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Appendices 1 to 4


This response report contains comments received on Appendices 1-4.

Contents

Appendix 1: Biodiversity/geodiversity sites within Tunbridge Wells borough

Comment No.

Name/Organisation

Response

DLP_534

RSPB

Appendix 1: Biodiversity/Geodiversity sites in Tunbridge Wells borough

Paragraph 174 of the NPPF sets out that plans should map ecological networks and plan for their enhancement by identifying and pursuing opportunities for measurable net gain. This includes those mapped by local or national partnerships.

A range of partners have come together to form Operation Turtle Dove in order to halt and address the rapid decline of this species (the fastest declining breeding bird in the UK). In England, its population is halving every six years, although the situation worsened in 2017-18 when the drop was -47%. Part of the RSPB’s response has been to identify a number of Turtle Dove Friendly Zones (TDFZs). These have been scientifically selected as areas where populations are at their highest and where conservation action on the ground with farmers is targeted most effectively. The RSPB employ Advisors to work in these locations.

Tunbridge Wells boasts five TDFZs (the highest density of any district-level authority in the south-east). We ask that the attached map showing these is added to Appendix 1 in order to be consistent with Paragraph 174 of the NPPF. We are happy to provide the appropriate GIs layer upon request.

DLP_1899

Royal Tunbridge Wells Town Forum

Appendix Number: 1 

We strongly support the inclusion under the protections contained in Draft Policy EN 12 of the following LWS sites in RTW: TW21/22/23; TW45/46/48; TW24 and TW58. We strongly support similar inclusion of RNR sites: TW09 and TW13.  We strongly support similar inclusion of SLNCV sites ID03/ID18/ID07/ID08/ID13/ID19 and LNR status Barnett’s Wood. We would support the addition of Greggs Wood town green and Knight’s Wood to Local Nature Reserve status.

DLP_2924

Chris Gow

All Biodiversity and geodiversity sites within the Tunbridge Wells borough should have protected status and be excluded from any development pressure. Any area of Biodiversity and geodiversity should mean development of such areas is completely undeveloped.

The biodiversity of our land is essential for the good health of wildlife and plants, and of course farm produce. This is reason enough to exclude development of all these areas.

DLP_3724

Capel Parish Council

No sites in Capel Parish are included and no proper assessment has been completed. A proper assessment of Biodiversity and Geodiversity must be completed for the locations of the proposed developments at Tudeley (AL/CA 1), the secondary school (AL/CA 2) and East Capel (AL/CA 3 & AL/PW 1).

DLP_4389

Mill Lane and Cramptons Residents Association

Appendix Number: 1 

  1. TWBC designated “Rural Lanes” should be listed where they are adjacent to proposed built development sites - as they too are designated sites which might very likely be affected.
  2. Kent County Council “Biodiversity Priority Habitats 2012” designated sites should be listed where they are on or adjacent to proposed built development sites.

These should also include sites designated “Other Grasslands of Importance”.

DLP_4390

Mill Lane and Cramptons Residents Association

Appendix Number: 4 

  1. “Best and most Versatile Agricultural Land” should be added to the Glossary. 

The best and most versatile land is defined as Grades 1, 2 and 3a by policy guidance (see Annex 2 of NPPF). This is the land which is most flexible, productive and efficient in response to inputs and which can best deliver future crops for food and non food uses such as biomass, fibres and pharmaceuticals.

DLP_5227

Culverden Residents Association

We strongly support the protections given under Policy EN 12 to all the Local Wildlife Sites, Roadside Nature Reserves, Sites of Local Conservation Value, Local Nature Reserves and Candidate Reserves in and around Tunbridge Wells Town and in particular to our adjacent examples at Broomhill and Reynolds Lane Pastures (TW46), Great Culverden Park (ID07), Hurst Wood (ID08) and Reynolds Lane Woodland (ID13). These areas of nature conservation are greatly appreciated by our members for their environmental protection and health benefits, and recreation in those which are fully accessible.

DLP_6862

John Gibson

Appendix Number: 1

a) Lanes designated “Rural Lanes” by TWBC should be listed when they are adjacent to proposed development sites as they are very likely to be affected.

b) KCC “Biodiversity Priority Habitats 2012” designated sites should be listed where they are on or adjacent to proposed built development sites and should include sites designated “Other Grasslands of Importance”.

DLP_8146

Ashley Saunders

No sites in Capel Parish are included but no proper assessment has been completed. A proper assessment of Biodiversity and Geodiversity must be completed for the locations of the proposed developments at Tudeley (AL/CA 1), the secondary school (AL/CA 2) and East Capel (AL/CA 3 & AL/PW 1).

Appendix 2: Schedule of designated Local Green Space sites within Tunbridge Wells borough

Comment No.

Name/Organisation

Response

DLP_103

Ashurst McDermott Hall Trust

The "Ashurst Churchyard" area also includes the land owned and run by the Ashurst McDermott Hall Trust, the charity that runs Ashurst Village Hall.  This is private land owned and run by the Trust on behalf of the Village.  However the Trust feels that Green Space status may be beneficial in maintaining the land for local good.

DLP_180

Rohan Barnett

I object to the inclusion of the Standen Street Orchard which is not a community resouce. The description supplied by BPC is inaccurate and this proposal has been withdrawn from the Benenden Village Local Plan.

DLP_357

Charlotte Raleigh

I support the designation of Site No 217 as Local Green Space.

I would like to strongly support that the adjoining fields either side of the north end of Sandown Park remain NOT allocated as shown on the draft Local Plan maps. I would like to suggest that this land (despite the fact that it belongs to a private developer) should also be 'Local Green Space'. This makes sense because it could incorporate the section of Owlsnest Wood which is west of A21 and adjoins these fields. The north end of Sandown Park still retains the character of estate parkland and is a mature horse chestnut avenue that is greatly loved by local residents. The joining of this area, the part of Owlsnest Wood and Site No 217 would be a great asset to the town. I note that the part of Owlsnest Wood west of the A21 is designated EN6 Historic Environment and it would be good to see this brought into the Local Green Space for it to be properly managed and preserved for people to enjoy (As has been successful at Dunorlan Park). See your paragraph 6.46 p.376 of the draft Local Plan 2019.

DLP_543

Brachers LLP for Mrs Katherine Callas and Mr Stephen Barnes, and Mr David Barnes and Mrs Ann Barnes

Local Green Space Designation

Site known as: AS_40: Hilly Fields Benenden

We have been instructed to write to you in connection with the Council’s current consultation on the designation of certain land within the district as Local Green Space. Specifically, regarding the land referred to in the consultation document as AS_40 (Hilly Fields).

We write on behalf of Mrs Katherine Callas and Mr Stephen Barnes who jointly own the land shown edged in red on the attached plan and which constitutes the majority of the land in question. Mrs Callas has received your letter of 29th July 2019 indicating that the site is proposed for designation as a Local Green Space. Mr Stephen Barnes has not received a similar letter but is aware of the letter to Mrs Callas.

We also write on behalf of Mr David Barnes and Mrs Ann Barnes who are the owners and occupiers of the adjoining property known as St Michael’s Lodge, Iden Green Road, Benenden.

This letter sets out the reasons for the objection to the designation of the Land as Local Green Space.

NPPF and TWBC Local Green Space Designation Methodology

Paragraph 100 of the NPPF states that:

  1. The Local Green Space designation should only be used where the green space is:
  2. in reasonably close proximity to the community it serves;
  3. demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and
  4. local in character and is not an extensive tract of land.

All three of these requirements must be met before a site can be considered suitable for designation.

The Council has produced 5 Criteria for assessing Local Green Space, namely:

  1. Land is not subject of a planning permission for development;
  2. The space is not allocated or proposed for development in the Local Plan;
  3. The space is not an extensive tract of land and is local in character;
  4. The space is within close proximity of the community it serves; and
  5. The space is demonstrably special to the local community and holds particular local significance

If any of these criteria are breached, then the site should not be allocated.

Having regard to the NPPF and the Council’s criteria we would comment as follows.

  1. NPPF paragraph 100(a) and TWBC Criteria 4

    The Land does not serve any given community.   As such it would be incorrect to say that it is proximate to a “community which it serves”. Whilst it is acknowledged that there is a footpath which runs across the land the publics does not have a right of access to the remainder of the field, as such there is no meaningful public right of access to the Land.

    At its closest point the Land is located approximately 250m to the south of the main road through Benenden. Our clients’ part of the Land is a further 50m to the south. There are numerous other sites which have been identified in the Council’s draft allocation which are closer to the village and which are more accessible.

  2. NPPF paragraph 100(b) and TWBC Criteria 5

    It is noted that the Council’s stated reason for this criterion being satisfied is as follows:

    “This area is a large open space accessible by a public right of way. This area is privately owned but is used by the village for informal recreational activities (such as walking, dog walking, etc.).”

    This is incorrect. As indicated above, there is no right of public access to the Land and any use of the land for informal recreational activity is unauthorised.

    There is a footpath across the field, but this does not authorise access to the Land itself. In the consultation document at page 8 the existence of this footpath is identified as the reason for satisfying criterion 5. However, this footpath does not set the land apart from the many fields across the district which are similarly bordered or crossed by public footpaths.

    The Land is also subject to a Farm Business Tenancy it is used for grazing livestock, currently sheep, but has previously been used for grazing cattle and horses. Any use of the land for informal recreational activity which might be taking place is not authorised. Indeed, additional use for dog walking would be detrimental to the lawful agricultural use of the land.

    The stated reason does not justify designation. It seems to be predicated on the assumption that designation as a Local Green Space will facilitate access for walking or dog walking. However, designation does not bring with it any rights of access, as your letter of 29 July 2019 clearly states.

    In paragraph 3.11 of the Local Green Space Designation Methodology the Council has set out sub-criteria for Criterion 5. Addressing each of these in turn we would comment as follows:

    • The site is not visible from the existing townscape or settlement and therefore does not contribute to its visual attractiveness. We are not aware that the land is mentioned in any relevant assessment nor that it contains any particular points of interest or historic buildings, nor that it is referred to in literature or art.
    • There are no historic buildings or landscape features on the Land. Nor, so far as we are aware has it played an important role in history . . . etc.
    • The site is not used for playing sport. In contrast there are other sites in the Council’s proposal locally which do meet this criterion. The public does not have access to the land beyond the footpath.
    • The site is not particularly tranquil as it is adjacent to Mr and Mrs Barnes residential curtilage including a garden and tennis court.
    • The land it not particularly rich in wildlife as it is actively farmed.
  3. NPPF paragraph 100(c) and TWBC Criteria 3.

When considering each of the sites under consideration in the Benenden area it is apparent that AS_40 (Hilly Fields) is the furthest from the village and juts out into the open countryside. As such it is the least local in character. There is nothing to particularly distinguish it from any other farm land in the vicinity which might justify its designation as Local Green Space.

Conclusion

For the above reasons we consider that none of the factors set out in paragraph 100 of the NPPF have been satisfied with regard to site AS_40 (Hilly Fields). We also consider that the site fails to meet Criteria 3, 4 and 5 of the Council’s own Designation Methodology.

As indicated above, if the site fails to meet any one of the criteria then it should not be considered suitable for designation. Given that it fails to meet any of the criteria in the NPPF and three of the five criteria in the Council’s own policy it should not be taken forward for designation.

Accordingly, we request that the site is not designated as Local Green Open Space.

Brachers LLP
22nd October 2019

DLP_562

Mr Mike Prentis

I refer to the letter dated 29 July 2019 from the Planning Officer addressed to myself, and the request for Representations from the Head of Planning Services (email dated 16 October 2019).

My wife and I own site 101 now proposed as Local Green Space. This site is subject to a tenancy. Whilst my wife and I are happy to see this site designated as Local Green Space there is a small part of this land we would request to be excluded. The area we would like to see excluded is West of Oakley and Pedler's End, and bound to the West by a line which links the end of the garden of The Stores and half way along the Northern boundary of Shepherds Lawn, roughly as Westerly as the Western most part of the buildings which form Shepherds Lawn.

This small parcel of land is one on which we may one day seek to obtain planning permission for a one or two storey residential property, probably which we could occupy when we are perhaps too old to live in our existing property (Benyons, which we have lived in for 20 years). Clearly any such development would have to have limited impact on adjoining properties. We are not seeking permission for such a development now, and indeed we may never do so. However my concern is that if this small land parcel is designated as Green Space now, we will never be able to seek the possible small development I have outlined; thus the email.

I hope this is clear, and I would happily clarify the above if you would like. Please also let me know as soon as possible if this format of response is not acceptable; I am obviously keen that our views are properly taken into account.

DLP_728

Jim Henley

Summary

It is strongly submitted that the Goudhurst Parish Site 102 – Goudhurst Green Field (North of Church Road) should not be allocated as a Local Green Space for the following reasons:

  1. The Goudhurst part of the local plan is not aligned to the requirements of Paragraph 99 of the NPPF that requires “Designating land as Local Green Space should be consistent with the local planning of sustainable development and complement investment in sufficient homes, jobs and other essential services.”
  2. The site does not meet the criteria for being a Local Green Space as it cannot be specifically demonstrated that this site is demonstrably special to the local community “and” holds a particular local significance.
  3. The methodology of how sites are chosen for assessment are not complete, are subjective and unclear. Leading to potential bias and ultimately do not meet the strategic objectives for a long-term plan.

Detailed

  1. A small amount of development land has been allocated / forced upon the Goudhurst area, which is all in the immediate term potentially prior to the approval of the Local plan. Further restrictions are being put in place to restrict any future development. This will not meet the longer-term strategic needs of the community or the identified areas of housing needed. Therefore, it is submitted that:

    The plan has not identified sufficient land in suitable location to meet identified development needs, and therefore the Local Green Space designation should not be used in a way that undermines the aim of Plan making – Local Green space Designation Methodology July 2019 Criterion 2:

  2. With reference to the requirement that a site is ‘demonstrably special to a local community and holds a particular local significance’, the NPPF provides the example that such sites may be capable of fulfilling such criteria due to its; - beauty,  - historic significance,  - recreational value (including as a playing field), - tranquility, or - richness of its wildlife.
    • With regards to the beauty of the agricultural land opposite Tattlebury Green, it does, as with all other land around the village, fall within the High Weald Area of Outstanding Natural Beauty (AONB), but in this instance is no different to sites that haven’t been allocated as Local Green Spaces, within the Goudhurst proximity area. The views on this site would not be protected by the status of a green field site as the main aspects are from the footpaths WC28 and WC30, looking to the North West.
    • With regards to the historic significance, the Borough Local Development Plan has not referenced this site as having any historic association with the settlements of Goudhurst or Tattlebury. The site is currently and has always been known to have been used, as it has been described, as ‘agricultural’ land. In addition this site has not previously been considered to be worthy of mention within the Conservation Area Appraisal for the locality unlike the adjacent parcel of land known as Tattlebury Green (proposed Local Green Space area 103).
    • With regards to the recreational value of the agricultural land opposite Tattlebury Green, it is clear that this land is, by definition, agricultural land, and so does not have recreational value in the same way that a playing field may provide.
    • With regards to the tranquillity of the site, the land abuts the busy A262 highway and could therefore not be described as tranquil and therefore could not reasonably be said to be demonstrably more special to the local community than other land surrounding the village, due to its tranquillity.
    • With regards to the richness of the wildlife of the site, it is respectfully submitted that the land is actively used for agricultural purposes and therefore does not differ from a wildlife perspective from any other field used in the community for that purpose.
  3. The methodology for the selection of sites is not complete. There are a number of sites that have not gone through any assessment. The selection is random and based on the opinions of “In-office selection”. This is not appropriate for a strategic Local planning review.

The criteria laid out in the Local Green Space Assessment is not clear, what exactly does a tick mean in the context. The definition on the document is ambiguous in relation to the context being explored.

DLP_888

Mr David Cooper

Re Appendix 2 site number AS_81 (Calverley Park East) page 516: this is intended to treat Calverley Park (there is no ‘east’ or for that matter ‘west’) as a Local Green Space under Policy EN17. The land at Calverley Park is listed Grade II (the buildings are all Grade II*). Para 2.4 of the Local Green Space Design Methodology contains an extract from the National Planning Practice Guidance states that "different types of designations are intended to achieve different purposes. If land is already protected by designation, then consideration should be given to whether any additional local benefit would be gained by designation as Local Green Space." Calverley Park’s listing (with Calverley Grounds, list entry no.1000266) places it in the class of nationally important sites and affords it protection under the national planning policy framework, such that any harm or loss of the asset which can include alteration or development, should require convincing justification and that  substantial harm or loss should be exceptional. I.e. there is already a presumption that the land will not developed, altered harmed etc. Furthermore, Calverley Park is private land, to which the public have strictly restricted permissive access limited to the carriageway and paths, is closed on Sunday afternoons and Good Friday, and is not a public recreation space. It is actively managed by the Calverley Park Association and Calverley Park Trust, to protect its rare example of unimproved grassland and also its veteran and newer trees having regard to its listing and wider importance in Decimus Burton’s Calverley Park development of villas in parkland. The parkland will also fall within the broader umbrella environmental policies for the Natural Environment under the Draft Local Plan. As such, the land at Calverley Park is already subject to very significant levels of protection and there are no additional local benefits to be gained by its additional designation as Local Green Space, so it should therefore be removed from the list of Local Green Spaces under Policy EN 17.

DLP_1031

Calverley Park Association

Site number AS 81, Calverley Park

The National Planning Practice Guidance (NPPG) explains that Local Green Space designation aims to protect sites of local community importance from future development.  “Designation is a way to provide special protection against development for green areas of particular importance to local communities.” It also states that “if land is already protected by designation, then consideration should be given to whether any additional local benefit would be gained by designation as Local Green Space”.

Historic England’s listing criteria for Historic Parks and Gardens, specifies that “all sites included on the Register of Parks and Gardens must hold a level of significance defined as ‘special historic’ interest in a national context.” Calverley Park is so listed as Grade II.

We therefore oppose designation of Calverley Park as a Local Green Space becausethis designation is not intended to cover nationally important sites that are already wholly protected by alternative designations. 

Calverley Park’s existing protection from the threat of future development includes:

  1. Listing on the Historic England 'Register of Parks and Gardens of Special Historic Interest in England' as Grade II. (An application for a higher listing has been lodged with Historic England.)
  2. Calverley Park Conservation Area as designated by TWBC.
  3. Paragraph 194 of the National Planning Policy Framework states that “Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification. Substantial harm to or loss of: a) Grade II listed buildings, or Grade II Registered Park or Garden, should be exceptional; b) assets of the highest significance, notably ……… Grade I and II* listed buildings, Grade I and II* Registered Parks and Gardens, and World Heritage Sites, should be wholly exceptional.” Calverley Park includes 27 Grade II* listed buildings within a Grade II Park setting. It is a nationally important example of late Regency town planning where equal emphasis was placed on the landscape and the buildings. Any development within this setting would have to meet the “wholly exceptional” test of paragraph 194 above.
  1. TWBC policies in the Draft Local Plan including EN6 Historic Environment, EN7 Heritage Assets,  EN 11 Net Gains for Nature: biodiversity,   EN 12 Protection of Designated Sites and Habitats, EN 14 Trees, Woodlands, Hedges, and Development,  EN 15 Ancient Woodland and Veteran Trees, EN 18 Landscape within the Built Environment and EN19 Arcadian Areas . In particular policies EN 14 and EN15, offer very relevant protections to the parkland. Calverley Park contains a large number of veteran oak trees as defined by Natural England. Paragraph 175 of the NPPF gives the same protection to habitats with veteran trees as it does to ancient woodland. The parkland has not been cultivated or grazed in the last 200 years. Unimproved grassland of this type is usually the most species rich, as most wildflowers grow best where soil nutrient levels are low. It is now a relatively rare habitat: the last ecological assessment described the grassland of the Park as “a remarkable survival from the early 19th century and therefore precious in conservation and ecological terms”. The High Weald ANOB, shows Calverley Park as a "wildflower meadow" on its map of features which contribute to the character of the ANOB. Kent County Council’s Priority Habitat survey also shows part of the Park as a “grassland of importance”.
  2. The Local Green Space Assessment recognises that Calverley Park as of “particular local significance because of its richness of wildlife.” But it goes on to incorrectly describe the Park as “an important open space used by the local community for informal recreational activities (e.g. walking, dog walking, etc.). This is completely wrong and contrary to the successful management of this space. To keep the nutrient levels low, residents are required to ensure that they bag and remove any dog faeces.  Unfortunately, non-residents usually do not and, for this reason, signs at both ends of the Park make it clear that visitors may not bring dogs into the Park. To be clear, Calverley Park is not available for “dog walking” by members of the public.
  3. The parkland gains further protection through being owned by The Calverley Park Trust whose objects require "good husbandry of the mature rural landscape of the Park … [and] a programme of planting for the future emulating where possible the style and species instigated by Burton in the 1830's". Management of the Park is by the Calverley Park Association whose programme includes provisions for the maintenance and enhancement of its rich wildlife and unimproved grassland. There is no public right of way through the Park and its gates are closed every Sunday afternoon and all day on Good Friday.  At other times the general public is welcome to walk through the Park, providing that they keep to the carriageway or the main path across the parkland.  To protect the grassland, the parkland is not available for picnicking or other general “informal recreational activities”. This limited footfall preserves the tranquility of the parkland and its importance as a wildlife habitat.  

EN17 may provide valuable protection from development to those areas without any other protection.  However, the approach taken to treat all such open spaces as if they had no other protection either by their owners or in law, has given rise to errors and inconsistencies.

As a result, The Calverley Park Association and the The Calverley Park Trust object to the proposed Local Green Space designation for Calverley Park as it is a site of national importance and is already more than adequately protected (see above).  We request that Calverley Park’s designation as a ‘Local Green Space’ be removed together with its entry in the Local Green Space Assessment since this is incorrect and potentially damaging to this delicate and historic ecology. This document also erroneously called Calverley Park, “Calverley Park East” which is an incorrect name and should also be removed.

DLP_1900

Royal Tunbridge Wells Town Forum

Appendix Number : 2 

We support the inclusion of all eligible sites across the Borough and welcome the added protection that designation as a Local Green Space will bring.

DLP_2660

Benenden Parish Council

Please note that the following sites have not been submitted by Benenden Parish Council:

Benenden:

AS_49 The Grange Grounds

Iden Green:

AS_48 North - Standen Street Community Orchard

DLP_2923

Chris Gow

In order to protect all designated green spaces I suggest Tree Preservation Orders are placed on all trees in these areas, as the default condition for  trees in green spaces, parks and all amenity spaces.

Thus trees would have a default protected status, and any felling lopping or pruning would need a specific permission.

This would make the status of trees in the landscape important and significant. The value of preserved status would deliver the best chance to mitigate the CO2 emissions, and promote the best opportunity to make a contribution to offset global warming.

The council have signed up to the Climate Emergency, and as a sign of their committent to making a contribution to climate change and global warming, delivering the enhanced status for all trees in the borough public space and placing Tree Preservation Orders on the trees would make a very clear statement.

The council may well decide to go further and place Tree Preservation Orders on every mature tree in the Borough and that indeed would be a statement, one that may well set the lead throughout the UK.

DLP_3725

Capel Parish Council

Site 27: Whetsted Wood was submitted by Paddock Wood Town Council to be designated as a Local Green Space in the dLP (see Local Green Space Assessment page 29), however, it was not selected with the justification being “There is insufficient evidence that this site meets the designation criteria, is already sufficiently protected under other designations, and is to be an allocated site in the new Local Plan

Clearly, it is not sufficiently protected by its status as Ancient Woodland (see Tunbridge Wells Borough Landscape Character Assessment LCA 13 – Paddock Wood / Five Oak Green Low Weald Farmland p.127) or the land would not be included in Policy AL / CA 3 & AL / PW 1.

Capel Parish Council requests that this area is designated as a Local Green Space and protected from development.

Site 24: Green Area with Village Sign was not designated as a Local Green Space, the justification being that “This area was not considered as it is already sufficiently protected under other designations”.

Capel Parish Council requests that this area is designated as a Local Green Space and protected from development.

DLP_3996

Lamberhurst Parish Council

Local Green Space AssessmentAS_35 – Brewer Street South Allotments

LPC would like to remove AS_35 from the designation as a local green space. The Council is the landowner and it may be at some time in the future that this area may be needed to accommodate car parking. It is not a 'statutory allotment' and was given to Lamberhurst Parish Council to be used as allotments or parking for allotments in 2003.

DLP_5228

Culverden Residents Association

We strongly support the inclusion of all the identified sites in Royal Tunbridge Wells as Local Green Spaces, including our adjacent Green Spaces Woodbury Park Cemetery (196), Great Culverden Parkland (197), St John’s Recreation Ground/Park (216) and the adjoining St John’s Meadows (AS 80) now part of the park. We think that the well-used Reynolds Lane Allotments at the top of Reynolds Lane before its junction with Culverden Down should be added to the list of Green Spaces as other allotment sites in the town have been listed.

DLP_5574

Rusthall Parish Council

Local Green Space

There are four areas within the Parish that Rusthall Parish Council specifically designate as Local Green Space to be protected from development.

Tunbridge Wells Golf Course

Notwithstanding its Green Belt status and its parts that are classified as Archaeological Potential, Conservation Area and Ancient Woodland, Rusthall Parish Council recognises its foremost benefit as a green open space buffer zone separating Rusthall Village from its large urban neighbour, Royal Tunbridge Wells.

With this regard Rusthall Parish Council’s policy is to rigorously oppose development of the golf course.

Southwood Rd Allotments

Southwood Rd Allotments Extension

Wickham Gardens Allotments

All three allotment sites are legally classified as Statutory Allotments.

Noting the measure of protection afforded them within the law they remain vulnerable to future development. Rusthall Parish Council recognises their value to our community to be critically important to the mental and physical health and wellbeing of its residents throughout the age spectrum.

Rusthall Parish Council’s policy, as owners of these sites, is not only to oppose but rigorously defend these allotment sites from development, for today’s residents and future generations.

We respectfully request Tunbridge Wells Borough Council note Rusthall Parish Council’s policies relating to Local Green Space Designations and incorporate these policies within the new Local Plan.

DLP_6064

Kember Loudon Williams for Cranbrook School

Our response relates to the inclusion of Rammell Field, Bakers Cross (Site No.36).  Please see KLW report (Chapter 7) for more details.

[TWBC: see full supporting statement attached to this comment. Chapter 7 is copied below]:

7 Rammell Field

Relevant Policies: STR1, STR/CRS1, EN17

7.1 The site in question is an existing ancillary playing field owned by Cranbrook School and used infrequently for rugby purposes. It is relatively remote from the main School campus and cut off from it by the main road (Bakers Cross). It is well within the limits to built development for Cranbrook and the Conservation Area boundary runs through the front of the site.

7.2 The field is surrounded by residential properties and the prevailing character is residential, with the exception of Rammel Boarding House & Tippins cottage to the west of the field. The field is set between and within close proximity to many notable listed buildings along the Hill and Bakers Cross, within the Conservation Area. The Conservation Area Appraisal Townscape Analysis also identifies significant tree groups opposite the site to the north, and along the western boundary to the field at the front. The Map below (Figure 8) has been taken from the Cranbrook Conservation Area Appraisal and shows the boundary to the Conservation Area.

[TWBC: for Figure 8 Map showing Cranbrook Conservation Area Boundary, see full supporting statement].

7.3 The Conservation Area Appraisal notes the site as having particular importance in providing a rural feel to the approach of the town from the east and the fact that the field is designated at a local level as an “important open space” in the 2006 Local Plan. This is further supported by TWBC in their recent Local Green Space Assessment where they proposed to designate Rammell Field in its entirety as a Local Green Space. The reasons given by TWBC for this designation were due to its visual prominence in the local community and its contribution to the character/setting of the settlement.

7.4 Notwithstanding the perceived community and visual value of the field, the land is privately owned and is gated, with any use by the wider community at the discretion of the school. Furthermore, by reference to historic aerial images, the site has been bordered to the south and south-west by housing since at least 1960 and accordingly has little or no broader visual relationship or contiguity with the wider, rural AONB landscape.

7.5 The field was previously considered under the SHELAA and Sustainability Appraisal, site reference 132, for its potential to accommodate housing development. However, it was concluded that the site was unsuitable as a housing allocation for a number of reasons, namely for heritage and landscape reasons. It was felt that the site makes an important contribution towards the setting of the Conservation Area and therefore it scored negatively in terms of heritage. Furthermore, it was suggested the development of the site would result in the loss of a historic field in the AONB, which resulted negatively on the landscape score.

7.6 Cranbrook School considers that the field remains a suitable and sustainable location to accommodate new housing and is promoting the inclusion of part of the field as an additional future housing allocation within the Local Plan. It is considered that in line with the diagram below (Figure 9) showing proposed land use, that the front part of the site should remain designated as Local Green Space, as per the recommendation under draft Policy EN17, but the rear section of the field be dedicated to housing development.

[TWBC: for Figure 9 Map showing proposed housing allocation at Rammell Field, see full supporting statement].

7.7 The recognised matters of importance in terms of the sites characteristics i.e. heritage and landscape features relate predominantly to the front section of the field. The retention of this part of the field as a Local Green Space, with additional landscape buffer beyond the Conservation Area boundary, will continue to provide the visual and landscape benefits to the setting of the Conservation Area, but will also offer wider community enhancements as a public open space for use by the local community. It should be noted that the dimensions of the field are such that it is very deep relative to its width (average depth of 180m approx.). Therefore, the visual significance of the rear part of the field is considered of lower value than the front portion.

7.8 In terms of the remainder of the site, this is considered a suitable location for housing, including affordable housing, potentially including key worker and/or local needs housing. Retaining a mixed and economically active population is a challenge with rural towns such as Cranbrook, owing to the affordability issue relating to its established housing stock. The provision of suitable lower cost housing to respond to local housing needs responds to both the TWBC Housing Needs Survey 2018 and the recent independent AECOM Housing Needs Assessment 2017 (as included within the draft Cranbrook and Sissinghurst Neighbourhood Plan). The draft Cranbrook and Sissinghurst Neighbourhood Plan includes a requirement of approximately 300 affordable homes made up of mostly 1-2 bedroom and some 3 bedroom properties.

7.9 Given the established residential pattern of development adjoining the site, a net yield of between 40-50 dwellings per hectare on the part of the site allocated for development has been identified as being appropriate. The size of proposed developable area measures approximately 1.1ha and therefore around up to 50 units should be considered, subject to design and landscaping considerations, which is less than the Housing Capacity Assessment yield identified by Tunbridge Wells in 2015. The potential for some apartments towards the south of the site should be considered but designed sensitively and incorporating a suitably ‘domestic scale’. Access is considered able to be achieved via Frythe Way, with public access into the front park area remaining via Bakers Cross.

7.10 On the basis of the above comments, we would urge TWBC to consider adapting its draft policies STR1, STR/CRS1 and EN17 to account for this additional housing and public space provision.

DLP_7017

Turnberry for Hadlow Estate

[TWBC: this comment relates to representations on AL/CA 1: Tudeley Village].

Policy AS/ 60 Private Burial Ground and Policy AS/ 64 Ancient Orchard

Although we are not opposed in principle to the designation of Local Green Space and there is no question that these spaces will be retained, particularly Site AS/ 60 given its status as the family’s private burial ground, we reluctantly object to the designations as currently proposed. In the course of the development of Tudeley Village there may be minor highway works and landtake required which could alter the current boundaries of the two spaces, and so the proposed designations are premature.

We would support the designation of these spaces once the detailed extent of the Masterplan is known, and indeed we have already identified the importance of these sites in our initial ecological appraisal as set out in Section 3 of this document. Despite their recognised importance and contribution to the area, we would oppose making spatial distinctions until exact boundaries are known and understood.

[TWBC: see full representation].

[TWBC: see also Comment Numbers DLP_6996, 7003-7009, 7013-7017 and SA_128]

DLP_8147

Ashley Saunders

Site 27: Whetsted Wood was submitted by Paddock Wood Town Council to be designated as a Local Green Space in the dLP (see Local Green Space Assessment page 29), however, it was not selected with the justification being “There is insufficient evidence that this site meets the designation criteria, is already sufficiently protected under other designations, and is to be an allocated site in the new Local Plan

Clearly, it is not sufficiently protected by its status as Ancient Woodland (see Tunbridge Wells Borough Landscape Character Assessment LCA 13 – Paddock Wood / Five Oak Green Low Weald Farmland p.127) or the land would not be included in Policy AL / CA 3 & AL / PW 1.

I requests that this area is designated as a Local Green Space and protected from development.

Site 24: Green Area with Village Sign was not designated as a Local Green Space, the justification being that “This area was not considered as it is already sufficiently protected under other designations”.

I requests that this area is designated as a Local Green Space and protected from development.

DLP_8284

Ashurst McDermott Hall Trust

We have consulted with our committee and would like to make clear our position and submit a formal comment on both the Ashurst Churchyard and Ashurst Sports Field.

Ashurst Churchyard (area 294):

  • The area on the plan and it’s name are factually incorrect.  Only a small part, probably less than ¼ of the total is owned by the Church and is the Churchyard.
  • The area is made up of a number of different sections under separate ownership:
    • Churchyard (northern side, around church, along A264)
    • Common Land (to East of Churchyard along A 264 forming a triangle)
    • Public Road (the old A264 loop running around the south and west of the church & common land)
    • Ashurst McDermott Village Hall, car park and gardens (west and south of church)
    • Private Garden of the Minoprios (to west of village hall)
    • Private Garden of the Woodhouses (along Claytons Lane)
  • We believe the area has been decided upon using very old and erroneous maps, and if anyone actually visited the site it would be obvious that large parts of it could not possibly be correctly proposed for Green Space
  • The Committee does not believe there would be any benefit in the Village Hall and Grounds being made a Green Space
  • The area is already well covered by the Green Belt and Area of Outstanding Natural Beauty regulations
  • All the Village Hall Trust’s property deeds have been placed in the custody of the Charities Commission.  Therefore the space has yet another level of protection
  • Therefore we do not understand the need to add the Green Space attribute as well, since it seems unnecessary.
  • As mentioned previously, the private, fenced/hedged gardens of the Minoprio and Woodhouse families should also be removed from the proposed area for Green Space.

Ashurst Sports Field (area AS_63):

  • This area is wholly owned by the Ashurst McDermott Hall Trust
  • The Committee does not believe there would be any benefit in the Ashurst Sports Ground being made a Green Space
  • The area is already well covered by the Green Belt and Area of Outstanding Natural Beauty regulations
  • All the Village Hall Trust’s property deeds have been placed in the custody of the Charities Commission.  Therefore the space has yet another level of protection
  • Therefore we do not understand the need to add the Green Space attribute as well, since it seems unnecessary.

DLP_5277

Susan Lovell

Green Spaces - I am concerned about the green space/rest area behind the Wesley Centre as it has been labelled as a potential development area and giving us a local green status may frustrate the potential. This should be labelled as a local green space and kept that way. Otherwise, there is potential for building on that site which is not what local residents want.

I am concerned about the Mascalls school playing field being given as insufficiently evident as a local green space. I would hope that this would not be built upon.

I’m also concerned about the natural woodland behind Warrington Road/Heather Bank 1.27 ha of natural woodland - this is important wildlife habitat and should be protected.

There is ancient woodland, ponds, and meadows to the south-east of Mascalls school, bounded by Mascalls Court road and Chantler’s Hill (including a public footpath.) It should be treated as a local green space.  This area is not marked on your local green spaces assessment.

Paddock Wood Primary School’s playing fields, AS_54, should be marked as a green space and protected.

Appendix 3: The Monitoring Framework

Comment No.

Name/Organisation

Response

DLP_1901

Royal Tunbridge Wells Town Forum

Appendix Number: 3 

We have no specific comments to make in addition to those already made in relation to numbered policies in the Draft.

DLP_2477

TWBC Property and Estates

TWBC

EN7 Monitoring

Unless there is a regular survey and review of possible designated heritage assets, this is unlikely to be measurable. there is probably a finite number of heritage assets that would qualify for designated status.

If the target is about better recording and access to the data as set out in para 187 of the NPPF, then that is fine. Wording of indicator will need adjusting.

DLP_3726

Capel Parish Council

the Monitoring Framework for Strategic Policy STR 4 (Green Belt) is unclear. What does the Indicator “65% or more appeal decisions support TWBC conclusion on Policy STR 4 (if relevant to appeal)” actually mean and how does it indicate whether the Green Belt has been protected from inappropriate development?

DLP_4221

Tunbridge Wells District Committee Campaign to Protect Rural England

Please see our comments on the relevant policies.  We have not had the time to scrutinise the proposed monitoring framework in detail but will aim to do so at Reg 19 stage.

Many of the targets and indicators proposed appear to us to be weak or insufficient.  65% is a pretty low indicator for appeal decisions (STR2, 4 and 8).  the targets and indicators for essential infrastructure and connectivity (STR5) are particularly insufficient.  On transport and parking (STR6) there need to be targets and indicators for active travel.  Why does the indicator for STR 8 (conserving the environment) refer to STR4?

DLP_8148

Ashley Saunders

the Monitoring Framework for Strategic Policy STR 4 (Green Belt) is unclear. What does the Indicator “65% or more appeal decisions support TWBC conclusion on Policy STR 4 (if relevant to appeal)” actually mean and how does it indicate whether the Green Belt has been protected from inappropriate development?

Appendix 4: Glossary

Comment No.

Name/Organisation

Response

DLP_732

Dr P Whitbourn

Your definition of a listed building is wrong, and not in accordance with the Act of Parliament quoted, in that it omits the word "special". Section 1 (1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 specifically refers to the listing of buildings of special architectural or historic interest, and the word "special" is the key difference between Locally listed buildings of architectural or historic interest, and statutorily listed buildings of special architectural or historic interest. Both are, of course, important in the context of a major historic town such as Royal Tunbridge Wells, but different statutory provisions apply, and the distinction is thus important.

DLP_1902

Royal Tunbridge Wells Town Forum

Appendix Number: 4 

The glossary is a very useful inclusion which might be worth also separately posting on the Planning pages of the TWBC website.

DLP_6864

John Gibson

Appendix Number: 4

“Best and most Versatile Agricultural Land” should be added to the Glossary. The best and most versatile land is defined as Grades 1, 2 and 3A by policy guidance (Annex 2 of the NPPF). This is land that is most productive and efficient in response to inputs and can best deliver future crops for food and non-foods uses such as biomass, fibres and pharmaceuticals.