Dear Sir/Madam Ref: Planning application for change of use of land to Traveller Site with associated development. As a result of the a meeting of the Well Hill Residents Association we would like to make the following objections, and request the following considerations and clarifications and would seek the planning departments reassurance on the following:- Clarifications -------------- 1. With regard the plan submitted by the applicant we note that the scale of the caravans (16-25 ft in length) are not drawn to scale on the plan, therefore we would ask that the applicant to issue a new plan which shows the density of the proposed development more accurately than the one submitted thus far so as it can be viewed by residents. We also note that it is hard to see to scale what allocation within the site for required parking there is. 2. We note that in the applicants Supporting statement it is claimed that the existing hard standing was laid by the previous owner, the previous owner in question claims that this is not the case and was laid by applicant and that he informed the council of this, we were under the impression that the enforcement notice was still in place and is now applicable to the current owners subject to the outcome of this current fresh application. In any respect the Residents Association would object to the current state of the site as it is. 3. We note that in the applicants Supporting statement item 1.6 describes the site as a ''good 90 m west of the m25'', we calculate that the site is actually slightly less than 90 m if the measurement is taken from the nearest sited caravan to the M25. And therefore this statement is slightly misleading. 4. New developments in Well Hill have usually carried weight in favour of refusal due to the lack of public services. Enquiries by the resident association as to the improvement of public services such as the extension of a bus route have led nowhere. Given the small scale of the site and the assumption that three caravans require three vehicles to move them, plus any additional vehicles for other family members together with work related vehicles, and in consideration of the lack of public transport in the area. Is the site adequate for such provision or will additional vehicles need to be parked off site? In either case should this not be made clear in the application with regard parking facilities? Objections ---------- Firstly it should be noted that the Well Hill Residents Association is committed to supporting and promoting the designations applied to the area including and not limited to its status as an A.O.N.B, and those areas designated as Special Scientific Interest. When it comments on planning applications, for all types of planning, special care and often advice is taken with this regard. 1. Well Hill Residents Association in the past have objected to applications made without due consideration to Planning Policy Guidance note 24. (PPG 24). Certainly residents seeking developments in this proximity have had to undertake noise readings to support their applications. An application nearby carried out the requisite noise assessment and it was found that his site fell into NEC C and D, denoting permission should be refused. We note that the applicant has not undertaken any noise assessments and therefore in the interests of health of the applicants and equal treatment for all residents we must maintain an objection on this point until such noise assessments are undertaken. 2. Likewise Planning Policy Guidance note 23 (PPS23) on Planning and Pollution Control has also been a factor in other residents applications and therefore we must object until an Air Quality Assessment is undertaken in the interests of the health of the applicants and equal treatment of all residents. 3. With regard Greenbelt and A.O.N.B, The Residents Association does not accept that there are other caravans in the locality or at the very least considers this statement misleading. If there are, then they are within the existing curtilage of existing buildings. The area concerned is a greenfield site not in the existing curtilage of existing buildings and with only recent development, itself subjected to an enforcement order. Therefore irrespective of other caravans it is still to be considered inappropriate development in the Green Belt. The site is surrounded by deciduous hedgerows which in the winter months do not provide adequate concealment. The replacement of such hedgerows with conifers would be contrary to the surroundings. Also it should be pointed out that ''Openness'' is more about the lack of development than what you can actually see, therefore any development has an impact by the very fact it exists, therefore the applicants suggestion of hedges ''allowed to grow a little higher to screen views of caravans'' does not address the matter of ''openness'' indeed it is contrary to it. So therefore is conflicting with Green Belt Policy. Well Hill is also the nearest rural area to Orpington and Chelsfield conurbations and close access from the M25 and A21, and is valued by a great number of walkers, cyclists and horse riders for its views and openness. It is the ''gateway to the A.O.N.B. ''. This is the fundamental purpose of Green Belt and indeed its designation as an A.O.N.B, we feel therefore especially as this is a Green Field site its development is to the detriment not only of residents but the wider community. Especially as the site can be viewed, especially during winter when the leaves are absent from the trees, from a number of view points on higher ground and from the public footpath network. And once again this has weighed heavily on the Residents Association comments on other planning applications and therefore with regard not only to equal treatment but specifically its leisure value, we are compelled most strongly to object on these grounds also. We also give weight to the fact that the management of this land has already changed, and would prefer it to be returned to its original condition in line with the enforcement order that either is or was in place. 4. We would also draw attention to ''The Good Practice Guide, designing Gypsy and Traveller sites 2008''. The application does not make any reference to the storage of propane gas, there is no mains gas supply within approximately a mile of the site. It must be of concern to the residence association that this is a safety issue and must be addressed. Well Hill is designated a ''Dark Area'', As the site entrance is on the corner of Firmingers Lane and Rock Hill Junction, the need to have additional lighting is likely to be required given the guidelines. Also that light emitted from the Caravans themselves has to be given due considration, again given this is a Green field site outside the curtilage of existing buildings this is also detrimental to the areas designation. The guidelines also recommend that a site should have more than one entrance, this site does not comply and to comply the destruction of ancient hedgerow would be required. Also we note that a cesspit is indicated in the plan, PPG4 calculates that 3 people will produce 9000 litres of waste in a 2 week period, there are seven people indicated to live on this site, that would require a typical waste emptying tanker to attend the site every week. Possibly more often if the Cesspit is of small capacity. We suspect that the current Cesspit was installed with one Caravan in mind and not three, so clarification is also sought with this regard. This in addition to the additional traffic the site will generate, please see ''Considerations/Reassurances'' Also note that access to the site is classed ''Unsuitable for Heavy Goods Vehicles'' Further more the land on which this site occupies is designated ''Environment Agency Groundwater Protection Zone 3'' Other applications have been weighted with the following statement ''Potable supplies are therefore at risk from activities at the site and all precautions should be taken to avoid discharges to the ground during construction and subsequent operation''. Given that frequent visits will be required to the site as suggested by PPG4. And given that Well Hill in winter snow is not accessable to most vehicles, any delay in emptying there is an obvious risk of overflow and putting at risk potable water supplies. We would bring special attention that an impoertant part of the Ecology of Well Hill is its numerous natural Springs, therefore this point is especially relevant. 5. With regard to the larger part of the Well Hill Area being designated an area of Special Scientific interest the Residents Association has for many years campaigned for local residents and business to give regard to wildlife, Well Hill is one of the few places where such protected species such as Bats, Field mice, Badgers and others and a great number of bird species are still in abundance. Therefore we have asked residents to maintain and not interfere with local habitats, not only those close to dwellings but those some distance from dwellings belonging to local landowners. We have promoted schemes to enhance and maintain this diversity, such as those promotions provided by Sevenoaks Council to provide free natural and local native hedging plants and extensive planting of natural hedging has been undertaken as a result. In Well hill over a 135 meters of new natural hedgerow has been planted since 2006. Further hedging projects are potentially to be undertaken this autumn to ultimately replace field fencing. We are again concerned that this specific locality is a Green Field site some distance from any residence of any density and the development itself is very close to existing ancient hedgerow, which is contrary to the position and advice/requests given to local residents and would be detrimental to a number of species currently occupying this habitat, some of which are protected. Therefore we must also object on these grounds. Considerations/Reassurances --------------------------- 1. Residents have often raised concerns about heavy lorries and large farm equipment and although we pass regard to this matter to Kent Highways, we would like to point out that residents already have some issues with the type of traffic using these two narrow lanes, (Firmingers and Redmans Lane), given the description of the applicants business, and the fact that it is a junction, this will add to residents anxiety. 2. The access to the site is shared by a number of residences some distant up an already poor condition track way, we note that an additional track way laid directly from the entrance to Fountain Farm is subject to an enforcement order for removal. In the interests of those residents also utilising this entrance, will provision be made for them for the additional wear and tear to the entrance as a result of this application if approved, Especially as noted earlier the increase of traffic over this entrance is likely to be significant and detrimental to existing residents. Also has it been established that the Applicants have the right of way over this entrance way, we understand no searches were undertaken prior to the land being purchased and obviously neighbour disputes are something the Residents Association is keen to avoid. 3. Is it likely that restrictions will be placed upon the site as to business use, thus generating further noise, disturbance, and vehicle activity, and if so is it likely that these will be enforceable. Yours Sincerely Well Hill Residents association