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Planning Services

PLANNING APPLICATION FORUM

Held In the Council Chamber at the Town Hall, on Thursday, 12 June 2014

APPLICATION REF: 14/01567 SITE ADDRESS: David Salomons Estate & Mill Farm, Broomhill Road, Tunbridge

Wells PROPOSAL: Creation of temporary Christmas attraction within the grounds of

Salomons Estate, including the installation of a number of temporary buildings and structures, demolition of brick enclosure adjacent to boundary wall and reinstatement of gap in wall, change of use of land at Mill Farm to temporary car park for the attraction including new surfacing for parking area, and erection of temporary structures.

PRESENT: Mrs Jean Marshall, Planning Policy Manager (Chairman) Mr Richard Allen, Team Leader, Planning Services Miss Denise Haylett, TWBC, Support Manager Mrs Cheryl Clark, Democratic Services Officer (Committee Administrator) Mr Roger Nightingale, Partner Kember Loudon Williams LLP Mr Nick Moore, Commercial Director, Markerstudy Leisure Councillors: Backhouse, Mrs Cobbold, Dr Hall, Hill, Munn, McDermott, Rusbridge, Scott, Sloan. Mrs Soyke and Mrs Thomas. 45 members of the public were also in attendance. APOLOGIES Councillors Elliott, Noakes, Patterson, Tompsett and Weatherly DECLARATIONS OF INTEREST None

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INTRODUCTION The Chairman, Mrs Marshall, opened the meeting and the attendees were introduced. The purpose and structure of the meeting were explained. PRESENTATION BY THE PLANNING OFFICER Mr Allen summarised key points from the following notes and additionally illustrated these by means of a powerpoint presentation.

[SLIDE OF AERIAL PHOTOGRAPH/BLOCK PLAN] - Speldhurst Road to north, Broomhill

Road to East

Salomons Estate comprising:

- Salomons House – large Victorian grade II listed manor house which is currently used

as wedding venue; conferencing; restaurant; events and a museum -

- 2 no. T-shaped accommodation blocks located to the east dating from 1970s

- Runcie Buildings: Grade II* former stable block

- Grade II Listed water tower

- Potting shed building on northern boundary adjacent to Speldhurst Road

- Extensive lawns and gardens. Woodland to west

- Car parking alongside main access road to Salomons House, with additional parking to

south and adjacent to potting shed on the site of former greenhouses

- Application (retrospective) 13/03643 and 13/03645 to remove section of listed wall along

Brroomhill Road to provide access to lower field – going to planning committee 18th June

2014

- Application 13/03531 for a 56-bed hotel adjacent to and abutting the potting sheds and

demolition of the 2 no. T-shaped accommodation blocks is currently pending

consideration

- Lawful use for Salomons for 1200 functions per year; no more than one per-day; not to

be attended by more than 500 attendees established by LDC 14/00184

- Levelling of lower field granted by application 13/01713

Mill Farm

- Located to south of Salomons

- Currently used as an equestrian centre

Land between the two (The application site)

- Substantial area of woodland

- Land slopes and descends north to south

Access

- Main access to Salomons is close to junction with Speldhurst

- Secondary access to south

- Third access which leads to two sites; Mill Farm is the northerly of the two; the southerly

leads to a detached dwelling known as ‘Cobblestone Mews

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Planning Constraints

- Outside the Limits to Built Development

- Metropolitan Green Belt

- Area of Outstanding Natural Beauty

- Historic Park and Garden

- Tree Preservation Order(s)

- Flood Zone 3

- Local Wildlife Site

[SLIDE OF BLOCK PLANS] Application proposals

- Establishment of temporary tourist attraction on land to the south of the Salomons

Estate and incorporating Mill Farm to the south

- Tourist attraction to be know as ‘Father Christmas World’

- Will operate between late-November and end of December

- Expected 45,000 visitors for 11,250 families

- Access taken from existing to Mill Farm/Cobblestone Mews with construction of ‘link

road’ within site to create ‘in/out’ access

- Parking for 239 cars

- Travel plan to be sought to encourage persons to park in town centre and take bus to

site

- Existing Cobblestone Mews residence to be retained and used as a reception/arrival

area during use; complete residential use out of season. (Corrected by Mr Nightingale

in his subsequent presentation – Cobblestone Mews is a different property – this

property is Mill Farm).

- Visitors will arrive at Mill Farm and then board a ‘road train’ which will lead to tourist

facility; applicant state a short area of road will need to be constructed north of the

PROW and will largely follow existing tracks within the woodland – which will be placed

with temporary matting and undulations filled in with crushed stone or similar.

- [SLIDES OF BUILDINGS]

- First train stop (north) – four temporary structures comprising on land which is currently

lawn:

o Welcome Marquee (tent)

o Igloo (inflatable)

o Elf Theatre and Polar Bear Ice Cave would be plywood constructions

o Temporary pathways

- South ‘Village Square’ comprising:

o Catering tent

o Central attraction for various rides

o Father Christmas reception area

o 10 Father Christmas tents

o Road train back to car parking area

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Main Issues

- Whether the proposal amounts to inappropriate development within the MGB; if so,

whether any merits and/or benefits of the proposal outweigh harm

- Whether the proposed use and temporary buildings cause significant harm the scenic

beauty of the AONB landscape;

- Whether the proposal harms the Historic Park and Garden ;

- Whether the proposal causes substantial, or less-than-substantial harm to the

significance of the setting of listed buildings;

- Impact on Trees;

- Whether the proposal is a flood risk/whether the site is suitably drained;

- Impact on the local highway network in terms of travel and traffic generation; suitable

access; parking quantum and sizes; deliveries and waste collection

- Whether the proposal harms ecology and wildlife;

- Whether the proposal causes harm to surrounding residential amenity;

Representations (N.B It is acknowledged that the website has been unavailable for some

time for residents and other interest groups to view and comment on the application online.

This has been because of the implementation of the new planning support shared service

which has seen TWBCs planning support amalgamated with that of Maidstone BC and

Swale BC and relocated to Maidstone, and the subsequent logistical and IT linking which

has followed.). There will be further time 21 days for interested parties to comment once

the website is operational again. However it may be useful to know that comments are

accepted right up until the date of committee. It is accepted that there are likely to have

been/ and there is likely to be more representations received than what I shall summarise

below.

- 27 letters of support;

o Enhance reputation of TW and make it a ‘go to’ place/raise profile of the town and be

hugely beneficial for the town

o Lots of new jobs (applicants state 160 over 2-months)

o Increase the festive lights which will aid the town’s commerce

o Boost the town’s economy

o Angry that was being asked to object when the development is exciting for the town

and that limited disruption can be accommodated

- 29 letters of objection;

o Increase in road traffic on narrow rural lane, which is already overloaded with traffic,

is totally inappropriate;

o The road network leading to Salomons cannot support the additional traffic – A26

already congested;

o 1360 cars extra per-day is unacceptable

o Road conditions not appropriate in cold weather;

o Detrimental impact on wildlife;

o Increase in carbon footprint to the area;

o Noise and disturbance to residences will be unbearable;

o Location is totally wrong;

o Weather conditions a major obstacle;

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o Why is another one needed – there is already a Christmas World at Bedgbury and

Bewl Water;

o Light pollution will be a major intrusion; there is no lighting plan included;

o Inappropriate development in the AONB for an Americanised theme park;

o Inappropriate development in the MGB;

o Inappropriate use of a historic building and land;

o There will be no extra trade in TW or Southborough and no demonstrable benefits to

the Town;

- 4 letters non committal

o One of which does not object but has concerns, and considers that if Members, at the

appropriate planning committee, are minded to grant planning permission that they

should consider conditions to the following:

Speed limits in Speldhurst (Barden Rd) should be reduced to 20mph

Only give a permission for this year only so that a full traffic assessment of actual

traffic generated can be undertaken and accepted before any longer period is

considered

Any travel advice and traffic signage is published or made by the applicants;

All commercial vehicles to arrive at the site via the main routes only (i.e not

through the villages)

NB: Other relevant issues may arise during the further assessment of the application.

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PRESENTATION ON BEHALF OF THE APPLICANT Statement from Mr R Nightingale, Partner, Kember Loudon Williams (agent to the applicant) Introduction You have been given a brief description of the proposal by Mr Allen and I would really just like to talk about on some of the main planning issues that this proposal raises. Nick Moore will then tell you more about some of the discussions we have been having with the Borough Council and local businesses and organisations aimed at making this initiative a success for Tunbridge Wells as a whole. Main Planning Issues Traffic and Travel Father Christmas World (FCW) will not work if people cannot get into and out of the site. It is not in the interests of the applicants if the local road system is gridlocked and brought to a standstill at any time. The number of people going through the attraction will be very closely controlled. All visits pre-booked for specific times; 120 people per half hour maximum; majority families; 4 people per car on average; thus a maximum of 30 cars in and 30 cars out every half hour at full peak. In practice it will be less than this as some people will travel by other means. Assessment of where people will be coming from shows that most will be arrive via A21 and A26 (approximately 80%). We will encourage people to use this route, and discourage cars using roads through Rusthall and Speldhurst. Working with TWBC for people to be able to park in the town centre, and with train companies to provide an incentive for people to travel by train. We will provide minibus transfers for these visitors. Some will come by taxi or get lifts etc. The remainder, which is likely to be the majority, will park in the proposed parking area at Mill Farm. No staff will park on site. Other Potential Impact - Noise and Lighting. This will be a family attraction – no loud or blaring music. Last tours finished by 9.30pm. No late night activities. No attractions aimed specifically at teenagers for evening entertainment. Most of activities inside or under cover because of potential for wet weather, therefore most lighting contained or screened. Outside lighting (eg of car park) will be designed just to light the areas where people need to move around safely, and not the wider countryside.

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Policies of Constraint Site in Green Belt, AONB, setting of Listed Building, locally listed historic garden – clearly a sensitive site. BUT – Proposal is for a temporary development running mid-November to end of December. Afterwards it will be removed and for the rest of the year the grounds will be restored to their normal appearance. We are also suggesting that a Landscape Management Plan be agreed in association with this proposal to help preserve the special qualities of the Salomons estate. Mr Nick Moore, Commercial Director, Markerstudy Leisure on behalf of the applicant. Statement made based on the following notes: Links with the town centre / Promotion of Tunbridge Wells at Christmas / Economic Benefits FCW expects an average of 12,000 families, 45,000 people over approximately 6 weeks. This

will generate an additional £3.5m worth of income into the local economy.

Employment

FCW will employ in excess of 200 people over a two-month period. We believe that the pool of

talent within Tunbridge Wells is strong and therefore intend to recruit locally.

Locally Sourced Suppliers

With such a diverse range of products and services required we will source locally where

possible.

Spend Within Local Area

We expect 70% of visitors to be day visitors to the area. It is thought that the average spend of

a day visitor to Tunbridge Wells is around £30/£35 per person. This is spent on petrol, food,

drinks and gifts.

Working with TWBC, local business groups and individual retailers, it is proposed that FCW will

be a part of a town wide initiative to market and promote TW as a Christmas destination and will

give people and families reason to come to the area, spend and even stay.

This initiative has already gained widespread support from other local businesses and retailers.

We are currently compiling a list of all festive attractions and promotional offers from businesses

and retail groups across the town. i.e. Ice rink, Pantomime, Pantiles etc

Via the FCW website, once a family have booked their ticket we will know exactly what

time they will be arriving and leaving FCW and the size/make up of their party. Our web

software will then tailor additional activities within TW for that party to do. i.e. 3pm you

can book ice skating at Calverly Grounds. This will be linked directly to the partners

website, and the ticket holder will be given a unique reference number which will enable

them to gain a discount to book that activity.

If we gain an uplift of 5,000 tickets sold for the Ice Rink, for example, this will generate

an additional £40k for that event owner, in this case TWBC, which can then be spent on

improving the town.

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We expect 30% of visitors to stay overnight in the area. Although some of these will stay

with friends and family we expect a high number to stay in local hotels and B&B’s. The

average spend of an overnight visitor to Tunbridge Wells is around £157 per person.

Again we intend to maximise this by partnering with local hotels and B&B’s to offer

special deals for those staying locally.

Public Transport

15% of visitors are likely to take public transport. We will encourage this by offering a free

dedicated mini-bus service from Tunbridge Wells train stations direct to FCW. Southeastern

Trains have agreed to offer a 25% discount to all FCW ticket holders and the FCW website will

be directly linked to the Southeaster Trains website to encourage travel booking at time of

purchase.

This will also help minimise the traffic impact on Tunbridge Wells.

Local Charity Benefits

It is our intention to apply for a temporary FM radio licence enabling us to operate a TW based

radio station during the festive period helping to promote the combined Christmas attractions, 7

days a week 24hrs a day. We intend to also use the radio station to raise £100K for regionally

based children’s charities and other charities in the run up to Christmas.

It is also our intention to distribute around 1,800 free tickets to local charities and

underprivileged children.

Marketing and PR

How will we tell all these people about TW and what’s happening?

Our first year will require considerable spend on marketing and PR. A fully integrated £250k

marketing campaign will include key messaging about Tunbridge Wells and encourage new

visitors maximising their spend within the local economy. The advertising will appear

nationwide across newspapers, magazines, posters and social media.

We are also combining our marketing & PR resources with others in the area. Working with the

team at Assembly Hall Theare we will host a press weekend in Tunbridge Wells for

representatives from UK based media owners to stay and see the area. Giving the borough

unprecedented media exposure.

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Other Marketing Initiatives

It is intended to include a tourist information centre within Father Christmas World

enabling visitors to purchase tickets to other TW based attractions. Local businesses are

also being offered the chance to rent a small retail outlet within the attraction.

A retail unit in the town will be opened in August to help deal with enquiries and promote

the combined festive offerings.

We will publish a tourist information guide in a paper and digital format to support and

promote all attractions, businesses etc. during the festive period.

As part of the marketing and attractions, we will also fund another ‘Santa Express‘ train

this year to help attract visitors and carry them around the town.

Parking

Having all these people visit TW is fantastic but where will they park? Well we’re helping with

that too.

Again working alongside TWBC and other local based businesses we intend to provide

initiatives to help make parking in the town centre easier.

Firstly, at the point of booking FCW tickets visitors will be encouraged to use trains and other

public forms of transport to reach the town. For those who do drive, via the website they will be

given clear advice on where and how to park in TW. And the number of available parking

spaces in TW car parks during the festive period will be increased this year.

The owners of derelict town centre cinema site providing the rear car park for use.

TWBC donating some of their staff car parking spaces

Markerstudy donating the car parks of their three town centre office buildings

It’s believed at weekends this could add as many as an additional 175 town centre car parking

spaces.

Information and news on parking will be displayed on the FCW website, broadcast regularly via

the radio station and via other media.

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PRESENTATION BY THE PETITIONERS Statements made based on the following notes along with visual displays: Mr Peter Waller, Planning Consultant, on behalf of the Residents Group

Introduction Tunbridge Wells and its surrounding countryside is a very special place. It has a very high quality beautiful and delicate character and environment. I know from personal experience as a Planner working here for many years that it requires careful and sensitive management to avoid irreparable damage being inflicted by development. Residents move here because of that high quality environment and are avid scrutineers of development proposals, not in a NIMBY fashion, but out of a passion to ensure that the cherished landscape and townscape is conserved. The principle of establishing an attraction like FCW in Tunbridge Wells has much to commend it. But if it is to realise the benefits that its promoters claim and not give rise to the significant harm that the local Community fears, then it needs to more thoroughly planned and located at a more appropriate site. It needs to be located to a site more easily accessible to people by means other than the private car. Broomhill Road at Southborough is not the place to locate FCW. Procedures The local community are concerned by the lack of meaningful engagement by MSL with the local population and Council Planners in pre application discussions. I am aware of the letter from MSL dated 21 May setting out all that they have done to publicise their proposals. But, announcing in the Courier that Father Christmas World will be happening next Christmas at Salomons and that the Council are enthusiastic about it, is not meaningful consultation in the sense set out by the Government in the NPPF at paragraph 188 where it says “Good quality pre-application discussion enables better coordination between public and private resources and improved outcomes for the community”. A major proposal such as this in a very sensitive location requires careful detailed planning and usually, would-be applicants call meetings with interested parties and the Council’s Planners where such details can be discussed and a sensible solution arrived at. This has not happened. As a result, local residents feel excluded, suspicious of both MSL and The Council and feel that normal pre application planning processes are being bypassed. Furthermore, having read all of the documents submitted with the application, they are then hearing different information and figures from MSL when they attended local Parish meetings regarding, how long the operation will last, the numbers employed and the financial benefits to the town that will accrue. All of this adds to the concern that MSL is giving out different information to different audiences and that nothing is fixed and certain in this proposal. Secondly, there is great concern and suspicion about the order and piecemeal way in which proposals have been submitted at Salomons, without any explanation of the linkages between them and the implications for Salomons and the wider area as a whole if they are approved. The application for the levelling of land at the southern end of the Salomons Estate in 2013 appeared to have no relationship to any other activities on the Estate, but it brought with it a very noisy music and social event that resulted in action by the Council’s environment team. Then came the hotel proposal, followed by the application to rebuild a widened service entrance at the southern end of the site and finally (to date) Father Christmas World. What is next the Community is asking?

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What the Community Wants Why are the three outstanding applications being dealt with by three different Planning Officers? To the public, there seems to be no attempt by the Planning Department to realise the interconnected nature of the proposals. The recommendation for approval of the wall and access applications ahead of the FCW application is a case in point and is seen as a great mistake because it will literally” open the door “ for FCW and other similar ventures. The Planning Committee is requested to defer the wall applications and instruct their Officers to deal with them as part of the FWC application. MSL appears to have a hidden agenda that seeks to marginalise the overarching and very strong planning policies covering this area by submitting seemingly minor applications and then submitting major proposals to capitalise on them. Salomons should not be viewed as a development opportunity site but as a historic site of buildings and complementary landscape gardens and woodland that needs to be conserved and not exploited. The Council should require MSL to submit a comprehensive Master Plan showing their full intentions at Salomons and the lands to the south that they have now acquired. Further this application should be refused or MSL invited to withdraw and discuss a revised more central location for this attraction. Mr Andy Jenkinson also spoke on behalf of the Petitioners based on the following notes: Highways The TA report acknowledges that the available sightlines do not reflect the speed limit on Broomhill Road and argues that speeds are reduced. However there is no traffic speed survey and no analysis of what sightlines are appropriate. There is consequently no drawing showing how these can be provided or identification of the trees that will need to be removed. The report also states that most traffic will arrive via the A26/Speldhurst Road junction but this assertion is not supported by any analysis of the route options or assignment of trips. Without this analysis there can be no certainty that this will be the case and our own analysis shows that most traffic will use inappropriate and narrow country roads. The process described for checking visitors tickets is flawed. It suggests that tickets will be checked on arrival but the drawing shows no location where this will be done. If it is to be done at the point of entry, the first parking spaces are only about 3 car lengths from Broomhill Road. The width of the access road allows only a single checkpoint and there is potential for cars to quickly back up onto the highway. There is no escape route shown for visitors arriving without tickets with the only route back to the road being through the parking areas. The calculation of parking demand assumes that 10% of visitors will travel by public transport. There is no evidence to support this assumption and the operators of a similar attraction at Bewl Water said that all visitors arrived by car because of its isolated location and absence of public transport. Salomon’s similarly has no public transport and is also isolated. The TA identifies a shortfall of available parking in Tunbridge Wells to provide for the intended shuttle bus users and in which case there will be more demand for parking on site. The application shows 238 parking spaces to provide for a demand of 235 cars. Even with car park marshals this is inadequate. A buffer of at least 10% of the peak demand is the minimum required and demand will be higher than estimated if fewer people than expected use public transport or park in Tunbridge Wells. The parking aisles are mainly culs-de-sac so cars getting into and out of spaces will interfere with cars getting into and out of the car park. This will be exacerbated by it operating at capacity for most of the day. Reference was made by the Makerstudy Group at a Rusthall Village Association meeting to school parties travelling by

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coach, but there is no provision for coach parking on site. Furthermore it was apparent at the staff party held last year that coaches caused major problems on the local roads. The application suggests that a shuttle bus will be provided to transfer visitors from Tunbridge Wells but no details are provided about this. There is no information about the locations of pick up points, on the size or number of buses to be provided, or any assessment of journey times, to demonstrate that there will be sufficient capacity to provide for the numbers assumed to use it. There is no information about the traffic associated with the construction and dismantling of the attraction. This will require a significant number of heavy goods vehicles, for instance to bring in the stone aggregate for the roads and paths, and to remove it afterwards. Many roads leading to the site, including Speldhurst Road are not wide enough to allow a car to pass a lorry without stopping. Two lorries would be unable to pass. This is an important consideration and is not mentioned in the report. The means of access for lorries is subject to a separate application (13/03643) for the widening of an existing and this has meant that the true implications of that application have been obscured from the Council. My clients sought to have that application also considered at this forum but were told it is not a major application. In reality it is essential for Father Christmas World and should be considered as part of this application. No parking on site is to be provided for any staff and it is intended that a shuttle bus will collect staff from pick up points in Tunbridge Wells, Southborough and High Brooms . In any event there are no details of where staff will be able to park off-site or where any staff transport pick up locations would be. Staff parking and pick up locations need to be identified so that any potential impacts can be assessed. The Transport Assessment makes no mention of highway safety nor includes any information of the existing accident record on the local roads. There are recorded personal injury accidents on all the local roads and there is no assessment of whether the development will have an impact on highway safety. Mr Peter Waller continued with the following comments: Planning Concerns about FCW The principle of establishing an attraction like FCW in Tunbridge Wells has much to commend it economically. But the Government expects planning applications be sustainable, not just in economic terms but, also social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles and these roles should not be undertaken in isolation, because they are mutually dependent. Economic growth can secure higher social and environmental standards, and well-designed buildings and places can improve the lives of people and communities. Therefore, to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions. In this case FCW would be highly damaging to the special environment of its location, not well located by means other than the car and therefore not a sustainable solution. The Location The site is remote from centres of population and public transport and not accessible on foot. Car borne access is the only way of reaching the site safely. The access from all directions via is narrow winding country lanes with poor forward visibility. The proposal runs totally contrary to

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modern planning and transport practice to seek to minimize uses that are not accessible by means other than the car. This proposal will not aid the Government’s policy of seeking a low carbon future. High Weald Area of Outstanding Natural Beauty The area is washed over by the High Weald AONB where national and local policies give great weight to conserving landscape and scenic beauty over other considerations. The conservation of wildlife, biodiversity and cultural heritage are important considerations in these areas. The essential character of the area is its peaceful rural tranquility where nature and the landscape and land form predominate. The Council’s Landscape Character Assessment shows the stream running through the proposed car park as an important contributory element to the character of the AONB, as is the Ancient Woodland opposite the site entrance and Broomhill Road is described as an historic routeway. These factors are interdependent and contributory to the overall character of the AONB and would be degraded and harmed by the FCW proposals. AONB Major Development This proposal is classified as “major development” by the Council and national policy says that planning permission should be refused for major developments in AONBs except in exceptional circumstances and where it can be demonstrated they are in the public interest. Consideration of such applications should include an assessment of:

the need for the development, including in terms of any national considerations

the impact of permitting it, or refusing it, upon the local economy;

the cost of, and scope for, developing elsewhere outside the AONB or meeting the need for it in some other way; and

any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

AONB Needs Case No specific case has been put forward of need for the development at Salomons specifically, other than a need to keep the site as a profitable going concern and so allow upkeep of the buildings. However, at public meetings they have said that the proposal will not directly benefit the Salomon’s site. The impact upon the local economy is referred to but no reason is given why such a proposal can only be operated at this sensitive location within the AONB rather than at some less sensitive and more sustainable location elsewhere in the town. Heritage The buildings, lawns and surrounding woodland are a balanced historic entity and are afforded special protection from harm to their fabric as well as their setting. MSL has produced no overriding need for FCW to be at Salomon’s rather than somewhere less damaging. This proposal would be in evidence for almost 3 months every year as it is set up, operated and dismantled with attendant heavy machinery and noise and disruption and be harmful to the setting of the buildings and gardens. as MSL’s Heritage adviser admits. If allowed it must be likely that other large scale events would follow in other parts of the year. Metropolitan Green Belt The area is within the Metropolitan Green Belt where the fundamental aim of National policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

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The FCW proposals come in two parts. Firstly,the arena activities and secondly, the car park and ancillary access and reception area and uses. The arena and structures are described as “temporary development” and, it is claimed, will not therefore impact upon the openness of the Green Belt. This interpretation is flawed, the use would be a permanent use albeit on an intermittent basis. The use would exist from 17 November to 31 December, (Planning Statement Appendix3 para1.1) a period of 45 days or 6.5 weeks and would according to MSL take 3 weeks on either side to set up and dismantle and so would be in situ for up to 11.5 weeks a year or over 22% of a year. The proposal is “inappropriate development”, which MSL’s Planning Consultant acknowledges. Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. A large part of the car park would not be temporary, but permanent development. The application is silent on what use or purpose this permanent car park and the three properties adjacent would be put to during the 45 weeks that it is not used in connection with FCW. Metropolitan Green Belt “Very Special Circumstances “ MSL claims there are very special circumstances that warrant allowing the proposal, which are that the proposal will provide a major boost to the local economy by

attracting a significant number of people to the area at an important time of the year

a good proportion are likely to spend money on local goods and services in the area outside of FCW.

It will raise the profile of Tunbridge Wells and the surrounding area.

It will provide up to 160 temporary jobs, mostly for local people.

The economic benefits to the area are estimated at close to £3 or 5 million.

The temporary nature of the proposal will not impact on the openness of the Green Belt on a permanent basis.

Metropolitan Green Belt Response to Very Special Circumstances An operation of this nature would no doubt attract large numbers of people, but most would be car borne. If MSL’s primary aim is to support business in the town then surely there are better more accessible locations closer to the rest of the business community where FCW could operate without causing major problems to the environment. Salomon’s is remote from the town and the mostly car borne visitors will find it hard to reach the town centre due to Christmas congestion MSL’s Planning consultant accepts that there is a shortage of spare car parking capacity in Tunbridge Wells. At Christmas parking and traffic conditions are very difficult and may deter possible visitors with young families from seeking to venture into the town centre as well as visiting FCW. Unemployment is low in the area so the need for new employment, while welcome, is not significantly compelling reason to approve this proposal. This use is wrongly described as “temporary” when it will occur permanently on an annual basis and harm the openness of the Green Belt, the AONB and historic assets from late October to late January every year. Much of the car park would not be temporary but a permanent feature

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Other Issues Noise The development will inevitably be a noisy, heavily trafficked use that is more appropriate in a urban location that can more easily assimilate it without harm to the essential character of the area. The application site is located in a very quiet valley where the loudest noise currently is the sound of gurgling water in the stream. While the site is rural in character, it is nevertheless close to many homes, including three within a few metres of the car park. Government policy urges Councils identify and protect such areas of tranquility, which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason. In this case the ambient sound character of the area would be spoilt for up to a quarter of every year by the construction, operation and dismantling of FCW. It is interesting to note that MSL has omitted to submit an acoustic assessment to support his claim of minimal harm to the area. Flooding. The siting of the car park in the valley, which is within a Zone 3 Flood Risk area may not give rise to an increased flood risk, but may have operational consequences for FCW. If, as is happening more frequently in our wetter winters, the valley floods it will make use of the car park difficult or unsafe to operate, then MSL will need to have contingency plans ready to cope

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QUESTIONS AND ANSWERS Q Cllr Dr Hall Asked for clarification of different areas on the site. A Mr Allen Indicated these on the site plan displayed as part of the presentation. Q Cllr Dr Hall Asked about the type of surface proposed for parking at Mill Farm, whether it was

temporary or permanent. A Mr Nightingale

Explained much of the land was currently grass paddocks. It would temporarily be covered with a plastic mesh to facilitate parking. A part of the site was already paved or consisted of an area previously used as a sand school.

Q Cllr Webb Asked if what appeared to currently be a separate one way entrance and exit to and from Salomons could be reversed, which he thought would help resolve access problems.

A Mr Nightingale

Explained that neither of these access points were proposed to be used for FCW. The entrance and exit were further down Broom Hill Road.

Q Cllr Backhouse Asked about concerns from residents that the Xmas Train would run to Salomons from Tunbridge Wells Town Centre.

A Mr Nightingale Confirmed the Xmas Train would only run around Tunbridge Wells Town Centre as it had the previous year. The transfer to and from Salomons from the railway station would be a minibus shuttle. There would be a separate train that would operate wholly within the Salomons site.

Q Cllr Mrs Thomas Asked about criticism over visibility and sight lines in relation to the proposed access. A Mr Nightingale

Accepted that visibility was not currently ideal. Some of the Leylandii would be cut back but otherwise the comments would be taken on board.

Q Cllr Mrs Thomas Asked about the length of a visit to FCW, white lines for parking, and Mother and Child parking spaces in addition to spaces for the disabled.

A Mr Nightingale Advised that each visit was timetabled to take up to 3.5 hours. There would be no white lines to avoid any permanent formalisation of parking on site. But as with the parking for many other attractions the parking could be managed through operation by competent ground staff. He would take on board the comments relating to Mother and Child space allocations.

Q Cllr Rusbridge Asked about the strategy for dealing with ad-hoc visitors who turned up without booking or who used the wrong entrance and would potentially cause a traffic jam.

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A Mr Nightingale There would be sufficient staff to re-direct visitors and sufficient turning space to avoid any blockages. Ticket sales would not be made on the door for ad-hoc visitors.

Q Cllr Webb Referred to the catalogue of objections made by the petitioners and would have

preferred to have seen a written report. A Mr Nightingale

Confirmed that he had made notes of all of the points raised by the objectors and would liaise with both planning officers and KCC Highways Officers to ensure that all of the information would be available by the time a formal report was due to go to Committee.

Q Cllr Dr Hall Asked how the wider Town would benefit if food, drink and retail provision were already provided on the site.

A Mr Nightingale Advised that the majority of retail in FCW was intended to be on a small scale incorporating local retailers and businesses.

Q Cllr Munn Asked whether the jobs would be based on zero hours contracts. A Mr Moore Stated they were unable to answer. Q Cllr Mrs Soyke Mention had been made of visiting school children and assuming they arrived in school

groups, she asked where coaches would park. A Mr Nightingale

Noted the question and although he did not have a definite answer, he suggested that they would probably need to use the main car park at the main house. This would be clarified in due course.

Q Cllr Hill As the traffic in Southborough was already chaotic from 8am to 10am and from 6pm to 10pm, what measures would be in place to avoid worsening the situation.

A Mr Nightingale

They were aware of the concerns over traffic levels on Speldhurst Road. He reiterated that attendance via timetabled ticketing would result in a controlled and steady flow. In their opinion there would only be a modest increase compared with existing traffic levels and they considered it was workable. It was not in the applicant’s interest for it to fail.

Q Cllr Rusbridge Asked the petitioners, in view of their feelings of exclusion, how they had actually been consulted.

A Mr Waller Advised that most people had found out about the event either through the Press or through neighbours. Residents in Broomhill Road were asking questions about what was intended and in particular one resident who was not notified, lived directly adjacent to the site, albeit at the end of the proposed car park. Government advice was that pre-application discussions should take place with local residents. This he felt would have dispelled ignorance over the proposals and allowed the applicant to take advantage of

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local knowledge. He was aware that there had been a number of discussions with Tunbridge Wells Borough Council but not necessarily the planning officers.

A Mr Nightingale Confirmed pre-application discussions had take place with TWBC including the planners but acknowledged that due to the tight lead-in time to plan, market and submit the application, there had not been sufficient time to consult more widely with local residents.

Q Cllr Webb Asked for confirmation that the site was considered a major development and whether it

was considered a special case. A Mr Nightingale

Agreed and confirmed that any development greater than one hectare had to be classified as a major development.

Q Cllr Dr Hall Expanded on the previous question stating that according to the NPPF a major application in the AONB should be refused unless there were exceptional circumstances and she asked what these were considered to be.

A Mr Nightingale Explained that these were fully set out in the supporting planning statement to the application. In summary, however the application would bring substantial economic benefits to the areas and as the event was only temporary, the land would be undeveloped for the most part of any year.

Q Cllr Sloan Asked how the event would be publicised. A Mr Moore

Indicated that advertising would commence in August, subject to planning permission. Advertising would be concentrated on an area within 2 hours driving time, by radio, magazines and on-line. FCW would be part of the wider range of events taking place within Tunbridge Wells in December.

Q Cllr Mrs Thomas Asked where the 160 staff would park if not on the site itself. A Mr Nightingale

Advised that details were still to be finalised as they would be dependent on where employees lived. They hoped to employ as many local people as possible and pick them up and bring them to the site by minibuses.

Q Councillor Rusbridge Asked about encouraging the use of public transport and in particular how public buses might be used to get to the site.

A Mr Nightingale Clarified that the use of public transport specifically related to arriving in Tunbridge Wells by train, where a minibus shuttle would transfer passengers directly from the station to FCW. There would not be any intermediate pick up points.

Q Councillor Webb Thought the statistics provided were contradictory and according to his own calculations an additional 175 car parking spaces would be required. He asked if the figures would be revisited.

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A Mr Nightingale Confirmed that he had taken note of the objectors’ comments and all figures would be double-checked before the application came to the Planning Committee.

Q Councillor Dr Hall

Wondered where staff would be found bearing in mind there was little unemployment in Tunbridge Wells.

A Mr Moore Advised they were looking at recruiting students returning home to Tunbridge Wells for Christmas and also looking at the retired market.

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SUMMING UP BY MR NIGHTINGALE ON BEHALF OF THE APPLICANT Mr Nightingale confirmed that he had made careful notes of all of the points raised and he was

very aware of all of the local concerns.

He pointed out that if people could not get to Salomons, the whole proposition would simply not

work and he was therefore confident that through liaising with the relevant authorities including

KCC Highways, any issues could be overcome.

He appreciated the sensitivity of the site in the AONB and Greenbelt but did not consider this

was sufficient reason to refuse the application. There would be very tangible benefits to the

wider Community as had been outlined. The event was only temporary and in his opinion the

benefits would considerably outweigh the disadvantages.

SUMMING UP ON BEHALF OF THE PETITIONERS Mr Peter Waller Commented that there appeared to be a number of unanswered points and the applicant would do well to consult with local people. He was also concerned that Councillors had been given no information before attending this forum. Finally, he considered that this was not a temporary event but a permanent one for at least three months every year to take account of both setting up and clearing away afterwards. Mrs Elizabeth Lineker Conclusions By way of conclusion, we as residents are NOT opposed to the principle of establishing Father

Christmas World in Tunbridge Wells. We do however strongly object to its proposed location at

Salomons Estate.

We support enterprise which benefits the town and local economy and believe that there could

be more appropriate sites closer to the centre of Tunbridge Wells for the setting of Father

Christmas World. A more central location would create greater economic benefits to the town

and would mean the rural site of Salomons Estate remains open and undamaged, as intended

by current legislation. Perhaps the Council and the applicant should jointly consider a change

of venue?

Father Christmas World will be a noisy, major, urban theme park in a very quiet, attractive, rural

location protected by Area of Outstanding Natural Beauty and Green Belt status. It will impact

all surrounding villages. Broomhill Road is a narrow country lane and the Estate is not served

by public transport.

We believe that Father Christmas World, at this location, would cause significant harm to the

AONB, the Metropolitan Green Belt, its Listed setting, its wildlife and historic park and garden.

There is no overriding need for this proposal at Salomon’s that justifies setting aside the very

strong presumption against development in the Green Belt

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For these reasons, in voicing concerns, the neighbouring residents should NOT be considered

NIMBY. We are all proud of Tunbridge Wells and its surrounding villages. We are asking for

responsible development, respectful of its setting.

There is real concern regarding MSL’s piecemeal approach to planning and development and

seeking planning permission retrospectively. This, in conjunction with a lack of meaningful

consultation with residents to date, creates a fear that should Father Christmas World be

approved, this would simply be the pre-cursor to other major events throughout the year.

They were grateful that this forum had been convened although they had been advised it could

not include the application on the boundary wall which they considered was pivotal to allowing

the event to take place. They therefore recommended that this separate application should be

deferred to allow consideration of both together. They also requested that consultation should

take place with the local community and any decisions should only be made after that

consultation had taken place.

CHAIRMAN’S COMMENTS Minutes of this Forum would be provided to the applicant and petitioners and published on the website. They would also be attached as an appendix to any future committee report on the application. If the applicant wished to make any changes to the application in light of comments made at this Forum, this should be done within 14 days of receipt of these minutes. A further period of consultation could take place before the application was presented to the Planning Committee. Finally, the Chairman thanked all the participants for their contributions and closed the meeting.