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Section 3: Vision and Objectives


This response report contains comments received on Section 3: Vision and Objectives.

Contents

General Comments on the Vision and Objectives

Comment No.

Name/Organisation

Response

DLP_246

James Venn

The whole Plan

I’m concerned that the Plan should only be developed/agreed via proper consultation with adjacent Borough Councils. In respect of transport, jobs, schooling & food shopping, some areas impacted by these proposals look more to other towns outside the borough for their supporting facilities, than they do to Tunbridge Wells itself.

For example, Capel & Tudeley currently have much easier (but still not good) access to Tonbridge train station than to T/Wells. But many residents’ facilities in Tonbridge are already strained, so Tunbridge Wells planners need to ensure they don’t just shirk responsibility - by passing their problems onto Tonbridge & other areas outside the Borough.

DLP_909

Louise Wilby

The Plan is making the mistakes of Calverley Square and the Hendy Motor Village - proposing building developments that will deliver profits for developers and landowners rather than answering the real needs of residents.

The Capel development is particularly inappropriate, forming the core of a Tunbridge Wells - Paddock Wood - Tonbridge conurbation, at the expense of both Green Belt and the AONB; I therefore support the Save Capel campaign.

The Green Belt can officially only be used for development in 'exceptional circumstances' - which these are not. In the light of the Climate Emergency we should be enriching the Green Belt by planting new trees and extending natural habitats, not paving over it.

Garden Towns elsewhere in the UK are not producing the utopia claimed; as Essex-based Cambridge academic Rosie Pearson puts it, they "look to the past, not the future"

https://medium.com/@stjohnscamalumni/spotlight-on-garden-towns-96027a927a37

The Plan proposes far more houses than are needed, even under the flawed "follow the Govt orders" basis adopted - the 2014 calculation method used to calculate house numbers has been superseded by a 2016 version that would halve the numbers.

A new figure of about 7,000 houses could be accommodated on brownfield sites in Tunbridge Wells and outside the Green Belt.

KCC reports that 10% of Kent residents live in fuel poverty and 23% of homes are poorly insulated, with the lowest EPCs - building 1000's of new houses based on a Govt. formula is not the answer to that.

"The Climate Emergency should drive us to make the best out of what we have - exploiting all available brownfield sites, making affordable incremental developments next to infrastructure, and upgrading existing accommodation - and making the Green Belt greener" John Hurst Green Party T Wells

DLP_1615

Mr Raymond Moon

Section3. Pg 31.Vision & Objectives1. OBJECT. Vision.

Mention is made of a Masterplan regarding the provision of the new infrastructure. This needs to be in place before any new houses are built in PW. More detail of time scales should be in the Draft Plan and submissions from the developers that they will support and implement the Masterplan before new build takes place.

Pg32.Vision & Objectives 2. OBJECT. Strategic Objectives.

As above, there needs to be improvements  in the existing infrastructure and no new build to be agreed by TWBC before they are in place to serve any new development proposed in the Draft plan.

DLP_1783

Ms Nicola Gooch

Whilst I wholeheartedly endorse the strategic objectives set in the draft plan, I would like to suggest adding an additional one. At the moment, the need to boost the economic role of the borough is included in objectives 1 and 5, but it does have the same level of priority as infrastructure planning, or meeting residential needs. These goals have their own strategic objective. Given the extent of out communting within the borough, and attracting high value employers to the area would help improve sustainable growth by reducing levels of commuting, it may be appropriate to consider including a strategic objective within the plans aimed at economic growth.

DLP_1796

Royal Tunbridge Wells Town Forum

We have no comments on paragraphs which are not contained in our response to the Vision and Objectives section below

DLP_2005

Dr David Parrish

Vision (Section 3) p.31

There is no justification to build on land next to, and on, Green Belt and floodplains

There no Flood Risk Assessment

The LP vision results in land that is Green Belt, next to a Flood Plain (although TGV is only 4” higher than the Environmental Depts’ flood boundary) and next to the AONB. The North East TW Borough has no such restrictions (Horsmonden and Frittenden). How can you have such a short sighted vision to plan for. Hadlow Estate was a latecomer to the Call for Sites. As a single Landowner it makes TWBC work more easy (lazy planning). The Hadlow Estate are profit driven – an Estate that allows their housing assets to fall into disrepair. And are now evicting tied tenants to make way for their plans. They have no experience of Land Development. Or planning.

The boundary of the Green Belt is not “being amended” (compensatory). A Middle section of the Green Belt is being eliminated only.

The whole Vision is flawed. Selecting the wrong site, for the wrong reasons, when there are viable, less detrimental, alternatives. The LP will not protect the Environment or local flora and fauna – as is the stated “Vision”

This seems to be Sloppy Planning by a biased Borough Council Cabinet working with a profit-driven, inexperienced, Land Owner.

DLP_2162

Andrew Davidson

I object to the strategy of building 1,750 houses east of Goudhurst when all the jobs and employment opportunities are to the west! This is not joined-up thinking. The infrastructure cannot support it.

DLP_2272

Mr John Wotton

Section 3: Vision and Objectives

This is not a Plan driven by the needs and interests of Tunbridge Wells Borough and its rsidents. It is driven by national policy objectives, particularly regarding housebuilding, that take no account of local circumstances. No rational local planning authority, taking into account the characteristics of this Borough, would produce a plan providing for development on anything like the scale contained in the draft Local Plan.

If due regard were given to the protection given by planning law and policy to the protection of the High Weald AONB and its setting, the Green Belt, the Conservation Areas throughout the Borough, other protected or designated sites, the many listed buildings, parks and gardens, scheduled ancient monments and other heritage assets in the Borough, many of the allocations in the draft Local Plan would be found to be incompatible with planning law and policy.

If due regard were given to the need to tackle the climate emergency, little or no development would take place on greenfield sites in the Borough, thereby losing the contribution they make to absorbing greenhouse gases and supporting biodiversity. A Local Plan which took the climate emergency seriously would have a vision for a sustainable and integrated transport system, linking rail and low emission bus services, cycle routes and other active transport solutions and necessarily looking beyond the Borough boundaries to achieve this.

A Local Plan with a serious commitment to reducing emissions from heating buildings would set far higher emision standards for new built homes and industrial and commercial buildings and mandate solar panel installation on them and include effective incentives for retorfitting existing buildings with insulation and solar panels.

The draft Local Plan meets none of these tests.

Development in the Borough should take plce primarily on brownfiled sites in existing settlements or other sustainable locations. Densification of existing towns and villages is the most sustainable way of providing new and affordable housing to meet the needs of the Borough's residents. Access to green spaces, including urban green spaces, must be preserved. Limited extension of existing settlements, in sustainable locations is possible in some cases. There should be no major developments in the High Weald AONB and no net loss of Green Belt land.

It follows that I disagree with Strategic Objective 7, to release "appropriate" land from the Green Belt through a plan-led approach and SO 9, to establish garden settlements as a model for the future delivery of development in the borough.

DLP_2348

Sarah Coulstock

There is too much development in the Local Plan for a rural area with much of it in AONB – TWBC should challenge the housing target it has been given in view of this & get it reduced.

The number of new dwellings proposed for the parish of Brenchley & Matfield is too high. All of proposed development is in Matfield – Brenchley should share the burden & take at least half, especially as has a school, 2 shops, a post office, a doctor’s surgery & a dentist.

The Limits to Build Development should not be changed; it should be strengthened to prevent or severely restrict any more intrusive inappropriate development within the Parish. The dark skies, wildlife, landscape & rural character need to protected against the destruction of the surrounding countryside & the detrimental impact on the High Weald AONB. The amount of development suggested in the AONB is contrary to the objectives of the High Weald AONB Management Plan & the TWBC’s statutory duty to conserve & enhance the High Weald AONB.

The proposed extra housing would put additional pressure on already stretched infrastructure & services, both within the parish of Brenchley & Matfield, & in the borough. I understood that TWBC had previously favoured focused growth in sustainable locations, however, the Local Plan is for dispersed growth in places with poor infrastructure & facilities, which are therefore not sustainable.

The proportional development distribution proposed in the Local Plan is unfairly distributed, with some areas expected to suffer a higher volume of development than is appropriate.

DLP_2721

Paddock Wood Labour Party

Section 3. Pg 31. OBJECT. Vision and Objectives 1.Vision. Mention is made of a Masterplan regarding the provision of the new infrastructure. This needs to be in place before any new houses are built in PW. More detail of time scales should be in the Draft Plan and submissions from the developers that they will support and implement the Masterplan before new build takes place.

Pg32. Vision & Objectives 2. OBJECT. Strategic Objectives. Strategic Objectives. As above, there needs to be improvements  in the existing infrastructure and no new build to be agreed by TWBC before they are in place to serve any new development proposed in the Draft plan.

DLP_2995

Mr Keith Lagden

Given that the Wealden AONB is recorded as comprising 70% of the borough’s land area, the vision is remarkable for its failure to recognise the importance of preserving its essential character or the borough council’s responsibilities towards it.

The Vision states:-

High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure. The growth of these settlements will have reflected local input and circumstance, including through assessment against neighbourhood plans;

In Hawkhurst it is clear this vision is being ignored as the proposed relief road is clearly not what is needed and the made NDP clearly states that developments must be small with under 10 houses!

DLP_3013

Cranbrook Conservation Area Advisory Committee

Cranbrook and Sissinghurst have grown organically over centuries and this is what has created their heritage character.Swamping them with estates of new houses a long way from the centre will kill their character. Some growth can and should happen but at a scale that can be absorbed and far below the current housing target.

Under Vision and Objectives the Plan aims “ to achieve the delivery of all forms of infrastructure to mitigate the impact of development”. Under 4.40 the Plan further states “a growth strategy that is based on infrastructure led development “. What does this mean - a massive road building programme across the Weald OR ever more clogged main roads and dangerous rat running on unsuitable country roads and lanes? Neither is acceptable.

DLP_4260

RTW Civic Society

As worded, this could apply to any town in Kent.  There’s nothing specific such as the Pantiles or the common mentioned.  We feel the need to protect the distinctive characteristics of Tunbridge Wells should be reflected here eg. the Commons and the Pantiles, and the town’s exceptional heritage of buildings and parks.

It is misleading to describe the Plan as infrastructure-led.  The legal framework requires it to be development-led, invariably by private sector developers, and the Plan’s ability to obtain the necessary infrastructure depends largely on negotiations with developers.  The draft Plan is much more demanding of developers to provide community benefits, including infrastructure, than the current Plan, and we welcome this, but experience with the current Local Plan makes it seem unlikely the Council will actually be able to require infrastructure on the scale required.

DLP_4359

British Horse Society

Vision and Objectives

Support with conditions

The major new settlements and the borough’s green infrastructure network should include new and generous provision for horse riding. This should be an integral part of the new infrastructure that is planned to mitigate the impact of development and to result where possible in “betterment”.

DLP_4394

Mill Lane and Cramptons Residents Association

Sissinghurst has grown organically over centuries and this is what has created its heritage character. Swamping it with estates of new houses away from the village centre will kill its character. Some growth can and should happen but at a much smaller scale that can be absorbed - and far below the current housing target.

Under Vision and Objectives the Plan aims “to achieve the delivery of all forms of infrastructure to mitigate the impact of development”. Under 4.40 the Plan further states “a growth strategy that is based on infrastructure-led development “. What does this mean - a massive road building programme across the Weald or ever more clogged main roads and dangerous rat-running on unsuitable country roads and rural lanes? Neither is acceptable.

DLP_4632

CBRE Ltd for Dandara Ltd

3.0 Local Plan Vision and Strategic Objectives 

3.1 The Draft Local Plan sets out an overall vision for a prosperous Tunbridge Wells borough, founded on a sustainable growth strategy which is based on an infrastructure-led approach that will largely be funded by development, and is focused on achieving high quality design standards.

3.2 The vision responds to the scale of growth required to meet identified needs. It includes Paddock Wood as a key location for settlement growth (including on land in eastern Capel parish) based on Garden Village [1 UK Gov.: Ministry of Housing, Communities and Local Government: Garden Communities Prospectus (August 2018).] principles, using a comprehensive masterplan-led approach. Alongside housing, it is expected to:

  • Provide a vibrant and regenerated town centre, together with enhanced employment, leisure, and other facilities;
  • Provide significant and strategically planned infrastructure;
  • Reduce (existing) flood risk to areas of Paddock Wood, Capel parish, and Five Oak Green.

3.3 Dandara supports the overall vision of the Draft Local Plan and the specific aspirations for the expansion to Paddock Wood and Royal Tunbridge Wells, and also welcomes the focus on sustainable development and achieving high quality design. Dandara also supports the Council’s aspiration for high quality development at other settlements across the borough which responds to the distinctive and particular character of their locations. The combination of strategic and smaller allocations form a critical component of the housing strategy that is capable of being delivered in the short, medium and long term within the Plan period.

3.4 The Council’s ‘Vision and Objectives 2’ strategic objectives include the appropriate release of land from Green Belt. Dandara welcomes the plan-led approach to the release of Green Belt land, though acknowledges that the exceptional circumstances case and evidence to justify amending Green Belt boundaries needs to be robust in accordance with paragraphs 136 – 142 of the NPPF.

3.5 Dandara supports the strategic objectives of the Draft Local Plan, particularly the emphasis on the delivery of new housing to help address the identified housing needs and the disparity between house prices and income in the borough. However, it is suggested some minor modifications are made to strategic objectives to clarify that the plan is positively prepared and fully aligned with the plan-making provisions of Chapter 3 of NPPF.

[TWBC: see full representation

DLP_4760

DHA Planning Ltd for Caenwood Estates and Dandara

3 The Tunbridge Wells Draft Local Plan

3.1 Overview

3.1.1 The TWBC Draft Local Plan (herein referred to as ‘the plan’) sets out the spatial vision, strategic objectives, and overarching development strategy for the borough. It details overarching place shaping policies for each parish and settlement, as well as site specific allocations to deliver the strategy and detailed policies to be applied to all new development.

3.1.2 The plan will set the agenda for development across the borough to 2036 and replace the current Development Plan, which comprises the Local Plan 2006 (saved policies), the Core Strategy 2010, and the Site Allocations Local Plan 2016.

3.2 Vision and Strategic Objectives

3.2.1 The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure led and largely funded by new development. The key components of the vision are summarised below:

  • The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.
  • Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.
  • A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop into the following years).
  • High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure
  • Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

3.2.2 The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

3.2.3 In order to turn this vision into reality the plan sets a number of strategic objectives.

  1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high-quality development;
  2. To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';
  3. To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;
  4. To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;
  5. To ensure that the borough is vibrant, culturally rich, and economically buoyant;
  6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;
  7. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;
  8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;
  9. To establish garden settlements as a model for the future delivery of development in the borough;
  10. To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.

3.2.4 We support the general thrust of these objectives, which seek to meet identified housing needs in full and boosting significantly the supply of new affordable homes. However, we would suggest some minor modification to clarify that the plan is positively prepared and fully aligned with the provisions of the National Planning Policy Framework (‘NPPF’). Indeed, we acknowledge that the Plan aspires to achieve the full development needs of the borough and therefore we consider that objective 1 should be modified to make certain on this point.

“To deliver the full housing, economic and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led and high quality development”

[TWBC: see full representation].

DLP_4864

DHA Planning for Berkeley Homes (Eastern Counties) Ltd

2.2       Vision and Strategic Objectives

2.2.1    The plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure led and largely funded by new development. The key components of the vision are summarised below:

  • The   heart of Royal Tunbridge Wells and Southborough will be culturally rich, full   of vitality, and will have the flexibility, robustness, and adaptability to   cope with changes in the economy and other circumstances.
  • Paddock   Wood as a settlement will have developed considerably (including on land in   eastern Capel parish) on the basis of garden settlement principles, using a   comprehensive, master-planned approach.
  • A   new garden settlement will have been established at Tudeley Village,   including homes, employment, and community facilities (which will continue to   develop into the following years).
  • High   quality development at other settlements across the borough will have been   realised, with the timely provision of relevant infrastructure
  • Rural   enterprise will have been supported, and the exceptional quality of the built   and natural environments will have been protected and enhanced.

2.2.2    The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

  1. In order to turn this vision into reality the   plan sets a number of strategic objectives.
  2. To deliver the housing, economic, and other   needs identified for the borough by the end of the plan period through well   designed, sustainable, plan led, and high quality development;
  3. To achieve the delivery of all forms of   infrastructure to mitigate the impact of development and where possible to   result in 'betterment';
  4. To prioritise active travel, but where   necessary to plan appropriately for use by private motor vehicle, in   particular embracing new technology;
  5. To boost significantly the supply of   affordable housing, and to seek to redress the disparity between house prices   and income in the borough;
  6. To ensure that the borough is vibrant,   culturally rich, and economically buoyant;
  7. To protect the valued heritage, and built and   natural environments of the borough, including the AONB and to achieve net   gains for nature;
  8. To release appropriate land from the Green   Belt through a plan-led approach, and to increase public accessibility, and   to protect the openness of remaining Green Belt land;
  9. To tackle climate change and minimise the impact   of development on communities, the economy, and the environment with   carefully considered design and by embracing technology, such as renewable   energy generation;
  10. To establish garden settlements as a model   for the future delivery of development in the borough;
  11. To work with neighbourhood plan groups to   ensure the formation of locally-led policies, with this reflected in   decisions on planning applications.
  12. We support the general thrust of these   objectives, which seek to meet identified housing needs in full, and boost   significantly the supply of new affordable homes. However, we would suggest   some minor modification to clarify that the plan is positively prepared and fully aligned with the provisions of the National Planning Policy Framework   (‘NPPF’). Indeed, we acknowledge that the Plan aspires to achieve the full   development needs of the borough and therefore we consider that objective 1   should be modified to make certain on this point (with the revision shown   underlined).

“To deliver the full housing, economic and other needs identified for the   borough by the end of the plan period through well designed, sustainable,             plan led and high quality development”

DLP_5076

Tally Wade

Economic Development

Vision and Objectives 1 (page 31)

I object to there being little proposed economic development in rural areas, with most employment land proposed for North Farm in Tunbridge Wells (Policy ED 1 - page 461). With the number of new houses east of Goudhurst adding up to 1,751, the highways are not big enough to accommodate the increase in traffic to this part of the borough. Road networks comprise historic narrow streets unsuitable for widening and heritage-designated landscape (High Weald AONB) that will be irreparably damaged by excessive cars and their pollution.

Vision and Objectives 1 (page 31)

I object to the strategy of placing 1,751 new houses east of Goudhurst when almost all employment opportunity for the borough is proposed in Tunbridge Wells. The highways are not big enough to accommodate the increase in traffic.

DLP_5174

Bloomfields for Fernham Homes

Vision and Strategic Objectives

The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure-led and largely funded by new development. The key components of the vision are summarised below:

  • The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.
  • Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.
  • A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop into the following years).
  • High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure
  • Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

In order to implement this vision, the plan sets a number of strategic objectives.

1) To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development;

2) To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';

3) To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;

4) To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;

5) To ensure that the borough is vibrant, culturally rich, and economically buoyant;

6) To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;

7) To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;

8) To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;

9) To establish garden settlements as a model for the future delivery of development in the borough;

10) To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.

[TWBC: see Comment Numbers DLP_5171, 5174, 5176, 5177 and 5180]

DLP_6029

Mr C Mackonochie

Vision and Objectives 1

I applaud the ambition for the Borough to be ‘vibrant and prosperous’ and the expanding the foundations and facilities to encourage economic activity and supporting sustainable growth

However there seems to be too much emphasis on house building; normal planning is to either create jobs and then housing or create both side by side. I appreciate that housing numbers has been forced upon the Borough but given the restrictions imposed by AONB, Green Belt, lack of rural infrastructure and seemingly reluctance to expand housing in the Tunbridge Wells itself, surely time has come force a review by Central Government - after all there only so many pages that can be stuffed into a folder

There is no mention of preventing Tonbridge, Tudeley, Five Oak Green, Paddock Wood, Southborough and Tunbridge Wells coalescing into one large city; the above mentioned places becoming suburbs. The use of Green Belt can only be used to prevent this, thus precedence should not be set by releasing existing Green Belt land

Mention is made of Tudeley Village developing in the future. It will not develop north of the railway line for financial reasons thus expansion will be towards Tonbridge and Five Oak Green and southwards towards Southborough and Tunbridge Wells. Again this must be prevented

DLP_6462

DHA Planning for Cedardrive Ltd

3 The Tunbridge Wells Draft Local Plan

3.1 Overview

3.1.1 The TWBC Draft Local Plan (herein referred to as ‘the plan’) sets out the spatial vision, strategic objectives, and overarching development strategy for the borough. It details overarching place shaping policies for each parish and settlement, as well as site specific allocations to deliver the strategy and detailed policies to be applied to all new development.

3.1.2 The plan will set the agenda for development across the borough to 2036 and replace the current Development Plan, which comprises the Local Plan 2006 (saved policies), the Core Strategy 2010, and the Site Allocations Local Plan 2016.

3.2 Vision and Strategic Objectives

3.2.1 The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure led and largely funded by new development.

3.2.2 Development is proposed to be spread around various locations in the Borough. As well as expanding Paddock Wood and creating a new garden village, the Plan proposes significant development in the eastern villages including Hawkhurst, Cranbrook, Sissinghurst, Hartley and Frittenden. As discussed in section 2.1, the Hawkhurst crossroads is already over capacity and if nothing is done to improve the situation, additional pressures from new residents from these allocations will only make matters worse when using the A229 through the Highgate crossroads. Therefore something must be done, and the proposed relief road is a critical part of the Council’s development and infrastructure strategy.

3.2.3 The key components of the vision are summarised below:

* The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.

* Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.

* A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop into the following years).

* High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure

* Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

3.2.4 The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

3.2.5 In order to turn this vision into reality the plan sets a number of strategic objectives.

1) To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high-quality development;

2) To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';

3) To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;

4) To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;

5) To ensure that the borough is vibrant, culturally rich, and economically buoyant;

6) To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;

7) To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;

8) To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;

9) To establish garden settlements as a model for the future delivery of development in the borough;

10) To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.

3.2.6 We support the general thrust of these objectives, which seek to meet identified housing needs in full and boosting significantly the supply of new affordable homes. However, we would suggest some minor modification to clarify that the plan is positively prepared and fully aligned with the provisions of the National Planning Policy Framework (‘NPPF’). Indeed, we acknowledge that the Plan aspires to achieve the full development needs of the borough and therefore we consider that objective 1 should be modified to make certain on this point.

“To deliver the full housing, economic and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led and high quality development”

[TWBC: see full representation].

[TWBC: see also Comment Numbers DLP_6461-6472].

DLP_6747

Mrs Carol Richards

Vision and Objectives 1 (yellow box)

TWBC’s Vision states that Paddock Wood will have been developed considerably by 2036, including the use of land at East Capel.

Para 136 of the NPPF states “Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development”. If you develop housing on East Capel you will be altering a greenbelt boundary without sufficient justification, in contravention of the NPPF. Specifically, there are other ‘call for site’ areas that have not been looked at with due consideration. For instance, I explain below how Horsmonden and Frittenden have been discounted on spurious grounds.

Para 134a) of the NPPF states that the purpose of Green Belt is “to check the unrestricted sprawl of large built-up areas” and para 134b) states that it is “to prevent neighbouring towns merging into one another”. Yet, development between Paddock Wood, Five Oak Green and Tudeley will contravene both of these policies.

The TWBC vision states that a new garden village will have been established at Tudleley Village. Rural enterprise will have been supported and natural environments will have been protected and enhanced by 2036. Strategically planned infrastructure, including reducing (existing) flood risk will result in’ betterment’ of the area.

This is not true. How can 2,800 homes on a ridge built on and overlooking more prime farming land be protecting the environment? The valley below is an idyllic natural landscape full of rich flora and fauna. The natural environment in Capel will be decimated if the development of new housing in Tudeley and East Capel goes ahead. The belief that building 2,800 homes will improve the flood risk is laughable. The amount of hard standing will produce more flooding and ensure that runoff into the valley will cause flooding to neighbouring boroughs – I am not convinced at the effectiveness of the SuDS proposals elsewhere in the Local Plan.

Neighbouring businesses to Capel as well as Tudeley will also be affected during the long, arduous building process, including huge amounts of roadworks on one of the busiest roads in the borough. Furthermore, I cannot see how the ‘village’ would be self -sustaining as a dormitory town to London.

The very idea of a garden settlement on the outskirts of a commuter town -Tonbridge is not really a site you would envisage a garden village to be placed, especially with a railway line running through the middle of it! The noise this will create will not be tranquil!

A garden village settlement should be somewhere remote and undeveloped, outside of the Green Belt and AONB, to give that area a retail/employment boost. There is a site outside of AONB and Green Belt that had enough land offered in the Call for Sites for a garden settlement; Horsmonden. Look again at putting a garden settlement here (if you still insist that you need 14,000+ houses in this borough)

The TWBC Vision should look again at the A 21 corridor where road improvements (which took 40 years to come to fruition),as this does already provide good transportation links to Tunbridge Wells and is a better plan than clogging the Five Oak Green Road even more, and bringing Tonbridge to a grinding HALT!.

The Issues and Options Consultation Statement (Appendix 1) has some illuminating feedback comments that do not seem to have been adequately addressed in the Vision and Objectives:

Place greater emphasis on role of TW as a strategic location within wider context of Kent and East Sussex - seek the growth of TW as a sub-regional settlement.

Another objective should relate to balance of growth and development across the borough, including, looking at how the many rural communities in the borough will be sustained economically over next 15 years.

Should include focus on brownfield sites to meet the housing demands; and integration of industrial estates with housing to provide jobs locally.

DLP_6847

Barton Willmore for Crest Nicholson

4.0 TWBC LOCAL PLAN/VISION AND OBJECTIVES

4.1 TWBC has presently published a more advanced Reg18 Local Plan than many other LPAs across Kent, and should be congratulated on a variety of levels, as it (and the accompanying Evidence Base) provides for a comprehensive suite of documents. In commenting upon the content of this, we are mindful that it is not a Reg19 Local Plan, albeit it has the outward appearance of actual Reg19 Local Plans elsewhere.

4.2 Unfortunately this has resulted in a significant degree of unnecessary duplication of strategic objectives and strategic policies, which we would expect to become more streamlined when preparing the actual Reg19 version of the TWBC Local Plan.

4.3 The Evidence Base [3 https://beta.tunbridgewells.gov.uk/local-plan/evidence] is extensive and relatively robust, albeit we consider that greater clarity could be provided in certain areas, particularly in respect of “transport infrastructure”, “flooding and drainage infrastructure” and “secondary education provision”. Again, we would expect greater clarification of a variety of matters when advancing the Local Plan to its next stage of preparation.

4.4 In preparing these representations, we have reviewed the relevant documents comprising the Council’s Evidence Base, and draw reference throughout our respective technical responses.

i) Vision and Objectives

4.5 Section 3 of the TWBC Reg 18 LP provides a high level “vision” of what the Borough will look like come 2036, and beyond. This is set out in 2No “Vision and Objectives” (Nos 1 & 2).

4.6 Crest whole heartedly supports these Visions and Objectives, and consider they provide a robust framework upon which more detailed policies are subsequently prepared in the later section of the Local Plan.

4.7 However, our only concern is the use of the word “betterment” in both V&O policies. We explore this in more detail in our actual policy-response representations, but would question the use of this word – when it has a variety of different meanings in “planning parlance” – and which we do think is actually what was/is intended by the Borough Council presently. (It is also noted that no explanation/definition is presently provided in the Glossary).

[TWBC: see full representation and supporting documents Appendix 1, Appendix 2 Part 1 , Appendix 2 Part 2 and Appendix 3]. See also Comment Numbers DLP_6836, 6844, 6847, 6843, 6855, 6859, 6860, 6863, 6865, 6866, 6869-6870, 6872, 6877, 6883, 6890, 6897, 6909-6911, 6926, 6928, 6931, 6933-6937].

DLP_7062

Bloomfields for Giles MacGregor

Vision and Strategic Objectives

The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure-led and largely funded by new development. The key components of the vision are summarised below:

  • The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.
  • Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.
  • A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop into the following years).
  • High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure
  • Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

In order to implement this vision, the plan sets a number of strategic objectives.

1) To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development;

2) To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';

3) To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;

4) To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;

5) To ensure that the borough is vibrant, culturally rich, and economically buoyant;

6) To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;

7) To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;

8) To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;

9) To establish garden settlements as a model for the future delivery of development in the borough;

10) To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.

[TWBC: for Policy AL/HO 2 see Comment No. DLP_7061. For Vision & Strategic Objectives see Comment No. DLP_7062. For Policy STR1 The Development Strategy see Comment No. DLP_7063. For Policy STR/HO 1 The Strategy for Horsmonden Parish see Comment No. DLP_7064. The full report is attached to this representation, along with supporting documents: Ecology Preliminary Ecological Appraisal Report, Highways definition team letter, Schedule of Accommodation , Sketch Scheme Existing, Sketch Scheme Site Layout Plan and Transport Statement Final with appendices].

DLP_7204

John Gibson

Draft Infrastructure Delivery Plan

Section 3 Paragraph 22 Table 2

There are no research figures provided for Staplehurst railway station which is where many new residents will commute from.

Infrastructure Delivery Plan

Section 3 Paragraph 36

No plans are provided to provide extra parking at Staplehurst railway station to accommodate the increased commuter traffic that will result from this and the other proposed developments in Cranbrook and Sissinghurst.

Infrastructure Delivery Plan

There is no mention of any improvement to the local public bus service.

DLP_7525

Charterhouse Strategic Land Ltd

Charterhouse Strategic Land Limited (“Charterhouse”) is promoting the land edged ‘red’ on the enclosed site plan. Accordingly, this letter contains our response to the published Tunbridge Wells Borough Council Draft Local Plan: Regulation 18 Consultation. Our representation responds on the emerging Vision and Objectives, the Development Strategy and Strategic Policies and the specific Place Shaping Policies for Paddock Wood.

Charterhouse participated in the earlier rounds of the early plan making process by submitting the site submitted to the Council as part of the Local Plan Call for Sites – Site references 402 & 51. In May 2017 the council published the Local Plan Issues and Options document for consultation. However at this time Charterhouse did not participate. The Issues and Options document contained a number of Strategic Options for the long term vision of the borough. Of the five options presented in the document, significant growth at Paddock Wood was included in Options one, two and three.

Section 3: Vision & Objectives

Charterhouse supports the vision for Paddock Wood including the comprehensive masterplanned approach. We are happy to be involved in the collaborative exercise and suggest that this be led by the Council. The strategic objectives of the Local Plan align with Charterhouse’s vision for the site at Paddock Wood and we broadly support the objectives in particular the use of garden settlements and to deliver the housing, economic and other needs identified for the borough.

[TWBC: see site location plan].

DLP_8006

Hobbs Parker Property Consultants Ltd for The Hedges Family Accumulation and Maintenance Trust

2 VISION AND OBJECTIVES 

2.1 Vision & Strategic Objectives

2.1.1 We fully support the Local Plan Vision & Strategic Objectives which aspires to the ensure that the borough of Tunbridge Wells is vibrant and prosperous throughout the plan period. In this context Hawkhurst is located within the High Weald Area of Outstanding Natural Beauty (AONB) and features local architecture that is distinctive to the area. It supports a wide rural hinterland and benefits from a primary school, small independent cinema, and two supermarkets, as well as a range of local services and facilities. New, well planned growth that is sensitively assimilated into the local landscape will support the settlement will help to reinforce the sustainability of Hawkhurst both as key service settlement and in terms of the support role that it performs within the wider borough.

DLP_8167

Highways England

Vision Statement 1 (Para 3.2) indicates that at the heart of all development in the borough will be connectivity, active travel…but makes no mention of sustainable travel options as a guiding principle. Highways England would recommend the rewording as follows:  at the heart of all development in the borough will be connectivity, sustainable and active travel…, to accord with guidance found within the NPPF.

Vision and Objectives 2 (Para 3.4) also makes no mention of sustainable travel, particularly within the sub-statement 3 which states: To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology.  While Highways England welcomes the move towards new technology, improvements within the public transport realms (such as Real Time Passenger Information, on-site bus service mobile apps) would also promote mode-shift away from private vehicles onto sustainable transport modes.

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

DLP_8368

DHA Planning for Mr and Mrs B Gear

2.2 Vision and Strategic Objectives

2.2.1 The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure led and largely funded by new development. The key components of the vision are summarised below:

  • The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.
  • Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.
  • A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop into the following years).
  • High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure
  • Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

2.2.2 The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

2.2.3 In order to turn this vision into reality the plan sets a number of strategic objectives.

  1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development;
  2. To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';
  3. To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;
  4. To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;
  5. To ensure that the borough is vibrant, culturally rich, and economically buoyant;
  6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;
  7. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;
  8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;
  9. To establish garden settlements as a model for the future delivery of development in the borough;
  10. To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.

2.2.4 We support the general thrust of these objectives, which seek to meet identified housing needs in full and boosting significantly the supply of new affordable homes. However, we would suggest some minor modification to clarify that the plan is positively prepared and fully aligned with the provisions of the National Planning Policy Framework (‘NPPF’). Indeed, we acknowledge that the Plan aspires to achieve the full development needs of the borough and therefore we consider that objective 1 should be modified to make certain on this point.

“To deliver the full housing, economic and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led and high quality development”

Vision and Objectives 1 (The Vision)

Comment No.

Name/Organisation

Response

DLP_720

Dr P Whitbourn

I had hoped that the "Vision" would present an inspiring mental picture, but instead found a somewhat dispiriting one. The concept of development funded infra-structure seems an anonymous one,that could just as well apply to Croydon or anywhere else.

The first bullet point is said to relate to "Royal Tunbridge Wells and Southborough", although there is no such single place of that name. The two towns have different histories, evolutions, and distinctive characters and each deserves to be treated in its own right. Southborough ranks with Cranbrook and Paddock Wood in having a democratically elected Town Council that is part of official local government structure and, like them, it should have a bullet point of its own. Given that Southborough is separately treated on pages 139-153 of section 5, it would appear illogical to do otherwise.

Royal Tunbridge Wells also should have its own distinctive bullet. Not only is it by far the largest town in the borough but, in national terms, it is a post-medieval historic town of national significance and, as such, thee Plan should have a distinct vision for its future.

A more ambitious vision for Royal Tunbridge Wells might be:

In 2036 Royal Tunbridge Wells will continue to be a great place to live, work, visit, shop, eat or study. It will continue to be a fine, vibrant and prosperous post-medieval inland spa town of historical importance nationally, and a destination town relating to southern England rather as Harrogate does to the north, and Cheltenham to the west country, it will serve also as the cultural centre of the High Weald, offering a range of attractions and cultural facilities . Any necessary adaptation to cope with economic or other circumstances will be subject to rigorous scrutiny from a conservation point of view. Heritage assets, open space and arcadian areas will be carefully safeguarded, and where new development is permitted within the Conservation Area, this will generally be in an appropriate historical style and traditional materials, in order to maintain the overall special character and cohesion of this major historic town.

DLP_851

Ian Pattenden

Comments the Vision (Section 3) p.31

A so-called garden settlement at Tudeley would be located on green belt. The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances, but there are no exceptional circumstances for this vandalism.

Your Vision states that rural enterprise will have been supported and natural environments will have been protected and enhanced by 2036, this is not possible with housing and associated civic amenities being built on green belt, this idea is therefore fanciful. The Horsmonden site is outside of the AONB and Green Belt and has enough land offered in the Call for Sites for a garden settlement. Your excuse for not adopting this site was that it would overpower the existing settlement??? If this is the case then it is even more relevant to the much smaller hamlet of Tudeley. This has never been explained and is cause for much speculation and concern.

DLP_1612

Maggie Fenton

A disappointing aspect of previous local plans has been the lack of vision regarding rural areas. This draft local plan is no better and is wholly unreasonable and far worse in that rural areas such as Capel have been targeted as a dumping ground for the development that TWBC say they “must deliver”.  Within the main document the main settlement of Five Oak Green hardly gets a mention and in the “Place shaping” Index isn’t referred to although the other villages in the Borough are. There is no “vision” whatsoever for the existing residents of  Five Oak Green and the hamlets of Capel except misery. The plans for road infrastructure “improvements” indicate they are are not scheduled to start until 2025, nor the Colts Hill bypass (& FOG bypass obviously even later) until 2028. However house building  is scheduled for East Capel to be at a rate of 333 houses a year from 2024 & Tudeley 150 a year from 2025 which is 1,450 before any potential bypass. I note, and am pleased for the residents of Calverley Park Gardens, that there will be restrictions on lorry movements.  Capel suffers from an excess of HGV movements on highly dangerous speeding roads but TWBC just want to exacerbate this problem.

It is possible to regenerate Paddock Wood without using greenbelt land at East Capel for housing.

Flood risk to both Paddock Wood and Five Oak Green can be reduced without using greenbelt land at East Capel.

The land in East Capel should be removed from the Vision for Paddock Wood. It is Capel NOT Paddock Wood

If you develop housing on East Capel you will be altering a greenbelt boundary without any justification and will cause coalescence between Paddock Wood and Five Oak Green. You would also be subsuming those houses in the site which are NOT Paddock Wood but are Five Oak Green. The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances.

A new garden settlement is not required at Tudeley. Flood risk can be reduced using the Environment Agency’s existing plan which can be funded without developers building houses on perfect, unspoiled greenbelt land. Please remove the creation of a garden settlement at Tudeley from your Vision.

Your Vision states that rural enterprise will have been supported and natural environments will have been protected and enhanced by 2036. This is not true. Your Local Plan will destroy rural enterprises, such as the equestrian facilities at Bank Farm and countless other businesses in Capel. The natural environment in Capel will be decimated if the development of new housing in Tudeley and East Capel goes ahead. Neighbouring businesses to Capel will also be affected during the long, arduous building process, including huge amounts of roadworks on one of the busiest roads in the borough. Far from encouraging new or existing businesses, they will be keen to relocate to areas that do not suffer from the  exacerbated congestion these proposals will bring. Put your garden settlement somewhere remote and undeveloped, outside of the Green Belt and AONB, to give that area a boost and to minimise disturbances caused by construction. There are two sites that satisfy the criteria and are identified in the evidence base; Horsmonden and Frittenden. Look again at those locations

DLP_2137
DLP_2153

Penelope Ennis
Michael O'Brien

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

Given that the Wealden AONB is recorded as compromising 70% of the borough's land area, the vision is remarkable for its failure to recognise the importance of preserving its essential character or the borough council's responsibilities towards it.

DLP_2966

Michael Alder

The TWBC VISION states" The growth of these settlements will have reflected local input and circumstances, including thorough assessment against neighbourhood plans"

The Hawkhurst NDPs have been ignored wherein it is stated that development must be small with under 10 houses. The proposed Golf Course development at 400 plus houses does not comply.

DLP_3028

Jacqueline Prance

Too big a site for the housing numbers etc currently proposed. ANOB Green Belt. Traffic Problems

DLP_4462

Paddock Wood Neighbourhood Plan Steering Group

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.

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

DLP_4598

Keith Stockman

Vision statement: Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

There is no mention in the plan of any effort to support rural enterprise in Cranbrook and Sissinghurst and the quality of the built and natural environments will most certainly NOT be protected and enhanced by the proposed development..

Vision Statement 1 At the heart of all development in the borough will be connectivity, active travel, an appropriate mix of uses and accommodation and, above all, the timely delivery of relevant infrastructure, which will have been funded by development: this infrastructure will have mitigated the impact of development, and, wherever possible, resulted in 'betterment' for existing residents, users, businesses, visitors, etc. ‘Betterment’ for the existing residents and users of Cranbrook and Sissinghurst is not in any way delivered by the proposed large scale housing developments which will inevitably necessitate use of cars to get to employment areas out of the Parish. No land has been allocated for a new Medical Centre and there is not a proven will from the GP practices to amalgamate in the proposed way. In actual fact, the GP practices are full to capacity and

there is a shortage of GPs in West Kent Health Authority. In the circumstances, to suggest that section 106 monies will be available to fund a new Medical Centre is, at best, misleading and, at worst, deceitful.

Vision and Objectives 2 1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development. A developer who has an option on land in the Parish of Cranbrook and Sissinghurst has already stated they will not build towards the aspirational qualities determined by the

Parish Council, instead they will build to the much lesser quality determined by TWBC. It is therefore imperative that TWBC raises its standards towards that of Norwich, for example, and aspires to PassivHaus, and the race to the bottom of low quality development is halted.

Vision and Objectives 2 To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough. Making homes affordable is not solved by simply building more houses, especially given the tenor of the development proposed. Many workers in the Parish of Cranbrook and Sissinghurst have to commute from the cheaper areas of the Borough and from outside the Borough, to come to work. The scale of the housing proposed will have no impact on this situation.

Vision and Objectives 2) 8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation TWBC Planning Department do not seem to have the ability, or the will, to enforce this vision and objective. Developers working on land already allocated in Cranbrook have

categorically stated that they would not be using renewables such as solar energy, triple glazing and other basic measures to tackle these issues, because, they say, it is not economically viable. This has not been commented on or pursued by the Planning Department and I have no confidence that they will seek to enforce this aspect of building codes as they should.

Vision and Objectives 1 All developments will be of high quality design, having responded to the distinctive and particular character of their locations: in some instances the development will have taken place within valued and protected landscapes, and this will be recognised in the quality of the design of the development, the protection and enhancement of the exceptional quality of the built, natural, and historic environment, and the provision and protection of landscape features and green

spaces. Green, grey, Consultation period: 20 September to 1 November 2019 Tunbridge Wells Borough Local Plan 31 Draft Local Plan (Regulation 18) Consultation Draft and blue infrastructure will be an integral and defining element in the design and layout of new developments

Development, particularly large scale development, is taking place in the Borough with very little attention to detail and directly in contravention of the stated vision and objectives. i.e. at Brick Kiln Farm, Cranbrook, where the developer has paid no attention to the rear elevations of the houses (which residents will see every time they are in their gardens) as it ‘does not affect the street scene’. In actual fact, the first set of proposals

had every front door on the entire site, identical, which was pointed out by local residents, not the Planning Department who, once again, seem to be abrogating their responsibilities in respect of the stated building code.

DLP_5988

Alexander Fisher

A so-called garden settlement at Tudeley (Tudeley new town) would be located on green belt. The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances, but there are no exceptional circumstances that have been articulated.

Your Vision states that rural enterprise will have been supported and natural environments will have been protected and enhanced by 2036, this is not possible with housing and associated civic amenities being built on green belt, this idea is wrong-minded and unsound. The Horsmonden site is outside of the AONB and Green Belt and has enough land offered in the Call for Sites for a garden settlement and has existing infrastructure. Frittenden was also identified. Your excuse for not adopting the Horsmonden site was that it would overpower the existing settlement. If this is correct reasoning then surely it is even more relevant to the much smaller hamlet of Tudeley.

Paddock Wood can be expanded and regenerated without using greenbelt land at East Capel for housing.

Flood risk to Paddock Wood and Five Oak Green can be reduced without using greenbelt land at East Capel.

Any development in East Capel will affect Green Belt land and fundamentally change two communities by merging Paddock Wood and Five Oak Green. A garden settlement (Tudeley town) at Tudeley linked with East Capel would create a conurbation stretching from Tonbridge to Paddock Wood. That would be a breach of garden settlement principles and not the only one as far as I can tell from the current proposal, although it is incomplete because of the lack of detail in relation to the Tudeley garden settlement.

A new garden settlement is not required at Tudeley. Flood risk can be reduced using the Environment Agency’s existing plan which can be funded without developers building houses on greenbelt land.

Please remove the creation of a garden settlement at Tudeley and the land in East Capel from your Vision.

DLP_6084

Gwenneth Heyking

In essence, I believe that far too many developments have been earmarked in Cranbrook.

DLP_6217

Amanda Wells

Strategic objective 1.  “To deliver the housing, economic and other needs identified for the borough….”

Nowhere can I find a proper objective assessment of the housing needs of the borough.  To me the most important issue is to ask why TWBC seems to have accepted the allocated housing target without challenge. Paragraph 4.2 of the Distribution of Development Topic Paper says ‘ Based on submission of the Local Plan in 2020, the objectively assessed housing need for the borough over the plan period to 2036 is confirmed as 13,560 dwellings (678 per year), identified by the standard method (and based on 2014 projections) as required by the NPPF.

This figure is not an assessment of the housing needs of the borough but an unchallenged acceptance of a figure derived from an outdated assessment of national housebuilding need based on the ONS 2014

methodology, of 300,000. The ONS acknowledged this was flawed in 2016 and produced a revised figure of 160,000 ie a nearly 50% reduction of the original target.  In addition TWBC appears to have added an arbitrary 40% uplift to the ‘standard method’ base figure of 484 homes to produce an annual requirement of 678 homes.  To quote Brenchley and Matfield Parish Council “We are fundamentally opposed to the construction of a policy framework based on an unsound target, which , if pursued, would cause irreversible damage to the landscape and habitats, pose a significant threat to wildlife – including protected species – and lead to the urbanizing of the north-east quadrant of the borough.”

The August 2019 report by the UK Collaborative Centre for Housing Evidence concluded that ‘the current policy focus on boosting supply does not offer a solution to the housing crisis and a fundamental rethink is badly needed.” It goes on to state that by 2018 there was a housing surplus of over 1.1million in England alone and the available data suggest that even in London and the South East, the number of houses has grown faster than the household count with a surplus stock of some 6%. The erosion of social housing stock and housing benefit cuts are major contributors to the reduced affordability of housing for young people.

The survey results the Council has used to support it’s assessment of need are based on a ‘wish list’ survey done in 2015 where residents were asked where they would like to be living in 5 years time.  It is inconceivable that many of the respondents were from the homeless, those on the housing waitlist or elderly/ infirm looking for sheltered accommodation.  The figures are therefore totally skewed and do not represent a genuine assessment of the housing needs of the borough.  The formula for arriving at the prices of the ‘affordable’ housing targets in the proposed developments does not produce genuinely affordable accommodation for the these groups of people.  What is needed is social housing which gets little if any mention in the Plan.

A report in 2018 by the London Green Belt Council stated:” that contrary to claims by developers, building in the Green Belt does virtually nothing to address the crisis of affordability of housing, especially for young people, in the South East.”

DLP_6251

Anne Trevillion

This plan does not have any clear vision. If you going to develop, against the wishes of most local people, then you need to be innovative – this should be a development that acts as an inspiration for other developments across the country. You need to build homes that meet the environmental Passivhaus standard, are genuinely affordable, and provide for a real community, with green spaces, allotments, local shops, and sustainable transport. We need homes young people can genuinely afford to live in. Surely in Tunbridge Wells we can build to match the innovation shown by Norwich City Council, which has just won the Riba Stirling Prize for architecture for Goldsmith Street?

Sustainability and wellbeing must be at the heart of what is done. The quality of the architecture in Paddock Wood as it currently stands is very poor – yet great architecture and art in the community can have a real impact on wellbeing, as you say yourselves elsewhere in the document. Paddock Wood has no public gardens of any merit – yet it is placed in an area where so many people garden and there are world famous gardens to visit. Why not include a ‘climate change garden’, to show what plants can be grown in the changing climate (drought-resistant), which also serve to encourage biodiversity?

The town centre should be pedestrianised, while hydrogen-powered local buses take people to the station and bus interchanges so that people do not need to use cars. There needs to be a regular, frequent, affordable bus link to Tunbridge Wells that continues sufficiently late in the evening that people could use the bus to enjoy an evening out. How do you get to the Knight’s Park cinema from Paddock Wood by bus? Or by any form of public transport?

Children should be taken to school by school bus when they cannot walk or cycle – the school run is a source of much congestion and pollution. There need to be dedicated cycle paths so people can cycle to Tonbridge/Tunbridge Wells and to local villages – currently it is far too dangerous to cycle anywhere from Paddock Wood. Other countries and towns can make cycling a real option – why not in Tunbridge Wells borough?

I am concerned that the maintenance of the open spaces in the development at Mascalls Court Farm is to be paid for by the residents – not by Tunbridge Wells. What guarantee do we have that ALL residents of Paddock Wood, and indeed Tunbridge Wells, will have access in perpetuity to what the plans lead us to believe are public open spaces? This seems also to be the case at Mascalls Farm.

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Susan Heather McAuley

I support the building of a new village – this was one of the most favoured options chosen at our local Options meetings.  I do feel though that Capel has been chosen as the easy option.  Capel has many areas of outstanding natural interest, there must be better areas available in the Borough.  Development along the A21 (Pembury, Kippings Cross, Lamberhurst Quarter) was another favoured option chosen by residents.  This plan does not address why that preference was not taken forward.

None of the current house builds reflect the ‘distinctive and particular character of their locations’.  At local NDP meetings the builders took pride in saying they ‘build what sells’, that they will replicate what they have built elsewhere and know they can shift easily and quickly.  How does TWBC intend to change this – given the small planning department how will they have any influence at all over builders?  This statement is a pipedream.  We will end up with more homogeneous estates all over the Borough.

The remainder of this Plan does not reflect the statement that there will be ‘protection of landscape features and green spaces’.  The proposed developments at Sissinghurst/Wilsley Pound will infill between the two currently distinct settlements, destroy an Arcadian area and create coalescence.  There is nothing in this plan that shows there will be any betterment for the people of Sissinghurst which will make up for the loss of their rural setting.  ‘At the heart of all development ….  will be connectivity and active travel’.  There are no concrete plans for this in the plan – this is a great vision but what does it actually mean – there is nothing in the rest of this plan that is a concrete proposal as to how people will be able to travel around without a massive increase in the number of cars on rural roads.

This vision is not reflected anywhere in this Local Plan as actual planned and financed actions.  This Local Plan is a plan for building houses, no more.

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Ms Margaret Borland

This is a depressing vision for existing residents not an inspirational one.   For me, a vision should create a holistic view of where the Borough wants to be – the things that will actually make residents love where they live.   What we’ve got is a list of what is going to be built and only a passing reference to protecting and enhancing the built and natural environment, which suggests that this is not really part of the Council’s vision.

I understand that there are housing targets set by Central Government,  but surely the vision in the Draft Local Plan should be about meeting the needs of real people/local people, not simply about building houses to meet a government target.  Affordable housing, social housing, zero-carbon housing aspirations should be in the vision. Where does our physical and mental health feature?  How has the Climate Emergency declared by TWBC earlier this year influenced this vision?

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Clare Govan
Philip Govan
Rory Govan
Stephanie Govan
Edward Govan
James Govan
Joe Hughes
Sophie Foster

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

This section (and elsewhere in the draft Local Plan) contains multiple references to “garden settlement” without any definition or explanation of that expression, although very large “garden settlements” are proposed in Tudeley and in Paddock Wood/Capel.  It is not even possible to understand what this aspect of the Vision and Objectives is proposing.  Persons commenting on the draft Local Plan will have different impressions of what this means and it may be significantly different from what is actually intended.

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Nicholas Fisher

A so-called garden settlement at Tudeley (Tudeley new town) would be located on green belt. The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances, but there are no exceptional circumstances that have been articulated.

Your Vision states that rural enterprise will have been supported and natural environments will have been protected and enhanced by 2036, this is not possible with housing and associated civic amenities being built on green belt, this idea is wrong-minded and unsound. The Horsmonden site is outside of the AONB and Green Belt and has enough land offered in the Call for Sites for a garden settlement and has existing infrastructure. Frittenden was also identified. Your excuse for not adopting the Horsmonden site was that it would overpower the existing settlement. If this is correct reasoning then surely it is even more relevant to the much smaller hamlet of Tudeley.

Paddock Wood can be expanded and regenerated without using greenbelt land at East Capel for housing.

Flood risk to Paddock Wood and Five Oak Green can be reduced without using greenbelt land at East Capel.

Any development in East Capel will affect Green Belt land and fundamentally change two communities by merging Paddock Wood and Five Oak Green. A garden settlement (Tudeley town) at Tudeley linked with East Capel would create a conurbation stretching from Tonbridge to Paddock Wood. That would be a breach of garden settlement principles and not the only one as far as I can tell from the current proposal, although it is incomplete because of the lack of detail in relation to the Tudeley garden settlement.

A new garden settlement is not required at Tudeley. Flood risk can be reduced using the Environment Agency’s existing plan which can be funded without developers building houses on greenbelt land.

Please remove the creation of a garden settlement at Tudeley and the land in East Capel from your Vision.

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Hallam Land Management Ltd

Hallam are in agreement with the Council’s vision, although would recognise that the significant development growth at Paddock Wood and New Garden Settlement at Tudeley Village will need to be complemented with additional growth in other sustainable settlements across the borough, notably the other Small Rural Towns, to ensure the Council continue to meet their housing delivery targets.

The above will ensure a supply of a wide range of housing allocations across the borough, to ensure the Council is not reliant on a single development / area on delivering development through the plan period, ultimately increasing the risk that delivery of the housing requirement is not met.

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Sigma Planning Services for Rydon Homes Ltd

1. The vision is too narrow and specific in its references to development proposals. It should present a wider picture of the position of the Borough in 2036 covering the full range of indicators of sustainable principles including the achievement of all the matters identified in Paragraph 20 of the NPPF and how it is anticipated that they will secure all those overriding objectives of sustainable development - Economic, Social and Environmental.

2. The proposed garden settlement at Tudeley Village is a highly controversial and unrealistic proposal. It should not form part of the vision of the Plan because if it is not achieved, or is withdrawn, then the whole vision will have failed. The garden settlement should not be given an undeserved status by which the success of the Plan's vision depends upon the successful implementation of one, questionable development proposal. Similar considerations, albeit not so compelling, apply to the extensive reference to proposed development at Paddock Wood.

3. The strategic objectives raise some issues - in particular

  • there is no reference to an objective of significantly boosting the supply of all homes and providing the size, type and tenure of housing needed for different groups in society. There is a reference to the provision of affordable housing but this partial approach falls short of fully embracing government objectives set out in Section 5 of the NPPF.
  • the term "active travel" is not one that is generally understodd and could be misinterpreted. The Plan should seek to reduce the need to travel, particularly by private car whilst at the same time accepting the inevitability of the need to reduce existing traffic congestion, avoud further congestion and embracing, encouraging and imposing new technology that mitigates the impact of vehicular traffic. At the same time walking and cycling should be prioritised.
  • the objective of creating a development model for future plans is unrealistic. There is a high risk of failure and this would prejudice development strategy options in future plans. Free standing new settlements have come into and out of fashion, with limited examples of success, since the 1950's and may not be part of current Government policy when the time comes to prepare future plans. There is no need to limit development strategy options in the future and therefore this objective is unnecessary, potentially limits future strategy options and depends upon very subjective future assessments of whether the garden settlements currently proposed, if they proceed at all, can be viewed as being sufficiently successful to be regarded as being a model for future delivery of development in the Borough.

[TWBC: See full representation]

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Mr and Mrs A J Herbert

The Wealden AONB comprises about 70% of the borough’s land area, the Vision does not recognise the importance of preserving its essential character or the Borough Council’s responsibilities towards it.

The Vision states:

High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure. The growth of these settlements will have reflected local input and circumstance, including through assessment against neighbourhood plans;

The objections to the Hawkhurst “relief road” have been explained in detail above and in relation to the recent outline planning application. The Draft Local Plan clearly does not take into account the Hawkhurst NDP.

The Vision does not reference or refer to the governments’ recent review of the management of AONB’s (The Glover Review) and draw on the emerging policy to protect and enhance these areas for future generations.

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William Fisher
Helena Fisher
Richard Fisher
Alexa Fisher

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

A so-called garden settlement at Tudeley (Tudeley new town) would be located on green belt. The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances, but there are no exceptional circumstances that have been articulated.

Your Vision states that rural enterprise will have been supported and natural environments will have been protected and enhanced by 2036, this is not possible with housing and associated civic amenities being built on green belt, this idea is wrong-minded and unsound. The Horsmonden site is outside of the AONB and Green Belt and has enough land offered in the Call for Sites for a garden settlement and has existing infrastructure. Frittenden was also identified. Your excuse for not adopting the Horsmonden site was that it would overpower the existing settlement. If this is correct reasoning then surely it is even more relevant to the much smaller hamlet of Tudeley.

Paddock Wood can be expanded and regenerated without using greenbelt land at East Capel for housing. Flood risk to Paddock Wood and Five Oak Green can be reduced without using greenbelt land at East Capel.

Any development in East Capel will affect Green Belt land and fundamentally change two communities by merging Paddock Wood and Five Oak Green. A garden settlement (Tudeley town) at Tudeley linked with East Capel would create a conurbation stretching from Tonbridge to Paddock Wood. That would be a breach of garden settlement principles and not the only one as far as I can tell from the current proposal, although it is incomplete because of the lack of detail in relation to the Tudeley garden settlement.

A new garden settlement is not required at Tudeley. Flood risk can be reduced using the Environment Agency’s existing plan which can be funded without developers building houses on greenbelt land.

Please remove the creation of a garden settlement at Tudeley and the land in East Capel from your Vision.

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Mr J Boxall

Vision and Objectives 1 – one key issue relating to development in the eastern area of the Borough, and particularly Cranbrook and Sissinghurst, is ease of movement to Tunbridge Wells.  The infrastructure required for this is the widening of the Lamberhurst to Blue Boys stretch of the A21.  This will not have been done prior to the development of many of the homes proposed for this area and hence there will not be “timely provision of relevant infrastructure” for The Weald as set out in this vision.  The local Plan is not infrastructure led, despite its premise.

If TWBC wishes to develop a garden village it must ensure that is its proposed location is close to fast transport links, both road and rail, and to economic opportunities. So adjacent to Tunbridge Wells or the dualled A21 corridor would meet this criteria.  The east of the borough has poor transport links and poor employment opportunities so such a development would be unsustainable in the eastern area of the Borough.

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Alison Nicholls

The vision put forward is compelling but I suspect it is little more than hope and optimistic imagination. The highways simply struggle to accommodate the current traffic through places such as Goudhurst, Sissinghurst and Hawkhurst. The only relatively decent access roadwise from Cranbrook is northwards towards Maidstone on the A229. The access roads to the West (A262 through Goudhurst), the East (A262 through Sissinghurst) and South (A229 through Hawkhurst) are all known for frequent and long traffic jams. Within these settlements the roads are narrow streets that are characteristic of the historical setting. They are unsuitable for widening and struggle to cope with the current traffic requirements. The added burden, wear and tear and pollution from the increased number of cars will create irreparable damage to this heritage-designated landscape. Whilst I understand the intention to ease the traffic through Hawkhurst with the creation of a relief road from Cranbrook Road to the Rye Road I have heard these arguments before and have witnessed the length of time it takes for this to happen. What is the plan to alleviate the crossroad difficulties at Hawkhurst? What is the route for the proposed relief road? Without clear and firm proposals for these the vision is meaningless words. Housing development of the scale envisaged at Hawkhurst should not predate the relief road. The creation of the necessary road infrastructure should be a pre requisite before any new house building, particularly of the scale put forward.

It appears that the scale of development put forward to the East of Goudhurst does not take into account the current problems of traffic passing through Goudhurst. If the majority of employment opportunity for the borough is in Tunbridge Wells, how will the A262 through Goudhurst cope with the extra demand?

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Mrs Susan May

Overall I think the plan is good in the way it considers everything.  However, the council must consider the current residents and the effects their imposition of inappropriate housing on villages has on the residents.  It would be good if you actually appeared to listen to residents’ concerns and tried to mitigate them. The sewage systems in Hawkhurst and the Moor are no longer fit for purpose having been built in the 1960s and until they are brought up to standard, no more housing should be built.

I also appreciate that the housing targets have been imposed from central Government without a thought to the effects on residents in the area.  Instead, the government should invest in other parts of the country, where there are empty houses and little employment so that the wealth of the South East can be shared by the whole of the country to the benefit of all.

Perhaps things will change after the election on 12 December 2019.

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Mr Colin Sefton

The NPPF guidelines are I believe “questionable” and I believe that TWBC should lobby both directly and via MPs representing the area for a review of National Government policy, including allocating a far higher proportion of resources away from London and South East England to provide a more “balanced” economy throughout the UK and consequently reduce the demand for development in SE England.

However, I support TWBC’s decision to produce a Draft Plan to meet the NPPF guidelines, as I believe that the consequences of not doing so would be more adverse. As most of the Borough is Green Belt and/or AONB and the part of the Borough that does not fall into either of these categories is situated away from the main facilities, I think it is correct in principle, subject to the full provision of all necessary related additional infrastructure, that the Draft Plan proposes the majority of development around Paddock Wood.  I also support the proposals for development where possible in larger sites, as I believe that these enable more easily the provision of related infrastructure.  This could (and in my opinion should) be further enhanced by linking where possible all proposed adjacent sites for development as larger single sites.

Given the “questionable” NPPF calculations and the possibility of a significant economic downturn and consequent significant fall in population as a result of Brexit, I believe that the proposed developments should be “phased” to focus initially on those outside the Green Belt and AONB, followed by those in Green Belt and those in AONB (e.g Tudeley) are only approved after other proposed developments.  Priority should also be given to developments that include a significant proportion of social housing.

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Andrew Chandler

I support the overall vision, but note that several aspects are not reflected in the proposed policies for Cranbrook & Sissinghurst, where several Policies are proposed to apply to sites without due regard for the distinctive character of the locations and the existing built, natural and historic environment, without any proposals for enhanced employment opportunities and without good transport connectivity.

I also note that design that “responds to the distinctive and particular character of locations” requires uniquely adapted design in each location, in this particularly distinctive and beautiful part of the country. We do not want unimaginative suburban housing developments in beautiful rural villages and locations, but this is what we see far too often across the borough. Please ensure that the Vision for high quality, responsive design actually leads to uniquely adapted design that does respond to the distinctive and particular character of locations, in each location.

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Sharon Pickles
Richard Pickles

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

Having read the plan, I see no efforts at all to support Rural enterprise in Cranbrook and Sissinghurst.

Betterment for the residents of Cranbrook and Sissinghurst is not delivered by large scale housing developments necessitating use of cars to get to employment areas out of the Parish

Suggesting that section 106 monies will help to fund a new Medical Centre is disingenuous as no land has been allocated for this and there is not a proven will from the GP practices to amalgamate in this way. In fact the GP practices are full to capacity and there is a shortage of GPs in West Kent Health Authority

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Ashley Saunders

object to the Vision set out on pages 31-32 of the Draft Local Plan (dLP) because too many of the strategies and policies of the dLP are ill-thought out and will not lead to the overall vision being achieved. In particular;

Bullet points 2 and 3 of the Vision – Paddock Wood (AL / CA 3 & AL / PW 1) / Tudeley ‘Village’ (AL / CA 1):

The ‘active travel connections to the new garden settlement’ are poorly planned and based on out of date data. There is nothing in the transport evidence base which justifies either the Colts Hill bypass or the Five Oak Green Bypass (Highway measures 202 and 203). Both of these measures will result the parish being carved up, unnecessary loss of AONB and MGB land and disruption to numerous home-owners (including some CPOs). It is, as yet, unclear how the proposed measures will result in a ‘betterment for these areas’. What is certain is that they will result in a significant worsening for residents of the settlement of Capel within Capel Parish. TWBC should not assume that a Bypass at Colts Hill is the solution to the issues caused by this road just because the scheme has long been lobbied for by prominent residents of that road. Some of the investigations into whether the road should be widened or bypassed are some forty years old and further studies should be undertaken rather than a Bypass being a given. The land safeguarded by Policy TP 6 should be re-considered.

Reducing existing flood risk to PW, Capel Parish & FOG resulting in “betterment” – reduced flood risk is welcome; but hardly a price worth paying for so much development and associated road infrastructure. The fact that the same ‘betterment’ comment is cut and pasted for Tudeley suggests this vision is not one that had the ‘betterment’ of Capel residents in mind.

The proposals to reduce ‘(existing) flood risk to areas of Paddock Wood, Capel parish, and Five Oak Green’ are also poorly planned and based on out if date data. The ‘Five Oak Green Flood Alleviation scheme’ outlined in page 57 of the supporting document ‘Level 1 & Level 2 Strategic Flood Risk Assessment’, will also result in a significant worsening for residents of the settlement of Capel within Capel Parish due to the increased flood risk further up the Alder Stream.

Bullet point 4:

The loss of MGB to allow for the development of Tudeley ‘Village’ (Tudeley New Town or Policy AL / CA 1) and the East Capel element of Policy AL / PW 1 is in direct conflict with this aspect of the Vision – “The exceptional quality of the built and natural environments will have been protected and enhanced.

I believe Paddock Wood can be regenerated without using greenbelt land at East Capel for housing and that either another location without constraints should have been chosen for a garden settlement, or one of the other Growth Strategy options should have been adopted. Similarly the flood risk to Paddock Wood and Five Oak Green can be reduced without using greenbelt land at East Capel.

The Vision for Paddock Wood should not include East Capel which is part of a completely different community.

Housing in East Capel will alter the greenbelt boundary without any justification and will cause coalescence between Paddock Wood and Five Oak Green. The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. See comments on SA. This land is key to preventing convergence between Five Oak Green and Paddock Wood.

A new garden settlement is not required at Tudeley. Flood risk can be reduced using the Environment Agency’s existing plan which can be funded without developers building houses on MGB land. A garden settlement at Tudeley should not be part of your vision and is only there because the land is in single ownership. It is certainly not part of the vision of those who live there at the moment.

Your Vision states that rural enterprise will have been supported and natural environments will have been protected and enhanced by 2036. This is not true. The Local Plan will destroy rural enterprises, such as the equestrian facilities at Bank Farm alongside other businesses in Capel. The natural environment in Capel will be badly damaged if the development of new housing in Tudeley and East Capel goes ahead. Neighbouring businesses will also be affected during the long building process, including huge amounts of roadworks on one of the busiest roads in the borough. These works are bound to take many years and will put untold stress on the local community. Moreover, the Tudeley and East Capel proposals which are within two miles of each other and share the same road links seem to be scheduled for development in the same timeframe. This will place severe and disproportionate strain on the local community and infrastructure. A garden settlement would be better in a more remote part of the borough outside the Green Belt and AONB, to give that area a boost and to minimise disturbances caused by construction. The two sites that satisfy the criteria and are identified in the evidence base; Horsmonden and Frittenden have not been explored further in the sustainability appraisal.

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Myriam Ruelle

The vision goes totally against NPPF guidelines (par.133 to 147).  Not only are there no exceptional circumstances to build on Green Belt and AONB, but stating that “rural enterprize will be supported and natural environment protected and enhanced” is beyond belief!  It is an absolute contradiction in terms.  Animal species live and settle in very particular environments that mostly cannot be recreated or relocated and urbanizing the countryside is completely the opposite of what rural communities need to thrive.  Moreover, it is completely nonsensical to build on Green Belt and AONB in the current climate emergency, which has been recognized by the council.

The whole vision needs re-examining focusing on real local needs and benefits, not on following inaccurate figures and continuing with destructive practices as it does now.  Building on Green Belt MUST NOT be a policy as it goes against national guidelines and common sense.

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Mrs Suzi Rich

I object to the Vision set out on pages 31-32 of the Draft Local Plan document.

Whilst the aim of enabling the borough of Tunbridge Wells to be vibrant and prosperous by 2036, too many of the strategies and policies are ill thought out and will not lead to the overall vision being achieved. In particular;

Bullet points 2 and 3 – Paddock Wood / Tudeley New Town:

The ‘active travel connections to the new garden settlement’ are poorly planned and based on out of date data. There is nothing in the transport evidence base which justifies either the Colts Hill bypass or the Five Oak Green Bypass (Highway measures 202 and 203). Both of these measures will result the parish being carved up, unnecessary loss of AONB and MGB land and disruption to numerous home-owners (including some CPOs) for the sake of a few residents living adjacent to Colts Hill. It is unclear how the proposed measures will result in a ‘betterment for these areas’. What is certain is that they will result in a significant worsening for residents of the settlement of Capel situated on and around Alders Road. TWBC should not assume that a Bypass at Colts Hill is the solution to the issues caused by this road just because the scheme has long been lobbied for by prominent residents of that road. Some of the investigations into whether the road should be widened or bypassed are some forty years old and further studies should be undertaken rather than a Bypass being a given.

The proposals to reduce ‘(existing) flood risk to areas of Paddock Wood, Capel parish, and Five Oak Green’ are also poorly planned and based on out if date data. The ‘Five Oak Green Flood Alleviation scheme’ outlined in page 57 of the supporting document ‘Level 1 & Level 2 Strategic Flood Risk Assessment’, is will also result in a significant worsening for residents of the settlement of Capel situated on and around Alders Road.

Bullet point 4:

The loss of MGB to allow for the development of Tudeley ‘Village’ (Tudeley New Town or Policy AL / CA 1) and the East Capel element of Policy AL / PW 1 is in direct conflict with this aspect of the Vision – “The exceptional quality of the built and natural environments will have been protected and enhanced.”

Paddock Wood can and should be regenerated without using greenbelt land in Capel and one of the other Growth Strategy options should have been adopted, without the need for a garden settlement, also taken from greenbelt land. The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. A new garden settlement is not required at Tudeley. Flood risk can be reduced using the Environment Agency’s existing plan which can be funded without developers building houses on MGB land. A garden settlement at Tudeley should not be part of your vision and is only there because the land is in single ownership. It is certainly not part of the vision of those who live there at the moment.

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

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Councillor David Shepherdson
Bidborough Parish Council

Individual but also Parish Councillor for Bidborough PC

Generally supportive of what you are trying to achieve in terms of trying to balance the increasing housing need and the very obvious desire of most existing residents to maintain areas of the Green Belt and other areas of land within the Tunbridge Wells area.

Given the numbers involved, fully accept that small developments are not going to get to the totals required so the concept of a major development at Capel/Tudeley seems to be the only realistic way of getting the high volume numbers which are required. Clearly there will be local opposition but if the plans can demonstrate that the local infrastructure that is envisaged will be an early priority in terms of being built, then maybe you can get some more sanguine voices to be heard.

In terms of my role as Bidborough parish councillor, I have mixed emotions about the fact that Bidborough does not contribute to the numbers target. Clearly there are those in the village who will be pleased to see no new development but the fact that the village school is having to attract numbers from further afield with only 25% from the village itself is worrying for its future health. Therefore I do not want to bury our heads in the sand about possible future new developments while acknowledging that there are few sites in the Bidborough region that are potentially suitable for housing development.

The closest site to Bidborough that is to be developed is at Mabledon and any high class hotel on our doorstep would offer potential employment and other benefits to the area. The housing development proposed on the east side of the A26 can be integrated into the landscape while maintaining the ribbon development that is apparent on that highway.

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Ann Gibson

Vision Statement: Rural enterprise will have been supported and the exceptional quality of the built and natural environments will have been protected and enhanced.

I see no efforts to support rural enterprise in Sissinghurst.

Vision statement 1: At the heart of all development in the borough will be connectivity, active travel, an appropriate mix of uses and accommodation and above all, the timely delivery of relevant infrastructure, which will have been funded by development: this infrastructure will have mitigated the impact of development, and wherever possible, resulted in “betterment for existing residents, users, businesses, visitors, etc.

Betterment of the residents of Sissinghurst is not delivered by further development necessitating use of cars to get to employment areas out of the parish.

Section 106 monies will not help to fund a new Medical Centre as no land has been allocated for this and there is not a proven will from the GP practices to amalgamate in this way.  The GP practices are full to capacity and there is a shortage of GPs in the West Kent Health Authority.

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Thomas Weinberg

Comments the Vision (Section 3) p.31

The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. Green Belt land must only be developed in “exceptional circumstances”. No exceptional circumstances have been articulated. There is plenty of land that can be developed outside of the Green Belt.

Paddock Wood can be expanded and regenerated without using greenbelt land at East Capel for housing.

Horsmonden has the existing infrastructure and is not on the Green Belt.

Flood risk to Paddock Wood and Five Oak Green can be reduced without using greenbelt land at East Capel.

Any development in East Capel will affect Green Belt land and fundamentally change two communities by merging Paddock Wood and Five Oak Green.

A new garden settlement is not required at Tudeley. Flood risk can be reduced using the Environment Agency’s existing plan which can be funded without developers building houses on perfect, unspoiled greenbelt land.

Please remove the creation of a garden settlement at Tudeley from your Vision.

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Roger Bishop

Vision and Objectives 1 - p31

You state that, among the alleged benefits of Tudeley New Town would be a reduction in “(existing) flood risk to areas of Five Oak Green; i.e. resulting in 'betterment' for these areas;”

It is difficult to envisage how removing hedges and trees and concreting over large tracts of (absorbent) farmland can reduce the existing flood risk. Although it is good to see that the existing flood risk – flooding is a reality rather than a risk – is acknowledged.

You go on to state that realising the Plan will mean that, “Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.”

It is difficult to see how these objectives are in any way compatible with getting rid of large swathes of Green Belt. Rather the Plan will destroy existing rural enterprises in Capel. The natural environment in a substantial area of Capel will be destroyed by the planned development in Tudeley and East Capel. Capel businesses will be severely impacted during the building process, even if only by roads even more clogged up than now.

[TWBC: see also Comment Numbers DLP_81 to 93].

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Gregg Newman

Comments the Vision (Section 3) p.31

The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances.

TWBC’s Vision is for an expanse of tarmac and concrete to replace Greenbelt land.

It is an inescapable fact that concrete and tarmac significantly increase flooding risks, since there is nowhere for the water to go, and nothing to absorb it.

Developing housing on East Capel will alter a greenbelt boundary without any justification and will cause coalescence between Paddock Wood and Five Oak Green.

Your Vision states that rural enterprise will have been supported and natural environments will have been protected and enhanced by 2036. There is no justification whatsoever for this statement. In fact, it breaks the moral contract between humans and the inhabitants of the land that cannot speak for itself. Greenbelt is not just for our benefit. It is to preserve ancient woodland and the hundreds of species of wildlife that call it home. We cannot simply pay lip service to “saving the planet” elsewhere in the world whilst ignoring our own doorstep.

This is simply immoral profiteering with no consideration whatsoever for the effects we have on the land.

Add to this the effects upon local businesses, country lanes etc. that will be called into use as rat runs for the construction and related equipment and we will end up with a wasteland.

I am advised that there is a site outside of AONB and Green Belt that was offered in the Call for Sites for a garden settlement; Horsmonden.

Please justify why this area has been rejected in favour of an area that is genuinely both Beautiful and Green. In fact, how many of the Councillors have ever even visited the area, and walked around it? I suspect that if they do, they will rapidly reconsider this very rash and ill thought through plan.

DLP_1481

Mrs Wendy Coxeter

Given that the Wealden AONB is recorded as comprising 70% of the borough’s land area, the vision is remarkable for its failure to recognise the importance of preserving its essential character or the borough council’s responsibilities towards it.

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Tonbridge & Malling Borough Council

TMBC recognises the challenges facing Tunbridge Wells Borough Council (TWBC) in preparing this Plan as we share many of the same constraints, including significant areas of Green Belt and Areas of Outstanding Natural Beauty in preparing the Tonbridge and Malling Local Plan. The aim of meeting objectively assessed needs for future development within the Borough is one we both share and is welcomed.

However, the proximity of some of the major development proposals to the borough boundary and specifically, the south east of our main settlement of Tonbridge, is a matter of serious concern due to the potential impacts on the local highway network, rail services and other community infrastructure including health care and education, particularly when combined with planned developments in Tonbridge as part of our own Local Plan.

While appreciating that this is an early stage of plan making and the development strategy may be subject to change, in the event that these proposals are brought forward in later versions of the Local Plan, TMBC needs to be assured that it will be a key partner involved with future infrastructure planning and master planning of the allocations that are likely to have a significant impact on Tonbridge and surrounding settlements close to the borough boundary. This collaborative approach would have to identify and mitigate any significant adverse impacts on existing infrastructure and services, including north-south travel throughout Tonbridge and Malling and any flood mitigation measures and also those planned as part of TMBC’s Local Plan.

It should be recognised that if following this process any of the new infrastructure or mitigations identified to meet the demand arising from any of the new developments is located in Tonbridge and Malling, then developer contributions should be allocated as necessary.

Tonbridge and Malling support the proposed approach to meeting the identified needs for future development in Tunbridge Wells within the borough, subject to both authorities proactively working together to ensure all cross-boundary issues are satisfactorily addressed as part of the Local Plan process. This will contribute to the conclusion of the ongoing master planning work and delivery of any identified infrastructure to be phased with the planned development so that any potential impacts are mitigated.

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Royal Tunbridge Wells Town Forum

Formed in 2005, the Royal Tunbridge Wells Town Forum is the voice of some 50,000 residents in the unparished area of Royal Tunbridge Wells. The Town Forum contributed detailed views and proposals during development stages of the Regulation 18 Draft Plan through publication of our Response to the Call for Sites Consultation in 2016, our Vision Statement for the town of Royal Tunbridge Well in 2017, our Response to the Consultation on Issues and Options also in 2017 and through our 2015 report “Developing our Green Network” and 2013 report “A Place of Pleasure and Resort” on developing tourism and culture in the town. These documents have been made available to TWBC with this response.

It is Town Forum policy that development should prioritise brownfield sites and only proven exceptional circumstances should justify encroachment into the surrounding Green Belt and AONB. Similarly, the exceptional historic fabric of the town calls for the greatest sensitivity towards heritage assets in considering any adjoining built development. Our comments should therefore be read against this policy background.

A strategic document such as the Local Plan should attempt to institute long term policies flexible enough to adapt to foreseeable trends in lifestyle choices in relation to housing type and location, transport mode, schools location, parking and retail provision.

For Royal Tunbridge Wells this should involve, inter alia:

  • Retaining clear, sustainable boundaries to the town so that suburban sprawl does not arise and all residents have safe walking or cycling access both to the town centre and to the open countryside
  • Urgently tackling the present atmospheric pollution which particularly threatens the health and wellbeing of children and the elderly and also noise pollution
  • Overcoming the present problem of road congestion by enabling modal shift away from private motor cars, ending rat-running in residential streets, ending the “school run” through modal shift and more accessibility to local schools and working with local employers to encourage active travel and alternative travel arrangements
  • Maintaining the historic fabric and semi-rural setting of the town which contributes to the general wellbeing of its residents and offers considerable future tourism potential
  • Maintaining sufficient local employment sites for all sectors of the population of RTW and further enabling employment in the town’s specialist fields of education, health, law and insurance and technology to reduce the risk of RTW becoming a dormitory town
  • Ensuring that any new housing development meets proven housing need, including the 50% element for affordable housing and is not primarily market-driven as has too often been the case under the existing Local Plan

We have welcomed the extent to which the Town Forum has been kept informed by Planning Policy Officers at all stages of the preparation of the Regulation 18 Draft and find that many of the specific policies in the Draft  broadly meet our own objectives for the town as summarised  in our comments in sections above.

Officers have faced an exceptionally difficult task in attempting to meet excessive government imposed housing targets while aiming for as little harm as seems reasonably practicable in these unusual circumstances to the valued natural and historic fabric of the Borough and of Royal Tunbridge Wells, which the Draft should seek to protect. They have succeeded to an extent in the policies affecting Royal Tunbridge Wells.

However, Town Forum policy is that development in the AONB and Green Belt should take place only on proof of exceptional circumstances. The greater the proportion of a district that consists of protected Green Belt and AONB areas, the less scope there should be for development in that district. Any evidence put forward of exceptional circumstances will therefore have to satisfy the Inspector at Examination in accordance with relevant legal precedent. We hope that some incursions into Green Belt and AONB can be reduced.

In the very difficult circumstances of the current unsatisfactory relationship between Central Government and Local Authorities, and subject to the important caveat above, we are broadly supportive of most of the sites now selected for allocation in the unparished area of Royal Tunbridge Wells, subject in many cases to conditions. We also strongly support decisions taken on those submitted sites deemed unsuitable for allocation as set out in our comments in Appendix 6. Full comments on sites proposed for allocation appear in our response to the AL/RTW Policies ante.

We particularly endorsed the Issues and Options Consultation document’s suggestion that enhancement of the exceptional quality of the built, natural and historic environment of RTW and its surrounds would be a pre-condition to any further built development in and around Royal Tunbridge Wells. We should like to see that wording maintained rather than the present lesser vision wording of merely “protecting” those special qualities. Possibilities for enhancement do exist and would help consolidate the town’s aspiration to be a destination town with a key role in retail, leisure and tourism in the High Weald.

Our main criticism of the Vision and the Draft Plan itself is not so much in relation to its aspirations but based on our scepticism as to whether the necessary provision of active travel infrastructure and substantial increases in public transport services in the Borough, water and wastewater infrastructure and adequate primary education sites and other health and wellbeing infrastructure will materialise at all or to the extent required to meet overall Plan objectives. Reliance principally on developer contributions seems to us an unreliable source, based on past experience, against the multi-million pound sums required to secure the objectives. With regard to transport infrastructure, we therefore reserve judgement pending the publication of a revised Transport Strategy to be ready for the Regulation 19 Consultation.

DLP_2025

Terry Everest

A more sustainanble vision in accordance with my furhter comments and observations would read that " Paddock Wood as a settelement will vae developed to some extent and have an enhanced and regenerated town centre.

I strongly oppose a new garden settlement at Tudely which would effectively destroy this historic village which should be protected by a conservation area and is within the green belt so should not be developed other than a tiny fraction of what is proposed, the current limits of development at Tudely coud support up to 15 new residential housing. To deliberately create a new town within protected land however "garden" like is not forward thinking or sustianable at all but represents a severe blight on the landscape and would be a net polluter, contribute to habitat loss, flood risk, the loss of ancient woodland, meadows and green spaces and risks with other proposals in this plan of creating a vast  negative suburban sprawl of developments connecting once distinct towns of  Tonbridge, Tunbridge Wells and Paddock Wood destroying and dissecting important green habitats, wildlife corridors and countryside buffer zones that are narrowly in place at present. This also applies even more strongly to Capel which is merely a hamlet and needs protection not massive development. Both of these elements I must strongly oppose as the scale of building is far too extensive and destructive to continue.

My entire family is in agrrement with opposing these elements of the plan as relatives of mine who live in Pembury informed me of these proposals and asked that I join in their opposal. Furthemore everyone that I have spoken to in my neighbourhood of Green Way and those within my circle at my running club at choir have expressed concern at the current pace and scale of developments already occurring around Tunbridge Wells - so I wrote for the opinions of at least a hundred people and maybe many  many more.

DLP_2124

James Tansley

The vision outlined is completely contradictory.  It is impossible to proceed with so much development while protecting "the exceptional quality of...the natural environments".  This is a management drivel ("betterment" - I ask you) at its most asinine.

DLP_2756

Lee Hatcher

Connectivity and active travel are mentioned again. How will this be possible from more rural areas? How can the Local Plan affect the provision of public transport - this would be a requirement to provide connectivity that isn't travel by car.

DLP_2829

Helen Parrish

Cross-referenced, detailed, reasons for my Objection:

Vision (Section 3) p.31

There is no justification to build on land next to, and on, Green Belt and floodplains

There no Flood Risk Assessment

DLP_3156

Nigel Bell

NPPF, Paragraph 11.

I understand that Tunbridge Wells Borough Council does not need to accept the levels of housing proposed by the Government where a large amount of land is protected by AONB as in Cranbrook. Maximising the protection afforded by AONB and applying for reduced development targets should be a fundamental part of the vision and objectives.

DLP_3166

Kent County Council (Growth, Environment and Transport)

Provision and Delivery of County Council Community Services

Bullet 2 and 3 –

The scale of development at Paddock Wood and Tudeley Village is considerable, it is therefore critical that KCC services are considered at an early stage for education, communities, youth, social care and broadband infrastructure to be commensurate with the scale of the development and future proofed to cater for the growing community

Sustainable Business and Community

KCC is supportive of the Plan’s approach to sustainable development and welcomes the Plan’s policies to support the transition to a zero-carbon economy; including high standards of energy and water efficiency, improving climate change resilience, biodiversity and green infrastructure, supporting innovative low carbon transport options and renewable energy and tackling poor air quality.


The Plan sets out proposals for the development of new garden village settlements, as well as significant expansion to existing urban areas. The Plan could further support the zero-carbon agenda by identifying where there is potential for these new settlements to become zero-carbon development hubs. This would demonstrate the Borough’s support for and encourage investment in trials and pilots of new zero-carbon technologies and infrastructure.

The transport challenge and opportunities section (paragraphs 2.23-2.27) must acknowledge the rapidly changing nature of transport. In particular, the section should acknowledge that the period of transition to electric and alternatively fuelled vehicles and that there is increasing use of shared/on demand vehicles. Whilst these issues are included in later paragraphs and polices, the rapid transformation expected during the Plan’s lifetime is significant enough to warrant inclusion within this high level section.

Heritage Conservation

KCC welcomes the recognition that the design of all developments must be of high-quality design and must take account of the outstanding built and historic environment of the Borough.

DLP_3497

Tara McCumiskey

Vision & Objectives 2 - I support - item 10. "To work with neighbourhood plan groups to ensure the formation pf locally-led policies. In decisions on Planning applications.

DLP_3676

Lynne Bancroft

Vision and Objectives 1 – one key issue relating to development in the eastern area of the Borough, and particularly Cranbrook and Sissinghurst, is ease of movement to Tunbridge Wells. The infrastructure required for this is the widening of the Lamberhurst to Blue Boys stretch of the A21. This will not have been done prior to the development of many of the homes proposed for this area and hence there will not be “timely provision of relevant infrastructure” for The Weald as set out in this vision. The local Plan is not infrastructure led, despite its premise.

If TWBC wishes to develop a garden village it must ensure that is its proposed location is close to fast transport links, both road and rail, and to economic opportunities. So adjacent to Tunbridge Wells or the dualled A21 corridor would meet this criteria. The east of the borough has poor transport links and poor employment opportunities so such a development would be unsustainable in the eastern area of the Borough.

DLP_3720

Capel Parish Council

Capel Parish Council (CPC) objects to the Vision set out on pages 31-32 of the Draft Local Plan (dLP) because too many of the strategies and policies of the dLP are ill-thought out and will not lead to the overall vision being achieved. In particular;

Bullet points 2 and 3 of the Vision – Paddock Wood (AL / CA 3 & AL / PW 1) / Tudeley ‘Village’ (AL / CA 1):

The ‘active travel connections to the new garden settlement’ are poorly planned and based on out of date data. There is nothing in the transport evidence base which justifies either the Colts Hill bypass or the Five Oak Green Bypass (Highway measures 202 and 203). Both of these measures will result the parish being carved up, unnecessary loss of AONB and MGB land and disruption to numerous home-owners (including some CPOs). It is, as yet, unclear how the proposed measures will result in a ‘betterment for these areas’. What is certain is that they will result in a significant worsening for residents of the settlement of Capel within Capel Parish. TWBC should not assume that a Bypass at Colts Hill is the solution to the issues caused by this road just because the scheme has long been lobbied for by prominent residents of that road. Some of the investigations into whether the road should be widened or bypassed are some forty years old and further studies should be undertaken rather than a Bypass being a given. The land safeguarded by Policy TP 6 should be re-considered.

Reducing existing flood risk to PW, Capel Parish & FOG resulting in “betterment” – reduced flood risk is welcome; but hardly a price worth paying for so much development and associated road infrastructure. The fact that the same ‘betterment’ comment is cut and pasted for Tudeley suggests this vision is not one that had the ‘betterment’ of Capel residents in mind.

The proposals to reduce ‘(existing) flood risk to areas of Paddock Wood, Capel parish, and Five Oak Green’ are also poorly planned and based on out if date data. The ‘Five Oak Green Flood Alleviation scheme’ outlined in page 57 of the supporting document ‘Level 1 & Level 2 Strategic Flood Risk Assessment’, will also result in a significant worsening for residents of the settlement of Capel within Capel Parish due to the increased flood risk further up the Alder Stream.

Bullet point 4:

The loss of MGB to allow for the development of Tudeley ‘Village’ (Tudeley New Town or Policy AL / CA 1) and the East Capel element of Policy AL / PW 1 is in direct conflict with this aspect of the Vision – “The exceptional quality of the built and natural environments will have been protected and enhanced.

CPC believe Paddock Wood can be regenerated without using greenbelt land at East Capel for housing and that either another location without constraints should have been chosen for a garden settlement, or one of the other Growth Strategy options should have been adopted. Similarly the flood risk to Paddock Wood and Five Oak Green can be reduced without using greenbelt land at East Capel.

The Vision for Paddock Wood should not include East Capel which is part of a completely different community.

Housing in East Capel will alter the greenbelt boundary without any justification and will cause coalescence between Paddock Wood and Five Oak Green. The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. See comments on SA. This land is key to preventing convergence between Five Oak Green and Paddock Wood.

A new garden settlement is not required at Tudeley. Flood risk can be reduced using the Environment Agency’s existing plan which can be funded without developers building houses on MGB land. A garden settlement at Tudeley should not be part of your vision and is only there because the land is in single ownership. It is certainly not part of the vision of those who live there at the moment.

Your Vision states that rural enterprise will have been supported and natural environments will have been protected and enhanced by 2036. This is not true. The Local Plan will destroy rural enterprises, such as the equestrian facilities at Bank Farm alongside other businesses in Capel. The natural environment in Capel will be badly damaged if the development of new housing in Tudeley and East Capel goes ahead. Neighbouring businesses will also be affected during the long building process, including huge amounts of roadworks on one of the busiest roads in the borough. These works are bound to take many years and will put untold stress on the local community. Moreover, the Tudeley and East Capel proposals which are within two miles of each other and share the same road links seem to be scheduled for development in the same timeframe. This will place severe and disproportionate strain on the local community and infrastructure.  A garden settlement would be better in a more remote part of the borough outside the Green Belt and AONB, to give that area a boost and to minimise disturbances caused by construction. The two sites that satisfy the criteria and are identified in the evidence base; Horsmonden and Frittenden have not been explored further in the sustainability appraisal.

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Mr Adrian Cory
Mrs Lucy Howells
Sandra Rivers
A & B Cowdery
Sadie Dunne
Geraldine Harrington
E Leggett
N T Harrington
Rob Crouch
Storm Harrington
B Draper
Nicki Poland
May Corfield
Peter Felton Gerber
Mary Jefferies
Mr Peter Jefferies
Diana Robson
Mike & Felicity Robinson
Mr Richard Cutchey
Kristina Edwards
Mr Peter Brudenall
Alistair Nichols
Kevin Conway
Charles Vernede
Mrs Sarah Vernede
Lorraine Soares
Angela Thirkell
Gary Birch
Madelaine Conway
Vivien Halley
Clive Rivers
Linda Beverley
Rosemary Cory
Deborah Dalloway
Mr Simon Whitelaw
Sally Hookham
Gillian Robinson
Paula Robinson
Andrew Roffey
Kylie Brudenall
Simon Parrish
Catherine Baker
Patrick Thomson
Catherine Pearse
Sally Thomson
Victoria Dare
Keith Peirce
Andrew Hues
Penny Ansell
Mary Curry
Jan Pike

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

Given that the Wealden AONB is recorded as comprising 70% of the borough’s land area, the vision is remarkable for its failure to recognise the importance of preserving its essential character or the borough council’s responsibilities towards it.

The vision states:

High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure. The growth of these settlements will have reflected local input and circumstance, including through assessment against neighbourhood plans;

This should be sufficient to dismiss the proposals in relation to Hawkhurst, where the Plan ignores local input and circumstances, dismisses the neighbourhood plan and follows, uncritically, the developer’s agenda in presenting proposals for an irrelevant “relief road” as a precursor to development approval.

DLP_3893

Ide Planning for Paddock Wood Town Council

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.

DLP_3934

Mrs June Bell

Vision statement pg 31 should include additional text in BOLD ‘All developments will be of high quality design and….. and meet local needs for new dwelling (eg in Cranbrook & Sissinghurst HNA - a range of local housing types and tenures to meet the needs of the population from first home to downsizing and for affordable homes for those who work in the parish).

DLP_4292

Changing Cities for 42 Leisure PLC

The vision states that the heart of Royal Tunbridge Wells will be culturally rich and full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances. The Main Urban Area of Royal Tunbridge Wells will offer a diverse range of attractions, and will have benefited from further investment and employment-generating development, while protecting its special qualities and those of its surrounds.

We are of the view that the vision fails to recognise the need to regenerate the area around the Pantiles and does little to enhance the vitality or range of attractions in this area. The approved development of Union House is primarily a residential development and does not deliver the range of uses or enhance the cultural offer in the southern part of the Town Centre. A more ambitious vision is required to enhance the town centre and its special qualities.

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Mill Lane and Cramptons Residents Association

Vision and Objectives 1 – Supported.

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Ann & John Furminger

Vision Statement 1

Betterment for the residents of Cranbrook and Sissinghurst is not delivered by large scale housing developments necessitating use of cars to get to employment areas out of the Parish. The needs analysis for the area does not show a need for the number of houses proposed in the local plan. Also local research for the LDP shows that local people want smaller, and more developments rather than larger and fewer developments. The large scale plans for housing in the area, for people working elsewhere is not environmentally focused as it merely serves to increase the number of commuters on our already stretched road network eg the A road via Goudhurst which is already over used and plagued with traffic queues throughout the day. We acknowledge that we do need more housing and also more support therefore for local businesses, however the volume planned will we fear mean that he area becomes a dormitory settlement and does not retain its local flavour and community and services. There appears to be no effort to support rural enterprise in Cranbrook or Sissinghurst.

No land has been allocated for section 106 money to help fund a new Medical Centre and there is no evidence that GP practices wish to amalagamate in this way. In addition it is known that there is a shortage of GPs in the west kent area.

Vision and objectives 2

TWBC needs to raise its standards required of developers to those of the parish councils of Cranbrook and Sissinghurst. Building needs to aspire to a higher level - similar to the PassivHaus standards as housing needs to be sustainable and of a quality that ensures areas of new housing are not purely for the financial benefit of the developers. Their profit margins mean that they are able to build to a higher standard and at the same time keep prices affordable for those they target as their market. In addition houses need to be affordable for the younger members of the population – the Crane Valley Land Trust is an example of the type of venture that we would like to see being used ie where there is a choice of renting, selling and investment in future development. Housing needs to be genuinely affordable eg Norwich scheme.

2.4 – there is no evidence to suggest there is affordable housing going to be made available and there is no evidence of section 106 money being used in the Cranbrook and Sissinghurst parish.

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Berkeley Strategic Land Ltd

INTRODUCTION

1.1. This representation is submitted by Berkeley Strategic Land Limited (“Berkeley”) in response to the Tunbridge Wells Local Plan Regulation 18 Preferred Options consultation.

1.2. Berkeley welcome the opportunity to continue to be involved in the local planning process and provide comments on the Draft Plan. Berkeley always seek to become involved in the plan-making process as early as possible and as a Group we value continuous engagement with the Local Authority.

1.3. Berkeley has control of land located at Tutty’s Farm, Hawkenbury. The land lies to the southeast of Tunbridge Wells and amounts to approximately 17.2 acres in size.

1.4. The site plan is attached at Appendix 1.

[TWBC: see full representation].

2. VISION AND OBJECTIVES 1

2.1. Berkeley agrees that the Council should look to disperse growth across the Borough, however we believe that there is a disproportionate level of growth towards Tudeley Garden Village and the multiple sites within the settlement of Paddock Wood as is outlined and discussed in section 4 of these representations.

2.2. We support and agree with the Council regards the

“High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure. The growth of these settlements will have reflected local input and circumstance, including through assessment against neighbourhood plans”

2.3. Berkeley also support the importance of maintaining and supporting growth across the rural areas of the Borough, which are plentiful across the Borough of Tunbridge Wells.

“Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced”.

2.4. We support the proposals for the high quality design, connectivity, active travel and an appropriate mix of uses as outlined within the vision;

“All developments will be of high quality design, having responded to the distinctive and particular character of their locations: in some instances the development will have taken place within valued and protected landscapes, and this will be recognised in the quality of the design of the development, the protection and enhancement of the exceptional quality of the built, natural, and historic environment, and the provision and protection of landscape features and green spaces. Green, grey and blue infrastructure will be an integral and defining element in the design and layout of new developments, with opportunities for inclusion of public art and improved cultural provision to have been realised”.

“At the heart of all development in the borough will be connectivity, active travel, an appropriate mix of uses and accommodation and, above all, the timely delivery of relevant infrastructure, which will have been funded by development: this infrastructure will have mitigated the impact of development, and, wherever possible, resulted in 'betterment' for existing residents, users, businesses, visitors,etc”.

DLP_5009

Stephen Roberts

This plan can be seen to shoehorn, in 30 years, four times more housing than has been sensitively added to the Capel landscape in over 400 years (that’s a proposed 5,300% acceleration in building!) For TWBC this plan can meet the short-term self-serving aims of the current administration enabling it to avoid a proper examination of housing need and a full reflection upon the current direction of preferred development of brown field and inner-city and town development promoted by central government. Why? Because they know they will not be re-elected if they do their jobs properly – by foisting the potential development of so much housing on so small a part of the Borough, they no doubt calculate this will have a minimal effect on their election  / re-election prospects and in the bargain, foist the run off, overspill, traffic, GP waiting lists, schooling and social shortfall onto Tonbridge, which is so much closer to the proposed development than T Wells.

I don’t know if this is relevant, but in the opening planning sign off meeting  (the first meeting where residents were granted attendance and were cut off after the allocated 6 minutes to listen to 25 minutes of self-congratulatory clap trap from the Council), one Councillor was overheard to say they didn’t know what all the fuss was about, she would be dead before the houses were built.

DLP_5045

Hawkenbury Village Association

We are strongly supportive of a new garden settlements to be established near Tudeley and Capel, including homes, employment, and community facilities.  A new settlement can be properly planned to provide the infrastructure and sustainable transport solutions which cannot be funded by s106 monies from smaller housing projects. The creation of a new settlement does not detract from or alter the character of any existing settlement or overload the facilities of the existing settlement but instead it provides an entire new community, with the facilities that the community needs.

[TWBC: this comment has also been entered under Policy AL/CA 1. See Comment Number DLP_5046].

DLP_5163

Cushman Wakefield for Ministry of Justice

The vision is incomplete because it is blind towards large previously developed sites in the countryside and so fails to make appropriate provision for their proper assessment which may not accord with the direction of the main strategy but which are of a scale which requires an appropriate and proportionate response in order to ensure the optimum planning outturn.

[TWBC: see Comment Numbers DLP_5154, 5157-5159, 5161, and 5163-5164. See also full representation].

DLP_5221

Culverden Residents Association

The Culverden Residents’ Association represents residents living in Culverden and St John’s Wards on Culverden Park Road, Culverden Park, Culverden Avenue and Campbell Road, parts of Culverden Down and Reynolds’ Lane as far up as Caenwood/ Woodgates Farms on the outskirts of Southborough. We currently have some 90 members and over two dozen members regularly attend our AGM held in April. We wish to see the new Local Plan deliver a cleaner, safer, quieter town with a dynamic economy, more cultural opportunities and much better overall wellbeing and reduced levels of stress in the population.

In particular, we would like to see:

  • urgent measures introduced to reduce atmospheric pollution in residential streets, which particularly threatens the health and wellbeing of children and the elderly and also noise pollution from road traffic;
  • the ending of rat-running in residential streets and reduction in the “school run” by encouragement of active travel through working with local employers and parents and by providing more accessible primary schools;
  • the prevention of suburban sprawl so that all town residents have safe walking or cycling access both to the town centre and to the open countryside
  • the maintenance of the historic fabric of the town centre and its semi-rural setting which contributes to the general wellbeing of our members and offers considerable future tourism potential for Tunbridge Wells as a destination town;
  • new housing development which meets only proven housing need, with an emphasis on affordable housing;
  • retention and development of  sufficient local employment sites for all sectors of the population of the town including the less skilled so that Tunbridge Well does not become a dormitory town with even more outward commuting;
  • Adequate new infrastructure in the borough to support any proposed further development provided in advance or concurrently with that development.

We therefore support those parts of the Vision set out after paragraph 3.2 of the Draft which are compatible with the above aspirations for our neighbourhood and the borough as a whole. We generally endorse the more detailed comments and proposals which have been put forward on the Vision and individual strategies and policies in this regard by the Royal Tunbridge Wells Town Forum in their response to the consultation.

We particularly strongly endorse the proposal by the Town Forum that a further strategic objective  of ensuring Health and Wellbeing should be included in the Vision and Objectives using the wording it has suggested:

“In co-operation with other relevant agencies, to devise, implement and enforce planning policies favouring the improvement of the health and wellbeing of the borough’s population.”

The health and wellbeing of the population should be a principal objective of the Local Plan. Developing Tunbridge Wells as a healthier place to live requires an integrated approach to the population’s wellbeing, and must be inclusive for all ages, incomes and abilities. As such, a wellbeing strategy is required, which should focus on the basics to make it easier for people to lead a healthy lifestyle.

DLP_5563
DLP_5613
DLP_7566

Mr Paul Hewitt
Mrs Jacqueline Hewitt
Mark Beales

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

Vision statement: Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

Having read the plan, I see no efforts at all to support Rural Enterprise in Cranbrook and Sissinghurst.

Vision Statement 1 At the heart of all development in the borough will be connectivity, active travel, an appropriate mix of uses and accommodation and, above all, the timely delivery of relevant infrastructure, which will have been funded by development: this infrastructure will have mitigated the impact of development, and, wherever possible, resulted in 'betterment' for existing residents, users, businesses, visitors, etc.

Betterment for the residents of Cranbrook and Sissinghurst is not delivered by large scale housing developments necessitating use of cars to get to employment areas out of the Parish

Suggesting that section 106 monies will help to fund a new Medical Centre is disingenuous as no land has been allocated for this and there is not a proven will from the GP practices to amalgamate in this way. In fact, the GP practices are full to capacity and there is a shortage of GPs in West Kent Health Authority

DLP_5883

Ms Sally Moesgaard-Kjeldsen

It's going to look like an eyesore, our greenbelt will be gone with a concrete jungle in it's place, more cars, more fumes, our intrastructure will not cope.

DLP_5891

Mr and Mrs Jonathan & Nicola Marriott

Although nobody could argue with the expressed wish of the Vision that Tunbridge Wells will, by 2036, be a vibrant and prosperous place to live, there must be serious concerns about the deliverability of the Vision and, most importantly, the infrastructure required to support the very substantial development proposed. In particular:-

1) We question the need for the scale of development throughout the Borough. The current housing ‘need’ figure of 300,000 is based on the Office of National Statistics (ONS) 2014 calculations, which the ONS overturned in 2016 saying the wrong methodology had been used and that the correct figure was 160,000. Figures from the ONS published on 21st October 2019 state that the population is growing at a slower rate than previously forecast in 2016, although the number of people over 85 will increase substantially. Thus it is likely that that housing need may well be adjusted downwards again. The Borough has accepted the original figure without challenge and, indeed, has over-provided in the DLP to the tune of approximately 9%.

2) The Borough is subject to a substantial number of constraints that contribute considerably to the Borough’s character and which make it a very attractive proposition for outsiders. The Borough’s current proposals are in no small part based on the aspirations of people from outside the Borough and take little account of genuine housing need of residents.

3) Very little mention is made of the railway infrastructure, but, if the Borough is to become a dormitory for London workers, then greater attention must be paid to this. Trains are already full. There is minimal scope for putting more trains into the London terminals at peak times. Increases in housing down the line at Marden and Staplehurst are adding to the strain. London mainline stations are near capacity and could not accommodate more passengers without extending platforms to take longer trains or making the trains into Continental style double deckers, which would necessitate major alterations to the tunnels. Both of these propositions would be expensive and cause major disruption, if they were possible at all. Additionally, the car parking would have to be increased, particularly at Paddock Wood, which will bear the brunt of the Eastern sector expansion. It will have to serve Paddock Wood residents and mainline commuters from Horsmonden, Matfield and Pembury and possibly from any new development at Tudeley.

4) Tunbridge Wells Borough is in an area of High Water Stress. Building the proposed number of houses will only exacerbate this, whilst building large numbers of houses around Paddock Wood has implications for the flood plains. The sewerage infrastructure is inadequate. Questions were raised by the Borough’s MP Greg Clark in an adjournment debate on 28th October 2019, regarding the present state of Southern Water’s sewerage systems currently serving Paddock Wood, which are woefully inadequate. There is no immediate resolution in prospect to deal with this, let alone thousands of new houses.

5) The traffic implications for the Borough’s roads of the developments at Capel and at Paddock Wood are considerable, especially when combined with the developments at Matfield, Horsmonden and Pembury, all in the Eastern sector. There will be many more vehicles using small rural roads, which are simply not designed to take the stress

6) There is inadequate use of brownfield sites across the Borough and particularly within the urban areas. More imaginative design and use of sites could provide homes and businesses in the towns where most facilities are available. Not enough thought has been given to the demise of retail and better use of redundant shop premises.

DLP_5970

Tim Wye

In general I believe there is too much dispersed development in the vision. Much better, in my opinion, to focus large growth in the existing urban areas like Tunbridge Wells and Southborough with limited growth in the rural areas in order to protect that special rural quality and way of lif, as well as making use of the existing choice of transport links (road, rail, etc) in the urban areas. The more development there is in rural areas the more infrastructure is required, more roads, more street lights more urban spill and the countryside will be damaged forever. Contain the urbanisation to existing towns and protect the villages.

DLP_5984

Steve Rix

Vision and Objectives 1 (page 31) I object to there being little proposed economic development in rural areas, with most employment land proposed for North Farm in Tunbridge Wells (Policy ED 1 - page 461). With the number of new houses east of Goudhurst adding up to 1,751, the highways are not big enough to accommodate the increase in traffic to this part of the borough. Road networks comprise historic narrow streets unsuitable for widening and heritage-designated landscape (High Weald AONB) that will be irreparably damaged by excessive cars and their pollution.

Vision and Objectives 1 (page 31) I object to the strategy of placing 1,751 new houses east of Goudhurst when almost all employment opportunity for the borough is proposed in Tunbridge Wells. The highways are not big enough to accommodate the increase in traffic.

DLP_6297

Tunbridge Wells Constituency Labour Party

Tunbridge Wells Labour Party recognises the challenges in the Local Plan to deliver on ambitious housing targets to 2036. Development should be focused primarily on brownfield sites with undeveloped green sites safeguarded for future generations to enjoy as countryside, parks and open space.

However we recognise that if we are going to start to solve the local housing crisis then this is best achieved by planned development of new communities with appropriate new infrastructure rather than through piecemeal smaller developments. The latter often comes with limited new infrastructure and insufficient developer contributions to mitigate pressure on existing services. With this in mind TW Labour broadly supports the principles contained in the Local Plan to deliver new development subject to commitments on providing affordable housing including a significant proportion for social rent (as outlined in the Local Plan) and new infrastructure being met.

We welcome that the Local Plan will resolve the situation where the Council has failed to maintain 5 years worth of land. Developers have been winning appeals because the Borough Council has lacked up to date strategic development policies and plans.  We welcome that this situation will be resolved so development can be better managed and directed to appropriate sites.

DLP_6537

Diana Badcock

Vision Statement 1:

Quote: ‘Rural enterprise will have been supported and the exceptional quality of the built environment (in this case - Cranbrook’s historic town) and natural environments will have been protected and enhanced.’

Really? I cannot see how Cranbrook (in the AONB) and Sissinghurst’s natural environment will have been protected by the huge unnecessary number of houses (insufficient of them affordable). And I see no evidence that Rural enterprise is being supported in the area.

Quote: ‘All developments will be of high quality design’

– but not of the highest quality it would seem. Bearing in mind climate change pressures and the nature of the AONB, surely the designs should be of the highest quality possible. Norwich has managed this for its new social housing and in winning the Stirling prize, has shown what ‘Vision’ truly is. TWBC you can do better than this.

‘Betterment’ will not be delivered to the residents of Cranbrook by large scale housing development. It is out of all proportion to the natural evolution of a such a historic market town.

‘At the heart of all development will be connectivity, active travel….’so where will all the people in these new Cranbrook houses go to work? Are they to travel in their cars to Tunbridge Wells (14 miles), Maidstone (14 miles),Hastings (18 miles) etc. and the car parks at Staplehurst station are already full. And where are the extra bus services or innovative and creative alternatives to the traditional bus?

Putting so much building east of Goudhurst will result in huge pressure on the already congested small roads through these historic small town centres. Goudhurst suffers already from serious traffic congestion, and the impossibility of two huge vehicles passing each other on the road round the church is commonly experienced. If the employment area is to be expanded at North farm estate, near the main arterial road the A21, then much of the new housing should surely be placed there too.

Vision and Objectives 2

2.6. How is it possible, given the large scale developments proposed for Cranbrook & Sissinghurst , for the ‘valued’ heritage and the AONB, to be protected sufficiently and there be ‘net gains for nature’ (Vision and Objectives 2.6). The 900 houses proposed are surely in contradiction to this objective.

2.8. The use of Renewable energy technology is welcome as far as it goes but why is TWBC not insisting on the highest standards for all the buildings, including those of Passivhaus?

2.10. Contrary to the Objective stated here, there is no evidence that TWBC has consulted with Cranbook’s NDP to ensure the formation of locally- led policies? Of course we need more housing but of the affordable kind, including social housing. And how did TWBC arrive at the supposed need for 900 new dwellings in this area when the NDP’s independent assessor‘s figure was 610?

DLP_6607

AAH Planning for Future Habitat Ltd

SECTION 3 – VISION AND OBJECTIVES

Section 3 of the Consultation Draft sets outs the Council’s overarching vision and objectives which identify the ambitions and philosophy of the Local Plan. The vision will set out what the Council believes the Borough will look like at the end of the plan period (2036). In order for this vision to be realised, a number of overarching objectives have been identified.

Vision

The vision, as set out within the Consultation Draft, states:

“In 2036, the Borough of Tunbridge Wells will be vibrant and prosperous. It will have grown throughout the plan period on the basis of being infrastructure-led, with this infrastructure largely funded by development:

The hearts of Royal Tunbridge Wells and SouthBorough will be culturally rich and full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances. The Main Urban Area of Royal Tunbridge Wells and SouthBorough will offer a diverse range of attractions, and will have benefited from further investment and employment-generating development, while protecting its special qualities and those of its surrounds;

Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, masterplanned approach. This will have provided a vibrant and regenerated town centre, together with enhanced employment, leisure, and other facilities, the delivery of significant and strategically planned infrastructure, to include active travel connections to the new garden settlement at Tudeley Village, Royal Tunbridge Wells and SouthBorough, and Tonbridge, and reducing (existing) flood risk to areas of Paddock Wood ,Capelparish, and Five Oak Green; i.e. resulting in 'betterment' for these areas;

A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities: this will continue to develop into the following years. It will be well connected to other settlements, be an exemplar development in design, sustainability, and active travel, and will contribute to strategically planned infrastructure, including reducing (existing) flood risk to areas of Five Oak Green; i.e. resulting in 'betterment' for these areas;

High quality development at other settlements across the Borough will have been realised, with the timely provision of relevant infrastructure. The growth of these settlements will have reflected local input and circumstance, including through assessment against neighbourhood plans; Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

All developments will be of high quality design, having responded to the distinctive and particular character of their locations: in some instances the development will have taken place within valued and protected landscapes, and this will be recognised in the quality of the design of the development, the protection and enhancement of the exceptional quality of the built, natural, and historic environment, and the provision and protection of landscape features and greenspaces. Green,grey and blue infrastructure will be an integral and defining element in the design and layout of new developments, with opportunities for inclusion of public art and improved cultural provision to have been realised.

At the heart of all development in the Borough will be connectivity, active travel, an appropriate mix of uses and accommodation and, above all, the timely delivery of relevant infrastructure, which will have been funded by development: this infrastructure will have mitigated the impact of development, and, wherever possible, resulted in 'betterment' for existing residents, users, businesses, visitors, etc.

The Local Plan, and the appropriate application of the policies, will be one of the key vehicles to deliver this vision.”

In general, our Client is supportive of the proposed vision as set out within the Consultation Draft, however, it is considered that further emphasis should be placed on the commitment to provide a variety of house types and sizes through the delivery of much needed new homes in sustainable locations to better reflect the emphasis on sustainable growth and boosting the supply of housing as highlighted in the NPPF (paragraph 59).

In light of this we advocate the following points added to the vision:

  • The Local Plan will seek to boost significantly the supply of housing within the Borough; ensuring that housing need can be sufficiently met over the plan period and that an appropriate balance between jobs and new homes is achieved.
  • That growth is focussed on sustainable locations within the Borough including logical extensions to the existing urban area.

As set out within national policy, the Council must allocate sufficient sites for new housing to meet the social and economic needs of the area, as well as ensuring the right location(s) are chosen to accommodate growth in a sustainable manner. In addition, paragraph 59 of the Framework goes on to place a requirement of Local Planning Authorities (LPAs) to boost significantly the supply of housing. For this to be achieved through the plan making process, it requires LPAs to fully illustrate the expected rate of housing delivery and set out a strategy to describe how the required delivery will be maintained.

The purpose of the vision is to set out the Council’s overall ambitions and philosophy of the Local Plan and it is considered that a stronger emphasis should therefore be placed on housing delivery, which is turn will support economic growth.

The Borough requires a demonstrable supply of residential development sites which are well located to key essential amenity including public transport links, education, healthcare and recreational facilities and which also have the potential to provide long term economic and infrastructure benefits.

It is considered that residential development at Hawkhurst will provide all these benefits and help support the provision of a number of new dwellings to meet the Council’s identified housing need.

[TWBC: see full representation and site plan].

[TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627].

DLP_6667

Gladman

4.2 Vision

4.2.1 Gladman believe that insufficient regard is attached to social issues within the vision set out in the Local Plan. No reference is made within the vision to ensure that current inequalities within the Borough such as access and opportunity to affordable and high-quality new homes are addressed over the plan period. The need for authorities to meet identified local housing need is a key government objective for planning and needs to be reflected in the vision in order for it to be found sound. Similarly, Gladman consider that the vision should contain a commitment to secure an increase in the delivery of affordable housing, ensuring that new homes constructed are sufficiently sized and diverse to meet and respond to the needs of the community.

[TWBC: see full representation].

[TWBC: see also Comment Nos. DLP_6656-6695]

DLP_6784

G M Whitehead

All developments will be of high quality design, having responded to the distinctive and particular character of their locations: in some instances the development will have taken place within valued and protected landscapes, and this will be recognised in the quality of the design of the development, the protection and enhancement of the exceptional quality of the built, natural, and historic environment, and the provision and protection of landscape features and green spaces. Green, grey,

and blue infrastructure will be an integral and defining element in the design and layout of new developments… above all, the timely delivery of relevant infrastructure, which will have been funded by development.

Your record is not good on design which responds to the character of locations where development takes place. There has been very poor development in Cranbrook in the past and the already agreed part of Brick Kiln Farm site doesn’t appear to have taken on board any of the High Weald AONB Building Design Guidance about layout and materials.

The ’timely delivery of relevant infrastructure’ means it should be there before the development not afterwards, funded by the development.

DLP_6854

John Gibson

Vision Statement.

There appears to be little or no attempt to support Rural enterprise within the Cranbrook and Sissinghurst parish.

Vision Statement 1

It is difficult for me to see how the introduction of the proposed AL/CRS13 development will be to the betterment of the residents of Sissinghurst. The dangerous road accesses, the increased traffic and the extra demand on the limited village infrastructure will greatly reduce the quality of urban life in this small village.

Vision and Objectives 2.1

The build qualities proposed by the local Parish Council are higher than those set by TWBC. It is imperative that TWBC raises its standards towards that of Norwich for example and aspires to PassivHaus. The obvious deficiencies in the proposed designs put forward by Dandara in their application to build on site AL/CRS13 must be denied.

Vision and Objectives 1

The requirement to be of high quality design having responded to the distinctive and particular character of their locations seems to have been missed by the Dandara planning application for AL/CRS13. The appalling bland rear elevations of the affordable homes adjacent to Cramptons in Sissinghurst is testament to that.

DLP_6973

Mrs Beryl Bancroft

The vision only seems to be able to be achieved if you live in the Centre of Tunbridge Wells as no thought has been given to the outlying areas of The Weald where infrastructure is poor. Local transport is sparce and Rural roads are increasingly swollen with heavy traffic which makes travelling difficult. More houses are planned in areas which cannot sustain them, due to lack of schoolplaces and local work opportunities.

DLP_6980

Nigel Tubman

The Vision is all about Tunbridge Wells and Southborough. The eastern part of the borough is totally excluded but it’s the eastern part of the borough that is expected to accept a disproportionate amount of housing without substantial improvements to its infrastructure and employment and training opportunities. The vision talks about infrastructure-led development funded by development but it will be housing that comes first and then maybe some infrastructure. But, we are all aware, infrastructure developments rarely meet the requirements in a timely fashion if ever.

A major development such as this requirements a major increase in infrastructure.

The Vision ignores the importance of the AONB and the level of local demand for more housing. The Vision should state that it will protect the AONB from future development and discuss with government that the borough should not have to accept such a large amount of new house building in view of the 70% of the area covered by the AONB.

This Vision is about attracting more people to the borough rather than providing for the wider needs of the existing population.

The Vision provides nothing for the eastern part in support of economic development, employment, transport, environment safeguards or traffic management and safety. As for talk about active travel, has anyone from TWBC taken a cycle ride around the roads and lanes of the eastern part of the borough at the busiest times of the day?

The Vision throws in worthy statements about sustainability, high quality housing standards, respect for historic settlements, culture, climate change and the needs of local communities and locally led policies. Does TWBC really expect people to believe any of this?

It’s unsustainable to expect people from the eastern part of the borough to travel by car to Tunbridge Wells for cultural, retailing, employment. It would be far better to provide these activities where they are needed. The vision should take account of Local Plan Option 3 Dispersed Growth ‘development distribution should be proportionate across all of the settlements.

DLP_7003

Turnberry for Hadlow Estate

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

5.1. The following proposed amendments have arisen in response to the specific issues regarding Soundness identified above. The following changes are considered necessary to ensure intentions are clearly expressed and the policies are Effective and Consistent with National Policy:

5.2. Vision and Objectives 1

Vision

A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities: this will continue to develop into the following years. It will be well connected to other settlements, be an exemplar development in design, sustainability, and active travel, and will contribute to strategically planned infrastructure, including reducing (existing) alleviating flood risk to areas of Five Oak Green where possible ; i.e. resulting in ‘betterment’ for these areas;

5.3. Tudeley Village

5.60 [Extract]: Would be subject to comprehensive masterplanning to ensure delivery of the allocation, including the proper provision of the necessary infrastructure, including highway works, which is recognised as a major issue to be addressed by the masterplanning work, active travel provision, a new secondary school, and a balanced mix of uses, including housing, employment, and community uses. It is likely that the land that will provide the routes of the transport links will be allocated within the Regulation 19 Pre-submission Local Plan;

[TWBC: see full representation].

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

DLP_7089

Brown & Co Planning Ltd for The Hendy Group

COMMENTS ON THE VISION (SECTION 3)

The Vision and Objectives 1; Object; General Observation

1.111 The 2036 vision for Tunbridge Wells is set out on the basis of being infrastructure-led with this infrastructure being largely funded by new development.

1.112 As set out at paragraph 34 of the NPPF, plans should set out the contributions expected from development, but this “should not undermine the deliverability of the plan”.

1.113 Strong infrastructure will be important to support new growth. However, the plan must be realistic in terms of what may be achieved from new sites in order to ensure that over ambitious objectives do not stifle growth or provide a brake on development.

1.114 As set out in the Infrastructure Delivery Plan (IDP, draft 2019), new development is expected to meet the needs for infrastructure that are generated from the development itself (IDP) (paragraph 2.27).

1.115 The Council cannot rely solely on new development to meet infrastructure needs and both the Council and statutory providers will also need to contribute in order to address existing deficiencies.

1.116 However, as set out in Appendix 1 (Infrastructure Delivery Schedule) of the IDP, the Council set out the delivery body and funding position for each infrastructure project. The critical and essential priority projects [13 The desirable priority projects have not been considered as they are less urgent.] are outlined below for Tunbridge Wells and Pembury:

Tunbridge Wells – there are 14 critical/ essential priority projects, of which 13 are to be funded either solely or partially through developer funding (CIL/S106).

Pembury – the only essential [14 There are no critical projects for Pembury.] priority project in Pembury is a medical facilities hub. Funding for this is not yet confirmed.

1.117 The IDP has not made it clear if the projects to be partially funded by other sources [15 Other sources including South East LE/ Local Cycling and Walking Infrastructure Plan / Government Future High Streets Fund (or similar).] in Tunbridge Wells have secured any funding.

1.118 Most notably, the Council are currently preparing a Local Cycling and Walking Infrastructure Plan (LCWIP). The IDP states that having a LCWIP in place will enable the Council to apply for any funding that becomes available under the Government’s Cycling and Walking Investment Strategy (CWIS), as well as any other relevant funding streams (paragraph 3.58 of the IDP, draft August 2019).

1.119 However, the Council have already cited that funding for some of the critical/essential projects in Tunbridge Wells will be partially delivered through the LCWIP, but there is no LCWIP in place.

1.120 As such it is clear that funding for critical infrastructure projects in Tunbridge wells is a long way off, with funding being heavily reliant on developer funding. This will impact the delivery of new development in the borough.

1.121 It makes sense to focus initial growth in the plan period within and on the edge of existing settlements.

1.122 Such development will not normally trigger a need for investment in new infrastructure, beyond any site-specific requirements, and will thus be more deliverable earlier in the Plan period and can contribute at an early stage to addressing the Council’s current housing supply deficit.

1.123 Sites such as the Client’s Mt Ephraim site in Tunbridge Wells (AL/ RTW 8) and the new Motor Village Dealership at Pembury (AL/PE 7) will (subject to relocating the existing business) be able to contribute in the short term to the Council’s housing need and the provision of jobs in the Borough. However, with anticipated high development costs, the additional impact of funding new infrastructure in the borough could (unless appropriately controlled) make redevelopment of the site unviable.

1.124 Our Client would question the robustness of this aspect of the vision and its consistency with national policy – enabling the delivery of sustainable development.

UNSOUND: Absence of evidence for relying predominately on Developer funding for infrastructure, means that the Council cannot proceed with confidence that this will not undermine the deliverability of development in the borough. 

[TWBC: see full representation and supporting documents: Park & Ride Feasibility Review and site location plan].

DLP_7237

Elizabeth Daley

Vision statement: Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

Having read the plan, I see no efforts at all to support Rural enterprise in Cranbrook and Sissinghurst.

Vision Statement 1 At the heart of all development in the borough will be connectivity, active travel, an appropriate mix of uses and accommodation and, above all, the timely delivery of relevant infrastructure, which will have been funded by development: this infrastructure will have mitigated the impact of development, and, wherever possible, resulted in 'betterment' for existing residents, users, businesses, visitors, etc.

Betterment for the residents of Cranbrook and Sissinghurst is not delivered by large scale housing developments necessitating use of cars to get to employment areas out of the Parish

Suggesting that section 106 monies will help to fund a new Medical Centre is disingenuous as no land has been allocated for this and there is not a proven will from the GP practices to amalgamate in this way. In fact the GP practices are full to capacity and there is a shortage of GPs in West Kent Health Authority

Vision and Objectives 2 1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development.

A developer who has an option on land in the Parish of Cranbrook and Sissinghurst has already stated they will not build towards the aspirational qualities determined by the Parish Council, instead they will build to the much lesser quality determined by TWBC. It is therefore imperative that TWBC raises its standards towards that of Norwich, for example, and aspires to PassivHaus and the race to the bottom of low quality development is halted.

Vision and Objectives 2 To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough.

Building more houses does not make them more affordable. Already many workers in the Parish of Cranbrook and Sissinghurst have to commute from the cheaper areas of the Borough and from outside the Borough, to work

There is a perception that ‘Affordable’ means just that, and this misconception is a reason that there are not many more objections to the scale of housing

Vision and Objectives 2) 8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation

A large scale developer working on land already allocated in Cranbrook stated that they would not be using renewables such as solar energy because this is not economically viable. Or indeed,triple glazing and other basic measures of sustainability. This has not been pursued by the planning department. I have no confidence that the planning department will enforce this aspect of building codes.

There is no mention of an aspiration for local sourcing of all aspects of building materials, including green planting.

Vision and Objectives 1 All developments will be of high quality design, having responded to the distinctive and particular character of their locations: in some instances the development will have taken place within valued and protected landscapes, and this will be recognised in the quality of the design of the development, the protection and enhancement of the exceptional quality of the built, natural, and historic environment, and the provision and protection of landscape features and green spaces. Green, grey, Consultation period: 20 September to 1 November 2019 Tunbridge Wells Borough Local Plan 31 Draft Local Plan (Regulation 18) Consultation Draft and blue infrastructure will be an integral and defining element in the design and layout of new developments

The above statement has not been evidenced by building design such as that at Brick Kiln Farm, Cranbrook, where the developer has paid no attention to the rear elevations of the houses (which residents will see every time they are in their gardens) as it does not ‘affect the street scene’

In fact the first set of proposals had every front door on the entire site, identical which was pointed out by local residents, not the planning department.

This underlines the fact that development, particularly large scale development is taking place in the Borough with very little attention to detail.

DLP_7341

Campaign to Protect Hawkhurst Village

The inherent characteristics of the Borough requires the Council, through the DLP to balance the competing demands of delivery of growth with the protection of the environment.

However, the overall Vision articulated in the DLP fails to place sufficient emphasis on environmental considerations.  It is plainly secondary to growth considerations.

The four specified bullet points all relate to the development side of the balance.

There should be a specific fifth bullet point that articulates that by 2036 the Borough’s valued landscapes (particularly the Green Belt and AONB) will be conserved and enhanced.

This needs to be a specific overarching aspiration in its own right – not purely a qualification to the acceptability of the development proposals.

DLP_7359

Wealden District Council

The vision is considered to provide an ambitious framework for the Tunbridge Wells Borough Local Plan to develop and does provide the spatial context for where the majority of new housing/employment development would take place. As stated elsewhere, the Draft Tunbridge Wells Borough Local Plan seeks to meet the objectively assessed housing needs of the Borough (using the standard methodology in national planning practice guidance) for the plan period that runs from 2016 to 2036, which is ambitious given the recognised constraints of the borough that includes substantial areas of Green Belt and Areas of Outstanding Natural Beauty (AONB). Although parts of the vision do consider the constraints to the Borough, particularly landscape, not all the major constraints to development are described and so it would be helpful to include those within the vision. For example, the Green Belt is not cited within the overall vision, although it covers a significant proportion of the Borough and is included within the strategic objectives described below (page 32 of the draft Tunbridge Wells Borough Local Plan). Similarly, there is no reference to the different types of housing that will be supported through the draft Tunbridge Wells Local Plan that includes affordable housing, student accommodation and older people’s housing and their associated needs, albeit that this is included in the Plan itself and the local evidence base relating to housing need.

DLP_7501

Sarah Parrish

Why build on land next to, and on, Green Belt and floodplains?

Why is there no Flood Risk Assessment?

DLP_7784

Annie Hopper

Vision statement: Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

There is no evidence in the TWBC draft LP that there are any efforts at all to support Rural enterprise in Cranbrook and Sissinghurst.

Given the amount of proposed development in Cranbrook and Sissinghurst Parish it is impossible to believe that natural environments will have been protected and enhanced.

Vision Statement 1 At the heart of all development in the borough will be connectivity, active travel, an appropriate mix of uses and accommodation and, above all, the timely delivery of relevant infrastructure, which will have been funded by development: this infrastructure will have mitigated the impact of development, and, wherever possible, resulted in 'betterment' for existing residents, users, businesses, visitors, etc.

‘Betterment’ for the residents of Cranbrook and Sissinghurst will not be delivered by large scale housing developments. This will only increase the use of cars to nearby stations and to employment areas out of the Parish.

It is hard to understand how infrastructure such as a new medical centre will be funded by section 106 contributions. There is no land allocated for a new medical centre in Cranbrook suggesting that this is an idea only but with no substance. If TWBC really had Cranbrook’s best interests at heart they would have taken the time to listen to local concerns and ideas and collaborated with the NDP steering group to come up with proposals that fulfilled local need and requirements.

Vision and Objectives 2 To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough.

Many workers in the Parish of Cranbrook and Sissinghurst have to commute from the cheaper areas of the Borough and from outside the Borough, to work.

Building more houses will not make housing more affordable.

Vision and Objectives 2) 8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation

This is difficult to take seriously given the amount of housing currently put forward for allocation in the draft LP. The effects of increased cars travelling in and out of the borough will only add to the heavy burden of climate change.

Renewable energy is not something that a large scale developer working on land already allocated in Cranbrook has said they would be using because it is not viable economically. Will the planning department enforce this?

There is no mention of any aspiration for local sourcing of all aspects of building materials.

DLP_7807

John Bancroft

All employment and leisure facilities are Royal Tunbridge Wells centred and residents of new developments at Capel, Tudely, Paddock Wood can easily access them. Plus they have easy access to mainline rail services and improvements to Colts Hill. Yet a high proportion of proposed development is in the east of the Borough where there are high movement problems due to the unsatisfactory nature of the A262 and A268, a lack of bus services (in particular into Tunbridge Wells, see service 297 timetable, where employment and leisure facilities are proposed) and a distant rail station at Staplehurst.

DLP_8278

Ann Gibson

Vision and Objectives 1: All developments will be of high quality design, having responded to the distinctive and particular character of their locations: in some instances the development will have taken place within valued and protected landscapes, and this will be recognised in the quality of the design of the development, the protection and enhancement of the exceptional quality of the built, natural and historic environment and the provision and protection of landscape features an green spaces.

The proposed development by Dandara in AL/CRS 13 shows poorly designed affordable houses, with no chimneys, which are grouped together in a ghetto at the north end of the site instead of being interspersed with the other houses in the development.

It also proposes to remove a large ash tree, on the grounds that it shows some damage, in order to build more houses in its location.  The tree has some damage to it but it is perfectly viable.  There is no reason to cut it down.  The Tree Officer should take an be involved in the decision and preserve it.

DLP_8328

Pam Wileman

TWBC: Comment was submitted on 19/11/19 after close of consultation (on 15/11/19).

Given that the Wealden AONB is recorded as comprising 70% of the borough’s land area, the vision is remarkable for its failure to recognise the importance of preserving its essential character or the borough council’s responsibilities towards it.

The Vision states:-

High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure. The growth of these settlements will have reflected local input and circumstance, including through assessment against neighbourhood plans;

In Hawkhurst it is clear this vision is being ignored as the proposed relief road is clearly not what is needed and the made NDP clearly states that developments must be small with under 10 houses!

DLP_8338

Joe Matthews

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

Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

Having read the plan, I see no efforts at all to support Rural enterprise in Cranbrook and Sissinghurst.

At the heart of all development in the borough will be connectivity, active travel, an appropriate mix of uses and accommodation and, above all, the timely delivery of relevant infrastructure, which will have been funded by development: this infrastructure will have mitigated the impact of development, and, wherever possible, resulted in 'betterment' for existing residents, users, businesses, visitors, etc.

Betterment for the residents of Cranbrook and Sissinghurst is not delivered by large scale housing developments necessitating use of cars to get to employment areas out of the Parish

Suggesting that section 106 monies will help to fund a new Medical Centre is disingenuous as no land has been allocated for this and there is not a proven will from the GP practices to amalgamate in this way. In fact the GP practices are full to capacity and there is a shortage of GPs in West Kent Health Authority

The Strategic Objectives

Comment No.

Name/Organisation

Response

DLP_2006

Dr David Parrish

Strategic Objectives (Section 3) p.32

The release of land from the green belt should not be a strategic objective.

Objective 7 states that TWBC aims to “release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.”

The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. Stating that you have an objective to release land from the green belt (regardless of your judgement that it is appropriate) is contrary to national guidance. Also, in the Introduction (1.6) “Protection of the Green Belt” is a key outcome from your last round of public consultations.

Objective 8 is “to tackle climate change”. Destroying 600 acres of fertile land in Capel, with mature trees and hedgerows in pursuit of the creation of houses will not tackle climate change. Nor will creating a new garden settlement that results in a high level of private car use. The TGV plan does not lead to this objective. The land built on will not let excess storm water flow away – increasing the risk of flooding.

Objective 9 states that TWBC would like to establish garden settlements as a model for the future delivery of development in the borough. There is no evidence that garden settlements lead to any positive outcomes for communities anywhere in the UK. The LP will not be positive for the inhabitants of the Borough of Tunbridge Wells. The residents were never asked if they wanrted a garden village (or town) and have made clear now that they do not want it.

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DLP_8247

Mrs Wendy Coxeter
Mrs Lucy Howells
Sandra Rivers
A & B Cowdery
Mary Jefferies
Mr Peter Jefferies
Diana Robson
Mike & Felicity Robinson
Mr Richard Cutchey
Kristina Edwards
Mr Peter Brudenall
Alistair Nichols
Kevin Conway
Charles Vernede
Mrs Sarah Vernede
Lorraine Soares
May Corfield
Angela Thirkell
Gary Birch
Madelaine Conway
Vivien Halley
Clive Rivers
Linda Beverley
Rosemary Cory
Deborah Dalloway
Mr Simon Whitelaw
Sally Hookham
Gillian Robinson
Paula Robinson
Andrew Roffey
Kylie Brudenall
Victoria Dare
Andrew Hues
Mary Curry
Penelope Ennis
Michael O'Brien
Mr Adrian Cory
Sadie Dunne
Geraldine Harrington
E Leggett
N T Harrington
Rob Crouch
Storm Harrington
B Draper
Nicki Poland
Simon Parrish
Catherine Baker
Patrick Thomson
Sally Thomson
Peter Felton Gerber
Jan Pike

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

Objective 10 is not credible given that TWBC ignores Neighbourhood Development Plans

DLP_2349

Sarah Coulstock

There is too much development in the Local Plan for a rural area with much of it in AONB – TWBC should challenge the housing target it has been given in view of this & get it reduced.

The number of new dwellings proposed for the parish of Brenchley & Matfield is too high. All of proposed development is in Matfield – Brenchley should share the burden & take at least half, especially as has a school, 2 shops, a post office, a doctor’s surgery & a dentist.

The Limits to Build Development should not be changed; it should be strengthened to prevent or severely restrict any more intrusive inappropriate development within the Parish. The dark skies, wildlife, landscape & rural character need to protected against the destruction of the surrounding countryside & the detrimental impact on the High Weald AONB. The amount of development suggested in the AONB is contrary to the objectives of the High Weald AONB Management Plan & the TWBC’s statutory duty to conserve & enhance the High Weald AONB.

The proposed extra housing would put additional pressure on already stretched infrastructure & services, both within the parish of Brenchley & Matfield, & in the borough. I understood that TWBC had previously favoured focused growth in sustainable locations, however, the Local Plan is for dispersed growth in places with poor infrastructure & facilities, which are therefore not sustainable.

The proportional development distribution proposed in the Local Plan is unfairly distributed, with some areas expected to suffer a higher volume of development than is appropriate.

DLP_2353

P K England

Protective designations such as AONB preserve the countryside both now and for future generations. Once lost, the land can never be recovered. The protection provided by these designations should therefore not be eroded. Once this process starts, it is likely to continue. For example, the application already made by Fernham Homes regarding the 'Island Site' argues that relaxations allowed for the adjacent Rydon Homes site should also be applied in their case. Given the scale of the current proposals in the DLP, this is a precedent that should not be allowed to continue. The Council should be seeking to conserve and enhance the natural beauty of the High Weald AONB, not allow it to be degraded.

Matfield is a small village in a rural setting. The proposals to add 'approx. 120 dwellings on four sites' would be an increase of around 30%, all of them in Matfield (none in Brenchley, even though the two villages are grouped together in the DLP). This would undoubtedly be high density development in an existing low density area, and would alter the nature of the existing village.

In addition to the density, the layout of the proposed buildings is not in keeping with the character of the existing village. The original buildings are built along the existing roads, whereas the four proposed new areas effectively add 'housing estate' type layouts spreading out into the countryside on either side of Maidstone Road. This would have an adverse impact on the character of the village in its rural setting. (The style of the proposed buildings and whether they would blend in with the existing is not yet apparent. )

Given the current proposals to relax planning constraints in existing protected areas, what confidence can there be that the 'over 200 Local Green Space designations across many settlements' (under Environment in the LOCAL magazine) will not be similarly affected in the future?

Matfield has very limited infrastructure and amenities, a situation that would be adversely affected by the proposed development.

A major consideration is the road network / vehicular access. The existing Maidstone Road through the village is only wide enough for a single lane of traffic in either direction. The road is already overloaded at times. In particular,

* Traffic flow is affected throughout the day by parked vehicles in the stretch between the butchers and the Poet Public House which forces drivers to queue in either direction. The length of the section of parked vehicles is often sufficient to cause delay and frustration.

* Problems also occur with vehicles parked on the footpaths, either wholly or partly between the village hall and the old cemetery, where the road width is further reduced and on a bend.

* A considerable amount of HGV's pass through Matfield already even though transfessa traffic is not supposed to do so.

* Kippings Cross roundabout is already a bottleneck on the A21 causing substantial delays with traffic also backing up along Maidstone Road.

* There will already be a substantial increase in traffic on Maidstone Road due to the excessive current and proposed house building works in Paddock Wood, both during and after construction. This will be added to by any current and/or additional proposed schemes in Matfield.

* Additional vehicular access onto Maidstone Road from further development would exacerbate the current situation.

Construction is already underway on a number of sites in Paddock Wood and on the Rydon Homes site in Matfield without any preparatory works to the road system. The infrastructure works need to be completed prior to housing development in order to cater for increased traffic from the actual building of the houses, as well as that generated by the new residents when they are occupied.

At this stage, it is not clear how the four sites proposed in Matfield are to be accessed. The location of these access points could have a significant effect on the traffic flows on Maidstone Road, and also in some cases on particular existing residents.

Even if the intention of the DLP is for additional traffic from the major developments in Paddock Wood to use the A228 and a new Colts Hill bypass, some of it will no doubt still travel via Matfield unless it is prevented from so doing. Consideration needs to be given to the traffic through Matfield from surrounding areas, even if none of the sites in Matfield is actually progressed, due to these other additional vehicles.

DLP_2781

Mr Andrew McConnell

In Point 3 of Visions and Objectives it is stated that the objective is to prioritise active travel and to plan for private motor vehicles. This is directly in conflict with the choice of the Misty Meadow AL/AL2 site for development as it is the furthest site from the centre of the village and it’s amenities. It is highly likely that all journeys from this site would be made via private vehicle which cause major impacts on the local environment, local traffic and parking.

In Point 6 of Visions and Objectives it is stated that the objective is to protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for the nature. This again appears to be directly in conflict with the choice of the Misty Meadow AL/AL2 as a site for development. The proposed development is on a pronounced ridgeline, is in conflict with the linear settlement structure of a traditional Wealden village. It is in the middle of an AONB adjacent to agent woodland and will have a massive net loss for nature rather than any kind of gain.

DLP_2967

Michael Alder

Objective 10 is not credible as TWBC continues to ignore the Hawlhurst NDPs. The development proposed is in no way sustainable from either an infrastructure or employment point of view.

DLP_3030

Jacqueline Prance

Too big a site too vague on green belt on AONB

DLP_5991
DLP_7538
DLP_7548
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DLP_7564

Alexander Fisher
William Fisher
Helena Fisher
Richard Fisher
Alexa Fisher

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

Objective 3:Vehicles and pedestrians cannot easily travel from the north side of the proposed Tudeley new town to the south side when there are only 2 points to cross the railway; one a single-track lane (Sherenden Road), the other has a pinch point at the Hartlake Bridge.

Objective 4:It is not possible to build affordable homes in a commuter belt and maintain a carbon neutral ethos. Moreover, there has been no effort to describe what constitutes ‘affordable’, or the cost for the consumer, and it is highly probable the properties will appeal to non-local residents in favour of those who can afford to pay more and commute from the area. Homes should be provided for local people in areas of local need, not the creation of a new commuter town for outsiders.

Objective 6: The heritage of over 70 grade 1 & 2 listed buildings and 2 culturally important churches within the parish of Capel will need protection which will not be possible with the proposed development. This is particularly the case with the Church of All Saints at Tudeley. There is no detail at all on how TWBC will achieve the net gains for nature when TWBC plans to cover up most of the area with housing. This is yet another “we will sort it out later” item, typical of the local plan relating to Capel.

Objective 7: States that TWBC aims to “release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.” The proposed development of Tudeley Town cannot support this claim by the very nature of its prominent location within the middle of the green belt.

Releasing land from the Green Belt should not be a strategic objective.

The NPPF states clearly in paras 133 to 147 that green belt should only be released in exceptional circumstances. Stating that TWBC has an objective to release land from the green belt (regardless of TWBC’s judgement that it is appropriate) is  contrary to national guidance. In the Introduction (1.6) Protection of the Green Belt” is a key outcome from your last round of public consultations. Yet the TWBC plan intends exactly the opposite. Objective 7 should be removed.

The Tonbridge, Sevenoaks and the Maidstone Local Plans do not have objectives which excuse the destruction of the Green Belt, but Tunbridge Wells is peculiarly intent on this, despite large areas of brownfield and non-Green belt and non-AONB land available within the borough.Has proper methodology been used to understand the proper capacity for brownfield sites withn the borough?

Objective 8 is “to tackle climate change”: Destroying 600 acres of good grade 2 & 3 fertile land in Capel, with mature trees and hedgerows in pursuit of the creation of houses will not tackle climate change, in fact it will have a negative impact. Nor will creating a new garden settlement that necessitates a high level of private car use. The objective should stay in, but the proposed developments in Capel should come out as they are intrinsically counter to this stated objective.

Objective 9 states that TWBC would like to establish garden settlements as a model for the future delivery of development in the borough:TWBC fails to articulate the basis for this. This should be removed as it has no basis. There is no evidence that garden settlements lead to any positive outcomes for communities anywhere in the UK. Objectives should have clear goals that can be proven to be positive for the inhabitants of the Borough of Tunbridge Wells, not just headline grabbing  playthings for planners.

DLP_6020

Katherine Wallwork

This is a difficult balancing act. The “disparity between house prices and income” is severe for many, for our own children cannot afford a first home.

Releasing Green Belt land could set a dangerous precedent. This must not be a signal for such land to be released carte blanche across the board.

DLP_6030

Mr C Mackonochie

There is no mention of the timelines of delivery of the infrastructure to mitigate the impact of development. There is no point in promising or delivering infrastructure after development; past developments have demonstrated otherwise

It is worry that mention is made ‘where possible to result in betterment’; this is in contradiction of Vision and Objectives 1 that states it will result in betterment

‘To release land from Green Belt’ - this will lead to coalescence

‘To establish garden settlements as a model for future delivery’ – this is only possible if they have good rail and road links and existing infrastructure including internet and not where the land is offered. Internet is becoming, if not more important, as transport links; existing internet is dire in rural areas – why is no mention made of this

DLP_6096

Christopher Wallwork

Point 8: Any new developments should be required to avoid gas or oil fired heating, with electrically driven heat pump systems preferred.

DLP_6254

Anne Trevillion

The Strategic Objectives do not seem to adequately address the issues of affordability of housing. ‘Seeking to redress’ is not sufficient. You can decide to actively redress the disparity between house prices and income by building council housing for rent only. You can place some rent controls on private landlords and make sure homes are set aside for people who work in the borough, not sold to commuters moving out of London.

I support the need to prioritise active travel. Urgently.
The amenities supporting the cultural richness of the borough need to be shared – not concentrated solely in Tunbridge Wells and Southborough.

We know that homes are going to need to stop using gas boilers, if we are to avert a climate catastrophe. Why are new homes being built without solar panels, or other form of renewable energy technology, and with gas boilers?

Where in the Local Plan is any effort to improve the energy efficiency of the current housing stock?

DLP_6316

Susan Heather McAuley

1 - There is nothing I can see here that is ‘plan-led’.  The sites for building have been identified by asking people if they want to sell their gardens and land.  This is not planning.  Planning would say this village needs 6-10 bungalows in a central location, 6-10 starter homes nearer the edge of the village and space for 3 business units on a local farm. You mention compulsory purchase so for example in Sissinghurst why not make a compulsory purchase of Collins Farm yard (no longer used as a farmyard) and put bungalows there.  It seems to me that would be a plan-led approach.  This Local Plan is opportunistic and takes the easy option at every turn.

2 – Deliver infrastructure by relying on builders – when has that happened in the Borough? An extra bus for twelve months and a few additional library books for Sissinghurst from the recently built estate of 60 houses around £500,000 each?

3 – Active travel or cars and new technology?  Active travel does not work when you have to get from Sissinghurst to Tunbridge Wells and even electric cars cause traffic jams.  Putting in charging points will not help people afford new electric cars.  The Plan mentions elsewhere shared bike schemes – at the moment I am not sure how this will help new residents of Sissinghurst get to work when you propose the majority of the employment will be in Tunbridge Wells.

4 – A Strategic objective needs detailed actions as to how it will be achieve – how does the Borough intend to bring house prices down?

6 – this is not aligned with what is being proposed for the villages in the Borough.

7 – this point again mentions a ‘plan-led approach’ and I make the same comment – that this Local Plan does not have planning at its heart.

8 – I ask again HOW? I cannot see that this objective has any detailed actions to make it happen.

9 – this Plan proposes vastly increasing the size and character of several Wealden villages – it does not rely on garden villages for future development.

10 – I believe the locally-led policies from the Cranbrook and Sissinghrust NDP have not been included in this Local Plan.

DLP_6605

Geoffrey Collins

Protective designations such as Areas of outstanding Natural Beauty (AONB) preserve the countryside both now and for future generations. Once lost, the land can never be recovered. The protection provided by these designations should therefore not be eroded. Once this process starts, it is likely to continue. For example, the application already made by Fernham Homes regarding the 'Island Site' argues that relaxations allowed for the adjacent Rydon Homes site should also be applied in their case. Given the scale of the current proposals in the Draft local Plan (DLP), this is a precedent that should not be allowed to continue. The Council should be seeking to conserve and enhance the natural beauty of the High Weald AONB, not allow it to be degraded.

Matfield is a small village in a rural setting. The proposals to add 'approx. 120 dwellings on four sites' would be an increase of around 30%, all of them in Matfield (none in Brenchley, even though the two villages are grouped together in the DLP). This would undoubtedly be high density development in an existing low density area, and would alter the nature of the existing village.

In addition to the density, the layout of the proposed buildings is not in keeping with the character of the existing village. The original buildings are of linear construction following the existing roads, whereas the four proposed new areas effectively add ‘housing estate' type layouts spreading out into the countryside on either side of Maidstone Road. This would have an adverse impact on the character of the village in its rural setting. (The style of the proposed buildings and whether they would blend in with the existing is not yet apparent. )

Given the current proposals to relax planning constraints in existing protected areas, what confidence can there be that the 'over 200 Local Green Space designations across many settlements' (under Environment in the LOCAL magazine) will not be similarly affected in the future?

Matfield has very limited infrastructure and amenities, a situation that would be adversely affected by the proposed development. The Doctors based in Brenchley, Pembury and Paddock wood are already close to capacity. The primary School in Brenchley is already oversubscribed with many of the attendees travelling from adjoining villages which already causes traffic issues on the Brenchley Road in the morning and afternoon.

A major consideration is the road network / vehicular access. The existing Maidstone Road through the village is only wide enough for a single lane of traffic in either direction. The road is already overloaded at times. In particular,

* Traffic flow is affected throughout the day by parked vehicles in the stretch between the butchers and the Poet Public House which forces drivers to queue in either direction. The length of the section of parked vehicles is often sufficient to cause delay and frustration.

* Problems also occur with vehicles parked on the footpaths, either wholly or partly between the village hall and the old cemetery, where the road width is further reduced and on a bend.

* A considerable amount of HGV's pass through Matfield Village already accessing local farms, Fruit Packing facilities and Storage and Distribution Sites.

* Kippings Cross roundabout is already a bottleneck on the A21 causing substantial delays with traffic also backing up along Maidstone Road in the morning from 07:30 on occasions traffic queue’s back as far as St Lukes Church.

* There will already be a substantial increase in traffic on Maidstone Road due to the excessive current and proposed house building works in Paddock Wood, both during and after construction. This will be added to by any current and/or additional proposed schemes in Matfield.

* Additional vehicular access onto Maidstone Road from further development would exacerbate the current situation.

* Oakfield Road is built with a simple single road access into the development. Previous Applications for modifications and construction have been denied based on insufficient vehicular access and in particular road width as there is limited off road parking available to residents. Using this road as access can only end up in causalities as the demographics of the road mean that a high percentage of the residents are elderly.

Construction is already underway on a number of sites in Paddock Wood and on the Rydon Homes site in Matfield without any preparatory works to the road system. The infrastructure works need to be completed prior to housing development in order to cater for increased traffic from the actual building of the houses, as well as that generated by the new residents when they are occupied.

At this stage, it is not clear how the four sites proposed in Matfield are to be accessed. The location of these access points could have a significant effect on the traffic flows on Maidstone Road, and also in some cases on particular existing residents.

Even if the intention of the DLP is for additional traffic from the major developments in Paddock Wood to use the A228 and a new Colts Hill bypass, some of it will no doubt still travel via Matfield unless it is prevented from so doing. Consideration needs to be given to the traffic through Matfield from surrounding areas, even if none of the sites in Matfield is actually progressed, due to these other additional vehicles.

DLP_6634

Nicholas Fisher

Objective 3:Vehicles and pedestrians cannot easily travel from the north side of the proposed Tudeley new town to the south side when there are only 2 points to cross the railway; one a single-track lane (Sherenden Road), the other has a pinch point at the Hartlake Bridge.

Objective 4:It is not possible to build affordable homes in a commuter belt and maintain a carbon neutral ethos. Moreover, there has been no effort to describe what constitutes ‘affordable’, or the cost for the consumer, and it is highly probable the properties will appeal to non-local residents in favour of those who can afford to pay more and commute from the area. Homes should be provided for local people in areas of local need, not the creation of a new commuter town for outsiders.

Objective 6: The heritage of over 70 grade 1 & 2 listed buildings and 2 culturally important churches within the parish of Capel will need protection which will not be possible with the proposed development. This is particularly the case with the Church of All Saints at Tudeley. There is no detail at all on how TWBC will achieve the net gains for nature when TWBC plans to cover up most of the area with housing. This is yet another “we will sort it out later” item, typical of the local plan relating to Capel.

Objective 7: States that TWBC aims to “release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.” The proposed development of Tudeley Town cannot support this claim by the very nature of its prominent location within the middle of the green belt.

Releasing land from the Green Belt should not be a strategic objective.

The NPPF states clearly in paras 133 to 147 that green belt should only be released in exceptional circumstances. Stating that TWBC has an objective to release land from the green belt (regardless of TWBC’s judgement that it is appropriate) is contrary to national guidance. In the Introduction (1.6) “Protection of the Green Belt” is a key outcome from your last round of public consultations. Yet the TWBC plan intends exactly the opposite.

Objective 7 should be removed.

The Tonbridge, Sevenoaks and the Maidstone Local Plans do not have objectives which excuse the destruction of the Green Belt, but Tunbridge Wells is peculiarly intent on this, despite large areas of brownfield and non-Green belt and non-AONB land available within the borough.Has proper methodology been used to understand the proper capacity for brownfield sites withn the borough?

Objective 8 is “to tackle climate change”: Destroying 600 acres of good grade 2 & 3 fertile land in Capel, with mature trees and hedgerows in pursuit of the creation of houses will not tackle climate change, in fact it will have a negative impact. Nor will creating a new garden settlement that necessitates a high level of private car use. The objective should stay in, but the proposed developments in Capel should come out as they are intrinsically

counter to this stated objective.

Objective 9 states that TWBC would like to establish garden settlements as a model for the future delivery of development in the borough:TWBC fails to articulate the basis for this. This should be removed as it has no basis. There is no evidence that garden settlements lead to any positive outcomes for communities anywhere in the UK. Objectives should have clear goals that can be proven to be positive for the inhabitants of the Borough of Tunbridge Wells, not just headline grabbing playthings for planners.

Comments on Section 4 Paragraph 4.16 (The Development Strategy) p.35

TWBC has been given a housing need figure of 13,560.

TWBC has taken the housing need figure of 13,560 and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. It is also commonly known these numbers will be massively downscaled as they were based on false projections. The numbers from ONS 2016 show a smaller demand.

The Ministry of Housing, Communities and Local Government have repeatedly made clear via their Ministers and the Secretary of State for Housing that ““the housing need figure is not a mandatory target. Local Authorities should make a realistic assessment of the number of homes their communities need, using the standard method as the starting point in the process. Once this has been established planning to meet that need will require consideration of land availability, relevant constraints and whether the need is more appropriately met in neighbouring areas... The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process. Last year we strengthened Green Belt policy in the revised NPPF”.

It should be the mission of TWBC to protect the borough from the destruction of Green Belt and AONB by following NPPF guidelines.

The NPPF para 11(b) says “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or

ii. Any adverse impact of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework when taken as a whole”.

The NPPF makes provision for TWBC to have a choice in the provision of the objectively assessed 13,560 houses. If provision of these houses is really only possible by sacrificing Green Belt land then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so. Reduce the number of houses delivered by the Local Plan.

Comments on Section 4 Paragraph 4.38 (The Development Strategy) p.39

TWBC is proposing a development strategy based on dispersed growth, i.e. proportional distribution of development across all of the borough’s settlements. You imply that you have achieved this but this is misleading. The Local Plan is almost entirely dependent on the successful implementation of a proposed garden settlement in Tudeley and the expansion of Paddock Wood including building on East Capel. They form 63% of the new

housing. If these sites fail to deliver then the associated infrastructure that is entirely reliant on developer capital would also never be realised. This appears to stack risk on risk, where both areas of development are inextricably linked and the failure of one would lead to collapse of the other and as a result the whole plan would fail.

Comments on Section 4 Paragraph 4.40 (The Development Strategy) p.39

You refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is apparent from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. I fear TWBC want to flood Tudeley and East Capel with housing until it coalesces with Tonbridge and Five Oak Green and coalesces Five Oak Green and Paddock Wood, ultimately creating a massive conurbation from Tonbridge to Paddock Wood.

You used NDAs to hide your plans until it was too late for residents to have a fair say. The Local Plan gives TWBC an excuse to dump its housing needs on green fields and meadows to pollute and clog up rather than addressing the needs of their residents and spreading development across the borough on brownfield sites or placing the garden settlement in the middle of the borough, to make it accessible north and south. The developments in Tudeley and East Capel are unsustainable, do nothing for local employment needs and it is totally counterproductive to put affordable housing right at the very north of the borough when so many residents live in the south of the borough.

DLP_6748

Mrs Carol Richards

Vision and Objectives 2 – Strategic Objectives (yellow box)

The statement at point 6,’to protect the valued heritage’ .. ‘and natural environment’.

TWBC will not be protecting the flood plain below Tudeley and will ruin the setting for the church and the Green Belt.

The statement at point 7 states that TWBC aims to “release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.”

Releasing land from the green belt should not be a strategic objective. This statement is particularly ironic as only last year, 31st July to be precise TWBC refused planning permission on a minor development to the Poacher Pub, Tudeley (a thriving business). Referencing Application Ref:18/01767/Full.

The refusal was on the grounds of and I quote,’ the proposal would constitute inappropriate development within the Metropolitan Green Belt which by definition is harmful to its openness’. It continues to state,’ there is insufficient evidence of the necessary ‘very special circumstances’ to overcome this harm. It further states, ’it would not conserve and enhance the rural landscape, nor would it protect the countryside for its own sake, nor preserve the interrelationship between the natural and built features of the landscape’.

The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. Stating that you have an objective to release land from the green belt (regardless of your judgement that it is appropriate) is contrary to national guidance and is contrary to your own guidance which was being handed out in July last year!!!!!!!!!!!!!!! TWBC also state that building one building with 6 bedrooms ‘would have more than minimal impact on the landscape character of the locality’.

The double standards of TWBC is clear for all to see. When it suits TWBC their Local Plan is a law unto itself. They refused one building with 6B&B rooms associated with an existing building, BUT TWBC are able to propose 1,900 homes!!!!!!!!!..... And a further 1000 to boot!!!!!!!!!!!!!.... Within yards of the pub.

The impact of this number of homes could be classified as more than ‘minimal’. Catastrophic and utterly inappropriate would be more accurate. The ridge of housing will be visible for miles around and an eyesore on the landscape.

The statement at point 8 is “to tackle climate change and minimize the impact of development on communities.’

The proposal to destroy 600 acres of fertile highgrade farmland in Capel, with mature trees and hedgerows in pursuit of the creation of houses will not tackle climate change. Nor will creating a new garden settlement that results in a high level of private car use. It will not minimize the impact on the community of Tonbridge- it will create a crisis for its residents.

Point 9 states that TWBC would like to establish garden settlements as a model for the future delivery of development in the borough. As I believe Tudeley is so unsuitable this statement begs the question where else are TWBC thinking of- maybe this would be more appropriate??

Point 10 TWBC states about’ locally led policies’ and yet in the Introduction (1.6) -“Protection of the Green Belt” was a key outcome from your last round of public consultation. If you are using green belt land in your strategy, this statement is not true, as TWBC are clearly going against ‘locally led policies’

The building of this number of homes will have the opposite effect of reducing the impact of climate change. Climate change will be producing warmer wetter winters and hot dry summers. This will mean that in the winter hard standing will create more run off into the valley. The valley that is between Tudeley and Golden Green is the floodplain for the river Medway. In winters e.g. like 2013/4 the runoff will be faster and the consequences downstream in East Peckham, Yalding and Maidstone will be of greater volume than that experienced in 2013/4. This is because, at the moment, some water is absorbed by the soil. This will not happen when this area is covered by houses and driveways. This plan will put the houses in the valley at greater risk of flooding and those downstream. A plan that puts houses at greater risk from flooding is a flawed plan and immoral. Rethink this plan it has been poorly thought out and has harmful consequences to both people and the environment. It is totally unsound. I object strongly when TWBC PLAN to flood homes. SuDS no matter how many you propose will not solve this issue.

DLP_6943

Hallam Land Management Ltd

‘Good growth’ in the context of Tunbridge Wells Borough would, in our opinion, be growth that meets in full the identified / required needs for development, particularly the needs for housing and affordable housing (as required by paragraph 11 of the NPPF 2019), in a way that has regard to the relative sustainability of the various settlements and the constraints that exist in the borough. These constraints include, most notably, the significant area of land within the High Weald Area of Outstanding Natural Beauty (AONB) across 70% of the borough, the area of Green Belt to the west of the borough.

The housing distribution strategy within the Draft Local Plan is key in helping to support a thriving local economy. A strategy which focuses appropriate levels of housing at the identified sustainable settlements, importantly, the Small Rural Towns and above, will help to ensure that the economy in the borough is supported as additional housing brings with it additional residents, which in turn generates additional expenditure in the local economy and achieving sustainable development.

DLP_7415

Andrew Dewdney

TWBC should challenge the housing targets set for it by Central Government. The standard methodology, using 2014 data and has ignored the Office for National Statistics 2016 forecast, which would reduce the National housing needs figure from 300,000 per annum to 160,000.  TWBC has not complied with its NPPF requirements to examine reasonable alternatives by using more recent data.  Rather than allowing developers to cover the borough with 4 bedroom detached houses at £500-£600k per unit, the draft plan seeks to find ways to accommodate central and out of date housing requirements imposed by government and not address the real housing needs of the borough – which is for affordable and social housing.

TWBC has chosen to base the housing need calculation for the Borough on the “standard method” using the 2014 base figure of 484 homes.  In addition to this TWBC has added an arbitrary 40% more homes per annum to get to its figure of 678 homes.  What is the justification for this 40% increase.  I can’t find it in any of the 500+ pages of the draft but again, it is evidence that the Council and its officers have not complied with their duties to develop this plan under the NPPF guidelines.  Why impose an arbitrary 40%  increase over the base housing need figure – why not 10% or 100%.  Because the 40% increase gets TWBC to its government quota. It can’t be justified in any other way.

This falsely derived housing requirement has an alarming distorting impact on the Local plan and distorts policy intentions.

I am totally opposed to the construction of a policy framework based on unsound housing targets, which, if approved and pursued, will cause irreversible damage to the landscape and habitats (including harm to wildlife) throughout the borough – espexially in the regions surrounding Paddock Wood and Tudely.

TWBC should not seek to use falsely derived housing targets to justify building on AONB and Greenbelt land, nor claim that it is necessary or unavoidable.

DLP_7700

Alison Nicholls

P4. To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough.

I acknowledge and welcome the intention to boost the supply of affordable housing. I would urge that this be done to allow people with a proven link or connection to the parish of Cranbrook and Sissinghurst who perform critical work (teachers, firefighters etc) to have the possibitlity of living where they have grown up, have family and/or where they work. I believe the proven link to the parish is critical to enhance the community feeling and to avoid the ridiculous situation where such people are forced to live elsewhere because of cost and commute into the town on traffic heavy roads.

DLP_7798

Robert Saunders

The vision and objectives refer to ‘betterment’ for existing residents – but the plan does not outline how the increased road traffic associated with 900 additional homes will be accommodated or mitigated: the local road network already suffers considerable congestion: for example, to travel the 10.7 miles to the Blue Boys Roundabout typically takes 30 minutes. Staplehurst and Marden station car parks already operate at capacity on peak days.  The plan makes no mention of increase health provision. Given these constraints, its difficult to see how the additional development will result in anything other than detriment.

DLP_7808

Mr Colin Sefton

I support the “gist” of the Strategic Objectives, but consider that these would be much better if they had target numbers – e.g. for #4:-

“To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough.

add a number of affordable houses with a timescale.  [Apologies if the target numbers already appear in another section].

DLP_7837

Andrew Chandler

I support the Strategic Objectives, particularly 6 (protect the valued heritage, and built and natural environments of the borough) and 10 (locally led policies).

DLP_8143

Ashley Saunders

I object to the inclusion of following strategic objectives

  1. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature.
  2. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.
  3. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation.
  4. To establish garden settlements as a model for the future delivery of development in the borough.
  5. To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications

Objective 6

Whilst Objective 6 is a laudable objective, it cannot be achieved by the current Draft Local Plan as too many policies are in direct conflict with it. In fact, these two objectives are clearly in direct conflict with one another – No.6. cannot be achieved alongside No. 7. It should not be an objective of any Draft Local Plan to release land from the Green Belt WHEN APPROPRIATE ALTERNATIVE LAND IS AVAILABLE.

The following policies should be removed from the Draft Local Plan to enable this Objective to be met:

AL / CA 1; AL / CA 2: AL / CA 3 & AL / PW 1; TP 6

Objective 7

Objective 7 should be removed as releasing land from the Green Belt should not be a strategic objective of the dLP.

The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. Stating that you have an objective to release land from the Green Belt (regardless of your judgement that it is appropriate) is contrary to national guidance.

Also, in the Introduction to the dLP at paragraph 1.6, it is stated that “Protection of the Green Belt” is a key key issue/concerns highlighted through the Issues and Options consultation.

There would be no need to remove Green Belt land if the Council had adopted the other options that it had before it; where are plans here to increase public accessibility or protect the openness of the remaining green belt? Unlike Tonbridge and Malling, TWBC has no plans to replace the lost Green Belt suggesting it places a low value on this form of designation. It clearly has also concluded that replacement land (originally mooted to the south and east of Paddock Wood) would not serve the same purpose as the two lost sections which prevent the convergence of settlements between Five Oak Green, Tonbridge and Paddock Wood.

I strongly urges the council to remove this objective.

Objective 8

Destroying 600 acres of fertile land in Capel, with mature trees and hedgerows in pursuit of the creation of houses will not tackle climate change. Nor will creating a new garden settlement that results in a high level of private car use. The proposal for development in the MGB East Capel and Tudeley scores negatively for climate change in the SA and does not back up this objective or the council’s wider policy on carbon neutrality adopted only a few weeks ago.

The following policies should be removed from the Draft Local Plan to enable this Objective to be met:

AL / CA 1; AL / CA 2: AL / CA 3 & AL / PW 1; TP 6

Objective 9

Where is evidence that garden settlements lead to any positive outcomes for communities anywhere in the UK?  Objectives should have clear goals that can be proven to be positive for the residents of Tunbridge Wells Borough and Capel Parish. This may be a passing fashion in planning policy that will disappear, and this approach may lead to future developments outside the LBD’s in the green belt and the AONB which will destroy the rural nature of the borough outside RTW.

I urge the council to remove this objective.

Objective 10

Tunbridge Wells Borough Council only made attempts to work with Capel Parish Council (in lieu of a neighbourhood planning group) after the strategic sites in Capel Parish had already been determined. Policies AL / CA 1; AL / CA 2: AL / CA 3 & AL / PW 1; TP 6 will have a huge impact on our residents and are NOT locally led. Any future planning decisions in Capel Parish will be dwarfed by the impact of the dLP, making the role of neighbourhood planning peripheral at best.

The following policies should be removed from the Draft Local Plan to enable this Objective to be met:

AL / CA 1; AL / CA 2: AL / CA 3 & AL / PW 1; TP 6

Once the above Policies have been removed from the dLP TWBC will be in a position to meet this objective by working with Capel Parish Council and/or Capel Parish Neighbourhood Plan Groups to formation policies which can be truly locally-led.

DLP_8212

Mrs Suzi Rich

I object to the inclusion of following bullet points:

6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature.

7. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.

Whilst they are laudable objectives, they cannot be achieved by the dLP as too many policies are in direct conflict with them. In fact, these two objectives are clearly in direct conflict with one another – No.6. cannot be achieved alongside No. 7. It should not be an objective of any Draft Local Plan to release land from the Green Belt simply to meet housing need, particularly where appropriate land is available elsewhere.

The following policies should be removed from the Draft Local Plan to enable this Objective to be met: AL / CA 1; AL / CA 2: AL / CA 3 & AL / PW 1; TP 6

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

DLP_8279

Ann Gibson

4.18 The ENS recommended that the Council should allocate sites to accommodate at least

14 hectares of new employment land (taking into account any residual capacity of existing employment allocations) to 2035 in order to support the creation of new employment opportunities alongside the provision of new housing, helping to reduce out-commuting from the borough over the plan period.

There are no new employment opportunities planned alongside the provision of new housing in Cranbrook and Sissinghurst.  The only employment created will be short-term during construction.  This will mean that at least 50% of the new residents will be out-commuting.  TWBC has no say in whether there will be an expansion of the car parking at Staplehurst Station to accommodate the increased number of cars that will be engendered.

DLP_42

Thomas Weinberg

Comments on the Strategic Objectives (Section 3) p.32

In the Introduction (1.6) “Protection of the Green Belt” is a key outcome from your last round of public consultation. However Objective 7 makes a fundamental category error: by stating TWBC aims to “release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.” It declares releasing land from the green belt to be a strategic objective.

The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. Stating that you have an objective to release land from the Green Belt is directly against national policy.

Objective 7 should be removed.

The Tonbridge Local Plan, the Sevenoaks Local Plan and the Maidstone Local Plan do not have objectives which excuse the destruction of the Green Belt. Why is TWBC so eager to vandalise protected rural areas?

Objective 9 states that TWBC would like to establish garden settlements as a model for the future delivery of development in the borough.

Objective 9 should be removed. There is no evidence that garden settlements lead to any positive outcomes for communities anywhere in the UK.

Objective 8 is “to tackle climate change”. This is bizarre. Destroying 600 acres of fertile land in Capel, with mature trees and hedgerows in pursuit of the creation of houses will not tackle climate change. Nor will creating a new garden settlement that results in a high level of private car use.

Given the current focus on the environment and climate change, to suggest destroying Green Belt to build houses and claim this will tackle climate change is absurd and contradictory.

Keep Objective 9 and actually act on it in good faith.

 

DLP_85

Roger Bishop

Vision and Objectives 2 – p32

Objective 6 is “To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature”.

Again, see above, it is difficult to see how these objectives are in any way compatible with getting rid of large swathes of Green Belt, and surrounding a national heritage site (Tudeley church is the only working parish church in the world with all of its windows by the renowned Marc Chagall) with houses or commercial buildings. You have failed to show how the Plan complies with the NPPF, which states (Para 194), “Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification”.

The site of Tudeley New Town is unsuitable for a new settlement. It has a major railway line running through the middle of it, so the settlement can never be a united one. It will be two settlements, making it well short of being a poster boy for so called garden settlements. Objective 7 states that TWBC aims to “release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.” But a strategic objective to release land from the Green Belt is at odds with the NPPF. This makes clear, in paragraphs 133 to 147, that Green Belt should be released only in exceptional circumstances. I have seen no claim in the planning documents that exceptional circumstances pertain to either Tudeley New Town or East Capel. Indeed, I understand that CPRE have made plain only recently that housing need is not able to be used as “exceptional circumstances” to overrule AONB/Green Belt.

The NPPF states (para 137) that before changes to Green Belt boundaries are proposed, councils should examine fully all other reasonable options, make as much use of brownfield as possible, optimise the density of development and instigate discussions with neighbouring authorities. Such a stance has been repeated and clarified further by Government ministers. Jake Berry (Minister DHCLG) stated in April 2019 that: “The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process. Last year we strengthened Green Belt policy in the revised NPPF”. (My emphasis)

Brandon Lewis (Housing Minister in 2015) stated that “maintaining strong protection for the Green Belt is national policy and that local authorities are required to observe this. In the context of planning applications or appeals, the policy is that unmet housing need alone will not amount to the “very special circumstances” to justify planning permission for inappropriate development on Green Belt. We have repeatedly made clear that demand for housing alone will not change Green Belt Boundaries.” (My emphasis)

Releasing Green Belt is at odds with a key outcome of your last round of consultation (noted in the introduction to the plan) which was “Protection of the Green Belt”. Should TWBC fear any repercussions from not releasing Green Belt land to meet a (flawed) housing need, they need only consider the words of Sajid Javid in 2018. He said, “Planning Inspectors cannot enforce Green Belt releases onto authorities”.

I understand that the Local Plans of Tonbridge, Sevenoaks and Maidstone do not have objectives which excuse the destruction of the Green Belt. I am puzzled why TWBC have chosen an alternative stance.

TWBC’s information boards at the public exhibition on the plan at Capel Village Hall on 21 September 2019 contained severa l statements that are at odds with the Plan (my emphasis below):

“Green and open spaces are important and as the population in the borough increases, their importance will also increase. These areas must therefore be safeguarded….”

“New positive approach to biodiversity, including principle of net gains”. Policies EN11 to 15

“Wide ranging recognition of landscape quality…”. Policy EN18 to 21

“Net gains for nature must be achieved in all new development….”

“There is now scope to ensure that Local Green Spaces demonstrably special to local communities are protected”.

Also, the Limits to Built Development Topic Paper (August 2019) states (my emphasis):

2.1. Limits to Built Development (LBDs) are used to differentiate between the built up areas of settlements and areas of countryside beyond. Generally, and subject to compliance with other policies in this Plan, there will be a presumption that the principle of proposed development such as infilling, redevelopment, and/or changes of use will be acceptable inside the LBD, while land and buildings outside the LBD will be considered as countryside where there is much stricter control over development.

2.2. The definition of LBDs is an established policy tool to provide both certainty and Clarity…on where new development would generally be acceptable in principle. By drawing LBDs around settlements (including land to meet growth needs), LBDs help focus growth to sustainable locations/settlements, while protecting the surrounding, more rural areas from inappropriate and intrusive development.

6.1. The existing LBDs (in the 2006 Local Plan and Site Allocations Local Plan 2016) have been reviewed to take account of the need for further development across the borough in line with the Council’s emerging growth strategy in Section 4 of the Draft Local Plan and to ensure features that define the LBD have not changed and remain current and relevant. The current policy stance, set out in Policy LBD1 of the Local Plan 2006, seeking to focus development in sustainable locations i.e. around existing settlements and site allocations, and as also more recently advocated in the NPPF, has been taken forward into the proposed LBD policy for the Draft Local Plan…

6.3. The inclusion of land within the LBD does not automatically indicate that it would be suitable for development. Other considerations, such as retaining open spaces, areas at risk of flooding or the setting of heritage assets or other features that contribute to local distinctiveness may mean that a particular development proposal is inappropriate.

Objective 8 is “to tackle climate change”. Building on 600 acres of agricultural land in Capel, and destroying mature trees and hedgerows is at odds with this, as is the huge increase in private cars on local roads to which the planned developments will give rise.

In Tunbridge Wells Local magazine in September 2019, under the headline “Tunbridge Wells Borough Council has joined the growing list of councils who have declared a climate emergency”, it is reported that members are looking “at ways in which the Council can reduce carbon emissions and make a contribution to combating climate change, including ensuring that forthcoming plans and strategies (including the new Local Plan) take account of this”. The planned developments are inconsistent with that.

[TWBC: see also Comment Numbers DLP_81 to 93].

 

DLP_124

Gregg Newman

Comments on the Strategic Objectives (Section 3) p.32

The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances.

Your stated objective is to release land from the green belt.

Please explain how this fits with the need for “exceptional circumstances”.

Neighbouring Councils, under The Tonbridge Local Plan, the Sevenoaks Local Plan and the Maidstone Local Plan do not have objectives which excuse the destruction of the Green Belt.

It is cynical in the extreme to be flying in the face of this in an area which is so far removed from Tunbridge Wells residents as to make it highly unlikely that they would even be aware of it, let alone object, whilst TMBC residents are having to “enter through the back door” to have their voices heard.

Objective 8 is “to tackle climate change”.

As noted above, concrete and tarmac do not tackle climate change. Trees and bees do.

The plan will result not only in the destruction of 600 acres of fertile land in Capel, with mature trees and hedgerows but will also add around 9,000 vehicles at least, with all the dire consequences that come from these.

Objective 8 is laudable – the Capel plan flies in the face of this in a  most immoral way.

 

DLP_527

Mr Neil Franklin

Nationally, excessive housebuilding is only needed because of government policy.

There is too much focus on developing/urbanising the south-east and Kent in particular.

Locally, the government is forcing excessive numbers of houses on to TWBC unless the intention is for large scale migration from other areas.  It would be totally unacceptable for another local authority to purchase or rent houses locally to solve their own housing shortages here.  Whatever happened to quality of life (especially for the people already living in the area)?  “Love where you live” is rather a forlorn hope.

Any extra housebuilding in the areas to the east or north-east of TW will only funnel more traffic bound for TW on to the A264/A228 Pembury Road which is already overloaded with queues much of the day.  The proposed Motor Village would make things even worse. Solving the problems of this road must be high on any list of priorities for infrastructure needing putting in place.

 

DLP_853

Ian Pattenden

Comments on the Strategic Objectives (Section 3) p.32

Objective 3: vehicles and pedestrians cannot easily travel from the north side of the proposed Tudeley New Town to the south side when there are only 2 points to cross the railway; one a single-track lane (Sherenden Road), the other has a pinch point at the Hartlake Bridge.

Objective 4: It is not possible to build affordable homes in a commuter belt and maintain a carbon neutral ethos. Developers will pay lip service to the requirement and then make excuses that they cannot complete their obligations and sell the houses at the going rate “due to commercial pressures”.

Moreover, there has been no effort to describe what constitutes ‘affordable’, or the cost for the consumer, and it is highly probable the properties will appeal to non-local residents in favour of those who can afford to pay more and commute from the area.

Objective 6: The heritage of over 70 grade 1 & 2 listed buildings and 2 culturally important churches within the parish of Capel will need protection which will not be possible with the proposed development. Furthermore there is no detail at all on how you are going to achieve the net gains for nature when you plan to cover up most of the area with housing. This is yet another “we will sort it out later” item, typical of the local plan relating to Capel.

Objective 7: states that TWBC aims to “release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.” The proposed development of Tudeley Town cannot support this claim by the very nature of its prominent location within the middle of the green belt.

Releasing land from the green belt should not be a strategic objective.

The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. Stating that you have an objective to release land from the green belt (regardless of your judgement that it is appropriate) is contrary to national guidance.

Also, in the Introduction (1.6) “Protection of the Green Belt” is a key outcome from your last round of public consultations. Yet the TWBC plan intends exactly the opposite.

Objective 7 should be removed.

The Tonbridge, Sevenoaks and the Maidstone Local Plans do not have objectives which excuse the destruction of the Green Belt, but Tunbridge Wells is peculiarly intent on this, despite large areas of brownfield and non-Green belt and non-AONB land available within the borough. 

Objective 8 is “to tackle climate change”. Destroying 600 acres of good grade 2 & 3 fertile land in Capel, with mature trees and hedgerows in pursuit of the creation of houses will not tackle climate change, in fact it will have a negative impact. Nor will creating a new garden settlement that necessitates a high level of private car use. The objective should stay in, but the proposed developments in Capel should come out as they are intrinsically counter to this stated objective.

Objective 9 states that TWBC would like to establish garden settlements as a model for the future delivery of development in the borough, but they fail to articulate the basis for this. This should be removed as it has no basis. There is no evidence that garden settlements lead to any positive outcomes for communities anywhere in the UK. Objectives should have clear goals that can be proven to be positive for the inhabitants of the Borough of Tunbridge Wells, not just headline grabbing playthings for planners.

 

DLP_1368

Mr and Mrs Leach

Re: Draft Local Plan (Regulation 18 Consultation) - Adjoining Resident Comment

It was good to meet you at the SaveCapel Public Meeting, on 18th September 2019.

We wish to comment on the Draft Local Plan (LP), in relation to certain policies outlined under the headings stated below. We are specifically concerned about the negative impacts of the proposed garden villages will have to our town, especially without adequate public transport provisions, and with such a large loss of the countryside and Green Belt.

1.11 Our points in relation to Vision and Objectives 2 are as follows:

a. We agree with the majority of these strategic objectives. However, we disagree with Objective 9 that proposes garden settlements as a model of future development. We are of the opinion that this Objective should be removed, as rural garden settlements rarely deliver sustainable developments; especially where there are limited employment opportunities and a lack of public transport options available. Also, with reference to Sir Letwin's (2018) review2, the average build-out "for sites over 1,000 homes is 15.5 years". This lengthy build out period is in part due to local market saturation of new homes. Thus, it would be better to disperse the new housing across the Borough rather a local area with c.6,000 houses.

b. We also believe that some of the other crucial Objectives are incompatible with the proposed rural garden settlements. For instance, Objective 8 aims to tackle climate change. We are not sure how destroying 600 acres of fertile land in Capel, containing small woods and hedgerows; replacing it with settlements built from energy intensive, man-made materials and hard surfacings, which will in part be occupied by commuters reliant on private cars, will help tackle climate change.

c. Furthermore, to help reduce the development congestion impacts and in light of the Governments new goal of achieving net zero emissions by 2050; we must avoid taking forward poorly planned and unsustainable developments, such as the proposed Tudelely village. As the development effectively promotes private car use and fails to meet its new needs, with the limited employment and transport options. This would significantly increase congestion; with the adverse effects outlined in 1.11d and will create more parking issues in Tonbridge, especially near the station.

d. Objective 8 also aims to minimise the development impact on communitiesm, the economy and environment. However, the current rural garden village proposals are likely to cause immense harm to all three, especially in Tonbridge that appears to have had little consideration in this draft Plan, with some of the issues listed below:

i. Communities - potential loss of identity that this massive modern development will have; in-terms of the character, sense of place and of a tight-nit community spirit that the existing small rural villages have and its residents currently share. There may also be a loss separate village identities, as future unsustainable development is mentioned in Paragraph 4.40 that may fill Tudelely and Capel with houses until they merge with Tonbridge and Paddock Wood. We are also concerned anout the impact on our community in Tonbridge, as increased congestion and air pollution (Items 1.10b and 1.11diii) is likely to impact on the vibrancy of our High Street. As people may potentially avoid the town centre, instead of using it; and move away, due to a loss of sense of place / identity.

ii. Economy - loss of local rural employment and agricultural/equestrian business, with relatively little new retail/service job provided as part of the developments. New retail offerings may struggle to be viable, with other established centres. Congestion from inapt infrastructure provisions will harm the viability of many local firms and limit Tonbridge's sustainable economic growth, even with some new spend. The short-term construction benefit should be given limited weight.

iii. Environment - loss of 600 acres of the countryside, carbon storing vegetation and habitats; with developments generating a disproportionately high carbon emissions, from a poorly thought-out car reliant settlements that are located away from good public transport links. Furthermore, due these settlements being so reliant on private car usage - it is very likely that the current proposals will cause more severe traffic congestion in our town, which has a limited road network that will struggle to meet our own planned development in Tonbridge. A further increase in traffic congestion is also likely to exceed air quality limits, especially on Tonbridge High Street that is in an Air Quality Management Area.

1.12 Additionally, we do not believe that the proposed rural garden villages and this Policy abide by the principles of sustainable development, which is at the heart of the NPPF. The sustainability objectives are set-out in Paragraph 8 (NPPF, 2019), as follows:

a) an economic objective - to help build a strong, ... economy, ...to support growth ... and by identifying and coordinating the provision of infrastructure;

b) a social objective - to support strong, vibrant and healthy communities ...

c) an environmental objective - to contribute to protecting and enhancing our natural, built and historic environment; including ...helping to improve biodiversity ... minimising waste and pollution ... including moving to a low carbon economy.

1.13 In relation to this, there will be negative impacts on all three of these objectives, as partly outlined in the points raised above (items 1.11di to iii). In addition, there will be a reduction in the quality of life and wellbeing of our communities; with the loss of the countryside to enjoy, loss of rural village character and reduced air quality - social impacts.

In conclusion, we do not consider that the Draft Local Plan is sound, in relation to the proposed large garden settlements, with inadequate infrastructure connecting nearby towns. The current proposal for such a substantial loss of the Green Belt and countryside, as part the massive village expansions, is not sustainable development and nor is it consistent with National planning policy. This will cause immense environmental harm, including a heavy reliance on car use with poor public transport links. The justification for building on the Green Belt is unsound, as there are alternative brownfield and non-Green belt sites available.

We are also concerned about the deliverability of the Draft Local Plan, with the local market saturation of nearly 6,000 new houses allocated for two nearby villages within one local area. In light of these concerns and the potentially flawed approach in favouring Green Belt development, over other suitable sites and as no exceptional circumstances exist, alternative sites should be considered. A more sustainable development approach might be to spread the allocation across the Borough, reducing the concentrated development pressures and local market saturation, whilst helping to unlock the greatest amount of brownfield re-development.

 

DLP_1773

CPRE Kent

The Council should ensure that sufficient land is identified to meet “other needs” in the borough. In particular, safeguarding of land for new primary schools within easy walking distance of new development and in the centre of Royal Tunbridge Wells. In doing so, this will limit and reduce the vehicular traffic and air pollution associated with school runs.

 

DLP_1890

Royal Tunbridge Wells Town Forum

Vision and Objectives 2

We consider that Objective 1 should be prefaced by the words “Taking account of all identified constraints on development, to deliver the housing, economic and other needs...” Proper weight should be demonstrated to have been given to the heritage, AONB, Green Belt and infrastructure constraints in the Borough in accordance with provisions of the NPPF and with the objective contained in Objective 6 of protecting the valued heritage, built and natural environments of Royal Tunbridge Wells.

We broadly support the principles outlined in Objectives 2-6 and 8 so far as RTW is concerned.

With regard to Objective 7, it seems contrary to the provisions of the NPPF to make release of Green Belt land an objective. Such proposed release is rather a consequence of imposed government policies and should be stated to be so. The remainder of the Objective 7 wording seems satisfactory.

We propose addition of a further strategic objective  of ensuring Health and Wellbeing in the following terms and for the reasons set out below:

“In co-operation with other relevant agencies, to devise, implement and enforce planning policies favouring the improvement of the health and wellbeing of the borough’s population.”

The health and wellbeing of the population is an unstated but underlying objective of many of the other elements within the Local Plan. This includes such things as a drive to reduce pollution, which has an impact on morbidity and mortality, which in turn also impacts on the need for improved, affordable public transport. Another key fundamental should be ensuring there are sufficient medical practices available, in easily accessible locations, to meet the health needs of a growing town. A case in point is that the proposed Spratsbrook Farm development is in an area where the only GP practice has recently closed.

Developing Tunbridge Wells as a healthier place to live requires an integrated approach to the population’s wellbeing, and must be inclusive for all ages, incomes and abilities. As such, a wellbeing strategy is required, which should focus on the basics to make it easy for people to lead a healthy lifestyle. Encouraging modest exercise, via walking, cycling or access to the many green spaces within and on the edge of town is essential for our younger age groups as is providing primary school places within walking distance for local children. With a growing older population, and increasing numbers of developments aimed at this age group, the design of the urban environment needs also to ensure it positively encourages healthy living for this age group, which, in turn, will also benefit the wider population. Ensuring there are adequate benches available to allow for those engaging in gentle exercise to take a break is a key requirement and deciding on their location should be part of the Local Plan strategy for active travel.

Research from the Soroptimists, updating data on the number of benches in Tunbridge Wells town centre, found a 21% reduction in the number of benches between 2010-2019. This not only means fewer places for people to rest, acting as a disincentive for some people in walking in the more hilly areas, but also means that the need to enhance the provision of benches within the town has been ignored. We would like to see the consideration of benches as a community space within all new developments, e.g. chatting benches back to back to encourage communication with others, information benches signposting to helpful local resources or providing information about the town, and the replacement and re-siting of those that have been lost to areas where they are needed. Tonbridge and Malling District Council has managed to do this in the newly refurbished High Street. It seems to have planned for the future by placing ample benches throughout.

Also required is the provision of toilet facilities within the town, in particular for those that are disabled or elderly. The lack of sufficient public toilets for these groups is a health and wellbeing challenge and actively discourages those that are less mobile from enjoying the benefits of the town. Similarly, the siting of bus stops should take particular account of the needs of the disabled and elderly to be within the minimum practicable reach of important town centre sites. Greater provision of safe pedestrian crossing points is another key requirement.

These “joined up” mutually reinforcing objectives will only be attained if the Local Plan includes a specific overriding objective to improve the health and wellbeing of the population with established targets and requirements to monitor progress.

 

DLP_1932

Ms Nicola Gooch

The Strategic Objectives for the Borough are well throught through and I support them as drafted; however it would be helpful if the borough's economic aspirations had a specific objection of their own. This would place them on an equal footing with the residential led objectives in the plan.

The Borough does contain a large number of out commuters and our office and employment land does require some attention if we are to attract more high quality employers into the borough. It would be nice to see this reflected in the strategic objectives of the plan in addition to the focus on cultural capital and housing affordability.

 

DLP_2027

Terry Everest

A truly sustainable vision would omit item 7 and change 9 to investigate the future possibility of garden settlements in the extreme long term of future development in the borough.

 

DLP_2442

Rosanna Taylor-Smith

2.  Infrastructure - it is vital that all forms of infrastructure are provided to ensure all residents have adequate water, sewerage provision, power, fast broadband, schools, etc.

Southern  Water must not be allowed to simply to pay lip service to adequate sewerage provision in areas such as Hawkhurst and Paddock Wood, where the existing provision is simply not fit for purpose and regularly suffers overflows/spillages, etc.

3.  Electric car chargers must be more readily accessible in public car parks and also in all new developments. It is not fair that as an electric car driver, I should have to pay twice for parking and charging my car.

If active travel includes cycling, more effort should be made to provide cycle paths in areas outside of Tunbridge Wells such as Hawkhurst.

4. I totally support the aim to provide significantly more social housing. However the delivery to date seems disappointing. It is important to provide housing for social rent which is classified as 'affordable' across the TWBC area so that those who grow up in villages such as Hawkhurst, for example, have a chance to stay in their village to work and help make the village sustainable.  The mix of young and more mature residents needs to work in a sustainable way and schools must get enough places for all those wanting to go to their local school which does not always happen.

6. Valued heritage in all its forms must be protected from unnecessary or unsympathetic development and consideration should be given to promote the use of designating some buildings as Assets of Community Value where local communities or villages express an interest in doing so.

All areas of AONB should be afforded greater protection and TWBC planners should work with developers to avoid or minimise new development within the AONB and to minimise the loss of wildlife habitats, woodland, etc.

 

DLP_2830

Helen Parrish

Cross-referenced, detailed, reasons for my Objection:

Strategic Objectives (Section 3) p.32

The release of land from the green belt should not be a strategic objective

 

DLP_2865

Chris Gow

Strategic Objectives

Point 3

The intention to embrace future technology to avoid the consequences of climate change and the energy crisis is foolhardy and it is unlikely the solutions will be delivered in time to avert problems.

Radical policy decisions must be implemented how, and this means drastic change in priorities.

To allow the status quo will result in falling further behind offering effective solutions to the problems facing society today.

Point 7

Green Belt land should be the last possible resort for development. It is an easy option and thus should be protected at all costs.

If the intention is to increase public accessibility, and to protect the openness of remaining Green Belt land then there is no way such land should be released for development.

It is cheap for developers and so pressure from developers must be resisted by clear policy to forbid Green Belt land.

 

DLP_2997

Mr Keith Lagden

Objective 10 is not credible given that TWBC ignores neighbourhood development plans.

Further we would comment that under item 4.40 the draft plan states:-

Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times

being aware that such development is taking place on valued and (in many cases) protected landscapes.

Once again to take the situation proposed in Hawkhurst it is clear that this statement is being utterly ignored. Hawkhurst is in no way sustainable from either an infrastructure or employment point of view.

 

DLP_3167

Kent County Council (Growth, Environment and Transport)

Provision and Delivery of County Council Community Services

Paragraph 9 - KCC supports the objective to establish garden settlements as a model of future delivery, providing they are suitably located with respect to existing infrastructure; upgrades to existing infrastructure are properly assessed for their ability to cope with new development and new supporting infrastructure is appropriate in terms of scale.

Appropriate land requirements to provide self-contained education facilities in particular (including parking and drop off) need to be considered.

Heritage Conservation

The inclusion of Strategic Objective 6 is welcomed - “To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature.”

 

DLP_3680

Lynne Bancroft

Vision and Objectives 2 – it is key that the TWBC Local Plan takes into account any Neighbourhood Development Plans that are still in the drafting/approving process whilst finalising its own plan to ensure that each area has its requirements taken into account

The AONB should be extended around Sissinghurst Castle and its adjacent village to protect the world renown tourist attraction and adjacent historic and sensitive landscapes from being over developed.

I agree that TWBC should work with neighbourhood plan groups to formulate locally-led policies. I believe that they should assist groups to finalise any existing draft neighbourhood development plans before progressing further with the Local Plan to ensure all neighbourhood development plans’ policies are covered by the TWBC Local Plan.

7. – The Local Plan is currently based on land availability not a plan led approach and thus green belt land is not being released. Instead more dispersed developments on AONB and other high value landscape areas in the Eastern of the Borough are shown in the Plan

 

DLP_3721

Capel Parish Council

Capel Parish Council objects to the inclusion of following strategic objectives

  1. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature.
  2. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.
  3. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation.
  4. To establish garden settlements as a model for the future delivery of development in the borough.
  5. To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications

Objective 6

Whilst Objective 6 is a laudable objective, it cannot be achieved by the current Draft Local Plan as too many policies are in direct conflict with it. In fact, these two objectives are clearly in direct conflict with one another – No.6. cannot be achieved alongside No. 7. It should not be an objective of any Draft Local Plan to release land from the Green Belt WHEN APPROPRIATE ALTERNATIVE LAND IS AVAILABLE.

The following policies should be removed from the Draft Local Plan to enable this Objective to be met:

AL / CA 1; AL / CA 2: AL / CA 3 & AL / PW 1; TP 6

Objective 7

Objective 7 should be removed as releasing land from the Green Belt should not be a strategic objective of the dLP.

The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. Stating that you have an objective to release land from the Green Belt (regardless of your judgement that it is appropriate) is contrary to national guidance.

Also, in the Introduction to the dLP at paragraph 1.6, it is stated that “Protection of the Green Belt” is a key key issue/concerns highlighted through the Issues and Options consultation.

There would be no need to remove Green Belt land if the Council had adopted the other options that it had before it; where are plans here to increase public accessibility or protect the openness of the remaining green belt? Unlike Tonbridge and Malling, TWBC has no plans to replace the lost Green Belt suggesting it places a low value on this form of designation. It clearly has also concluded that replacement land (originally mooted to the south and east of Paddock Wood) would not serve the same purpose as the two lost sections which prevent the convergence of settlements between Five Oak Green, Tonbridge and Paddock Wood.

Capel Parish Council strongly urges the council to remove this objective.

Objective 8

Destroying 600 acres of fertile land in Capel, with mature trees and hedgerows in pursuit of the creation of houses will not tackle climate change. Nor will creating a new garden settlement that results in a high level of private car use. The proposal for development in the MGB East Capel and Tudeley scores negatively for climate change in the SA and does not back up this objective or the council’s wider policy on carbon neutrality adopted only a few weeks ago.

The following policies should be removed from the Draft Local Plan to enable this Objective to be met:

AL / CA 1; AL / CA 2: AL / CA 3 & AL / PW 1; TP 6

Objective 9

Where is evidence that garden settlements lead to any positive outcomes for communities anywhere in the UK? Objectives should have clear goals that can be proven to be positive for the residents of Tunbridge Wells Borough and Capel Parish. This may be a passing fashion in planning policy that will disappear, and this approach may lead to future developments outside the LBD’s in the green belt and the AONB which will destroy the rural nature of the borough outside RTW.

Capel Parish Council urges the council to remove this objective.

Objective 10

Tunbridge Wells Borough Council only made attempts to work with Capel Parish Council (in lieu of a neighbourhood planning group) after the strategic sites in Capel Parish had already been determined. Policies AL / CA 1; AL / CA 2: AL / CA 3 & AL / PW 1; TP 6 will have a huge impact on our residents and are NOT locally led. Any future planning decisions in Capel Parish will be dwarfed by the impact of the dLP, making the role of neighbourhood planning peripheral at best.

The following policies should be removed from the Draft Local Plan to enable this Objective to be met:

AL / CA 1; AL / CA 2: AL / CA 3 & AL / PW 1; TP 6

Once the above Policies have been removed from the dLP TWBC will be in a position to meet this objective by working with Capel Parish Council and/or Capel Parish Neighbourhood Plan Groups to formulate policies which can be truly locally-led.

 

DLP_3802

Government Team
Natural England

Section 3: Vision and objectives

Vision and objective 2

Natural England welcomes the vision and objectives guiding this local plan, particularly objective 6 which aims ‘to protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature.’

Natural England, however has concerns that the proposed allocations as currently set out in this local plan do not contribute to protecting the natural environments of the borough, including the AONB, as set out in Objective 6. Natural England’s advice on landscape issues and specific allocations in relation to the High Weald AONB are provided in subsequent sections of this letter.

Natural England also welcomes point 8, which looks to tackle climate change by embracing and adapting to technology such as renewable energy generation. Natural England advises that this statement could be further strengthened to align with paragraph 20 (d) of the NPPF through referencing of mitigation in respect to climate change. It would be beneficial to clarify that development will be managed alongside climate change impacts, particularly in relation to supporting climate change adaptation and allowing species movement. In this regard, the more generic wording of ‘minimise the impact of development’ could be specified and better related to the climate change objective.

 

DLP_3855

Liane & Alan Chambers

Strategic Objective 2 implies that in some instances it would be acceptable for new infrastructure to just maintain the current status of “service” even if that is insufficient. For example, traffic in the Borough is already too high in certain pinch points (Hawkhurst, roads into Tunbridge Wells etc). This objective is not aspirational enough and the objective should be to achieve betterment in all situations, otherwise there is a real risk that the plan may lead to the deterioration of certain services for residents.

Strategic Objective 6 is very welcome, however the plan as set out does not fully deliver against this objective especially for the AoNB.

 

DLP_3900

IDE Planning for Paddock Wood Town Council

OBJECT

The strategic objectives are borough wide; no indication is provided in the list as to their priority; whilst SO2 refers to the delivery of infrastructure, SO9 refers to the garden settlements (plural) and part of STR5(5) should be added to SO9 i.e. to say that new development at these settlements will only be supported if sufficient infrastructure capacity exists, or can be provided in time to serve the development.

An objective should be added related to flood risk i.e. to protect people and property from flooding and to safeguard land from development that is required or likely to be required for current or future flood management.

 

DLP_3935

Mrs June Bell

Comment:

Working with neighbourhood plan groups should be first on the list of strategic objectives recognising that the Localism Act has existed since 2011 and ‘Place shaping’ is primarily about people, yet the involvement of the community in co-creating places is last to be recognised despite recent government reports:

* In order to challenge poor-quality design and ensure that future building is done with consent from the public, the Government set up the Building Better, Building Beautiful Commission which published its interim report in July 2019. The report focuses on the importance of proactive and collaborative community engagement rather than what is often experienced as cynical ‘consultation’. Evidence to the Building Better, Building Beautiful Commission demonstrates concern about the failure to properly engage communities with development, and the breakdown in trust in the planning system that this generates.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf page 79 ‘Collaboration not just consultation’

 

DLP_4219

Tunbridge Wells District Committee Campaign to Protect Rural England

Please see the response from CPRE Kent’s head office (DLP_1773)

 

DLP_4293

Changing Cities for 42 Leisure PLC

The Strategic Objectives fail to recognise the potential to make Royal Tunbridge Wells a more attractive sub-regional destination. This will require an enhanced cultural and visitor offer. Greater emphasis should be placed on the enhancement of heritage assets- not just their protection and of making best use of underutilised sites within the town centre to deliver a range of uses.

 

DLP_4385

Mill Lane and Cramptons Residents Association

Vision and Objectives 2 – Supported- particularly in regard to item 10. “To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications”.

Support:

Policy – STR 2 – “Presumption in favour of sustainable development”

Policy – STR 7 – “Place shaping and design”

Policy -  STR 8 – “Conserving and Enhancing the natural, built , and historic environment”

Policy – STR 9 – “Neighbourhood Plans”

Object:

Policy – STR 10 – “Limits to Built Development Boundaries”

We object to the proposed new LBD boundaries at Sissinghurst. A larger open landscape gap is required between Sissinghurst Village and Wilsley Pound/ Cranbrook Common.

The sites CRS 13 and Part CRS 12 should not be included in the new LBD.

 

DLP_4532

Historic England

Vision and Objectives 2: Strategic Objectives – bullet point 6 should include a requirement to ‘enhance’ as well as protect the heritage of the Borough to better reflect the NPPF to plan positively, as stated above.

 

DLP_4879

Berkeley Strategic Land Ltd

VISION AND OBJECTIVES 2

3.1 Berkeley agree and supports the 10 strategic objectives of the Vision and Objectives 2 and should be applied to each development where applicable.

3.2 If the Tutty’s Farm site was to come forward as an allocation within the Local Plan it would accord with the strategic objectives of the Local Plan.

 

DLP_5010

Stephen Roberts

The strategic plan when read in conjunction with the wider objectives of TWBC (carbon neutral / environmentally protective / sensitive) is an illogical and predatory attack on greenbelt between conurbations in an area ill-suited to the demands that would be placed upon it if the development were to be granted permission and proceed.

If and it is a big if, there is a need for the amount of housing quoted by TWBC (this is contested under the relevant provisions of the National Planning requirement) then it should be a burden shared equally across the borough (for example, create a grid with a thousand squares and put 5 houses in each) – but I would argue, better to properly calculate the need and contest whether the South East of England is the right place to increase the housing burden at all – geographically the South East of England is approximately a 12th of the land mass of the country, housing a third of the UK population  - adding to this factual population burden is unsustainable in the South East in general and in our precious remaining green belt in particular; better to seek to even out the population across the country and increase the relevance and productivity of the more sparsely populated areas of the country than denude what is left of the south east of England’s green space. This is where the Borough should be pushing back on Central Government.

The plan does not take into account the cost of these proposals in environmental or infrastructural terms  - there are no suitable roads, schools, GPs, Gas electrical or water supplies for in particular area 446 – I should like to see how this infrastructural development is proposed to be costed, funded and completed AHEAD of the proposed housing build – I don’t believe it could be supplied on the current criteria for such requirements in the green belt and to rely on the existing infrastructure is absolutely unsustainable.

There was no suitably robust consideration of more suitable development areas outside of the paltry small scale infill development approach outlined in the plan – I vehemently maintain that the Southeast should be spared the brunt of national at scale housebuilding because of the obvious current imbalance in population density here. It is also the case that the current calculation is based on outmoded and outdated information (it also doesn’t consider the potential for population decrease in Brexit), but if needs must, then TWBC should consider the areas already desecrated through the A21 corridor extension and look to the tracts of land adjacent to and surrounding the TW Industrial Estate at Longfield Road and Great Lodge (TN2) where the trees have already been destroyed, the protected species moved and the infrastructure, broadly, is in place.

 

DLP_5141

Terence Knights

The Proposed Use of Green Belt Land for Housing

There seems to be a total disregard for the preservation of green belt areas.  These areas give local villages “breathing space” and maintain the local community spirit and outlook.

The requirement of only releasing green belt areas to meet exceptional circumstances seems to be being totally ignored.

The Local Plan has a Strategic Objective to “release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.”

This implies that more green belt will become accessible to local people to use and enjoy, however, the proposed use of the majority of green belt areas within the proposed Local Plan is for housing development.

Continually releasing green belt areas for housing around small villages will undoubtedly lead to villages being linked through progressive development to become towns and then further development creating garden cities, as is the proposed case for the villages of Borough Green and Ightham.

 

DLP_5272

Tunbridge Wells Friends of the Earth

With respect to the 10 “Strategic Objectives” you set out we like to comment as follows:

  • Travel:

    To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology.

Increasing support for infrastructure for private vehicle use directly conflicts with your intention to “prioritise” active travel. The easier private car travel is made—whilst simultaneously not creating safe alternatives in the form of segregated, safe cycle paths, linked up in an extensive network of cycle paths—the less likely it is people will choose active travel. Though we have seen instances in the LDP where you say you want to implement active travel—it is by no means treated as a ‘priority’. Quite the opposite: private car use is still best catered for.

  • Green Belt:

    To strategically release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.

We strongly object to releasing land for the Green Belt for new housing development.

We also feel it contradicts your following other two objectives:

  • The borough's distinctive environment:

    To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature.
  • Climate Change

    To tackle climate change and minimise the impact of development on communities, the economy and the environment with carefully considered design and by embracing technology such as renewable energy generation.

You cannot tackle climate change by reducing green land. We also want to emphasise again (as we have in our comments on the LDP) that Biomass technology does not provide clean renewable energy generation and all recommendations for biomass burning should be scrapped from the LDP.

 

DLP_5564

Mr Paul Hewitt

Vision and Objectives 2 1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high-quality development.

A developer who has an option on land in the Parish of Cranbrook and Sissinghurst has already stated they will not build towards the aspirational qualities determined by the Parish Council, instead they will build to the much lesser quality determined by TWBC. It is therefore imperative that TWBC raises its standards towards that of Norwich, for example, and aspires to Passivhaus and the race to the bottom of low quality development is halted.

Vision and Objectives 2 To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough.

Building more houses does not make them more affordable. Already many workers in the Parish of Cranbrook and Sissinghurst have to commute from the cheaper areas of the Borough and from outside the Borough, to work

There is a perception that ‘Affordable’ means just that, and this misconception is a reason that there are not many more objections to the scale of housing

Vision and Objectives 2) 8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation

A large-scale developer working on land already allocated in Cranbrook stated that they would not be using renewables such as solar energy because this is not economically viable. Or indeed, triple glazing and other basic measures of sustainability. This has not been pursued by the planning department. I have no confidence that the planning department will enforce this aspect of building codes.

There is no mention of an aspiration for local sourcing of all aspects of building materials, including green planting.

Vision and Objectives 1 All developments will be of high quality design, having responded to the distinctive and particular character of their locations: in some instances the development will have taken place within valued and protected landscapes, and this will be recognised in the quality of the design of the development, the protection and enhancement of the exceptional quality of the built, natural, and historic environment, and the provision and protection of landscape features and green spaces. Green, grey, Consultation period: 20 September to 1 November 2019 Tunbridge Wells Borough Local Plan 31 Draft Local Plan (Regulation 18) Consultation Draft and blue infrastructure will be an integral and defining element in the design and layout of new developments

The above statement has not been evidenced by building design such as that at Brick Kiln Farm, Cranbrook, where the developer has paid no attention to the rear elevations of the houses (which residents will see every time they are in their gardens) as it does not ‘affect the street scene’

In fact, the first set of proposals had every front door on the entire site, identical which was pointed out by local residents, not the planning department.

This underlines the fact that development, particularly large-scale development is taking place in the Borough with very little attention to detail.

 

DLP_5614

Mrs Jacqueline Hewitt

Vision and Objectives 2 1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high-quality development.

A developer who has an option on land in the Parish of Cranbrook and Sissinghurst has already stated they will not build towards the aspirational qualities determined by the Parish Council, instead they will build to the much lesser quality determined by TWBC. It is therefore imperative that TWBC raises its standards towards that of Norwich, for example, and aspires to Passivhaus and the race to the bottom of low quality development is halted.

Vision and Objectives 2 To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough.

Building more houses does not make them more affordable. Already many workers in the Parish of Cranbrook and Sissinghurst have to commute from the cheaper areas of the Borough and from outside the Borough, to work

There is a perception that ‘Affordable’ means just that, and this misconception is a reason that there are not many more objections to the scale of housing

Vision and Objectives 2) 8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation

A large-scale developer working on land already allocated in Cranbrook stated that they would not be using renewables such as solar energy because this is not economically viable. Or indeed, triple glazing and other basic measures of sustainability. This has not been pursued by the planning department. I have no confidence that the planning department will enforce this aspect of building codes.

There is no mention of an aspiration for local sourcing of all aspects of building materials, including green planting.

Vision and Objectives 1 All developments will be of high quality design, having responded to the distinctive and particular character of their locations: in some instances the development will have taken place within valued and protected landscapes, and this will be recognised in the quality of the design of the development, the protection and enhancement of the exceptional quality of the built, natural, and historic environment, and the provision and protection of landscape features and green spaces. Green, grey, Consultation period: 20 September to 1 November 2019 Tunbridge Wells Borough Local Plan 31 Draft Local Plan (Regulation 18) Consultation Draft and blue infrastructure will be an integral and defining element in the design and layout of new developments

The above statement has not been evidenced by building design such as that at Brick Kiln Farm, Cranbrook, where the developer has paid no attention to the rear elevations of the houses (which residents will see every time they are in their gardens) as it does not ‘affect the street scene’

In fact, the first set of proposals had every front door on the entire site, identical which was pointed out by local residents, not the planning department.

This underlines the fact that development, particularly large-scale development is taking place in the Borough with very little attention to detail.

 

DLP_5884

Ms Sally Moesgaard-Kjeldsen

Whoever is proposing all this building hasn't thought about the consequences at all. We are having a new town hall etc being built with theatre

etc. We can't afford that. More electricity, gas, sewerage, cars, polution. Health first!

 

DLP_5972

Tim Wye

In general I believe there is too much dispersed development in the vision. Much better, in my opinion, to focus large growth in the existing urban areas like Tunbridge Wells and Southborough with limited growth in the rural areas in order to protect that special rural quality and way of lif, as well as making use of the existing choice of transport links (road, rail, etc) in the urban areas. The more development there is in rural areas the more infrastructure is required, more roads, more street lights more urban spill and the countryside will be damaged forever. Contain the urbanisation to existing towns and protect the villages.

 

DLP_5997

Pro Vision for Cooper Estates Strategic Land

The ‘Vision and Objectives 2’ of the draft Local Plan (paragraph 3.4) contains a ‘housing’ strategic objective (bullet point 1) that seeks to only (is limited to) ‘deliver the housing… needs identified for the borough by the end of the plan period through… sustainable, plan led… development’. 

It does not mention at all (let alone give any emphasis/priority to) the need for housing for older people.

For the reasons explained in our comments on Section Two, on Paragraph 4.7 and Policies H9 and STR1 the Council’s approach to meeting the need for care and accommodation of older persons via this Strategic Objective will not ‘realise the Vision’ or ‘address the key issues’ or ‘specific challenges’ that is otherwise referred to by the Council in Paragraph 3.3.

The draft Local Plan is therefore materially inconsistent with NPPF paragraph 59 as it will not adequately address the needs of groups with specific housing requirements (such as older persons) and so is not NPPF paragraph 15 ‘genuinely plan-led’ in this regard. It will also therefore not ensure that the ‘type and tenure of housing for different groups in the community…’, such as older persons will be adequately ‘…reflected in planning policies (including… older people…)’ as NPPF paragraph 61 requires, including both strategic and development management policies.

This is also inconsistent with the Council’s previous commitment and very clear ‘steer’/expectation from the Inspector who examined the Council’s Site Allocation Local Plan in 2015 (and reported on in 2016). CESL objected to that plan including for essentially the same or similar reasons and concerns as are evident now in the Councils draft Local Plan. Rather than address the (then) already evidenced need for C2 development the Inspector agreed with the Council that to do so was not a purpose of the SALP (which was concerned with delivering/meeting the Core Strategy housing requirement/need).

However, on the issue of C2 need the Inspector gave significant weight to the position of the Council that “new evidence has arisen and new policies have been articulated which suggest additional needs and new directions of travel, which are proposed to be met by a replacement Local Plan (rLP) which is under active preparation” (Inspector’s report paragraph 14). The Council has reneged on this commitment and these C2 needs are not met by the draft Local Plan.

 

DLP_6209

Pamela Smart

Vision and Objectives 2 Support both 6 and 10

6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature

Cranbrook, historically the centre of the wool trade in the borough, it is the central settlement in this area; it is an historic town with many period and listed buildings, any large scale development would change this character to its detriment, as would building further out into the countryside into the rural parts of the AONB. There is no evidence that any large scale development can achieve any net gains for nature, whether it be the increased number of cars using rural roads to get to and from work and the encroachment onto farm land to build the proposed large scale housing projects.

10 To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications

It is unclear whether TWBC have taken into account the local opposition to large scale development within an AONB nor indeed have listened to the local parish councils. There is no evidence that TWBC have taken advice on large scale development within and AONB from Natural England and have clearly ignored the AONB management plan 2019-2024 adopted by TWBC where objective S2 for settlement is to ‘protect the historic pattern and character of settlement in order to protect the distinctive character of towns, villages, hamlets and farmsteads and to maintain the hinterland and other relationships, including separation between such settlements’.

 

DLP_6300

Tunbridge Wells Constituency Labour Party

Comments above on the Vision also applicable here too.

Tunbridge Wells Labour Party recognises the challenges in the Local Plan to deliver on ambitious housing targets to 2036. Development should be focused primarily on brownfield sites with undeveloped green sites safeguarded for future generations to enjoy as countryside, parks and open space.

However we recognise that if we are going to start to solve the local housing crisis then this is best achieved by planned development of new communities with appropriate new infrastructure rather than through piecemeal smaller developments. The latter often comes with limited new infrastructure and insufficient developer contributions to mitigate pressure on existing services. With this in mind TW Labour broadly supports the principles contained in the Local Plan to deliver new development subject to commitments on providing affordable housing including a significant proportion for social rent (as outlined in the Local Plan) and new infrastructure being met.

We welcome that the Local Plan will resolve the situation where the Council has failed to maintain 5 years worth of land. Developers have been winning appeals because the Borough Council has lacked up to date strategic development policies and plans.  We welcome that this situation will be resolved so development can be better managed and directed to appropriate sites.

 

DLP_6420

Hawkhurst Parish Council

p.32: Strategic Objective 10 of 10 is Neighbourhood Planning

We are concerned that of the ten objectives listed, neighbourhood planning is the last in the list. Of course, in a top ten list, something will always appear at the end, but it reveals a lack of support for neighbourhood planning by the TWBC team.

 

DLP_6608

AAH Planning for Future Habitat Ltd

Strategic Objectives

For the vision to be achieved, the document then sets out several strategic objectives.

The importance of housing delivery is recognised within this section and our Client is generally supportive of these. However, it is considered that the objectives should seek to boost significantly the supply of all housing in addition to affordable housing and, in particular, set a specific aim of enabling the development of at least 13,560 new homes in order to meet the housing needs and aspirations of those living and working in the Borough.

It is also considered the objectives should seek to provide a range of housing products providing types and tenures of homes suitable for all people and have a portfolio of sites of different sizes, different housing products and delivery rates for the short, medium and long term.

This would ensure that the Plan is consistent with national policy contained the Framework. Without a consistent and robust approach, the objectives can be regarded as unsound for being ineffective and inconsistent with national policy as the Local Plan will be in direct conflict with the clear aspirations of national policy and will undermine the delivery of the overarching vision.

[TWBC: see full representation and site plan attached].

[TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627].

 

DLP_6668

Gladman

4.3 Objectives

4.3.1 Gladman is broadly supportive of the 10 Strategic Objectives as cited in the Local Plan subject to the following amendments:

* The words “in full” should be referenced to the delivery of identified development needs in the plan period as set out in Objective 1;

* The words “through a step change in housing delivery” should be added to Objective 4 as a response to redressing disparity between house prices and income; and

* A new objective should be inserted which seeks to secure new homes of the right size, type and tenure to meet the diverse housing needs of the community and improve access to housing.

[TWBC: see full representation].

[TWBC: see also Comment Nos. DLP_6656-6695]

 

DLP_6785

G M Whitehead

  1. Infrastructure needs to be in place before the development. There is no additional health provision in Sissinghurst despite the addition of approx. 100 more houses and the 3 surgeries in Cranbrook are expected to cope with these plus the 800 of Cranbrook itself.
  1. This is very laudable but will depend on the Council’s willingness to stand up to developers who want to make more money building ‘executive’ houses. What we need are some well-designed terraces and/or low-rise flats as well as some property for rent.
  1. Again, very laudable but you are already proposing to encroach on parts of the HWAONB and, in Cranbrook, to go right down to the Crane Brook. How is that going to be good news for nature.
  1. Yes please, let us have locally-led policies driving planning decisions. Unfortunately, this plan is not locally-led. If it were we would not be expecting the number of houses inappropriately encroaching on the HWAONB.
 

DLP_6971

Mrs Beryl Bancroft

There are no plans to improve transport links to new employment areas from the Cranbrook area and surrounding villages. The Borough has extended the area to build here without consultation. As there is no local employment planned in this area, more cars will be used to get to new employment areas which will affect climate change.

The Borough of TW has not fully considered the local plan for Cranbrook and Sissinghurst.

 

DLP_6974

Mrs Beryl Bancroft

The objectives for Cranbrook and Sissinghurst are unmanageable. Too many houses are planned compared to Tunbridge Wells Centre which has employment and plans for increased employment and no easy transport system from Cranbrook and Sissinghurst to get to these opportunities unless by car which causes environmental problems. No thought has been given to the ageing population who need good transport and more pavements rather than cycling paths.

 

DLP_6981

Nigel Tubman

There is nothing strategic about these objectives. It is focused on the availability of sites which is hardly the right way of setting strategy.

The Objectives focus on Tunbridge Wells and not the borough as a whole. What evidence is there that people will travel from the eastern parts of the borough to Tunbridge Wells bearing in mind the lack of public transport and congestion on the roads and difficulty of parking in the town?

 

DLP_7342

Campaign to Protect Hawkhurst Village

In respect of Paragraph 3, the Strategic Objectives should acknowledge that several parts of the Borough currently suffer from severe congestion on the highway network which has a material impact on the lives of residents.  It should be a clear strategic objective to seek to alleviate the existing congestion where possible and achieve “betterment” – as per Paragraph 2.

Secondly it is notable that whilst the Green Belt has a specific standalone Strategic Objective in paragraph 6, the AONB is incorporated within a wider catch-all objective including protection of heritage and built environment and biodiversity matters.  The effect of this approach is to dilute the importance of AONB preservation.

The AONB represents 70% of the Borough – a far larger area than the Green Belt that has its own specific Strategic Objective.

The AONB should be attributed the highest degree of protection in accordance with national policy.

In order to demonstrate that the Council understands and places sufficient emphasis on its statutory duty, the DLP should include a specific standalone Strategic Objective to conserve and enhance the AONB.

 

DLP_7360

Wealden District Council

The strategic objectives set out under page 32 of the draft Tunbridge Wells Local Plan includes the provision of housing, affordable housing and employment land, amongst other needs identified in the Borough to be delivered by the end of the Plan period. Other strategic objectives relate to the delivery of infrastructure and transport schemes, tackling climate change, the protection of the High Weald AONB, the release of appropriate Green Belt land for development in a plan-led system, the formation of garden settlements and joint working with neighbourhood plan groups. It is considered that those strategic objectives are relatively brief and could be expanded upon to include details as to how those spatial objectives are expected to be achieved, even if this is just included within supporting text.

As discussed above, it appears that the vision does not include the planned release of appropriate Green Belt land, but this is included as a strategic objective. Conversely, the vision confirms that rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced, but rural development and enterprise is not specifically identified within the strategic objectives. Given the above, it is considered that the proposed vision and the strategic objectives could be better aligned to ensure that they correspond with one another in a coherent fashion.

 

DLP_7472

Catherine Pearse

Objective 10 is not credible given that TWBC ignores neighbourhood development plans.

Further we would comment that under item 4.40 the draft plan states:-

Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes.

Once again to take the situation proposed in Hawkhurst it is clear that this statement is being utterly ignored. Hawkhurst is in no way sustainable from either an infrastructure or employment point of view.

 

DLP_7502

Sarah Parrish

Why is releasing land from the green belt a strategic objective? This should not be so.

 

DLP_7568

Mark Beales

4.44 To achieve the strategic objectives of this Draft Local Plan, it is essential for development to be planned in a coordinated way and, for some of the strategic sites and locations, it will be appropriate to deliver this through a comprehensive masterplanning process

When Brick Kiln Farm in Cranbrook was allocated, the developer was told to take a masterplanning approach.This has not happened. I have no confidence that this approach will be enforced by the Planning Department

4.18 The ENS (Economic Needs Study) recommended that the Council should allocate sites to accommodate at least 14 hectares of new employment land (taking into account any residual capacity of existing employment allocations) to 2035 in order to support the creation of new employment opportunities alongside the provision of new housing, helping to reduce out-commuting from the borough over the plan period. This target will be reviewed as part of the preparation of the Regulation 19 Pre-submission version of the Local Plan There are no new employment opportunities planned alongside the provision of new housing in Cranbrook and Sissinghurst. The only employment created, will be temporary, and only during construction of the allocated sites

 

DLP_7644

John Gibson

The build qualities proposed by the local Parish Council are higher than those set by TWBC. It is imperative that TWBC raises its standards towards that of Norwich for example and aspires to PassivHaus.

Supported.

in particular regarding Item 10 – “To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications”.

 

DLP_7670

Mr J Boxall

Vision and Objectives 2 – it is key that the TWBC Local Plan  takes into account any Neighbourhood Development Plans that are still in the drafting/approving process whilst finalising its own plan to ensure that each area has its requirements taken into account

The AONB should be extended around Sissinghurst Castle and its adjacent village to protect the world renown tourist attraction and adjacent historic and sensitive landscapes from being over developed.

I agree that TWBC should work with neighbourhood plan groups to formulate locally-led policies.  I believe that they should assist groups to finalise any existing draft neighbourhood development plans before progressing further with the Local Plan to ensure all neighbourhood development plans’ policies are covered by the TWBC Local Plan.

7. – The Local Plan is currently based on land availability not a plan led approach and thus green belt land is not being released. Instead more dispersed developments on AONB and other high value landscape areas in the Eastern of the Borough are shown in the Plan

 

DLP_7691

Keith Peirce

Objective 10 is not credible given that TWBC ignores neighbourhood development plans.

Further we would comment that under item 4.40 the draft plan states:-

Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes. 

Once again to take the situation proposed in Hawkhurst it is clear that this statement is being utterly ignored. Hawkhurst is in no way sustainable from either an infrastructure or employment point of view.

 

DLP_7735

Peter Smart

Vision and Objectives 2 Support both 6 and 10

6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature

Cranbrook, historically the centre of the wool trade in the borough, it is the central settlement in this area; it is an historic town with many period and listed buildings, any large scale development would change this character to its detriment, as would building further out into the countryside into the rural parts of the AONB. There is no evidence that any large scale development can achieve any net gains for nature, whether it be the increased number of cars using rural roads to get to and from work and the encroachment onto farm land to build the proposed large scale housing projects.

10 To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications

It is unclear whether TWBC have taken into account the local opposition to large scale development within an AONB nor indeed have listened to the local parish councils. There is no evidence that TWBC have taken advice on large scale development within an AONB from Natural England and have clearly ignored the AONB management plan 2019-2024 adopted by TWBC where objective S2 for settlement is to ‘protect the historic pattern and character of settlement in order to protect the distinctive character of towns, villages, hamlets and farmsteads and to maintain the hinterland and other relationships, including separation between such settlements’.

 

DLP_7787

Annie Hopper

4.44 To achieve the strategic objectives of this Draft Local Plan, it is essential for development to be planned in a coordinated way and, for some of the strategic sites and locations, it will be appropriate to deliver this through a comprehensive masterplanning process

This was a condition ‘imposed ‘on the developers of Brick Kiln Farm and those of the adjacent site, Cornhall Farm (Site 292) allocated in the current Local Plan 2016. To date this ‘Masterplan’ has not been produced.

I have no confidence that this approach will be enforced by the Planning Department

4.18 The ENS (Economic Needs Study) recommended that the Council should allocate sites to accommodate at least 14 hectares of new employment land (taking into account any residual capacity of existing employment allocations) to 2035 in order to support the creation of new employment opportunities alongside the provision of new housing, helping to reduce out-commuting from the borough over the plan period. This target will be reviewed as part of the preparation of the Regulation 19 Pre-submission version of the Local Plan

Where are the new employment opportunities alongside the provision of new housing in Cranbrook and Sissinghurst? The only employment created, will be temporary, and only during construction of the allocated sites.

 

DLP_7817

Robert Austen

Vision and Objectives 2 Support both 6 and 10 

6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature

Cranbrook, historically the centre of the wool trade in the borough, it is the central settlement in this area; it is an historic town with many period and listed buildings, any large scale development would change this character to its detriment, as would building further out into the countryside into the rural parts of the AONB. There is no evidence that any large scale development can achieve any net gains for nature, whether it be the increased number of cars using rural roads to get to and from work and the encroachment onto farm land to build the proposed large scale housing projects.

10 To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications

It is unclear whether TWBC have taken into account the local opposition to large scale development within an AONB nor indeed have listened to the local parish councils. There is no evidence that TWBC have taken advice on large scale development within an AONB from Natural England and have clearly ignored the AONB management plan 2019-2024 adopted by TWBC where objective S2 for settlement is to ‘protect the historic pattern and character of settlement in order to protect the distinctive character of towns, villages, hamlets and farmsteads and to maintain the hinterland and other relationships, including separation between such settlements’.

 

DLP_7823

Anneke Turner

Vision and Objectives 2 Support both 6 and 10 

6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature

Cranbrook, historically the centre of the wool trade in the borough, it is the central settlement in this area; it is an historic town with many period and listed buildings, any large scale development would change this character to its detriment, as would building further out into the countryside into the rural parts of the AONB. There is no evidence that any large scale development can achieve any net gains for nature, whether it be the increased number of cars using rural roads to get to and from work and the encroachment onto farm land to build the proposed large scale housing projects.

10 To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications

It is unclear whether TWBC have taken into account the local opposition to large scale development within an AONB nor indeed have listened to the local parish councils. There is no evidence that TWBC have taken advice on large scale development within an AONB from Natural England and have clearly ignored the AONB management plan 2019-2024 adopted by TWBC where objective S2 for settlement is to ‘protect the historic pattern and character of settlement in order to protect the distinctive character of towns, villages, hamlets and farmsteads and to maintain the hinterland and other relationships, including separation between such settlements’.

 

DLP_7893

Barry Chamberlain

As referenced above [TWBC: see Comment No. DLP_7892 Policy STR 1], we support the overall growth strategy and objectives of the emerging Local Plan and the spatial approach to directing growth across the borough. We consider the plan however, given the calculations suggesting a greater housing need and the structure in setting out a quantum range for housing allocations requires a further review to ensure appropriate delivery and a cushion.

 

DLP_7965
DLP_7996

Sharon Pickles
Richard Pickles

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

A developer who has an option on land in the Parish of Cranbrook and Sissinghurst has already stated they will not build towards the aspirational qualities determined by the Parish Council, instead they will build to the much lesser quality determined by TWBC. It is therefore imperative that TWBC raises its standards towards that of Norwich, for example, and aspires to PassivHaus and the race to the bottom of low quality development is halted

 

DLP_8026

Penny Ansell

Objective 10 is not credible given that TWBC ignores neighbourhood development plans. Further we would comment that under item 4.40 the draft plan states:-

Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes.

Once again to take the situation proposed in Hawkhurst it is clear that this statement is being utterly ignored. Hawkhurst is in no way sustainable from either an infrastructure or employment point of view.

 

DLP_8058

Sophie Foster

It is impossible to comment helpfully on Strategic Objective 9 without a definition or any explanation of “garden settlement”.

 

DLP_8157

Myriam Ruelle

Strategic objectives: Strongly object

Building on Green Belt MUST NOT be an objective, it goes completely against NPPF guidelines.  Please REMOVE objective 7.

 

DLP_8331

Andrew Richards

INTRODUCTION

I am not a resident of Tunbridge Wells Borough, but I live near to the Borough boundary just outside Tonbridge.

I visit the Borough regularly and enjoy the benefits of its countryside, notably the Green Belt and the Areas of Outstanding Natural Beauty, which need to be preserved in line with National Planning Policy.  I also drive around Tonbridge regularly and am shocked at the impact the proposals in your draft Local Plan (LP) would have on Tonbridge and its environs.

The LP is vast and complex and has clearly consumed a significant amount of effort; I congratulate the officers for their diligence in seeking to balance the various competing demands of policy, legislation and local constraints.  As a private individual I do not have similar resources or expertise; I have therefore confined my comments to a small number of topics.  This is not to say I endorse the remainder of the LP and its associated material; I am aware of some of the concerns raised by others and support many of them.

Notwithstanding the level of effort that has gone into the LP, I’m afraid my overall assessment is that the Borough has fallen short of the diligence needed.  Sadly, it seems to have taken the easy way out of its obligations in a number of areas.  It has:

  • Failed to challenge the standard method for determining the housing need;
  • Failed to widen its search for housing sites beyond those yielded in the voluntary Call for Sites;
  • Analysed poorly those comments raised against the Issues and Options paper;
  • Failed in its Duty to Co-operate with Tonbridge and Malling Borough Council (TMBC);
  • Been selective in its application of the ‘exceptional’ burden of proof;
  • Opted for the easy route of selecting sites for large scale development owned by a single or small number of landowners;
  • Failed to take account of commuting habits and the pressures resulting from its proposals on rail services, notably but not exclusively in Tonbridge;
  • Failed in its duty of care to students by proposing the establishment of a new school spanning a busy railway line;
  • Failed to provide housing suitable for an increasingly aging population

I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation and should repeat the exercise, having first addressed some of the fundamental concerns raised.  I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation.

My comments are in relation to a number of documents identified below.

Vision and Objectives 2 – Strategic Objectives 7 – Green Belt

30. I object to objective 7, “To release appropriate land from the Green Belt”.

31. Planning policy requires that:

a. “Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified” (NPPF 136)

b. “Green Belt boundaries [should have an] intended permanence in the long term, so they can endure beyond the plan period” (NPPF 136).

c. “Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development” (NPPF 137).

d. “Where . . . it is necessary to release Green Belt land for development, plans should give first consideration to land which . . . is well-served by public transport” (NPPF 138).

e. “Plans should . . . e) be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period” (NPPF 139)

f. “Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances” (NPPF 143)

32. The Minister for Housing and Planning added:

a. “The Government are committed to the strong protection and enhancement of green-belt land. Within the green belt, most new building is inappropriate and should be refused planning permission except in very special circumstances”. (Hansard, 18 Jul 16)

33. Whereas:

a. TWBC seems content to justify its encroachment onto Green Belt as an “exceptional” circumstance, but is unwilling to exercise the same justification that would have allowed it to push back on the use of the standard method for assessed housing needs, for instance:

(1) “strategic policies should be informed by a local housing need assessment, conducted using the standard method . . . unless exceptional circumstances justify an alternative approach” (NPPF 60)

A case of one rule if you want to encroach on Green Belt, but another when determining the local housing need.

b. The LP at para 4.40 specifically identifies the intent to continue to expand into Green Belt – “A new garden settlement at Tudeley Village within Capel parish to deliver development within this plan period and into the next plan period”, which directly contravenes NPPF 139 above.

c. TWBC has failed to demonstrate the “exceptional” circumstances required by policy, which require it to have “examined fully all other reasonable options”. TWBC has examined only settlement options presented to it through its Call for Sites, a reactive approach, and has not adopted a more pro-active approach of searching out sites suitable for garden settlements outside the Green Belt that could be acquired through compulsory purchase or other means

d. TWBC rejected a planning application ref 18/01767 from the Poacher pub on Hartlake Road on the grounds it would intrude on Green Belt, noting as a reason for the refusal:

(1) “The proposal would constitute inappropriate development within the Metropolitan Green Belt, which by definition is harmful to its openness. There is insufficient evidence of the necessary 'very special circumstances' to overcome this harm. The proposal is thus contrary to . . . and the National Planning Policy Framework 2018” (rejection letter dated 31 Jul 18)

34. It is worth noting that the boundaries of the Green Belt in TWBC have remained materially unchanged since 1997, so the encroachment onto Green Belt proposed in the LP will be the first for 20 years. The diagram below shows the 1997 and the 2017 extents:

Conclusion

39. In conclusion, to reiterate the point made in opening, I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation. It should therefore repeat the exercise, having first addressed some of the fundamental concerns raised.

40. I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation.

[TWBC: See  full representation]

 

DLP_8339

Joe Matthews

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

To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development.

A developer who has an option on land in the Parish of Cranbrook and Sissinghurst has already stated they will not build towards the aspirational qualities determined by the Parish Council, instead they will build to the much lesser quality determined by TWBC. It is therefore imperative that TWBC raises its standards towards that of Norwich, for example, and aspires to PassivHaus and the race to the bottom of low quality development is halted

 

DLP_8329

Pam Wileman

TWBC: Comment was submitted on 19/11/19 after close of consultation (on 15/11/19).

Objective 10 is not credible given that TWBC ignores neighbourhood development plans.

Further we would comment that under item 4.40 the draft plan states:-

Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes.

Once again to take the situation proposed in Hawkhurst it is clear that this statement is being utterly ignored.  Hawkhurst is in no way sustainable from either an infrastructure or employment point of view.