Outline Application for the erection of 8 houses with access to be considered at this stage and all other matters reserved for future consideration.
In conjunction with the production of our Neighbourhood Plan, our consultant carried out a Baseline Landscape Assessment. This study made us aware of the much wider ecological importance of this land so that we are now in the position that we have to object to the proposed development.
- Local importance
1.1.The development area is of great importance for Lenham as it is adjacent to Glebe Pond and the ‘Upper Stour’, which is of very high amenity value for both visitors to and the people of Lenham.
This is highlighted by our previous support for development of this land, whereby we sought to safeguard the pond and the land to the north of the pond for the amenity of the village.
Since the 1970s the village has carried out maintenance on the area to the north of the pond in agreement with the then landowner. In the early 1970s Lenham Parish Council also received permission to carry out maintenance work in the pond. Unfortunately, after a failed planning application, the then landowner withdrew this permission and, since that time, no maintenance work has taken place, leading to the pond being overshadowed by trees. This has lead to a reduction in ground flora and invertebrates. Bats, however, love this environment and locals have spotted much wildlife.
We want to draw your attention to § 110 NPPF:
‘Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this Framework.’
- Groundwater Flooding
2.1.The land proposed for development is wetland created by groundwater flooding. The development to the west of this site, Glebe Gardens, lies higher than this site. When evaluating this site, groundwater flooding is recognised as an issue in SHLAA 2016. It is very difficult to mitigate against groundwater flooding, especially in areas where the flooding is due to the location of aquifers, as it is in this case.
The Environment Agency explains: ‘Flooding from groundwater is most common in areas where the underlying bedrock is chalk… https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/297421/flho0911bugi-e-e.pdf
2.2 The very wet winter of 2014/15 was, in our opinion and that of many meteorologists, a precursor of things to come due to climate change. Water was running in streams off the fields around Lenham. This is partially due to the soil compaction due to modern farming methods but also to the fact that the soils in the foreground of the North Downs were saturated with water. More information on this topic can be fond in our ‘Baseline Capacity Study’, which is available on the Internet.
Lenham Parish Council considers it as its duty to point out this risk, which so far has not been properly evaluated.
Building on this site contravenes § 99 of NPPF ‘Local Plan should take account of climate change over the long term, including factors such as flood risk….
2.3. SUDS militate only against flooding from surface water. In the case of groundwater flooding the consequences are different: ‘Water may rise up through floors rather than coming in through doors. (See EA: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/297421/flho0911bugi-e-e.pdf)
- Wider importance
2.1.The wetland is associated with the location of two springs of the Stour, which feed, into Glebe pond. The pond and its associated wetland are the visible landmark for the Kentish watershed, which runs through Lenham. To the west of the village is the source of the Len (Thames River Basin); to the east there is Glebe Pond, the first source of the Stour, which flows towards the South East River Basin.
Visible modern housing development, directly behind the pond when viewed form Old Ashford Road, would detract from this landmark.
2.2. Wetland is an important part of a river ecosystem. It retains water and delivers it over a long period into a river system, thus helping to maintain water levels and chemical balance in the river.
This service function of wetland will be lost and cannot be mitigated. Retaining some land to the east of the development site cannot mitigate for the loss of land in volume.
Building on the land contravenes § 109. NPPF, as it does not ‘recognise the wider benefits of the ecosystem services.’
We are especially concerned in this case for the future of this blue infrastructure, as the ‘Upper Stour’ is not even mapped on MBC’s plans!
2.3. Wetlands are an important and threatened wildlife habitat. NPPF §109 recognises this:
‘‘The planning system should contribute to and enhance the natural and local environment by. ……minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures’.’
Securing a small parcel of land to the east as wetland might, in the short term deliver this, but in the long-term this small area won’t be able to stand up to future pressure as a result of climate change and cumulative impact of development. The approved conversion of the old farm buildings on the neighbouring Tanyard Farm and the construction of three new dwellings on this site will displace wildlife recorded from this area: bats, slow worms and grass snakes.
If this planning application is approved ,a wildlife corridor between Glebe Pond, two smaller ponds to the south and the water meadow to the south would be largely eliminated.
- Impact on the Upper Stour
Surface water run-off from the new development would be directed via a storage tank and ‘filter’ into the Upper Stour. The EA describes the Stour at this point as in ecologically ‘bad condition’, which won’t be helped by the influx of surface run-off, not to mention any pollution incidents which could occur (such as cars losing petrol or oil).
- Local distinctiveness
Looking at the plans it cannot be said that the development would make a ‘positive contribution to local character and distinctiveness as required by NPPF §126. Glebe Pond, the grade 2 listed Tanyard Farm building, the mill on Tanyard Farm, the traditionally managed and grazed water meadow to the south of the site, and the grade 1 listed Tithe Barn to the south west form a historic environment outside of Lenham’s conservation area. This historic environment is very much part of Lenham’s collective memory.
One member of the public put it bluntly during public participation at our planning meeting: “Putting these houses into this location is like putting a modern building into Constable’ s Hay Wain”.
Although Constable did not visit Lenham, we would ask you to recognize the intrinsic value of this land and to refuse this application