I am writing on behalf of the Tenterden & District Residents Association (TDRA) to object again to this application for the following reasons:
In addition to our previous objections and in response to the amended drawings two points seem the most pertinent – one is the access for emergency vehicles – there should be a second access in our opinion. Page 126 of Kent Design suggests a minor access road which this is, almost, “generally serves up to 100 dwellings, including those in other residential areas which feed onto it. The road should either be a throughroad or, if a cul-de-sac, serve no more than 50 dwellings unless an alternative emergency access route, to serve also as a pedestrian and cycle route, can be provided.” There are more than 50 dwellings and we consider the need for an emergency access is especially pertinent for a care home where the population will be elderly by definition and may need more frequent emergency vehicle access.
The second is the description of the site as sustainable. The data in section 3.3.3 of the Transport Assessment gives a table showing the walk distances that are preferred and then promptly illustrates that this site is at the extremities of what would be acceptable. No consideration of the topography has been made when applying PTAL walking speeds designed for London urban living. We find this a weak point. However KCC Highways, as the Highway Authority, has not reached the same conclusion – their letter dated 2nd November explains “for a proposal to receive a sustainable recommendation of refusal on highway grounds it must have a severe impact on highway capacity or highway safety. This is simply not the case with the tabled planning application.” We think the need for an emergency access is something that has been overlooked and that should have been picked up in the safety audit and is possible grounds for refusal on highway safety. We support the legitimate concerns of the many objecting local residents. We would also point out that the Transport Statement and the latest highway drawings do not now match.
Siggi Nepp – Planning Secretary