Gypsy, Traveller and Travelling Showpeople Development Plan Document

Disagree

I am writing to lodge a formal representation on the emerging Gypsy, Traveller and Travelling Showpeople Development Plan Document. I am writing in a personal capacity, but as a Member of the Royal Town Planning Institute with a wealth of relevant experience in assessing sites, having regard to the development plan and other material considerations. I have over 20 years’ experience practicing in the local area, having been involved with many sites promoted through the Local Plan process in the Borough. I am writing with particular regard to the proposed allocation at The Lodge, Water Lane, Bearsted (draft Policy C4S(008)), objecting to its inclusion in the Plan for reasons detailed below. I live in the area local to this site so know it and Water Lane well, and when visiting neighbouring Bridge Farm, have been a frequent user of the adjacent access, which currently serves The Lodge. In the absence of any detail on the proposed number of pitches etc, I have more general concerns about the allocation in the context of the site’s location in the setting of the National Landscape, but wish to raise two primary issues which in their own right very clearly fail the relevant tests as defined at Paragraph 36 of the NPPF; namely highway safety and sustainability of location (itself leading to significant highway safety concerns). Highway Safety In my professional capacity, I am very aware of the relevant standards applied to any proposed access point to ensure highway safety is maintained. Water Lane is subject to the national speed limit at this location and is a narrow, unlit country lane. Visibility at the existing adjacent access is already severely limited. I am aware of the assessment carried out by the owners of neighbouring Bridge Farm, which I understand has been prepared by a qualified highways Civil Engineer. Having reviewed this assessment, it applies relevant industry standards. This has established what visibility splays are achievable at the proposed access point, namely a mere 14 metres and 29.5 metres to the north and south respectively. This level of visibility is extremely limited and it would be unheard of for this to be considered acceptable in the context of both the proposed allocation/development and the nature of the road on which it is located. Even if recorded speeds at this location are lower than the speed limit (I’m not aware of any available data on this), this level of visibility would fail to meet the required splays as set out in Manual for Streets by some distance. Put simply, if a planning application were submitted proposing this access, it would represent a clear and indisputable reason for refusal, fully supported by the NPPF (Paragraph 116) and Local Plan Review Policy LPRHOU8, which requires sites to be “safely accessed to and from the highway by all vehicles using the site on a regular basis”. The fact it can be expected that larger vehicles and those towing would also use the access only serves to strengthen these significant safety concerns. Draft Policy TR8 rightly states that all sites must “provide safe vehicle and pedestrian access to and from the site to the public highway”, yet The Lodge site is unable to satisfy this basic site requirement. It is therefore of deep concern that the LPA have taken a site forward to the Regulation 18 stage, essentially declaring it a ‘preferred’ site, without undertaking any meaningful highways assessment and without any engagement with the Local Highway Authority, as the draft Plan and evidence base confirms. To the best of my knowledge, The Lodge site has no alternative vehicular access points available to serve any additional development, with existing Tree Preservation Orders placing further constraints on the proposed access. From all the information available to me and my own direct experience, the proposed access falls significantly short of the required standards and would pose a very real highway safety threat. Accordingly, I would urge Officers to undertake a proper highways assessment of the site and consult with Kent Highways as a priority. Sustainable Location Whilst The Lodge site is geographically favourably located relative to Bearsted and the services found there, this belies the reality of the site’s accessibility. The nature of Water Lane is such that all future occupiers of the site would be wholly reliant on the private car for any journeys, the alternative being an unsafe walk along the narrow, unlit Water Lane with its national speed limit. This road is also regularly prone to flooding, which is consistent with the available Environment Agency surface water flood mapping. This is in direct conflict with the national Planning Policy for Travellers, Policy LPRHOU8, and the overarching aims of the NPPF to deliver sustainable development. There is a clear need and statutory duty for the Council to allocate and provide sufficient sites in the Borough, and for this reason the production of this DPD in itself is fully supported and will greatly assist in the proper planning for Gypsy, Traveller and Travelling Showpeople sites in a sustainable, plan-led manner. However, all allocated sites must be suitable and deliverable and no site should result in unacceptable highway safety risks. Given the clear highway safety risks identified above, I object to the draft DPD in its current form and would request that The Lodge site (draft Policy C4S(008)) is removed from the subsequent Regulation 19 draft, with alternative, safe, suitable and deliverable sites included in its place.