BGPC DRAFT IQW SUBMISSION

TM/11/01191 Crest Nicholson 177 Houses

Isles Quarry West, Borough Green.

Borough Green Parish Council has serious reservations about the viability of this site for housing, and believes that part of the Local Development Framework is based on invalid evidence and was not sound.

However, it is important that we accept the development could go ahead, and make positive suggestions towards mitigating the impact on our community, and suggestions that could afford some benefit.

We believe that Crest Nicholson and T&MBC must do more than pay lip-service to the legitimate concerns of the Parish Council and the residents it represents.

1. Domestic Traffic, Noise and Visual Impact on Quarry Hill Area.

Both the invalid 2005 Borough Green Parish Plan, the current 2011 Parish Plan, and T&M's own Character Area Appraisal, highlight Quarry Hill as an area of historic significance. The Character Area Appraisal refers back to the MDE-DPD and Core Strategy CP24, and Policy SQ1 and I quote the extract in full below, because it is extremely relevant to this application.

3.3 Managing Development and the Environment DPD - April 2010

The DPD states that the diverse character of Borough Green should be protected and enhanced for its own sake as it is important for the social, economic and environmental wellbeing of the Borough.

 It is important that the unique characteristics of the area are identified and protected and where practicable enhanced in line with Core Policy CP24 having regard to the Character Area Appraisals SPD in order to strengthen this diversity rather than eroding its character and local distinctiveness.

Policy SQ1 requires proposals for development to reflect the local distinctiveness, condition and sensitivity to change of the local character areas as defined in the Character Area Appraisals SPD.

All new development should protect, conserve and, where possible, enhance:

(a) the character and local distinctiveness of the area including its historical and architectural interest and the prevailing level of tranquillity;

(b) the distinctive setting of, and relationship between, the pattern of settlement, roads and the landscape, urban form and important views...

The only way that a development at IQW can be both implemented, and comply with the above, is to ensure all housing traffic is managed via the Haul Rd. This will also have the added benefit of mitigating the traffic impact on Woodlands and Valley View Estates. Part of this could be to condition traffic lights at the Quarry Hill/A25 Junction.

We draw your attention to the developer's wish to use the inevitable modern design palette of buff/red brick, with board or tiling detail, and no doubt the occasional imitation dovecote, of which we have already suffered a surfeit in the village.

Referring to (a) above , we would like to see an echo of the local vernacular utilising ragstone, ironstone, galleting, and brickwork/ragstone combinations, both on housing, and in occasional boundary walls.

Simon Wright Homes proposed a laudable "gateway" house that echoed oast houses, and we think this would enhance the development, and endow it with a distinctive character.

2 Ground Contamination

The 2007 K Haward submission to the LDF, and the 2008 ground surveys included in this application, indicate severe contamination of the site, particularly the northern part  and the adjacent High Level Platform.

Apart from contamination hazardous to human health, underground utilities, and construction workers, there is an ongoing gas hazard to the housing allocation area. This gas seepage is problem enough on its own, but it is an indicator of underground decomposition of organic waste which will eventually cause subsidence, a process currently being undergone at Stangate 1 & 2 to the south.

We believe that no construction whatsoever should be allowed on the northern end and HLP until an intensive ground survey has been carried out, the contamination remediated, and the extent of buried organic waste established.

It must not be forgotten that the bulk of this area has been a landfill site since the beginning of the last century, no-one knows what is down there.

3. Loss of Current and Future Employment opportunity.

The current application will demolish the large industrial premises currently occupied by Invicta Skips, and will remove the LDC's that could have led to commercial development and employment opportunities.

The housing planned for the High Level Platform will cause conflict between residents and the current commercial occupiers of the Hornet Estate. This will be further aggravated by traffic noise from HGVs climbing the hill to the Hornet Estate directly past these houses.

4. Stangate Landfill

The Stangate  Landfill sites have extant permissions for topping up losses due to decomposition, and finished land profiling, expected to continue for a minimum 10 years. The conditioned access to these sites, and the Generating Station at Mill Lane, are subject to planning conditions under TM/82/1138 and TM/94/597 regarding routeing, that being via the Haul Rd and the Isles Quarry West internal Haul Road. There are no viable alternatives. The current Crest plans show the housing estate being built right across the conditioned HGV access route.

This would clearly be an impossible situation, in terms of noise, dust and pollution to residents, traffic hazard to pedestrians, and traffic clash between residential traffic and HGVs.

5. Sewage Disposal.

In the early Southern Water submissions to the LDF, it is categorically stated that the existing network does not have any spare capacity for this development.

 Crest's application lists £580,000 of work to supply new and upgrade existing equipment, but we are concerned that this does not address the lack of capacity on the main line to Wrotham Heath, that runs under the A25 through Borough Green.

 This has already had a major burst that flooded the Recreation Ground, and there are ongoing problems with sewage leaking into gardens on Sevenoaks Rd when the system blocks further downstream.

We urge the developer to adopt grey water recovery systems to mitigate impact on the sewage network.

6. Infrastructure Shortages

The medical and dental services, and the schools, are already suffering from population growth. We are concerned that the Section 106 money identified in the application will be used generally by Borough and County Councils, rather than being used to target specific local needs that will be generated by the arrival of 177 new families.

We have none of the services needed by young families and social housing residents.

7. Haul Road.

We are bitterly opposed to any reduction in width on the Haul Road. This road is conditioned as the HGV access to the Hornet Estate, the Stangate landfills, and the housing construction traffic. 5.5 metres is simply too narrow to allow HGVs to safely pass, and would force HGV's  to mount the pavement, or to use Quarry Hill Road, which is wider and has no HGV restriction.

There is ample room to install the required footpath beside the Haul Rd without restricting the carriageway width. Centre hatching could limit traffic speeds.

A 7.5tonne limit needs to be imposed on Quarry Hill Rd prior to construction traffic being allowed to access the site.

8. The Thong Lane Bridge

This bridge should have been removed as planning condition of  the IQW/E restoration permission TM/94/155, but was never enforced.

If this bridge was deemed strong enough in 1995 for the 40tonne dumpers used for the restoration, it should still be strong enough today for pedestrian use. We also understand there are species habitat concerns that may preclude demolition.

We would like to see it restored as the only remaining piece of Industrial Heritage from the quarrying days, and maintained as a pedestrian route from the Crest Housing Estate to the public access area at Isles Quarry East.

 TM/94/155 also conditioned public access to IQE.

Conclusions

The simplest way to mitigate the problems above is to move the entire estate to the west by a few metres, and to reassign the northern, HLP and Invicta sections of housing to the western side of the development.

 This would eliminate the risks of building houses on severely contaminated land, and release the northern area and High Level Platform for employment use.

 It would also eliminate the traffic clash between industrial and residential traffic, and would make noise mitigation on the Hornet boundary achievable, benefitting the residential area below.

The only access to the housing estate should be via the new Haul Rd access, with the entrance biased to the west, away from Quarry Hill, which would greatly reduce the residential traffic impact on Quarry Hill and its estates.

We also suggest improving pedestrian access to the village by installing a new fenced footpath between the Haul Rd entrance to join the Ightham footpath at Bell Lane.

Borough Green was chosen by T&M as a "Rural Service Centre". To achieve that role we need to be able to offer good services to old and new residents. These services are largely situated in Tonbridge, which makes them virtually inaccessible to Borough Green residents without their own transport. We therefore suggest that the Hanson Office is donated to the Borough Council to house seconded T&M/KCC staff from Social Services, Housing Dept, KCA, Connexions, and perhaps even the Jobcentre. This would allow retention of the current recycling area.

The Invicta Skips site should be saved, another source of employment.

The LDF has already cost us a significant amount of greenbelt, and more encroachment is proposed for the new access road. The loss of a few more metres as suggested above could significantly reduce the development's impact on Borough Green, and that reduction could be justified as an Exceptional Circumstance for Greenbelt Development should the application be called in.

We would also like the new (reduced) amenity area planned for the west of the site, and Isles Quarry East, to be transferred to the Parish Council with a maintenance grant, and for a significant proportion of the Section 106 grants to be assigned directly to Parish Council projects in Borough Green such as Potters Mede, as suggested by our T&M Members.