Gypsy, Traveller and Travelling Showpeople Development Plan Document

Disagree

POLICY C4S (008) – The Lodge, Water Lane, Thurnham The Bearsted and Thurnham Society is aware that this site does not comply with policy, is therefore undeliverable and objects to its inclusion in the DPD on the grounds of highway safety and access. 1. Proposed Policy on Highway Safety and Access a. Policy TR8: General site design and layout - Access, Parking and Storage states at point “o” that there is a requirement to “Provide safe vehicle and pedestrian access to and from the site to the public highway.” (Emphasis added) b. Policy TR8: General site design and layout - Access, Parking and Storage states at point “142” that “Highway layout should be designed with consideration of the movement of touring caravans or the delivery of static caravans in mind. Sufficient space and turning/manoeuvring area should be created to allow residents to easily take caravans on and off their pitches. Highways should be wide enough that a large static caravan can be delivered by a large goods vehicle to all pitches.” (Emphasis added) 2. Highway Safety a. Running north from Roundwell, Bearsted, to the Pilgrims Way in Thurnham Water Lane is the second narrowest lane within the two parishes and in places the carriageway is only some 3.6 metres wide. i. The images in Appendix I of this document give a clear indication of the carriageway width. ii. Images 1 to 5 show Water Lane southbound between the proposed site and Roundwell.  The green vehicle in these images is a Volkswagen Caddy which has a body width of 1.85 metres. iii. Image 6 shows the junction between Water Lane and Pilgrims Way.  The vehicle in this image is a JCB Pothole Pro which is 2.5 metres wide. b. An application was submitted by the owners of The Lodge in 2024 (24/500444/TPOA ) to remove three protected oak trees to the north of the metalled access serving Bridge Farm and The Lodge on the grounds that they obscured the view when accessing Water Lane. i. There was one comment supporting the application and which contained the following- “I have been using the drive to access The Lodge regularly over the last 3 years. As a car driver it is particularly dangerous when exiting the drive as your vision to the right is severely impaired by the vegetation and trees.” ii. On the application form it was stated that- “The three trees obstruct the view from the driveway of Bridge Farm onto Water lane when pulling out into the road and make it extremely dangerous especially as the road has a 60mph limit. We have had several occasions of near misses.” iii. The application was refused and it is noted that only tree T3 is on land owned by the proposer of the site. iv. The three English Oak trees designated as T1, T2 and T3 are within tree preservation order TPO No. 14 of 2007. c. The site plan shown for Policy C4S (008), The Lodge, mirrors the HM Land Registry Title Plan for The Lodge (K564029). i. The Title Plan shows that the access onto Water Lane is adjacent to the protected Oak T3. ii. The available evidence indicates that this access was in use in 1990 but by 2003 was unavailable until at least 2022 as land to the east was covered in trees and shrubs. iii. This area had been cleared by June 2024 and therefore presumably the intended access for the proposal. iv. This is further evidenced by two applications submitted in 2025 to trim branches to T3 (25/500122/TPOA and 25/501294/TPOA) where it was stated that- “There is a large branch that over hangs the double gated entrance into K564029 from Water Lane and it restricts agricultural vehicles from entering without risk of damage to the tree or vehicles. There is also a long branch that enters the land which also restricts work in the corner.” And- “Further to our recent application that has been granted on T3 in K564029, we have realised that there is another branch protruding across the double gated entrance which will also restrict agricultural vehicles from entering without risk of damage to the tree or vehicles.”  The Case Officer noted that the Oak tree is a prominent feature and is one of 3 TPO Oak trees in a line along Water Lane and that its contribution to public amenity was good as it was clearly visible to the public.  This would clearly also apply to trees T2 and T1, located just to the north of tree T3. v. The site was originally put forward for consideration during the 2022 Call for Sites exercise where it was stated that- “Access is from Water Lane with a, titled right of way through Bridge Farm and formerly part of the same holding.” And- “A secondary route for access within The Lodge title is available to the north and to Water Lane.”  Although potentially a civil matter the Bridge Farm trackway to the south only allows access to The Lodge and not to any additional development to the east.  It sits some 13 metres from the dwelling at Bridge Farm and bisects the residential garden area.  As it cannot be screened in any way its use by an unknown number of vehicles and pedestrians would have an intolerable impact on the residential amenity of the property and would be unacceptable in planning terms. vi. The “secondary route for access” referred to above is some 11 metres further to the north of the Bridge Farm trackway and therefore closer to the protected trees and the ancient hedgerow fronting Water Lane.  As the applicant has acknowledged that the Bridge Farm access is dangerous then, by definition, this northern access is substantially more dangerous.  Water Lane is subject to the national speed limit of 60mph.  At a point 2.4 metres back from the edge of the highway clear sight lines of at least 215 metres are required in both directions.  These sight lines cannot be achieved.  The fact that the access was used occasionally some 30 years ago is not relevant with respect to this proposal. d. With regard to pedestrian safety there are no footpaths on either side of Water Lane over its entire 450 metre length between the site access and its junction with Roundwell. 3. Access a. Point 142 of Policy TR8 clearly states that “Highways should be wide enough that a large static caravan can be delivered by a large goods vehicle” (Emphasis added) b. When being transported static caravans require a minimum of 300mm clearance on either side when the carrier vehicle in on a straight road. c. Dimensions of static caravans are listed below, with their required clearance widths shown in red. i. Small static caravans typically measure between 8.5m to 9.8m long and 3m (3.6m) to 3.7m (4.3m) wide. ii. Medium static caravans typically measure between 10.7m to 11.6m long and 3.7m (4.3m) wide. iii. Large static caravans, as specified in the policy, start at 12.2m long and 4m (4.6m) wide. iv. The articulated lorries required to transport static caravans will normally be running between 4.4m to 4.7m high with an overall length of between 13m and 16.7m. v. Even the smallest static caravan is some 25% wider than a standard refuse freighter and this does not include the clearances required during transportation. vi. The images in Appendix I clearly indicate that Water Lane, with its narrow carriageway and overhanging trees, is not capable of taking the traffic required to deliver or remove the static units. 4. Conclusions a. This proposed site is unsuitable for the following reasonsi. Highway safety ii. Pedestrian safety iii. Access b. It should be removed from the draft DPD.