The High Weald AONB Unit

Tunbridge Wells Site Allocations Plan

Further comments and evidence relating to Matter G

11th December 2015

1. Introduction

1.1 This representation is submitted by the AONB Unit (a) in response to a request by the

Inspector to provide further evidence relating to the Historic Landscape Characterisation (HLC) for

Cranbrook, supporting the AONB Unit’s oral submission on the afternoon of 3rd December 2015, and

(b) to provide additional comments in respect of issues not dealt with due to the session being

curtailed.

1.2 The High Weald AONB Unit is funded by a partnership of 15 local authorities and Defra to

provide advice on the conservation of the High Weald AONB, an exceptionally beautiful medieval

landscape covering 1461 sq km across the counties of East and West Sussex, Kent and Surrey. The

comments below represent advice from the AONB Director within the scope of the AONB

Management Plan and are not necessarily the views of the High Weald AONB Partnership.

1.3 The AONB Management Plan is a statutory plan adopted by Tunbridge Wells Borough

Council in March 2014 as ‘their policy for the management of the area and the carrying out of their

functions in relation to it’1.

2. Summary of oral submission Matter G – 3rd December 2015

2.1 National Planning Practice Guidance makes it clear that planning should have regard to the

statutory AONB Management Plan and these should be taken into account in local plans.

2.2 The AONB Unit contends that the Site Allocations DPD (SA DPD) in relation to Cranbrook

draft allocation site AL/ CR4 (land adjacent to the Crane Valley/ Brick Kiln Farm) is not consistent

with national policy because ‘great weight’ has not been given to conserving AONB landscape and

scenic beauty as required by NPPF Para 115. Evidence from the Historic Landscape Characterisation

of Cranbrook is submitted (Para 3 below) to show that the site is likely to contain medieval field

systems with substantially intact field boundaries. These are identified in the AONB Management

Plan as fundamental components of natural beauty yet their significance has not been properly

identified or addressed in the supporting evidence, Sustainability Appraisal or justification for the

draft allocation AL/CR4.

2.3 In addition the NPPF Para 116 states quite clearly that major development in an AONB

should be refused unless exceptional circumstances are justified, stating that consideration should

include three assessment ‘tests’. In our view these tests have not been properly carried out for

1 Countryside and Rights of Way Act, 2000, Section 89

policy AL/CR4. Both the Council and potential developers – Persimmon Homes and Countryside

Properties - accept that this is a major development. Further evidence for treating this allocation as

major is provided in Map 2, Appendix A which shows that draft allocation AL/CR4 represents a

significant increase of up to 24% in the built area of Cranbrook.

2.4 DHA Planning on behalf of Persimmon Homes and Countryside Properties suggest, in

response to The Inspector’s Questions, that the recent appeal decision at Highgate Hill Hawkhurst

should have a bearing on draft site allocation AL/CR4. In our view these allocations are very

different. This is in part due to the size of the AL/ CR4 allocation but also as a result of the close

proximity of the AONB boundary to Cranbrook. Map 1, (Para 3,below) shows the satellite hamlet of

Wilsley Pound on the AONB boundary lying less than 1 mile from Cranbrook church, primary and

secondary schools along a main road with a pavement. It is our view, therefore, that it is reasonable

for the Council to consider the potential to meet some or all of the housing need for Cranbrook

outside of the AONB boundary as required by the second test set out in the NPPF Para 116. No

evidence is provided to demonstrate that this has been properly considered.

2.5 In our view the Sustainability Appraisal in respect of AL/CR4 is neither robust nor credible

and, therefore, policy AL/CR4 is not justified. The Cumulative Impact on the Natural/ Built

Environment for all Cranbrook polices (SA DPD Table 26, page 71) is judged as ‘uncertain’ despite the

clear dominance of ‘negatives’ against these policies. Had a double negative score been recorded we

contend that this should have led to a comprehensive review of all of the Cranbrook policies such

that alternative, and more appropriate solutions, could have been explored lessening the need for a

major housing allocation on the Crane Valley/Brick Kiln Farm site.

3. Historic Landscape Characterisation of Cranbrook

3.1 The AONB Management Plan is a statutory plan adopted by Tunbridge Wells Borough

Council. Plan policies relating to Field and Heath seek to maintain the pattern of small irregularly

shaped fields as a ‘key component of what is a rare UK survival of an essentially medieval

landscape’2.

3.2 All field systems dating from the medieval period (usually considered to end around the mid

1500’s) and earlier are therefore significant and representative of AONB character, particularly

where these are associated with other features dating from that time period including medieval

farmsteads and ancient woodland.

3.3 Medieval field systems which survive into the modern-day landscape can be provisionally

identified using Historic Landscape Characterisation (HLC), a national methodology initiated by

Historic England. A revised HLC for Cranbrook parish was undertaken by Dr Nicola Bannister in

2013/14. The report (revised August 2015) incorporating the HLC for Cranbrook and 4 other parishes

in Kent is attached.

3.4 Map 1 (below) covering the Cranbrook area is extracted from the HLC and shows Early-

medieval (AD 410 – 1065), Medieval (AD 1066 – 1499) and Early Post-medieval (AD 1500 – 1599)

fields in block colour. These fields are likely to date from at least the medieval period. Their origin

2 High Weald AONB Management Plan 2014-2019, Objective FH2, p. 42

may be much older but further research would be needed to confirm this. Hatched areas on Map 1

show where these fields retain mostly intact field boundaries (< 25% boundary loss).

Map 1: HLC Medieval Field systems: Cranbrook

3.5 A proportion of the site allocation AL/CR4 contains these fields which are some of the most

significant field systems in the High Weald due to their exceptional survival, coherence and

representativeness of AONB character.

3.6 The HLC summary statement for Turnden (incorporating draft site allocations AL/CR4) states

‘The land between Turnden and the High Street is the last remaining part of the rural historic

landscape of Cranbrook which still retains its close historic association with the medieval town

layout. The medieval and early post-medieval fields and woods nest immediately with the edge of the

historic medieval town with a clear juncture and no grading of development in between. Anything

other than small scale development on this site will compromise this local historic character and

distinctiveness’. A summary of issues for Turnden (March 2014) covering site AL/CR4 is attached.

3.7 The AONB Unit contends that the proper application of NPPF para. 115 and 116 which would

include a review the impact of the proposed allocation against the AONB Management Plan should

have identified the sensitivity of these fields and led to the site being considered inappropriate for a

major allocation.

4. Additional issues:

Suggested minor modifications to Policy AL/CR4 (incorporating AONB response to Persimmon

Homes and Countryside Properties, November 2015)

4.1 We do not support the removal of any reference to employment or economy in this policy

and propose a further modification. We ask that, should some form of development go ahead on

this site, any proposal would be expected to:

Provide opportunities for economic activity that reflect the origins of Cranbrook as a centre

for trade and craft; and support AONB designation and the land management objectives of

the AONB Management Plan;

Demonstrate the highest standards of design, maximise the use of local materials and

deliver buildings to Passivhaus (PH) standard in line with objectives G3 and S3 of the AONB

Management Plan.

Suggested modifications to Cranbrook polices taken as a whole

4.2 It is our view that local plan policies for Cranbrook, a small rural town washed over by AONB

designation, should seek to contribute, where it is reasonable to do so, to the full range of AONB

Management Plan objectives in line with National Planning Policy Guidance and NPPF Para 115.

4.3 The AONB Management Plan (AONB MP) identifies the need to reconnect settlements,

residents and their supporting economic activity with the surrounding countryside (AONB MP

objective S1); the need to secure agriculturally productive fields for local markets as part of

sustainable land management (AONB MP objective FH1) and the need to increase opportunities for

learning about and celebrating the character of the AONB (AONB MP UE1). Taking Cranbrook

policies as a whole there appears to be no evidence that positive planning in order to contribute to

these objectives has been considered.

4.4 There is some confusion about the delivery of a community facility with reference to it in

both policies AL/CR4 and AL/CR6 (Wilkes Field). The wording of the latter policy is puzzling and

ambiguous particularly, given the generally accepted definition of enabling development as follows:

“Enabling development is development that would be unacceptable in planning terms but for the

fact that it would bring public benefits sufficient to justify it being carried out, and which could not

otherwise be achieved” (Historic England ‘Enabling Development and the Conservation of Significant

Places’ 2012). We suggest opportunities to bring forward a community facility through alternative

mechanisms that might also support AONB MP Objective’s S1, FH1 and UE1 have not been explored.

We ask the Inspector to examine this clause carefully and, if the phrase ‘enabling development’ is

maintained we ask that it be used in the context of delivering demonstrable enhancement of the

AONB.

4.5 We contend that Cranbrook policies as a whole are unsound and ask that all policies for

Cranbrook be reviewed in light of the points made above in this submission. The revised policies for

Cranbrook should, in our view, taken as a whole reflect the national importance of the AONB

landscape. This in our view is entirely feasible but may require innovative and contemporary

planning solutions to deliver the necessary housing allocation while conserving the character of the

AONB. It is our understanding that the Neighbourhood Planning Committee is exploring such

solutions.

Appendix A

Map 2 – Potential increase in built area of Cranbrook