodation for the elderly

pursuant to TW/84/0191

Granted 01.11.85


84/00191/OUT Outline new building to provide sheltered

accommodation for the elderly.

(condition placed on the decision to be single

storey only and shall be designed to comply with

the requirements of the Chronically sick and

disabled persons Act 1970).

Granted 21.06.84

Main care home to south west side of the site.

05/00719 Demolition of existing care home and erection of

replacement care home. Granted 15.11.05

The application was granted as it was considered that the very special circumstances existed

outweighing any harm by reason of inappropriateness and any additional harm to the MGB by

reason of other factors being ;

significant need for care home places in the Borough;

lack of alternative sites;

application provides an opportunity to redevelop the existing care home facility;

opportunity for a phased development;

minimising disruption to residents; and;

the site has advantages in that it is accessible to existing services and infrastructure.

The scale, location and design of the development was considered to be acceptable, the traffic

movements generated by the development could be accommodated without detriment to highway

safety.

02/01690 Outline (Means of Access and siting not

reserved) 60 bed nursing care home Refused 25.02.04

Refused on the following grounds;

Inappropriate development in the Metropolitan Green Belt, that would introduce major

new development into the countryside, contrary to policy;

Proposal likely to give rise to an adverse impact on highway safety arising from potential

conflict between pedestrians and other road users.

MAIN REPORT 1.0 DESCRIPTION OF SITE 1.01 The application site is located immediately south of the Limits to Built Development

(LBD), of Pembury, within the Green Belt and within the High Weald Area of Outstanding Natural Beauty (AONB). The site is between the A21 and boundary with Pembury village.

1.02 Along the northern boundary of the site, there is a rough access track that backs onto

residential dwellings of Cornford Park located to the north that is gated and locked. However, there is also an unlocked pedestrian access, from the site through to Cornford Park. Mature oaks are located on this northern boundary, along with conifers and pine trees. There is a drop in levels across the site, with land levels dropping down towards the A21 to the south. Finished ground floor levels change across the wider site, from +124.000 above datum level at the lowest part of the


existing care home to + 127.260 at the neighbouring dwellings to the north. There is a two/three storey existing care home on the south western part of the site.

1.03 The existing care home is a modern building of red brick and red/brown tile hanging, which was constructed following consent in 2005 under ref. 05/00719. To the front of the building there is car parking for 22 cars, 3 disabled spaces and 1 bus. To the northern part of the site, where the site levels are relatively flat, there is a single storey building located in the position of the proposed care home. The building is currently in use as staff accommodation. The building measures 5.7m in height, and its footprint is not of uniform shape. It has a maximum width of 30m and maximum depth of 25.5m, with a footprint of 402 sq.m. The existing buildings (the main care home and a single storey building) are set within landscaped grounds.

1.04 The site is accessed from Cornford Lane, a narrow lane. A narrow footpath runs

along the north west side of the lane, and has reflective bollards set into the edge of the footpath. This path runs out at the Cornford Close entrance, just north of Cornford House/Cornford Court entrance. A short stretch of road needs to be negotiated to reach the High Street on foot.

1.05 To the north there are residential properties, of two storey in height, with gardens,

that abut the site and close boarded fences separating the dwellings from the track to the rear.

1.06 To the west, on the other side of Cornford Lane, is the rear of the Tesco site and

associated land. There is an extant consent for the construction of a new significantly larger foodstore to replace the existing foodstore, with associated car parking and landscape works and the construction of 320 Park and Ride spaces and associated bus facilities as a result of ref 09/01265, which has been deemed to be implemented by virtue of the installation of an access road.

2.0 PROPOSAL 2.01 The application seeks permission for the demolition of the existing single storey staff

accommodation building and the erection of a three storey Integrated Community Healthcare Centre (ICHC), comprising a 68 bed care home in Class C2 use, with integrated Community Day Care Centre of 58 sq.m. The new building would be located to the north east section of the site, where the land levels become more even. The development would be within 10m at the closest point to the northern boundary. To the south side of the proposed building, the height would be 11m, with a full three storeys, with a pitched roof. To the north, the building would appear as a two storey building, with dormer windows in the roof at the third storey. The care home would have a central core on the northern elevation, providing the shared facilities, including consultation rooms. The flat roofed, central core would be finished externally with a green living wall. Similarly, to the south side, a flat roofed element would project some 8.6m, with open terrace at second floor. This element would form the main entrance to the building. This projection would also be finished in a green living wall. The terraces are proposed at second floor level above the southern and northern projections, to enable patients to gain assess to an amenity space. These central cores would be two storey in height, with terraces above.

2.02 The day care centre would provide day care for a maximum of 20 people at one time.

The applicant has confirmed that this will be facilitated by a local support group such as the Alzheimers society or similar and a community mini bus would collect the majority of service users – but there may be the exception where service users are dropped by private transport. Data gained from the other homes run by the


applicant, indicates that the average amount of users is 10 per day. The day care would operate from the community room of the proposed care home.

2.03 The treatment centre aims to provide additional capacity to care for complex patients

without the need for A & E acute admission/re-admission. This would enable a new diagnostic assessment and treatment facility with modern care suites that are equipped to deliver a high level of care, to provide an enhanced extension of their own primary care, thereby providing dedicated medical, nursing and therapy support in one building. The suites would be provided within the eastern and western wings of the building generally – the community room would be located at ground floor level to the western part of the building, along with a large lounge/dining room in the centre of the building. A central core would accommodate consultant rooms/rehab rooms in the northern section of the building and in the southern section of the core of the building, there would be office/reception/drugs store on ground and first floors, and a large lounge/dining room and two terraces on the second floor, the deeper terrace being south facing. There would be care stations on the ground and second floors. A basement level would provide functioning elements, being the kitchen, laundry, staff rest room and plant room.

2.04 Access would be taken from the existing access along Cornford Lane, with no

alterations proposed. Parking provision would be as follows;

Location Existing Proposed Change

To the front of the existing care home

13 None No change

To the south east of the existing care home

14 None No change

To the west of the proposed care home

12 19 (+7) +7

To the south of the proposed care home

None 36 +36

Totals 39 43 new spaces 39 +43 totals = 82 Parking spaces

2.05 The proposal would be focused upon a short stay service aimed at rehabilitating the

elderly including those subject to hospital discharge, a “half way house”, in response to the need for higher quality accommodation but also to address “bed blocking”-delayed transfer of care for the elderly, although no formal mechanism has been submitted to secure such a relationship with the nearby Pembury Hospital. The proposal would provide communal living and lounge areas, offer a home from home environment and accommodation that would enable visitors to stay with their relatives.

2.06 Light wells are proposed to the south of the building to let in natural light to the

basement. The landscaping around the building as proposed, would provide a more structured approach to the landscaping.

3.0 SUMMARY INFORMATION

Existing

Proposed Change (+/-)

Site Area 22,014 sq.m 22.014 sq.m No change


Volume calculations

Single storey building to be

replaced

Three storey care home to the

south west of the site

1, 616m3

13, 132m3

14, 469m3

13, 132m3

+12, 853m3

unchanged

Land use(s) including floor area(s)


replaced

Three storey care home to the

south west of the site

382 sq.m

(single storey

building)

3776 sq.m

(existing care

home)

4977

(C2 Care

Facility)

As existing

4595 sq.m

As existing

No. bedspaces 6 (staff

accommodation)

68 (C2 care) +62

Number of jobs 60 existing full

time

20 Part time

100 full time

equivalents

(i.e. 40

additional)

20 part time

(shared with

the existing

care home).

+ 40 Full time

equivalent

Car parking spaces 39 82 +43

Disabled car spaces 3 5 +2

No. of storeys


replaced

Existing care home to the south

west of the site

Single

Three

Three storey

Three

+ two storey

No change

Max height 5.4m 11.2m

6.8, (living wall)

+ 5.5m

Max eaves height 2.5m North 6.2m –

8.4m

South 8.6m

6.1m

4.0 PLANNING CONSTRAINTS

Agricultural Land Grade 3 Agricultural Land Classification Grade 3 (The site contains one single storey building and is part of a wider care home complex - as such the site is unavailable to agricultural farming and not part of a farming unit. This matter need not be considered further).

Area of Outstanding Natural Beauty AONB (statutory protection in order to conserve and enhance the natural beauty of their landscapes - National Parks and Access to the Countryside Act of 1949 & Countryside and Rights of Way Act, 2000)


Metropolitan Greenbelt MGB1 - Metropolitan Greenbelt (site is located within the Metropolitan Green Belt.)

Limits to built development (The site immediately abuts the Limits to Built development, that is situated to the immediate north of the application site).

Potentially Contaminated Land – (Affects the siting of Cornford House itself, to the south of the proposed siting of the new building).

Tree Preservation Order OAK/VAR – (located to the north of the existing Cornford House, T1 and T2 are oak trees classified as significant and shown to be retained).

5.0 POLICY AND OTHER CONSIDERATIONS

The National Planning Policy Framework (NPPF) March 2012

National Planning Practice Guidance (NPPG)

Development Plan:

Tunbridge Wells Borough Core Strategy 2010;

Core Policy 1: Delivery of Development

Core Policy 2: Green Belt

Core Policy 3: Transport Infrastructure

Core Policy 4: Environment

Core Policy 5: Sustainable Design and Construction

Core Policy 6: Housing Provision

Core Policy 14: Development in the Villages and Rural Areas Tunbridge Wells Borough Local Plan 2006

Policy MGB1: Metropolitan Green Belt

Policy LBD1: Development outside the limits to Built Development

Policy EN1: Development Control Criteria

Policy EN8: Outdoor Lighting

Policy EN13: Tree and Woodland Protection

Policy EN16: Protection of groundwater and other watercourses

Policy EN25: Development Control Criteria for all development proposals affecting the rural landscape

Policy R2: Recreation open space in development of more than 15 bedspaces

Policy TP4: Access to the road network

Policy TP5: Vehicle Parking Standards

Policy TP9: Cycle Parking.

Supplementary Planning Documents:

- Borough Landscape Character Area Assessment 2002: Second Edition. Local Character Area :

- Renewable Energy SPD (April 2007) - Recreation Open Space SPD (July 2006)

Other documents

- Green Belt Study 2017


- Kent Design Guide Review IGN3 Nov 2008

- High Weald AONB Management Plan 2014-2019

- Sevenoaks and Tunbridge Wells Strategic Housing Market Assessment (SHMA) September 2015

6.0 LOCAL REPRESENTATIONS 6.1 Three site notices erected, one in Cornford Park – a residential street, and two on

Cornford Lane, one near the site access and one further north, outside residential properties.

6.2 Re-consultation carried out for 14 days, 3 site notices erected in the previous

positions, posted 18.09.17. 6.3 16 letters/ emails of objections received. Following re-consultation, 9

representations were received confirming previous comments still stand and additional comment made, 5 additional representations received. Objections arising can be summarised as follows;

6.4 Scale and form

Layout and density of the proposed development would be overbearing and out of scale with neighbouring 2 storey properties; and the low building heights of Pembury generally; and;

Applicant has another site in Pembury – designed and landscaped to fit in with the natural contours of the land and to minimise the effect on neighbours;

6.5 Impact on neighbouring amenity.

Proposal would impact on residential properties to the north and north west , in terms of loss of privacy, sunlight and overshadowing; caused by the proposed terraces, height of the development, layout and lack of screen;

There would be ongoing noise and disturbance as a result of the use of the proposed development – concern regarding early morning/late night deliveries; ambulances 24 hours a day;

Impact from increased use of the pedestrian access through to Cornford Park;

The proposal will block views for the residential neighbours of the AONB;

No regard to pre-application advice recommending 30m separation distance; 6.6 Highways, parking and access.

There is no footpath to the site via Cornford Lane which means many staff and visitors to the existing care home use a gate on private land in Cornford Park as a cut through, there would be an increased use of this cut through;

No designated footpath through Cornford Park and with parked cars on both sides pedestrians are forced to walk in the road;

Development would attract additional traffic movements and other vehicle usage in the area, already seriously congested;

Cornford Lane is already an extremely busy and narrow road, development will only increase the traffic to a more dangerous level;

Parking could increase within Cornford Park, that is already limited in capacity;

Travel Plan under TW 05 00719 has not been met;

Cornford Lane is difficult to access for larger vehicles, and there are proposals for a one way system;

Under covenant, cyclists are not permitted to use the Cornford Park access; and


There is already a lack of lighting in Cornford Lane; making it dangerous for pedestrians from Cornford House and Peppenbury.

6.7 Trees

Concerned that the construction works would affect the stability of the oak tree and damage to the spread of roots;

Protection measures should be put in place to protect the trees;

Concern for trees T1 and T2 with the expansion of the car park. 6.8 Drainage and water resources

Kent is seen as a water deprived area- developer should be required by condition to have a self contained water recycling plant;

Concern relating to potential impact on drainage and surface flooding from such an extensive building; and;

Full investigation of the sewer is still outstanding.

6.9 AONB & Metropolitan Green Belt

The proposed footprint would not conform to the protection requirements for an AONB; demolished bungalow technically brownfield, but within greenfield;

The AONB designation has resulted in many residents in the High Street and Cornford Park reducing their schemes significantly (Officer Note: An objector refers to a decision relating to a Lawful Development Certificate for a loft conversion with 3 velux windows to front elevation and a flat roof dormer to the rear elevation at 22 Cornford Park ref. 12/00458/CPD/EA1);

This scheme is many times greater in size and height so will have a significant impact and be too prominent; and;

Site is located in the Metropolitan Green Belt, would reduce its openness and no demonstration that there are no alternative sites outside the Green Belt;

6.10 Ecology

Adverse impact on wild birds nesting in the area, Directive 2009/147/EC and Directive 92/43/EEC;

Wildlife, Countryside and Rights of Way Act will also be adversely affected, destroying habitats and rights of access to adjacent land;

Adverse impact on bats, owls and hedgehogs, endangered and protected species, as well as slow worms and rabbits seen in the area;

Impact of lighting on wildlife;

Impact on hedgerows.

6.11 Other matters

Proposal would adversely affect the population demographic of the area and impact on local services and local GP’s;

Applicant assumes existing boundary planting and hedging will be retained as they are – but they are outside the applicants’ control; and;

Would like to see a curfew of between 10pm and 8 am with the exception of the emergency services.

6.12 One comment neither objecting nor supporting – raising the following comments

Concern at increase in flow of traffic and other vulnerable pedestrians using the road.

7.0 CONSULTATIONS Pembury Parish Council


7.01 (20.10.17) –The parish continue to have concerns set out as follows; 1. Style of building not in keeping with the local environment 2. Property is too large and imposing 3. Property will overlook nearby properties, invading their privacy 4. Because it is a healthcare facilities, lights are likely to be on all night causing a problem of light pollution to nearby residents 5. Increase of traffic along Cornford Lane – already a busy cut-through that is not suitable for more traffic 6. Local doctor does not have the resources to manage such an extensive nursing home housing residents with high need

7.02 (13.06.17) Identical comments to those submitted on 20.10.17 7.03 Scottish Gas

17.10.17 - On the mains record there is a low/medium/intermediate pressure gas main near the site. There should be no mechanical excavations taking place above or within 0.5m of a low/medium pressure system or above or within 3.0m of an intermediate pressure system. The position should be confirmed using hand dug trial holes. Safe digging practices in accordance with HSE publication HSG47 “Avoiding Danger from Underground Services” must be used to verify and establish the actual position of the mains, pipes, services and other apparatus on site before any mechanical plant is used.

7.04 Kent Police

05.06.17 & 26.10.17 – No reference to crime prevention or CPTED in the Design and Access Statement and no communication to date from the applicant/agent. There is merit in pre-application meetings prior to submission of any planning application. Request made that the applicant’s attention is drawn to the Kent Design Initiative which will assist them with Crime Prevention and Community Safety. Failure to contact may have an effect of the development in with regards to Secure By Design and future services and duties of the Community Safety Unit (CSU).

7.05 A condition is requested regarding measures to minimise the risk of crime. If a condition is not used then we suggest you consider using an informative.

Southern Water 7.06 06.06.17, 30.10.17 29.11.17– No objections raised – Results of an initial desk top

study indicates that Southern Water currently cannot accommodate the needs of this application without the development providing additional infrastructure, the proposal could increase flows to the wastewater sewerage system and result in increase flooding, contrary to the NPPF.

7.07 Alternatively, the developer can discharge foul flow no greater than existing levels if proven to be connected and it is ensured that there is not overall increase in flows into the foul system. The applicant would be required to provide a topographical site survey with the connection application showing the existing connection points, pipe sizes gradients and calculations confirming the proposed foul flow will be no greater than the existing contributing flows.

7.08 Should the LPA be minded to approve the application, Southern Water would like conditions to be attached to any permission regarding the drainage strategy, detailing means of foul disposal and implementation timetable, to be submitted to and approved in writing. An informative regarding formal agreements with Southern Water to provide the necessary sewerage infrastructure to service the development is also requested.


7.09 Building Control officers or technical staff should be asked to comment on the

adequacy of soakaways to dispose of surface water.

7.10 Due to the vibration, noise and potential odour generated by sewage pumping stations, no habitable rooms should be located closer than 15 metres to the boundary of a proposed pumping station site.(Officer Note: The applicant has confirmed that habitable rooms would not fall within the 15m zone).

7.11 The detailed design for the proposed basement should take into account the possibility of the surcharging of the public sewers. We request that should this application receive planning approval, an informative is attached to the consent to that effect.

7.12 Additional comment on 30.10.17 in addition to the comments set out above – Drawing number 10118-SK500 appears to show that the applicant is proposing to divert a sewer that is not showing in Southern Waters records. Southern Water requests a formal application for sewer diversion under S185 of the Water Industry Act to divert any public sewer, for further advice please contact Southern Water at the address provided.

7.13 (Officer Note: Following discussion with Southern Water regarding this matter, it is

understood that it is not unusual for the detailed design to be prepared following the grant of permission. It would be expected that evidence of the existing flow would be provided at conditions discharge stage, and, if it could not be demonstrated that proposed foul flows would be no greater than existing (which is likely in this case), then a feasibility study would be required and site specific solutions would then be formulated. Southern Water suggest that if the proposed flows would be greater than existing, it is suggested that they submit a pre-development enquiry (which will identify the nearest point of capacity or submit an application for a feasibility study, to find out what work is required to accommodate the proposed development).

UK Power Networks 7.14 16.05.17 & 17.10.17 – No objections to the proposed works. Details regarding safe

practices supplied. Natural England 7.15 28.09.17 & 30.10.17 – No objections raised – The proposal is unlikely to affect any

statutorily protected nature conservation sites.

7.16 The proposed development is for a site within a nationally designated landscape namely the High Weald AONB. Natural England advises that the planning authority uses national and local policies, together with local landscape expertise and information to determine the proposal. The decision of the Local Planning Authority should be guided by para 115 and 116 of the NPPF. It is also advised that the AONB Partnership or conservation board is consulted. Where available, a local Landscape Character Assessment would be a valuable contribution.

7.17 Standing advice on protected species should be followed. KCC Lead Flood Authority 7.18 30.05.17 & 27.10.17 – No objections raised – it is noted that it is proposed to use

infiltration drainage on this site comprising permeable paving and concrete ring soakaways.


7.19 The site is underlain by Ardingly Sandstone and Tunbridge Wells Sand. The Tunbridge Wells Sand in particular is often fine grained and therefore offers a low permeability. Due to this low permeability, infiltration devices require a very high surface area in order to achieve acceptable half drain times. There is a lack of other suitable outfall for surface water in this location given known capacity constraints on the combined sewerage in the area.

7.20 Additionally, KCC will require that the design accommodates the 1 in 100 year storm with a 20% allowance for climate change and an additional analysis undertaken to understand the flooding implication for a greater climate change allowance of 40%.

7.21 Following the submission of further information, KCC have removed their previous

objection. The site investigation highlights some variance in infiltration across the site, and drainage features will need to be carefully designed to penetrate into the permeable strata at depth whilst remaining as shallow as possible for sufficient infiltration.

7.22 It is strongly recommended additional testing is carried out prior to detailed design as

some infiltration results are extrapolated or interpolated. Any additional testing should be in full accordance with BRE 365:2016. At the detailed design stage, KCC Lead Flood Authority would expect to see the drainage system modelled using FeH rainfall data in any appropriate modelling or simulation software. As LLFA, KCC will require that the design accommodates the 1 in 100 year storm with a 20% allowance for climate change and an additional analysis undertaken to understand the flooding implication for a greater climate change allowance of 40%.

7.23 This analysis must determine if the impacts of the greater allowance are significant

and exacerbate any flood risk. The design may need to be minimally modified but may also need additional mitigation allowances, for example attenuation features or provision of exceedance routes. This will tie into existing designing for exceedance principles. If the LPA are minded to grant permission for the development conditions are proposed to seek Sustainable surface water drainage details, a condition is also recommended seeking the details of the implementation timetable and management and maintenance plan. A condition seeking a Verification Report pertaining to the Surface Water drainage system is also requested.

Environment Agency 7.24 (18.05.17 & 19.10.17) – No comments to make – falls outside remit of the EA as a

statutory consultee. The EA wish to be re-consulted if foul drainage is not directed to the mains sewer. KCC Highways

7.25 (15.07.17 08.11.17 & 09.11.17) – No objection raised. A balanced judgement is required in reaching a recommendation on this application. Access to the site has a number of limitations in terms of the width of Cornford Lane and lack of pedestrian facilities. However, the proposals are not introducing a new use to the area, but rather additional facilities at an existing care facility and KCC Highways are also mindful of other care facilities within the vicinity. The planning statement advises that the proposal will offer short term rehabilitation services complimentary to the existing facility and that the two facilities would be operated to provide co-ordinated services using shared staff.

7.26 Updated comments recognise the use is not a high traffic generator in the peak

periods, when flows increase on Cornford Lane. On balance, the highway authority would not seek to raise objections.


7.27 Further details were sought regarding the operation of the site including the day care

facility and also regarding the existing facility to place the proposals in the context of the existing use, and its traffic generation and parking demand. The applicant has clarified the existing and proposed parking levels at the site and these met the expectations of SPG4, which is employed as guidance.

7.28 KCC Highways previously commented that the applicant should be asked to explore options to improve the sustainable links of the site and as to confirm whether Tesco link was secured as mentioned under TW/05/00719. Recent comments confirm that TWBC are undertaking a Corridor Study along the Pembury Road corridor with a view to relieving congestion and whilst bids for central funding continue, any development that will benefit is also expected to make a financial contribution. A contribution has been calculated at £32,188, based on am and pm trips. (Officer note – a formal pedestrian link to Tesco, through from Cornford Lane was not secured through TW/05/00719, although an informal desire line has been established. The end that is closest to Cornford Lane is paved, but this route is not paved all the way to Tesco. This link is shown on an approved extant permission for the replacement foodstore, (planning reference 09/01265) but was not secured by condition. This route would be outside of the application site being considered and therefore it would not be reasonable to condition under this application).

TWBC Planning Policy

7.29 17.05.17 – On viewing the floor plans and needs assessment it is clear that the proposal would be fairly specialist accommodation that would fit in Class C2 as a modern version of a nursing home. The only difference is that shorter terms stays are mentioned as people recover from a hospital stay and before return to home. The unit would have individual bedrooms etc. rather than being separate dwellinghouses.

7.30 TWBC do not have detailed information regarding the level of need and so normal assessment of policy would apply.

Mid Kent Environmental Protection 7.31 14.06.17 – 06.11.17, 29.11.17. No objections raised, subject to recommended

conditions and informatives. Main points considered; Noise, amenity, air quality, land contamination, asbestos, lighting, odour, accumulations, sewage and Private Water supplies. For the purposes of Environmental Health’s consideration the area is more urban than rural, traffic noise is unlikely to be a significant problem for this particular site and a condition is proposed to demonstrate internal noise levels.

7.32 Similarly, air quality is not considered to be an issue at the site, although Electric

Vehicle charging points would be a useful promotion of a sustainable travel option. It is noted that the foul sewage will be dealt with via mains system, and that there are no known private water supplies in the vicinity. It is noted that Southern Water have stated that a Drainage Strategy should be submitted and that documents have been submitted in this respect. It is also noted that conditions regarding contaminated land are still relevant.

7.33 Conditions recommended relate to the following; submission of lighting details, hours

of working, plant and ducting systems, rating levels, day and night, EV charging, code of construction practice storage of oils, fuels and chemicals. Informatives regarding the Mid Kent Code of Development Practice and asbestos.


7.34 The 2006 land contamination report has been considered, some of the assessment criteria submitted have changed since it was prepared, the land contaminants in the soils were generally very low with the exception of one Benzo (A) pyrene result. Five samples is considered to be a low number, and due to the age of the report and changes to guidance it should be reviewed. Conditions requested previously are maintained with the addition of a contaminated land condition.

7.35 Confirmation has been received that road traffic noise is not considered to be such

that the development could not be approved subject to a noise condition to demonstrate internal noise levels.

TWBC Environmental Officer 7.36 (10/07/17) – In line with the Renewable Energy SPD – the developer has outlined

numerous measures to ensure energy use is reduced by 20% beyond building regulations.

7.37 Although not a renewable energy source, the proposal to offset 10% of the sites

carbon emissions using combined Heat and Power appear reasonable and are also in line with the Renewable Energy SPD and 2016 update.

7.38 The use of a CHP instead of traditional gap-fired boilers will reduce CO2 emissions by 28%. The proposals are acceptable and the application can be supported.

TWBC Landscape & Biodiversity 7.39 (13.07.17) – No objections raised. The ecological report has been carried out by

appropriate professionals to a recognised methodology and as such the findings are accepted. Report recommends a scheme of mitigation for reptiles including an area of habitat enhancement and long term management associated with an area previously uses as a reptile receptor site, which will be important to secure. Bird and bat boxes would be included in the enhancement measures. Recommended to secure this through a LEMP condition. Controlled lighting should be secured through condition.

7.40 The Landscape and Visual Impact Assessment has been prepared by a suitable

professional to a recognised methodology and as such the findings are broadly accepted. The report provides for a generally thorough evaluation of the site and relevant policies. The building would be uncompromising in design being a large monolithic form with a single roof line, uniform elevational treatments and materials which the landscape assessment could have commented on and sought changes to mitigate landscape effects. There is perhaps a lack of rigour in considering the effects of the height of the building which may be more prominent locally than the report suggest. The green walls are of some help in reducing visual effects (and promoting sustainable design).

7.41 The Landscape and Biodiversity Officer is not convinced about the visual effects but

agree that they will be limited. It is not agreed that the effect on the landscape features and character of the site is beneficial as this approach ignores the imposition of the large monolithic building, but there are some landscape benefits (being a planned approach to the landscaping). Overall, the landscape and visual effects are limited and one cannot ignore the adjacent facility and how this proposal will be read in that context as well as the rather nondescript character of the existing site. Taking account of the benefits of such a scheme and the limited nature of adverse landscape and visual effects that it would be hard to sustain landscape/AONB objections to this proposal. Improvements to external appearance and design could be sought via condition. The landscape strategy is acceptable and the necessary


details for this can be secured by standard landscaping conditions for details of hard and soft and implementation.

TWBC Client Services 7.42 17.10.17 – No objections raised. This will be considered to be commercial and

would require suitable and correct method for storage and required frequency of collection to ensure waste contained between collections, as well as disposal of that material by a suitable waste carrier.

TWBC Parking 7.43 (16.05.17) – No parking restrictions near this site and no significant parking issues in

the vicinity are known of. Therefore the following are observations in respect of possible parking implications.

7.44 The Transport Statement comments on the missing section of footway between the site and Pembury High Street then seems to be dismissed as an issue (it is suggested) signing indicates that pedestrians use the carriageway. Cornford Lane is a well known short cut for traffic wishing to avoid the A264 Pembury Road and therefore carries a disproportionate amount of traffic, particularly at peak hours. The narrow width and lack of segregated pedestrian facilities make this a very unattractive route for those on foot, so proximity of bus services etc. may be academic. This has potential to impact on travel to and from the site by car instead of foot.

TWBC Trees 7.45 (22.08.17 & 01.11.17) – The two oak trees on the northern side near the entrance are

protected by TPO. Other trees on the site are not protected. 7.46 The proposal would result in the loss of 13 trees or groups of trees which are internal

to the site. The key tree to be lost is T4, a Cedar. 7.47 The tree report makes a detailed assessment of the trees on the site and those which

would be removed for the proposed works, all would be internal within the site. T4 Cedar, is quite a key tree and is visible from outside the site. It would be a shame to lose this tree, it is noted however, that there is a proposal that it could be replaced south of the drive and that other planting should take place. It is agreed that there is an opportunity for a good landscape strategy, and on balance no objections are raised, subject to suitable landscape and tree protection conditions.

7.48 A plan would also be required to be submitted showing the route of services into the

site and a condition that they be installed to NJUG specifications. From an arboriculture perspective, concerns are raised to the proposal, but these can be overcome by appropriate conditions.

Pembury Society 7.49 30.05.17 – whilst aware of the need nationally for more care home accommodation,

some reservations are expressed regarding this scheme. These can be summarised as follows;

- Site is located in the Green Belt and High Weald Area of Outstanding natural Beauty, therefore only a building of exceptional need should be allowed. Building would have a footprint of four times that of the one it would replace, existing was stipulated to be single storey. Building proposed would be too prominent;

- Cornford Lane is particularly narrow between Pembury High Street and Cornford House entrance and there is no pavement and no space for a pavement, proposal would make this even more dangerous;


- Impact on the local GP service; and; - Development should be refused on the grounds of overdevelopment.

8.0 APPLICANT’S SUPPORTING COMMENTS

The applicant’s supporting comments can be summarised as follows; - The proposal would provide additional capacity to care for 68 complex patients, with

the need for A & E or acute care admission; - There are benefits of shared resourcing and staff training between the proposed

ICHF and existing care home at Cornford Court, as well as potential links to Pembury Hospital; There would be a benefit from co-location of facilities and reduce costs on local healthcare facilities;

- Creation of approximately 40 new full time equivalent permanent jobs; - Contribution of 68 new dwellings; - Release of under occupied dwellings into the housing market; - Building proposed would be of a suitable design and would respect the character of

the area; - Impact on neighbouring amenity would be minimised; - Adequate provision is made for parking, access and communal space, whilst

encouraging more sustainable modes of transport; and; - The proposal represents benefits that together comprise very special circumstances,

and outweigh any perceived harm to the Green Belt.

9.0 BACKGROUND PAPERS AND PLANS Drainage Strategy Updated August 2017 Planning Statement Care Needs Assessment Arboricultural Survey and Planning Integration Travel Plan Transport Statement Preliminary Planning Compliance Report Landscape Strategy Plan Ecology Assessment Energy Strategy and Renewable Energy Assessment Contaminated land Appraisal and Reports Landscape and Visual Impact Appraisal Design and Access Statement A-685- 01 B – Site Location Plan A-685- 100 A5 – Site Plan A-685- 101 A2 – Basement Plan A-685- 102 A2 – Ground floor Plan A-685- 103 A2 – First floor Plan A-685- 104 A3 – Second floor Plan A-685- 105 A2 – Existing elevations A-685- 203 A4 – Proposed elevations

10.0 APPRAISAL

10.01 The site lies outside the Limits to Built Development (LBD), within the Metropolitan

Green Belt and within the AONB. The main issues to consider are therefore;

The principle of development, including whether the proposal would be appropriate development in the Green Belt and if not whether very special circumstances (VSC) exist to outweigh the harm;

Sustainability of the proposal and the impact on the landscape and the AONB;


Scale, design and appearance of the proposal;

Impact on residential amenity;

Highways and parking;

Impact on trees; Principle of Development

10.02 The site lies outside of the limits to built development (LBD), within the countryside

that is designated Metropolitan Green Belt (MGB) where there is a general presumption against development. Policy LBD1 states that outside the LBD development will only be permitted where it would be in accordance with all relevant local plan policies. Para 79 of the NPPF attaches great importance to the Green Belt and protection of its essential characteristics, being openness and permanence. Core Policy 2 (in accordance with Para 87 of the NPPF) sets out a presumption against ‘inappropriate development’ within the Green Belt, as supported by the NPPF.

10.03 The NPPF, para 88, comments that when considering any planning application, local

planning authorities should ensure that substantial weight is given to any harm to the Green Belt. “Very Special Circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

10.04 The proposal is considered to constitute more than just a replacement for an existing

building, involving a substantial increase in the scale and footprint of the proposed care home compared to the existing single storey building on the site. However, para 89 of the NPPF sets out a number of exceptions being for the following purposes;

- Agriculture and forestry; - Outdoor sport and recreation as long as it preserves the openness of the green belt

and does not conflict with the purposes of including land within it; - The extension or alteration of a building provided that it does not result in

disproportionate additions over and above the size of the original building; - The replacement of a building, provided the new building is the same use and not

materially larger than the one it replaces; - Limited infilling in villages, and limited affordable housing for local community needs; - Limited in-filling or partial or complete redevelopment of previously developed sites

(brownfield land) whether redundant or in continuing use (excluding temporary buildings) which would not have a greater impact on the openness of the Green Belt and purpose of including land within it than the existing development.

10.05 The NPPF states that previously developed land is land which “is or was occupied by

a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed)”, and excludes “land in built-up areas such as private residential gardens”.

10.06 Previous Inspectors, when considering development within the MGB, have

considered the degree of containment within the site, the concept of openness encompasses not only the visual aspects but its spatial implications. In effect, openness in Green Belt terms means that land within it should remain, on the whole, free from development.

10.07 Limited infilling is not defined within the Framework, however scale, massing and

solidity can be taken into account when making an assessment on this matter.


10.08 In this case, the single storey building on the site, of some 1,616 m3 would be

replaced with a building of some 14, 469m3. The height of the existing building is 5.4m whilst the height of the proposed building would be 11.2m. The proposal, due to its substantial increase in volume, is unlikely to be considered limited infill in the ordinary meaning of the word. However, there is a single storey building on the site and, in the ordinary meaning of the word, it would be reasonable to conclude that the development would comprise “the partial or complete redevelopment of previously developed sites (brownfield)” subject to there being no greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development”. Impact on Openness and purpose of including within the Metropolitan Green Belt

10.09 The proposed Integrated Care Facility would result in building of substantial scale

and massing when compared to the existing single storey building on the same site and result in a greater impact on the “openness” of the Metropolitan Green Belt and therefore is considered to be inappropriate development. It is therefore necessary to consider the level of impact. In this case, development would be within the envelope of the existing built form. “Openness” is the absence of development such as buildings and hard surfacing, but also relates to the extent of development and its physical effect on the site, there is a spatial effect as well as a visual effect. Views of the building from the south west would be viewed with the existing 2/3 storey care home in the fore ground. The ridge height of the proposed building, due also to a change in levels, would stand at approx.1m higher, that would not be discernible from longer views from the surrounding area. However, Viewpoint 3 within the LVIA shows that from Cornford Lane, where it crosses over the major route of the A21, mature and partially evergreen tree belts curtail the views of the existing care facility. Similarly, when looking north west, from Chalket Lane, there is significant vegetation that screens the site currently. Whilst the proposal would have an impact on openness, in terms of the scale of the replacement building, it would be seen in the context of the existing larger care home on the site and the residential development immediately to the north. It would be within a contained site, and one that is well landscaped, and, due to the position of the proposal, it would not lead to further incursion into the countryside. A more open site, less contained, could result in a harmful spatial and visual impact that would be correspondingly greater.

10.10 In terms of the purposes of Green Belt, the 2017 Green Belt Study acknowledges

that this parcel of land relates more strongly to the large built up area rather than the wider area. The proposed building, whilst it would be larger in scale than the existing building, would be viewed on the context of the edge of the village and the existing care home on the site.

10.11 Due to the presence of the A21, “urban sprawl” would be contained and the proposal

would not result in a wider urbanising effect. As a result of the position to the A21, the Pembury would not merge with Royal Tunbridge Wells. In view of the position of the proposed building between the A21 and existing care home, would prevent incursion into the open countryside. The existing access would be utilised and would not need upgrading to accommodate the development. It is not considered that the proposal would have a greater impact on the purposes of including the land within the Green Belt.

10.12 The Green Belt study has analysed the land parcel in detail and describes the land

parcel as being contained between Pembury and the A21 and bounded by the Pembury Northern bypass to the west. There is open countryside to the south of the


A21. In terms of the purposes for including the land within the Green Belt, the parcel is rated as relatively weak, this is due to the following reasons;

Purpose Comment

1 – Check the unrestricted sprawl of large built up areas

The parcel is adjacent to the large built area and relates more strongly to this than to the wider area.

2 – Prevent neighbouring towns merging

Development of this parcel would result in a moderate narrowing of the perceived gap but the A21 would preserve separation.

3 – Assist in safeguarding the countryside from encroachment

The parcel relates more strongly to the settlement than the wider countryside.

4- To preserve the special character of historic towns

The parcel forms a minor element in the setting of Tunbridge Wells.

5 – Assist in urban regeneration by encouraging the recycling of derelict and other urban land

Individual parcels are considered to make an equal contribution to this purpose and so have not been assessed.

10.13 The A21 is considered to be a strong separating feature. Whilst it is recognised

within the study that the parcel, that extends some distance from Tesco’s in the west to the bypass in the east, forms a largely undeveloped skyline, it is recognised, that the southern views would be affected by the existing care home facility on this site and the new building, designed to be in keeping with the character of this building, would be viewed in this context. It is also of note that the proposed siting of the building would be well related to the envelope of existing built form on the site, to be sited between the existing building and the Limits to Built Development.

10.14 It is considered that the proposal, would comprise redevelopment of a previously

developed site. It is it is acknowledged that the development would affect the permanence of the open aspect on this part of the site due to the scale and massing of the replacement building. However, due to the site specific context of the site, the level of harm caused by the impact on openness is considered to be low for the reasons set out above. It is therefore necessary for Members to consider whether VSC exist in this case, although, relative to the low level of harm to the openness that has been identified. Very Special Circumstances. Need

10.15 Merely because a proposed development is by definition inappropriate does not mean that there is a prohibition on it. Very special circumstances is a matter for the decision maker in the exercise of their judgement. In this case, there are a number of matters that could comprise very special circumstances. The identified need could be such a circumstance, Paragraph 159 requires local planning authorities, through the Strategic Housing Market Assessment (SHMA), to identify the range of types and sizes of accommodation likely to be needed by the population. The Sevenoaks and Tunbridge Wells Strategic Housing Market Assessment September 2015 indicates that the population of persons aged over 65 accounts for 18% of the population in Tunbridge Wells, and the number of residents aged over 65 is expected to grow substantially - 61% in Tunbridge Wells to 2033, with particularly strong growth expected in those aged over 75, driven by improved life expectancy.

10.16 The SHMA goes on to state that a growing older population and increasing longevity

is expected to result in a substantial growth in people with dementia and mobility problems – in Sevenoaks and Tunbridge Wells people with mobility problems is expected to increase by over 6000 and an increase of more than 2,500 persons with


dementia to 2033. Some of these households would require adaptations to properties to meet their changing needs whilst others may require specialist accommodation or support, there is clear evidence of need for properties which are capable of accommodating peoples changing needs.

10.17 It is also relevant that the SHMA highlights a need for all types of housing in the

Borough, including specialist housing for the elderly. Specialist housing includes sheltered and extra care housing. The SHMA estimates a need for an additional 1,400 specialist dwellings for older persons over the 2013-33 period. This forms part of the overall housing need. The SHMA goes on to say that decisions about appropriate mix should take account of the current stock, other local needs evidence and policies regarding accommodation and care for older persons. An “indicative” figure of 796 bedspaces over the 2013-33 period is identified for care/nursing home bed spaces for older persons, that is a separate need from the assessed overall housing need as it relates principally to a C2 Use Class.

10.18 Para. 50 of the NPPF makes it clear that local planning authorities should plan for a

mix of housing based on current and future demographic trends… and needs of different groups in the community such as older people and people with disabilities. At present, records indicate that since 2012, some 442 beds/extra care units (net) have been permitted. This accounts for a range of care needs, from support on site in self contained accommodation, to traditional bed spaces in care homes. It is clear that the indicative number set out in the SHMA is unlikely to be reached in terms of meeting bedspaces.

10.19 The applicant has submitted with their application a Care Needs Assessment and

planning statement that sets out why they consider that very special circumstances exist in this case. The reasons can be summarised as follows;

- The proposal is to provide a 68 suite care home for elderly people requiring specialist nursing and dementia care;

- The proposed ICHC aim to offer short-term rehabilitation services, that would reduce pressure on hospital beds and also assist patients in regaining independence;

- Services would complement those in the existing care home and the nearby existing Tunbridge Wells Hospital;

- Whilst virtual supply and demand parity exists in terms of registered beds for the elderly, the statistics fail to reflect the environmental quality and standard of the accommodation offered;

- There is a significant under supply of bedrooms for single occupancy with en-suite facilities;

- NHS England publishes data on a monthly basis including information relating to delayed transfer (“bed-blocking as referred to”) – the data confirms a proportionately higher than average level of delayed transfer days resulting from issues surrounding discharge to appropriate nursing/residential care facilities;

- KCC makes specific comment in their Accommodation Strategy in terms of the nature of care provision required – specifically seeking short term beds which might offer intensive enablement into order to facilitate a return home for elderly client – and also specifies a desire for such a service to be in close proximity to the acute hospital (Pembury);

- In terms of total care for the elderly, and dementia care beds – with en-suite facilities, demand comfortably exceeds supply of appropriate accommodation;

- NHS England data for 2016 indicates a slightly higher level of delayed transfer days due to care associated availability than would normally be expected 17.9 days/1,000 persons local population) compared to the national figure of 14.5 days/1,000 persons;

- There is an associated cost with delayed transfer, that is avoidable;


- The site is within a wider C2 care site and as such the principle of a care use is established;

- The proposed ICHC would meet a pressing identified need for new care accommodation providing a new model of integrated care;

- Benefits of shared resourcing and staff training between the proposed ICHF and the existing care home at Cornford House

10.20 It is considered that the applicant has demonstrated a need for the development, in

terms of the bed spaces of the required standard to meet the National Minimum Standards. The need is recognised in the SMHA and by KCC. There is also a clear need identified through the now out of date core strategy policies. The proposal does not include a mechanism to secure clear public benefits from the proposed scheme, for example by providing clear links to the Pembury Hospital but the likelihood is that the proposal would provide some benefits in meeting specialist accommodation. The applicant has been requested to provide additional information regarding this matter, and it has been confirmed that the proposal would provide a Day Centre intended to be utilised by residents of the existing care home and new ICHC, whilst also supporting the local community. The proposal will enable occupants of the existing care home to attend that would not require a vehicular journey. This would serve the existing care residents but also the surrounding community. The care that could be provided on the site would be increased, enabling the support of the existing care home without referring to Pembury Hospital, they also comment that there would be a reduction in admissions from the care home to the local hospital as dehydration and breathing difficulties could be addressed in the ICHC.

Co-locational siting with the existing care home 10.21 The applicant confirms that Cornford House (the existing care home) has a long

established link with Pembury Hospital by way of accommodating a large number of “fast track” continuing healthcare residents i.e. those with short life expectancy who cannot go home and who no longer require acute hospital treatment but who qualify for on-going NHS funded care). The existing care home has insufficient capacity to fulfil the demand for these residents and a new building will extend this relationship with the hospital and help them delay their delays in transfers of care and reduce pressure on the A & E department. The applicant further comments that “60 NHS continuing healthcare residents have been accommodated at Cornford House over the last three years (since 1/1/15) and this is solely within the existing care home. By developing an ICHC on the site this enables this service to be continued and expanded as the length of stay for residents in the ICHC is much shorter.”

Employment Generation

10.22 The proposal would create an additional 40 full time equivalent members of staff, along with being in a position to share 20 staff due to the proposed siting of the development, bringing economic benefits. Such matters have been taken into the balance of considerations when weighing the special circumstances and other benefits of the scheme, with the harm by virtue of the impact on the openness of the Green Belt.

Efficient use of land 10.23 The proposal would make efficient use of the site, provide specialist care in close

proximity to an existing facility and would replace a small building with a building that can potentially deliver the benefits as set out above.

10.24 Officers consider that the development can be considered “complete redevelopment

of previously developed sites”, however, the due to the impact on openness of the


Metropolitan Green Belt, the proposal would comprise inappropriate development. The harm arising from the inappropriate development that is identified as being caused by the development, would relate to height and bulk of the building proposed. The second consideration is whether the benefits created by the development clearly outweigh the harm so as to amount to very special circumstances. Significant weight is to be attached to the very special circumstances and they are considered to outweigh the specific and definitional harm to the openness of the Metropolitan Green Belt.

Whether the proposal constitutes sustainable development

10.25 As Tunbridge Wells Borough cannot demonstrate a 5 year housing land supply, the NPPF also requires consideration of whether the proposal can be considered to be sustainable development. Policies in relation to the supply of housing are “out-of-date” and Paragraph 14 of the NPPF is therefore “engaged”. Paragraph 14 sets out that:

“At the heart of the NPPF is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking. Para 7 of the NPPF sets out that there are “three dimensions to sustainable development: economic, social and environmental”.

10.26 For decision-taking this means:

- approving development proposals that accord with the development plan without delay; and

- where the development plan is absent, silent or relevant policies are out of date, granting permission unless:

any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or

specific policies in this Framework indicate development should be restricted [Footnote 9]”. (Footnote 9 includes land designated as AONB and Green Belt).

10.27 The application would not accord with the development plan by virtue of the position

of the site outside the LBD, within the Metropolitan Green Belt and its position within the AONB and does indicate development should be restricted. It is therefore necessary to consider whether the proposal comprises sustainable development and any adverse impact of granting permission when assessed against the policies in the Framework as a whole.

10.28 The key matters for consideration in this case are;

Does the NPPF MGB policy indicate that this development should be restricted;

Whether or not the proposed development would represent a sustainable form of development, having regard to local planning policies and the NPPF, and particularly whether specific policies in the NPPF (specifically relating to the AONB) within para 14 indicate this development should be restricted.

10.29 On the first matter it is concluded that MGB Belt policy does indicate that

development should be restricted. However, the impact on openness is not considered to be so harmful for the reasons set out in paras 10.09 – 10.14 above as


to warrant refusal of the application, when weighed against the very special circumstances in paragraphs 10.15- 23 above. The second matter will be addressed below. The NPPF sets out that there are three dimensions to sustainable development, the economic, social and environmental roles.

10.30 The site is located outside the LBD, although immediately adjacent to it, where

development would normally be constrained. The development would make a contribution towards meeting a need in the C2 use Class, however, this is one of a number of needs to be met through the preparation of the local plan and should be considered on its merits. The need does not override the needs to ensure good planning and design, and to accord with the development plan and NPPF policies in all other respects.

Specialist accommodation considerations (social and environmental role) 10.31 For the reasons set out above it is considered that the proposal would provide social

benefits in the form of the provision of specialist residential accommodation, as an identified need within the SHMA, development plan and NPPF. Significant weight can be attached to this in considering whether the proposal constitutes sustainable development, under the ‘social’ considerations of sustainable development. This provides substantial weight in favour of the scheme.

10.32 Whilst the supporting documents comment that the development would contribute

towards meeting housing need, traditional C2 Use Class, whilst meeting a specialist need, would not contribute 68 units towards housing land supply as the proposal would not be for self contained residential units. However, weight can be attributed to the social element of providing for a specialised need.

Location of the site (social and environmental) 10.33 The sub-text to Policy LBD1 in the Local Plan (para 3.39) sets out that the LBD’s

purpose is to direct development to built up areas to ensure sustainable development patterns. The application site lies immediately adjacent to the LBD to the north. The site is connected through a footway to the north to the main village and the site lies in close proximity to the main urban area of Royal Tunbridge Wells. The site is also in close proximity to other care services to benefit from shared resources. The location and accessibility is considered to be sustainable. The site is not considered to be “isolated” on the context of the site and surrounding area and modest weight can be attached.

Employment generation and construction (social and economic) 10.34 The proposal would result in employment opportunities during the construction period

and up to 40 full time equivalent members of staff would be employed in the proposed development.

10.35 The applicant has confirmed that 94 (full and part time) staff – equating to 60 full time

equivalents, are required for the existing unit. Twenty existing part time roles would be shared with the existing unit as a shared resource. The employment generation would accord with the NPPF’s priority to support economic growth. This provides significant weight in favour of the scheme.

Impact on landscape (AONB) and ecology (environmental role) 10.36 This will be assessed below, however, in summary, the Landscape and Biodiversity

Officers raises no objections on the grounds of landscape and ecology. The impact on the landscape will be addressed below, however, to summarise, the LVIA shows that long and medium views will not be affected by the proposed development, short views would be filtered by the existing trees and landscaping and any views would be


seen in the context of the existing large care home on this site. It is not considered that views from the AONB would be harmed by the proposed development as to warrant an objection on landscape and AONB grounds. It is also considered that the site is well contained and that the landscape proposals would contribute to improvement to the landscape in this location, where it would benefit from a management of the grounds. Landscape and ecology enhancements would be secured through condition, modest weight can be attributed to these factors. Para. 116 of the NPPF states major development should be refused except in exceptional circumstances and where it can be demonstrated to be in the public interest, considerations of such applications should include and assessment of;

the need for the development and impact of permitted it or refusing it, upon the local economy;

cost of, and scope for, developing elsewhere outside the designated area, or meeting the need in some other way; and

any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

10.37 The impact on the landscape and AONB will be addressed in detail below, however, in this case, there is a need for such development and the development plan is silent on the extent of this need, although the 2015 SHMA demonstrates a need for more specialist housing for the elderly as outlined above. There is a clear rationale behind locating the development in this location, alongside an existing care home and it is not considered that the proposal would result in a detrimental effect on the environment, that cannot be addressed through conditions.

Previously Developed Land (environmental role) 10.38 As set out above, the site includes a single storey building. The glossary of the

NPPF specifically sets out the PDL: the site is considered to be PDL which contributes positively towards the proposal being considered to be sustainable development, and is seen as a slight benefit. Sustainable construction methods (environmental role)

10.39 The applicant is committed to incorporating sustainable measures of construction where viable. The Planning Environmental Officer comments that, in line with the Renewable Energy SPD, the developer has outlined numerous measures to ensure energy use is reduced by 20% beyond the building regulations. Although not a renewable energy source, the proposal to offset 10% of the site’s carbon emissions using Combined Heat and Power (CHP) appear reasonable and are in line with the Renewable Energy SPD and 2016 update. The use of CHP instead of traditional gas fired boiler will reduce CO2 emissions by 28%. The application can be supported subject to conditions. Furthermore, the applicant is prepared to explore the feasibility of using other measures such as sustainable sourced materials – slight weight can be attributed to this element.

Summary of whether the proposal comprises sustainable development 10.40 Having regard to the above, there are slight and modest benefits to the scheme in the

form of providing sustainable methods of construction, re-development of an existing site, ecology and landscape improvements, inherent in the redevelopment of the site. However, there would be associated public benefit in the location of the scheme and proximity to the existing care home and LBD, but also the provision of employment and specialist care for the elderly. Limited harm has been identified to the AONB and the Green Belt, overall, on balance, by virtue of the benefits of the scheme, along with the slight and modest benefits detailed above, it is considered that the proposal meets the overarching aims of the NPPF to achieve sustainable development and complies with Paragraph 14 of the NPPF. The following sections of the report


therefore assess whether the proposal accords with the development plan in all other respects.

Scale, massing, design and appearance

10.41 The design and appearance of the building takes its cue from the existing care home on the site, in terms of style, proportions and use of materials. The proposal has been sited to preserve trees to the north of the site to ensure screening is retained where possible. The design would result in a curved building of approximately 85m in width, with a central core with flat roof garden and terrace above. This central core would accommodate communal facilities such as consulting rooms, lounge/dining room. To the south side the building would appear as a three storey building, however, to the north, the building would appear as two storey, with dormer windows in the roof slope, thereby reducing the scale of the building when viewed from the north. This will also assist in making the transition in character between the two storey properties to the north (set beyond a belt of mature trees) and the three storey care home to the south.

10.42 The proposal seeks to introduce “living walls” on the central core of the building, to

add further architectural interest and to provide sustainability and ecological benefits. The living walls also seek to assist in the assimilation of the building in the surrounding countryside.

10.43 The proposal seeks to reduce the apparent scale and mass of the building with the

introduction of the pitched roof design and dormer windows to break up the apparent scale. The curve of the building would introduce a greater element of visual interest, reduce the apparent scale of the building, and reduce the impact on the entire width of the building, viewed at once.

10.44 It is considered that, whilst the proposal would have a greater impact on the site than

the existing building, that the building proposed would respond to the immediate context of the site, with the three storey care home to the south and two storey dwellings to the north and to the design of the existing care home.

10.45 The building has been sited at the northern part of the site due to the change in

levels across the wider site. Levels drop more severely further south of the site. The siting selected is relatively flat, if the building was moved further south, significant earthworks would be required, with the introduction of high embankments and retaining walls, and positioned closer to trees. Furthermore, the area proposed is relatively flat with an approximate fall of 1.1m, that, as well as minimising the earthworks, will assist future occupants, as care facilities typically require flat areas to avoid level changes for residents to negotiate stairs and ramps. The design, appearance, height and siting is considered to be acceptable given the context of the site and surrounding area.

Landscape and Visual Impact 10.46 The site lies outside the Limits to Built Development and within the High Weald

AONB. In order to assess the impact of the proposal on the landscape, a Landscape and Visual Impact Assessment has been submitted and assessed by the Landscape and Biodiversity Officer. The report has been prepared by a suitable professional to a recognised methodology and as such the findings are broadly accepted. Six viewpoints have been selected, that include the residential area of Cornford Park, a view from Cornford Lane, but also longer views from the Tunbridge Wells Circular walks, some 1.9km away at most. These views are from within the


AONB. View point one is located in the residential area, and views are likely to be obtained at second floor level. However, whilst the view is changed it is not to say that this would be harmful. Looking from the northern residential areas, the view would be in the context of modern residential development and it is not considered harmful. When viewed from the site entrance, there are trees to filter the view, some of which are protected and therefore likely to be retained, subject to the health of the tree. Similarly, when viewed from the north west (Chalket Lane), the site is viewed in the context of the A21, with tree screen on the northern bank of the road filtering views. When viewed from the southern side of the site, the proposal would be seen in the context of the modern care home and the residential development to the north. As set out above, in view of the context of the site, along with a landscape plan that can be secured by condition, it is not considered that long or medium views would be affected to a harmful extent, by the proposed development.

10.47 Short term views, would again, be filtered by the existing trees on the site. However,

any views would be in the context of adjacent, modern development. A landscape plan has been submitted to support the application, which makes provision for communal lawns to the north, set within landscaped grounds. A restored orchard and meadow area is indicated to the south side of the proposed parking area, along with tree planting to reinforce the field boundary. The plan also indicates a potential siting of a replacement parkland tree to the south eastern side of the proposed building. The landscape proposals would enhance the already landscaped grounds of the existing care home and demonstrates respect for the existing character of the site, which is landscaped and green. In addition, green walls are proposed on the central core of the building to the north and south that would assist in assimilating the building into its environment.

10.48 The proposal does not require alterations to the access and the impact on the

landscape would be largely unchanged in this respect. The internal roads would be amended, but would not result in excessive hardstanding, which respects the setting of the site.

10.49 Whilst the LBO comments that there is a lack of rigour in assessing the height of the

building and that it could be more prominent locally than suggested, he agrees that the green walls would help in reducing the visual effects (and promote sustainable design). Whilst not in full agreement about the visual effects and benefits, it is agreed that the visual effects are limited. Overall, the landscape and visual effects are considered to be limited and the context of the existing facility cannot be ignored and the LBO is in agreement with this.

10.50 On balance, taking into account the benefits of the scheme and limited nature of the

adverse landscape and visual effects, that it would be hard to sustain landscape/AONB objections to the proposal. The site is currently of a nondescript character – the proposals would ensure that the site benefited from management of the grounds and a planned scheme of landscaping. Improvements to the external appearance and design, along with landscape conditions, could be used to secure improvements to the scheme.

10.51 Paragraph 115 of the NPPF seeks to ensure that great weight is given to conserving

landscape and scenic beauty in Areas of Outstanding Natural Beauty. Para 116 refers to major development in such areas, and the need to refuse major development except in exceptional circumstances where it can be demonstrated to be in the public interest, consideration of such applications should include the need for the development, the cost of developing elsewhere outside the designated area, or meeting the need in some other way, and any detrimental effect on the


environment, landscape and recreational opportunities. As set out in previous discussion in this report, it is considered that whilst a clear need has been demonstrated, the proposal is not considered to be harmful in landscape terms. The scheme would provide significant benefits, as set out in paras 10.15-10.26 above and the site has been selected as a result of the existing care home on the site and benefits arising from the co-location of services.

10.52 On balance, it is not considered that the proposal would be harmful to landscape

designations for the reasons set out above. It is considered that the scheme would not conflict with the aims of the NPPF or policy EN25 of the 2006 Local Plan, points 1 and 2. The visual impact on the setting of the settlement, the site and the surrounding land is considered to be acceptable.

10.53 The Landscape and Biodiversity Officer has been asked to comment on the

application and concludes that the findings of the Landscape and Visual Impact Assessment are generally accepted and agrees that the visual effects would be limited. It is also considered that, taking into account the existing nature and condition of the site, that there would be some landscape benefits, including the proposed planting scheme. Overall it is considered that the landscape and visual effects would be limited and the adjacent existing facility cannot be ignored and how this proposal would be read in that context. It is not considered that a landscape/AONB objection to the proposal could be sustained. It is therefore considered that there would not be a landscape objection to the proposed scheme.

Residential Amenity

10.54 Concern has been raised by neighbours to the north that the proposal would result in

harm to neighbouring amenity by way of loss of light, loss of privacy and loss of views. The applicant undertook pre-application consultation with neighbours. Following concerns raised at that stage, revisions were undertaken to change the internal usage to a quiet room and treatment room at the closest point to neighbouring properties. The proposal would be some 25.5m from the back of the dwelling to the rear of 7 Cornford Park, which is the closest rear facing property.

10.55 Rear gardens to 4-7, 9 and 11 Cornford Park immediately face the site to the north.

9 and 11 face the site side on, with garden areas back to back. 10.56 At ground floor level, a lounge would be placed at the eastern end of the building,

and residential suites would be located along the north east side of the building. This would be repeated on the first floor level. On the second floor, the east end of the building would have a treatment room, where the window orientates to the south east, therefore reducing the opportunity of overlooking to the north east. As the building curves around a quiet room would be the next room, that is served by a dormer window, set into the roof and facing north west. This would be separated from the front elevation and vehicular access of 9 Cornford Park by some 22.5m. Number 9 has two ground floor windows, one obscure glazed and clear glazed, and no first floor windows on the southern flank wall. Given the separation distances, and the proposed uses of the rooms, the impact on 4-7 and frontage of 9 Cornford Park are considered to be acceptable.

10.57 The rear gardens of 9 & 11 Cornford Park would be in line with the projecting central

core of the building. The flat roofed, central core, is proposed with no windows on the north elevation, although two dormer windows would be set back into the roof slope some 25-26.5m at the closest point to the boundary, 31m to the side flank of No.11 and separation to amenity areas. Given the separation distances to windows,


given the windows are set behind what would be a privacy screen, it is not considered that the proposed building would result in an unacceptable level of overlooking of the garden areas of these properties. In addition, the terrace area has been set back further through the course of the application to reduce the terrace above the core area. The privacy screen can be conditioned to be of obscure glass and the height can also be controlled. This on balance is considered to be acceptable. Number 11 has a ground floor obscured glazed window and side door with obscure glass and no first floor windows. There is a patio area to the rear and side (south). Six dormer windows are proposed on the north west side of the building, these would stand at some 30m separation which is considered to be a suitable separation distance and in view of the window positions on number 11. For the reasons set out above, the impact on this neighbour is considered to be acceptable.

10.58 Number 12 Cornford Park would be separated from the site by some 31m at the

closest point, which is considered to be acceptable and would prevent direct overlooking.

10.59 On balance, the impact on privacy is considered to be acceptable in this instance.

There are no adopted separation distances and each case is considered on its merits. The applicant’s comment that a minimum of 22m would be achieved to the nearest windowless garages of any neighbour to the north and 26m to the nearest dwelling with façade windows, both being in excess of 21m usually adopted.

10.60 Preventing directly opposing windows, and making use of oblique windows can assist

in preventing direct overlooking, as in this case, along with consideration of the separation distances proposed. It is not considered that the proposal would result in direct overlooking to an unacceptable level and therefore the proposal would accord with EN1 of the 2006 Local Plan.

10.61 By virtue of the separation distances, it is not considered that the proposal would

result in dominance of the neighbouring dwellings and garden areas to the north. Whilst there may to a perceived change, and a perception of overlooking, it is not considered that it is to such an extent as to warrant refusal of the application. It is necessary to consider whether the proposal would be overbearing to neighbouring properties, however, the neighbours do not have a right to a view.

10.62 It is also necessary to consider the impact of the central core of the building on,

particularly numbers 9 and 11 Cornford Park. This would be positioned within 12m at the closest point to the house. This would stand at a maximum height of 7m, be of a green living wall finish and would stand in a similar position to the single storey building on the site, which at 5.4m in height, would be just 1.6m lower than the central core of the building as proposed. The element of the building would be some 16.2m in depth before the main building connects to this element. It is not considered at this height and siting, that the central core would be overbearing on the neighbours to the north. The site section indicates that the existing residences stand on slightly higher ground than the proposed flat roofed central core, any approval would be subject to a condition to seek details of the finished floor levels and eaves and ridge heights of the neighbouring dwellings and the proposed building, as set out in Section 11 of this report. Finally, as discussed above, details of the privacy screen to the second floor northern terrace can be secured by condition. The applicant has reduced the proposed terrace to 4m in depth from the previously proposed 8m – with a green roof beyond. It is considered that this would serve to assist in protecting the privacy of the neighbours to the north, whilst providing some outdoor space for occupiers of the new care facility.


10.63 Concern has been raised to loss of privacy to neighbours to the north, however,

whilst the new facility could be viewed, it is necessary to consider whether there would be direct loss of privacy. In this instance, separation distances, choice of floor layout, careful position of windows, (some at oblique angle) and changes to the roof terrace, would result in an acceptable relationship between the proposed development and neighbours to the north.

10.64 In terms of loss of light, the closest element of the building would be the central core

of the building. At the height proposed, and the separation distances, it is not considered that the proposal would result in an acceptable loss of light. The main body of the building would be set a significant distance to the boundary and is considered sufficient to prevent a loss of light to neighbours to the north. Having regard to the separation distances, it is the officers overall conclusion that the proposal would not have such an impact in terms of loss of light, as to warrant refusal of the application.

10.65 The care home to the south of the building would be located some 47m distant and it

is not considered that the amenities of these occupiers would be harmed. 10.66 It is also of note that whilst some trees are to be removed on the northern boundary,

the track would retain separation and planting on the northern boundary is to be reinforced through the landscape strategy.

10.67 To summarise, the proposed main building would be at it closest point 22m from the

nearest residential dwelling (12m from the windowless, green walled central core). This would ensure a minimum window to window distance of approximately 25m. These distances and the intervening planting are sufficient to ensure that there would not be a harmful impact on residential amenity.

10.68 On balance, the impact on neighbouring amenity is considered to be acceptable in

terms of preventing unacceptable loss of light, overlooking and dominance of neighbouring dwellings.

Highways

10.69 The application is supported by a Transport Statement and Travel Plan. Both

documents set out that when fully occupied the facility would employ up to 40 members of staff, full time equivalent, and 20 part time roles, that are accounted for in the existing staffing on the site. Staff would be working on a shift pattern.

10.70 The applicant has applied the following adopted parking standard; Integrated Community Healthcare Centre: Employees: 1 space per resident staff + 1 space per 2 other staff Residents/visitors: 1 space per 6 beds or residents. 10.71 Both homes would operate 3 shifts, and the maximum staff on site at any one time

would be 65 (between morning and afternoon/evening shift)for the existing 60 bed care home (and 60 staff) and proposed development on this site 68 beds and 40 staff. Considering the whole site, 32.5 parking spaces would be required for the staff and 25 spaces for the combined residents. The combined 82 parking spaces are considered sufficient to meet the existing and proposed care home’s parking needs.


10.72 KCC comment that access to the site has a number of limitations in terms of the width of Cornford Lane and a lack of pedestrian facilities. However the proposals are not introducing a new use to the area but rather additional facilities complementary to the existing care facility. KCC Highways also comment that the use is not a high traffic generator in the peak periods, when flows increase on Cornford Lane. On balance KCC do not raise any objections. It is also noted that the existing care home functions well at this site.

10.73 Additional information had been sought regarding the operation of the site including

the day care facility, but also regarding the operation of the existing facility to place the proposals in the context of the existing use. The shift patterns have been considered, along with parking provision on the site and these are considered to meet the expectations of SPG4 which is the relevant guidance.

10.74 The agent has commented that there is a walkway through to Tesco, however, this is

not made up with tarmac along its entire length, although it is clearly in use as an informal desire line. There is an existing pedestrian route through to Cornford Park. The desire line from Cornford Lane, being used as a cut through to Tesco it is not with land in the applicants control to insist it is made fully accessible. There are existing opportunities of sustainable links to the site, that will remain in place to the north, however, the link to the west is considered to be of limited benefit. However, in view of the existing care home facilities on the site, the proposed development and use, along with land ownerships, it is not considered that the lack of pedestrian facilities would represent a reason for refusal in its own right.

10.75 KCC Highways have confirmed that, in conjunction with TWBC, they are undertaking

a Corridor Study along the Pembury Road corridor with a view to relieve congestion and whilst bids for central funding continue, any development is expected to make a financial contribution. A contribution, calculated on the am and pm trips and the data provided in the TS has been used giving a figure of £32,188. The applicant has agreed to this contribution.

Impact on trees 10.76 An Arboricultural Report has been submitted in support of the application. This

confirms that a number of trees are shown to be removed, the scheme would result in the loss of 13 trees or groups of trees that are internal to the site. These include 4 fruit trees, including apple and plum (T31-33 and T39), 3 silver birch (T34, 35, and 37) but also includes 1 ash, hazel, Norway maple beech and eucalyptus. A group of Lawson cypress/western red cedar and a hedge of western red cedar are also shown to be removed. These are located within the site and not subject significant public views. However, the key tree to be lost would be T4 which is a Cedar.

10.77 The tree report makes a detailed assessment of the trees on the site and those which

would be removed for the proposed works. All of the trees would be internal within the site, but T4 is a key tree and visible from outside of the site. Whilst it is considered to be unfortunate to lose the tree, it is noted that there is a proposal that it could be replaced south of the drive and that other planting should take place. There is an opportunity for a good landscape strategy, and on balance, no objection is raised on the grounds of trees, subject to suitable landscape conditions and suitable tree protection conditions. A plan showing the route of services into the site and condition that they be installed to NJUG specifications is also required. Concerns are raised to the proposal but these can be overcome by appropriate conditions. The Council’s Tree Officer agrees with this assessment.


10.78 The main oak specimens would remain on the site. The cedar tree, whilst it is unfortunate to lose, would be compensated for in the wider site area. A number of trees would be retained on the north east boundary to assist with retaining privacy of neighbouring properties. A landscape objection has not been raised generally and it is the cedar that can be seen from the wider public realm, other specimens do not have such an impact on public views. Therefore the loss of the trees would not be so harmful to the character of the area as to warrant refusal of the scheme, when balanced against the public impact and benefits of the scheme. On balance, the impact on trees is considered to be acceptable and policy EN1 of the 2006 Local Plan and Core Policy 4 of the 2010 Core Strategy would be satisfied.

Other Matters

Drainage 10.79 The submitted drainage strategy sets out that Cornford Court currently discharges its

surface water run off into soakaways positioned at intervals around the building. The existing facility to the south constructed in 2006 also discharges into a soakaway system. Foul water from Cornford Court connects into a gravity system which in itself discharge to an adopted pump station sited near its north east boundary. A rising main then carries the sewage to a gravity system in Cornford Park.

10.80 Due to the presence of soakaways in and around the site it is proposed to use a

SUDS system for the development comprising a mix of permeable paving to the car parks which will also be designed to allow the roof water drainage to the front of the new building and soakaways to the rear of the building. The car parking areas will be in accordance with a Type A infiltration system based on CIRIA SuDS manual 2015. A robust design to cater for roof and yard drainage for the 1:100 year storm event plus a 30% climate change factor is being proposed. The exceedance for an additional 10% for 40% climate change factor will be contained within the car parking and depressions created within the softscape in the locality of the cellular soakaways. Surface water will filter through the permeable sub base of the car park and water quality will be improved by this process.

10.81 The updated Drainage Strategy details that foul water will be connected into the

existing system on the north boundary. 10.82 KCC Lead Flood Authority and Southern Water have been consulted as part of the

application and neither object to the proposed development. Both consultees recommend conditions regarding submission of details for dealing with surface water and foul. Whilst Southern Water comment that an initial desktop study indicates that Southern Water cannot currently accommodate the needs of this application without the development providing additional local infrastructure, Southern Water also comment that the developer can discharge foul flow no greater than existing levels if proven to be connected and it is ensured that there is no overall increase in flows into the foul system. Such a development is, however, likely to increase the foul flows to the sewer. On further discussion with Southern Water, they have undertaken a desk top study only. The developer would be required to provide a topographical site survey and/or a CCTV survey with the connection application showing the existing connection points, pipe sizes, gradients and calculations and provide positive evidence of the existing flows and calculation to enable the existing and proposed flows to be assessed. Southern Water also comment that if proposed flows would be greater than existing, they suggest the applicant submit a pre-development enquiry (which will identify the nearest point of capacity) or submit an application for a feasibility study to find out what work is required to accommodate the proposed site. A Drainage Strategy detailing means of foul disposal is sought through


condition and an informative is recommended to advise early consultation with Southern Water. It is considered that the developer has demonstrated that this can be achieved, however, detailed work it is required to establish what, if any, additional infrastructure is required. This is usual at this stage to await the final calculations, to be submitted through conditions, and therefore conditions are recommended.

10.83 In terms of dealing with surface water, the applicant has undertaken further work on

infiltration. KCC as Lead Flood Authority are now able to remove their holding objection to the scheme but comment the there is some variance in infiltration across the site, and drainage features will need to be carefully designed to penetrate into the permeable strata at depth. Additional testing is recommended prior to detailed design and the detailed drainage system should be modelled as per KCC advice. The analysis must determine if the impacts of the greater allowance are significant and exacerbate any flood risk. The design may need to be minimally modified but may also need additional mitigation allowances, for example attenuation features or provision of exceedance routes. It is considered that the developer has demonstrated that a scheme could be prepared for the site, subject to conditions.

Air Quality. 10.84 Environmental Health have confirmed that the scale of this development and its

position (outside of Tunbridge Wells Air Quality Management Area), does not warrant either an air quality assessment or an Air Quality Emissions Reduction condition applied to it. The Graham Land & Development travel plan is satisfactory, however, Electric Vehicle charging points are recommended as a sustainable travel option. Given the sites location, on the edge but outside the LBD, it is recommended that this is applied.

Contaminated land 10.85 Cornford House is located within a potentially contaminated land buffer. Cornford

Court to the north east is outside of the buffer. However, a contaminated land report has been submitted that concludes that no mitigation measures are considered necessary at the site with regard to the risk of future end users or from a viewpoint of phytotoxicity in future garden landscaped areas. Environmental Health have reviewed the document and conclude that, due to its age and changes to guidance since the report, it is recommended that conditions are applied to deal with risks associated with contamination, which is considered appropriate and included within section 11 of this report.

Noise 10.86 The site is in an urban area (for the purposes of Environmental Health’s

consideration), however, Environmental Health have commented that traffic noise is unlikely to be a significant problem for this particular site in view of the distance from the A21. The Design and Access Statement comments that KP Acoustics concludes that some mitigation measures may be required once a detailed design specification has been completed. No objections are raised to the scheme subject to conditions, therefore it is recommended to apply the conditions as recommended, and these are as set out in Section 11 of this report.

Ecology 10.87 Concern has been raised that there are bats and wildlife would be affected by the

scheme. An Extended Phase 1 and Ecology Assessment have been submitted and it is considered that these have been carried out by suitable professionals to a recognised methodology and as such the findings are accepted. The report recommends a scheme of mitigation for reptiles including an area of habitat enhancement and long term management associated with an area previously used


as a reptile receptor site. It would be important to secure this mitigation properly together with long term management. Mitigation and enhancement measures are also recommended for a range of species including the provision of bird and bat boxes, it is suggested that these are secured through a single condition requiring a LEMP and thereafter to be managed in accordance with the approved LEMP. A condition for all external lighting should also be applied.

10.88 Whilst concern is raised regarding the impact on ecology, the applicant has

submitted a suitable assessment and its findings accepted by the Landscape and Biodiversity Officer. The Assessments acknowledge the presence of bats in the emergence survey, but no bat roost confirmed. Recommendations are made within the Ecology Assessment regarding seeking a lighting strategy through conditions, along with installation of bat tubes. These can be secured through.

10.89 The Ecology Assessment concludes that no further surveys are required for GCN,

reptiles or dormice. With regard to reptiles a method statement has been provided which includes details regarding measures to ensure their protection during and after the scheme. Bats are addressed above, however, in addition, as a precaution it is recommended that roof voids are checked for bats prior to demolition. It is therefore considered that the proposal satisfactorily addresses concerns raised regarding wildlife on this site and Core Policy 4 is addressed.

Developer contributions 10.90 Legislation requires that planning obligations (including Legal Agreements) should

only be sought where they meet all of the following tests:

- Necessary to make the development acceptable in planning terms; - Directly related to the development and; - Fairly and reasonably relate in scale and kind to the development.

10.91 The requirement for developments to provide or contribute towards the services for

which they create a need is set out in Policy 1 of the Core Strategy and requirements relating to various types of contributions, for instance for education, recreation, transport etc. are referred to in various CS and LP Policies and in relevant sections of this Report.

10.92 The application clearly identifies a Class C2 use that would not attract developer

contributions in terms of education, recreation and play space. However, the developer has agreed to pay the requested KCC Highways contribution of £32,188. This would allocated to undertaking the study, and would contribute to relieving the congestion, that the development would directly relate to. The developer contribution is necessary in view of the added vehicle trips generated by the proposal, and relates to improvements that all developments in the Pembury area would be expected to contribute towards. The sum is directly related to the am and pm trips and therefore directly relates to meeting the needs of this development and is also related in scale and kind.

Conclusion

10.93 In view of the above considerations, it is considered that, whilst the proposal would

result in a change to the character and appearance of this part of the Green Belt, it is not considered that the proposal would result in harm to the landscape, including the AONB, or the Green Belt, in an area where the A21 is considered to preserve the gap and create a strong separating feature. It is considered that this site relates more strongly to the settlement rather than the wider countryside, that is south of the


A21. The proposed building would be sited no further south than the existing building on this site. Given the site is considered previously developed land and that the public benefits and identified need for this development, are considered to outweigh the level of harm identified. The impact on the openness and purposes of including land within the Green Belt are, on balance, considered to be acceptable, and the proposal is considered to be sustainable development. The scale and massing is considered to be acceptable in the context of the immediate site and surrounding area. The impact on residential amenity, is, on balance, considered to be acceptable, with suitable separation distances. The proposal would be able to meet its operational needs and provide suitable parking and access. One tree of note would be lost, although mature specimens that are protected would be retained. The surface water and foul drainage scheme would need to be explored further, and would be the subject of conditions. All other matters are considered to be able to be addressed through suitable conditions.

11.0 RECOMMENDATION –

A) Delegated powers to GRANT subject to:- THE COMPLETION OF A LEGAL AGREEMENT UNDER SECTION 106 OF THE TOWN AND COUNTRY PLANNING ACT 1990 AS AMENDED BY THE PLANNING AND COMPENSATION ACT 1991, IN A FORM TO BE AGREED BY THE HEAD OF LEGAL PARTNERSHIP MID KENT LEGAL SERVICES BY 30th March 2018 UNLESS A LATER DATE IS AGREED BY THE HEAD OF PLANNING SERVICES TO SECURE THE FOLLOWING:- (i) Developer Contributions towards:

- A contribution of £32, 188 towards a Corridor Study along the Pembury Road corridor with a view to relieving congestion.

(ii) Payment of the Council’s reasonable legal fees for the negotiation and satisfactory completion of the legal agreement.

1/ The works hereby permitted shall be begun before the expiration of three years from

the date of this permission.

Reason: In pursuance of Section 91 of the Town and Country Planning Act 1990 as amended by Section 51 of the Planning and Compulsory Purchase Act 2004.

2/ The development hereby permitted shall be carried out in accordance with the

following approved plans: A-685- 01 B – Site Location Plan

A-685- 100 A5 – Site Plan A-685- 101 A2 – Basement Plan A-685- 102 A2 – Ground floor Plan A-685- 103 A2 – First floor Plan A-685- 104 A3 – Second floor Plan A-685- 105 A2 – Existing elevations A-685- 203 A4 – Proposed elevations

Reason: To clarify which plans have been approved.

3/ Prior to the commencement of the development a Code of Construction Practice

shall be submitted to and approval in writing by the Local Planning Authority. The construction of the development shall then be carried out in accordance with the approved Code of Construction Practice and BS5228 Noise Vibration and Control on


Construction and Open Sites and the Control of dust from construction sites (BRE DTi Feb 2003).unless previously agreed in writing by the Local Planning Authority.

The code shall include: - An indicative programme for carrying out the works - Measures to minimise the production of dust on the site(s) - Measures to minimise the noise (including vibration) generated by the construction process to include the careful selection of plant and machinery and use of noise mitigation barrier(s) - Maximum noise levels expected 1 metre from the affected façade of any residential unit adjacent to the site(s) - Design and provision of site hoardings - Management of traffic visiting the site(s) including temporary parking or holding areas - Provision of off road parking for all site operatives - Measures (including wheel wash) to prevent the transfer of mud and extraneous material onto the public highway - Measures to manage the production of waste and to maximise the re-use of materials - Measures to minimise the potential for pollution of groundwater and surface water - The location and design of site office(s) and storage compounds - The location of temporary vehicle access points to the site(s) during the construction works - The arrangements for public consultation and liaison during the construction works Reason: To protect the amenity of local residents and in the interests of highway safety. This is pre-commencement to ensure that the site set up is secured at an early stage to ensure highway safety and the amenity of local residents.

4/ Development shall not begin until a detailed sustainable surface water drainage scheme for the site has been submitted to (and approved in writing by) the local planning authority. The detailed drainage scheme shall demonstrate that the surface water generated by this development (for all rainfall durations and intensities up to and including the climate change adjusted critical 100 year storm) can be accommodated within the curtilage of the site without increase to flood risk on or off-site. The drainage scheme shall also demonstrate that silt and pollutants resulting from the site use and construction can be adequately managed to ensure there is no pollution risk to receiving waters. Reason: To ensure the development is served by satisfactory arrangements for the disposal of surface water and to ensure that the development does not exacerbate the risk of on/off site flooding. These details and accompanying calculations are required prior to the commencement of the development as they form an intrinsic part of the proposal, the approval of which cannot be disaggregated from the carrying out of the rest of the development.

5/ No building hereby permitted shall be occupied until details of the implementation, maintenance and management of the sustainable drainage scheme have been submitted to and approved in writing by the local planning authority. The scheme shall be implemented and thereafter managed and maintained in accordance with the approved details. Those details shall include: a) a timetable for its implementation, and b) a management and maintenance plan for the lifetime of the development which shall include the arrangements for adoption by any public body or statutory


undertaker, or any other arrangements to secure the operation of the sustainable drainage system throughout its lifetime. Reason: To ensure that any measures to mitigate flood risk and protect water quality on/off the site are fully implemented and maintained (both during and after construction), as per the requirements of paragraph 103 of the NPPF and its associated Non-Statutory Technical Standards.

6/ No building on any phase (or within an agreed implementation schedule) of the development hereby permitted shall be occupied until a Verification Report pertaining to the surface water drainage system, carried out by a suitably qualified professional, has been submitted to the Local Planning Authority which demonstrates the suitable operation of the drainage system such that flood risk is appropriately managed, as approved by the Lead Local Flood Authority. The Report shall contain information and evidence (including photographs) of earthworks; details and locations of inlets, outlets and control structures; extent of planting; details of materials utilised in construction including subsoil, topsoil, aggregate and membrane liners; full as built drawings; and topographical survey of ‘as constructed’ features. Reason: To ensure that flood risks from development to the future users of the land and neighbouring land are minimised, together with those to controlled waters, property and ecological systems, and to ensure that the development as constructed is compliant with the National Planning Policy Framework.

7/ Development shall not commence until a drainage strategy detailing the proposed

means of foul disposal and an implementation timetable, has been submitted to and approved in writing by, the local planning authority in consultation with the sewerage undertaker. The development shall be carried out in accordance with the approved scheme and timetable.

Reason: To avoid pollution of the surrounding area. This is pre-commencement to ensure that suitable drainage is designed at early stage to prevent flood risk.

8/ Notwithstanding the details submitted, prior to the commencement of above ground

construction works, written details including source/ manufacturer, and samples of bricks, tiles, cladding and all roofing materials to be used externally shall be submitted to and approved in writing by the Local Planning Authority and the development shall be carried out using the approved external materials.

Reason: In the interests of visual amenity.

9/ No external lighting shall be installed until a detailed scheme of lighting has been

submitted to, and approved in writing by the Local Planning Authority prior to the commencement of the development of above ground works. This scheme shall take note of and refer to the Institute of Lighting Engineers Guidance Notes for the Reduction of Obtrusive Lighting, GN01, dated 2005 (and any subsequent revisions) and shall include a layout plan with beam orientation and a schedule of light equipment proposed (luminaire type; mounting height; aiming angles and luminaire profiles) and an ISO lux plan showing light spill. The scheme of lighting shall be installed, maintained and operated in accordance with the approved scheme unless the Local Planning Authority gives its written consent to any variation.

Reason: To protect the rural character and appearance of the locality, neighbouring

amenity, and in the interests of biodiversity.


10/ Notwithstanding the details submitted, prior to the first occupation of the dwelling hereby permitted, details of a Landscape and Environmental Management Plan (LEMP) for the site in accordance with BS42020 Biodiversity shall be submitted to and approved in writing by the Local Planning Authority. This will include details of avoidance measures with regards to the protected and notable species (such as nesting birds) as well as enhancement measures for biodiversity and the long term design objectives, management responsibility and maintenance schedules for all communal landscape areas. The approved management and monitoring plan shall be implemented in accordance with the approved proposals within it and shall be carried out in perpetuity;

Reason: In the interests of ecology, the landscape and scenic beauty of the area

11/ Prior to the commencement of above ground construction works, a scheme for the

enhancement of biodiversity on the site shall have been submitted to and approved in writing by the Local Planning Authority. The approved scheme shall take account of any protected species that have been identified on the site, and in addition shall have regard to the enhancement of biodiversity generally. It shall be implemented in accordance with the approved proposals within it and shall be carried out in perpetuity.

Reason: To protect and enhance existing species and habitat on the site in the future.

12/ Notwithstanding the details submitted, prior to any above ground construction works,

details of boundary treatment shall be submitted to and approved in writing by the Local Planning Authority. This should include a plan indicating the positions, design, materials and type of boundary treatment to be erected. The boundary treatment shall be completed before the first occupation of the dwellings hereby approved. Development shall be carried out in accordance with the approved details and shall be permanently maintained.

Reason: In the interests of the amenity of the area.

13/ No development shall take place until an Arboricultural method statement (AMS), to cover the following; Arboriculture supervision, phasing of works and construction of the parking area within the RPA of the retained trees, and in accordance with the current edition of BS 5837, has been submitted to and approved in writing by the local planning authority.

Reason: In the interests of the amenity of the area. This is a pre-commencement condition to ensure that trees are protected at an early stage of the development.

14/ No development shall take place until details of tree protection in accordance with the

current edition of BS 5837 have been submitted to and approved in writing by the local planning authority. All trees to be retained must be protected by barriers and/or ground protection. The approved measures shall be fully implemented prior to any works commencing on site. Reason: To safeguard existing trees to be retained and to ensure a satisfactory setting and external appearance to the development. This is a pre-commencement condition to ensure that trees are protected at an early stage of the development.

15/ Notwithstanding the details submitted, no development shall take place until a landscape scheme, to include hard and soft landscaping, designed in accordance


with the principles of the Council's landscape character guidance has been submitted to and approved in writing by the local planning authority. The scheme shall show all existing trees, hedges and blocks of landscaping on, and immediately adjacent to, the site and indicate whether they are to be retained or removed. It shall detail measures for protection of species to be retained, provide details of on site replacement planting to mitigate any loss of amenity and biodiversity value together with the location of any habitat piles and include a planting specification, a programme of implementation and a 5 year management plan. The landscape scheme shall specifically address the need to provide new planting with positions, size and species to be used. Reason: No such details have been submitted and to ensure a satisfactory setting and external appearance to the development. This is a pre-commencement condition to ensure that trees are protected at an early stage of the development.

16/ All planting, seeding or turfing comprised in the approved details of the landscaping shall be carried out in the first planting and seeding seasons following the occupation of the buildings or the completion of the development which ever is sooner and any trees or plants (including trees and plants shown to be retained which within a period of 5 years from the completion of the development die, are removed or become seriously damaged or diseased shall be replaced in the next planting season with others of a similar size and species , unless the Local Planning Authority gives written consent to any variation.

Reason: Pursuant to Section 197 of the Town and Country Planning Act 1990 and to protect and enhance the appearance and character of the site and locality.

17/ No development shall take place until a plan of the proposed services into the site has been submitted to and approved in writing. All services shall be installed to NJUG specifications where appropriate.

Reason: To safeguard existing trees to be retained and to ensure a satisfactory setting and external appearance to the development. This is a pre-commencement condition to ensure that trees are protected at an early stage of the development.

18/ No development shall commence until the following components of a scheme to deal with the risks associated with contamination of the site shall have been submitted to and approved, in writing, by the local planning authority:

(1) A preliminary risk assessment which has identified: - all previous uses - potential contaminants associated with those uses - a conceptual model of the site indicating sources, pathways and receptors - potentially unacceptable risks arising from contamination at the site. (2) A site investigation, based on (1) to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site. (3) A remediation method statement (RMS) based on the site investigation results and the detailed risk assessment (2). This should give full details of the remediation measures required and how they are to be undertaken. The RMS should also include a verification plan to detail the data that will be collected in order to demonstrate that the works set out in the RMS are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action.


(4) A Closure Report is submitted upon completion of the works. The closure report shall include full verification details as set out in 3. This should include details of any post remediation sampling and analysis, together with documentation certifying quantities and source/destination of any material brought onto or taken from the site. Any material brought onto the site shall be certified clean;

Any changes to these components require the express consent of the local planning authority. The scheme shall thereafter be implemented as approved.

Reason: To protect future occupiers of the site. The reason these details are required prior to commencement are to prevent harm to the environment and protect the health and safety of construction workers and future occupiers.

19/ Prior to the first use of the premises, details of any plant (including ventilation,

refrigeration and air conditioning) or ducting system to be used in pursuance of this permission shall be submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved details. The scheme shall ensure that the noise generated at the boundary of any noise sensitive property shall not exceed Noise Rating Curve NR35 (in areas of low background sound levels a target of NR30 shall be achieved) as defined by BS8233: 2014 Guidance on sound insulation and noise reduction for buildings and the Chartered Institute of Building Engineers (CIBSE) Environmental Design Guide 2006. The equipment shall be maintained in a condition so that it does not exceed NR35 as described above, whenever its operating. After installation of the approved plant, no new plant or ducting system shall be used without the prior written consent of the Local Planning Authority

Reason: In the interest of residential amenity. 20/ The rating level of noise emitted from the proposed plant and equipment to be

installed on the site (determined using the guidance of BS 4142 : 2014 Rating for industrial noise affecting mixed residential and Industrial areas) shall be low as can be possible. In general this is expected to be 5dB below the existing measured background noise level LA90, T. In exceptional circumstances, such as areas with a very low background or where assessment penalties total above 5 the applicants consultant should contact the Environmental Protection Team to agree a site specific target level.

Reason: In the interest of residential amenity.

21/ Any facilities used for the storage of oils, fuels or chemicals shall be sited on impervious bases and surrounded by impervious bund walls. The bund capacity shall give 110% of the total volume of the tanks.

Reason: To prevent pollution of the water environment.

22/ Prior to the commencement of the development hereby approved, a scheme to

demonstrate that the internal noise levels within the residential units and the external noise levels in back garden and other relevant amenity areas will conform to the standard identified by BS 8233 2014, Sound Insulation and Noise Reduction for Buildings - shall be submitted to and approved in writing by the Local Planning Authority. The work specified in the approved scheme shall then be carried out in accordance with the approved details prior to occupation of the premises and be retained thereafter.


Reason: In the interest of residential amenity. 23/ Prior to the occupation of the development hereby approved, details of the provision

of at least 2 'fast charge' electric vehicle-charging points, including a timescale for its provision, shall be submitted to, and approved in writing by, the Local Planning Authority. The charging point shall be provided in accordance with the approved details and in accordance with an agreed timescale and retained thereafter.

Reason: To ensure a satisfactory standard of development which meets the needs of current and future generations.

24/ The area shown on the approved site layout plan as vehicle parking and turning shall

be provided, surfaced and drained in accordance with details submitted to and approved in writing by the Local Planning Authority before the buildings they serve are occupied, and shall be retained for the use of the occupiers of, and visitors to, the development in accordance with the details approved in the preceding planning condition, and no permanent development, whether or not permitted by the Town and Country Planning (General Permitted Development) (England) Order 2015 as amended (or any Order revoking and re-enacting that Order), shall be carried out on that area of land so shown or in such a position as to preclude vehicular access to this reserved parking space.

Reason: Development without provision of adequate accommodation for the parking and turning of vehicles is likely to lead to parking inconvenient to other road users.

25/ Prior to the occupation of the development hereby permitted, written and illustrative

details for renewable energy technologies within the development shall be submitted to, and approved in writing by the Local Planning Authority and the development shall be carried out in accordance with the approved details.

Reason: To ensure a satisfactory standard of development which meets the needs of current and future


details for water conservation within the development, shall be submitted to, and approved in writings by the Local Planning Authority and the development shall be carried out in accordance with the approved details.

Reason: To ensure a satisfactory standard of development which meets the needs of current and future generation.


details for energy conservation within the development, shall be submitted to, and approved in writing by the Local Planning Authority and the development shall be carried out in accordance with the approved details.

Reason: To ensure a satisfactory standard of development which meets the needs of current and future generation.

28/ Before the occupation of any part of the building, details of the balconies shall be

submitted to and approved in writing, to include, screening panels on the northern

terrace shall be installed to a height of 1.8m from the terrace or balcony, to be of

obscured glass Pilkington level 3. The balconies shall be installed and maintained

thereafter, in accordance with the approved details.


Reason: To protect the residential amenity of the locality.

29/ The Integrated Community Health care Centre (Care Home) hereby approved shall be used for no other purpose than (including any proposed in Class C2 (Residential Institutions)) of the schedule of the Town and Country Planning (Use classes) order 1987 (as amended), or in any provision equivalent to that class in any statutory instrument revoking and re-enacting that order) only.

Reason: To ensure the development meets the particular need identified to justify the grant of permission notwithstanding the site in the Green Belt.

30/ Prior to the commencement of above ground construction works, details of the

finished ground floor levels, shown in relation to the existing and proposed site levels as well as eaves and ridge heights of neighbouring buildings, shall be submitted to and approved in writing by the Local Planning Authority. The development shall be constructed in accordance with the approved details.

Reason: To ensure a satisfactory appearance on completion of the development.

INFORMATIVES

1/ Your attention is drawn to the Mid Kent Environmental Code of Development Practice, the terms of which should be met in carrying out the development.

2/ A formal application for connection to the public sewerage system is required in order to service this development. To initiate a sewer capacity check to identify the appropriate connection point for the development, please contact Southern Water, Sparrowgrove House Sparrowgrove, Otterbourne, Hampshire SO21 2SW (Tel: 0330 303 0119) or www.southernwater.co.uk Your attention is drawn to the need for early consultation with Southern Water regarding the drainage on this site.

3/ Adequate and suitable measures should be carried out for the minimisation of asbestos fibres during demolition, so as to prevent airborne fibres from affecting workers carrying out the work, and nearby properties. Only contractors licensed by the Health and Safety Executive should be employed. Any redundant materials removed from the site should be transported by a registered waste carrier and disposed of at an appropriate legal tipping site.

4/ The applicant/developer should enter into a formal agreement with Southern Water to provide the necessary sewerage infrastructure required to service this development along with the need to discuss the potential diversion of the sewer. The applicant/developer should contact Southern Water regarding drainage matters, at Sparrowgrove House, Sparrowgrove, Otterbourne, Hampshire SO21 2SW (Tel: 0330 303 0119) or www.southernwater.co.uk’ in order to progress the required infrastructure. 5/ Detailed design of the proposed drainage system should take into account the possibility of surcharging within the public sewerage system in order to protect the development from potential flooding. The applicant’s attention is drawn to the comments of Southern Water and comments regarding diversion of the sewer and the pumping station.

http://www.southernwater.co.uk/


6/ The applicant is advised to review the HSE Publication HSG47 “Avoiding Danger from Underground Services” regarding safe digging practices in proximity to gas mains and review the comments of Scotia Gas Networks. 7/ The applicant, agents, or successors in title, are encouraged to undertake discussion external bodies such as Kent Police Crime Prevention Design Advisors (CPDAs) to ensure that a comprehensive approach is taken to Crime Prevention and Community Safety. CPDA Team are; Kent Police Headquarters, CPDA Team, Sutton Road, Maidstone ME15 9BZ email: [email protected] Tel No- 01622 653209/3234. 8/ This development is the subject of an Obligation under Section 106 of the Town and Country Planning Act 1990.

B) IF THE APPLICANTS FAIL TO ENTER INTO SUCH AGREEMENT BY 30 March 2018 THE HEAD OF PLANNING SERVICES SHALL BE AUTHORISED TO REFUSE PERMISSION FOR THE FOLLOWING REASON (UNLESS A LATER DATE BE AGREED BY THE HEAD OF PLANNING SERVICES):

(1) The proposal would not contribute towards a Corridor Study along the Pembury Road

corridor seeking to relieve congestion would therefore conflict with Core Policy 3 of the Tunbridge Wells Borough Core Strategy 2010.

Case Officer: Marie Bolton NB For full details of all papers submitted with this application please refer to the relevant Public Access pages on the council’s website. The conditions set out in the report may be subject to such reasonable change as is necessary to ensure accuracy and enforceability.

REPORT SUMMARY REFERENCE NO -...

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