APPENDIX 7 - ws.tunbridgewells.gov.uk · 1.2 EDP is an independent environmental planning consultancy with offices in Cirencester, Shrewsbury, Cardiff and Cheltenham. The practice

APPENDIX 7

Land at Sandown Park, North of Pembury Road, Tunbridge Wells Landscape and Visual Appraisal

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Land at Sandown Park, North of Pembury Road, Tunbridge Wells Landscape and Visual Appraisal Prepared by: The Environmental Dimension Partnership Ltd On behalf of: Gleeson Strategic Land May 2019 Report Reference edp3824_r004b


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Contents Executive Summary Section 1 Introduction, Purpose and Methodology ...................................................................... 1 Section 2 The Site .......................................................................................................................... 5 Section 3 Findings of EDP Data Trawl .......................................................................................... 9 Section 4 Existing (Baseline) Conditions: Landscape Character ............................................. 17 Section 5 Existing (Baseline) Conditions: Visual Amenity ......................................................... 29 Section 6 The Proposed Development and Mitigation ............................................................. 35 Section 7 Predicted Landscape and Visual Effects .................................................................. 39 Section 8 Conclusions ................................................................................................................ 47 Appendices Appendix EDP 1 Illustrative Masterplan Appendix EDP 2 Site Photographs/Photoviewpoints Appendix EDP 3 Methodology: Tables Defining the Thresholds and Definitions of

Terminology used in this Appraisal Appendix EDP 4 Extract from Tunbridge Wells Landscape Character Assessment Appendix EDP 5 Extract from Landscape Sensitivity Assessment of Countryside around

Tunbridge Wells Plans Plan EDP L1 Site Location (edp3824_d010a 18 January 2019 OW/TR) Plan EDP L2 Site Character and Local Context (annotated aerial photo) (edp3824_d013a 18 January 2019 OW/TR) Plan EDP L3 Environmental Planning Context

(edp3824_d009a 18 January 2019 OW/TR)


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Plan EDP L4 Findings of EDP’s Visual Assessment (edp3824_d011a 18 January 2019 OW/TR)

This version is intended for electronic viewing only

Report Ref: edp3824_r004

Author Formatted Peer Review Proofed by/Date 004_DRAFT OW CR TR JM 121218 004a OW - TR NH 210119 004b OW NH - -


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Executive Summary S1 This Landscape and Visual Appraisal (LVA) has been prepared by the Environmental

Dimension Partnership Ltd (EDP), on behalf of Gleeson Strategic Land, to inform planning proposals for the development of approximately 75 residential units with associated landscape and public open space on Land at Sandown Park, North of Pembury Road, Tunbridge Wells. The location of the site is shown on Plan EDP L1.

S2 The site broadly comprises a square field, down to rough grassland with areas of scrub across the western third. The eastern two-thirds comprise areas of rough grassland and woodland, divided by fencing into some four compartments. There is a strong tree corridor along Pembury Road (A246) which runs along the southern site boundary.

S3 The proposed development includes additional elements of landscape mitigation,

including: the retention and buffering of boundary vegetation; planting of a significant number of new trees throughout the scheme; and the provision of areas of public open space for recreational amenity and biodiversity enhancement.

S4 This appraisal has found that the overall impact of the proposal on the landscape

character of the site itself would yield some limited harm, largely in relation to the perceptual and sensory elements of the landscape character of the site itself. However, the proposals give rise to the potential for beneficial effects on landscape features through the retention and enhancement of mature boundary features, addition of new trees and new open spaces. Along with the provision of a new woodland planting belt along the Pembury Road, the development would retain mature boundary vegetation to soften short-distance views from Pembury Road.

S5 This appraisal has confirmed that the theoretical visual effects within 2km of the site are

considerably limited by mature landscape features within the landscape – the pattern of which would be reinforced by new tree planting within the proposals and the strengthening and addition of perimeter tree belts. The undulating topography surrounding and including the site further ensures that notable visual effects were only recorded for receptors in close proximity to the site boundary, predominantly for existing residents with views into the site from an existing urbanised setting and road users including pedestrians along Pembury Road adjacent to the site.

S6 The scale, form and appearance of the development would reflect and enhance the

positive characteristics of the surrounding area and raise the overall standard of development expected. Being well-integrated with the surrounding areas, the development would appear as a natural and logical addition to Tunbridge Wells. Having taken into account, and assessed accordingly, the potential effects of the proposed scheme on the landscape and visual amenity within the study area, it is considered that the proposed development is entirely in keeping with the landscape character and would not therefore result in any significant material landscape or visual effects.


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S7 The loss of a field in the western part of the site to facilitate the development of approximately 75 properties would, inevitably, create a localised effect. When this effect is considered with the local context, with the perceptual and sensory dimension experiencing a worst-case moderate adverse effect, it would not constitute an unacceptable impact on landscape fabric or character in the long-term.


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Section 1 Introduction, Purpose and Methodology

Introduction

1.1 The Environmental Dimension Partnership Ltd (EDP) has been commissioned by Gleeson Strategic Land (‘the applicant’) to undertake a Landscape and Visual Appraisal (LVA) of proposals to develop land at Sandown Park, North of Pembury Road, Tunbridge Wells (‘the site’). The site is within the Tunbridge Wells Borough Council Local Planning Authority (LPA). The site extends to 6.3 hectares (ha) and is briefly described in Section 2 of this LVA.

1.2 EDP is an independent environmental planning consultancy with offices in Cirencester, Shrewsbury, Cardiff and Cheltenham. The practice provides advice to private and public sector clients throughout the UK in the fields of landscape, ecology, archaeology, cultural heritage, arboriculture, rights of way and masterplanning. Details of the practice can be obtained at our website (www.edp-uk.co.uk). EDP is a Registered Practice of the Landscape Institute (1) specialising in the assessment of the effects of proposed development on the landscape.

1.3 The site is located on the north-eastern edge of Tunbridge Wells, c.500km west of

Pembury. It measures a total of c.6.3 hectares (ha) in area and is centred on National Grid Reference (NGR) TQ 61138 40590 (Plan EDP L1).

1.4 This LVA is part of a suite of documents put forward in support of the allocation of the site within the new Tunbridge Wells Borough Local Plan. The proposed development is for approximately 75 residential units with associated landscape and public open space. The proposals are illustrated on the Illustrative Masterplan at Appendix EDP 1. Purpose and Structure of this LVA

1.5 The purpose of this LVA is to identify the baseline conditions of the site and surrounding area and to determine those landscape and visual characteristics which might inform the design of the development proposals, including recommendations for mitigation. It then provides an assessment of the landscape and visual effects predicted to arise from development on the site with reference to the baseline analysis.

1.6 In undertaking the assessment described in this LVA, EDP has: • Undertaken a thorough data trawl of relevant designations and background

documents, described in Section 3;

1 LI Practice Number 1010

http://www.edp-uk.co.uk/


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• Assessed the existing (baseline) condition and character of the site and its setting, described in Section 4;

• Assessed the existing visual (baseline) context, especially any key views to and from

the site (Section 5). The establishment of baseline landscape and visual conditions, when evaluated against the proposed development, allow the identification and evaluation of landscape effects later in the LVA at Section 7;

• Described the landscape aspects of the proposed development that may influence any landscape or visual effects (Section 6);

• In Section 7, assessed the landscape and visual effects in accordance with the approach described below;

• Reached overall conclusions in Section 8; and

• Provided an analysis of the likely landscape and visual effects of the proposed

scheme, which is determined by combining the magnitude of the predicted change with the assessed sensitivity of the identified receptors. The nature of any predicted effects is also identified (i.e. positive/negative, permanent/reversible).

Methodology Adopted for the Assessment

1.7 The proposed development that is the subject of this LVA is not subject to an Environmental Impact Assessment (EIA). This LVA has, therefore, been undertaken in accordance with the principles embodied in ‘Guidelines for Landscape and Visual Impact Assessment – Third Edition (LI/IEMA, 2013)’ (GLVIA3) and other best practice guidance insofar as it is relevant to non-EIA schemes.

1.8 Familiarisation: EDP’s study has included reviews of aerial photographs, web searches, Local Planning Authority (LPA) publications and landscape character assessments. EDP has also obtained, where possible, information about relevant landscape and other designations such as Areas of Outstanding Natural Beauty (AONBs), conservation areas, and gardens and parks listed on Historic England’s ‘Register of Historic Parks and Gardens of Special Historic Interest in England’ (RPG).

1.9 Field Assessment: EDP has undertaken a comprehensive field assessment of local site

circumstances, including a photographic survey of the character and fabric of the site and its surroundings, using photography from a number of representative viewpoints. The field assessment was undertaken by a qualified landscape architect in November 2018. This involved walking and driving the local area to understand the character of the site and its context, and to consider the likely landscape and visual effects that might arise from development of the land.


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1.10 Design Inputs: EDP’s field assessment has informed a process whereby the development proposals have been refined to avoid, minimise or compensate for landscape effects. Such measures are summarised in Section 6.

1.11 Assessment Methodology: Predicted effects on the landscape resource arising from the proposed development (as detailed in Section 7 of this LVA) have been determined in accordance with the principles embedded within published best practice guidance (Guidelines for Landscape and Visual Assessment 3rd Edition, Landscape Institute and Institute of Environmental Management and Assessment 2013) insofar as the assessment adopts the following well-established, structured approach:

• Likely effects on landscape character and visual amenity are dealt with separately;

• The assessment of likely effects is reached using a structured methodology for

defining sensitivity, magnitude and significance which is contained as Appendix EDP 3. This framework is combined with professional judgement. Professional judgement is an important part of the assessment process; it is neither ‘pro’ nor ‘anti’ development but acknowledges that development may result in beneficial change as well as landscape harm;

• As advised in GLVIA3, the appraisal takes into account the effects of any proposed

mitigation; and

• Typically, a 15-year time horizon is used as the basis for conclusions about the residual levels of effect. Fifteen years is a well-established and accepted compromise between assessing the shorter-term effects (which may often be rather ‘raw’ before any proposed mitigation has had time to take effect) and an excessively long time period.

Study Area

1.12 To establish the baseline and potential limit of material effects, the study area has been

considered at two geographical scales.

1.13 First, a broad ‘study area’ was adopted, the extent of which is illustrated on Plan EDP L1. Based mainly on desk-based study, this broad study area allowed the geographical scope of the assessment to be defined based on the potential extent of views to/from the site and site’s environmental planning context.

1.14 Second, following initial analysis and subsequent field work the broad study area was refined down to that land which is most likely to experience landscape effects. The extent of this detailed study area is 2km from the site boundary, although occasional reference may be made to features beyond this area where appropriate. This detailed study area is illustrated on Plan EDP L3.


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Section 2 The Site

2.1 Plan EDP L1 illustrates the location of the site’s boundaries and the study area for the LVA. The site’s character and local context is illustrated at Plan EDP L2 while its environmental planning context is illustrated at Plan EDP L3.

2.2 The site immediately adjoins the eastern edge of the built up boundary of Tunbridge

Wells, and the Pembury Bypass (A21) to the east. Beyond the A21, Notcutts Nursery, Tunbridge Wells Hotel, Tunbridge Wells Hospital and a superstore fall between the road and the settlement of Pembury and surrounding High Weald Area of Outstanding Natural Beauty (HWAONB), which here comprises an extensive area of woodland.

2.3 The southern boundary is contained by the Pembury Road, a busy tree-lined A road that

runs along a low ridge and marks the HWAONB boundary. To the south of the road lies Oakley School and The Coach House with its associated buildings and grounds, with open agricultural land beyond.

2.4 The site falls within the former ‘parkland’ associated with Pembury Grange, a Grade II listed house to the north of the site. To the north lies an area of grassland with parkland trees with residential development, at the eastern edge of Tunbridge Wells, and woodland beyond.

2.5 The site broadly comprises a square field, down to rough grassland with areas of scrub,

across the western third, and the eastern two-thirds comprise areas of rough grassland and woodland, divided by fencing into some four compartments.

2.6 The western field is broadly level with gentle undulations, and generally at grade with the

adjacent road and housing, and generally enclosed by well treed boundaries as shown in Images EDP 2.1 and 2.2. This area of the site primarily relates to the adjacent housing and road, and has an urban edge character.


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Image EDP 2.1: Taken from the sothern site boundary, looking north. The site’s western field

parcel comprises rough grassland and scrub enclosed by mature tree boundaries.

Image EDP 2.2: Taken from within the western site area, looking south. The southern site

boundary along Pembury Road is lined with well established mature trees. 2.7 The eastern area of the site is divided by a dry valley, running south-west to north-east,

and marked by a row of mature trees. To the north of the valley is a small area of rough grassland with a south-easterly aspect, and to the south the land has a north-westerly aspect with rough grassland to the west and woodland to the east. At the north-eastern extent the land is low lying and very enclosed with little visual connectivity to the rest of the site. The topography, mature trees and woodland across the eastern site area provide enclosure and reduce the influences of surrounding land uses, with the exception of noise from the adjacent roads to the south and east.


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Image EDP 2.3: Taken from within the eastern site area, looking east. This area of the site is

enclosed and bounded by mature woodland. The A21 lies further to the east, on the other side of the woodland block.


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Section 3 Findings of EDP Data Trawl

3.1 The findings of EDP’s data trawl of relevant environmental and planning designations

are illustrated on Plan EDP L3. In summary: • The site falls outside the HWAONB, which broadly wraps around the eastern edge of

Tunbridge Wells, to the east of the A21, and abuts the southern side of Pembury Road in the vicinity of the site;

• The site lies within designated green belt, which extends up to the built up boundary

of Tunbridge Wells. However, this is not a Landscape Designation aimed at protecting a valued landscape, but a spatial planning tool. The site’s location in the green belt does not confer or imply any elevated value or quality in landscape terms; and

• The site’s southern boundary, where it abuts the Pembury Road, falls within the

Tunbridge Wells Conservation Area, as addressed below with regard to heritage matters. The trees along this road are protected by the fact that they fall within the conservation area. In addition, groups of trees abutting the Pembury Road are protected by a Tree Preservation Order (TPO).

3.2 The site does not lie within a locally designated landscape. However, Tunbridge Wells

Local Plan (2006) Policy EN23: Important Landscape Approaches aims to protect important landscape approaches to settlements including the Pembury Road where it abuts the southern site boundary.

Background Documents

3.3 The following documents are relevant and will be discussed as appropriate later in this report: • Tunbridge Wells development plan comprising:

o Saved policies from Tunbridge Wells Borough Local Plan (Adopted March 2006);

o Tunbridge Wells Borough Core Strategy (Adopted June 2010); and

o Tunbridge Wells Borough Site Allocations Local Plan (Adopted July 2016).

• Supplementary planning documents (SPD):

o Tunbridge Wells Borough Green Infrastructure Plan (SPD adopted August 2014).

• Evidence base documents and associated guidelines including:


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o Tunbridge Wells Borough Landscape Character Assessment (February 2017);

o Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (February 2017);

o Tunbridge Wells Borough Council Open Space, Sport and Recreation Study

(2013-2033) (Adopted June 2018);

o High Weald Area of Outstanding Natural Beauty Management Plan (2014-2019);

o Tunbridge Wells Borough Green Belt Strategic Study (November 2016);

o Tunbridge Wells Borough Green Belt Study – Stage Two (July 2017); and

o Royal Tunbridge Wells and Rusthall Conservation Area Appraisal

(November 2000).

Planning Policy National Policy

3.4 At the heart of the National Planning Policy Framework (NPPF) is a presumption in favour of sustainable development; this being the golden thread running throughout the document. For landscape, this means recognising the intrinsic character and beauty of the countryside (para. 170 (b)) and balancing any ‘harm’ to the landscape resource with the benefits of the scheme in other respects.

3.5 This balancing exercise is to be undertaken by the decision taker (in this case the LPA) and falls outside the remit of this report. The benefits of the scheme are to be weighed against the effects on the landscape character and visual amenity as set out in this report. The policy framework is supported by the national Planning Policy Guidance (PPG) where relevant.

3.6 Paragraph 172 sets out the following with regard to development within AONBs and

National Parks (emboldened by EDP for emphasis): “172. Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited.”

3.7 Accordingly, the policy is judged to be not applicable to the proposed development, as the site is not located within the High Weald AONB. The site and High Weald AONB are separated by Pembury Road (see Plan EDP L3) which is lined by a dense understorey


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and mature tree growth. The impact of the site upon the setting of the AONB will be addressed further on in this report. Local Planning Policy

3.8 The statutory development plan relevant to the site comprises of the saved Local Plan 2006 policies, the Core Strategy 2010, and the Site Allocations Local Plan 2016. The council is currently preparing a new Local Plan for the period 2013-2033. A review of the local planning policy circumstances, including relevant supplementary planning documents, evidence base documents and associated guidelines relevant to this assessment is contained below. Saved Policies from Tunbridge Wells Borough Local Plan (Adopted March 2006)

3.9 The saved policies of the Tunbridge Wells Local Plan (2006) of relevance to landscape matters and the site include: • Policy EN13: Trees and Woodland Protection, which aims to protect trees protected

by a Tree Preservation Order, or identified as ancient woodland, or in a conservation area, unless:

“1. The removal of one or more trees would be in the interests of good

arboricultural practice; or 2. The desirability of the proposed development outweighs the amenity value of

the protected tree.” • Policy EN23: Important Landscape Approaches which aims to protect important

landscape approaches to settlements including the Pembury Road. It states that:

“Proposals for development affecting the important landscape approaches to settlements … will only be permitted where no significant harm would be caused to the appearance and character of the approaches and the development would not materially detract from the contribution which that approach makes to the locality.”

Tunbridge Wells Borough Core Strategy (Adopted June 2010)

3.10 The Core Strategy policy of relevance to landscape matters and the site includes Core Policy 4: Environment, which aims to protect heritage assets, landscape value, and biodiversity to conserve locally distinctive senses of place and character with reference to the Tunbridge Wells Landscape Character Area Assessment 2002 (which has been superseded by Tunbridge Wells Borough Landscape Character Assessment 2017).


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Supplementary Planning Documents Tunbridge Wells Borough Green Infrastructure Plan (Adopted August 2014)

3.11 This Supplementary Planning Document (SPD) provides guidance on the creation of new green infrastructure (GI) as well as the enhancement and conservation of existing GI assets within the Borough. The SPD refers to PPG17 Sport, Recreation and Open Space Study (2007), which outlines the parameters of existing open space within the Borough, although this PPG has been revoked it remains an important source of evidence for the GI Plan. Other Documents Tunbridge Wells Borough Council Open Space, Sport and Recreation Study (2013-2033) (Adopted June 2018)

3.12 This study examines existing and projected needs for open space, sport and recreation provision within the Borough. The site is currently undesignated within this study and is not regarded as ‘Open Space’ asset within the Borough. However, it does form part of the evidence base for the new Local Plan (2013-2033) and provision of open space for recreation will need to be considered within the site. Tunbridge Wells Borough Landscape Character Assessment (February 2017) and Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (February 2017)

3.13 The Tunbridge Wells Borough Landscape Character Assessment (February 2017) is the Council’s current published landscape character assessment for Tunbridge Wells Borough, it supersedes SPD Borough Landscape Character Area Assessment 2002: Second Edition Adopted October 2011. The landscape character assessment, together with the Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (February 2017), forms part of the evidence base for the new Local Plan 2013-2033. These assessments are considered more fully in Section 4 of this report.

High Weald Area of Outstanding Natural Beauty Management Plan (2014-2019)

3.14 As illustrated by Plan EDP L3, the site falls outside the HWAONB. However, this designation broadly wraps around the eastern edge of Tunbridge Wells, beyond the A21, and abuts the southern side of Pembury Road in the vicinity of the Site.

3.15 The Management Plan outlines the importance of the setting of the AONB, recognising that “development and other activities within the setting of an AONB may have an impact…as well as affecting views into and out of the AONB”. Due to the site’s proximity to the AONB, development within the site will have to consider potential effects on the character of its setting as well as views into and from the AONB. These are addressed later in this report.


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Tunbridge Wells Borough Green Belt Strategic Study (November 2016)

3.16 The site lies within designated green belt, which extends up to the built-up boundary of Tunbridge Wells. However, this is not a Landscape Designation aimed at protecting a valued landscape, but a spatial planning tool. The site’s location in the green belt does not confer or imply any elevated value or quality in landscape terms. An independent Green Belt Assessment carried out by EDP (ref. edp3824_r005b) assesses the site and this Green Belt Strategic Study in detail and should be read in conjunction with this LVA.

Royal Tunbridge Wells and Rusthall Conservation Area Appraisal (November 2000).

3.17 The Pembury Road (A426), adjacent to the site and including the site’s southern

boundary, falls within the Tunbridge Wells Conservation Area (see Plan EDP L3). While this is a heritage matter that is dealt with in a separate Heritage Assessment prepared by EDP (ref. edp3824_r003a), it is recognised that the Tunbridge Wells Conservation Area Appraisal (November 2000) makes reference to the role of the site in contributing to the character and visual amenity of the conservation area.

3.18 The appraisal describes that the “essential character of the conservation area is, however, linear with views strongly contained by dense planting along the Pembury Road corridor”. It does note that this area provides the approach and eastern gateway to Tunbridge Wells, and that there are broad views northwards below the canopy across the open fields from Pembury Road. Nonetheless, it concludes that the key characteristic of this part of the designated area is its linearity and enclosure by dense vegetation, which generally governs the character of the views.

3.19 The contribution of the site to the character of the road is explore in Section 5 while views northward are explored in Section 6.

Heritage Matters

3.20 Heritage assets can influence the visual character of the landscape and enrich its

historic value. This LVA addresses heritage assets only insofar as they are components of the wider contemporary landscape – not in terms of their significance and value as heritage assets, which is a matter addressed by the separate heritage assessment prepared by EDP (edp3824_r003).

3.21 Within the wider study area, the following heritage assets are components of the contemporary landscape, their locations are shown on Plan EDP L3:

• The frontage of the site along the Pembury Road (A426) lies within Tunbridge Wells

Conservation Area;

• Pembury Conservation Area is situated some 760km east of the site boundary;

• There are three grade II listed buildings located within 500m of the site boundary. These are as follows: ‘Pembury Grange’ situated 0.2km north of the site;


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‘Blackhurst’ situated 0.5km south west of the site; and ‘Muxelwell Farm House’ situated 0.5km south west of the site;

• There is one registered park and garden known as ‘Dunorlan Park’ situated 1.1km

south west of the site; and

• There are no scheduled monuments located within the wider study area. 3.22 In addition, the site falls within former parkland associated with Pembury Grange; a

Grade II listed building sited on the edge of Sandown Park to the north of the site.

3.23 The Historic Landscape Characterisation for the area lists the site as being part of a large parcel designated ‘scattered settlement with paddocks (post 1800 extent)’ which aligns with the information shown on historic maps.

Ecology Matters

3.24 An ecology assessment was undertaken as part of the position paper (see report ref. CLH_EDP3824_02b) which was submitted to the LPA in June 2017 as part of the Council’s call for sites. This ecology assessment considers the ecological assets on the site and within the wider study area. The assessment concludes that: • Development of the site is not considered to be directly constrained by any statutory

ecological designations given their distances and spatial separation from the site;

• The proximity of Pembury Walks and Gregg’s Wood and Pastures Local Wildlife Sites (LWSs) to the site means that they are more sensitive to residential development of the site, predominantly as a result of potential increased recreational pressure and this should be a consideration in the proposals for development of the site; and

• The Extended Phase 1 habitat survey, completed on 10 March 2017 by a suitably

qualified ecologist, found that poor semi-improved grassland, which dominates the site, is considered of limited ecological value. However, mature tree standards and the woodland present on and adjacent to the site are of good ecological value, given their potential to support protected and notable species including bats.

3.25 The pre-application advice from the LPA notes that further survey work is required prior

to the submission of a planning application and that such an application should preserve and enhance biodiversity on site.


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Arboricultural Matters

3.26 The Position Paper in Respect of Arboriculture (see report ref. T_EDP3824_01b) considers the arboricultural assets on the site. In addition, Plan EDP L3 shows the location of area of ancient woodland across the wider study area. The following matters are relevant to this LVA: • TPO 5014/2015/TPO is located on the western site boundary;

• TPO 005/1953 covers two tree blocks on site. The TPO includes trees along the

southern site boundary along Pembury Road, where it falls within Tunbridge Wells Conservation Area, and also woodland in the easternmost part of the site; and

• There are no areas of ancient woodland on or adjacent to the site. However, there

are several areas within 1km of the site comprising:

o Coneyburrow Wood is located 0.5km north west of the site;

o Gregg’s Wood is located 0.4km north west of the site;

o Robingate Wood is located 0.65km north of the site;

o Owlsnest Wood is located 0.25km north of the site;

o Marshleyharbour Wood is located 0.55km north east of the site;

o Chalket Wood is located 0.7km south east of the site;

o Cooper’s Rough is located 0.8km south east of the site; and

o Six smaller copses located within 1km to the south of the site.

Public Access and Rights of Way

3.27 Public Rights of Way (PRoW) are illustrated on Plan EDP L4. A review of the definitive map reveals that there are very few PRoW within 1km of the site. These PRoW, and those within the wider study area, are generally part of the built up area of Tunbridge Wells and Pembury or separated from the site by woodland or development.

3.28 Notably, there is a National Trail known as Tunbridge Wells Circular Walk (TWCW) which is located 1.3km south of the site and orientated in an east-west direction. There are PRoW that sporadically run off from this route.

3.29 National Cycle Route 18 runs along the southern site boundary located on the pavement

alongside the northern edge of Pembury Road.


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Section 4 Existing (Baseline) Conditions: Landscape Character

4.1 This section provides an assessment of the ‘baseline’ (existing) conditions in respect of the character of the site and its landscape context. It summarises any relevant published landscape assessments which contribute to a better understanding of the landscape context. Such assessments provide a helpful understanding of the landscape context, but rarely deliver sufficiently site-specific or up to date information to draw robust conclusions about the significance of any change proposed by the development. Accordingly, EDP has undertaken its own assessment of the site itself which is included in this section. National Character Assessment

4.2 At the national level, the character of England has been described and classified in the National Character Area (NCA) profiles published by Natural England2. The site and its surroundings fall within NCA 122: High Weald.

4.3 While the NCA is broadly representative of the site’s landscape context, it is far too generic to reliably inform an assessment of the suitability of the proposals in landscape terms. Of much greater use are the more localised, borough-specific assessments described below. Local Landscape Character Assessments Tunbridge Wells Borough Landscape Character Assessment (February 2017)

4.4 The Tunbridge Wells Borough Landscape Character Assessment was prepared by Land Use Consultants in February 2017. There are six Landscape Character Types (LCT) identified across the Borough. The site falls within LCT Forested Plateau and more specifically within the Landscape Character Area (LCA) 14: Pembury Forested Plateau. The site also lies adjacent to non-host LCA 19: Bayhall Open Farmland. The location and description of LCA 14: Pembury Forested Plateau is included at Appendix EDP 4.

4.5 This LCA is described (among other things) as a “contained area comprising large-scale

forest cover with a large proportion of ancient woodland. The wooded mosaic surrounds an extensive area of lowland heathland, which has been recreated from plantation and arable farmland”.

4.6 Key characteristics of the LCA are listed below with those of greater relevance to the site and immediate context emphasised by highlighting:

2 https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-

making/national-character-area-profiles


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• “Sandstone forming a high plateau rising to rounded hill tops in the centre of the forest, cut by long valleys of streams flowing northwards to the Medway, creating the locally characteristic topography of deep valleys and ghylls;

• Extensive woodland and forest cover dominates and tends to conceal local topographic variations and limits views both within the area and beyond”. In relation to this characteristic, the assessment goes onto detail that “The nature of the land cover with its large-scale blocks of woodland means that the area is very contained, lacking the extensive views out across successive ridges that are common in many other parts of the High Weald;

• Wooded slopes form a backdrop to views from the surrounding areas including from Royal Tunbridge Wells;

• Within the woodland, grassland pastures bounded by thick shaws and sweeps of

parkland provide an important contrast;

• Areas of relict heathland on the light soils of the sandstone ridges with two extensive areas of heathland restoration at Pembury Heath and Brenchley/Cinderhill Wood;

• A relative sense of remoteness despite its proximity to Royal Tunbridge Wells,

Tonbridge and two main roads slicing through the area. Well served with recreational routes allowing good access on foot;

• A self-contained landscape with a ‘remote’ secretive character with comparatively little settlement apart from Pembury village; and

• Occasional rural lanes, vernacular buildings and small scale irregular fields provide an intricate pattern and human scale as well as a sense of history.” In relation to this characteristic, the assessment goes onto detail that “Pembury Village: This is a ridgetop settlement, although the still dense surrounding forest cover means that it is not a visually dominant feature in the landscape. The self-contained character of the village is accentuated by physical severance from its surroundings by the road bypasses, which run to the south and to the west. Pembury, nevertheless, retains its character as a ‘forest village’ with tree cover extending up to the settlement edge. It has an individual character and sense of separateness from Royal Tunbridge Wells. …”

4.7 With regard to evidence of past use and cultural evolution, the assessment notes, of relevance here, that in this regard the assessment notes elsewhere that “The main road between Pembury and Royal Tunbridge Wells was historically called ‘Wood gate’ and may have been one of the medieval droveways into the wooded pastures to the west and south of Royal Tunbridge Wells. Greggs Wood is a remnant of assart woodland of this former forested chase.”


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4.8 The assessment goes on to note that the majority of the LCA lies within the High Weald AONB, except for four small areas including “the area between Pembury and Royal Tunbridge Wells”, which includes the site. The following key qualities related to the AONB are particularly valued in this character area, with those of most relevance to the site emboldened:

• “Historic farmsteads, which are dispersed across the character area, provide local

distinctiveness, historic interest from their local materials and distinctive steep, clay tile and hipped roofs;

• Ancient routeways, valued for their history and sense of place, particularly where they are narrow, deeply sunken and edged with trees, hedges and boundary banks;

• Ancient woodland, ghylls and shaws. Woodland managed as coppice is valued for its sense of local distinctiveness in its cultural links to historic management in the past. Woodland is also of particular value where it is publicly accessible – for recreation for local communities – including the population of nearby Royal Tunbridge Wells, and for biodiversity;

• The small, irregularly shaped historic fields, bounded by hedgerows and small woodlands, valued for the human-scale pattern they create in contrast with the larger scale woodlands, and the sense of history they hold with past farming activities; and

• Heathland, valued for its relative rarity in the national context, as well as the rare species it supports, its value as a reminder of the past state of the landscape and for its scenic qualities.”

4.9 The list continues with “other features and qualities considered to be of particular

landscape and visual value to the character area include:

• A strong natural character which is readily and extensively accessible on foot, including Council owned woodland (Marshley Harbour Wood), and land owned by public bodies such as the RSPB and woodlands around the Knights Park development.

• The woodlands, wooded ghylls and mosaic of pasture, heathland, wildflower meadows provide a rich perceptual experience for the local population to experience wildlife from footpaths and recreational routes.

• The sense of relative remoteness and a ‘secret’ quality provided by the enclosure of woodland and ridges, with occasional glimpsed views from high points. The relative lack of modern intrusions such as main roads and views of modern development, particularly in the core of the character area, provides a valued sense of ‘escape’.”


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4.10 The assessment goes on to note detractors and opportunities across the LCA:

“1) Impact of busy main roads cutting through the landscape introducing background noise, visual intrusion and movement, including the A21 – especially the new flyover at Longfield Road. Ensure locally sensitive screen planting (as appropriate), in association with development proposals along main road corridors, to reduce visual impact and the wider infiltration of traffic noise.

2) Vulnerability to visual effects of the development beyond the AONB boundary,

including the industrial estates and warehouse developments on the north east edge of the town of Royal Tunbridge Wells and in the area between Pembury and Royal Tunbridge Wells. Opportunities for woodland planting around Royal Tunbridge Wells should be considered to help integrate this urban edge into the forested landscape and provide a measure of screening from the AONB. The former tip site represents an important opportunity for woodland planting. Species mixes and design should reflect the existing woodland character of the area.

3) Severance of Pembury village from its forest setting by the A21 and vulnerability

of severed land to development. Seek further opportunities to re-integrate Pembury village visually into its forest setting, particularly as part of the landscaping of infrastructure and other development proposals. The existing Pembury Walks, providing pedestrian access out from the village, are a good example. The retention and management of areas of woodland and pasture severed by the bypass is a priority.

4) The communications masts at Castle Hill introduce a sense of modern intrusion in

the landscape and are widely visible. Proposals for tall structures should be carefully considered in terms of potential landscape and visual impacts.”

4.11 Generally, the description of the LCA is representative of the site and its context which

describes a rolling, well wooded, visually enclosed landscape with detractors resulting from development and infrastructure including “busy main roads cutting through the landscape introducing background noise, visual intrusion and movement, including the A21” and “visual effects of the development beyond the AONB boundary.” In addition, the site itself contains small characteristic elements including areas of grassland bounded by hedgerows and small woodlands.

4.12 However, there are few key characteristics, or characteristics related to the HWAONB,

that are of more direct relevance to the site. In addition, the assessment does not note the local circumstances that have an influence on the character of the site. This is not a criticism of the assessment but a consequence of the scale of the area that it assesses and the small proportion of this area that comprises the site.

4.13 Generally, the site offers a more urbanised landscape character than described by the

assessment. This is due to the proximity of the settlement edge and main roads which create a peri-urban character across the site and immediate context and removes any sense of ‘remote secretive character’ identified as a key characteristic within the published LCA. This is particularly felt within the western field area on site where there


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are views of adjacent residential properties and the intrusion of background noise of traffic on the adjacent A roads, with glimpses of light and movement of traffic on the Pembury Road, as shown in Image EDP 2.2 and 4.1.

Image EDP 4.1: Taken within the site, looking north-west. The north-western corner of the site

has clear views of adjacent residential properties along Tree Lane.

4.14 The wooded and enclosed character of the LCA is characteristic of the site and its immediate context along Pembury Road. As shown in Image EDP 4.2, mature vegetation lines Pembury Road on either side. This distinct character and appearance of the landscape is recognised within Policy EN23 of Tunbridge Wells Local Plan (2006) and designates the route into Tunbridge Wells via Pembury Road an ‘Important Landscape Approach’.

Image EDP 4.2: Looking south-west along Pembury Road. Pembury Road is lined with mature

trees along with a gapped understorey. This road is designated as an Important Landscape Approach in Policy EN23.


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4.15 As the site is situated along this designated route, consideration of the conditions in which the policy allows development will need to be considered. The policy states that development “will only be permitted where no significant harm would be caused to the appearance and character of the approaches and the development would not materially detract from the contribution which that approach makes to the locality”.

4.16 It is therefore important to establish the existing appearance and character of the approach nearest to the site which, in essence, is a well-treed, busy A road with multiple access points along it. Along this ‘approach’ there are multiple junctions and adjoining roads that link onto Pembury Road as shown in Image EDP 4.3. These are named Hall’s Hole Road, City Livery Club Close, Tree Lane, and most notably, the unnamed access roads to Oakley School and a private estate of which their respective access points onto Pembury Road are situated opposite the southern site boundary. Therefore, an additional access point along Pembury Road that leads into the site would not cause significant harm to the appearance and existing character of the approach and would in fact be consistent with the current landscape character and appearance of both Pembury Road and the Important Landscape Approach at that particular locality.

Image EDP 4.3: Looking south-west along Pembury Road. The access points leading to Oakley

School and a private estate join Pembury Road opposite the sites southern boundary.

Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (2017)

4.17 This study is an update to the 2009 Landscape Character Assessment and Capacity Study (2009) and reflects changes in landscape sensitivity as a result of the A21 roadwork improvements and the relationship between Tunbridge Wells and adjacent settlements such as Pembury.


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4.18 The site falls within sub-area Pe4. This area consists of land to the north of Pembury Road between Tunbridge Wells and Pembury and is bisected by the A21 as illustrated in Figure EDP 4.1. A full description of this sub area is included at Appendix EDP 5.

Figure EDP 4.1: Taken from Tunbridge Wells Sensitivity Assessment (2017). The site

boundary is shown in red.

4.19 As shown in Figure EDP 4.1, the site forms a relatively limited part of sub-area Pe4 and falls adjacent to the settlement of Tunbridge Wells, the A420 slip road, and A246. This indicates that the landscape sensitivity of the site is likely to be subject to localised influences that may not be apparent across the wider study area.

4.20 Each sub-area’s sensitivity is assessed with respect to three ‘scales’ of development that relate to the form of buildings rather than the quantity of development. This assessment relates to development proposals for this site that fall within the small scale category defined as “Two/two and a half-storey residential dwellings – either terraced, semidetached or detached – with associated access roads, private gardens and garaging, and with an assumed density of approximately 30-40 dwellings per hectare.”


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4.21 Sub-area Pe4 has been assessed as having an overall medium-high landscape sensitivity to small-scale development scenarios west of the A21.

4.22 The assessment for sub-area Pe4 is included at Appendix EDP 5 with commentary below. The overall description of the area is: “Sub-area PE4 consists of land to the north of the A264 between Tunbridge Wells and Pembury. It is bisected by the A21. West of the A21 small fields are defined by lines of mature trees, with tree cover more dominant to the east of the A21, occupying most of the space between the A21 and Tonbridge Road. Several large developments are set within the eastern half of the sub-area: Tunbridge Wells Hospital, Notcutts Garden Centre and the Mercure Tunbridge Wells Hotel. There are also several residential dwellings set within the woodland. The sub-area lies outside of the High Weald AONB.”

4.23 The text of relevance to the site is noted below and referenced within relevant sections of the report, with primary matters in relation to the site considered at Section 7: “Physical character Land to the west of the A21 has a parkland character, with a strong structure of mature tree lines and individual specimens, but its physical containment by major roads and strong tree cover reduces its contribution to landscape character.” – “Settlement form and edge .. this [western] part of the sub-area is … contained from the wider countryside by main roads and trees, which serves to strengthen its relationship with the settlement edge, so sensitivity in this respect is limited. There is significant development to east of A21, outside of the Limits to Built Development, but woodland containment means that there is still a clear distinction between this and the main urban area of Pembury to the east of the A264.” “Settlement setting The sub-area forms a narrow gap between Tunbridge Wells and Pembury, and there is some perception from the A264, a major approach into Tunbridge Wells, of the parkland character of the area to the west of the A21. The A21 and its containing tree cover, which prevents any intervisibility between the two settlements, is a key element in settlement separation, but the small size of the gap and the connection provided by the A264 mean that the open space within the western half of the parcel also makes an important contribution to the settlement gap.”


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“Visual character There is strong visual containment, so the sub-area doesn’t contribute to wider landscape character other than through the screening impact of its tree cover, but views from the A264 contribute to the perception of a gap between Tunbridge Wells and Pembury, and the role of this route as one of the principal approaches into Tunbridge Wells heightens sensitivity in this respect. Tree cover prevents any visibility into the area from the A21.” “Perceptual qualities Containment by major roads and trees limits perception of this area as relating to the wider countryside and limits the sense of rural tranquillity that might otherwise be associated with the sub-area’s woodland and parkland.” “Sensitivity conclusions This is not a strongly rural setting, given its containment by urban edge development and major roads, but retention of the sub-area’s wooded character is important in terms of screening the A21, maintaining settlement separation and contributing to the wooded settings of Pembury and Sandown Park, and the fields to the west of the A21 retain a landscape character that is important in the retention of an open approach to Tunbridge Wells. Any new access or visibility of urbanising built landscape elements from the A264 would be likely to increase landscape impacts through reduction of perceived separation from Pembury. Assuming that sufficient tree cover is retained to prevent development from significantly reducing the current extent of wooded containment … There is medium-high sensitivity to small-scale development … to the west of the A21. There is little scope for more large scale development without significant impact on this containment and wooded setting.”

4.24 The primary matters for consideration within Section 7 of this report are: • Retention of the sub-area’s wooded character to:

o Screen the A21; and

o Contributing to the wooded settings of Pembury and Sandown Park.

• Retention of the sub-area’s wooded character and the fields to the west of the A21

to: o Retain the landscape character and open approach to Tunbridge Wells; and

o Maintaining perceived separation from Pembury.


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EDP Site Assessment

4.25 While the above published assessments provide a helpful contextual appreciation of the wider landscape, none provide a sufficiently site-specific assessment to allow a reliable assessment to be made of the effects of the proposed development on the landscape. In particular, published assessments tend to miss more localised influences on the landscape such as the effect of traffic or existing development on tranquillity and visual character, especially in close proximity to settlements. This requires an appropriately detailed assessment of the site itself and its immediate surroundings which EDP has undertaken and is described below.

4.26 Site visits have taken place between April and November 2018. The visits were complemented by a review of aerial photography, mapping and field assessments from publicly accessible locations (e.g. from local roads and PRoW).

4.27 The land reaches a height of approximately 147m above Ordnance Datum (aOD) on the western edge of the site, generally falling from west to north-east to a height of approximately 128m aOD. The site is located on a ridge of higher ground, which runs approximately west to east.

4.28 The site broadly comprises a square field, down to rough grassland with areas of scrub,

across the western third (Image EDP 2.1), and the eastern two-thirds comprise areas of rough grassland and woodland, divided by fencing into some four compartments.

4.29 The western field is broadly level with gentle undulations, and generally at grade with the

adjacent road and housing, and generally enclosed by well-treed boundaries. 4.30 The eastern area of the site is divided by a dry valley, running south-west to north-east,

and marked by a row of mature trees. To the north of the valley is a small area of rough grassland with a south-easterly aspect, and to the south the land has a north-westerly aspect with rough grassland to the west and woodland to the east. At the north-eastern extent the land is low lying and very enclosed with little visual connectivity to the rest of the site. The topography, mature trees and woodland across the eastern site area provide enclosure and reduce the influences of surrounding land uses, with the exception of noise from the adjacent roads, mainly the A21 and Pembury Road.

4.31 The site’s western boundary consists of mature trees with a dense understorey comprising partly hedgerow and scrub with well-treed rear gardens of the residential development beyond. The north-west corner of the site lacks any established boundary vegetation resulting in views of adjacent housing off Tree Lane as illustrated in Image EDP 4.1.

4.32 The north of the site is enclosed by an agricultural fence with intermittent vegetation allowing views across the adjacent open green space to the residential properties, to the north-west, and across the predominantly wooded landscape, with glimpsed views to the hospital, to the north-east.


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4.33 The northern boundary consists of an agricultural fence with mature trees and areas of dense understorey scrub. At the western end of this boundary the scrub is disjoined in parts resulting in views across a narrow area of grassland to residential properties off Pembury Grange as shown in Image EDP 4.5. To the east, there are views from the northern boundary across the rising grassland with parkland trees to woodland with glimpses to secluded residential property off the unmarked road.

4.34 The southern boundary is marked by mature trees with some understory scrub to the

west and woodland to the east with the busy A426 beyond.

Image EDP 4.5: Residential properties off Pembury Grange are visible through gaps in vegetation

along the sites northern boundary.

4.35 Visually, the site is generally well-contained within the wider landscape by: the treed rear garden boundaries of properties along Tree Lane to the west; trees and woodland lining the Pembury Road to the south; and the wooded embankment of the roundabout slip road and A21 to the east. To the north, the site is enclosed by an agricultural fence with intermittent vegetation allowing views beyond limited to those across the adjacent grassland with parkland trees contained by residential properties, to the north-west, and across the predominantly wooded landscape, with glimpsed views to the hospital to the north-east. Visual containment is acknowledged by the Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (2017) which states that: “There is strong visual containment, so the sub-area doesn’t contribute to wider landscape character other than through the screening impact of its tree cover … Tree cover prevents any visibility into the area from the A21.”

4.36 The rough grassland, areas of scrub, and fallen trees within the woodland all create an air of neglect across the site. The noise, light, and movement from the adjacent


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transport routes, and adjacent development, provide urbanising influences, notably across the western end of the site which is considered to have an urban edge character which diminishes to the east.

4.37 The site is visually contained, by vegetation and development, and physically detached, by transport routes and development, from the wider agricultural and wooded landscape to the east and south, including within the HWAONB. This visual and physical detachment is recognised by the Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (2017) which states that: “Containment by major roads and trees limits perception of this area as relating to the wider countryside and limits the sense of rural tranquillity that might otherwise be associated with the sub-area’s woodland and parkland.”

4.38 The site therefore has less of a relationship with this wider landscape and more of a relationship with the urban fringe of Tunbridge Wells as recognised by the Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (2017) which states that:

“.. this [western] part of the sub-area is … contained from the wider countryside by main roads and trees, which serves to strengthen its relationship with the settlement edge, so sensitivity in this respect is limited.”

Image EDP 4.6: Private view of the eastern site area, looking north east. This area is enclosed

by mature woodland which restricts any intervisibility with the surrounding landscape. The A21 is situated immediately beyond the tree line to the north.

4.39 Within this context, the primary contribution of the site to its context is, the contribution

that the trees lining the A426 make to enclosing the Pembury Road, strongly containing views along the road corridor and contributing to the character of this approach to Tunbridge Wells; and, at a broader level, the wooded character of the host character area.


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Section 5 Existing (Baseline) Conditions: Visual Amenity

Introduction

5.1 Visual amenity (as opposed to ‘visual character’ described in the previous section) is not about the visual appearance of the site, but has to do with the number, distribution and character of views towards, from or within the site. An analysis of visual amenity allows conclusions to be reached about who may experience visual change, from where and to what degree those views will be affected by the proposed development.

5.2 This section describes the existing views; changes to views wrought by the proposed development are analysed in Section 6. An analysis of existing views and the ‘receptors’ likely to experience visual change is conducted in three steps described in turn below. Step One: Defining Zones of Theoretical and Primary Visibility

5.3 The starting point for an assessment of visual amenity is a computer-generated ‘Zone of Theoretical Visibility’ (ZTV). The ZTV is derived using digital landform height data only and therefore it does not account for the screening effects of intervening buildings, structures or vegetation, but it does give a prediction of the areas which, theoretically, may be able to experience visual change; it thus provides the basis for more detailed field assessment.

5.4 The ZTV is then refined by walking and driving local roads, rights of way and other publicly accessible viewpoints to arrive at a more accurate, ‘field-tested’ Zone of Primary Visibility (ZPV). The ZPV is where views of the proposed development would normally be close-ranging and open, whether in the public or private domain, on foot, cycling or in a vehicle. In this instance, the field assessment was undertaken in November with overcast conditions and therefore is a good representation of wintertime views of the proposed development.

5.5 Beyond the ZPV lies a zone of visibility which is less open, being either partly-screened or filtered. Views from within this zone would include the proposal – it may not be immediately noticeable, but once recognised would be a perceptible addition to the view. Step Two: Defining Receptor Groups

5.6 Within the ZPV and wider area, the people (‘receptors’) likely to experience visual change can be considered as falling into a number of discernible groups, each discussed below.


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Rights of Way Users

5.7 There are no PRoW within or adjacent to the site and very few within 1km. Notably, there is a National Trail known as Tunbridge Wells Circular Walk (PRoW No. WB43), which is located 1.3km south of the site and orientated in an east-west direction.

5.8 PRoW to the west, north, and east of the site fall within settlement area or within woodland and it is assessed that there will be no visibility from them to the site. Views to the site from PRoW No. WB51 and PRoW No. WB43, located within a more open agricultural landscape landscape of the HWAONB to the south of the site, are non-existent due to a combination of topography and the presence of mature woodland blocks around Oakley School, Pepenbury Hall and along Pembury Road as shown in Images EDP 5.1 and 5.2.

Image EDP 5.1: Taken from within the HWAONB along Tunbridge Wells Circular Walk, looking

north towards the site. There are no views to the site due to intervening topograpphy and mature woodland blocks.


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Image EDP 5.2: Taken from within the HWAONB along PRoW No. WB51. There are no views of

the site due to intervening topography and mature woodland blocks.

5.9 It is considered that, due to the focus on the surrounding landscape and interest in the local area, users of the above PRoW, although with some de-sensitisation where close to built form and man-made features, are high sensitivity receptors.

Road Users

5.10 There is one road within the study area that affords views of the site, namely Pembury Road. Views to the site from other roads across the study area are prevented by interveneing built form, mature roadside vegetation and/ or woodland blocks.

5.11 Pembury Road runs adjacent to the southern site boundary as shown on Plan EDP L4.

Views from this road to the site are represented by Photoviewpoint EDP 1, representative of views for road users travelling south-west, Photoviewpoint EDP 2, representative of views for road users at the access point opposite the southern site boundary, and Photoviewpoint EDP 3, representative of views for road users travelling north-east from Tunbridge Wells towards Pembury and the A21 junction.

5.12 These photoviewpoints illustrate that where vegetation allows there are infrequent, glimpsed, oblique, filtered, short-distance views into the site between tree trunks and below tree canopies. Where views are available they are generally limited by vegetation across the Site and along its northern boundary.

5.13 However, the focus of the view for road users on Pembury Road is not necessarily directed at the site. The focus of road users here is likely to be on safely reaching a destination rather than enjoyment of the view; they are likely to be concentrating on travel along the busy A road.

5.14 The focus of the view for road users at Photoviewpoint EDP 2, is likely to be on joining the main traffic travelling along Pembury Road and not focussed on the glimpse views


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into the site opposite. The receptor here would be concentrating on their journey rather than appreciating the views of the immediate landscape within the site.

5.15 The focus of road users at Photoviewpoint EDP 3 is likely to be focused on the approach towards the busy roundabout ahead. Image EDP 4.4 illustrates the view for road users passing the site, heading north east, on the approach towards the roundabout.

5.16 Road users with views of the site from along Pembury Road, including users of public transport, have very little focus on the surrounding landscape. For the above reasons, it is considered that road users are of low sensitivity.

Roadside Pedestrians and Cyclists

5.17 Views from roadside pedestrians and cyclists are presented within Photoviewpoints EDP 1, 2 and 3. Receptors identified at these locations (see Plan EDP L4) are within a peri-urban setting and surrounded by a number of detracting features, primarily the traffic and cyclists on this busy adjacent A road, and the associated infrastructure such as lighting columns and telegraph.

5.18 The focus of the view for roadside pedestrians on Pembury Road is not necessarily directed at the site as pedestrians are primarily here to reach a destination rather than enjoy the view. Perceptually, senses are alerted towards the noisy and busy A road that runs adjacent to this cycle/pedestrian route. As a result, they are concentrating on travel along Pembury Road, and it is unlikely that they appreciate enclosed views of the site to the north.

5.19 Roadside pedestrians and cyclists therefore have a reduced susceptibility to change within the landscape when compared to PRoW users and for this reason are considered to be of medium sensitivity. Track Receptors

5.20 Photoviewpoint EDP 4 is representative of views for pedestrian users of the unnamed track connecting Blackhurst Lane and Sandown Park as shown on Plan EDP L4. This is a publicly accessible track used predominantly by pedestrians travelling between Tonbridge Road and Blackhurst Lane. The track is lined by mature trees with a well-established scrub understorey. Where there are gaps in between tree trunks and the understorey layer, medium distance glimpse views of the tree canopies in the eastern part of the site are partially visible. There are no views of the western area of the site from this locality. Where views are available they are generally limited by interviewing vegetation along the track and across the parkland north of the site.

5.21 Although not visible, the presence of the A21 can be heard from this locality which significantly reduces the tranquillity at this Photoviewpoint. In addition, heading south west along the track there are clear views of residential properties along Sandown Park which could potentially draw the attention away from glimpse views south across the parkland.


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5.22 The track is closely linked with Blackhurst Lane and the pedestrian footbridge which crosses the A21. This suggests track users would be using the route for either recreation or ease of access between Sandown Park and their destination. As this track is an extension of the vehicular route along Sandown Park, the focus of the view for the receptors is not necessarily directed at the site as pedestrians are primarily here to reach a destination rather than enjoy the view. Track users would therefore have a reduced susceptibility to change within the landscape when compared to PRoW users and for this reason are considered to be of medium sensitivity. Residential Dwellings/Groups

5.23 Receptors in private residential properties, although likely to be of high to very high sensitivity to changes in the view, are not protected by national planning guidance or local planning policy. Accordingly, changes to the character, ‘quality’ and nature of private views are not a material planning consideration in the determination of a planning application. However, in the interests of good masterplanning, they remain relevant to this review of the predicted extent and nature of visual change, so are reviewed briefly below.

5.24 Due to the distribution and orientation of residential properties and intervening mature

vegetation within the undulating landscape surrounding the site, the number of private residential properties with potential views of the proposed development is limited. These views will largely be experienced by a small number of properties along Tree Lane, Pembury Grange and the unnamed road off Sandown Park, as well as glimpse views from three properties south of Pembury Road.

5.25 As the site is in close proximity to existing residential development, it follows that neighbouring dwellings have views into the site, but these tend to be from first floor level above the domestic curtilage treatment. Notwithstanding this, any masterplan would need to be sensitive to the residential amenity of these dwellings in terms of development offset.

5.26 Residents within the wider study area often become less susceptible to the proposed development due to their views being contained to the ‘settlement setting’ and immediate surrounding fields and vegetation. The sensitivity of residential receptors is dependent, to some extent, on the room(s), and the activities of people in those rooms, from which the site is visible. Residents with visibility from rooms normally occupied in waking hours will generally have a very high sensitivity, with a lower sensitivity from bedrooms and rooms from which there may be no expected view, for example bathrooms. In some instances, the purpose of rooms with potential views towards the site cannot be ascertained from public vantage points, and thus in those circumstances a cautionary approach is adopted where the receptor is accorded a very high sensitivity. Step Three: Defining Representative Viewpoints

5.27 Within the ZPV, there are clearly many individual points at which views towards the site are gained. EDP has selected a number of viewpoints which are considered


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representative of the nature of the views from each of the receptor groups. The selection of the representative viewpoints is based on the principle that the assessment needs to test the ‘worst case’ scenario, and In selecting these viewpoints, EDP has sought to include: • A range of viewpoints from all points of the compass, north, south, east and west;

• A range of viewpoints at varying distances from the site; • Viewpoints from all the above receptor groups.

5.28 Four photoviewpoints (PVPs) have been selected. Their location is illustrated on Plan EDP L4. Photographs from the selected viewpoints are contained in Appendix EDP 2.

5.29 The purpose of these viewpoints is to aid assessment of a visual receptor(s). These viewpoints are not assessed separately. Details of each view, and the reason for its selection as a ‘representative viewpoint’, are provided in the table below (Table EDP 5.1): Table EDP 5.1: Summary of Representative Photoviewpoints

PVP. No.

Location Grid Reference

Distance and Direction of View

Reason(s) for selection & Sensitivity of Receptor

1 Taken from Pembury Road

561302, 140578

Adjacent to the eastern corner of the site, looking south-west.

Represents views experienced by road users, including roadside pedestrians and cyclists, travelling from Pembury towards Tunbridge Wells.

2 Taken from Pembury Road, adjacent to Oakley School

561176, 140483

Adjacent to the southern site boundary, looking north.

Represents views experienced by road users, including roadside pedestrians, at the junction between Oakley School a private estate and Pembury Road.

3 Taken from Pembury Road, adjacent to residential properties

560967, 140428

Adjacent to the south western corner of the site, looking north-east.

Represents views experienced by road users, including roadside pedestrians and cyclists, travelling from Tunbridge Wells towards Pembury.

4 Taken from a track on Sandown Park

561116, 141122

450m to the north of the site boundary, looking south.

Represents views experienced by pedestrians and cyclists.


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Section 6 The Proposed Development and Mitigation

6.1 Having defined the baseline conditions in the previous two sections, this report now

reviews the proposed development and (in the next section) undertakes an assessment of the likely effects in landscape and visual terms. The Proposed Development

6.2 The proposed development is illustrated by the Illustrative Masterplan at

Appendix EDP 1 and comprises:

• Up to approximately 75 residential dwellings; • Dwellings would be predominantly two storey detached and semi-detached

properties; • An informal central open space; • Retention and enhancement of the eastern site area for informal public open space

supporting visual, recreational amenity and biodiversity; • Proposed access off Pembury Road; • Retention and enhancement of planting along the southern site boundary; • Provision of an Informal footpath providing new cycle/pedestrian connections to

Pembury Road; and • Sustainable drainage features and new tree planting. Mitigation Measures

6.3 The masterplan for the site has evolved over time with inputs from the EDP consultant

team in relation to heritage, ecology, arboriculture and landscape. Consistent with the landscape-led approach, EDP’s landscape team has provided continuing feedback from the early stages of this LVA process, recommending masterplan responses to avoid or minimise potential landscape and visual effects in light of the more detailed findings of our field assessments. This process is mitigation through design, or primary mitigation. Some of the suggested masterplan responses are discussed below and referred to in the landscape and visual assessment in Section 7.

6.4 Consequentially, the Illustrative Masterplan shows how this site could come forward while retaining the key landscape elements, providing mitigation to potential effects on


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the landscape character, ‘Important Landscape Approach’ (Policy EN23), the setting of the HWAONB, and on the visual amenity of adjacent residents. This to be achieved by:

• Limiting development to the sites western field with an indented well planted

eastern development edge to provide a soft, integrated new settlement edge adjacent to the retained area of naturalistic open space to the east;

• Retaining the majority of existing planting along Pembury Road; access into the

site has been located to minimise tree losses to two grade B trees within the TPO (G9 – sycamore ‘a self set group’, T10 – beech), which will be replaced within the site. The remaining trees to be managed to ensure their longevity, and the planting to be enhanced with new trees and shrubs to increase screening and contribute to the wooded, enclosed, landscape character of this approach. In addition, there is potential within this woodland belt to provide a footpath set back from the road edge that meanders through the trees to provide an alternative, more attractive, route than the existing roadside shared footpath/ cycleway;

• Providing an area of open space at the new entrance, minimising and softening

views into the development from Pembury Road;

• Setting development back from existing properties, and providing new planting at here, to minimise overlooking; and

• Retention of the eastern site area as naturalistic, informal open space based on

its current character of woodland with incidental areas of open space. This would provide potential areas for Sustainable Drainage Systems (SuDS) and for ecological enhancements that would link to planting along the A21. Retention and enhancement to the woodland would also go some way to fulfilling the Landscape Character Area Assessment 2002 opportunities for enhancement: “consider further opportunities for woodland planting around the town of Royal Tunbridge Wells to help integrate this urban edge into the forested landscape and provide a measure of screening from the AONB.”.

6.5 Specific mitigation measures relating to planting comprise:

• Existing protected trees on site, as part of a TPO and/or within Tunbridge Wells Conservation Area, are to be retained and enhanced through management. Existing tree belts both within and along the site boundaries are to be retained and enhanced with additional tree planting to reinforce the existing tree buffer. Further tree planting along the southern site boundary will uphold the aspirations of local policy such as the preservation and enhancement of the ‘Important Landscape Approach’ (EN23);

• Additional native tree and woodland planting will be included within both the north western corner and within the gap in vegetation along the northern boundary. This will further enhance the enclosed character of the site and soften/limit views of the development from adjacent properties identified in Section 5;


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• Additional native planting to soften views of the development within the site. Planting palettes to be in line with aspirations of published character assessments and guidelines; and

• Additional naturalistic shrub and tree planting along the eastern edge of the

developable area to soften the edge of the development.


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Section 7 Predicted Landscape and Visual Effects

Introduction

7.1 In this section, the predicted effects on landscape character and visual amenity are assessed. The assessment uses the thresholds for magnitude, sensitivity and significance defined at Appendix EDP 4 as a guide, but moderated where appropriate with professional judgement. Professional judgement is an important part of the assessment process; it is neither ‘pro’ nor ‘anti’ development but acknowledges that development may result in beneficial change as well as landscape harm. The assessment also takes account of the likely effectiveness of any proposed mitigation. Predicted Effects on the Character of the Site

7.2 Clearly, in terms of land use of the western area of the site, the proposals would result in change of this area from an area of open grassland to a residential development. This would result in a very high magnitude of change on the sensory and perceptual dimensions of the landscape character. This is not surprising. The conversion of any greenfield site to a residential development site would yield such an outcome and this is not a reflection on the quality of the scheme masterplan, but of the process that requires an assumption to be made that most people would see the visual and sensory change from greenfield to development as adverse. However, it should be noted that some such adverse effects will be necessary; indeed, cannot be avoided if the Council’s housing needs are to be met.

7.3 However, the retention of the eastern site area as informal open space largely unaltered from its current form means that changes to the sensory and perceptual dimensions of the landscape character in this area would be limited. There would be some change due to visibility from this area to the proposed new development to the west. However, this could be limited through the sensitive design of the eastern edge of the proposed development area, indented with tree planting as shown on the illustrative masterplan, which would limit the intrusion of the development across the eastern site.

7.4 The magnitude of change across the western site area would be tempered by the following considerations:

• There are already detractors, or urbanising influences, on the site including

resulting from intervisibility with adjacent residential development and the “impact of busy main roads cutting through the landscape introducing background noise, visual intrusion and movement, including the A21”, as acknowledges by the LCA, and the A246;


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• The proposed residential development is consistent – in land use terms – with the adjacent residential development to the west and north and would not constitute a land use that is either un-neighbourly or incongruous in the settlement context;

• In terms of extent, layout, form, and scale the proposals are consistent with the

development pattern of the adjacent settlement edge; and • The proposals are also sensitive to the adjacent residential development and would,

therefore, form an integrated addition to the settlement. 7.5 With regard to the sensory and perceptual aspect of the site it is assessed that at year 1,

the magnitude of change to the character of the site will be very high, yielding a moderate adverse effect due, primarily, to the change of use across the western site area. Through the maturation of the landscape proposals, the magnitude of change at year 15 is likely to reduce to medium, yielding a moderate/minor adverse effect on this aspect of landscape character.

7.6 With regard to landscape features, the published character assessment recognises only

one characteristic that is reflected locally within the site and its immediate context: its contained and wooded character. The effects on this would be minimal as careful masterplanning and sensitive landscape design, as illustrated by the Illustrative Masterplan, would allow for the preservation and enhancement of the majority of this key landscape characteristic. Losses as a result of the proposals would include the removal of some existing trees along Pembury Road to allow creation of one new vehicular access. The majority of trees onsite, and along its boundaries, would be managed to ensure their long term retention and replacement should they fail. There is no prospect of enhancement under the current management regime and no ability of the Council to enforce enhancements on private land for public benefit. The proposals offer the opportunity, secured through condition, to enhance long term management.

7.7 In addition, there are no factors in terms of the site’s biodiversity, arboricultural, heritage or archaeological value that preclude the change of use as a matter of principle. Consideration of the effects on these aspects of landscape are addressed in detail in the separate Archaeological and Heritage Assessment, Ecological Assessment, and Position Paper in Respect of Arboriculture. These reports should be consulted for more detailed assessment of the effects of the development on these site features.

7.8 In addition, the proposals provide the opportunity to secure the retention and

maintenance of the vast majority of existing trees and shrubs, and provide new planting both within the development area and across the eastern site area that could be secured through condition. On this basis, it is predicted that the proposals will yield a significantly beneficial effect on the landscape fabric and biodiversity value of the landscape, especially in the medium and long term as the proposed new landscape fabric matures.


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Predicted Effects on the Site Context Published Landscape Character

7.9 The limited contribution made to the wider character area to the east of the A21 is acknowledged by the Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (2017) which states that: “Land to the west of the A21 has a parkland character, with a strong structure of mature tree lines and individual specimens, but its physical containment by major roads and strong tree cover reduces its contribution to landscape character.”

7.10 The site adjoins the urban edge of Tunbridge Wells along its western boundary. Where there are views to the site from its context within the wider character area this settlement edge is apparent. This limits the predicted scale of change resulting from the proposals.

7.11 The proposed development is relatively small in relation to the wider area of Pembury

Forested Plateaux and would not have a material change on its key characteristics. 7.12 Despite the site being situated adjacent to non-host LCA 19 to the south, there are no

such predicted effects on this landscape character area due to a severe lack of intervisibility between both the site and LCA 19. This is primarily due to reasons outlined in Section 5, where it details that views to the wider landscape are restricted due to the presence of mature woodland blocks and mature trees alongside Pembury Road.

7.13 For these reasons, it is assessed that the proposals will result in a low magnitude of

change. When combined with a high sensitivity, this change gives rise to a worst case moderate/minor adverse level of effect at both years 1 and 15. Settlement Edge and Pembury Road

7.14 Although the development will extend the settlement edge marginally further east (but will not be the easternmost part of Tunbridge Wells), the proposals will remain barely perceptible in views from the surrounding landscape, with development being contained by a combination of site boundary vegetation, existing woodland blocks, and the nature of surrounding topography. The Illustrative Masterplan shows preservation of key landscape features within and along the site’s boundaries as well as providing an additional woodland planting belt along part of its southern boundary along Pembury Road. This will further enhance its enclosed landscape character. The site comprises a small proportion of the character area, and development is concentrated within the western half of the site. These considerations limits the scale of predicted change resulting from the proposals.

7.15 Upon completion, at year 1, due to the retention of the existing mature landscape fabric,

it is not considered that the local landscape character will be dramatically altered by the proposed development. With the exception of a loss of a somewhat rural view to few residential receptors immediately adjacent to the site on Tree Lane, the development


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will not obscure views of the wider landscape. Although views to the site are very limited where glimpsed viewing opportunities are available, looking towards the site from the adjacent A246, the development will largely be seen within the context of a peri-urban environment due to the presence of busy traffic, lighting columns, traffic lights, existing housing and a school along Pembury Road.

7.16 For these reasons it is assessed that the proposals will result in a low magnitude of

change. When combined with a high sensitivity, this change gives rise to a worst case moderate/minor adverse level of effect at both years 1 and 15.

Predicted Effect on Landscape Designations – High Weald AONB 7.17 The review of planning policy at a national and local level indicates that the site’s

location adjacent to the High Weald AONB is the greatest factor to consider in terms of the development’s acceptability in landscape and visual terms. How the development fits within the landscape context should be tested against the objectives contained within the High Weald AONB Management Plan relating to both the preservation of the setting and supporting the vision of the AONB.

7.18 The proposed development would inevitably change the character of the landscape

setting within a discrete geographical area. However, the change would be experienced within a very limited geographical context due to the presence of mature landscape features along and within the site boundary. Such features limit intervisibility between the site and its immediate context. It is considered that the proposed development would not be perceptible in views both towards and from the High Weald AONB, at publicly accessible locations. This is illustrated by the visual appraisal on Plan EDP L2.

7.19 Overall, owing to the very limited intervisibility with the proposals, along with the

retention of the site’s key landscape features, it is not considered that the proposed development is in conflict with the vision of the High Weald AONB. The site is well-related to an existing settlement edge and is visually well-enclosed by mature landscape features. The magnitude of change is considered to be very low at most and, when combined with a very high sensitivity of the wider AONB, would yield in a moderate/minor adverse level of effect at most at years 1 and 15.

Predicted Effect on the Gap between Tunbridge Wells and Pembury 7.20 The primary matters raised by the Landscape Sensitivity Assessment of Countryside

around Tunbridge Wells (2017) contributing to an assessment of medium high sensitivity, and of relevance to the assessment are summarised in Section 4 and comprise:

• Retention of the sub-area’s wooded character to:

o Screen the A21; and


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o Contributing to the wooded settings of Pembury and Sandown Park.

• Retention of the sub-area’s wooded character and the fields to the west of the A21 to:

o Retain the landscape character and open approach to Tunbridge Wells; and

o Maintaining perceived separation from Pembury.

7.21 This Illustrative Masterplan shows that the majority of the vegetation at the site

boundaries and across the eastern site area will be retained. The only vegetation proposed for removal comprises a select few trees along Pembury Road to allow for new vehicular access into the site. Moreover, the proposals include additional planting within the site and provide the opportunity to secure long term management and maintenance of this planting. These mitigation measures will ensure that there will be no reduction in screening of the A21 or contributing or to the wooded setting of Pembury and Sandown Park.

7.22 With regard to character and perceived separation from Pembury this LVA has found

that given the nature of the topography north of the site and the mature vegetation along the northern side of Pembury Road (see Images EDP 2.1 and 7.1), views from Pembury Road into the site field are severely restricted and so the site area beyond the boundary vegetation contributes very little in the perception of a gap between Tunbridge Wells and Pembury. As noted above, perceived changes to wooded character from Pembury Road will be minimal.

Image EDP 7.1: View from the southern site boundary looking north-east along Pembury Road

towards Pembury and the roundabout junctions illustrates there is no existing visual connection between Tunbridge Wells and Pembury.

7.23 This LVA has found that the effect of the proposals on the landscape character of the

site context will be very limited due primarily to limited visibility into the site, and the fact that the proposed development area directly abuts existing development within Tunbridge Wells. The site is surrounded by urbanising elements which contribute to its peri-urban landscape character and reduced landscape sensitivity such as traffic along


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Pembury Road, the A21 and visible development adjacent to the site. An additional access point into the site from Pembury Road would not be out of character given the number of existing access points along Pembury Road, so therefore would not be an unexpected element in the landscape.

7.24 The low level of perceived change to the site from Pembury Road means that the

perceived separation of Tunbridge Wells from Pembury will be minimal. 7.25 This assessment shows that perceived change to the landscape character and open

approach to Tunbridge Wells and the perceived separation of Tunbridge Wells from Pembury will be substantially limited and should not be a reason for refusal of the proposals.

Predicted Effects on Visual Amenity Receptors using Public Rights of Way

7.26 There would be a no visibility to the site from PRoW within the wider LVA study area including from PRoW within the High Weald AONB, as illustrated by Images EDP 5.1 and 5.2. This is due to the screening provided by topography, mature woodland blocks and the existing built form. Consequentially there are no predicted effects on visual amenity for PRoW users.

Track Users East of Sandown Park

7.27 Views south from the track east of Sandown Park, across the parkland are shown in

Photoviewpoint EDP 4. Views of the site are restricted by mature vegetation along the track as well as interviewing mature trees within Pembury Grange. Where there are gaps in between tree trunks and the understorey layer, medium distance glimpse views of the trees in the eastern part of the site are partially visible. There would be no views of the western area of the site from this locality. Considering the severely restricted view of the site along with the existing urbanising elements at this locality, outlined in Section 4, the development will form a barely noticeable component of the view, the magnitude of change is very low for these receptors yielding a minor/negligible adverse and long-term.

Road Users including Pedestrians and Cyclists

7.28 Due to intervening topography, built form and vegetation, views from local roads are

limited to those from the Pembury Road where it runs adjacent to the site as illustrated by Photoviewpoints EDP 1, 2, and 3. These views are limited to glimpsed, oblique, short distance filtered views between trees and below tree canopies. These views will be influenced (in perceptual and physical terms) by existing urban elements and detracting features. These considerations will limit the scale and geographic extent of change at completion.


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7.29 At year 15, the maturation of the landscape proposals on the southern boundary of the site would serve to further limit intervisibility with proposed built form. However, the proposed development is likely to be recognised by the receptor, particularly in winter months, giving rise to an overall medium magnitude of change at year 15, yielding a minor adverse and long-term effect for vehicle users and a moderate/minor adverse and long-term effect for roadside pedestrians. This level of effect will be limited to the short section of the road adjacent to the western site area with the level reducing rapidly with distance from the site.


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Section 8 Conclusions

8.1 EDP is an independent environmental consultancy and Registered Practice of the

Landscape Institute specialising the assessment of developments at all scales across the UK.

8.2 This report has summarised the findings of a comprehensive landscape data trawl and field appraisal undertaken by EDP’s landscape team (Sections 2,3,4 and 5). In Section 6 the proposed development was described with proposed mitigation. Section 7 undertook an assessment of the likely landscape and visual effects having regard to the above and based on a combination of the thresholds set out in Appendix EDP 4 coupled with professional judgement.

8.3 The findings confirm that the site relates well to the existing settlement of Tunbridge Wells, such that the proposed development represents a logical area for growth that can be readily assimilated and integrated into this part of the landscape. The very limited adverse harm predicted to occur on the perceptual dimension of the landscape character of the site is outweighed by the beneficial landscape effects arising as a result of the proposed development. Likewise, there are limited adverse visual effects predicted to affect users of the track east of Sandown Park, Pembury Road and residential receptors, given the nature and design of the development proposals.

8.4 There may be some intervisibility experienced by some receptor groups in close proximity to the site, but the existing nature of the landscape, and the use proposed, would serve to moderate any effect accordingly. For residential receptors, views are limited to a few properties along Tree Lane, an unnamed road off Sandown Park, Pembury Grange and Pembury Road.

8.5 The loss of a field in the western part of the site to facilitate the development of approximately 75 properties would, inevitably, create a localised effect. When this effect is considered within the local context, with the perceptual and sensory dimension experiencing a worst-case moderate adverse effect, it would not constitute an unacceptable impact on landscape fabric or character in the long-term. Accordingly, whilst the proposed development will certainly yield change to the open character of the site itself, this appraisal finds no reason why the change of land use should be found to be so harmful as to be unacceptable in terms of the effects on the landscape character and visual amenity.

8.6 The proposed development includes a variety of landscape features, which in turn would have many beneficial effects on both the site and its immediate surroundings. In addition to the extensive mitigation measures outlined in section 6, the proposed development would provide further benefits for the local community, including the provision of new areas of informal public open space across the previously privately-owned field parcel together with new areas of attractive, accessible, linked public open space across the site, which will be enhanced by SuDS features. Additional proposed tree planting will add to the landscape fabric and biodiversity value, as will the planted SuDS features.


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8.7 The proposed development comprises a modest extension to the existing built-up area of Tunbridge Wells. The scale, form and appearance of the development would reflect and enhance the positive characteristics of the surrounding area and raise the overall standard of development expected. Development would be limited to the western half of the site which would ensure the scheme integrates well with the existing settlement edge of Tunbridge Wells. In turn, such masterplanning ensures the subsequent effects of development on both landscape character and visual amenity are limited. Being well-integrated with the surrounding areas, the development would appear as a natural and logical addition to Tunbridge Wells. Having taken into account, and assessed accordingly, the potential effects of the proposed scheme on the landscape and visual amenity within the study area, it is considered that the proposed development is entirely in keeping with the landscape character and would not therefore result in any significant material landscape or visual effects. At year 15, there would be a worst case moderate/minor adverse level of effect on Published Landscape Character, the settlement edge of Tunbridge Wells, Pembury Road and the High Weald AONB.

8.8 The assessment also shows that the effect of the proposed development on the perceived change to the landscape character, the open approach to Tunbridge Wells and the perceived separation of Tunbridge Wells from Pembury would be substantially limited. The site is therefore considered to be suitable for residential development as proposed.