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Section 2: Setting the Scene


This response report contains comments received on Section 2: Setting the Scene.

Contents

Setting the Scene

Comment No.

Name/Organisation

Section or paragraph number(s)

Response

DLP_24

Darren White

 

difficult to comment when you cant view the section opposite

DLP_1459

Mrs Wendy Coxeter

Paragraph numbers 2.7, 2.8, 2.11, 2.22, 2.32 plus procedure for submitting comments

Comment relating to the procedure for submitting comments on the Draft Local Plan.

This is an impenetrable procedure designed to dissuade comment from an already ‘battle weary’ community besieged with planning applications. I know that a few members of our community will be able to work online and offline to complete the document you have provided. Those who do put something on paper will undoubtedly complete the process in a way that you do not consider valid and others will not comment. You may interpret this as disinterest I fear but our community is anything but disinterested.

I have concerns over your Consultation Process. I was unable to attend the public event but I hear that you ran out of material for residents to take away. It takes 4 maybe 5 clicks to reach the point that residents can comment on the document and I believe that to be against the principles of consultation.

2.7 It is frustrating to see us aligned with towns such as Cranbrook and Paddock Wood when we are a village. Drawing false comparisons does not reflect well on any of your arguments for substantial development. From a local point of view, this is a fundamental factual error and invalidates the whole document from the outset. Our village has been incorrectly classified as ‘urban with rural features’ in the 2016 Classification and as 100% of our village is within an AONB we cannot possibly be classified as urban.

2.11 As, up until quite recently KCC Highways have been unable to maintain satisfactory road surfaces throughout our village and South East Water have failed to control their sewerage systems there is little faith in the infrastructure needs associated with new developments will be assessed or addressed, let alone in a timely fashion ahead of development.

2.32 The Draft Local Plan contains proposals which will have an unacceptable adverse impact upon the character and setting of the natural and built environment of the borough’. Your failure to protect the AONB is noted.

DLP_1593

Mr Raymond Moon

 

Section 2.Setting the Scene. Sustainable Development. OBJECT. 2.13-2.16 Infrastructure. 2.17-2.22

2.13-2.16. The sustainable aspects  of the Draft Plan are laid out in the criteria of sustainable development. It is clear in the plan that the present infrastructure for over 4,000 new house in Paddock Wood is not sustainable with out substantial upgrades in the present Surface Water and Foul Water network and extension to the present sewage management site to the north of the railway. There is not any detail as to who will pay for this and when it will be implemented. i.e. before the houses are built.

The risk of future flooding in Paddock Wood at some of the allocated sites is high with the threat of climate change and many have present flood risk designations.

Infrastructure 2.17 - 2.22

The present infrastructure can not cope with the already agreed developments in Church Road, Green Lane & Badsell Road (Over 900 houses.) How can then the present infrastructure  cope with the proposed 4,000 houses in the draft plan. Any mitigation proposed by the present utilities such as Southern Water should be in place before any houses are built. Also there is no mention of the provision of new water supplies for the proposed new houses in the plan. These utilities need to give evidence that they can provide the new infrastructure  and time scales when they provide the  new network in the Draft Plan.

DLP_1639

Richard Bysouth

 

Transport 2.23:

The A26 (St John's Road) in particular needs a proper plan to reduce traffic and significantly reduce pollution levels. I have to walk along here every day and it is unbearable. There are far too many HGVs using the road, but it is unclear why - they seem to be through traffic. The dualling of the A21 didn't seem to make any difference - in fact, I would say that the traffic has increased since this was completed. 

Transport 2.25:

"...by promoting non-motorised forms of travel, including walking and cycling..." Agreed, but promoting walking and cycling will not have any effect on the numbers of HGVs on the A26, which must be creating much of the pollution. Additionally, are all of the buses as clean (non-emitting) as they could be? We have far too many older diesel-powered buses using the roads in Tunbridge Wells.

Transport (additional):

Missing from the transport section seems to be any mention of stopping "rat runs" through existing roads, which could easily get worse through increased usage from additional vehicles (resulting from new developments).

DLP_1684

Frittenden Parish Council

Section 2 - Paragraphs 2.13, 2.17, 2.23 & 2.45

2.13 - On the basis that sustainable development is a key theme, we would comment that the quantum of housing allocated specifically to Cranbrook, Sissinghurst and Hawkhurst appears disproportionate to those settlements and the infrastructure available in those settlements.

2.17 - In settling the allocation for Cranbrook and Sissinghurst, has the Council considered that the infrastructure in those settlements not only has to support the increased population in those settlements, but also the increased population in surrounding settlements that rely on the infrastructure and facilities in Cranbrook? There are many villages and hamlets that have no shops, doctors surgeries/dentists and leisure facilities etc that rely completely on Cranbrook. The concern is that the overall impact of additional housing in the wider Cranbrook area will result in the infrastructure not being able to support the level of growth proposed. Specifically, doctors surgeries in the locality are already oversubscribed and the provision of additional healthcare facilities should be a priority.

2.23 - It is likely that a significant proportion of the increased population in Hawkhurst, Sissinghurst and Cranbrook and surrounding villages and hamlets will travel for employment due to the limited employment opportunity in these areas. We are concerned about the impact on the capacity of the rural road network to handle the increase in traffic and the volume of additional traffic that will inevitably need to travel to and from Staplehurst Rail Station as the main option for commuters. We realsie that Staplehurst Rail Station is not in the Borough, but the capacity is key for the east of the Borough. Has this been taken into account?

2.45 - The Weald Leisure Centre in Cranbrook is currently borderline fit for purpose serving the current population in the area. For the east of the Borough this is the only facility available outside Tunbridge Wells. Ensuring the provision of appropriate leisure facilities not just for Cranbrook but for the wider area should be a key priority.

DLP_2720

Paddock Wood Labour Party

 

Section 2. Sustainable Development 2.13- 2.16 Infrastructure. 2.17-2.22

Section 2. Setting the Scene. Sustainable Development. 2.13-2.16 Infrastructure. 2.17-2.22

2.13-2.16. OBJECT. The sustainable aspects  of the Draft Plan are laid out in the criteria of sustainable development. It is clear in the plan that the present infrastructure for over 4,000 new house in Paddock Wood is not sustainable with out substantial upgrades in the present Surface Water and Foul Water network and extension to the present sewage management site to the north of the railway. There is not any detail as to who will pay for this and when it will be implemented. i.e. before the houses are built.

The risk of future flooding in Paddock Wood at some of the allocated sites is high with the threat of climate change and many have present flood risk designations.

Infrastructure 2.17 - 2.22. OBJECT.

The present infrastructure can not cope with the already agreed developments in Church Road, Green Lane & Badsell Road (Over 900 houses.) How can then the present infrastructure  cope with the proposed 4,000 houses in the draft plan. Any mitigation proposed by the present utilities such as Southern Water should be in place before any houses are built. Also there is no mention of the provision of new water supplies for the proposed new houses in the plan. These utilities need to give evidence that they can provide the new infrastructure  and time scales when they provide the  new network in the Draft Plan.

DLP_2784

Mrs Karen Langston

Section 2

The draft Local Plan identifies an affordability issue in the borough, stating that, “Evidence from the Strategic Housing Market Assessment and the Office for National Statistics indicates notable affordability pressures for market house purchases, with entry level house prices approximately 13 times earnings of households in the borough. This compares to a ratio of 6.5 nationally, and an average of 10 within Kent as a whole.” (Para 2.29) Analysis of this data suggests the high cost of housing is having an impact, including a fall in home ownership and an increase in households renting privately. The relationship between assessed housing need and affordability should be interrogated as this could be skewing the data; people need houses, but houses they can afford. I can find no evidence in the supporting documents to justify the assumption that an increase in supply of housing will cause a fall in general market house prices. Therefore, building more homes that are unaffordable for the people who need them is not the solution.

The NPPF makes provision for exceptional circumstances when it comes to housing need assessment. It states that, “strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.” (NPPF para.60) I argue that the issue of affordability and its impact on declining home ownership is an “exceptional circumstance”. The high supply of new homes will not address local need. The Council should adopt an alternative, appropriate method of assessing need so that the borough’s protected landscapes are not developed unnecessarily in order to build houses that the borough does not need and local people can’t afford.

DLP_2983

Mr Keith Lagden

Section 2 para 2.7, 2.8, 2.11, 2.13, 2.15, 2.22, 2.27, 2.32, 2.46

Comment relating to the procedure for submitting comments on the Draft Local Plan.

The Council has made it very difficult to comment on the Draft Local Plan by requiring the completion of a complex form, on or off-line, which people not used to working on Word documents or completing online forms would find very off-putting. I certainly have and just hope this gets through so it can be taken note of! Nowhere does the Council encourage people simply to send in their comments in their own words. The result will, inevitably, be that many people will not submit comments on the Draft Local Plan because they find it too difficult to do so and that the Council will draw misleading conclusions from an artificially low response rate.

2.7. This section (and the Plan itself) misleadingly compares the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The draft plan mistakenly treats Hawkhurst as an “urban” area whereas it is no such thing. It is a village and as a village, Hawkhurst must be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess.

2.13 The Draft Local Plan claims that the achievement of sustainable development is a key theme that underpins national planning policy: Any further development in Hawkhurst is clearly unsustainable. The sewerage (recently raised in Parliament by Greg Clark M.P. for TW), roads, school, GP’s and employment opportunities, are all factors which show complete overload.

2.15 The Draft Local Plan talks about climate change and that it will seek to support carbon reduction and the transition to a low carbon future to help to counteract the impacts of climate change. This is patently untrue as the effects of major development within Hawkhurst will reduce the number of trees and vastly increase the traffic problems with the associated CO2 emissions from cars and lorries as a direct result of the proposed “relief road” which will do no such thing.

2.22 The Draft Local plan suggests that infrastructure mitigation proposals will be put in place however the proposal of a “relief road” in no way mitigates the situation – it ensures things will get worse. The planning application 19/02025 clearly shows the proposed relief road to be a substandard additional road totally unsuited to the sort of traffic flow it envisages – HGV’s, buses and substantial numbers of cars. It tries to explain that changes to the Flimwell lights will ensure this proposal will work but apart from being in another council area the planned changes will still not allow HGV’s to turn left onto the A21. A total nonsense!

2.27 The Draft Local Plan states that it must encourage and promote the uptake of active and sustainable transport where possible. This is impossible in Hawkhurst due to the topography, along with the fact that there are virtually no useable public transport links. With little or no employment opportunities within the village new residents will be forced to use their cars. No one in their right minds would contemplate cycling far anywhere out of the village as this would involve risking their lives on roads wholly unsuitable for cycles or walking.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46 The Local Plan suggests the provision of leisure, recreation, and cultural facilities will enhance the sustainability of communities and, at a wider borough level, will create a more vibrant economy that will attract businesses, visitors, and tourists to the area. Yet it proposes that Hawkhurst will benefit from concreting over the Golf Course. This demonstrates the absurdity of the plan and the lack of cross referencing. Apart from the developers absolutely no one benefits from this proposal. The huge number of objections to the development clearly shows the feelings of local residents. Yet the Local Plan dismisses the village response

DLP_2999

Lightfoot Alpacas

Section 2: para 2.11, 2.13, 2.15

The village is not able to sustain the number of houses it has now, lack of Doctors, dentist etc. The sewerage is unable to cope, the schools are full the car parks are not big enough. So the answer to all of these problems is not to build 400 more houses to bring the village to its knees.

Climate change is mentioned but destroying acres of grass and woodland and covering it with concrete and tarmac and filling it with so many more cars is the direct opposite to what is needed.

We already have developments that have been built on the understanding that improvement to roads will be incorporated but the buildings are there and the roads stay the same.

Please see above comments. I could sit down and comment on everything that is in this Draft Local Plan but it is very clear that no notice at all is taken of what the residents think and we are all wasting our time.

DLP_3012

Cranbrook Conservation Area Advisory Committee

Section 2 para 2.32

The scale of housing development proposed across Kent is unprecedented and will have a disastrous effect on the historic High Weald settlements of Cranbrook. Sissinghurst and Wilsley. Why is TWBC not challenging this level of growth. The ‘housing numbers’ are from studies that have already been challenged. There are more recent factors that also need to be addressed:

-Brexit with or without a deal is likely to mean economic decline in the UK and a reduction in immigration, which has largely fuelled the increase in population . Why have the housing figures not been recalculated ?

- Why is so much housing planned for the already overheated SE of England. The North and deprived parts of Britain are crying out for investment. Government Strategic policy should be focussing on rebalancing the country with appropriate investment of economic activity and housing, where it is most needed.

TWBC should be working with other Kent Districts, Kent County Council, the LGA and local MPs to challenge the scale of proposed housing. This proposed housing will kill the ‘golden goose’ that is the Weald of Kent, with its high quality AONB landscape and unique heritage towns and villages like Cranbrook and Sissinghurst. It will turn this part of the country into somewhere suburbanised and soulless bisected by unpleasant and polluting main roads.

DLP_3015

Cranbrook Conservation Area Advisory Committee

Section 2 Para 2.44

SECTION 2 2.44; SECTION 4 4.69; SECTION 4 4.70

AGREE with the aims set out in these sections

COMMENT

Why then is TWBC planning large scale developments for Cranbrook and Sissinghurst that are not ‘intimate and small scale’ and are totally at odds with the aspirations set out in these sections.

Why is COALESCENCE of the historic and seperate settlements of Cranbrook, Wilsley and Sissinghurst being actively encouraged under various of the proposed housing sites.

DLP_3019

Cranbrook Conservation Area Advisory Committee

Section 2 para 2.27 and 2.25

SECTION 2 2.27;

COMMENT

TRAFFIC IMPACT

The estimated 1000+ houses in Cranbrook and Sissinghurst mean at least another 2000 cars in the immediate area. This is further exacerbated by the fact that many of the larger housing sites are some way from Cranbrook and Sissinghurst necessitating car journeys for school, work, shopping and services. But Cranbrook is not alone - there is also the huge increase in housing which is already happening or planned in nearby Hawkhurst, Staplehurst, Headcorn and Marden. Roads in the area are already at capacity - recent accidents on the A229 north of Cranbrook show the dangers of too much traffic and the chaos caused on small country roads, when the main roads had to be closed.

The local stations eg Staplehurst, Marden and Headcorn are mentioned in TWBC’s own Transport report (TWBC Local Plan Transport Evidence Base) and point out that Staplehurst is already the busiest station. There will inevitably be an increase in traffic to those stations especially with little new employment locally.

SECTION 2 2.25

COMMENT

AIR QUALITY

This section talks of opportunities for improving air quality yet development on important greenfield sites and the AONB plus the added traffic volume is bound to decrease air quality, owing to the loss of the beneficial effects of trees and plants on air pollution.

The section also has a worthy aim to promote non motorised transport eg walking and cycling, with which we agree. Why then are there large development sites for Cranbrook well out of walking range of the town’s services and schools ?

As well as congestion there will be added noise and loss of air quality all of which affect the fragile Conservation Areas, the many listed buildings in the area and the surrounding AONB landscapes.

DLP_3048

Mr Adrian Cory

Section 2 para 1.35, 2.7, 2.8, 2.11, 2.13, 2.22, 2.32 & 2.46

I find the process mandated by the Council for commenting on the Draft Local Plan to be extremely onerous. The process does not allow for the submission of narrative commentaries, but instead prescribes two highly structured and complex proforma, one hosted online and an offline alternative in similar form.

The online form is unlikely to be used by those who are not comfortable with the technology and also by those who (like myself) are expert users of IT but whose experience leads them to distrust Web-based forms owing to their propensity to malfunction, losing previously entered content.

The offline form is long and complex, requiring comments to be assigned to the correct text boxes (which are sometimes ambiguous) and requiring sections of tables to be copied and pasted. This, again, will deter those who are not comfortable dealing with Word documents. Both proforma require comments to be structured in a form which is clearly designed to assist officials in consolidating comments at the expense of complexity in completing the form.

The result will, inevitably, be that many people will not submit comments on the Draft Local Plan because they find it too difficult to do so. It is hard to avoid the conclusion that this is a deliberate tactic by TWBC to minimise public response to the proposals.

1.35. The importance of producing and complying with neighbourhood plans (NDPs) is correctly described here. What is not explained is why, therefore, the Council has pointedly failed to recognise the existence of the 2019 NDP for Hawkhurst, duly prepared after local referendum and submitted in March 2019. And why the Council’s plans (and, indeed, many of its recent planning decisions) so flagrantly fly in the face of the NDP. There is substantial local opposition to the proposal (which has already been the subject of an application for outline planning permission) to build over the Hawkhurst golf course. It would be profoundly oppressive and undemocratic for the Council to ride roughshod over the clearly stated wish of local residents to preserve their village and their rural way of life.

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. As with so much else in the draft local plan, the intention appears to be to obscure significant relevant facts in order to provide a tendentious rationale for unsuitable and unsustainable development in small Wealden villages. As a village, Hawkhurst is better counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11. The Draft Local Plan, at this point, introduces a theme which is repeated throughout the document, and which is repeatedly expressed in misleading terms. The claim, here and elsewhere, that infrastructure needs associated with new developments will be assessed and addressed is designed to provide a measure of reassurance. But the claim is hollow because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. The “general presumption” in paragraph 2.22 that infrastructure to mitigate the impact of new development should be funded by developers is, similarly, meaningless. Thus, in Hawkhurst for example, the council has failed to compel a developer to comply with the terms of planning permission even though the developer’s failure has left a road junction in a dangerous condition, and the site of at least one recent serious accident. And the council continues to approve new development in the face of evidence that the local waste treatment facilities are increasingly overloaded.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. I shall argue later in this submission that the Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. The reference, here, to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals which will clearly and inevitably have such an adverse impact. The key consideration is who decides what is “unacceptable”. Clearly the council’s view of what is acceptable in this context is very different from that of those who live in, or otherwise value, the AONB.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_3241
DLP_3382
DLP_3498

Sadie Dunne
Mrs Lucy Howells
Sandra Rivers

Section 2 para 1.35, 2.7, 2.8, 2.11, 2.22, 2.32

TWBC: the following comment was submitted by the list of responders on the left:

Procedure for submitting comments on the Draft Local Plan.

The Council has made it very difficult to comment on the Draft Local Plan by requiring the completion of a complex form, on or off-line, which people not used to working on Word documents or completing online forms would find very off-putting. Nowhere does the Council encourage people simply to send in their comments as a narrative. The result will, inevitably, be that many people will not submit comments on the Draft Local Plan because they find it too difficult to do so and that the Council will draw misleading conclusions from an artificially low response rate.

1.35. The importance of producing and complying with neighbourhood plans (NDPs) is correctly described here. What is not explained is why, therefore, the Council has pointedly failed to recognise the existence of the 2019 NDP for Hawkhurst, duly prepared after local referendum and submitted in March 2019. And why the Council’s plans (and, indeed, many of its recent planning decisions) so flagrantly fly in the face of the NDP. There is substantial local opposition to the proposal (which has already been the subject of an application for outline planning permission) to build over the Hawkhurst golf course. It would be profoundly oppressive and undemocratic for the Council to ride roughshod over the clearly stated wish of local residents to preserve their village and their rural way of life.

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_3519

Andrew & Bronwyn Cowdery

Section 2 para 1.35, 2.7, 2.8, 2.11, 2.22, 2.32

Procedure for submitting comments on the Draft Local Plan.

The Council has made it very difficult to comment on the Draft Local Plan by requiring the completion of a complex form, on or off-line, which people not used to working on Word documents or completing online forms would find very off-putting. Nowhere does the Council encourage people simply to send in their comments as a narrative. The result will, inevitably, be that many people will not submit comments on the Draft Local Plan because they find it too difficult to do so and that the Council will draw misleading conclusions from an artificially low response rate.

1.35. The importance of producing and complying with neighbourhood plans (NDPs) is correctly described here. What is not explained is why, therefore, the Council has pointedly failed to recognise the existence of the 2019 NDP for Hawkhurst, duly prepared after local referendum and submitted in March 2019. And why the Council’s plans (and, indeed, many of its recent planning decisions) so flagrantly fly in the face of the NDP. There is substantial local opposition to the proposal (which has already been the subject of an application for outline planning permission) to build over the Hawkhurst golf course. It would be profoundly oppressive and undemocratic for the Council to ride roughshod over the clearly stated wish of local residents to preserve their village and their rural way of life.

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.15 The major impact in CO2 emissions are the result of lack in investment in reducing emissions from existing properties in the area, not by building new ones.

2.22 Our concern is that the proposal of a “relief road’ in no way mitigates the situation. The Flimwell lights are not adequate to deal with the significant increase in volume of traffic and will snarl up traffic along the A21.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan, which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan, which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_3533

Lynne Bancroft

para 2.39

One of the key tourism locations, known worldwide, is Sissinghurst Castle which is not referred to in this paragraph. Improved protection of this site, its surrounding area and adjacent village, through which most visitors travel, is required by extending the AONB around Sissinghurst village and preventing overdevelopment around the village and surrounding areas.

Cranbrook also is a tourist destination with its windmill, museum and historic buildings and should be protected from over development

The rural area and landscape around Cranbrook and Sissinghurst should be protected from over development as it is a well-known walking area with The High Weald trail, The 1066 Harolds Way, Walk in Time series of walks and the “Green Book” walks going through the area encouraging green tourism.

DLP_3542

Lynne Bancroft

Para 2.23

The A21 between Lamberhurst and Blue Boys needs dualling as it is congested now without further housing put into eastern side of the Borough.

With the majority of proposed growth outside Tunbridge Wells and to the north and east of the Borough the A21 will be under greater pressure in this area.

Sissinghurst village centre also has unresolved congestion issues causing air quality issues

DLP_3543

Lynne Bancroft

para 2.43

New development should not impact on the Landscape and Environment

DLP_3756

John Windeatt

paragraph 2.7, 2.8, 2.11, 2.13, 2.15, 2.22, 2.27 & 2.32

Rather than repeat all the comments made by Keith Lagden on his Response Form, I would simply say that I agree with his comments and reiterate our total objection to this development and to the loss of the sporting facilities provided by the Golf Club (even though the facilities have been intentionally run down as the scheme has been developed)

DLP_3771

Mary Jefferies

paragraph 2.7, 2.11, 2.32, 2.46

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. Hawkhurst is not an urban area.

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance.

2.32. It is essential to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. A recreational facility will be lost.

DLP_3790
DLP_3861
DLP_3886
DLP_3904
DLP_3937
DLP_3953
DLP_3980
DLP_4065

Mr Peter Jefferies
Geraldine Harrington
E Leggett
N T Harrington
Rob Crouch
Storm Harrington
B Draper
Nicki Poland

paragraph 2.7, 2.11, 2.13, 2.32, 2.46

TWBC: the following comment was submitted by the list of responders on the left:

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and built environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_3874

Mrs June Bell

para 2.11 The delivery of infrastructure is key.

The importance of the provision of additional infrastructure alongside development as stated in paragraph 1.6 has not been demonstrated in our parish.

Reasons for comment:

Healthcare: The 3 GP surgeries in the parish have limited/no space to add significant numbers (1800 +) of new patients to their register of patients

Lloyds pharmacy have had staffing drastically reduced since July 2018 which has affected service provision for prescriptions and access to pharmacy (as notified to patients on the Crane Surgery website)

STR1 The development strategy states to include new healthcare and other facilities but where and when?

As part of major development site AL/CR4 ‘Land adjacent to the Crane Valley’ already has a Resolution to grant Consent and site plans are well advanced then why has the allocation policy AL/CRS 9 not specified the provision of the Health Facility as a priority contribution?

Lack of local employment: the DLP is focussing expansion of employment growth in a prestigious new business park north of North Farm / Kingstanding way >16miles from Parish along already congested roads A262, A21 single carriage way from Lamberhurst roundabout to ‘Blue Boys roundabout.

Policy STR /CRS1 does not identify additional car park provision or acknowledge the need to fully assess the impact of proposed scale of development.

Appendix 1: Infrastructure Delivery Schedule, Table 16 shows a reliance of Developer Funding for Community, Public and Social services, Open Space, Sport and Recreation Infrastructure. This does not imply consistency of quality and a timely provision of infrastructure, ie ahead of development.

DLP_3876

Ide Planning for Paddock Wood Town Council

Paragraphs 2.13-2.16 Sustainable Development and 2.17-2.22 Infrastructure

Paragraphs 2.13-2.16 Sustainable Development 

OBJECT

1. The Plan is confined to the borough’s boundary. The strategy proposes transformational change to Paddock Wood/east Capel, and a new settlement at Tudeley, close to Tunbridge Wells and Tonbridge. Paddock Wood would no longer remain a small rural town. The strategy proposed would more sharply divide the borough into an urban west and rural east.

2. There is a Duty to Cooperate in Plan preparation concerning strategic cross boundary matters. Statements of common ground have not yet been agreed with Tonbridge and Malling BC, or for West Kent.

3. In its present form, the Plan should proceed on the basis of a joint Plan that includes Tonbridge and Malling BC (i.e. Tonbridge) and perhaps part of Maidstone BC in order -

i. to ensure cross boundary issues are fully addressed including health, transport, social care and education;

ii. in view of the planned provision of development at Tudeley beyond 2036; and

iii. to consider the possibility that development proposed at Paddock Wood/east Capel could similarly be phased over a longer time frame. This would allow for a reduction to be made in the allocations proposed under AL/PW1 – there is the additional point, in light of the physical constraints referred to elsewhere in Paddock Wood/east Capel, whether any unmet need in the borough could be more sustainably located within the Tonbridge and Malling and Maidstone boroughs under a jointly prepared Plan?

4. For development to be sustainable there is a need to identify land for the right type of development, sites must be in the right place, and development must be supported by infrastructure.

Borough wide, the allocations proposed for Paddock Wood/east Capel and Tudeley have been determined substantially on the basis of minimising the release of green belt and minimising the impact of development upon the AONB.

Objection is made to the loss of green belt to the west of Paddock Wood to accommodate development at parcels 1, 2 and part of 3 under AL/PW1.

All the housing sites identified in the Key Diagram and under AL/PW1 require flood compensation. Bringing forward development sites presently prone to flooding is arguably more contentious than releasing sites in the green belt or AONB given the costs involved (including the opportunity cost) and environmental impact i.e. given that with climate change the prospect is storage, attenuation and mitigation measures will need to be ‘topped up’ in future. Building upon the ‘wrong’ sites if, indeed, is what is proposed, is not sustainable - it absorbs developer contributions better put elsewhere and compromises the garden village ideal that underpins the strategy for Paddock Wood/east Capel.

A Strategic Flood Risk Assessment (SFRA) 2019 underpins much of what is proposed for Paddock Wood/east Capel but this is considered to be an unreliable basis for doing so. An initial review of the SFRA raises questions concerning the period over which the SFRA was undertaken, how it tied in with the Sustainability Appraisal (in particular, in assessing alternative strategies), and how robust the SFRA is in terms of the data it has relied upon and the modelling undertaken. The absence of detail concerning flood storage, alleviation and mitigation measures raises fundamental doubts about the viability and deliverability of the strategy proposed for Paddock Wood/east Capel –

a. the SFRA has been carried out on a borough wide basis. As the Plan has evolved, cross boundary issues have become more prominent. The impact of the strategy proposed at this stage, beyond the boroughs boundary, in flood risk terms, appears not to have been assessed;

b. the SFRA has not carried out a Sequential Test (ST) of potential development sites (para. 13.2, Level 1 Report). If an ST has not been carried out borough wide, it cannot be said there are not other sites that are less prone to flooding, and which may be more suitable for development;

c. further to ‘b’, it is unclear at the moment what this means for the individual parcels identified for development under AL/PW1. For example, in the Level 2 Report, for parcel 1, it was noted by the borough council’s consultants ‘Parcel 1a is located in the path of an easterly flood flow route, which continues into Paddock Wood. During initial discussions with the council, it was agreed to position the residential area in this location (and therefore not following the sequential approach for placement of development)…’ (Appendix I).

d. Information in the SFRA provides insufficient detail to satisfy the requirements of the Exceptions Test (ET) for ‘individual developments or groups of developments as part of a masterplanned or comprehensive development approach’ (para. 1.4.1, Level 2);

e. the Stage 2 SWMP for Paddock Wood noted that the town’s susceptibility to flooding is influenced by the existing surface water network being at capacity (para. 2.4.2, Level 1 Report);

f. the SFRA appears to have mixed up the Beult and the Bewl (Table 6-1, Level 1 Report). It is unclear if this is a typing error or, if intended, how this might affect the modelling undertaken by the consultants;

g. It appears that the UMIDB has, at best, had only limited involvement in the preparation of the strategy;

h. it is unclear as to how the existing/planned developments at Mascalls Farm, Mascalls Court Farm and Church Farm, and the proposed development of certain of the individual parcels under AL/PW1 will relate to one another.

Detailed comment on the SFRA is supplied under separate cover.

Comment on individual parcels under AL/PW1 follow. PWTC’s concern is the extent to which the allocations made under that policy accord with the NPPF/PPG.

5. Whilst the LPA subscribes to garden settlement principles in guiding development at Paddock Wood/east Capel and Tudeley, it is unclear whether both places could be designated as garden villages and so benefit from assistance that the government’s programme can provide.

The Plan proposes masterplanning and betterment as a cure-all. When the planning, resource and coordination that is implied by this is compared, to take one example, with Homes England’s garden community initiative in West Ifield (West Sussex), PWTC remains unconvinced that the borough council, despite its best intentions, has the capacity to deliver its strategy in its present form.

6. Homes England suggests ‘given its complexity, potential for infrastructure provision needed up front and long timeframe for delivery, CIL may not always be feasible or appropriate for a garden community scheme’ (MHCLG Land Value Capture and Funding Delivery, 27th September 2019).

7. The LPA’s assessment of housing need/provision inflates housing numbers required over the Plan period which has a bearing upon the allocations proposed for Paddock Wood/east Capel.

8. With regard the distribution of housing development, objection is made above under ‘4’ above to the loss of green belt.

It is considered there is more scope for development to be allocated elsewhere within the borough. For example, Cranbrook has escaped the development allocated in the SALP, whilst Hawkhurst (a smaller town in the Borough & the AONB) has seen considerable house building and is taking more houses than Cranbrook in the draft Local Plan. Why has Cranbrook not been allocated an increased share, when flooding is not a problem and the town centre is well established with schools that have capacity for increased student numbers? It is possible to build sympathetically within the AONB – other Boroughs have done this. It is also unclear whether some of the development proposed at Paddock Wood/east Capel could be more sustainably located at Tudeley.

9. Questions arise concerning the identification, prioritisation and phasing of specific infrastructure schemes and hence the deliverability of the strategy. In respect of their prioritisation, more infrastructure may be critical and essential than desirable. Of particular concern is how critical many of the projects are, the magnitude of cost, the uncertainty concerning their phasing and the funding position overall. For example, the IDP lists the new Colts Hill bypass as being critical (p94), as needing to be in place before sites come forward for development, yet the all-important policy STR1(2) refers to the bypass in terms of it being a potential scheme.

Comment follows [below] on improvements required to the highway network to accommodate the development proposed. These improvements are needed to add to capacity locally and to mitigate impacts upon air quality.

10. The viability of the Plan is unconfirmed – whilst the Stage 1 Viability Assessment says the consultant’s find reasonable viability prospects available borough-wide to support the Plan’s delivery, the viability of the larger/strategic site allocations has yet to be addressed in a Stage 2 assessment.

Paragraphs 2.17-2.22 Infrastructure

OBJECT as above

DLP_3877

Mrs June Bell

paragraph 2.32

The scale of development proposed for this parish (900 + new dwellings) is not sustainable for the following reasons:

* Large Scale Developments in AONB is contrary to policy EN21 and EN 7.

* Lack of local employment - the DLP is focussing expansion of employment growth in a prestigious new business park north of North Farm / Kingstanding way >16miles from Parish along already congested roads A262, A21 single carriage way from Lamberhurst roundabout to ‘Blue Boys roundabout.

* Connectivity: Less than adequate but quintessential road networks within the parish comprise of historic narrow streets, unsuitable for widening and HGVs

Limited public transport to meet today’s work schedules 24/7, especially as economic development is focussed on North Farm in Tunbridge Wells – not a direct bus route from Cranbrook & Sissinghurst.

DLP_3879

Mrs June Bell

paragraph 2.60

What is meant by the term ‘a range of comparison shopping facilities’ ?

There is no mention of the attraction of Cranbrook and Sissinghurt’s distinct conservation areas and unique heritage highlights: Sissinghurst Castle, windmill, museum, Cathedral of the Weald, annual traditional Apple fair, Nuts in May and repeated success of Cranbrook in Bloom within the South and South East and Nationallly all adding to the boost in economy to the borough through tourism.

This will be at significant risk if development is allowed on the scale and speed proposed in the DLP.

DLP_5105
DLP_5125

Mr Peter Brudenall
Alistair Nichols

Paragraph 2.7

TWBC: the following comment was submitted by the responders on the left:

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook.  The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

DLP_5231

Tunbridge Wells Friends of the Earth

Section 2 various paragraphs

Sustainable development

2.14 We welcome the assurance that the new Local Plan will follow sustainability principles and carry out Sustainability Appraisals to assess the impact of its policies. We feel that the statement: “Where potential adverse impacts are identified, mitigation measures may be set out by the Sustainability Appraisal to remove or reduce the adverse effect and enhance beneficial effects.” needs further clarification though.

2.15 We are pleased that climate change is recognised as a major issue and that the policies contained within this Draft Local Plan will seek to support carbon reduction and the transition to a low carbon future to help to counteract the impacts of climate change. However, we strongly object to the promotion of biomass as if a renewable form of energy generation. [Please, see document on biomass research attached].

Transport

2.25 We strongly support the intention to improve air quality not only within the AQMA but throughout the urban area of RTW, but question whether proposed measures will be sufficient.

2.26 We challenge whether ‘predict and provide’ in relation to parking will allow the transition to active travel promoted elsewhere in the Draft and are worried that instead it will increase car traffic.

Demographics and housing

2.32 We support the efficient use of land which will generally require higher housing densities than have previously been the case, while seeking to avoid adverse impact on the character and setting of the natural and built environment.

Natural, built and historic environment

2.40 - §2.44 The constraints of the Green Belt and AONB mentioned in §2.40 should be cross-referred to §2.10 where they are also described as having balancing attributes which should be given their full weight in restraining inappropriate development.

2.40 We recognise the value of the Metropolitan Green Belt and consider it right that it should pose a significant constraint to development. We would oppose to any development in Green Belt land.

2.41 We encourage the protection of the wide network of biodiversity sites in the borough.

2.43 We agree with the explicit recognition that pressure for new built development across the borough, including on greenfield land, could have direct impacts on landscape and environmental assets and their settings, and that the Draft Local Plan needs to ensure that, in facilitating development, proposals take full account of, and reflect, each site's landscape and environmental sensitivities.

2.44 When balancing the competing pressures of housing, employment, and other development with the preservation and enhancement of local character and distinctiveness of sites, we maintain that conservation of Green Belt, High Weald AONB, Sites of Special Scientific Interest, Wildlife Sites, Nature Conservation sites and Nature Reserves should prevail and be excluded from development.

DLP_6742

Mrs Carol Richards

 

Sustainable development para 2.14

Para 2.13 states that “the achievement of sustainable development is a key theme that underpins national planning policy . . . the Plan has applied a presumption in favour of sustainable development, in accordance with the NPPF

so under 2.14 how can you justify the adverse effects of the devastating effects of environment (car fumes) services (shopping and train access) and social- as Tonbridge grinds to a halt? Is it that the sustainable issues in Tonbridge are not relevant to TWBC -being outside the borough and are therefore not within the scope of this Local Plan.

Infrastructure – para 2.17

This para asserts ‘Infrastructure planning is the process of planning to meet all requirements for infrastructure in accordance with proposed development’.

This is an admirable wish, but I have the following concerns:

* Infrastructure build needs to take place BEFORE 7000 homes are built along the Tudeley to Paddock Wood route.

* Even if the road was improved, it is not going to change the fundamental issue, which is that the new sites will largely be dormitory towns for London. As a result, more cars will use this route as the fare is more expensive from Paddock Wood and there are fewer trains in peak rush hour per hour from Paddock Wood. In addition, Tudeley and Five Oak Green are closer to Tonbridge.

This plan is just not sustainable- as Tonbridge is too small a town with constraints of a river and many rail lines at its centre.to accommodate such an invasion of cars and people.

Demographics and housing – para 2.32

This para states:

Given the environmental constraints within the borough, it is important that new development makes the most efficient use of land, while also ensuring that development is of a high quality in sustainable locations, and does not have an unacceptable adverse impact on the character and setting of the natural and built environment of the borough’.

This is completely parochial, and focuses solely on the needs of TWBC and fails to take account of knock-on implications for its neighbours. For instance, the proposed main sites TWBC wish to develop are in areas which will flood or in the case of Tudeley will have dire consequences- and will cause flash flooding downstream to the valley below in East Peckham and Yalding.

So although these proposals do indeed ensure that these developments will not impact adversely on the Borough of Tunbridge Wells- they will impact on Tonbridge instead.!...Which by the way is in the Borough of Tonbridge and Malling. How TWBC can cause such a huge problem for a neighbouring borough and get away with it is beyond belief!

DLP_7300

Kylie Brudenall

Paragraph 2.7

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook.  The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

Borough Profile and Context

Comment No.

Name/Organisation

Section or paragraph number(s)

Response

DLP_1564

Peter Hay

2.7 2.8

Comment relating to the procedure for submitting comments on the Draft Local Plan.

The Council has made it very difficult to comment on the Draft Local Plan by requiring the completion of a complex form, on or off-line, which people not used to working on Word documents or completing online forms would find very off-putting. Nowhere does the Council encourage people simply to send in their comments as a narrative.  The result will, inevitably, be that many people will not submit comments on the Draft Local Plan because they find it too difficult to do so and that the Council will draw misleading conclusions from an artificially low response rate.

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook.  As a village, Hawkhurst is better counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook

DLP_2017
DLP_2144

Penelope Ennis
Michael O'Brien

2.7, 2.11, 2.32

TWBC: the following comment was made by the list of responders on the left:

2.7 It is frustrating to see us aligned with towns such as Cranbrook and Paddock Wood when we are a village. Drawing false comparisons does not reflect well on any of your arguments for substantial development. From a local point of view, this is a fundamental factual error and invalidates the whole document from the outset. Our village has been incorrectly classified as ‘urban with rural features’ in the 2016 Classification and as 100% of our village is within an AONB we cannot possibly be classified as urban.

2.11 As, up until quite recently KCC Highways have been unable to maintain satisfactory road surfaces throughout our village and South East Water have failed to control their sewerage systems there is little faith in the infrastructure needs associated with new developments will be assessed or addressed, let alone in a timely fashion ahead of development.

2.32 The Draft Local Plan contains proposals which will have an unacceptable adverse impact upon the character and setting of the natural and built environment of the borough’. Your failure to protect the AONB is noted.

DLP_2963

Michael Alder

2.7, 2.8

2.7:- It is incorrect to compare the village of Hawkhurst with the urban areas - towns - of Paddock and Cranbrook. Hawkhurst is to be included in the category variety of villages and hamlets as recorded in paragraph 2.8.

DLP_5200

Culverden Residents Association

Paragraph 2.25

Paragraph 2.25: We welcome the intention to improve air quality not only within the Air Quality Management Area but throughout the urban area of RTW. This is important for us because most of our members live not far from the A26 AQMA and suffer particularly badly from air pollution from rat-running and the school run and also as users of the local shopping parades in St Johns.

DLP_5820
DLP_5845
DLP_6175
DLP_6578
DLP_6755
DLP_7027
DLP_7418
DLP_7434
DLP_7453
DLP_7475
DLP_7587
DLP_8015
DLP_8091

Charles Vernede
Mrs Sarah Vernede
May Corfield
Vivien Halley
Linda Beverley
Sally Hookham
Simon Parrish
Catherine Baker
Patrick Thomson
Sally Thomson
Victoria Dare
Penny Ansell
Mary Curry

Paragraph 2.7

TWBC: the following comment was made by the list of responders on the left:

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook.  The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

DLP_7203

Mr Michael Armitage

Paragraph 2.7

Hawkhurst is not an urban entity, it is a village, and should be treated as such.

DLP_7449
DLP_7643

Catherine Pearse
Keith Peirce

Paragraphs 2.7, 2.8, 2.11, 2.13, 2.15, 2.22, 2.27, 2.32, 2.46

TWBC: the following comment was made by the list of responders on the left:

2.7. This section (and the Plan itself) misleadingly compares the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook.  The draft plan mistakenly treats Hawkhurst as an “urban” area whereas it is no such thing.  It is a village and as a village, Hawkhurst must be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11.  The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess.

2.13 The Draft Local Plan claims that the achievement of sustainable development is a key theme that underpins national planning policy:  Any further development in Hawkhurst is clearly unsustainable.  The sewerage (recently raised in Parliament by Greg Clark M.P. for TW), roads, school, GP’s and employment opportunities, are all factors which show complete overload.

2.15 The Draft Local Plan talks about climate change and that it will seek to support carbon reduction and the transition to a low carbon future to help to counteract the impacts of climate change.  This is patently untrue as the effects of major development within Hawkhurst will reduce the number of trees and vastly increase the traffic problems with the associated CO2 emissions from cars and lorries as a direct result of the proposed “relief road” which will do no such thing.

2.22 The Draft Local plan suggests that infrastructure mitigation proposals will be put in place however the proposal of a “relief road” in no way mitigates the situation – it ensures things will get worse.  The planning application 19/02025 clearly shows the proposed relief road to be a substandard additional road totally unsuited to the sort of traffic flow it envisages – HGV’s, buses and substantial numbers of cars.  It tries to explain that changes to the Flimwell lights will ensure this proposal will work but apart from being in another council area the planned changes will still not allow HGV’s to turn left onto the A21.  A total nonsense!

2.27 The Draft Local Plan states that it must encourage and promote the uptake of active and sustainable transport where possible.  This is impossible in Hawkhurst due to the topography, along with the fact that there are virtually no useable public transport links.  With little or no employment opportunities within the village new residents will be forced to use their cars.  No one in their right minds would contemplate cycling far anywhere out of the village as this would involve risking their lives on roads wholly unsuitable for cycles or walking.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many

proposals in the Plan which will clearly have such an adverse impact.

2.46 The Local Plan suggests the provision of leisure, recreation, and cultural facilities will enhance the sustainability of communities and, at a wider borough level, will create a more vibrant economy that will attract businesses, visitors, and tourists to the area.  Yet it proposes that Hawkhurst will benefit from concreting over the Golf Course.  This demonstrates the absurdity of the plan and the lack of cross referencing.  Apart from the developers absolutely no one benefits from this proposal.  The huge number of objections to the development clearly shows the feelings of local residents.  Yet the Local Plan dismisses the village response.

DLP_7863
DLP_8237

Andrew Hues
Jan Pike

Paragraphs 2.7, 2.11, 2.13, 2.32, 2.46

TWBC: the following comment was made by the list of responders on the left:

2.7. This section (and the Plan itself) misleadingly compares the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook.  The draft plan mistakenly treats Hawkhurst as an “urban” area whereas it is no such thing.  It is a village and as a village, Hawkhurst must be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11.  The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess.

2.13 The Draft Local Plan claims that the achievement of sustainable development is a key theme that underpins national planning policy:  Any further development in Hawkhurst is clearly unsustainable.  The sewerage (recently raised in Parliament by Greg Clark M.P. for TW), roads, school, GP’s and employment opportunities, are all factors which show complete overload.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_1738

Peter Hay

Figure 2 Borough Location

Figure 2 Borough Location

2.7

This section (and the Plan itself) misleadingly compares the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The draft plan mistakenly treats Hawkhurst as an “urban” area whereas it is no such thing. It is a village and as a village, Hawkhurst must be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

DLP_2647

Lee Hatcher

Figure 2 Borough Location

2.6

I note that in 2.6 you state that, for Cranbrook 'The local architecture and features give it a distinctive character.' - I hope that any potential developments will have to fit in with this character

DLP_2861

Chris Gow

Figure 3 Borough Overview Map

Figure 3 Borough Overview Map

2.2

I question the assertion that there is any support for a new theatre complex, and that there is any general and widespread desire among the residents to make Tunbridge Wells a cultural centre of the High Weald. It seems this is a minority view held by a few influential residents, or even residents outside the borough who have some grand ideal.

I would like the Local Plan to make a clear and decisive commitment to the historical and architectural features of the town, and preserve for example the brick pavements in the town, and many of the parks and open spaces, including the trees, and the historic and interesting buildings, and take positive and determined steps to preserve the character and charm of the town. In the same context, traffic and congestion must be a priority before the new prestige projects are contemplated.

Challenges and Opportunities

Comment No.

Name/Organisation

Section or paragraph number(s)

Response

DLP_67

The Access Group

Paragraph 2.15 to 2.16

My members having looked at the proposed Draft Local Plan have instructed me to make the following observations and legal demands:

  1. LEGAL DEMANDS
  • All new buildings, dwellings and workplaces must have sola panels on the roofs.

DLP_83

Roger Bishop

Transport – para 2.27 – p27

Summary

The Plan contravenes Government policy on the Green Belt, and TWBC’s policies and aspirations with regard to, for example, the environment and biodiversity, climate change, transport, and heritage assets, all in the pursuit of meeting a stated housing need which it is acknowledged is not soundly based.

Detailed comments are below.

Transport – para 2.27 – p27

You state that, “the Local Plan must encourage and promote the uptake of active and sustainable transport where possible.”

But the Plan cannot but lead to a significant increase in journeys by private car. The number of houses in the parish will rise exponentially. The irregular, expensive and limited bus service clearly caters, and is only ever likely to cater, for the needs of a small number of people, and hardly falls into the sustainable category.

[TWBC: see also comments DLP_81 to 93].

DLP_1565

Peter Hay

2.11 2.13 2.15 2.22 2.27 2.32 2.46

2.11.  The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess.

2.13 The Draft Local Plan claims that the achievement of sustainable development is a key theme that underpins national planning policy: Any further development in Hawkhurst is clearly unsustainable. The sewerage (recently raised in Parliament by Greg Clark M.P. for TW), roads, school, GP’s and employment opportunities, are all factors which show complete overload.

2.15   The Draft Local Plan talks about climate change and that it will seek to support carbon reduction and the transition to a low carbon future to help to counteract the impacts of climate change. This is patently untrue as the effects of major development within Hawkhurst will reduce the number of trees and vastly increase the traffic problems with the associated CO2 emissions from cars and lorries as a direct result of the proposed “relief road” which will do no such thing.

2.22   The Draft Local plan suggests that infrastructure mitigation proposals will be put in place however the proposal of a “relief road” in no way mitigates the situation – it ensures things will get worse. The planning application 19/02025 clearly shows the proposed relief road to be a substandard additional road totally unsuited to the sort of traffic flow it envisages – HGV’s, buses and substantial numbers of cars. It tries to explain that changes to the Flimwell lights will ensure this proposal will work but apart from being in another council area the planned changes will still not allow HGV’s to turn left onto the A21. A total nonsense!

2.27   The Draft Local Plan states that it must encourage and promote the uptake of active and sustainable transport where possible. This is impossible in Hawkhurst due to the topography, along with the fact that there are virtually no useable public transport links. With little or no employment opportunities within the village new residents will be forced to use their cars. No one in their right minds would contemplate cycling far anywhere out of the village as this would involve risking their lives on roads wholly unsuitable for cycles or walking.

2.32.  The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46   The Local Plan suggests the provision of leisure, recreation, and cultural facilities will enhance the sustainability of communities and, at a wider borough level, will create a more vibrant economy that will attract businesses, visitors, and tourists to the area. Yet it proposes that Hawkhurst will benefit from concreting over the Golf Course. This demonstrates the absurdity of the plan and the lack of cross referencing. Apart from the developers absolutely no one benefits from this proposal. The huge number of objections to the development clearly shows the feelings of local residents. Yet the Local Plan dismisses the village response.

DLP_1795

Royal Tunbridge Wells Town Forum

Paragraphs 2.10, 2.15, 2.22, 2.25, 2.26, 2.32, 2.35, 2.36-2.38, 2.40-2.44, 2.46

In Paragraph 2.10, we support the recognition that, while some of the natural and built assets of the Borough are a constraint to new built development, they perform valuable roles in relation to the further development of tourism, the rural economy, leisure and recreation.

In Paragraph 2.15, we endorse the intention to support carbon reduction and transition to a low carbon future. With regard to water stress, we consider this to be a significant looming problem in the Borough and that it should be taken more seriously as a constraint on built development.

In Paragraph 2.22, based on the experience of the past, we are sceptical that sufficient funding from development will become available to fund mitigation of the impact of new development. Development on the scale proposed in the Draft would also require very substantial public investment which cannot be relied on at present and so may act as a constraint in practice.

In Paragraph 2.25, we strongly support the intention to improve air quality not only within the AQMA but throughout the urban area of RTW, but question whether proposed measures will be sufficient.

In Paragraph 2.26, we challenge whether “predict and provide” in relation to parking will allow the transition to active travel promoted elsewhere in the Draft. We provide more detailed comment on this issue elsewhere in our response.

In Paragraph 2.32, we strongly support the efficient use of land which will generally require significantly higher housing densities than have previously been the case, while seeking to avoid adverse impact on the character and setting of the natural and heritage environment.

In Paragraph 2.35, we support the provision of appropriate additional land to facilitate business growth and expansion. Too much employment land has recently been lost to office conversions to residential in the town centre against the wider public interest. However, considerably more than the predicated 14Ha seems to have been allocated in Royal Tunbridge Wells.

In Paragraphs 2.36-2.38, we particularly support the encouragement of a strong cultural element to development, including public art, to add to the cultural and creative offer of the Borough and flexibility of uses within RTW town centre to ensure long term adaptability to retail change. Every possible source of funding should be explored to make this a reality.

In Paragraph 2.40- 2.44, the constraints of  the Green Belt and AONB mentioned in Paragraph 2.40 should be cross referred to Paragraph 2.10 where they are also described as having balancing attributes which should be given their full weight in restraining inappropriate development when assessed according to each site’s landscape and environmental sensitivity.

In Paragraph 2.46 we support the securing of development money to enable improved local leisure and recreation provision.

DLP_2218

Tracy Belton

2.13, 2.15, 2.19, 2.26, 2.27, 2.3, 2.31

2.13 The NPPF indicates that plans should take into account loacl circumstances and opportunities, but in Horsmonden the number of dwellings planned are in excess of those allocated to Matfield, Brenchley, Lamberhurst and Goudhurst combined. Horsmonden, as with most villages, has few employment opportuities nowadays. The current doctors surgery is shared with Brenchley and the nearest dental practice that is taking on NHS patients is in Paddock Wood (Brenchely is too full). Therefore, how can local circumstanes have been taken into account when allocating this number of dwellings to Horsmonden compared to the villages that surround it? Horsmonden may be outside the AONB but it is overlooked by villages that are in the AONB so surely this must be taken into account?

2.15 I don't see how building so many dwellings in villages where there are few services (trains, buses, etc) is going to support carbon reduction. Most properties have at least 2 vehicles as public transport is either not available at all to get to a required destination, or not frequent enough to allow the vast majority to travel to work. Therefore, more dwellings will bring at least 2 vehicles per dwelling into the villages and create more emissions. There are not enough employment opportunities in villages to support the idea of reducing carbon.

2.19 The infrastructure around sites that are up for development is not suitable to take on the amount of traffic that will be created. Villages have many single track roads or shared roads, few, if any, pedestrian crossings, no policing of yellow lines/parking on junctions etc meaning that roads will become far more dangerous for drivers and pedestrians with the addition of more dwellings. Many roads cannot be widened to accomodate the extra traffic so I can't see a solution to this problem. All villages and towns in the area will simply be much more congested,meaning journey times are increased along with carbon emissons.

2.26 New developments in villages need to make sure that enough parking is provided. Adequate visitors spaces need to be taken into consideraton as there are not sufficient spaces provided in existing residential areas to take on the extra parking requirements. Many family homes need at least 4 parking spaces as children/young adults are living at home until they are older than in previous generations. Mixing up types of dwellings within developments (family homes/bungalows/starter homes) would help with this problem.

2.27 See comments above in 2.15 & 2.19

2.3 The housing needs of the villages themselves need to be taken into account when planning new developments. In Horsmonden, a need to housing for the elderly was shown but building family homes (as has been the case in the lastest development in the village) will not satisfy this need. If housing for the elderly/less able was built, villagers could move to more suitable accommodation in the village and this will free up family homes elsewhere within the village to suit the needs of those wanting to buy or rent.

2.31 From this paragraph, it appears that we do not actually have any say as to what it built as there are 'serious consequesces' if targets are not met. It appears that the targets are set by those who seem to not mind losing farmland and AONB, and who also have no care for the environmental impacts and the protection of wildlife.  From this I fear that villages in Kent will simply all merge together and end up as part of London. I feel very sad that those who have chosen to live in these currently quiet areas that have a lovely community feel will be forced out of their villages because they have lost their appeal and have grown into towns and become too congested to live in. I had thought that Kent was 'The Garden of England', but clearly this is not something that those who have imposed these new developments on us agree with.

DLP_2461

Mr Peter Bird

2.9 2.31

In the original discussion you were looking at the corridor along the A21 what happend to that possibilty.Also the new town why did you not look at the land around Frant station?

This would have given you a mainline station with direct access to London far better than having more cars on the roads.

There are no social houses planned a lack of which is a problem within this area, there fore forcing private rents up.Affordable prices are not the answer because all will happen is the London borough's will be snapping them up because of the very high prices of properties in London.This has already happened in other parts of Kent

DLP_2651

Lee Hatcher

2.15, 2.27

2.15 - You mention that climate change is a major issue, yet you propose large developments where the only choices for travel are via car. For instance, lots of housing development in Hawkhurst, Cranbrook, but commercial development around Tunbridge Wells. Travel between these location will mostly be via car on already busy roads through bottlenecks in Goudhurst, Hawkhurst itself, and Flimwell.

2.27 - How does the Local Plan 'encourage' active and sustainable transport from rural areas that are currently poorly served by public transport?

DLP_2754

James Hammond

 

Under paragraph 2.21 of the Draft Local Plan, the Council advises that it has commissioned specialist consultant advice on whether it is most appropriate to secure infrastructure through a Community Infrastructure Levy (CIL), through contributions secured through Section 106 agreements, or a combination of the two. The Council is to make a decision on the position in due course.

Following recent amendments to the Community Infrastructure Levy (CIL) Regulations (2010) which came into force on 1 September 2019, the most noticeable immediate change is likely to be the lifting of the ‘pooling restriction’, which will arise from the deletion of Regulation 123. In practice, any development granted planning permission on or after 1 September 2019 may be subject to a section 106 agreement contributing to infrastructure that has already benefited from contributions from five or more planning obligations (since 2010); this has not been possible since 2015 or earlier (where CIL charging schedules took effect sooner). The intended effect of this is to allow CIL and planning obligations to fund the same piece of infrastructure and accordingly remove what can be a barrier to development.  Of course, it is important to note that the tests in Regulation 122 will continue to apply, and so the s.106 agreement will still need to be (a) necessary to make the development acceptable in planning terms, (b) directly related to the development, and (c) fairly and reasonably related in scale and kind to the development.

It is opined that, following amendments to the Community Infrastructure Levy (CIL) Regulations (2010), S106 provides the appropriate mechanism for securing contributions to secure/fund necessary infrastructure.

In the event the Council decides to proceed with preparation of (and consulting on) a draft Charging Schedule, it is suggested that the charging rates to be applied should be consistent with the rates adopted by neighbouring Sevenoaks District Council, bearing in mind the obvious associations between the two authority areas in respect of housing market area, land values, affordable housing requirements, end sales values for market housing and, ultimately, viability. It is considered the rate setting applied by Sevenoaks DC strikes an effective balance by ensuring CIL receipts are collected in areas where development takes place without unnecessarily burdening a developer on grounds of viability, thereby ensuring that development proceeds in a timely fashion.

DLP_2862

Chris Gow

2.11 - 2.16

If infrastructure is key, how are local doctor surgeries being planned and delivered?

The new developments at Knights Farm have not made additional surgery a priority, simply expecting existing established surgeries to expand and take larger patient lists. This leads to over worked and over loaded GP surgeries.

The same is the case for schools, and no provision is made in the plan for the expansion of schools with larger premiss or more staff. It is no good waiting for the problem to be solved later.

Sustainable development is mentioned, but no decisive policy is proposed.

For example, new development could restrict vehicle access and egress, and persuade residents to use public transport, cycle or walk. This will avoid congestion, pollution, and unsustainable energy consumption.

Water stress is a significant problem and the Plan should include definite and clear policy on water use in new developments, for example avoiding the installation and use of appliances and not allowing outside mains water use.

Building on flood plains should be avoided in all cases. The climate situation will only get worse.

DLP_2863

Chris Gow

2.23 - 2.27

The problem of congestion is not solved by adding capacity to the network. Any additional capacity is immediately filled with additional traffic movement.

The solution is to reduce the traffic movement by encouraging (forcing) users to use alternative methods, cycling or walking, or using a well funded and therefore affordable, frequent and reliable public transport network.

This reduction of traffic movement will reduce congestion, energy consumption and emissions. These benefits are problems raised in these paragraphs of the plan, but no decisive policy is established.

Reducing access and egress to the town will frustrate traffic movement and there will be "traffic evaporation" and so a reduction if traffic movement.

A policy of reducing multiple car ownership per household will help in reducing congestion of residential streets plagued with parked vehicles. But for this to work there must be alternative public transport policy, and car sharing schemes.

The widespread use of the pavement for car parking must be prohibited, to allow safe and secure pavement space for pedestrians. A benefit will be an initial reduction, and then a zero cost cost of pavement reinstatement.

Children will not want to walk to school if they perceive the pavements are used by vehicles for casual parking.

A sustainable transport policy demands a positive and determined policy in the local plan.

If casual vehicle movements are difficult in the Borough, by filtering residential side streets, and limiting access and egress through residential streets to discourage rat-running, there will be "traffic evaporation" as drivers use alternative transport, and the amenity of residential streets will improve, with improved air quality and safer streets.

Para 2.26 Rather than including parking provision, new developments should discourage vehicle ownership. However, at any cost, parking vehicles on pavements must be prohibited.

Sustainable development policies are essential for all the well known reasons of pollution, air quality, energy consumption and the well being of society as a whole community.

If the council is serious, and having signed up to the Climate Emergency, then the actions to ensure the town is prepared for the future should be delivered in policies that are clear, determined and decisive to promote and deliver a town plan that is taking account of current thinking  about Climate Change.

DLP_2864

Chris Gow

2.28 - 2.32

Demographics and housing

If average house price is this high, it is clear the priority should be for low cost housing for the Borough. If the town wants to attract population it will have to offer a supply of low cost housing, and new developments should be consistent with the type of house available on the development with all houses of the same price bracket. Mixed development does not favour the low cost housing , and the town has enough high cost housing already. The town lacks low cost housing.

It is not good enough to leave the decision of house type and so cost, to the developer, as their choice will always be for the expensive sale price.

Low cost housing should not be determined by the market average for the cqalculation as this has led to inflated house prices in the borough.

Low cost housing should be determined by the ability of low paid income to afford the housing.

Reference to national figures should not be the determining factor, and local planning policy, and the local plan should promote a more affordable housing structure that benefits the lower paid members of our society, and lower pain residents of the borough.

Affordable housing must be located in areas of the borough where there are (or will in the future) good public transport delivery.

Such low cost housing development will encourage community and well being for the local residents.

DLP_2866

Chris Gow

2.33 - 2.38

Economy

The studies that underpin the strategy are out dated and the current economic climate is changing rapidly, and assertions from the studies should be regarded with suspicion.

A look at the economy in other areas demonstrates the idea of perpetual growth is a flawed concept, and future projections should be based on zero growth or even a contraction of the economy.

I suggest the areas set aside for retail development are unrealistic, and better use is made of existing retail areas.

The areas of retail development could be better delivered to the borough by being used for housing needs.

Housing in the town centre would be welcome.

DLP_2964

Michael Alder

2.11, 2.13, 2.15, 2.22, 2.32.

2.11:- TWBC has restricted powers in the provision of infrastructure and has an abominable track record in provision to date. There is no confidence that this will improve.

2.13:- The Draft Local Plan emphasises the importance of sustainable development as a requirement of national planning policy. Any further development in Hawkhurst is totally unsustainable. The village already suffers from sewage running down the streets, road gridlock, a full primary school, no secondary school, GP surgeries overloaded, minimal employment opportunities.

2.15:- The Draft Local Plan's stated aim to move to a low carbon future is patently untrue. The major developments planned within Hawkhurst by reducing the number of trees, and vastly increasing the traffic will by definition increase emissions.

2.22:- The Draft Local Plan maintains that the provision of a " relief road" will improve the traffic situation. This is totally incorrect. The planned road width is inadequate for the intended use of HGV's, buses, and the substantial additional cars that would be generated by the planned additional housing. The traffic jams within Hawkhurst at present - without development - show the faults in the new plan.

2.32:- TWBC has the responsibility to note and care for the ANOB within its boundaries. Such responsibility has been totally ignored.

2.46:- TWBC has ignored multiple objections to the development of the Golf Course in Hawkhurst. These must be recognised in the Local Plan.

DLP_3097

Caroline Taylor

2.23

Insufficient consideration has been given to the increased transport requirements of the new housing. Each house is likley to produce 2 more cars on the roads that are already heavily congested at peak times. Station carparks [Staplehurst & Morden esp] are already full. Bus services are poor. Trains to London are already standing room only. Will the train service be improved?

DLP_3099

Caroline Taylor

2.21

The plan states the delivery of infrastructure is key! Local SP lists are at capacity so people would need transport to access facilities out of area. Even if a medical centre was built it's unlikely to find GPs to work in it, as there is an acknowledged shortage of GPs.

DLP_3145

Nigel Bell

Section 2 Paragraph 2.32

Paragraph 2.32

As a local resident in Cranbrook I know that local residents are strongly against large scale developments and prefer small scale developments in keeping with how Cranbrook evolved. Cranbrook character is small scale and historic. I object to large scale housing developments in Cranbrook. In particular I object to major development sites in the Cranbrook AONB – for example 150 dwellings at Golford Road, 134 dwellings at Turnden and 90 dwellings at Gate Farm, and other developments of such scale. 

DLP_3146

Nigel Bell

Paragraph 2.44

Paragraph 2.44

"The cumulative impact of minor piecemeal development and small changes in land use can have a significant overall adverse impact on the natural, built, and historic environment, and on the character and settlement pattern within, and adjacent to, the High Weald AONB. These issues need to be recognised"

In the case of Cranbrook, despite the statement at Plan 2.44, the Plan supports and proposes many large-scale developments (100+) which will have a significant overall adverse impact on the natural, built, and historic environment, in Cranbrook and on the character and settlement pattern within Cranbrook. Also uses ANOB land which should be protected for generations to come. I object to this.

DLP_3161

Kent County Council (Growth, Environment and Transport)

Section 2 Challenges and Opportunities

Waste Management

The significant development within the borough will undoubtably put pressure on the waste services provided by KCC in this area. KCC as the Waste Disposal Authority provides a Waste Transfer Station (WTS) at North Farm for the receipt of kerbside waste collected by Waste Collection Authorities (both Tunbridge Wells Borough Council and some of Tonbridge and Malling Borough). There is also a co-located Household Waste and Recycling Centre for residents to dispose of household waste. Both of these facilities are strategic, serving not only the whole of Tunbridge Wells Borough area but also parts of adjoining Districts.

Paragraph 2.10 and 2.11 refer to a Development Constraints Study of October 2016. KCC would like to see consideration of Waste Infrastructure. KCC is pleased to see that Waste Infrastructure is referred to in Section 2.17 and is included in the new Infrastructure Delivery Plan dated August 2019.

DLP_3162

Kent County Council (Growth, Environment and Transport)

Sustainable Development

Provision and Delivery of County Council Community Services

The County Council requests that reference is made to the Kent Design Guide (currently being refreshed for 2020 publication).

DLP_3163

Kent County Council (Growth, Environment and Transport)

Transport

Transport Policy

The County Council is generally supportive of the policies set out as part of the Draft Plan, which mirror KCC priorities from a transportation policy perspective.

In 2017, KCC published and adopted its Local Transport Plan 4 (2017) Delivering Growth without Gridlock 2016-2031. It would therefore be preferable for this document to be referenced instead. This should be referred to within the Local Plan and supporting evidence base as opposed LTP3.

DLP_3164

Kent County Council (Growth, Environment and Transport)

Town Centres and Retail

Provision and Delivery of County Council Community Services

The County Council would like to see consideration of how the Borough Council, working with KCC as appropriate, will be looking to revitalise the town centre, creating a range of uses that are resilient to the changing needs of the high street.

DLP_3165

Kent County Council (Growth, Environment and Transport)

Natural, built and historic environment

Heritage Conservation

Paragraph 2.42 ‘Archaeological sites’ should be added to the list of heritage assets in the Borough.

DLP_3655

Capel Parish Council

Paragraphs 2.9, 2.23-2.44

General Observation

Capel Parish Council makes the following general observation on these paragraphs:

Paragraph 2.9 (p.24) states “As the challenges highlighted in the section below show, the potential of some areas of the borough to accommodate new growth is constrained by factors such as highway capacity, landscape sensitivity, flooding, and the nature of the natural and built environment. These factors have all been taken into account when considering the growth strategy and distribution of development set out within this Draft Local Plan”

All of the constraints listed above, plus many more, affect the proposed developments at Tudeley (AL/CA 1) and East Capel (AL/CA 3 & AL/PW 1), as well as the land safeguarded for the proposed A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley AL/CA1 to the Colts Hill Bypass (Five Oak Green Bypass) according to the SWECO Local Plan Transport Evidence Base p.138 and 142). There is no evidence in all of the supporting documents which demonstrates that these factors have properly been taken into account.

Under Transport, paragraphs 2.23-2.24 (p.26) state “2.23 Tunbridge Wells borough faces significant transport challenges, particularly in terms of managing existing congestion and future growth, as well as needing to respond to the impacts of air quality and climate change. The borough has an extensive highway network, with several A roads converging in the urban area of Royal Tunbridge Wells, including the A21, A26, A264 and A228, and A267. There have been recent improvements to the strategic road network at North Farm and duelling of the A21, but congestion on the A21 at Kippings Cross and the A228/A264 Pembury Road remain unresolved. There are also further congestion, capacity, and air quality issues on the A26, A264, and A228 Colts Hill. 2.24 The Council has an adopted Borough Transport Strategy, which sets out the vision for transport infrastructure for the period from 2015 to 2026. The objective of this document is not only to address existing transport problems, but also to support the level of growth set out within the previous adopted Core Strategy and Site Allocations Local Plan. Updated transport assessment and modelling work has been undertaken, which will allow, in parallel with the new Local Plan, preparation of a refreshed version of the Borough Transport Strategy to cover the period to 2036. The transport evidence, including assessment and modelling work, is available on the Supporting Documents page of the Local Plan website”

Please see our comments under COMMENT BOX 2 in relation to Policies TP 1, TP 2 and TP 6 and in COMMENT BOX 7 in relation to the SWECO Local Plan Transport Evidence Base.

DLP_4357

British Horse Society

Paragraph 2.43

Para 2.43

Object

This refers to an extensive network of public rights of way but fails to mention that bridleway provision in the Borough is exceptionally poor.

DLP_4393

Mill Lane and Cramptons Residents Association

Paragraph 2.32 (p. 28)

The scale of housing development proposed across Kent is unprecedented and will have a disastrous effect on many historical settlement including Sissinghurst. Why is TWBC not challenging this level of growth ?

The ‘housing numbers’ are from studies that have already been challenged. There are more recent factors that also need to be addressed:

  • Brexit with or without a deal may mean economic decline in the UK and a reduction in immigration, which has largely fuelled the increase in population. Why have the housing figures not been re-calculated ?
  • Why is so much housing planned for the already overheated SE of England. The North and deprived parts of Britain are crying out for investment. Government Strategic policy should be focusing on rebalancing the country with appropriate investment of economic activity and housing, where it is most needed.
  • TWBC should be working with other Kent Districts, Kent County Council, the LGA and local MPs to challenge the scale of proposed housing. This proposed housing will kill the ‘golden goose’ that is the Weald of Kent, with its high quality AONB landscape and unique heritage villages like Sissinghurst. It will turn this part of the country into somewhere urbanised and soulless - bisected by unpleasant and polluting main roads.

DLP_4396

Mill Lane and Cramptons Residents Association

Paragraph 2.44

AGREE with the aims set out in these sections

COMMENT 

Why then is TWBC planning large scale developments for Sissinghurst that are not ‘intimate and small scale’ and are totally at odds with the aspirations set out in these sections.

Why is COALESCENCE of the historic and separate settlements of Cranbrook, Wilsley, Cranbrook Common, and Sissinghurst being actively encouraged with the proposed housing sites.

DLP_4399

Mill Lane and Cramptons Residents Association

Paragraph 2.27

TRAFFIC IMPACT 

The estimated 1000+ houses in Cranbrook and Sissinghurst mean at least another 2000 cars in the immediate area. This is further exacerbated by the fact that many of the larger housing sites are some way from Cranbrook and Sissinghurst necessitating car journeys for school, work, shopping and services. But Cranbrook is not alone - there is also the huge increase in housing which is already happening or planned in nearby Hawkhurst, Staplehurst, Headcorn and Marden. Roads in the area are already at capacity - recent accidents on the A.229 north of Cranbrook show the dangers of too much traffic and the chaos caused on small country roads, when the main roads had to be closed.

The local railway stations e.g. Staplehurst, Marden and Headcorn are mentioned in TWBC’s own Transport report (TWBC Local Plan Transport Evidence Base) and point out that Staplehurst is already the busiest station. There will inevitably be an increase in traffic to those stations especially with little new employment locally.

DLP_4400

Mill Lane and Cramptons Residents Association

Paragraph 2.25

AIR QUALITY 

This section talks of opportunities for improving air quality - yet development on important greenfield sites and the AONB plus the added traffic volume is bound to decrease air quality, owing to the loss of the beneficial effects of trees and plants on air pollution.

The section also has a worthy aim to promote non-motorised transport e.g. walking and cycling, with which is agreed. Why then are there large development sites for Cranbrook well out of walking range of the town’s services and schools ?

As well as congestion there will be added noise, light-pollution at night, and loss of air quality - all of which affect the fragile Conservation Areas, the many Listed buildings in the area and the surrounding AONB landscapes.

DLP_4436
DLP_4442

Mr James Rourke
Nick Lucas

Paragraph 2.23

TWBC: the following comment was made by the list of responders on the left:

I object to the strategy of placing 1,751 new houses east of Goudhurst, when almost all employment opportunities for the borough is proposed in Tunbridge Wells. The highways are not big enough to accommodate the increase in traffic. Development compromises historic narrow streets, especially on the A262 in Goudhurst where there is no provision to widen or upgrade in the local plan. The increase in traffic (Cars, Lorries, Buses,etc) will result in increased pollution leading to irreparable damage to heritage assets, detrimental impact on the health of local residents and destroy the AONB as a whole.

DLP_4459

Paddock Wood Neighbourhood Plan Steering Group

Paragraphs 2.13-2.16 Sustainable Development

The Plan is confined to the borough’s boundary. The strategy proposes transformational change to Paddock Wood/east Capel, and a new settlement at Tudeley, close to Tunbridge Wells and Tonbridge. Paddock Wood would no longer remain a small rural town. The strategy proposed would more sharply divide the borough into an urban west and rural east.

Although outside the Paddock Wood Neighbourhood Plan designated area we are very concerned about the loss of Green Belt between Paddock Wood and Capel.

For development to be sustainable it must be supported by infrastructure that is reasonably necessary. All the housing sites identified in the Key Diagram and under AL/PW1 require flood compensation.  This will absorb developer contributions better put elsewhere and compromises the garden village ideal that underpins the strategy for Paddock Wood/east Capel.

Questions arise concerning the identification, prioritisation and phasing of specific infrastructure schemes and hence the deliverability of the strategy. In respect of their prioritisation, more infrastructure may be critical and essential than desirable. Of particular concern is how critical many of the projects are, the magnitude of cost and the uncertainty concerning their phasing, and the funding position overall. For example, the IDP lists the new Colts Hill bypass as being critical (p94), as needing to be in place before sites come forward for development, yet the all-important policy STR1(2) refers to the bypass in terms of it being a potential scheme.

The Plan proposes masterplanning and betterment.  The NP group still has to be convinced that TWBC can deliver this.

DLP_4460

Paddock Wood Neighbourhood Plan Steering Group

Paragraphs 2.17-2.22 Infrastructure

The Infrastructure Delivery Plan contains insufficient detail on which the Neighbourhood Plan could comment.

DLP_4571

Keith Stockman

2.21 The delivery of the infrastructure is key

The need for a new Medical Facility is generated by development, so contrary to TWBC Plan, it is not ‘infrastructure led’. All the local GP surgeries are working to capacity and no site has, as yet been identified for a Medical Centre. New residents to Cranbrook will be forced to sign on at surgeries out of the Parish (needing transport to get there, so not sustainable in these terms).

DLP_4577

Keith Stockman

2.32

2.32 Given the environmental constraints within the borough, it is important that new development makes the most efficient use of land, while also ensuring that development is of a high quality, in sustainable locations, and does not have an unacceptable adverse impact on the character and setting of the natural and built environment of the borough.

The large scale developments proposed in Cranbrook and Sissinghurst are simply not sustainable. There is a lack of local employment and people will have to travel to work outside of the Parish along already overstretched roads. Large scale developers are not building to a high quality standard, and are citing TWBC building standards (far below that of the Parish) as an excuse. The local GP surgeries and schools are full to capacity, no provision for new facilities has been made. The scale of the development proposed will clearly have an unacceptable adverse impact on the character and setting of the natural and built environment of the borough, especially as this is in an AONB.

DLP_4580

Keith Stockman

2.44

2.44 The cumulative impact of minor piecemeal development and small changes in land use can have a significant overall adverse impact on the natural, built, and historic environment, and on the character and settlement pattern within, and adjacent to, the High Weald AONB.

Large scale developments are completely out of place and not necessary to meet the housing needs of the Parish of Cranbrook and Sissinghurst. The inference of the above statement, that ‘piecemeal’ means bad development, is disingenuous as minor ‘piecemeal’ development is exactly how habitation in the High Weald actually evolved. Small scale, high quality development could be used to provide a template for new, high quality Conservation Areas in the future.

DLP_4584

Keith Stockman

2.16

2.16 Additionally, the Draft Local Plan will seek to achieve sustainable construction objectives and the use of responsibly sourced and low environmental impact building materials to reduce waste and resources.

Clearly, these objectives are not being met by the current development in Cranbrook. If TWBC are serious about these objectives then the whole development plan proposed should be reviewed accordingly, as should TWBC’s own codes of practice for building contractors.

DLP_4588

Keith Stockman

2.15

2.15 Furthermore, climate change is a major issue at both the national and local level, and the policies contained within this Draft Local Plan will seek to support carbon reduction

If TWBC are serious about supporting carbon reduction, why are they proposing to build large scale developments in Cranbrook and Sissinghurst which are miles away from designated centres of employment and are located in an area where there is very poor public transport infrastructure, thus necessitating new residents to use personal transport to get to/from work. The road system is already overstretched, with regular traffic jams, especially at peak times. Idling cars in traffic queues are one of the chief contributors to carbon pollution. Apart from the infrastructure problems that would flow from the proposed development, the design and build quality of the proposed housing is generally not such that it does not contribute in any way to carbon reduction.

DLP_4615
DLP_4727
DLP_4861
DLP_5789
DLP_5858
DLP_6216
DLP_6506
DLP_6697
DLP_6900
DLP_7123
DLP_7161

Diana Robson
Mike & Felicity Robinson
Mr Richard Cutchey
Kevin Conway
Lorraine Soares
Angela Thirkell
Madelaine Conway
Clive Rivers
Deborah Dalloway
Gillian Robinson
Paula Robinson

Section 2 para 2.7, 2.8, 2.11, 2.22, 2.32

TWBC: the following comment was made by the list of responders on the left:

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_4617

Anne Watson

2.21

Section number 2.21

Several local GP’s are approaching retirement age, so will need replacing. However the surgeries at present are at or are very near capacity, so new Cranbrook residents will have to go elsewhere for appointments. My surgery has had several recent replacement doctors and they have lasted less than a year. Patients may therefore be needing transport: own cars or hospital cars or infrequent buses to get to an appointment.

DLP_4645

Ann & John Furminger

paragraph 2.21

the delivery of infrastructure has not been fully thought out eg roads/usage, public transport, medical services, car parking etc

DLP_5527

Mr Paul Hewitt

Paragraph 2.21

2.21 The delivery of infrastructure is key

All the local GP surgeries are working to capacity. No site has, as yet been identified for a Medical Centre. It is believed that new residents to Cranbrook will be expected to sign at surgeries out of the Parish (needing transport to get there)

The need for a new Medical Facility is generated by development, so contrary to TWBC Plan, it is not ‘infrastructure led’

DLP_5535

Mr Paul Hewitt

Paragraph 2.32

2.32 Given the environmental constraints within the borough, it is important that new development makes the most efficient use of land, while also ensuring that development is of a high quality, in sustainable locations, and does not have an unacceptable adverse impact on the character and setting of the natural and built environment of the borough.

The large-scale developments proposed in Cranbrook and Sissinghurst are not, in any way, sustainable. There is a lack of local employment and people will have to travel to work

The GP surgeries are full to capacity

The road network dictates that it is not possible to use active transport in many areas

The Parish advocates a building standard towards Passivhaus which is long term sustainable and of high quality. Large scale developers are not building to this standard, citing TWBC building standards (far below that of the Parish)

DLP_5537

Mr Paul Hewitt

Paragraph 2.44

2.44 The cumulative impact of minor piecemeal development and small changes in land use can have a significant overall adverse impact on the natural, built, and historic environment, and on the character and settlement pattern within, and adjacent to, the High Weald AONB.

This is a very misleading statement as minor ‘piecemeal’ development is exactly how habitation in the High Weald DID evolve. Large scale developments are out of place and not necessary to meet the housing need of the Parish of Cranbrook and Sissinghurst.

The implication of this statement, is that ‘piecemeal’ means bad development. When in fact small scale, high quality development using a Masterplanning Approach could deliver the Conservation Areas of the future, an exciting prospect

DLP_5543

Mr Paul Hewitt

Paragraph 2.16

2.16 Additionally, the Draft Local Plan will seek to achieve sustainable construction objectives and the use of responsibly sourced and low environmental impact building materials to reduce waste and resources.

A large-scale developer about to build in Cranbrook stated that they build to parameters set by TWBC building codes. This is reflected in the poor design and sustainability of the plans so far.

Cranbrook has a much higher quality building code, aspiring for construction to be towards ‘Passivhaus’ standard

DLP_5550

Mr Paul Hewitt

Paragraph 2.15

2.15 Furthermore, climate change is a major issue at both the national and local level, and the policies contained within this Draft Local Plan will seek to support carbon reduction

Building large scale developments in Cranbrook and Sissinghurst so far from centres of employment in areas where there is poor transport infrastructure which is almost impossible to mitigate, does not support carbon reduction.

Why is the Parish taking 11% of the Borough’s housing when employment is being targeted to Tunbridge Wells?

Carbon reduction is not supported when TWBC building design codes allow the most basic of carbon reducing building methods.

DLP_5582

Mrs Jacqueline Hewitt

Paragraph 2.21

2.21 The delivery of infrastructure is key

All the local GP surgeries are working to capacity. No site has, as yet been identified for a Medical Centre. It is believed that new residents to Cranbrook will be expected to sign at surgeries out of the Parish (needing transport to get there)

The need for a new Medical Facility is generated by development, so contrary to TWBC Plan, it is not ‘infrastructure led’

DLP_5586

Mrs Jacqueline Hewitt

Paragraph 2.32

2.32 Given the environmental constraints within the borough, it is important that new development makes the most efficient use of land, while also ensuring that development is of a high quality, in sustainable locations, and does not have an unacceptable adverse impact on the character and setting of the natural and built environment of the borough.

The large-scale developments proposed in Cranbrook and Sissinghurst are not, in any way, sustainable. There is a lack of local employment and people will have to travel to work

The GP surgeries are full to capacity

The road network dictates that it is not possible to use active transport in many areas

The Parish advocates a building standard towards Passivhaus which is long term sustainable and of high quality. Large scale developers are not building to this standard, citing TWBC building standards (far below that of the Parish)

DLP_5589

Mrs Jacqueline Hewitt

Paragraph 2.44

2.44 The cumulative impact of minor piecemeal development and small changes in land use can have a significant overall adverse impact on the natural, built, and historic environment, and on the character and settlement pattern within, and adjacent to, the High Weald AONB.

This is a very misleading statement as minor ‘piecemeal’ development is exactly how habitation in the High Weald DID evolve. Large scale developments are out of place and not necessary to meet the housing need of the Parish of Cranbrook and Sissinghurst.

The implication of this statement, is that ‘piecemeal’ means bad development. When in fact small scale, high quality development using a Masterplanning Approach could deliver the Conservation Areas of the future, an exciting prospect

DLP_5595

Mrs Jacqueline Hewitt

Paragraph 2.16

2.16 Additionally, the Draft Local Plan will seek to achieve sustainable construction objectives and the use of responsibly sourced and low environmental impact building materials to reduce waste and resources.

A large-scale developer about to build in Cranbrook stated that they build to parameters set by TWBC building codes. This is reflected in the poor design and sustainability of the plans so far.

Cranbrook has a much higher quality building code, aspiring for construction to be towards ‘Passivhaus’ standard

DLP_5599

Mrs Jacqueline Hewitt

Paragraph 2.15

2.15 Furthermore, climate change is a major issue at both the national and local level, and the policies contained within this Draft Local Plan will seek to support carbon reduction

Building large scale developments in Cranbrook and Sissinghurst so far from centres of employment in areas where there is poor transport infrastructure which is almost impossible to mitigate, does not support carbon reduction.

Why is the Parish taking 11% of the Borough’s housing when employment is being targeted to Tunbridge Wells?

Carbon reduction is not supported when TWBC building design codes allow the most basic of carbon reducing building methods.

DLP_5821
DLP_5846
DLP_5106
DLP_5126
DLP_6176
DLP_6579
DLP_6756
DLP_7028
DLP_7301
DLP_7419
DLP_7454
DLP_7476
DLP_7588
DLP_8092

Charles Vernede
Mrs Sarah Vernede
Mr Peter Brudenall
Alistair Nichols
May Corfield
Vivien Halley
Linda Beverley
Sally Hookham
Kylie Brudenall
Simon Parrish
Patrick Thomson
Sally Thomson
Victoria Dare
Mary Curry

Paragraphs 2.11, 2.13, 2.32 and 2.46

TWBC: the following comment was made by the list of responders on the left:

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_5936

S J Ireland

Leisure and Recreation

My personal interest is as a local resident of Cranbrook with professional experience as past Director of Open Spaces for City of London (recently retired), a career in Landscape Management and a Fellow of the Landscape Institute.

  1. Having reviewed the retail study and your proposals for Tunbridge Wells, I object to the number of houses you have allocated to the main urban area. Your report accepts that the retail sector is changing significantly and yet your proposal to locate on average 1271 houses (whilst for example, requiring Cranbrook to take 761) is proportionately wrong. This is the ideal location for apartments- particularly one and two bed accommodation aimed specifically at younger and older elements of the population; where all the services are located close by and limited transport requirements. needed. By increasing the housing in the main urban area, your sustainability requirements will be easily achieved.
  2. Cranbrook has substantial AONB landscapes. I found no explanation , within the plan, as to why you are ignoring government policy which allows the Council to reduce the housing pressure by 50% in such cases. You have a duty to protect theses landscapes.
  3. The use of the term " affordable housing" is unhelpful because such units are not affordable by local people. I would encourage you to review your policy and instead focus on 1 & 2 bed properties, which can better suit need.
  4. The Leisure and Recreation policy makes no reference to Cranbrook schools sports pitches which are used in part by the community. At the very time you are proposing increasing housing and thus population; a full assessment of future recreation needs is required. Once sports facilities have been lost it is much harder to replace, particularly in a "rolling" landscape where flat or level land is limited.

DLP_5989

Pro Vision for Cooper Estates Strategic Land

Paragraphs 2.30 and 2.31

Section 2 of the draft Local Plan sets the context and confirms the challenges that the Borough faces. The Council acknowledge the need to facilitate the delivery of specialist forms of housing, including housing for older people, across the plan period in paragraphs 2.30 and 2.31 (a clear positive statement of intent).

But, despite acknowledging this need for older persons housing, it is not then reflected in the plan Strategic Objectives, nor is it therefore delivered in the draft policies of the Plan (see our comments on the Strategic Objectives and policies H9- Housing for Older People and STR1- The Development Strategy).

DLP_6004

Laura Rowland

paragraph 2.21

The GP surgeries are full and only have enough staff to see the current patients. There is no new Medical Centre site that has been recommended. This would mean new residents would need to go to new GP’s outside of the Parish which would add to further traffic/need for better public transport. Medical centre needs to be addressed before any new houses are built otherwise this is not following ‘infrastructure as key’.

DLP_6009

Laura Rowland

Paragraph 2.32

The large scale developments proposed in Cranbrook and Sissinghurst are not, in any way, sustainable. There is a lack of local employment and people will have to commute.

The GP surgeries are full to capacity

The road network dictates that it is not possible to use active transport in many areas

The Parish advocates a building standard towards Passivhaus which is long term sustainable and of high quality. Large scale developers are not building to this standard, citing TWBC building standards (far below that of the Parish)

DLP_6018

Laura Rowland

Paragraph 2.15

Building large scale developments in Cranbrook and Sissinghurst so far from centres of employment in areas where there is poor transport infrastructure which is almost impossible to mitigate, does not support carbon reduction.

Why is the Parish taking 11% of the Borough’s housing when employment is being targeted to Tunbridge Wells?

Carbon reduction is not supported when TWBC building design codes allow the most basic of carbon reducing building methods.

DLP_6206

Amanda Wells

2.15, 2.40

Sustainable Development

2.15   Biomass is not Carbon Neutral

Cutting trees down to use as fuel in energy production–known as biomass energy or bioenergy–is one of the most counterproductive things we can do if our goal is clean air and a liveable planet. Calling something ‘bio’does not mean it is good for the environment

In the draft Local Plan Biomass is mentioned in several places and in particular Policy EN 25 and paragraphs §6.242 - §6.245

This entire policy should be scrapped and any reference to biomass as carbon neutral as this is simply untrue. According to Chatham House, biomass, when burnt, emits more carbon per unit of energy than most fossil fuels.

The exact amount varies with the type of biomass and the type and age of the power plant, but figures from the Drax power station, Europe’s largest consumer of wood pellets, show that in 2013 it emitted about 13 per cent more carbon dioxide per unit of energy generated from biomass than from coal.

2.40  In the light of the overriding priority to mitigate the impact of climate change there is no justifiable reason for building on green belt.

DLP_6248

Anne Trevillion

2.30

Housing needs to be genuinely affordable for the long term. ‘Generation rent’ will not be able to continue paying exorbitant rents when they are reliant on their pensions or become ill. This needs to be council housing with secure tenancies at rents affordable on a state pension. It needs to be built to the highest standards with adequate space, and incorporating solar panels and the latest ‘green’ technology.

DLP_6264

Susan Heather McAuley

2.22, 2.23, 2.27, 2.30, 2.31, 2.32, 2.33, 2.35, 2.39

2.22

I do not think this will work.  For the development of 60 houses in Common Road Sissinghurst over the last couple of years, I understand that the Section 106 money paid for one extra bus in the early morning for a period of 12 months and for a small number of extra books for Cranbrook Library.  Nothing was paid towards improved sewerage, replacement open space for villagers etc.  This indicates that there will be very little money available from builders for infrastructure such as new roads, footways and community facilities.

2.23

The plan is correct in saying we face significant transport challenges.  These include congestion at Kippings Cross and on the entry to Tunbrige Wells and the lack of regular, timely and affordable public transport from the east of the borough into our main cultural and employment centre in Tunbridge Wells.  Therefore it is illogical and economically and environmentally unsustainable to put large numbers of houses in the eastern part of the Weald, in particular Sissinghurst, as the new people will not be able to get to the employment centre in Tunbridge Wells.  They will no doubt commute to London and create a new dormitory village out of our village of Sissinghurst.

2.27

As the plan says, local public transport in Sissinghurst is poor (in terms of routes, frequency, reliability and cost) so people use their private cars to access services and employment.  The volume of building proposed away from the urban centres will significantly increase this car usage which is environmentally unsustainable.  The increased car usage will worsen the air quality in the borough even further.  This can be avoided by putting the new buildings in Tunbridge Wells, reducing the need for car journeys to get to work and for leisure activities.  To suggest that people should walk and cycle exhibits a lack of understanding of rural issues.  Are older people to be told to walk and cycle to get to the doctor’s surgery and to do their shopping. Are young Mothers with children to be told the same?  As villages such as Sissinghurst continue to lose their local services the number of car journeys will increase from existing residents without doubling our village in size.

To avoid these environmental problems the new buildings should go in the existing urban centres.

2.30

The plan says that a mix of housing will be provided but this is not borne out by current practice.  The builders appear to be building what they choose, based on where the greatest profit lies.  Large numbers of the houses going up are 4 and 5 bedroomed, this is doing nothing to address the housing ‘crisis’. On the most recent estate built at Sissinghurst there are no starter and no downsizing homes for sale.  The shared ownership houses are out of reach financially of local people who do not qualify for social housing.  How is TWBC now going to achieve a mix of housing when it has not managed to do so to date?

2.31

Much of this paragraph seems to be a duplicate of para 2.30.  I make the same comments - The plan says that a mix of housing will be provided but this is not borne out by current practice.  The builders appear to be building what they choose, based on where the greatest profit lies.  Large numbers of the houses going up are 4 and 5 bedroomed, this is doing nothing to address the housing ‘crisis’. On the most recent estate built at Sissinghurst there are no starter and no downsizing homes, no bungalows, for sale.  The shared ownership houses are out of reach financially of local people who do not qualify for social housing.  How is TWBC now going to achieve a mix of housing when it has not managed to do so to date?

IN ADDITION – the Housing Delivery Test – this will enable TWBC to simply measure the number of houses built against the number of houses required – if housing type is not determined, planned and measured the people who need homes will not get them and the houses built will go to second homers and London money as is happening in Sissinghurst.  How does TWBC propose to measure that the right kind of homes are built?  The measurement criteria at the end of the Local Plan just refers to numbers.

2.32

The draft plan is correct – the most efficient use of land must be made.  Surely the most efficient method will be to reuse brownfield sites, not build on all of our green fields, not destroy all of the Wealden villages you are responsible for (except Bidborough and Brenchley)?  How many brownfield sites in Tunbridge Wells are not being used in this draft local plan?  Many are listed at the end of the Local Plan – there does not seem to be a shortage of brownfield sites put forward in and around Tunbridge Wells so why have so many been turned down?

2.33

The plan describes the Borough as an attractive business location but the new employment is to be concentrated in Tunbridge Wells town (extra jobs at Gills Green will be insignificant). More employment in Tunbridge Wells town means more people need to live there, not be spread across the eastern end of the borough and have to drive to Tunbridge Wells. This is not economically sustainable.  If you do not build more houses in urban Tunbridge Wells then this paragraph is proposing an economically and also environmentally unsustainable approach.

2.35

The plan states that Article 4 directives have been placed on buildings in and around Tunbridge Wells town centre.  The plan does not address the fact that these directives should also be placed on rural business locations.  Many small business and commercial centres in village and rural locations are being sold for housing. This loses employment for rural people and means more people need to travel to the town to work – which is not economically or environmentally sustainable.  This plan should include measures to stop the loss of rural businesses.

2.39

This paragraph mentions the Pantiles but not Sissinghurst Caste which receives over 200,000 visitors between April and October.  The plan says that the landscape of the rural areas is important for tourism and therefore Sissinghurst is not suitable for the amount of building yspecified in the Plan and particularly not in the locations included – along an ancient rural lane and on the entrance to the village from one of the main routes used by people visiting the Castle. These are sites AL/CRS12 and AL/CRS13.  Sissinghurst and also Cranbrook are valuable sources of income for the whole Borough and as such deserve greater protection than is being proposed in this plan.

DLP_6426

Gary Birch

Section 2 para 2.7, 2.8, 2.11, 2.22, 2.32

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

DLP_6486
DLP_6507

Clare Govan
Philip Govan

2.23

TWBC: the following comment was made by the list of responders on the left:

The statement does not mention the problems on the A262 in Goudhurst when large vehicles travelling in opposite directions meet on the corner by the church where there is no scope to widen the road.  This regularly causes extended hold-ups and there has been damage to buildings and to the churchyard wall.  This should be taken into account in considering major development in areas which will add to the traffic travelling through Goudhurst to or from Royal Tunbridge Wells.

DLP_6533

Diana Badcock

Paragraph 2.15

If Climate change is identified as a major issue, why has TWBC not insisted on the most environmental, water-saving and carbon neutral standards for all future house building? Cranbrook’s NDP has a higher building standard that it expects for all new local housing, but I see no evidence that TWBC has acted on this. The NDP also supports housing to the ‘passivhaus’ standard. TWBC should surely be taking an imaginative lead on this if we are to build houses fit for the future.

Also, new builds can offer an opportunity to help wildlife, in particular to combat the alarming decline in numbers of one of our iconic birds, the Swift, by the simple measure of incorporating Swift nest bricks/boxes under the eaves of the new buildings. It would be a small measure to set against the enormous loss of habitat that the Local Plan will entail. (Vision and Objectives 2.6 aims to achieve ‘Net gains for nature’)

DLP_6536
DLP_6646
DLP_6704
DLP_6727

Rory Govan
Stephanie Govan
Edward Govan
James Govan

2.23

TWBC: the following comment was made by the list of responders on the left:

The statement does not mention the problems on the A262 in Goudhurst when large vehicles travelling in opposite directions meet on the corner by the church where there is no scope to widen the road.  This regularly causes extended hold-ups and there has been damage to buildings and to the churchyard wall.  This should be taken into account in considering major development in areas which will add to the traffic travelling through Goudhurst to or from Royal Tunbridge Wells.

DLP_6563

Myrtle Newsom

Paragraph 2.23

The congestion at Kippings Cross deters people from travelling in from the east of the Borough – Cranbrook, Sissinghurst, Hawkhurst – for either work or pleasure. Therefore it would be unsustainable to over-develop in this area.

DLP_6566

Myrtle Newsom

Paragraph 2.27

Local public transport in Sissinghurst is poor and unreliable so people use their private cars.

DLP_6568

Myrtle Newsom

Paragraph 2.32

The most efficient use of land is not being made – brown field sites in urban areas are not being used for new housing developments.

DLP_6569

Myrtle Newsom

Paragraph 2.39

As Sissinghurst and Cranbrook are tourist sites it is important they are not spoiled by urbanisation but are protected. They are valuable sources of income for the whole Borough.

DLP_6786

G M Whitehead

Vision and Objectives 2 and Section 4

Cranbrook and Sissinghurst.

Section 2.32 states that new development should make efficient use of the land while it should not have an unacceptable adverse impact on the character and setting of the natural and built environment of the borough. In Section 4.7 it says the assessed housing needs for the borough is 678 per year.

ALL Cranbrook’s TWBC site allocations lie within the AONB including several large allocations.

70% of the Borough is protected as an AONB and national policy allows for development to be reduced where valued landscapes could be damaged. (NPPF Para.11). Why hasn’t TWBC assessed the harm that cumulative development can do to the AONB landscape and its communities and argued for lower housing numbers as a result?

DLP_6835

John Gibson

Paragraph 21

There is no local GP surgery in Sissinghurst and those in Cranbrook are heavily oversubscribed. This means that any new facility will be driven by the increased over-development and will not infrastructure led

DLP_6839

John Gibson

Paragraph 32

This proposed development is not sustainable. There is little new employment and new inhabitants will have to travel to work.

The GP surgeries are over-subscribed.

The proposed access points around the site are dangerous.

The local public transport facilities are infrequent and unattractive meaning many more car journeys.

The architectural quality of the “affordable homes” proposed in the Dandara planning application falls well short of the stated building requirements, which themselves are not of sufficiently high quality, particularly taking into account the quality of the local properties.

DLP_6874

Rosemary Cory

Section 2 para 2.7, 2.8, 2.11, 2.13, 2.22, 2.32

2.7. The Plan misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11. The claim that the infrastructure needs associated with new developments will be assessed and addressed is not credible because the council does not have the necessary powers of compulsion in relation to infrastructure.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. Many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. There is very little in the Plan which recognises the Council’s responsibility to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is meaningless in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The Plan claims that it will encourage the provision of community leisure and recreation facilities – and then proposes to replace the Hawkhurst golf course with a housing estate. This is just another inconsistency in the Plan, which calls into question its validity.

DLP_6957

Mr Simon Whitelaw

Section 2 para 2.7, 2.8, 2.11, 2.22, 2.32

2.7 Hawkhurst appears to have been bracketed with the towns of Paddock Wood and Cranbrook.Please confirm that Hawkhurst should be correctly classified as a village.

2.11 No details are provided on timing and delivery of infrastructure needs and how TWBC will work with other relevant bodies to finance and deliver the additional infrastructure.

2.13 Again no details or schedule is provided on how sustainable development will be achieved particularly in relation to road traffic,schools,sewerage and local employment.

2.15 No. details or time scale provided on how carbon emissions will be reduced

2.22 No detailed traffic flow analysis,particularly on hgv traffic growth is provided.

Damage to vehicles from potholes is an ongoing issue- what is the long term plan?

2.27 No detail or timing provided on the development of sustainable public transport to reduce private car use. What facilities are planned for E transport e.g. charging points?

2.32 What are the plans to maintain and improve the areas of AONB within the scope of the Plan

2.46 In terms of improving the local economy what cost benefit analysis is available?

DLP_7150

Kay Margaret Goodsell

2.27, 2.30, 2.32

2.27

I do not drive and rely on buses and they are not good.  Any new houses should go in Tunbridge Wells so people don’t use more cars.

2.30

My son has had to move away to Hastings as he cannot afford to live in Sissinghurst.  The wrong houses are being built and local people’s needs are being ignored.  I rarely see my grand-daughter as they are so far away.  Build the houses we need not those that second-homers and London money wants.

2.32

Use brownfield sites in Tunbridge Wells, there were plenty put forward that have not been accepted.  Do not use the green fields around our villages.

DLP_7176

Andrew Roffey

Section 2 para 2.7, 2.8, 2.11, 2.22, 2.32

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_7190

John Gibson

Section 2 paragraph 21

There is no local GP surgery in Sissinghurst and those in Cranbrook are heavily oversubscribed. This means that any new facility will be driven by the increased over-development and will not be infrastructure led

DLP_7193

John Gibson

Section 2 paragraph 32

This proposed development is not sustainable. There is little new employment and new inhabitants will have to travel to work.

The GP surgeries are over-subscribed.

The proposed access points around the site are dangerous.

The local public transport facilities are infrequent and unattractive meaning many more car journeys.

DLP_7208

Elizabeth Daley

Section 2 para 2.21

All the local GP surgeries are working to capacity. No site has, as yet been identified for a Medical Centre. It is believed that new residents to Cranbrook will be expected to sign at surgeries out of the Parish (needing transport to get there)

The need for a new Medical Facility is generated by development, so contrary to TWBC Plan, it is not ‘infrastructure led’

DLP_7212

Elizabeth Daley

Para 2.32

The large scale developments proposed in Cranbrook and Sissinghurst are not, in any way, sustainable. There is a lack of local employment and people will have to travel to work

The GP surgeries are full to capacity

The road network dictates that it is not possible to use active transport in many areas

The Parish advocates a building standard towards Passivhaus which is long term sustainable and of high quality. Large scale developers are not building to this standard, citing TWBC building standards (far below that of the Parish)

DLP_7214

Elizabeth Daley

Para 2.44

This is a very misleading statement as minor ‘piecemeal’ development is exactly how habitation in the High Weald DID evolve. Large scale developments are out of place and not necessary to meet the housing need of the Parish of Cranbrook and Sissinghurst.

The implication of this statement, is that ‘piecemeal’ means bad development. When in fact small scale , high quality development using a Masterplanning Approach could deliver the Conservation Areas of the future, an exciting prospect

DLP_7218

Elizabeth Daley

Para 2.16

A large scale developer about to build in Cranbrook stated that they build to parameters set by TWBC building codes. This is reflected in the poor design and sustainability of the plans so far.

Cranbrook has a much higher quality building code, aspiring for construction to be towards ‘Passivhaus’ standard

DLP_7221

Elizabeth Daley

Para 2.15

Building large scale developments in Cranbrook and Sissinghurst so far from centres of employment in areas where there is poor transport infrastructure which is almost impossible to mitigate, does not support carbon reduction.

Why is the Parish taking 11% of the Borough’s housing when employment is being targeted to Tunbridge Wells?

Carbon reduction is not supported when TWBC building design codes allow the most basic of carbon reducing building methods.

DLP_7244

Mr John Telling

Para 2.13 - 2.16

The word 'sustainable' seems to be conjured up to justify any proposal. It is used as a cover to validate any policy. It is hard to see how using 5% of the Greenbelt for housing is 'sustainable' in environmental terms. Next time another 5% goes, then another. Where does it stop?

We have a climate and environmental crisis which require fundamental new policies to safeguard the future of those to follow us, yet this document assumes the unquestioned objective of 'growth', and more of the actions which have got us to where we are: living 'unsustainable' lifestyles, wrecking the climate and natural environment. This plan does not feel as if it recognises the climate and environmental imperatives of today, particularly in regard to environmental impacts and transport. The ubiquity of car use is taken as a given. I comment further under 5.37 and 6.506 specifically.

There is no mention of transport in the section on climate change (para 2.15).

DLP_7412

Andrew Dewdney

2.17

I am concerned that the language in this section is rather woolly and, although full of good intent, is not sufficient with respect to proposed development in the draft plan.  I agree with Greg Clark’s recent comments that infrastructure should come before development (following a visit to Paddock Wood to hear about resident’s concerns with flooding risk and the water infrastructure there).

I was bought up in Paddock Wood in the 1970s and there has hardly been any development in terms of roads or schools or medical infrastructure since then.  In rail terms it now takes longer to get to London than it did 40 years ago, and there are no more rail services to the station since that time.  I asked one of your planning officers at the Horsmonden meeting what consultations there have been with rail providers – given that the Secretary of State for Transport recently canvassed opinion on reducing stopping services from Ashford to London (to reduce journey times for Ashford to London).  She responded saying that the rail operator had come back and said that there “may be some additional capacity”  She didn’t know whether this was at peak times or whether the rail company would operate longer trains to increase capacity.

I find this lack of analysis troubling. We live within commuting distance of London and there are plans for substantial developments down in the line in Marden and Staplehurst.  It is likely that many of the buyers of houses in Hawkhurst and Sissinghurst will commute from those stations.  The proposed development in Paddock Wood and Tudely will further significant increases in demand for rail services.  TWBC should be co-operating with other councils along the rail line to London and developing concrete plans to address capacity and parking demands that will be driven by the proposed developments.  To address this by saying that the rail company “may have some additional capacity” is not addressing infrastructure needs.  It is not joined-up government and again is evidence that the Local Plan has not been “positively prepared”.  There should be a cast iron plan to accommodate the travel, medical, educational and other infrastructure needs of the existing population and new inhabitants in the borough.

In terms of road infrastructure, the dualling of the A21 (which has been discussed since the 1970s ) has finally happened, but this has created significantly more congestion along the B2160, and at times the queues to get through Matfield can be significant.  The planning officer at the Horsmonden consultation meeting rather tritely commented that such queues are good for reducing speeding vehicles – but I would argue that having lines of stationary cars is not good for the environment or the inhabitants of Matfield or other villages across the borough.  Try getting through Sissinghurst at almost any time of the day and you will see the problem as well.

Provision should be made in the plans in the villages for off-road parking for residents and visitors alike to maintain the road capacity and allow it to accommodate the additional demand from the proposed housing developments.  Your planning officer said that this was difficult as landowners didn’t want to sell land for parking – but for housing.  She said I should make a comment on the plan – but also identify sites that I thought  could be appropriate for such purpose.  That is not my job.  The aim of the Local plan is to set the outline for development in the borough, and to address the constraints on infrastructure to accommodate it.  If more development in the villages means that the developers have to allow for new off street parking for existing residents to maintain road capacity, I am sure that the landowners will find ways of accessing suitable sites.  Again, this is evidence that the Local Plan has been built to accommodate a centrally imposed housing quotas rather than a bottom-up approach as to how local communities will be impacted.

I share my Parish Council’s concerns about the incomplete Infrastructure Development Plan (IDP).  Surely TWBC should be specifying the core infrastructure assets that need to be in place and ready by construction or occupation of the first phase of house-building.  At the time of the Horsmonden consultation, the Calverley Square Project was still going ahead.  TWBC’s  external borrowing limit is currently £108m and Calverley Square would have taken up at least £97m of this limit.  I asked the planning officer how TWBC could expect to deliver the projects on the “Infrastructure” board at the presentation if it could only borrow an additional £10m, and she said that infrastructure improvements would be delivered by developers funding them as a condition to obtaining planning permission.

Developers are commercial companies and as such can change strategies, merge and go bankrupt.  I think it is a great weakness of the draft Plan that the council has not commented on how it would guarantee the infrastructure commitments given by developers would actually happen.  I asked her what would happen to such infrastructure commitments given in Paddock Wood, now that the second phase of the development has been stopped by the developer.  To my great surprise, she said that the Paddock Wood contract had been a “mistake”.

I think that a development led plan, rather than an infrastructure led plan, will lead to many more mistakes by TWBC and risk leaving inhabitants with the housing but not the associated infrastructure improvements.

DLP_7435

Catherine Baker

Paragraphs 2.11, 2.13, 2.32 and 2.46

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_7617

Mr J Boxall

2.23, 2.39, 2.43

2.23

With the majority of proposed growth outside Tunbridge Wells and to the north and east of the Borough the A21 will be under greater pressure in this area.

The A21 between Lamberhurst and Blue Boys needs dualling as it is congested now without further housing put into eastern side of the Borough.

Sissinghurst village centre also has unresolved congestion issues causing air quality issues

2.39

One of the key tourism locations, 200,000 plus visitors a year, known worldwide, is Sissinghurst Castle which is not referred to in this paragraph.  Improved protection of this site, its surrounding area and adjacent village, through which most visitors travel, is required by extending the AONB around Sissinghurst village and preventing overdevelopment around the village and surrounding areas.

Cranbrook also is a tourist destination with its windmill, museum and historic buildings and should be protected from over development

The rural area and landscape around Cranbrook and Sissinghurst should be protected from over development as it is a well-known walking area with The High Weald trail, The 1066 Harolds Way, Walk in Time series of walks and the “Green Book” walks going through the area encouraging green tourism.

2.43

New development should not impact on the Landscape and Environment

DLP_7624

Mr James Peace

Paragraph 2.44

This statement implies that piecemeal development is bad development whereas this is exactly how the High Weald has developed over time. Large scale developments are out of place and not needed/wanted in the Parish of Sissinghurst and Cranbrook. Small scale development could create an exciting opportunity to enhance our small town.

DLP_7674

Joe Hughes

2.23

The statement does not mention the problems on the A262 in Goudhurst when large vehicles travelling in opposite directions meet on the corner by the church where there is no scope to widen the road.  This regularly causes extended hold-ups and there has been damage to buildings and to the churchyard wall.  This should be taken into account in considering major development in areas which will add to the traffic travelling through Goudhurst to or from Royal Tunbridge Wells.

DLP_7756

Annie Hopper

Para 2.21

No site has been identified for a Medical Centre – why not? There is no capacity in any of the three surgeries in Cranbrook. Sissinghurst does not have its own surgery despite having significant numbers of new housing built in the village.

The need for a new Medical Facility is generated by development (900 houses) and cannot possibly be ‘infrastructure led as stated in the TWBC LP.

DLP_7760

Annie Hopper

Para 2.32

There is a lack of local employment in Cranbrook and Sissinghurst. The number of proposed houses within the Parish are not, in any way, sustainable as people will have to travel to work outside the Parish.

The GP surgeries are full to capacity meaning any new incomers will have to travel to Hawkhurst for medical facilities.

The road network is already congested with cars so active transport is not feasible in many areas.

The Parish advocates a building standard towards Passivhaus which is long term sustainable and of high quality. Large scale developers are not building to this standard, citing TWBC building standards (far below that of the Parish)

DLP_7762

Annie Hopper

Para 2.44

The habitation in the High Weald DID evolve in this manner. It is large scale developments that are completely out of place and out of character. They will have significant adverse impacts on the natural built and historic environment. Such proposed large developments are not necessary to meet the housing need of the Parish.

The implication of this statement, is that ‘piecemeal’ means bad development when in fact small scale, high quality development using a Masterplanning Approach would be much more beneficial to the above.

DLP_7767

Annie Hopper

Para 2.15

Building large scale developments in Cranbrook and Sissinghurst does not support carbon reduction.

Building so far from centres of employment in areas where there is poor transport infrastructure which is almost impossible to mitigate, does not support carbon reduction.

Why is the Parish taking 11% of the Borough’s housing when employment is being targeted elsewhere in the borough. This does not support carbon reduction

TWBC building design codes allow the most basic of carbon reducing building methods – more needs to be done to support this statement above.

DLP_7800

Mr Colin Sefton

2.15

2.15  Sustainable Development 

I strongly welcome this paragraph and I propose that the objectives in this paragraph should be rigorously enforced, e.g. by only granting planning permission for houses that are zero carbon and include actions to reduce water use, e.g. “grey water” systems.

DLP_7801

John Bancroft

Para 2.23

There is no recognition of the problems on the A262 particularly through Sissinghurst village where there is a stream of 42 tonne HGVs (many from Continental Europe) and heavy duty tractors with trailers carrying chicken waste from Fridays egg farms.

Sissinghurst village does not have any public car parks - consequently all householders on A262 (The Street) and on Common Road tend to park on their respective road thus adding to the traffic problem.

In addition, there are existing bottlenecks on the A262 at Goudhurst and Biddenden.

DLP_7860

Peter Felton Gerber

Section 2 para 2.7, 2.8, 2.11, 2.22, 2.32

2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook.

I am aware that the council wanted to designate Hawkhurst as a town, it did not however, because the council decided Hawkhurst is a town it is a town and the council are simply riding roughshod over the wishes and desires of the democratic population of Hawkhurst. I would suggest that the council is acting ultra vires in that regard

2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance. Once again the council has made up its mind and is simply paying lip service to any form of discussion, the council is not acting according to proper democratic principles.

In particular, there is no adequate assessment of the requirements for dealing with foul water effluent, there are already repeated incidents of raw sewage being released into the environment. Further, the crossroads at Hawkhurst is frankly impassable owing to the considerable volume of traffic and the local authorities total failure to take any adequate steps to alleviate the difficulties.

2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs.

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan.

DLP_7951
DLP_7992

Sharon Pickles
Richard Pickles

Paragraph 2.21

TWBC: the following comment was submitted by the list of responders on the left:

All the local GP surgeries are working to capacity. No site has, as yet been identified for a Medical Centre. It is believed that new residents to Cranbrook will be expected to sign at surgeries out of the Parish (needing transport to get there)

The need for a new Medical Facility is generated by development, so contrary to TWBC Plan, it is not ‘infrastructure led’

DLP_8016

Penny Ansell

Paragraphs 2.11, 2.13, 2.15, 2.22, 2.7, 2.32 and 2.46

2.11. The Draft Local Plan stresses the importance of infrastructure and its ability to accommodate future growth and claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess.

2.13 The Draft Local Plan claims that the achievement of sustainable development is a key theme that underpins national planning policy: Any further development in Hawkhurst is clearly unsustainable. The sewerage (recently raised in Parliament by Greg Clark M.P. for TW), roads, school, GP’s and employment opportunities, are all factors which show complete overload.

2.15 Regarding climate change, the Plan states that to counteract the impacts of climate change - “ (its) policies will seek to support carbon reduction.” This is patently untrue as the effects of major development (700+ dwellings) within Hawkhurst will reduce the number of trees and vastly increase the traffic problems and the associated CO2 emissions from cars and lorries.

2.22 The Draft Local plan suggests that infrastructure mitigation proposals will be put in place. However, the proposal of a “relief road” in Hawkhurst in no way mitigates the situation – it ensures things will get worse. The planning application 19/02025 clearly shows the proposed relief road to be a substandard additional road totally unsuited to the sort of traffic flow it envisages – HGV’s, buses and substantial numbers of cars. It tries to explain that changes to the Flimwell lights will ensure this proposal will work but apart from being in another council area the planned changes will still not allow HGV’s to turn left onto the A21. A total nonsense!

In any case, how can the introduction of a vast housing estate and its associated hundreds of extra cars and vehicle journeys mitigate the congestion situation in Hawkhurst?

2.27 The Draft Local Plan states that it must encourage and promote the uptake of active and sustainable transport where possible. This is impossible in Hawkhurst due to the topography, along with the fact that there are virtually no useable public transport links. With little or no employment opportunities within the village new residents will be forced to use their cars. No one in their right mind would contemplate cycling far anywhere out of the village as this would involve risking their lives on roads wholly unsuitable for cycles or walking.

indeed, the Council acknowledges this “local residents must travel further and often these journeys are undertaken by car”

2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact.

Reference here should also be made to the strategic objective number 6 “ to protect the valued heritage of built and natural environment of the borough including AONB and to achieve net gains for nature”

2.46 The Local  Plan  suggests the provision of leisure, recreation, and cultural facilities will enhance the sustainability of communities and, at a wider borough level, will create a more vibrant economy that will attract businesses, visitors, and tourists to the area. Yet it proposes that Hawkhurst will benefit from concreting over the Golf Course. This demonstrates the absurdity of the plan and the lack of cross referencing. Apart from the developers absolutely no one benefits from this proposal. The huge number of objections to the development clearly shows the feelings of local residents. Yet the Local Plan dismisses the village response.

DLP_8031

Rose May McAuley

2.22, 2.23, 2.27, 2.33

2.22

This will not happen – the traffic is bad as it is, there are not enough local services for more people so every one will be driving making the traffic worse.  When Bramling Gardens was built in Common Road Sissinghurst no space was made for them at the School and they all drive miles to go shopping even though the Transport Plan done by the builder said there would be a footpath and they would walk everywhere. This was never going to happen and it hasn’t.  They all drive to get anywhere so what is the point of them living in Sissinghurst.

2.23

I live in Sissinghurst but do not drive and it is very expensive for me to get anywhere.  The buses do not go at the right times and are unreliable and have been limited as not enough people use them if I want to go to London they often don’t join up with the trains, especially on the way home.  I often get stranded and have to call for a lift.  I try to be independent but it doesn’t work.  I cycle to work one mile away and risk my life every day doing that on country roads where people never keep to the speed limit.  We do not need even more cars on these roads.  I have elderly relatives in the village and they find they have to drive to the shop as the road is too busy and cars are parked everywhere, it is more dangerous for them to walk.  I have to walk along a busy road to get to a bus to Tunbridge Wells so it won’t help me having all the entertainment in that town.

2.27

As the Draft Plan says, public transport from Sissinghurst is not good and new people will use their cars making everywhere dirtier and more dangerous.  If the new houses go in the town of Tun Wells people will use the buses to get around and there will be fewer car journeys which is exactly what you are trying to achieve.  Our village shop is not supported by the new people who go to Tenterden to shop so our local services are reducing and more people will need to drive to get their food.

2.33

The Draft Plan describes the Borough as an attractive business location but the jobs are all going to go to the town of Tunbridge Wells.  If there are more jobs in Tun Wells then more people should live there, not right out here.

DLP_8048

Sophie Foster

2.23

The statement does not mention the problems on the A262 in Goudhurst when large vehicles travelling in opposite directions meet on the corner by the church where there is no scope to widen the road.  This regularly causes extended hold-ups and there has been damage to buildings and to the churchyard wall.  This should be taken into account in considering major development in areas which will add to the traffic travelling through Goudhurst to or from Royal Tunbridge Wells.

DLP_8066

Ashley Saunders

 

I make the following general observation on these paragraphs:

Paragraph 2.9 (p.24) states “As the challenges highlighted in the section below show, the potential of some areas of the borough to accommodate new growth is constrained by factors such as highway capacity, landscape sensitivity, flooding, and the nature of the natural and built environment. These factors have all been taken into account when considering the growth strategy and distribution of development set out within this Draft Local Plan

All of the constraints listed above, plus many more, affect the proposed developments at Tudeley (AL/CA 1) and East Capel (AL/CA 3 & AL/PW 1), as well as the land safeguarded for the proposed A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley AL/CA1 to the Colts Hill Bypass (Five Oak Green Bypass) according to the SWECO Local Plan Transport Evidence Base p.138 and 142). There is no evidence in all of the supporting documents which demonstrates that these factors have properly been taken into account.

Under Transport, paragraphs 2.23-2.24 (p.26) state “2.23 Tunbridge Wells borough faces significant transport challenges, particularly in terms of managing existing congestion and future growth, as well as needing to respond to the impacts of air quality and climate change. The borough has an extensive highway network, with several A roads converging in the urban area of Royal Tunbridge Wells, including the A21, A26, A264 and A228, and A267. There have been recent improvements to the strategic road network at North Farm and duelling of the A21, but congestion on the A21 at Kippings Cross and the A228/A264 Pembury Road remain unresolved. There are also further congestion, capacity, and air quality issues on the A26, A264, and A228 Colts Hill. 2.24 The Council has an adopted Borough Transport Strategy, which sets out the vision for transport infrastructure for the period from 2015 to 2026. The objective of this document is not only to address existing transport problems, but also to support the level of growth set out within the previous adopted Core Strategy and Site Allocations Local Plan. Updated transport assessment and modelling work has been undertaken, which will allow, in parallel with the new Local Plan, preparation of a refreshed version of the Borough Transport Strategy to cover the period to 2036. The transport evidence, including assessment and modelling work, is available on the Supporting Documents page of the Local Plan website

Please see our comments under COMMENT BOX 2 in relation to Policies TP 1, TP 2 and TP 6 and in COMMENT BOX 7 in relation to the SWECO Local Plan Transport Evidence Base.

DLP_8166

Highways England

Transport (Section 2: Challenges and Opportunities)

Transport (Section 2 – Challenges and Opportunities)

1. It is noted at paragraph 2.23 that Tunbridge Wells Borough faces “significant transport challenges, particularly in terms of managing existing congestion and future growth”, and while the focus of the Draft Local Plan is to ensure that both active travel and sustainable modes of transport are provided, there exists a need to balance the rural regions and private vehicle as the preferred mode of transport.  Highways England accepts that inevitably, mode shift in rural regions is difficult without access to good sustainable transport options and that there will be a requirement to plan for vehicles (para 2.27).

2. Highways England would strongly encourage all parties to engage with us at an early stage on all planning matters (plans/ applications) that might have an impact on the SRN. We are committed to working with local planning/ highway authorities, applicants, other statutory consultees and infrastructure providers recognising that we have a responsibility to support and develop a more coordinated approach to planning with regards the SRN and the local highway network.

It may, therefore, be helpful to include text somewhere in the plan covering applicants’ need to engage with Highways England. Such text could usefully refer to the need for any developer of a site that by virtue of its location or traffic generation may affect the safety or operation of the strategic road network to provide robust evidence regarding the impacts and, as appropriate, to mitigate them. Any SRN mitigation is likely to be agreed and delivered via the use of S278 agreements under the Highways Act, rather than via S106 or CIL. A cross reference to national transport policy and Highways England guidance would also assist.

This would work well in conjunction with paragraph 2.24, that highlights the need for the infrastructure planning process to identify certain issues as part of a robust and credible evidence base.  The process should outline what infrastructure is needed (e.g. public transport measures, cycle lanes with road building as a last resort) to enable the delivery of all the DLP development and also detail the associated costs, sources of funding, timescales for delivery and gaps in funding.

It should also cross reference to the text on Transport Assessment and Travel Plans Section 6.

Similar text and cross references should also be included in the IDP.

TWBC: see Technical Note. See also full representation].

DLP_8189

Mrs Suzi Rich

2.9 - 2.10, 2.23-2.24

Paragraph 2.9 (p.24) states “As the challenges highlighted in the section below show, the potential of some areas of the borough to accommodate new growth is constrained by factors such as highway capacity, landscape sensitivity, flooding, and the nature of the natural and built environment. These factors have all been taken into account when considering the growth strategy and distribution of development set out within this Draft Local Plan”

All of the constraints listed above, plus many more, affect the proposed developments at Tudeley (AL/CA 1) and East Capel (AL/CA 3 & AL/PW 1), as well as the land safeguarded for the proposed A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley AL/CA1 to the Colts Hill Bypass (Five Oak Green Bypass) according to the SWECO Local Plan Transport Evidence Base p.138 and 142). There is no evidence in all of the supporting documents which demonstrates that these factors have properly been taken into account.

Paragraphs 2.23-2.24, under the sub-heading ‘Transport’ (p.26) it states “Tunbridge Wells borough faces significant transport challenges, particularly in terms of managing existing congestion and future growth, as well as needing to respond to the impacts of air quality and climate change. The borough has an extensive highway network, with several A roads converging in the urban area of Royal Tunbridge Wells, including the A21, A26, A264 and A228, and A267. There have been recent improvements to the strategic road network at North Farm and duelling of the A21, but congestion on the A21 at Kippings Cross and the A228/A264 Pembury Road remain unresolved. There are also further congestion, capacity, and air quality issues on the A26, A264, and A228 Colts Hill. 2.24 The Council has an adopted Borough Transport Strategy, which sets out the vision for transport infrastructure for the period from 2015 to 2026. The objective of this document is not only to address existing transport problems, but also to support the level of growth set out within the previous adopted Core Strategy and Site Allocations Local Plan. Updated transport assessment and modelling work has been undertaken, which will allow, in parallel with the new Local Plan, preparation of a refreshed version of the Borough Transport Strategy to cover the period to 2036. The transport evidence, including assessment and modelling work, is available on the Supporting Documents page of the Local Plan website”

Please see my comments under COMMENT BOX 2 in relation to Policies TP 1 and TP 6 and in COMMENT BOX 8 in relation to the SWECO Local Plan Transport Evidence Base.

[TWBC: See comments DLP_8189-8214 for full representation]

DLP_8259

Ann Gibson

2.15, 2.21, 2.32, 2.44

2.15

Building large scale developments in Sissinghurst so far from centres of employment in areas where there is poor transport infrastructure, which is almost impossible to mitigate, does not support carbon reduction as travel to work will be by private cars.

Why is housing being planned for Sissinghurst when employment is being targeted to Tunbridge Wells?

2.21

All the local GP surgeries are working to capacity. No site has, as yet been identified for a Medical Centre. It is believed that new residents to Cranbrook will be expected to sign at surgeries out of the Parish (needing transport to get there)

The need for a new Medical Facility is generated by development, so contrary to TWBC Plan, it is not ‘infrastructure led’.

There is no new employment planned for Sissinghurst.  This will result in at least 50% of residents out-commuting by private vehicle to work thus increasing carbon production.  Infrastructure is clearly not the key of the Local Plan.

2.32

The large -scale developments proposed in Cranbrook and Sissinghurst are not, in any way, sustainable. There is a lack of local employment and people will have to travel to work

The GP surgeries are full to capacity. The road network dictates that it is not possible to use active transport in many areas.

2.44

Minor ‘piecemeal’ development is exactly how habitation in the High Weald DID evolve. Large scale developments are out of place and not necessary to meet the housing needs of the Parish of Sissinghurst.

DLP_8335

Joe Matthews

Section 2 Challenges and Opportunities

TWBC: correspondent submitted the following comments on 20/11/19, after the close of consultation on 15/11/19:

Paragraph 2.21

The delivery of infrastructure is key

All the local GP surgeries are working to capacity. No site has, as yet been identified for a Medical Centre. It is believed that new residents to Cranbrook will be expected to sign at surgeries out of the Parish (needing transport to get there)

The need for a new Medical Facility is generated by development, so contrary to TWBC Plan, it is not ‘infrastructure led’