Submission to Ashford Borough Council from Boughton Aluph & Eastwell Parish Council
17/00005/EIA/AS: Environmental Impact Assessment Screening Opinion for a Residential Development on Land at Lenacre Hall Farm, Sandyhurst Lane, Boughton Aluph
While not a formal consultee on this application, the Parish Council recently assessed the Lenacre Hall Farm site for land allocation in our emerging Neighbourhood Plan. As such, we want to put forward a case that the site is a valued local landscape and should be considered an environmentally sensitive area. This was a contributing factor in the Parish Council’s decision not to allocate the site for housing development in our Neighbourhood Plan.
We understand that an EIA Screening Opinion must be based on narrow criteria set out in the Town and Country Planning (Environmental Impact Assessment) Regulations 2011. We have not yet taken up the specialist advice which will be available to Ashford Borough Council and the other consultee agencies. However, we can provide important local knowledge and perspective which we hope you will be able to take into account in reaching a decision.
Our focus is on the contribution landscape character has on sense of place and quality of life for parish residents and their sense of well-being. Based on the information provided in ECE Planning’s submission of 6 July 2017, this development will result in the rural setting of sections of Sandyhurst Lane and Lenacre Street being lost. Development on the site would breach a longstanding urban/rural boundary at Sandyhurst Lane setting a precedent for further development. Existing rural local views will be changed or lost.
The magnitude of the development must be considered significant in a parish of which c.90% of the land area is rural. The proposed density of the housing on the Lenacre Hall Farm site contrasts markedly with adjacent dwellings on Sandyhurst Lane and Lenacre Street. The average housing density in the parish is 2.51 per hectare. The developer of Lenacre Hall Farm proposes 99 houses on 4 hectares (within a 12 hectare site) with an associated increase in air, light and noise pollution. This development will increase the total parish population by 10% putting c.200 extra cars on local roads. This comes on top of development planned at Eureka Park of 375 new residential dwellings.
The development does not fit the strategic vision set out in Ashford Borough Council’s draft Local Plan 2030 that “new development should be of a scale appropriate to the individual characteristics of the settlement.” Or the aim to conserve and enhance “the identity and attractive character of the Borough’s rural area” in recognition that “the attractiveness of the Borough’s countryside is an important aspect of the economic potential of the Borough, especially of the rural economy, and a significant income generator.”
We believe that the highest level of impact assessment is required before development is considered on this greenfield site. While popular opinion may not be a factor in the Screening Opinion, it should be noted that 75% of respondents to a parish household survey conducted in 2016 were against the development on the Lenacre Hall Farm site.
Our observations below are restricted to environmental considerations.
Landscape Assessment – Adopted Policy
The Lenacre Hall Farm site is located within The Stour Gap Landscape Character Area of Ashford Borough Council’s Landscape Character Supplementary Planning Document (April 2011).
Ashford Borough Council’s adopted policy for landscape assessment (Studio Engleback 2005) classifies the Lenacre Hall Farm site as “Conserve and Create”, specifically to plant more woodland and re-instate hedges. Studio Engleback described the site as having a “unique and separate character”.
Proximity to AONB
The eastern edge of the site is within 100m of the boundary of the protected North Downs Area of Outstanding Natural Beauty (AONB). Running between the site and AONB are mature gardens of a row of properties in Lenacre Street, a rural road with woodland on the opposite side.
Ashford Borough Council has a statutory duty to protect the character of the AONB. This duty extends to development located outside an AONB but which would have a significant adverse effect on the setting of the AONB.
Proximity of Ancient Woodland, Local Wildlife Sites and Historic Parkland
The wooded south west parcel of Lenacre Hall Farm is Ancient Woodland and is on the Priority Habitat Inventory for deciduous woodland. The site adjoins Tile Lodge Wood, designated as a Local Wildlife Site. To the north, the site abuts the open countryside of Eastwell Park. Although Eastwell Park is no longer formally registered as historic parkland, it is a site of interest and identified on the Historic Environment Record. To the west the site joins the fields used by Sandyhurst Lane Sports and Social Club.
Agricultural Land Classification
As greenfield agricultural land the soil classification is a material consideration. The site has potential value as productive and versatile agricultural land. Although currently used for grazing of sheep, it comprises roughly 50% Grade 2 and 50% Grade 3 soils and is suitable for other types of farming as has been the case in the past. It was formerly part of the historic Eastwell Estate.
There has been a longstanding issue with flooding from the site onto Sandyhurst Lane. Development of the site may exacerbate this problem. Even if the hard landscape surfaces were all permeable, the rain run-off from roofs would add a significant loading to any sustainable drainage system. Flash flooding from thunderstorms will tend to run-off rather than percolate though permeable driveways. There is already a tendency during the winter for Sandyhurst Lane to carry excess surface water. Extra run off (especially as the climate continues to change) would exacerbate this and could create a highway safety issue.
There is no sewerage on the site.
In addition to grassed agricultural land and an area of Ancient Woodland, Lenacre Hall Farm contains mature hedgerows and tree boundaries both within the site and along the roadside. There is a spring, 3 ponds and associated drains.
Ashford Borough Council’s Blue and Green Grid Strategy Policy aims to enhance biodiversity by linking, extending and creating Biodiversity Action Plan (BAP) habitats. Policy ENV1 – Biodiversity in the draft Local Plan 2030 states that proposals should safeguard features of nature conservation interest and should include measures to retain, protect and enhance habitats, including BAP (Priority) habitats, and networks of ecological interest, including ancient woodland, water features, ditches, dykes and hedgerows, as corridors and stepping stones for wildlife. Tower Wood behind the Lenacre Hall Site is a BAP site as well as the Ancient Woodland within Lenacre Hall Farm and Tile Lodge Wood behind Sandyacres. So maintaining key corridors via hedgerows, ditches and the mature gardens of Lenacre Street which abut the farmland is key, for example influencing bat foraging and commuting routes between woodlands. Building 99 houses on the site would inevitably affect this. The current proposal for the site does not appear to link to Tower Wood.
The hedgerows on the site are mature, over 30 years old and 20 metres or longer with 5 or more plant species and therefore, we believe, of high ecological value and protected by legislation. Under the Wildlife and Countryside Act there should be a survey of Schedule 1 nesting sites in hedgerow and on the mature trees (not just ground nesting birds). Residents report that there are a number of Schedule 1 birds that breed or feed on the site. Other species such as protected invertebrates or key BAP species like hedgehogs, frogs and toads have been reported in gardens abutting Lenacre Hall Farm. There are Barn Owls resident in Tower Wood. Development would affect their foraging grounds. There are Badger setts in Tile Lodge Wood. There needs to be an analysis of their foraging habits.
While the eDNA results indicate the “likely absence” of Great Crested Newts from the water bodies on the site this does not consider migration routes between garden ponds and farm ponds. There are a number of ponds in the mature gardens abutting Lenacre Hall Farm where newts have been reported. These would need to be surveyed for Great Crested Newts.
It is stated that the vegetation is below 15cm and therefore not a viable migration route. However, it has been the practice that the fields only gets cut once a year or never relying on grazing, so it is highly suitable vegetation for migration. The landowner receives an agro-environment grant for farming environmentally.
Under Ashford Borough Council’s Dark Skies Policy, our view is this would be a light sensitive site affecting the diurnal rhythms of a wide range of plants and animals, including bats foraging and commuting routes. It is difficult to see how the building of 99 new dwellings, especially 3 storey houses would not impact on this by affecting hedgerow navigation for example. Also the high number of new houses is likely to increase light emissions. This light would almost certainly impact on the adjacent AONB habitats.
Changes in Specific Views
The site rises from Sandyacres to the ridge at Lenacre Street and is likely to be highly visible from both the low lying Sandyhurst Lane, Sandyacres and to be visible from and other parts of Ashford looking north. It will completely change the views of the residents of Lenacre Street which will look down on the site changing their living environment from rural to urban.
The development will spoil the footpath views towards Ashford. This is a widely used path. It will also significantly change views to and from Sandyacres and its playing fields.
A Grade II listed building Lenacre Hall is located outside of and to the south east of the application site along Sandyhurst Lane. There are additional listed buildings in the near vicinity including Eastwell Towers and adjacent flint wall.
Boughton Aluph & Eastwell Parish Council
26 July 2017