Aylesford	575312 160268	29.06.2004	TM/04/02250/FL
Blue Bell Hill And Walderslade
Proposal:	Install temporary telecommunications equipment until 28th June 2005 comprising of a 15m high column, housing 2 no. dual band dual polar antennas and 1 no. 600mm transmission dish along with four equipment cabinets located adjacent to the pole
Location:	Land East Of 257 Chatham Road Aylesford Kent
Applicant:	Orange

1. Description:

1.1 The mast is required for a temporary period whilst negotiations are continuing with Union Railways South to locate a permanent installation within their demise. The mast is required in order to ensure coverage of the Eurostar Route. The mast and cabinets would be installed on the edge of a tree copse and the site fenced by a 2.1m high temporary haras fencing.

1.2 Access to the site would be via the Pilgrims Way PROW adjacent to Cossington PFS.

2. The Site:

2.1 The site lies on the eastern side of the A229, immediately to the east of the CTRL.

3. Planning History:

3.1 No relevant history.

4. Consultees:

4.1 PC: Strong objection raised as site lies within an Area of Outstanding Natural Beauty and adjacent to the White Horse Stone.

4.2 CE(BS): No objection.

4.3 DHH: No objection.

4.4 County Archaeologist: The proposed siting of this development is in a sensitive location archaeologically and from the historic landscape view. The White Horse Stone Scheduled Ancient Monument may be directly affected by this scheme and as such I recommend English Heritage are consulted. They take the lead in advice on developments affecting SAMs and my comments here are subject to the views of English Heritage.

With regard to archaeological remains, there are several nationally important Neolithic monuments in this vicinity including the White Horse Stone, a single sarsen stone probably representing the remnants of a Neolithic monument. The stone stands only a few metres to the north east of the proposed development. Recent archaeological investigations preceding the CTRL scheme located two Neolithic long houses and associated remains in the field to the north and there are clear indications that this area was favoured for Neolithic activity, both settlement and ritual. Further prehistoric, Roman and Medieval remains were located before and during works for CTRL here, indicating that this area has been favourable for occupation and settlement since the early prehistoric period onwards. Although there has been extensive groundworks associated with the construction of the CTRL, there is potential for the proposed scheme to have an impact on archaeological remains.

The proposed siting of the mast is also in a sensitive location in terms of the impact on the historic landscape and the setting of the White Horse Stone. As mentioned above, the White Horse Stone, located just a few metres to the north east of the proposed mast and cabinets, is one of several nationally important upstanding Neolithic monuments which form a group known as the Medway Megaliths.

Most of these seem to be related to burial/ritual practices and the character of this Neolithic ritual landscape can still be appreciated. From the White Horse Stone views extend across a small dry valley towards the more extensive North Downs scarp slopes and the valley of the River Medway. The White Horse Stone is located just off the Pilgrims Way, an ancient trackway which continues along the foot of the scarp slope of the North Downs.

In respect of the proposed development, to a certain extent it may be possible to mitigate against any impact on buried archaeological remains but the impact on the historic landscape and the setting of the White Horse Stone is less easy to assess. From the details supplied there does not seem to be any detailed assessment of the proximity of the proposed mast and cabinets to the White Horse Stone. It would be useful to have a plan clearly and precisely indicating the location of the mast and cabinets and the White Horse Stone. It would also be useful to have a representative image of the views from and towards the White Horse Stone with the mast and cabinets present. The proposed development seems to be round the corner from the Neolithic monument, close to the CTRL bridge and may not necessarily be seen from the White Horse Stone. However, the mast and cabinets would undoubtedly be seen in views towards the White Horse Stone and would probably have a detrimental impact on the historic landscape.

I recommend a Historic Landscape and Visual Impact Assessment is undertaken to provide supplementary information for the application. This assessment could provide important guidance to enable an informed decision to be made as well as to put forward possible mitigation measures. It would also be useful if the applicant could provide any additional information on the extent of existing ground


disturbance, particularly from the CTRL works, and provide an assessment of the potential for locating important archaeological remains as well as proposals for mitigation measures.

4.5 EH: Summary

The proposed location for the telecommunications equipment lies very close to the scheduled monument that is the White Horse Stone. The application drawings should be revised to show the relationship of the proposed installation site to the scheduled monument. This is by definition a site of national archaeological importance. It is thought to be the remains of a megalithic long barrow dating from the Neolithic period. As such it is a component of the group of such monuments known as the Medway Megaliths that includes the nearby sites of Kits Coty and Little Kits Coty. This type of monument is rare nationally and the Medway group are unique in the Kent.

English Heritage advice

The site of the scheduled monument is tightly drawn to the stone and so scheduled monument consent would not be required for the proposed works. The works would however have a significant detrimental impact upon the setting of the Horse Stone. The stone stands to one side of the Pilgrims Way footpath in a highly accessible location for visitors. This is a route way held to be of great antiquity and at this location it forms an attractive tree lined hollow way with the White Horse Stone to one side, reached by steps. The telecommunications equipment would be highly visible on the approach to the White Horse Stone from the direction of the A229 and its 15 metre high mast would be visible above the trees that surround the scheduled monument. This impact would be increased in winter months when the trees are not in leaf. The CTRL passes in close proximity to the scheduled monument and is a major modern feature in the landscape. Its visual impact is however limited by the fact that new railway runs in a deep cutting. From the eastern end of the new footbridge over the CTRL the view up the Pilgrims Way is of the scarp slope of the Downs AONB and there are few modern intrusions into this landscape view.

English Heritage Recommendations

The setting of a scheduled monument is a material consideration for the planning process and the advice of PPG 16 (as reflected in Development Plans) introduces a presumption against development that would be harmful to scheduled monuments and their settings. On this basis English Heritage objects to the principle of the proposed telecommunications installation at this location. This objection is unlikely to be capable of resolution by mitigation of the visual impact of the works in this location. We see no alternative but to explore other locations. The proposed temporary nature of the installation is noted but this does not overcome our objection.

The application provides no justification for its statement that the Area of Archaeological Importance drawn around the scheduled monument will not be affected. Our experience is that prehistoric and other remains are to be anticipated in close proximity to the megaliths in this group of monuments. This was demonstrated by the work carried out near White Horse Stone in advance of the construction of the CTRL. This revealed a Neolithic long house that is unique within Kent and also a major late Bronze Age and Iron Age settlement. A human burial was located adjacent to the Pilgrims Way. The ground disturbance required for the proposed installation could have a significant impact upon buried archaeological remains and this would need to be tested by archaeological evaluation in advance of a decision about planning permission. The impact of the proposal on the setting of the scheduled monument is considered sufficient grounds for this application to be rejected and so it is not recommended that a predetermination evaluation be required. If however you were minded to accept the installation in principle the below ground archaeological impact would then need to be evaluated. If remains were to be identified the presumption from PPG 16 could be in favour of their physical preservation in situ. This could be further grounds for a refusal of planning permission.

Next steps

We consider that the implications of this application are so significant that we would welcome the opportunity of advising further on the revised proposals. Please let me have the necessary additional information in time for us to comment again if necessary before the application is determined.

4.6 MKWC: No response.

4.7 HMU: No response.

4.8 MBC: No response.

4.9 Kent Downs AONB Unit: No response.

4.10 Ramblers Association: No response.

4.11 Private Reps: 3/0X/0S/85R + site and press notice. Of the letters/e-mails of objection received, 3 are from neighbours of the site. Many of the e-mails received are from other parts of the UK and overseas and they include a petition of 44 signatures from an address in Nottingham. The objections are on the grounds of:

· Visual impact.

· Not conducive to a site of international historical importance.

5. Determining Issues:

5.1 The site lies in the Kent Downs AONB and the Strategic Gap which separates the Medway Towns urban area from north Maidstone. KSP policy ENV3 provides long term protection for the AONB which gives priority to the conservation and enhancement of natural beauty, including landscape, wildlife and geological features over other planning considerations. TMBLP policy P3/5 re-iterates the KSP policy and P2/18 protects the Strategic Gap from development which significantly extends the built confines of existing rural settlements or urban area or other areas reserved for development.

5.2 KSP policy ENV18 protects the archaeological and historic integrity of Scheduled Ancient Monuments, important archaeological sites and historic landscapes, together with their setting and prohibits development which will adversely affect them unless exceptionally justified. TMBLP policy P4/2 reflects that policy.

5.3 Policy P7/16 refers specifically to telecommunications development and will only allow such equipment where there are no satisfactory, alternative sites; there is no reasonable possibility of sharing existing facilities; no reasonable possibility of erecting antennae on an existing building or other structure; the equipment is removed when no longer required; the benefits and wider implications of the development are more significant than any other direct environmental impacts; the development is sited and designed and incorporates appropriate measures to minimise its visual impacts on amenity. Full regard will be paid to licence obligations and technical and operational constraints faced by telecommunications operators in the application of the above criteria.

5.4 Although the mast would be seen against the background of trees in the copse it would be visually intrusive located at the field edge in this sensitive part of the AONB. The site is very prominent and can be seen quite clearly from Lower Warren Road, Chatham Road and the Pilgrims Way PROW. In addition the mast would be sited in close proximity to the White Horse Stone, an archaeological site of international importance. I do not consider that this is an appropriate location for a mast. This view is shared by both English Heritage and the County Archaeologist.

5.5 In addition to the mast, the cabinets and the heras fencing proposed would be an incongruous feature in the landscape.

5.6 I appreciate that the application is for a temporary period only, for a year or less, to give coverage over the CTRL. The applicant has not explored alternative locations in respect of this application other than to state that the AONB designation covers all of the area and therefore it would be difficult to locate the mast elsewhere whilst still affording the required coverage to the portal. I do not consider that these reasons justify overriding the landscape and archaeological concerns.

6. Recommendation:

6.1 Refuse Permission, as detailed in letter dated 28/06/04 and plan nos. 30/ATN0322/01, 30/ATN322/02 and 30/ATN322/03 date stamped on the 29/06/04 for the following reasons:

1 The development would be detrimental to the rural character of an area designated by the Countryside Commission as an Area of Outstanding Natural Beauty by virtue of the introduction of inappropriate alien features into the landscape contrary to policies ENV3 of the Kent Structure Plan 1998 and P3/5 of the Tonbridge and Malling Borough Local Plan.

2 The proposal would be detrimental to the setting and ambience of the White Horse Stone, an internationally important scheduled ancient monument contrary to policies ENV18 of the Kent Structure Plan 1998 and P4/2 of the Tonbridge and Malling Borough Local Plan.

3 Because of the harmful and direct impact on the Area of Outstanding Natural Beauty and the setting of the Ancient Monument, the proposal does not meet the criteria set out in Tonbridge and Malling Borough Local Plan policy P7/16. Notwithstanding the temporary nature of the proposal, the Local Planning Authority does consider the operational case submitted in support of the application to be sufficient to outweigh the other planning policy objections.

Contact: Jill Hamilton