Kent Wool Growers Application 14/00910/AS POINTS you might like to consider THE BUILDING HAS MOVED Site Address is wrong - it relates to the original siting. Why is this important? Well, it’s kind of complicated, so bear with us. In December 2012 the developer put in a planning application (12/00020/EIA/AS) basically asking for a decision on whether an Environmental Impact Assessment (EIA) would be required for the proposed site. ORIGINAL SITE was north west of Highfield Lane and involved just the extension of Church Road. ABC’s decision was that an EIA would not be necessary. The Design and Access Statement (Page 16) states that it was not possible to place the KWG building at the original location because of the gas main. So the developer has moved the building to a site south east of the proposed realigned Highfield Lane: So what are the issues? This new location has had no decision regarding an Environmental Impact Assessment (EIA) as case 12/00020/EIA/AS applies only to the original location. The developer is trying to assert that the decision for the previous site can be transferred to this site (Planning Statement Appendix 2), but the new site is totally different, having mature hedgerows and trees with nesting birds and other animals living in them. THE POINT This new site therefore should have its own EIA. (as Natural England state in their comments of Sept 22) ROADS Under this application developer is proposing more changes to roads than simply improving and extending Church Road into KWG the site; the plans also show realignment and extension of Highfield Lane, beyond the gates to the KWG building. The realignment of Highfield Lane will destroy wildlife habitat. Roads extend beyond proposed KWG site - why? Does this mean that the developer has had tacit approval for the whole site? The POINT when does a developer decide local road policy? RETAIL USE Section 6.155 of DPD Policy U19 states “Retail uses will not normally be acceptable here unless they are only subsidiary to a B-class use or other sui-generis employment generating use”. KWG will effectively be running two businesses from these premises: 1. Its wool processing factory. 2. Its retail warehouse shop. KWG’s retail outlet is therefore not subsidiary to its wool processing business but a separate going concern; If it were to be housed in a separate building it would be considered 100% retail. This is evidenced by the 85 car parking spaces plus extra parking space to the rear of the building (workforce is stated at 39) meaning that they expect significant retail trade. Also note that TVA performed a traffic count at KWG site in Tannery Lane (Thu 7 Feb 2013 between 8 am and 5 pm). The results show that retail use is significant: • 2 way delivery vehicle count 44 vehicles • 2 way cars/4x4s (retail use) 420 vehicles The retail counter is open to the public so retail trade could increase at the new location. The POINT retail use must only be ancillary, this is not, thus it cannot be located here. BUILDINGS • Footprint : 5,239 sq m according to Design and Access Statement. • Height : 10m or 12m (depending where you look in the application) Section 6.166 of DPD Policy U19 states “The location of this site adjacent to attractive open countryside at a key entrance to the town means that it is essential that development here is built to a high quality design and layout. Innovative designs will be encouraged and approaches which seek to soften the impact of large bulky buildings will be supported.” THE POINT The proposed building is hardly “innovative” - it is a standard metal box. It is not properly landscaped. Ref developer’s Design and Access Statement (Page 35) - the drawing indicates wall (6) and roof (1) to be different shades of grey, but the key shows them to be the same colour (RGB 155, 152, 140). However, the text talks of greens and browns. Which is it? This is a Detailed Planning application - we would expect this to be properly defined. THE POINT even the detail of the innovative stripes is wrong - go back and try again Utility Network 2011 This document contains two drawings relating to buildings on both sides of Highfield Lane - what have these drawings got to do with the KWG application? THE POINT This document appears to be an irrelevance and superseded so should be removed. THE POINT WHY GREENFIELD? We know why the developer and KWG are proposing to put the new KWG shed here, but is it sensible? There are plenty of brownfield and vacant sites e.g. Orbital Park (close to Market), Barrey Road etc. THE POINT This is a standalone application yet assumes the rest of U19 will be built. It should not. It should have its own landscaping not rely on other boxes next to it which cannot be occupied until 2018 at the earliest. KWG will be a singular blot on the landscape. OTHER POINTS to consider • Noise • Lighting • Pollution • Water run-off (Most of these points have been dismissed as insignificant) CONCLUSION Substandard submission with many details missing, inconsistent or glossed over (you wouldnt get away with this if you were wanting to build a house or extension well done if you read this far... please do sent an email or letter voicing your views
Posted on: Thu, 16 Oct 2014 11:00:31 +0000
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