Chestfield Parish Council Office 4, Jagow House, Joseph Wilson Industrial Estate, Millstrood Road, Whitstable CT5 3PS Telephone: 01227 773121 Email: clerk@chestfieldparishcouncil.gov.uk Ruth Wilkes Development Management Officer Canterbury City Council Military Road Canterbury CT1 1YW 05 August 2014 Dear Ms Wilkes This letter has been written as Chestfield Parish Council’s response to the following outline planning application: CA//14/01319/OUT Land at Bodkin Farm, Thanet Way, Chestfield, CT5 3JD Outline application for a mixed used development comprising up to 290 dwellings (Use Class C3), primary school (Use Class D1), restaurant (Use Class A3), office building (Use Class B1), community building (Use Class D1/D2), gym/fitness centre (Use Class D2), 24 unit care home (use Class C2), convenience shop (Use Class A1), clubhouse/changing room building (Use Class D2) and 18.81 ha of parks, amenity greenspace, children's play areas, playing fields, allotments and community woodland and associated access, infrastructure, landscaping and cycle/footways. All matters except Access and Scale are reserved) Chestfield Parish Council undertook a survey with Maydowns Road residents to gauge their views, in order to inform this representation. Chestfield Parish Council objects to this planning application on a number of grounds, as set out below. Loss of the green gap The submission draft Canterbury District Local Plan (CDLP) clearly has this site designated by Canterbury City Council as “green gap”. If Canterbury City Council grants this application it will encourage applications of similar green gap encroachment - a move that Communities Secretary Eric Pickles MP has voiced concern against in parliamentary comment as recent as June 2014. This must be resisted. Canterbury City Council must respect their own designations. Page 31 Para 1.65 in the CDLP details the Green Infrastructure Strategy: Green infrastructure…plays an essential role in supporting ecological process and improving the health and well-being of individuals and societies. The site was submitted as a Strategic Housing Land Availability Assessment (SHLAA) but not accepted for inclusion in the CDLP by Canterbury City Council. Appropriate development sites have been identified and published. Page 6 para ix in the CDLP states “planning decisions must be taken in accordance with the development plan unless material considerations indicate otherwise.” We do not believe that this application justifies why the Local Plan policy to direct development to existing urban areas should be set aside in this case. Coalescence Canterbury City Council has the site allocated as green gap to prevent the coalescence of the built up areas. This site protects the coalescence of Chestfield with Swalecliffe. Strategy Canterbury City Council’s allocations/strategy is for large sites in urban areas in order to pay for the infrastructure requirements needed. For example the new garden city at Canterbury will pay for improvements to the A2 junction, and all the developments of Herne Bay and along the A28 will contribute to the improvements to the Sturry level crossing. Chestfield Parish Council consider that if smaller sites are allowed to be brought forward, this prejudices the whole strategy - due to the reduction in housing numbers needed on the big sites, and thus reducing the deliverability of the infrastructure provision. Alternative site assessment Eton College should be made to do an alternative site assessment as other sites have been identified for housing, and they should explain why their site is better. For the distribution of housing in the district, in line with the provisions of the South East Plan and the initial Core Strategy Options Report, there is a requirement for a greater proportion proposed for the city of Canterbury. Sufficiency of Housing Land Canterbury City Council has deemed that 15,600 new houses are needed on new land to 2031. An Appeal on a reserve site (owned by Kitewood, and in case no other site came forward) in the old Local Plan went to Appeal in December 2012 and tested housing need/numbers. Every local authority needs a five year housing allocation plus 5%. At this appeal Canterbury City Council demonstrated 6.5 years’ worth of land so there was no special need to bring that site forward. Therefore we would contest that a similar argument arises for the proposed Bodkin Farm development, as this site is not allocated for housing, and we believe, Canterbury does have 5 years plus of its housing numbers required. The interim household projections for Canterbury are for 840 dwellings per year, some 60 units per year higher than the requirement set out in the draft Local Plan. But the National Planning Policy Guidance does allow for testing of those figures, and the difference between the two figures can be explained by different approaches to the counting of students in the area through the Census. This indicates that the scale of development identified in the draft Local Plan is of the correct order. New households projection We understand that new population projections are out and Canterbury City Council await the new household projection based on it. We believe the new households projection should show lower household growth, which weakens the applicant’s comment that the housing identified in the submission draft Local Plan is below that as previously identified as needed. We understand that the city council’s Annual Monitoring Report and Housing Information Audit is currently being worked on and due for publication later this year. Ideally, this information will be available prior to the development management meeting when this application is considered, in order to inform the Members’ decision. Land designation / Agricultural land Page 20 para 1.51 in the CDLP states that The National Planning Policy Framework says, “re-use land that has been previously developed (Brownfield land)… and para 1.52 … that the council will encourage developers to consider whether there is previously developed land available in suitable locations for new development, rather than locating development on fresh land. Clearly the SHLAA application process has dealt with this, and the Bodkin Farm land was rejected. We are aware that Eton College were given the land in question, as agricultural land for agricultural development and research with students, at a reasonable price. This land is adjacent to an ancient woodland. It is not fallow land. 2.10 of the application states “the land is pasture land, which is predominantly managed for hay.” In June 2014, Eric Pickles, the Communities Secretary, says Britain must remain a “green and pleasant land”, with new housing development instead concentrated on brownfield sites, “preserving the best of our countryside”. New figures published in June 2014 show that there’s enough of this land for 200,000 new homes across more than 5000 hectares. Foul Water Drainage At Chestfield, during heavy rains, quite a lot of surface water goes in to the foul system which increases levels and problems. The development will probably need a holding tank, the costs of which would be down to the developer, and this may make a scheme less viable. The application is deficient in that it does not detail an appropriate point of connection to the foul water network to discharge foul drainage from the development. We understand that a formal application must be made by the developer to Southern Water and that Southern Water must confirm in writing that there is capacity in the network for this development to be accommodated. We seriously question whether there is capacity as we are aware of a planning application (CA/05/1653CHE) submitted by Southern Water for a new foul/storm water pumping station on land at the bottom of Chestfield Road and opposite Maydowns Road. This application was intended to alleviate existing flooding problems in the area. (It was subsequently withdrawn, we believe on the grounds of costs of its provision). We therefore believe that robust alleviation measures will be required to create capacity in the existing system. Peter Brooks the city council’s drainage engineer in his drainage impact assessment states: “The successful disposal of the foul flow is critical to any development and I will need to see and approve Southern Water’s written confirmation that they can accept the new flow from the development into their public foul sewer system. However, as it is extremely unlikely that there is sufficient space capacity in Southern Water’s existing local foul sewer system to safely accommodate the flow from some 300 new houses and from more than 8 hectares of office, retail and hotel development, I recommend that the applicant gets a full capacity check from Southern Water and then works out what enhancement to the local infrastructure will be required to service his project and how this will affect the scheme’s financial viability. This should be done very early on in the design process as at this scale of development it is far too important to be left as a condition of any planning approval.” The developer must get written confirmation from Southern Water around a suitable connection and capacity measures. We must ensure this is received prior to the application getting any permission from Canterbury City Council – rather than afterwards as a condition of a permission – and be satisfied that both the existing village and any development’s foul water is adequately dealt with. Flooding There is a known history of flooding in Chestfield, exacerbated by the London Clay soil. Page 149 Para 7.22 of the CDLP states that Canterbury City Council’s objective is to discourage inappropriate development in areas at known risk from flooding. Para 7.33 states that Chestfield is a known flood risk and Para 7.34 advises the Swalecliffe Brook is at saturation. Flooding of the Old Thanet Way occurs at the very entrance to the proposed development – near to the entrance with Johnson Nurseries. Flooding on the Old Thanet Way also occurs on the nearby section by McDonalds. It remains our opinion that flooding on the Old Thanet Way won’t be stopped by the provision of attenuation tanks. We would like to remind planning officers and members that the area for the proposed entrance was flooded so badly in the winter of 2013, that it was necessary to totally close this particular stretch of road. Any future road closure if this development was allowed, would effectively prevent vehicular access for residents, visitors and emergency vehicles alike. Flooding would make the entrance and egress very dangerous for residents and visitors alike. Only one access means that if there is a major accident emergency vehicles will not be able to access all parts of the site. Additionally, there is a barrier at Herne Bay where, if an accident occurs, this may divert all traffic down Chestfield Road. During such closures this proposed development site would be landlocked. Traffic and Speedwatch statistics Chestfield has a very active team of speedwatch volunteers who undertake weekly checks at various different sites within the village. Since November 2011 the speedwatch volunteers have undertaken 88 checks and recorded 1197 vehicles speeding in the village between 36 and 65 mph. The traffic modelling submitted with the application has suggested more than 1,100 extra vehicles on Chestfield Road per day purely from this proposed development – a 12% increase, which coupled with the background growth in traffic predicted, will mean 10,000 vehicles per day using Chestfield Road in 10 years’ time. This is of particular concern to Chestfield Parish Council. These figures would be further increased by the proposed new development at the Herne Bay Golf Club. Hackington parish council Hackington Parish Council has traffic concerns over number of vehicles and speed of vehicles through their village. They have speedwatch statistics backing up speeding traffic through their village. To get to Canterbury vehicles will travel through Hackington, so measures to control traffic and speeding will be needed outside of the parish and all along the primary route to the City. Speed limit reduction from 60mph to 40mph Para 3.4 in the application proposes a reduction in the speed limit to 40mph from 250m east of the proposed new roundabout to the Reeves Way roundabout. Chestfield Parish Council welcomes the proposal to reduce this stretch to 40mph, and would like to see this implemented immediately if the development goes ahead, particularly in view of those pedestrians/cyclists wishing to use the (new) school and/or train station. Helping Maydowns Road vehicles to exit Maydowns Road residents have highlighted to the parish council the already existing problem they have, in trying to exit from their road, particularly if they wish to turn right. Drivers enter Chestfield Road at that point at speed, and often without indicating. Vehicles trying to exit Maydowns Road are very reliant on other drivers ‘letting them out’. The parish council facilitated a traffic counting exercise at the end of Chestfield Road by Maydowns Road on 18 July 2014. This highlighted 319 vehicles exiting from Maydowns Road between 07.30 and 18.30. (Only exiting vehicles were recorded in the exercise, not numbers entering the road.) Therefore, in this response, Chestfield Parish Council would request one of the following in order to give Maydowns Road vehicles an opportunity to exit: i) A fifth leg on the Maydowns / Chestfield Road existing roundabout There is a precedent with a five legged roundabout just up the road. We would like to see this be traffic light controlled. ii) Traffic lights on the Maydowns / Chestfield Road roundabout If a fifth legged roundabout was not considered possible we would like to see the existing roundabout become traffic light controlled, not just to aid Maydowns Road vehicles, but to act to slow down traffic and because there are pinch points / blocking (and flooding) that occurs frequently already just under the Swalecliffe Railway Bridge. iii) A new controlled crossing near Maydowns Road Near to the entrance to Maydowns Road there is an existing island/crossing point with railings for pedestrians and cyclists to cross the road. In view of (a) The speed with which vehicles come off the Old Thanet Way and enter the village at this point (b) The observation that cyclists do not use the roundabout (for fear of speed and volume of traffic presumably) - but prefer instead to use the pavements at this point to move on in the direction to Sainsburys, Swalecliffe, or Herne Bay (c) The increase in traffic that this development would add to Chestfield Road (12%) and (d) The increase in pedestrians and cyclists from the development also wanting to cross at this point: The parish council therefore ask that the Section 106 agreement with the developer (should the application be granted) include provision that the developer should install a new controlled crossing at this point. This would aid Maydowns Road vehicles exiting also. Servicing and refuse collection vehicles There is concern that servicing and refuse collection vehicles will not be able to work within the development – the proposed layout does not provide adequate flow and turn around places. Public transport provision Chestfield Parish Council has seen Stagecoach’s representation that states that they do not believe the diversion of the No 5 service in to the development to be commercially attractive. The vast majority of the site is more than the recommended maximum distance of 400m from a bus stop. Chestfield Parish Council agrees with their comment that the site will be heavily car reliant and therefore objectionable. Visual impact The Master Plan contours appear to show that the playing fields part of the site is sloping. If that is the case, provision of these would require re-grading and the resultant contouring of the natural landscape which would be a retrograde step. Listed building setting Bodkin Farm farmhouse is an 18th Century Grade II listed building. Policy HE4 states that development that is likely to have an adverse impact on the setting of listed buildings will not be permitted. Chestfield Parish Council therefore argue that this is a very traditional farmhouse and that it would have always been standalone surrounded by farmland. This development impacts on its setting. Employment element Jobs are always needed. And people can live and work in the same area. How is the applicant going to bring the employment elements forward? Canterbury has struggled with this and the latest Canterbury District Local Plan shows historical allocations at the coast for employment land now allocated for housing. There is therefore a credibility issue with this part of the proposal. There are also its effects on the development of other sites which need to be delivered. This development would take employment away from Canterbury where it is more wanted and needed. Impact on the SSSI site at Swalecliffe These are sensitive coasts and we should be satisfied about this – new residents if the development goes ahead will use the coast for leisure and dog walking etc. There should be consideration for a developer contribution to offset this impact. Dynamics and demographics and Integration with the rest of Chestfield village The village currently has 1400 homes. Whilst the parish council realises that to keep the village alive for the future some development is potentially needed, but this development is a 21% increase. The development does of course also create a village within a village, and does not integrate into the existing village at all. Affordable housing 90 of the 290 homes would be ‘affordable’. Of these 70% are usually for rent and 30% for shared ownership. Chestfield Parish Council would prefer to push for a greater proportion of shared ownership, to keep the social demographics of the village more comparable to the situation now. And / or the parish council would also ask for a self-build scheme for a number of the plots. The South East Local Enterprise Partnership offers grant aid for self-build schemes. Chestfield Parish Council would also like a local connection criteria for prospective tenants of the social rented housing, similar to those social homes at Littlebourne Court Meadows and the rural exception site at Adisham. The parish council would be happy to determine the details of the criteria with the city council, the developer, and the social registered landlord in due course. The parish council would also like to suggest that some of the market value (for sale) properties should be specifically designed for older people – for example, built around a green and with very small manageable gardens. The parish council feel it would be good to encourage some of the ‘asset rich, cash poor’ residents of Chestfield to down-size in view of the excess winter deaths statistics for Chestfield. But the homes would need to be of high quality and be attractive enough to achieve this. (During the four winter months of November, December, January, and February there are more deaths than when compared to the other eight months in the year. However since 2005 the Chestfield and Swalecliffe ward has experienced significantly worse numbers than the national average – becoming the 3rd highest in England. The ward statistics have been broken down into ‘super lower output areas’ and this shows that the ‘problem’ areas are only in Chestfield. Causes of mortality are the same as the England average – the top three killers being heart disease, cancers, lung disease.) The proposed new school Chestfield Parish Council is aware that Swalecliffe primary school is at full capacity already, and therefore the need for a new school is accepted. Two forms would be 60 children per year. The school does intensify the traffic to and from the scheme. School run traffic and parking has not been adequately thought out. Not only children from this development would attend this school. The drop off area and parking provision for the school is not enough. There is major concern from Maydowns Road residents that school run parking may overflow in to the top of Maydowns Road, with the proposed footpath linkage from the top there in to the development site. Preschool capacity - Additionally, Chestfield Parish Council would point out the known lack of preschool capacity in the local area. This development would only exacerbate that. Allotments The developer must provide a water supply and an adequate number of taps to serve the allotments. Consideration for the disposal of any rubbish arising is also needed. Future maintenance of open spaces, verges, roads, allotments, sports pitches, PROWs and community hub Chestfield Parish Council need assurances that these have been given enough thought and that there is one or more bodies willing to take over their future maintenance and management and upkeep. The parish council is supportive of a community hub. This could if designed well, accommodate a hall, lettable rooms, and a separate self-contained pre-school as the other half of the building – this would bring in income and still allow a dual-use of the premises at weekends and evenings. Chestfield Parish Council sought clarification from Eton College for some aspects of the application, and found the representatives willing to enter into dialogue. Chestfield Parish Council would like to have first refusal to be the body to take over the running and future management of the Community Hub facility, and perhaps some of the other elements of the scheme such as the incubator offices, if a suitable agreement can be reached to do so. Perhaps also there is a need for the creation of a residents association and committee and an annual financial levy applied and collected. In the feedback from the May 2014 exhibitions (Application Appendix 1) under planning concerns, is that the remaining open space within the application boundary should be protected from development for a minimum of 30-50 years. Alongside this it states “the applicant is willing to provide a planning obligation securing the long term protection from development of the open space”. Chestfield Parish Council would like to see this obligation implemented. Public right of way CW68 CW68 is within the site and runs along the back of Maydowns Road (odd numbers). KCC PROW department has asked that this be upgraded to Public Bridleway to facilitate walking and cycling and all pedestrian/cycle paths to be a minimum 3m width. The current design places the existing public footpath CW68 within an enclosed environment which is contrary to both police advice and Kent design standards. This can lead to reduced use due to personal security and fear of crime issues. The developer should look towards a design that reduces the length of ‘enclosure’ to improve the overlooking required by design standards. The parish council would also like to see the section of CW68 that runs along the back of Maydowns Road (odd numbers) to be strengthened and reinforced with mature trees and planting to retain the residents’ sense of security given by the overgrowth currently. The cycling infrastructure and links to the existing system The section of path from The Long Reach to Tesco beside the Old Thanet Way has been used as cycle path for many years. It is designated as shared use and although not wide enough and not signposted very well it does serve its purpose. However for the entire length of the Old Thanet Way path, despite the shared use parts at each end, the section between Chestfield and Greenhill is appalling. It's effectively derelict, with very little maintenance since the 1980s. It seems the perfect place for a proper wide shared use path. There have been plans to do exactly this. Spokes have a summary here: http://www.spokeseastkent.org.uk/future-routes/Old-Thanet-Way/index. If the development is to be built, the parish council would urge Canterbury City Council to ask the developers to pay/contribute for the upgrade/installation of a proper shared use path along the Old Thanet Way between Chestfield and Greenhill that links into the development. Clearly this would encourage some of the new residents to cycle/walk but also be of benefit to existing residents. Regard for the known existing problem of nuisance scramble/motorbikes in the immediate local area must also be considered and suitable gates/stiles to prevent them access must be provided - particularly where CH8 meets Molehill Road. This area should also be designed with gates to prevent flytipping on and at entrance to the proposed bridleway'. Great crested newts Eton College commissioned a study in March (when the newts go into water to breed). A variety of techniques were used over four days in two of the ponds on site but no newts were found. Despite this Chestfield Parish Council would point out that there is a third pond on the site – at the west end which needs surveying. Additionally, it is a requirement to survey any water/neighbouring ponds within a 500m radius of the site – this will include several ponds in Maydowns Road residents’ gardens. (A previous application CA/10/01644/FUL for five new houses at Chestfield Farm had to do this.) Logistics and security A key element that appears to have been overlooked is practical logistical planning and security during the project build. There is no mention in the document of how materials will be delivered into site, either in terms of delivery routes, or proposed storage methodology. And no mention of security arrangements, namely how the site will be policed, or for what periods. With regards to logistical movement of materials into site, we have concerns about heavy goods deliveries utilising Chestfield Road to access the site. We would oppose this on both road safety and environmental grounds, and insist that all deliveries into site are via an approved route, and with good appropriate signage to ensure this. We would suggest utilising the Chestfield by-pass, thus meaning that site traffic would approach the site from the eastern direction of the A299 Thanet Way from Herne Bay. There would be less overall traffic nuisance by employing this route as this is does not impinge on residential areas, and also serves to avoid known traffic congestion areas approaching from the western side of the A299 Thanet Way. (We have provided a sketch CT01; rev 01 direct to the case planning officer). There is no specific mention of designated delivery times or controlled logistics processes. Although ‘Just in Time’ deliveries are widely recognised as the preferred methodology of material delivery on most new construction projects, we would not want to see deliveries at times likely to affect those residents in close proximity to the Bodkin Farm site. Should the application be successful, we would request that the parish council is consulted so as to agree suitable and acceptable times of delivery. It is assumed that there will be a designated materials lay-down area within the site during construction. This in itself presents a potential security risk, not only to the site but also to the village in general, in particular adjoining areas such as Maydowns Road. We would therefore ask as to how the applicant intends to police the site, particularly outside of normal working hours and at night. Will the applicant be employing the services of a permanent 24/7 security presence, or be reliant solely on ad-hoc security patrols? We do not feel that the latter option would serve to placate those residents whose houses are nearest to the proposed development. Current Kent Police statistics show that there is minimal crime within Chestfield – we therefore feel that the absence of permanent security presence during the project build would surely exacerbate this situation. We are also concerned as to the actual working times during the construction works. We would therefore expect to see a structured day- working pattern, which should be precise in their timings – timings which the parish council would wish to be consulted upon, and would like to be made a condition should the application be granted. Overall, we do not feel that the applicant has duly considered the logistical planning of the project in its application, nor indeed the effect that such a severe oversight would have on the residents of Chestfield. Conclusion Chestfield Parish Council do not believe that the applicant has demonstrated why this site should come forward for development above those allocated in the draft Local Plan. Paragraph 5.2.6 states the Canterbury District Local Plan has anticipated adoption in Spring 2015, and paragraph 5.2.7. states the more advanced the preparation, the greater the weight that may be given to it. Previous applications to develop this site have been refused, primarily on the loss of agricultural land; the classification of the land as Green Gap, and on the grounds of increased traffic. Chestfield Parish Council trusts that these material considerations, along with the other major concerns listed above, not least of which is the need for the developer to have written confirmation from Southern Water around a suitable connection and capacity measures, prior to any application getting permission, will ensure this application is also now refused. Chestfield Parish Council is wholly opposed to this development and would like to send a speaker to the development management meeting when this application is heard. Best wishes Amanda Sparkes Clerk to the Council Cont/… Summary Amendments the parish council is seeking, should officers and Members be minded to grant the application: 1. Foul water drainage – assurances that this can be accommodated and without affecting existing residents must be established prior to any decision to grant. 2. Traffic calming measures – To build in to the S106 agreement for the developer to - bring about an immediate reduction in the speed limit as proposed to 40mph; - provide traffic light control for the Old Thanet way with Chestfield Road roundabout, and - provide a new controlled pedestrian crossing near Maydowns Road. 3. Impact on SSSI site at Swalecliffe – that an appropriate developer contribution is sought. 4. Affordable housing - That for the 90 affordable homes, that a greater proportion (more than 30%) of these be for shared ownership - A self-build scheme to be offered within the development. - A local connection criteria for prospective tenants of the social rented housing be included in the S106 agreement (after discussion and agreement of this criteria between the city council, parish council, developer and social registered landlord is reached) 5. Primary school – that a review of the drop off area and parking provision is done. 6. Pre-school capacity – that provision for the local area or suitable contribution is sought. 7. Community centre/hub - Chestfield Parish Council would like to have first refusal to be the body to take over the running and future management of the Community Hub facility, and perhaps some of the other elements of the scheme such as the incubator offices, if a suitable agreement can be reached to do so. 8. Allotments – provision of a water supply and suitable future maintenance and management provision put in place 9. Future maintenance of open spaces, verges, footpaths etc – that concern over the future upkeep is satisfied 10. Public Right of Way CW68 – to change the proposed design/layout on order to comply with police advice and Kent design standards. 11. Cycle infrastructure – Secure the provision by the developer of a shared use path between Chestfield and Greenhill. Ensure suitable accesses preclude the entry by motorbikes. 12. Great Crested Newts – that further studies in all locations within 500m radius of the site be undertaken and the findings dealt with as appropriate. 13. Logistics – ensure that heavy goods deliveries are via an approved route and avoid Chestfield Road, and with good appropriate signage to ensure this. And that consultation with the parish council be undertaken to agree designated delivery times to protect those residents in close proximity to the site. We would also seek a on how the applicant intends to police the site, particularly outside of normal working hours and at night. 14. Working times – impose a condition of allowable actual working times during the construction works, with precise days and timings – timings which the parish council would wish to be consulted upon, and would like to be made a condition should the application be granted.